HomeMy WebLinkAbout09-24-2025 Steering Committee Complete Agenda Packet
SPECIAL NOTICE
PUBLIC ATTENDANCE & PARTICIPATION AT PUBLIC MEETINGS
Steering Committee Meeting
Wednesday, September 24, 2025
5:00 p.m.
Your participation is always welcome. OC San offers several ways in which to interact during meetings. You will find information as to these opportunities below. IN-PERSON MEETING ATTENDANCE
You may attend the meeting in-person at the following location: Orange County Sanitation District Headquarters
18480 Bandilier Circle
Fountain Valley, CA 92708 ONLINE MEETING PARTICIPATION
You may join the meeting live via Teams on your computer or similar device or web browser by
using the link below: Join the meeting now
We suggest testing joining a Teams meeting on your device prior to the commencement of the
meeting. For recommendations, general guidance on using Teams, and instructions on joining a Teams meeting, please click here. Please mute yourself upon entry to the meeting. Please raise your hand if you wish to speak
during the public comment section of the meeting. The Clerk of the Board will call upon you by
using the name you joined with. Meeting attendees are not provided the ability to make a presentation during the meeting. Please contact the Clerk of the Board at least 48 hours prior to the meeting if you wish to present any
items. Additionally, camera feeds may be controlled by the meeting moderator to avoid
inappropriate content.
HOW TO PARTICIPATE IN THE MEETING BY TELEPHONE To join the meeting from your phone: Dial (213) 279-1455
When prompted, enter the Phone Conference ID: 648 195 800#
All meeting participants may be muted during the meeting to alleviate background noise. If you are muted, please use *6 to unmute. You may also mute yourself on your device.
Please raise your hand to speak by using *5, during the public comment section of the meeting.
The Clerk of the Board will call upon you by using the last 4 digits of your phone number as identification. NOTE: All attendees will be disconnected from the meeting at the beginning of Closed
Session. If you would like to return to the Open Session portion of the meeting, please login or dial-in to the Teams meeting again and wait in the Lobby for admittance. WATCH THE MEETING ONLINE
The meeting will be available for online viewing at:
https://ocsd.legistar.com/Calendar.aspx SUBMIT A COMMENT
You may submit your comments and questions in writing for consideration in advance of the meeting by using the eComment feature available online at: https://ocsd.legistar.com/Calendar.aspx or sending them to OCSanClerk@ocsan.gov with the subject line “PUBLIC COMMENT ITEM # (insert the item number relevant to your comment)”
or “PUBLIC COMMENT NON-AGENDA ITEM”.
You may also submit comments and questions for consideration during the meeting by using the eComment feature available online at: https://ocsd.legistar.com/Calendar.aspx. The eComment feature will be available for the duration of the meeting.
All written public comments will be provided to the legislative body and may be read into the record or compiled as part of the record.
For any questions and/or concerns, please contact the Clerk of the Board’s office at
714-593-7433. Thank you for your interest in OC San!
September 16, 2025 NOTICE OF REGULAR MEETING
STEERING COMMITTEE ORANGE COUNTY SANITATION DISTRICT
Wednesday, September 24, 2025 – 5:00 P.M. Headquarters 18480 Bandilier Circle
Fountain Valley, CA 92708
ACCESSIBILITY FOR THE GENERAL PUBLIC Your participation is always welcome. Specific information as to how to participate in this meeting is detailed on the Special Notice attached to this agenda. In general, OC San offers several ways in which to interact during this meeting: you may participate in person, join the
meeting live via Teams on your computer or similar device or web browser, join the meeting live via telephone, view the meeting online, and/or submit comments for consideration before or during the meeting.
The Regular Meeting of the Steering Committee of the Orange County
Sanitation District will be held at the above location and in the manner indicated on Wednesday, September 24, 2025 at 5:00 p.m.
STEERING COMMITTEE & BOARD MEETING DATES
October 22, 2025
November 19, 2025 *
December 17, 2025 *
January 28, 2026
February 25, 2026
March 25, 2026
April 22, 2026
May 27, 2026
June 24, 2026
July 22, 2026
August 26, 2026
September 23, 2026
* Meeting will be held on the third Wednesday of the month
ROLL CALL STEERING COMMITTEE
Meeting Date: September 24, 2025 Time: 5:00 p.m.
COMMITTEE MEMBERS (7) Ryan Gallagher, Board Chair
Jon Dumitru, Board Vice-Chair
Pat Burns, Operations Committee Chair Christine Marick, Administration Committee Chair
Glenn Grandis, Member-At-Large
Chad Wanke, Member-At-Large
John Withers, Member-At-Large
OTHERS Scott Smith, General Counsel
STAFF
Rob Thompson, General Manager
Lorenzo Tyner, Assistant General Manager
Jennifer Cabral, Director of Communications Mike Dorman, Director of Engineering
Laura Maravilla, Director of Human Resources
Riaz Moinuddin, Director of Operations & Maintenance Wally Ritchie, Director of Finance
Lan Wiborg, Director of Environmental Services
Kelly Lore, Clerk of the Board
ORANGE COUNTY SANITATION DISTRICT Effective 2/11/2025 BOARD OF DIRECTORS Complete Roster
AGENCY/CITIES ACTIVE DIRECTOR ALTERNATE DIRECTOR
Anaheim
Carlos A. Leon
Ryan Balius
Brea Christine Marick Cecilia Hupp
Buena Park Joyce Ahn Lamiya Hoque
Cypress Scott Minikus Bonnie Peat
Fountain Valley Glenn Grandis Ted Bui
Fullerton Jamie Valencia Shana Charles
Garden Grove Stephanie Klopfenstein Cindy Ngoc Tran
Huntington Beach Pat Burns Gracey Van Der Mark
Irvine Melinda Liu Kathleen Treseder
La Habra Jose Medrano Rose Espinoza
La Palma Debbie Baker Vikesh Patel
Los Alamitos Jordan Nefulda Tanya Doby
Newport Beach Erik Weigand Michelle Barto
Orange Jon Dumitru John Gyllenhammer
Placentia Chad Wanke Ward Smith
Santa Ana Johnathan Ryan Hernandez Jessie Lopez
Seal Beach Lisa Landau Ben Wong
Stanton David Shawver John D. Warren
Tustin Ryan Gallagher Austin Lumbard
Villa Park Jordan Wu Kelly McBride
Sanitary/Water Districts
Costa Mesa Sanitary District Bob Ooten
Art Perry
Midway City Sanitary District Andrew Nguyen Tyler Diep
Irvine Ranch Water District John Withers Dan Ferons
Yorba Linda Water District Tom Lindsey Gene Hernandez
County Areas
Board of Supervisors Doug Chaffee Janet Nguyen
STEERING COMMITTEE
Regular Meeting Agenda
Wednesday, September 24, 2025 - 5:00 PM
Huntington Beach Room
Headquarters
18480 Bandilier Circle
Fountain Valley, CA 92708
(714) 593-7433
ACCOMMODATIONS FOR THE DISABLED: If you require any special disability related accommodations,
please contact the Orange County Sanitation District (OC San) Clerk of the Board’s office at (714) 593-7433 at
least 72 hours prior to the scheduled meeting. Requests must specify the nature of the disability and the type
of accommodation requested.
AGENDA POSTING: In accordance with the requirements of California Government Code Section 54954.2, this
agenda has been posted outside OC San's Headquarters located at 18480 Bandilier Circle, Fountain Valley,
California, and on the OC San’s website at www.ocsan.gov not less than 72 hours prior to the meeting date and
time above. All public records relating to each agenda item, including those distributed less than 72 hours
prior to the meeting to a majority of the Board of Directors, are available for public inspection with the Clerk of
the Board.
AGENDA DESCRIPTION: The agenda provides a brief general description of each item of business to be
considered or discussed. The recommended action does not indicate what action will be taken. The Board of
Directors may take any action which is deemed appropriate.
MEETING RECORDING: A recording of this meeting is available within 24 hours after adjournment of the
meeting at https://ocsd.legistar.com/Calendar.aspx or by contacting the Clerk of the Board.
NOTICE TO DIRECTORS: To place items on the agenda for a Committee or Board Meeting, the item must be
submitted to the Clerk of the Board: Kelly A. Lore, MMC, (714) 593-7433 / klore@ocsan.gov at least 14 days
before the meeting. For any questions on the agenda, Board members may contact staff at:
General Manager: Rob Thompson, rthompson@ocsan.gov / (714) 593-7110
Asst. General Manager: Lorenzo Tyner, ltyner@ocsan.gov / (714) 593-7550
Director of Communications: Jennifer Cabral, jcabral@ocsan.gov / (714) 593-7581
Director of Engineering: Mike Dorman, mdorman@ocsan.gov / (714) 593-7014
Director of Environmental Services: Lan Wiborg, lwiborg@ocsan.gov / (714) 593-7450
Director of Finance: Wally Ritchie, writchie@ocsan.gov / (714) 593-7570
Director of Human Resources: Laura Maravilla, lmaravilla@ocsan.gov / (714) 593-7007
Director of Operations & Maintenance: Riaz Moinuddin, rmoinuddin@ocsan.gov / (714) 593-7269
STEERING COMMITTEE Regular Meeting Agenda Wednesday, September 24, 2025
CALL TO ORDER
ROLL CALL AND DECLARATION OF QUORUM:
Clerk of the Board
PUBLIC COMMENTS:
Your participation is always welcome. Specific information as to how to participate in a meeting is detailed in the
Special Notice attached to this agenda. In general, OC San offers several ways in which to interact during
meetings: you may participate in person, join the meeting live via Teams on your computer or similar device or
web browser, join the meeting live via telephone, view the meeting online, and/or submit comments for
consideration before or during the meeting.
REPORTS:
The Board Chairperson and the General Manager may present verbal reports on miscellaneous matters of
general interest to the Directors. These reports are for information only and require no action by the Directors.
CONSENT CALENDAR:
Consent Calendar Items are considered to be routine and will be enacted, by the Committee, after one motion,
without discussion. Any items withdrawn from the Consent Calendar for separate discussion will be considered in
the regular order of business.
1.2025-4484APPROVAL OF MINUTES
RECOMMENDATION:
Approve minutes of the Regular meeting of the Steering Committee held August 27,
2025.
Originator:Kelly Lore
Agenda Report
08-27-2025 Steering Committee Meeting Minutes
Attachments:
NON-CONSENT:
2.2025-4455BAY BRIDGE PUMP STATION AND FORCE MAINS REPLACEMENT,
PROJECT NO. 5-67
RECOMMENDATION: Recommend to the Board of Directors to:
A. Consider, approve, and adopt Addendum No. 2 to the Environmental Impact
Report for the Bay Bridge Pump Station and Force Mains Replacement Project
No. 5-67; and
B. Adopt Resolution No. OC SAN 25-18 titled, “A Resolution of the Board of
Page 1 of 4
STEERING COMMITTEE Regular Meeting Agenda Wednesday, September 24, 2025
Directors of the Orange County Sanitation District Approving and Adopting
Addendum No. 2 to the Environmental Impact Report for the Bay Bridge Pump
Station and Force Mains Replacement Project (Project No. 5-67) Pursuant to the
California Environmental Quality Act”.
Originator:Mike Dorman
Agenda Report
Addendum No. 2 to the EIR, 5-67
Addendum No. 1 to the EIR, 5-67
Environmental Impact Report, 5-67
Resolution No. OC SAN 25-18
Attachments:
3.2025-4474IRWD/OC SAN AGREEMENT DEAL POINTS
RECOMMENDATION: Recommend to the Board of Directors to:
Authorize the preparation of two new agreements and a resolution to streamline
operations, better align billing with services provided, and maximize the use of existing
infrastructure in Orange County as follows:
1. Agreement No. 1 between Orange County Sanitation District (OC San) and
Irvine Ranch Water District (IRWD) will realign boundaries and payment
structures with current service provisions. This agreement will consolidate many
prior agreements that were created as development occurred.
2. Agreement No. 2 between OC San, IRWD, and Orange County Water District
(OCWD) will replace the current Green Acres Project (GAP) Agreement which
expires in January 2027.
3. An OC San Board of Directors resolution will support the Orange County Local
Agency Formation Commission (OC LAFCO) process to annex the former Los
Alisos Water District (LAWD) area into OC San’s service area.
Originator:Mike Dorman
Agenda Report
Map No. 1: Services Area (Districts) Before Consolidation
Map No. 2 : OC San/IRWD Flow Accommodation Agreement
Areas
Map No. 3: Proposed Modifications
Map No. 4: Proposed Annexation of Los Alisos Area
Attachments:
4.2025-4512SIDE LETTER TO THE MEMORANDUM OF UNDERSTANDING FOR
THE INTERNATIONAL UNION OF OPERATING ENGINEERS - LOCAL
501
RECOMMENDATION: Recommend to the Board of Directors to:
Page 2 of 4
STEERING COMMITTEE Regular Meeting Agenda Wednesday, September 24, 2025
Authorize the execution of a Side Letter Modifying Article 19 - Standby Pay of the
current Memorandum of Understanding between Orange County Sanitation District and
the International Union of Operating Engineers Local 501 retroactive to the first pay
period of July 2025.
Originator:Laura Maravilla
Agenda Report
Local 501 MOU Side Letter
Attachments:
INFORMATION ITEMS:
None.
DEPARTMENT HEAD REPORTS:
CLOSED SESSION:
During the course of conducting the business set forth on this agenda as a regular meeting of the Board, the
Chairperson may convene the Board in closed session to consider matters of pending real estate negotiations,
pending or potential litigation, or personnel matters, pursuant to Government Code Sections 54956.8, 54956.9,
54957 or 54957.6, as noted.
Reports relating to (a) purchase and sale of real property; (b) matters of pending or potential litigation; (c)
employment actions or negotiations with employee representatives; or which are exempt from public disclosure
under the California Public Records Act, may be reviewed by the Board during a permitted closed session and are
not available for public inspection. At such time the Board takes final action on any of these subjects, the minutes
will reflect all required disclosures of information.
CONVENE IN CLOSED SESSION.
CS-1 2025-4501CONFERENCE WITH REAL PROPERTY NEGOTIATORS -
GOVERNMENT CODE SECTION 54956.8
RECOMMENDATION: Convene in Closed Session:
A.Property: 10700 Spencer Street, Fountain Valley, CA - APN No.156-154-07 and
156-163-16.
Agency negotiators: General Manager Rob Thompson; Assistant General
Manager Lorenzo Tyner; and Director of Finance Wally Ritchie.
Negotiating parties: Shabtai Itzhak Tr Ins Tr
Under negotiation: Price and Terms of payment
B.Property: 18250 Euclid Street, Fountain Valley, CA - APN No.156-171-41.
Agency negotiators: General Manager Rob Thompson; Assistant General
Page 3 of 4
STEERING COMMITTEE Regular Meeting Agenda Wednesday, September 24, 2025
Manager Lorenzo Tyner; and Director of Finance Wally Ritchie.
Negotiating parties: Rexford Industrial Realty LP
Under negotiation: Price and Terms of payment
Agenda Report
Steering CS Memo re Real Property 09-24-25
Attachments:
RECONVENE IN REGULAR SESSION.
CONSIDERATION OF ACTION, IF ANY, ON MATTERS CONSIDERED IN CLOSED
SESSION:
OTHER BUSINESS AND COMMUNICATIONS OR SUPPLEMENTAL AGENDA ITEMS, IF
ANY:
BOARD OF DIRECTORS INITIATED ITEMS FOR A FUTURE MEETING:
At this time Directors may request staff to place an item on a future agenda.
ADJOURNMENT:
Adjourn the meeting until the Regular Meeting of the Steering Committee on October 22,
2025 at 5:00 p.m.
AFFIDAVIT OF PUBLICATION:
I hereby certify under penalty of perjury and as required by the State of California, Government Code §
54954.2(a), that the foregoing Agenda was posted online at www.ocsan.gov, in the lobby, and outside the main
door of Orange County Sanitation District Headquarters at 18480 Bandilier Cir. Fountain Valley, CA 92708 not
less than 72 hours prior to the meeting date and time above. All public records relating to each agenda item,
including those distributed less than 72 hours prior to the meeting to a majority of the Board of Directors, are
available for public inspection with the Clerk of the Board.
/s/ Kelly A. Lore, MMC
Clerk of the Board
September 16, 2025
Page 4 of 4
STEERING COMMITTEE
Agenda Report
Headquarters
18480 Bandilier Circle
Fountain Valley, CA 92708
(714) 593-7433
File #:2025-4484 Agenda Date:9/24/2025 Agenda Item No:1.
FROM:Robert Thompson, General Manager
Originator: Kelly A. Lore, Clerk of the Board
SUBJECT:
APPROVAL OF MINUTES
GENERAL MANAGER'S RECOMMENDATION
RECOMMENDATION:
Approve minutes of the Regular meeting of the Steering Committee held August 27, 2025.
BACKGROUND
In accordance with the Board of Directors Rules of Procedure,an accurate record of each meeting
will be provided to the Directors for subsequent approval at the following meeting.
RELEVANT STANDARDS
·Resolution No. OC SAN 24-09
ATTACHMENT
The following attachment(s)may be viewed on-line at the OC San website (www.ocsan.gov)with the complete agenda
package:
·August 27, 2025 Steering Committee meeting minutes
Orange County Sanitation District Printed on 9/15/2025Page 1 of 1
powered by Legistar™
Orange County Sanitation District
Minutes for the
STEERING COMMITTEE
Wednesday, August 27, 2025
5:00 PM
Huntington Beach Room
Headquarters
18480 Bandilier Circle
Fountain Valley, CA 92708
(714) 593-7433
CALL TO ORDER
A regular meeting of the Steering Committee of the Orange County Sanitation District was
called to order by Board Vice Chairman Jon Dumitru on Wednesday, August 27, 2025 at 5:00
p.m. in the Orange County Sanitation District Headquarters.
ROLL CALL AND DECLARATION OF QUORUM:
The Clerk of the Board declared a quorum present as follows:
PRESENT:Jon Dumitru, Pat Burns, Glenn Grandis, Christine Marick, Chad
Wanke and John Withers
ABSENT:Ryan Gallagher
STAFF PRESENT: Rob Thompson, General Manager; Lorenzo Tyner, Assistant General
Manager; Jennifer Cabral, Director of Communications; Mike Dorman, Director of
Engineering; Laura Maravilla, Director of Human Resources; Riaz Moinuddin, Director of
Operations and Maintenance; Wally Ritchie, Director of Finance; Lan Wiborg, Director of
Environmental Services; Kelly Lore, Clerk of the Board; Mortimer Caparas; Sam Choi; Raul
Cuellar; Don Cutler; Thys De Vries; Martin Dix; Justin Fenton; John Fratalli; Al Garcia; Mark
Kawamoto; Joe Manzella; Tom Meregillano; Rob Michaels; Tania Moore; John Powell;
Thomas Vu; Kevin Work; Sammady Yi; and Ruth Zintzun were present in the Huntington
Beach Room.
OTHERS PRESENT: Scott Smith, General Counsel was present in the Huntington Beach
Room. Danielle Dychter, Special Counsel, Michael Sullivan & Associates LLP was present
telephonically.
PUBLIC COMMENTS:
None.
REPORTS:
Vice Chair Dumitru did not provide a report.
General Manager Rob Thompson provided a brief report on the Miller Holder Easement
Cleanup project, noting the bids received and stated that the contract would be presented to
the Board for approval in October.
Page 1 of 6
STEERING COMMITTEE Minutes August 27, 2025
CONSENT CALENDAR:
1.APPROVAL OF MINUTES 2025-4426
Originator: Kelly Lore
MOVED, SECONDED, AND DULY CARRIED TO:
Approve minutes of the Regular meeting of the Steering Committee held July 23, 2025.
AYES:Jon Dumitru, Pat Burns, Glenn Grandis, Christine Marick, Chad
Wanke and John Withers
NOES:None
ABSENT:Ryan Gallagher
ABSTENTIONS:None
NON-CONSENT:
2.BUDGET INCREASE FOR FISCAL YEAR 2024-25 2025-4433
Originator: Wally Ritchie
Director of Finance Wally Ritchie provided a brief report on this item.
MOVED, SECONDED, AND DULY CARRIED TO: Recommend to the Board of
Directors to:
Approve a budget increase of $20,000,000 for FY 2024-25, for a total budget as
follows:
FY 2024-25
Net Operating $232,674,493
Self-Insurance - Worker’s Comp.$1,124,029
Self-Insurance - Property & Gen. Liability $4,402,500
Net Capital Improvement Program $243,075,113
Debt/COP Service $61,027,421
Intra-District Joint Equity Purchase/Sale (1)$3,500,000
Total $545,803,556
(1)Cash to/from Revenue Area 14 (RA14) in exchange for capital assets to/from
Consolidated Revenue Area 15 (RA15)
AYES:Jon Dumitru, Pat Burns, Glenn Grandis, Christine Marick, Chad
Wanke and John Withers
NOES:None
ABSENT:Ryan Gallagher
ABSTENTIONS:None
Page 2 of 6
STEERING COMMITTEE Minutes August 27, 2025
3.COMPENSATION AND BENEFITS FOR UNREPRESENTED
EMPLOYEE GROUPS - CONFIDENTIAL EXEMPT AND NON-EXEMPT
2025-4449
Originator: Laura Maravilla
Director of Human Resources Laura Maravilla provided a brief report on this item.
MOVED, SECONDED, AND DULY CARRIED TO: Recommend to the Board of
Directors to:
A. Adopt Resolution No. OC SAN 25-10 titled, “A Resolution of the Board of
Directors of the Orange County Sanitation District approving salary and benefit
adjustments for unrepresented exempt Confidential Group employees for Fiscal
Years 2025-2026, 2026-2027, and 2027-2028;”
B. Adopt Resolution No. OC SAN 25-11 titled, “A Resolution of the Board of
Directors of the Orange County Sanitation District approving salary and benefit
adjustments for unrepresented non-exempt Confidential Group employees for
Fiscal Years 2025-2026, 2026-2027, and 2027-2028.”
AYES:Jon Dumitru, Pat Burns, Glenn Grandis, Christine Marick, Chad
Wanke and John Withers
NOES:None
ABSENT:Ryan Gallagher
ABSTENTIONS:None
4.COMPENSATION AND BENEFITS FOR UNREPRESENTED
EMPLOYEE GROUPS - EXECUTIVE MANAGEMENT TEAM AND
MANAGER GROUP
2025-4448
Originator: Laura Maravilla
Ms. Laura Maravilla provided a brief report on this item.
MOVED, SECONDED, AND DULY CARRIED TO: Recommend to the Board of
Directors to:
A. Adopt Resolution No. OC SAN 25-12 titled, “A Resolution of the Board of
Directors of the Orange County Sanitation District approving salary and benefit
adjustments for unrepresented Executive Management Team employees for
Fiscal Years 2025-2026, 2026-2027, and 2027-2028;”
B. Adopt Resolution No. OC SAN 25-13 titled, “A Resolution of the Board of
Directors of the Orange County Sanitation District approving salary and benefit
adjustments for unrepresented Manager Group employees for Fiscal Years
2025-2026, 2026-2027, and 2027-2028.”
AYES:Jon Dumitru, Pat Burns, Glenn Grandis, Christine Marick, Chad
Wanke and John Withers
Page 3 of 6
STEERING COMMITTEE Minutes August 27, 2025
NOES:None
ABSENT:Ryan Gallagher
ABSTENTIONS:None
5.GENERAL MANAGER’S COMPENSATION AND BENEFITS 2025-4447
Originator: Laura Maravilla
Ms. Laura Maravilla provided a brief report on this item.
MOVED, SECONDED, AND DULY CARRIED TO: Recommend to the Board of
Directors to:
Adopt Resolution No. OC SAN 25-14 titled: “A Resolution of the Board of Directors of
the Orange County Sanitation District approving salary and benefit adjustments for the
General Manager for Fiscal Year 2025/2026.” The changes consist of a salary
increase and corresponding salary range adjustment of 4.5%, effective in the first pay
period of July 2025, and changes to a leave bank, 457(b) contribution and mileage
reimbursement.
AYES:Jon Dumitru, Pat Burns, Glenn Grandis, Christine Marick, Chad
Wanke and John Withers
NOES:None
ABSENT:Ryan Gallagher
ABSTENTIONS:None
INFORMATION ITEMS:
None.
DEPARTMENT HEAD REPORTS:
None.
CLOSED SESSION:
CONVENED IN CLOSED SESSION PURSUANT TO GOVERNMENT CODE SECTIONS
54956.9(d)(1), 54956.8 & 54956.9(D)(4).
The Committee convened in closed session at 5:08 p.m. Item No. CS-1(B) was not heard.
Confidential minutes of the Closed Sessions have been prepared in accordance with the
above Government Code Sections and are maintained by the Clerk of the Board in the
Official Book of Confidential Minutes of Board and Committee Closed Session meetings.
CS-1 CONFERENCE WITH LEGAL COUNSEL RE EXISTING LITIGATION -
GOVERNMENT CODE SECTION 54956.9(d)(1)
2025-4440
CONVENED IN CLOSED SESSION:
Page 4 of 6
STEERING COMMITTEE Minutes August 27, 2025
Number of Cases: 2
A. Ddaze Phuong, Workers’ Compensation Claim, Workers Compensation Appeals
Board, Case Nos. ADJ16015389 and ADJ18947693; and
B. James Cabral, Workers’ Compensation Claim, Workers Compensation Appeals
Board, Case Nos. ADJ20490382 and ADJ20620306.
CS-2 CONFERENCE WITH REAL PROPERTY NEGOTIATORS -
GOVERNMENT CODE SECTION 54956.8
2025-4439
CONVENED IN CLOSED SESSION:
A.Property: 10700 Spencer Street, Fountain Valley, CA - APN No.156-154-07 and
156-163-16.
Agency negotiators: General Manager Rob Thompson; Assistant General
Manager Lorenzo Tyner; and Director of Finance Wally Ritchie.
Negotiating parties: Shabtai Itzhak Tr Ins Tr
Under negotiation: Price and Terms of payment
B.Property: 18250 Euclid Street, Fountain Valley, CA - APN No.156-171-41.
Agency negotiators: General Manager Rob Thompson; Assistant General
Manager Lorenzo Tyner; and Director of Finance Wally Ritchie.
Negotiating parties: Rexford Industrial Realty LP
Under negotiation: Price and Terms of payment
CS-3 CONFERENCE WITH LEGAL COUNSEL RE ANTICIPATED
LITIGATION - GOVERNMENT CODE SECTION 54956.9(D)(4)
2025-4424
CONVENED IN CLOSED SESSION:
Number of Potential Cases: 1.
Initiation of litigation.
RECONVENED IN REGULAR SESSION.
The Committee reconvened in regular session at 5:57 p.m.
CONSIDERATION OF ACTION, IF ANY, ON MATTERS CONSIDERED IN CLOSED
SESSION:
General Counsel Scott Smith stated there was no reportable action.
Page 5 of 6
STEERING COMMITTEE Minutes August 27, 2025
OTHER BUSINESS AND COMMUNICATIONS OR SUPPLEMENTAL AGENDA ITEMS, IF
ANY:
None.
BOARD OF DIRECTORS INITIATED ITEMS FOR A FUTURE MEETING:
None.
ADJOURNMENT:
Vice Chair Dumitru declared the meeting adjourned at 5:58 p.m. to the next Regular Steering
Committee meeting to be held on Wednesday, September 24, 2025 at 5:00 p.m.
Submitted by:
__________________
Kelly A. Lore, MMC
Clerk of the Board
Page 6 of 6
STEERING COMMITTEE
Agenda Report
Headquarters
18480 Bandilier Circle
Fountain Valley, CA 92708
(714) 593-7433
File #:2025-4455 Agenda Date:9/24/2025 Agenda Item No:2.
FROM:Robert Thompson, General Manager
Originator: Mike Dorman, Director of Engineering
SUBJECT:
BAY BRIDGE PUMP STATION AND FORCE MAINS REPLACEMENT, PROJECT NO. 5-67
GENERAL MANAGER'S RECOMMENDATION
RECOMMENDATION: Recommend to the Board of Directors to:
A. Consider, approve, and adopt Addendum No. 2 to the Environmental Impact Report for the
Bay Bridge Pump Station and Force Mains Replacement Project No. 5-67; and
B. Adopt Resolution No. OC SAN 25-18 titled, “A Resolution of the Board of Directors of the
Orange County Sanitation District Approving and Adopting Addendum No. 2 to the
Environmental Impact Report for the Bay Bridge Pump Station and Force Mains Replacement
Project (Project No. 5-67) Pursuant to the California Environmental Quality Act”.
BACKGROUND
The Bay Bridge Pump Station and associated force mains were constructed in 1966 on Pacific Coast
Highway just east of the Lower Newport Bay Channel.The pump station and force mains are critical
to the Orange County Sanitation District’s (OC San)infrastructure as it conveys over half of Newport
Beach’s wastewater.The pump station is over 50 years old and at the end of its useful life.The
pump station and force mains are currently being upgraded to ensure continuous service.
In February 2021,OC San certified the Environmental Impact Report (EIR)for the Bay Bridge Pump
Station and Force Mains Replacement,Project No.5-67 (State Clearinghouse No.2016111031).
Modifications to the project construction area have been proposed and analyzed with respect to a
Court Ruling issued in January 2023 with the Revised Order for Prejudgment Possession.In July
2023 Addendum No.1 to the EIR was prepared with these modifications analyzed.The
modifications did not result in new significant impacts or a substantial increase in the severity of
previously identified significant environmental impacts.No new mitigation was required as a result of
the project modifications.
In June 2025,the Contractor notified OC San of ongoing negotiations to secure additional
construction staging area adjacent to the Bay Bridge Pump Station.In response,Addendum No.2 to
the EIR was prepared to evaluate the proposed modifications.The analysis concluded that the
changes would not result in any new significant environmental impacts,nor would they substantially
increase the severity of previously identified impacts.Accordingly,no new mitigation measures are
Orange County Sanitation District Printed on 9/16/2025Page 1 of 4
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File #:2025-4455 Agenda Date:9/24/2025 Agenda Item No:2.
increase the severity of previously identified impacts.Accordingly,no new mitigation measures are
required to implement the project modifications.
In August 2025,the Contractor submitted a request to OC San to allow nighttime delivery of
oversized loads via Coast Highway to the construction site.The current mitigation measures
(specifically,TRA-1)restrict such oversized loads to weekdays between 9:00 a.m.and 3:00 p.m.
Upon review,OC San determined that restricting nighttime deliveries of oversized loads along Coast
Highway was not required to reduce environmental impacts.In fact,permitting nighttime deliveries of
oversized loads along Coast Highway would present a safer alternative,one that Caltrans and the
City of Newport Beach prefer.In response,Addendum No.2 to the EIR was prepared to assess the
proposed modification and to demonstrate that,in fact,the restriction of nighttime deliveries of
oversized loads along Coast Highway was not for the purpose of reducing environmental effects.
The Addendum’s analysis concluded that the change would not result in new significant
environmental impacts or substantially increase the severity of existing impacts.Based on these
findings,the mitigation measure may be revised to permit nighttime oversized load deliveries via
Coast Highway,with the necessary permit from Caltrans and required notification to the City of
Newport Beach.
RELEVANT STANDARDS
·Meet CEQA standards
·Listen to and seriously consider community input on environmental concerns
·Maintain collaborative and cooperative relationships with regulators,stakeholders,and
neighboring communities
PROBLEM
Addendum No.1 restricted the project construction staging areas to Lower Castaways Park and OC
San’s Plant No.2 to comply with the Court Ruling issued in January 2023 with the Revised Order for
Prejudgment Possession.The Contractor requested the use of a construction staging area adjacent
to the Bay Bridge Pump Station and needs to perform nighttime deliveries of oversized loads via
Coast Highway due to a limited turning radius along the pump station access road.Per Section
15164(a) of the CEQA Guidelines, an addendum to the previously certified EIR is appropriate.
PROPOSED SOLUTION
Consider,approve,and adopt Addendum No.2 to the Environmental Impact Report for the Bay
Bridge Pump Station and Force Mains Replacement,Project No.5-67 (“Addendum")and approve the
modifications to the project and mitigation measure TRA-1 that are identified in the attachment and
identified and described in Addendum No.2 to the Environmental Impact Report for Bay Bridge
Pump Station and Force Mains Replacement, Project No. 5-67.
TIMING CONCERNS
The Contractor will not be able to use the adjacent construction staging area and deliver nighttime
oversized loads via Coast Highway until the addendum is approved.Delaying the ability to deliver
oversized loads will impact the microtunneling activities which are scheduled to begin in the coming
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oversized loads will impact the microtunneling activities which are scheduled to begin in the coming
months.
RAMIFICATIONS OF NOT TAKING ACTION
The project cannot utilize the additional staging area before complying with CEQA.Similarly,there is
no way to safely deliver oversized loads to the project site except via Coast Highway.Caltrans
allows oversized loads to be delivered via Coast Highway at night to minimize impacts to traffic flow
and safety during daytime (high use) hours.
PRIOR COMMITTEE/BOARD ACTIONS
February 2025 -Awarded a Construction Contract Agreement to J.F.Shea Construction,Inc.for Bay
Bridge Pump Station Replacement,Project No.5-67,for a total amount not to exceed $87,321,000;
and approved a contingency of $8,732,100 (10%).
August 2024 -Approved a Utility Permit Agreement with the County of Orange for installing force
mains under the Lower Newport Bay Channel for the Bay Bridge Pump Station Replacement,Project
No.5-67;and approved a one-time payment of $5,000 to the County of Orange for fees associated
with the Utility Permit Agreement.
August 2024 -Approved a Project Specific Maintenance Agreement with the California Department of
Transportation (Caltrans)for the construction and maintenance of force mains,drainage pipes,
retaining wall,sidewalk,curb and gutter hardscape,and landscaping within the Caltrans right-of-way
for the Bay Bridge Pump Station Replacement, Project No. 5-67.
September 2023 -Approved a License Agreement with the City of Newport Beach for the
construction staging area for the Bay Bridge Pump Station and Force Mains Replacement,Project
No. 5-67.
July 2023 -Considered,Received,and Certified the Addendum to the Environmental Impact Report
for the Bay Bridge Pump Station and Force Mains Replacement Project No.5-67,dated July 2023;
and adopted Resolution No.OC SAN 23-13 entitled,“A Resolution of the Orange County Sanitation
District Board of Directors receiving and filing the Addendum to the Environmental Impact Report for
the Bay Bridge Pump Station and Force Mains Replacement Project No.5-67 and approved the
Modified Project”.
February 2021 -Considered,received,and certified the Environmental Impact Report for the Bay
Bridge Pump Station and Force Mains Replacement Project,Project No.5-67,dated January 2021;
and adopted Resolution No.OC SAN 21-03,entitled:“A Resolution of the Board of Directors of the
Orange County Sanitation District Certifying the Environmental Impact Report for the Bay Bridge
Pump Station and Force Mains Replacement Project,Project No.5-67;Adopting the Mitigation
Monitoring and Reporting Program;and Approving the Bay Bridge Pump Station and Force Mains
Replacement Project, Project No. 5-67”.
ADDITIONAL INFORMATION
N/A
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CEQA
OC San,as lead agency,prepared a Final Program EIR for the Bay Bridge Pump Station and Force
Mains Replacement Project,Project No.5-67,dated May 2018.The Board certified the EIR on
2/24/2021.OC San filed a Notice of Determination on 3/1/2021.Since that time,modifications to
project construction staging area have been proposed as required by the Court Ruling issued in
January 2023 with the Revised Order for Prejudgment Possession.The environmental impacts of
the proposed modifications were analyzed,and it was determined that the modifications would not
result in any new significant impacts or a substantial increase in the severity of previously identified
significant impacts.(CEQA Guidelines §15162.)Addendum No.1 was prepared accordingly,and
OC San approved Addendum No. 1 on 7/26/2023 and filed a Notice of Determination on 7/27/2023.
In June 2025,the Contractor notified OC San of ongoing negotiations to secure additional
construction staging area adjacent to the Bay Bridge Pump Station.In response,Addendum No.2 to
the EIR was prepared to evaluate the proposed modifications,as well as to evaluate modifications to
TRA-1 to permit nighttime deliveries of oversized loads via Coast Highway.Addendum No.2 was
prepared accordingly for a new modification to project construction staging area (CEQA Guidelines §
15164).Addendum No.2 confirms that the proposed modifications to the construction staging area
and mitigation measure TRA-1 do not trigger any of the conditions described in State CEQA
Guidelines section 15162 that would require preparation of a subsequent EIR.
FINANCIAL CONSIDERATIONS
N/A
ATTACHMENT
The following attachment(s)may be viewed on-line at the OC San website (www.ocsan.gov)with the complete agenda
package:
·Addendum No. 2 to the Environmental Impact Report, Project No. 5-67
·Addendum No. 1 to the Environmental Impact Report, Project No. 5-67
·Environmental Impact Report, Project No. 5-67
·Resolution No. OC SAN 25-18
CM:lb
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ADDENDUM NO. 2 TO THE ENVIRONMENTAL IMPACT REPORT
FOR THE
Bay Bridge Pump Station and
Force Mains Replacement Project
(Project No. 5-67)
State Clearinghouse No. 2016111031
Lead Agency:
18480 Bandilier Circle
Fountain Valley, California 92708 Contact: Mr. Kevin Hadden
Principal Staff Analyst 714.962.2411
Prepared by:
MICHAEL BAKER INTERNATIONAL 5 Hutton Centre Drive, Suite 500
Santa Ana, California 92707 Contact: Ms. Kristen Bogue
949.472.3505
September 2025
JN 208429
Addendum No. 2 to the Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project (Project No. 5-67)
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TABLE OF CONTENTS
Section I: Summary .................................................................................................................................. 1
Section II: Applicable CEQA Principles ................................................................................................ 3
Section III: Project Description: The Modified Project ........................................................................ 4
Section IV: Environmental Assessment ................................................................................................... 6
Exhibits
1 Added Staging Area and Truck Access ............................................................................... 5
Attachments
1 Orange County Superior Court Case No. 30-2021-00194238 Ruling
Addendum No. 2 to the Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project (Project No. 5-67)
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I. Summary
As Lead Agency, the Orange County Sanitation District (“OC San”) prepared the Draft
Environmental Impact Report (“Draft EIR”) for the Bay Bridge Pump Station and Force Mains
Replacement Project (State Clearinghouse No. 2016111031)1. The OC San’s Board of Directors ultimately certified the DEIR on February 24, 2021. On March 1, 2021, OC San submitted a Notice of Determination (“NOD”) for the Final EIR to both the State Clearinghouse and the Orange County Clerk’s Office (“County Clerk’s Office”). The County Clerk’s Office posted the NOD on
March 1, 2021, and the State Clearinghouse posted the NOD on March 2, 2021.
On April 1, 2021, Bayside Village Marina filed a Verified Petition for Writ of Mandate against OC San in Orange County Superior Court alleging that the Draft EIR failed to comply with CEQA on numerous grounds. (Orange County Superior Court Case No. 30-2021-01194238.) On December 16, 2022, Judge William Claster of the Orange County Superior Court issued a ruling
that upheld the Draft EIR in all respects except one. The Court issued a limited writ directing OC San to correct deficiencies in the Draft EIR’s description of the project’s proposed construction staging areas. The Court made this ruling (the “Ruling”) on December 16, 2022.
The Draft EIR explained that construction staging would occur somewhere in the “Adjacent Pump Station Work Area” (identified in Draft EIR Exhibit 3-6, Adjacent Pump Station
Work Areas), which included both Lower Castaways Park and a portion of the Bayside Village
Marina private property. The Draft EIR considered all potential impacts that could occur in the Adjacent Pump Station Work Area including, among others, impacts on biological resources, aesthetics, cultural resources, archeological resources, transportation, noise, land use plan consistency, and emergency response during construction activities.
The City of Newport Beach submitted a comment letter to OC San stating that the “City will likely neither support a permanent nor temporary easement through Lower Castaways Park” because the City plans to develop the site with park facilities. In responses to comments, OC San stated that, should Lower Castaways not be available, construction staging would occur elsewhere within the Adjacent Pump Station Work Area.
The Court found that, assuming Lower Castaways is not available, “it is unclear whether creating a staging area in the limited, designated space is even possible.” The Court concluded that no specific location with adequate square footage had been identified in the Draft EIR, nor was there any analysis as to whether Draft EIR Mitigation Measures AES-1 and TRA-1 would apply to any area other than the Lower Castaways.
The Court also noted that Draft EIR Mitigation Measure TRA-1 implies that construction staging could occur outside the Adjacent Pump Station Work Area. Draft EIR Mitigation Measure TRA-1 states in relevant part, “[construction drawings shall] identify any and all construction staging or material storage sites located outside of the project area.” The Court further noted that counsel for the District stated in a prior hearing that the lowest responsible bidder will have
complete discretion to decide where staging would occur and how many staging sites would be necessary. The Court explained that because the Draft EIR’s analysis failed to account for impacts that could occur elsewhere, and the low responsible bidder could place the project staging
1 The Draft EIR refers to the 2020 Recirculated Draft EIR for the Project, which was circulated for public review in
August 2020.
Addendum No. 2 to the Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project (Project No. 5-67)
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elsewhere in its sole discretion, Draft EIR Mitigation Measure AES-1 was “toothless.” The Court also questioned whether AES-1 imposed enforceable standards.
In July 2023, OC San prepared an Addendum (Addendum No. 1) to the Final EIR in
response to the Ruling. Addendum No. 1 provided additional information regarding the proposed use of the Lower Castaways Park as a construction staging area and added a new construction staging area at OC San Plant No. 2, located in the City of Huntington Beach, for soil storage/drying activities. Addendum No. 1 modified Draft EIR TRA-1 to eliminate any reference to additional
construction staging or material storage areas and, per a new condition of project approval, stated
that the construction contractor would not have discretion to select staging areas. Finally, Addendum No. 1 modified and addressed the enforceability of Draft Mitigation Measure AES-1. Mitigation measures for public projects are considered enforceable when they are incorporated into the project design. (Public Resources Code § 21081.6(b); 14 Cal. Code Regs. §
15126.4(a)(2).) A resolution incorporating AES-1 into the project design was included with
Addendum No. 1.
Addendum No. 1 considered all potential impacts that could occur within the proposed staging areas, including, among others, impacts on aesthetics, air quality, biological resources, cultural and tribal cultural resources, geology and soils, greenhouse gas emissions, hazards and
hazardous materials, hydrology and water quality, land use and planning, noise, population and housing, public services, recreation, transportation, utilities, and wildfire. Addendum No. 1 concluded that the additional staging area at OC San Plant No. 2 and revisions to Draft EIR Mitigation Measures AES-1 and TRA-1 would not result in new significant impacts or a substantial increase in significant impacts previously identified in the Draft EIR. Collectively, the
Draft EIR, Final EIR, and Addendum No. 1 are referred to as the “previously analyzed project.”
The property owner at Bayside Village Marina LLC (“Bayside Village Property”) has offered to allow OC San’s Contractor to stage construction materials on a portion of its property. Thus, OC San wishes to analyze the environmental impacts of using a portion of the Bayside Village Property as a staging area for the project, in addition to the delivery of oversized loads in
the nighttime hours. Specifically, in August 2025, the Contractor submitted a request to OC San to allow nighttime delivery of oversized loads via Coast Highway to the construction site. The current mitigation measures (specifically, TRA-1) restrict such oversized loads to weekdays between 9:00 a.m. and 3:00 p.m. Upon review, OC San determined that restricting nighttime deliveries of oversized loads along Coast Highway was not required to reduce environmental
impacts. In fact, permitting nighttime deliveries of oversized loads along Coast Highway would present a safer alternative, one that Caltrans and the City of Newport Beach prefer. In response, OC San wishes to modify TRA-1 as shown in Section IV, Environmental Assessment, Transportation, below. Thus, OC San has prepared this Addendum (Addendum No. 2) in order to analyze the environmental impacts that may occur from adding a portion of the Bayside Village
Property as a staging area, as well as nighttime delivery of oversized loads, is referred to herein as the “Modified Project”.
As set forth in detail below, the Modified Project would not result in new significant impacts or a substantial increase in the severity of previously identified significant impacts. As a result, an addendum is appropriate. (CEQA Guidelines §§ 15162, 15164.)
Addendum No. 2 to the Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project (Project No. 5-67)
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II. Applicable CEQA Principles
When an EIR has been certified or a negative declaration adopted for a project, no
subsequent or supplemental environmental review documentation shall be required unless one or
more of the following events occurs:
1) Substantial changes are proposed in the project, which will require major revisions of the previous EIR or negative declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified
significant effects;
2) Substantial changes occur with respect to the circumstances under which the project is undertaken, which will require major revisions of the previous EIR or negative declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects; or
3) New information of substantial importance, which was not known and could not have been known with the exercise of reasonable diligence at the time the previous EIR was certified as complete or the negative declaration was adopted, shows any of the following:
A. The project will have one or more significant effects not discussed in the previous
EIR or negative declaration;
B. Significant effects previously examined will be substantially more severe than shown in the previous EIR;
C. Mitigation measures or alternatives previously found not to be feasible would in fact be feasible, and would substantially reduce one or more significant effects of
the project, but the project proponents decline to adopt the mitigation measure or alternative; or
D. Mitigation measures or alternatives which are considerably different from those analyzed in the previous EIR would substantially reduce one or more significant effects on the environment, but the project proponents decline to adopt the
mitigation measure or alternative.
The lead agency shall prepare an addendum to a previously certified EIR if some changes or additions are necessary but none of the conditions described in Section 15162 calling for preparation of a subsequent or supplemental EIR have occurred. (CEQA Guidelines § 15164(a).) Circulation of an addendum for public review is not necessary (CEQA Guidelines § 15164(c));
however, the addendum must be considered in conjunction with the adopted Final EIR by the agency’s decision-making body (CEQA Guidelines § 15164(d).)
Addendum No. 2 to the Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project (Project No. 5-67)
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III. Project Description: The Modified Project
In addition to staging activities at 300 East Coast Highway in Newport Beach (the proposed
Pump Station location), 100 Dover Drive in Newport Beach (Lower Castaways Park), and 22212
Brookhurst Street in Huntington Beach (OC San Plant No. 2), the Modified Project would add a staging area at a portion of the Bayside Village Property (Bayside Village Marina Staging Area), which is privately owned and currently operates as an RV storage and boat slip area; refer to Exhibit 1, Added Staging Area and Truck Access. Under existing conditions, vehicular access to
the marina is provided by a private driveway along North Bayside Drive, secured by a gate with ingress and egress on either side of the manned guard station.
Proposed staging activities at this location would include storage of equipment and materials, loading and unloading of equipment and material, limited employee parking, and truck ingress/egress access. The staged construction materials would include piping, conduits, shoring,
formwork, rebar, and other materials necessary for construction. Staged construction equipment at
this location may include trucks, lifts, excavators, loaders, cranes, and other equipment necessary for the construction. Soil and dredged materials would not be stored on the Bayside Village Marina Staging Area.
Existing public access to the RV storage area and to the dock structures in the marina would
not be obstructed or altered during project construction. Ingress and egress for both renters and project construction vehicles would be provided via the existing driveway to the property along the west side of Bayside Drive. For larger truck loads, both ingress and egress would occur at the vehicle ingress of the driveway, as depicted in Exhibit 1. As larger trucks are unable to complete the exit turn in the egress lane, larger trucks would exit through the guard shack ingress point and
utilize a flagger at that time. All other vehicles would exit through the egress point of the guard
shack.
No changes to proposed staging/hauling activities at Lower Castaways Park or OC San Plant No. 2 would result from the Modified Project; these project features would remain the same as that considered in Addendum No. 1. However, in order to minimize potential safety concerns
pertaining to the hauling of oversized loads on public right-of-way, the Modified Project proposes nighttime deliveries of oversized loads at the project driveway at East Coast Highway subject to applicable Caltrans permit(s). Examples of oversized loads would include delivery of the grout plant, large drill, tunneling machine sections, plant equipment, and other materials/equipment. Delivery of such equipment would also include movement of equipment to/from the proposed
pump station and launch shaft location as well as the reception shaft area.
It is acknowledged that given the construction period for the proposed project (Fall of 2025 through Winter of 2028), staging of these materials may be utilized at any of these three locations, depending on availability at the time of staging. Should utilization of Lower Castaways Park as a staging location terminate, such staging activities would shift to the Bayside Village Marina
Staging Area and OC San Plant No. 2.
5
Addendum No. 2 to the Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project (Project No. 5-67)
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IV. Environmental Assessment
Potential environmental impacts associated with the temporary use of the Adjacent Pump Station
Work Area and Lower Castaways Park for construction staging purposes during implementation
of the previously analyzed project were evaluated in the Draft EIR. Potential environmental impacts associated with the temporary use of OC San Plant No. 2 for construction staging purposes were evaluated in Addendum No. 1. The Modified Project would include a staging area within the existing Bayside Village Property (Bayside Village Marina Staging Area). It is acknowledged that
the Draft EIR did evaluate potential staging activities at a portion of this staging area, at the existing
RV storage area depicted in Draft EIR Exhibit 3-6, Adjacent Pump Station Work Areas. As noted above and depicted in Exhibit 1, activities would be limited to equipment and materials storage, limited employee parking, and truck ingress/egress. The Modified Project would not change staging/hauling activities at Lower Castaways Park or OC San Plant No. 2. Potential impacts due
to implementation of the Modified Project are discussed below.
Aesthetics/Light and Glare
The potential aesthetic/visual impacts associated with the temporary use of the Adjacent Pump Station Work Area, which included Lower Castaways Park and a portion of the Bayside Marina Village property for construction staging purposes were analyzed in
the Draft EIR. (Draft EIR, p. 3-12, 3-13, 5.1-16, 5.1-17, 5.1-18.)
The potential aesthetic/visual impacts associated with the temporary use of OC San Plant No. 2 for construction staging purposes were analyzed in Addendum No. 1. (Addendum No. 1, p. 9, 10, 11.) Identified changes since the Draft EIR were limited to the potential visibility of stockpiled soil at the new staging site. Overall, with implementation
of modified Mitigation Measure AES-1, which would require screening for staging areas, impacts related to degraded visual quality, including visual impacts from stockpiling at the OC San Plant No. 2, would be less than significant. The Modified Project would include an additional construction staging location at
the Bayside Village Marina Staging Area, a portion of which was considered for staging in the Draft EIR. Under existing conditions, Bayside Village Marina Staging Area already blocks views of coastal bluffs along Coast Highway; as such, temporary construction staging activities would not increase view blockage of scenic resources, such as coastal bluffs, compared to existing conditions. While the storage of construction equipment and
materials would result in short-term impacts to existing visual character/quality, these impacts would be temporary and cease once construction is completed. Nonetheless, the Modified Project would implement Mitigation Measure AES-1 from the previously analyzed project, and as modified by Addendum No. 1, to ensure that the staging area is screened from public view. Under existing conditions, nighttime security lighting is used
at the existing pump station and within the RV storage area; other sources of light and glare in the general vicinity include existing streetlights and headlights along adjacent roadways and security lighting associated with adjacent development. As staging activities at the Bayside Village Marina Staging Area would be limited to the storage of equipment and materials, loading and unloading of equipment and material, limited employee parking, and
truck ingress/egress access, and would not increase haul trips or require changes to
Addendum No. 2 to the Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project (Project No. 5-67)
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nighttime activities, for staging purposes, previously considered, impacts related to light and glare would not change from the previously analyzed project.
The Modified Project would allow delivery of oversized loads in the nighttime
hours. The Draft EIR analyzed nighttime lighting at the delivery locations, since the project proposed 24-hour construction activities in these areas for the purpose of replacing the force mains. The addition of nighttime lighting as a result of oversized load deliveries at these locations would not result in substantial increases in the nighttime lighting at these
locations. As detailed in the Draft EIR, short-term light and glare impacts associated with
construction activities would likely be limited to nighttime lighting (for construction and security purposes). Mitigation Measure AES-3 would require a construction safety lighting plan. Nighttime security lighting, as necessary, would be oriented downward and away from adjacent residential areas. With implementation of Mitigation Measure AES-3,
impacts in this regard would be reduced to less than significant levels. (Draft EIR p. 5.1-
19.) With compliance with the Draft EIR Mitigation Measure AES-3, the Modified Project would not result in any significant change in impacts related to light and glare from the previously analyzed project.
The Modified Project would not change any operational aspects of the previously
analyzed project.
Following implementation of Mitigation Measure AES-1, as modified by Addendum No. 1, and considering the short-term duration of staging activities at the Bayside Village Marina Staging Area, the Modified Project would not result in new significant impacts or a substantial increase in previously identified significant impacts
pertaining to aesthetics.
AES-1 Prior to issuance of any grading and/or demolition permits, whichever occurs first, engineering drawings and specifications shall be prepared by the Project Engineer, or their designee, and submitted for review and approval by the Orange County Sanitation District Director of Engineering. These documents
shall, at a minimum, indicate the equipment and vehicle staging areas, stockpiling of materials, screening/fencing (, and haul route(s). Staging areas shall be sited away from public views, to the extent feasible and reasonable. Construction haul routes shall minimize impacts to sensitive uses in the project area by avoiding local residential streets. Staging areas shall be screened
utilizing temporary fencing with opaque materials to buffer views of construction equipment and materials for the duration of construction.
AES-3 Prior to any nighttime construction activities, a construction safety lighting plan shall be prepared by the Project Engineer, or their designee, and submitted to the Orange County Sanitation District Director of Engineering for review and
approval. The plan shall include, but not be limited to, the following:
• Identify all required construction lighting fixtures, anticipated locations and heights, and maximum wattage required;
Addendum No. 2 to the Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project (Project No. 5-67)
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• Ensure all construction-related lighting fixtures (including portable
fixtures) are shielded and oriented downward and away from adjacent
sensitive areas (including residential and biologically sensitive areas);
• Provide the minimal wattage necessary to provide adequate nighttime visibility and safety at the construction site; and
• Demonstrate that nighttime construction lighting does not spillover onto adjacent residential properties.
Air Quality
The potential air quality impacts associated with the temporary use of the Adjacent
Pump Station Work Area for construction staging purposes were analyzed in the Draft EIR. (Draft EIR, p. 3-12, 3-13, 5.2-13, 5.2-14, 5.2-15, 5.2-16, 5.2-17, 5.2-19, 5.2-20, 5.2-24, 5.2-25.)
The potential air quality impacts associated with the temporary use of OC San Plant
No. 2 for construction staging purposes were analyzed in Addendum No. 1. (Addendum No. 1, p. 11, 12.) Changes considered since the Draft EIR were limited to the addition of new haul truck trips (approximately 1,674) to and from the new staging area. Nevertheless, Addendum No. 1 concluded that hauling activities would not exceed the South Coast Air Quality Management District’s (SCAQMD) significance thresholds. Overall, the
previously analyzed project was determined to result in less than significant air quality impacts.
The Modified Project would include an additional construction staging location at the Bayside Village Marina Staging Area, a portion of which was considered for staging in the Draft EIR. The Modified Project would allow nighttime hauling of oversized loads at
the project driveway at East Coast Highway. However, the Modified Project would not require additional hauling, compared to that analyzed in the Draft EIR, nor would the project result in any increased staging/hauling activities at Lower Castaways Park or OC San Plant No. 2. Rather, by adding an additional staging area in proximity to construction activities, the Modified Project has the potential to reduce air quality emissions due to
fewer/shorter construction truck trips. As a result, short-term construction staging activities under the Modified Project would not exceed SCAQMD’s significance thresholds and would result in the same or less construction-related air quality impacts on sensitive receptors compared to those identified by the previously approved project.
The Modified Project would not change any operational aspects of the previously
analyzed project. As such, it is not anticipated that the Modified Project would conflict with any applicable air quality plans, as these plans are primarily concerned with long-term impacts.
Following adherence to SCAQMD’s rules and regulations, the Modified Project would not result in new significant impacts or a substantial increase in previously identified
significant impacts pertaining to air quality.
Addendum No. 2 to the Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project (Project No. 5-67)
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Biological Resources
The potential impacts on biological resources associated with the temporary use of
the Adjacent Pump Station Work Area for construction staging purposes were analyzed in
the Draft EIR. (Draft EIR, p. 3-12, 3-13, 5.3-13, 5.3-14, 5.3-15, 5.3-16, 5.3-17, 5.3-19, 5.3-20, 5.3-21, 5.3-23, 5.3-24, 5.3-25.)
The potential impacts on biological resources associated with the temporary use of OC San Plant No. 2 for construction staging purposes were analyzed in Addendum No. 1.
(Addendum No. 1, p. 13, 14.) Identified changes since the Draft EIR were limited to the
presence of ornamental trees at Lower Castaways, where nesting birds could be present. Overall, following implementation of Mitigation Measure BIO-2, as modified by Addendum No. 1, which would require nesting bird surveys and subsequent nest avoidance, impacts related to biological resources would be less than significant.
The Modified Project would include a new staging area within the fully developed
Bayside Village Marina Staging Area. However, it is acknowledged that the majority of this staging area was analyzed in the Draft EIR; refer to Figure 4, Vegetation Communities and Land Uses, of the Biological Resources Report included in Appendix 11.3, Biological Resources Reports, of the Draft EIR. The vast majority of the soils on-site have been
significantly altered due to compaction and construction of the RV storage area and
existing pump station. The only vegetation that exists on site consists of a limited area of ornamental non-native grasses and shrubs along Coast Highway. Thus, the proposed staging area within the Bayside Village Marina Staging Area does not present suitable habitat for sensitive/special-status biological resources. Additionally, there are no riparian
habitats, wetlands, or environmentally sensitive area (ESA) present at the Bayside Village
Marina Staging Area. Due to the presence of ornamental landscaping on site, there is a potential for nesting birds to be present and impacted during construction. As a result, Draft EIR Mitigation Measure BIO-2, as modified by Addendum No. 1, would apply to the Modified Project in order to reduce construction impacts to biological resources to less
than significant levels. The nighttime hauling of oversized loads would not change any
construction-related aspects of the previously analyzed project pertaining to biological resources.
The Modified Project would not change any operational aspects of the previously analyzed project.
Following implementation of Draft EIR Mitigation Measure BIO-2, as modified by Addendum No. 1, and considering the short-term duration of construction staging activities, the Modified Project would not result in new significant impacts or a substantial increase in previously identified significant impacts pertaining to biological resources.
BIO-2 Should construction activities occur within the nesting season, all suitable
habitat surrounding the project site and Orange County Sanitation District (OC San) Plant No. 2 shall be thoroughly surveyed for the presence of nesting birds by a qualified biologist, defined as an individual with a bachelor’s degree or above in a biological science field and demonstrated field experience, within three days prior to commencement of site disturbance activities.
Addendum No. 2 to the Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project (Project No. 5-67)
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If an active avian nest is discovered in proximity to the project site or OC San Plant No. 2 during the nesting bird survey, construction activities (those
activities that could result in direct or indirect impacts to active nests either
through noise, light, or physical contact) shall stay outside of a 300- foot buffer around the active nest. For raptor species, this buffer shall be expanded to 500 feet. The qualified biologist shall be present to delineate the boundaries of the buffer area and to monitor the active nest in order to ensure that nesting
behavior is not adversely affected by construction activities. If the qualified biologist determines that nesting behavior is adversely affected by construction activities, the qualified biologist shall halt construction activities that result in the adverse effect and file a written report to OC San and the construction contractor stating the recommended course of action. The buffer area and
limitations on construction may be reduced upon approval by the California Department of Fish and Wildlife, and only if the nesting behaviors are not disrupted by construction activities, as determined by the qualified biologist. Once the young have fledged, normal construction activities shall be allowed to occur.
Cultural Resources
The potential cultural resources impacts associated with the temporary use of the Adjacent Pump Station Work Area for construction staging purposes were analyzed in the Draft EIR. (Draft EIR, p. 3-12, 3-13, 5.4-15, 5.4-16.)
The potential cultural resources impacts associated with the temporary use of OC
San Plant No. 2 for construction staging purposes were analyzed in Addendum No. 1. (Addendum No. 1, p. 14.) Overall, as no historic resources are located within the project area, and as no grading or excavation is proposed at project staging areas, impacts to cultural resources for the previously analyzed project were determined to be less than significant.
The Modified Project would include an additional construction staging location at the Bayside Village Marina Staging Area, a portion of which was considered for staging in the Draft EIR. Activities at construction staging areas under the Modified Project would be temporary during construction, would cease when construction is completed, and would not require any ground disturbing activities that could impact previously undiscovered
cultural resources. Construction impacts would be less than significant. The nighttime hauling of oversized loads would not change any construction-related aspects of the previously analyzed project pertaining to cultural resources.
The Modified Project would not change any operational aspects of the previously analyzed project.
The Modified Project, therefore, would not result in new significant impacts or a substantial increase in previously identified significant impacts pertaining to cultural resources.
Addendum No. 2 to the Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project (Project No. 5-67)
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Geology and Soils
The potential geology and soils impacts associated with the temporary use of the
Adjacent Pump Station Work Area for construction staging purposes were analyzed in the
Draft EIR. (Draft EIR, p. 3-12, 3-13, 5.4-15, 5.4-16.)
The potential geology and soils impacts associated with the temporary use of OC San Plant No. 2 for construction staging purposes were analyzed in Addendum No. 1. (Addendum No. 1, p. 15.) Identified changes since the Draft EIR were limited to the
addition of soil drying/stockpiling at the new staging area, which could result in erosion. However, Addendum No. 1 required compliance with SCAQMD Rule 403 during construction to prevent fugitive dust, as well as compliance with OC San established protocols and existing regulations to minimize the potential of erosion at proposed staging areas during construction. Overall, geology and soils impacts associated with the
previously analyzed project were determined to be less than significant. As the Modified Project would include the Bayside Village Marina Staging Area, the majority of which was previously analyzed in the Draft EIR. As described in the Draft EIR, the Modified Project would not be located on a geologically sensitive area, including
within an earthquake fault zone or zones prone to landslides, lateral spreading, subsidence, liquefaction or collapse. Proposed staging activities under the Modified Project would be temporary during construction, would cease when construction is completed, and would not require any new ground disturbing activities not previously considered in the Draft EIR that could impact previously undiscovered paleontological resources. Additionally, the
Modified Project would not result in any new stockpiling activities that could result in fugitive dust emissions or erosion. The nighttime hauling of oversized loads would not change any construction-related aspects of the previously analyzed project. No new significant geology and soils impacts would result from implementation of the Modified Project.
The Modified Project would not change any operational aspects of the previously analyzed project. The Modified Project, therefore, would not result in new significant impacts or a
substantial increase in previously identified significant impacts pertaining to geology and soils.
Greenhouse Gas Emissions
The potential greenhouse gas (GHG) emissions impacts associated with the temporary use of the Adjacent Pump Station Work Area for construction staging purposes
were analyzed in the Draft EIR. (Draft EIR, p. 3-12, 3-13, 5.6-11, 5.6-12, 5.6-13.)
The potential GHG emission impacts associated with the temporary use of OC San Plant No. 2 for construction staging purposes were analyzed in Addendum No. 1. (Addendum No. 1, p. 15, 16.) Identified changes since the Draft EIR were limited to the addition of new haul truck trips (approximately 1,674) to and from the new staging area.
Nevertheless, it was determined that emissions created by off-road construction equipment
Addendum No. 2 to the Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project (Project No. 5-67)
12
and on-road vehicles (including haul truck trips) affiliated with construction staging areas would not exceed the SCAQMD’s GHG emissions significance thresholds, and therefore
would not conflict with an applicable plan, policy, or regulation adopted for the purpose of
reducing GHG emissions. Impacts for the previously analyzed project related to GHG emissions were determined to be less than significant. The Modified Project would include the Bayside Village Marina Staging Area, a
majority of which was considered for staging in the Draft EIR. The Modified Project would allow nighttime hauling of oversized loads at the project driveway at East Coast Highway. However, the Modified Project would not require additional hauling, compared to that analyzed in the Draft EIR, nor would the Modified Project change any staging/hauling activities at Lower Castaways Park or OC San Plant No. 2. As such, it is not anticipated
that the Modified Project would exceed the SCAQMD’s GHG emissions significance threshold. Further, it is acknowledged that by adding an additional staging area in proximity to construction activities, the Modified Project has the potential to reduce GHG emissions due to fewer/shorter construction truck trips.
The Modified Project would not change operational aspects of the previously
analyzed project. As such, it is not anticipated that the Modified Project would conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing GHG emissions, as these plans are primarily concerned with long-term impacts.
The Modified Project, therefore, would not result in new significant impacts or a substantial increase in previously identified significant impacts pertaining to GHG
emissions.
Hazards and Hazardous Materials
The potential hazards and hazardous materials impacts associated with the temporary use of the Adjacent Pump Station Work Area for construction staging purposes were analyzed in the Draft EIR. (Draft EIR, p. 3-12, 3-13, 5.5-15, 5.7-13, 5.7-14, 5.7-15,
4.7-16, 5.7-17, 5.7-20.)
The potential hazards and hazardous materials impacts associated with the temporary use of OC San Plant No. 2 for construction staging purposes were analyzed in Addendum No. 1. (Addendum No. 1, p. 16, 17, 18, 19.) Identified changes since the Draft EIR include the presence of existing soil contamination and existing hazardous materials
site conditions documented at OC San Plant No. 2, which could expose humans to
hazardous substances through an accidental release. Nonetheless, it was determined that compliance with the National Pollutant Discharge Elimination System (NPDES) General Permit, Waste Discharge Requirements for Discharges of Storm Water Runoff Associated with Construction Activities, impacts would be less than significant. The NPDES General
Permit requires the proper handling and discharge of harmful pollutants that could affect water quality in the area. Therefore, compliance with the NPDES General Permit would ensure that any harmful pollutants or hazardous materials would be properly handled and disposed of to prevent unsafe exposure to construction workers. As project construction would require temporary lane closures to allow for staging and work area access, and as
OC San Plant No. 2 is situated in the proximity of identified evacuation routes for the
Addendum No. 2 to the Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project (Project No. 5-67)
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Tsunami Hazard Zone, the previously analyzed project included Mitigation Measure TRA-1, as modified by Addendum No. 1, to require that emergency access is maintained during
all construction activities.
The Modified Project would include the Bayside Village Marina Staging Area, the majority of which was considered for staging in the Draft EIR. As discussed in the Draft EIR, staging at this location would not occur at an existing listed hazardous materials site. The Modified Project’s proposed staging activities would be temporary during
construction, would cease when construction is completed, and would not involve any
demolition of on-site structures or ground disturbing activities. Additionally, as construction staging would not require dredging or earthwork, it was determined that impacts related to the routine transport, use, or disposal of hazardous materials, or accident conditions involving the release of hazardous materials would be less than significant.
Further, the Modified Project’s use of potentially hazardous materials associated with truck
hauling operations, including oils, lubricants, and vehicle fuels, would comply with applicable Federal, State and local regulatory requirements. Mitigation Measure TRA-1, as modified by Addendum No. 1, would apply to the Modified Project to ensure that emergency response and evacuation is maintained during construction.
Regarding emergency access, the Modified Project proposes ingress and egress for both renters and project construction vehicles would be provided via the existing driveway to the property along the west side of Bayside Drive. For larger truck loads, both ingress and egress would occur at the vehicle ingress of the driveway, as depicted in Exhibit 1. As larger trucks are unable to complete the exit turn in the egress lane, larger trucks would
exit through the guard shack ingress point and utilize a flagger at that time. All other
vehicles would exit through the egress point of the guard shack. In order to ensure that these activities occur, Draft EIR Mitigation Measure TRA-1, as modified by Addendum No. 1, would require a Construction Management Plan (CMP) to identify necessary traffic controls and detours, and a construction phasing plan to reduce impacts to local streets and
plan for traffic control signage and detours along identified haul routes. The CMP would
also specify the hours during which hauling activities could occur and would require traffic control barricades, cones, flaggers, and/or warning signs to reduce construction-related impacts to adjacent streets. With compliance with TRA-1, temporary construction-related impacts would be less than significant.
The Modified Project would also allow nighttime hauling of oversized loads at the project driveway at East Coast Highway subject to applicable Caltrans permit(s). Nighttime hauling of oversized loads would reduce potential traffic hazard conflicts with vehicles, bicyclists, and pedestrians, as oversized hauling would occur in the nighttime hours when these activities are less likely to occur. This aspect of the Modified Project would result in
less impacts than those considered as part of the Draft EIR, where these activities occurred solely during daytime hours. As such, the Modified Project would not result in new significant impacts or a substantial increase in previously identified significant impacts pertaining to hazards and hazardous materials during construction.
The Modified Project would not change any operational aspects of the previously
analyzed project.
Addendum No. 2 to the Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project (Project No. 5-67)
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Following implementation of Draft EIR Mitigation Measure TRA-1, as modified by Addendum No. 1, and considering the short-term duration of staging activities at the
Bayside Village Marina Staging Area, the Modified Project would not result in new
significant impacts or a substantial increase in previously identified significant impacts pertaining to hazards and hazardous materials.
TRA-1 Prior to initiation of construction activities, engineering drawings and
specifications, and/or contractor shop drawings shall be prepared by the Project
Engineer, or designee, and submitted for review and approval by the Orange
County Sanitation District, California Department of Transportation (Caltrans),
City of Huntington Beach Public Works Department, and the City of Newport
Beach Public Works Department. These documents shall, at a minimum,
address the following:
• Traffic control protocols shall be specified for any lane closure, detour,
or other disruption to traffic circulation, including bicycle and
pedestrian trails. Disruption to traffic circulation shall be minimized to
the greatest extent feasible. Bicycle and pedestrian trails shall remain
open, to the greatest extent feasible, during construction or shall be re-
routed to ensure continued connectivity.
• Bus stop access impacts shall be coordinated with, and approved by, the
Orange County Transportation Authority.
• At least one week before any construction activities that would affect
travel on nearby roadways, the construction contractor shall notify the
City of Huntington Beach Public Works Department, City of Newport
Beach Public Works Department and Caltrans, as applicable, of
construction activities that could impede movement (such as lane
closures) along roadways, to allow for planning temporary detours or
identifying alternative emergency access routes where appropriate.
Surrounding property owners shall also be notified of project activities
through advanced mailings.
• Identify construction vehicle haul routes for the delivery of construction
materials (i.e., lumber, tiles, piping, windows, etc.) to the site; necessary
traffic controls and detours; and a construction phasing plan for the
project to reduce impacts to local streets and plan for traffic control
signage and detours along identified haul routes to minimize impacts to
existing traffic flow.
• Specify the hours during which hauling activities can occur and methods
to mitigate construction-related impacts to adjacent streets such as
traffic control barricades, cones, flaggers, and warning signs.
• Require the contractor to keep all haul routes clean and free of debris,
including but not limited to gravel and dirt resulting from project
Addendum No. 2 to the Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project (Project No. 5-67)
15
construction. The Contractor shall clean adjacent streets, as directed by
the Orange County Sanitation District, of any project material which
may have been spilled, tracked, or blown onto adjacent City of Newport
Beach, City of Huntington Beach, and Caltrans streets or areas.
• Hauling of oversize loads shall be allowed between the hours of 9:00
a.m. and 3:00 p.m. only, Monday through Friday. No hauling or
transport shall be allowed during nighttime hours (10:00 p.m. to 7:00
a.m.), weekends, or Federal holidays, with the exception of overside
loads for the purpose of minimizing safety risk. Oversized hauling
activities may occur along Coast Highway in the nighttime hours subject
to the applicable Caltrans permit. All oversized loads shall not occur
during peak traffic hours of 7:00 a.m. to 9:00 a.m. and 5:00 p.m. to 7:00
p.m. on weekdays. Any oversized loads utilizing Coast Highway shall
obtain a Caltrans permit for such activities.
• Use of local streets shall be prohibited, except when required to provide
direct access to the project site and in compliance with the approved
project haul routes.
• Haul trucks entering or exiting public streets shall yield to public traffic
at all times.
• If hauling operations cause any damage to existing pavement, streets,
curbs, and/or gutters along the haul route, the contractor shall be fully
responsible for repairs. The repairs shall restore the damaged property
to its original condition.
• All construction-related staging of vehicles shall be kept out of the
adjacent public roadways and shall occur on the project site or within
additional off-street staging areas previously identified and arranged.
• Construction-related lane closures would only occur between the hours
of 8:30 a.m. and 3:30 p.m., Monday through Friday, with the exception
of oversized hauling activities. More or less restrictive closure hours
may be prescribed by the City.
• Use of a construction flagperson (as deemed appropriate by the Orange
County Sanitation District) to assist in maintaining efficient vehicle
travel in both directions (particularly during peak travel hours) and use
of construction signage and safe detour routes for pedestrians and
bicyclists when travel lanes and sidewalks along Coast Highway are
affected.
• The engineering drawings and specifications shall meet standards
established in the current California Manual on Uniform Traffic Control
Device (MUTCD).
Addendum No. 2 to the Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project (Project No. 5-67)
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Hydrology & Water Quality
The potential hydrology and water quality impacts associated with the temporary
use of the Adjacent Pump Station Work Area for construction staging purposes were
analyzed in the Draft EIR. (Draft EIR, p. 3-12, 3-13, 5.8-16, 5.8-17, 5.8-18, 5.8-19, 8-6.)
The potential hydrology and water quality impacts associated with the temporary use of OC San Plant No. 2 for construction staging purposes were analyzed in Addendum No. 1. (Addendum No. 1, p. 19, 20.) Identified changes since the Draft EIR included
stockpiling activities at the new staging area, which could result in water contamination due to erosion. Additionally, it should be noted that the Draft EIR analyzed staging areas within the Santa Ana Region Basin Plan (Basin Plan) within the jurisdiction of the Santa Ana Regional Water Quality Control Board (RWQCB), but the OC San Plant No. 2 is located within the Orange County Groundwater Basin and, therefore, is within the
jurisdiction of the Orange County Water District (OCWD). Nevertheless, it was determined that the previously analyzed project would result in less than significant impacts related to water quality and hydrology.
The Modified Project would include the Bayside Village Marina Staging Area, the majority of which was considered for staging in the Draft EIR. As described in the Draft
EIR, staging at this location would not be within a flood hazard. (Draft EIR, p. 8-6.) However, the site is located within an area that could be subject to inundation as a result of a tsunami or seiche within Newport Bay. The Modified Project’s staging activities would be temporary during construction, cease when construction is completed, and would not require any ground disturbing activities that could interfere with groundwater recharge or
substantially alter the existing drainage pattern of the site or area. Additionally, the Modified Project would not require any changes to hauling or stockpiling that could result in water contamination due to erosion or any increased risk of release of pollutants due to inundation from a tsunami or seiche. The Modified Project would not result in any new significant impacts pertaining to increased water demand during construction, compared to
that considered in the previously analyzed project documentation. The nighttime hauling of oversized loads would not change any construction-related aspects of the previously analyzed project pertaining to hydrology and water quality. As such, the Modified Project would not result in any new significant impacts or any substantial increases in previously identified hydrology or water quality impacts during construction.
The Modified Project would not change any operational aspects of the previously analyzed project. The Modified Project, therefore, would not result in new significant impacts or a substantial increase in previously identified significant impacts pertaining to hydrology and
water quality.
Land Use and Planning
The potential land use and planning impacts associated with the temporary use of
the Adjacent Pump Station Work Area for construction staging purposes were analyzed in the Draft EIR. (Draft EIR, p. 3-12, 3-13, 5.9-8., 5.9-9, 5.9-12, 5.9-14, 5.9-15, 5.9-16, 5.9-
17).
Addendum No. 2 to the Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project (Project No. 5-67)
17
The potential land use and planning impacts associated with the temporary use of OC San Plant No. 2 for construction staging purposes were analyzed in Addendum No. 1.
(Addendum No. 1, p. 20, 21.) Overall, as no changes to land uses or zoning designations
would occur as a result of temporary construction staging, impacts to land use and planning for the previously analyzed project were determined to be less than significant.
The Modified Project would include the Bayside Village Marina Staging Area, the majority of which was considered for staging in the Draft EIR. The Modified Project’s
proposed staging activities would be temporary during construction, would cease when
construction is completed, and would not require or result in changes to land uses or zoning designations. Additionally, during construction staging, including truck ingress and egress to the staging site, public access to the marina, including rented areas for RV storage and boat slips, would remain accessible. As such, the Modified Project would be consistent
with the recreational policies of the California Coastal Act. Last, the nighttime hauling of
oversized loads would not change any construction-related aspects of the previously analyzed project pertaining to land use and planning. Construction impacts would be less than significant.
The Modified Project would not change any operational aspects of the previously
analyzed project.
The Modified Project, therefore, would not result in new significant impacts or a substantial increase in previously identified significant impacts pertaining to land use and planning.
Noise
The potential noise impacts associated with the temporary use of the Adjacent Pump Station Work Area for construction staging purposes were analyzed in the Draft EIR. (Draft EIR, p. 3-12, 3-13, 5.10-12, 5.10-13, 5.10-14, 5.10-15, 5.10-16, 5.10-17, 5.10-18).
The potential noise impacts associated with the temporary use of OC San Plant No. 2 for construction staging purposes were analyzed in Addendum No. 1. (Addendum No. 1,
p. 21, 22, 23.) Identified changes since the Draft EIR are limited to the increase in haul trips (approximately 1,674 trips), which could result in short-term construction noise impacts. However, with implementation of Draft EIR Mitigation Measures NOI-1, as modified by Addendum No. 1, potential noise impacts would be less than significant. Specifically, Mitigation Measure NOI-1 would reduce short-term construction noise
impacts by requiring mobile equipment to be muffled and requiring best management practices such as avoiding noise sensitive uses while hauling and prohibiting construction activities outside of allowable hours specified by the Municipal Code. Mitigation Measure Overall, noise impacts associated with the additional haul truck trips would be temporary and cease upon completion of construction. Impacts for the previously analyzed project
related to noise were determined to be less than significant. The Modified Project would include the Bayside Village Marina Staging Area, the majority of which was considered for staging in the Draft EIR. The Modified Project would not change construction equipment assumptions considered in the Draft EIR. The Modified
Project would allow nighttime hauling of oversized loads at the project driveway at East
Addendum No. 2 to the Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project (Project No. 5-67)
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Coast Highway. However, the Modified Project would not require additional hauling, compared to that analyzed in the Draft EIR, nor would the Modified Project change any
staging/hauling activities at Lower Castaways Park or OC San Plant No. 2.
The Modified Project would allow delivery of oversized loads in the nighttime hours. The Draft EIR analyzed nighttime construction noise at the delivery locations, since the project proposed 24-hour construction activities in these areas for the purpose of replacing the force mains. The addition of nighttime noise as a result of oversized load
deliveries at these locations would not result in substantial increases in the nighttime
lighting at these locations, compared to that analyzed in the Draft EIR. As detailed in the Draft EIR, Mitigation Measure NOI-2 requires the preparation of a Construction Noise Control Plan to demonstrate sensitive receptors would not be disturbed by construction noise levels prior to issuance of demolition or building permits. The Construction Noise
Control Plan would identify noise reduction measures (e.g., temporary construction noise
barriers, sound-attenuating enclosures, etc.) to minimize construction noise levels at off-site sensitive receptors and demonstrate compliance with Municipal Code Chapter 10.26 and 10.28. Compliance with Municipal Code Chapter 10.26 and 10.28 would ensure sensitive receptors are not disturbed outside of allowable construction hours. With the
implementation of Mitigation Measure NOI-2, nighttime noise levels would be reduced
below the City’s nighttime noise standards. As such, sensitive receptors would not be disturbed by construction noise as mitigated nighttime construction noise would not exceed the City’s exterior nighttime noise standard of 50 dBA and/or interior nighttime noise standard of 40 dBA. In conclusion, the addition of nighttime noise as a result of oversized
load deliveries at these locations would not result in substantial increases in the nighttime lighting at these locations, compared to that analyzed in the Draft EIR.
The proposed staging activities at Bayside Village Marina Staging Area would not result in any significant changes to noise analyzed as part of the Draft EIR. Therefore, the Modified Project would not result in new significant impacts or a substantial increase in
previously identified impacts pertaining to noise.
The Modified Project would not change any operational aspects of the previously analyzed project. The Modified Project, therefore, would not result in new significant impacts or a
substantial increase in previously identified significant impacts pertaining to noise.
Addendum No. 2 to the Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project (Project No. 5-67)
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NOI-2 Prior to issuance of Demolition or Building Permits, the Orange County Sanitation District, or designee, shall retain a qualified Acoustical Engineer,
defined as an individual with a bachelor’s degree or above in acoustics, physics,
or another closely related engineering discipline and demonstrated field experience, to prepare a Construction Noise Control Plan. The Construction Noise Control Plan shall identify the types, location, and duration of equipment to be used during project construction. Construction noise levels shall be
quantified and estimated at the nearest sensitive uses (i.e., residences, schools, churches, recreation/park facilities, hospitals, libraries, etc.) within 1,000 feet of the project construction area. Based on proposed construction hours and equipment to be used, the Construction Noise Control Plan shall identify noise reduction measures to minimize construction noise levels at off-site sensitive
uses, demonstrating compliance with the Newport Beach Municipal Code Chapter 10.26 and 10.28. Noise reduction measures may include the use of sound blankets, sound walls/barriers, noise shrouds, and/or limiting the use of heavy noise-emitting equipment to non-sensitive hours (during daytime work hours and not after 5:00 p.m., etc.). The noise reduction measures shall be
included in the project engineering drawings and specifications, and/or contractor shop drawings for review by the City of Newport Beach Planning Division. All noise reduction measures identified in the Construction Noise Control Plan approved by the City of Newport Beach shall be included in all project designs and construction plans for the project.
Population and Housing
The potential population and housing impacts associated with the temporary use of the Adjacent Pump Station Work Area for construction staging purposes were analyzed in the Draft EIR. (Draft EIR, p. 3-12, 3-13, 8-1).
The potential population and housing impacts associated with the temporary use of
OC San Plant No. 2 for construction staging purposes were analyzed in Addendum No. 1. (Addendum No. 1, p. 23.) Impacts associated with the temporary use of construction staging areas during implementation of the previously analyzed project were determined to be less than significant.
The Modified Project would include the Bayside Village Marina Staging Area, the
majority of which was considered for staging in the Draft EIR; there are no existing residents or housing at this proposed staging location. The Modified Project would not cause a change in the labor force resulting in unplanned population growth in the area, nor any operational aspects of the previously analyzed project. Further, the nighttime hauling of oversized loads would not change any aspect of population and housing, as analyzed in
the Draft EIR. The Modified Project, therefore, would not result in new significant impacts or a substantial increase in previously identified significant impacts pertaining to population and housing.
Addendum No. 2 to the Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project (Project No. 5-67)
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Public Services
The potential public services impacts associated with the temporary use of the
Adjacent Pump Station Work Area for construction staging purposes were analyzed in the
Draft EIR. (Draft EIR, p. 3-12, 3-13, 8-1).
The potential public services impacts associated with the temporary use of OC San Plant No. 2 for construction staging purposes were analyzed in Addendum No. 1. (Addendum No. 1, p. 23, 24.) Overall, temporary construction staging activities would not
result in the need for new or physically altered fire, police, school, parks and recreational, or other public service facilities, and impacts would be less than significant.
As discussed above under Population and Housing analysis, the Modified Project would not result in unplanned population growth in the area. As such, it is not anticipated that the Modified Project would require new or physically altered fire, police, school, parks
and recreational, or other public service facilities during construction.
The Modified Project would not change operational aspects of the previously analyzed project.
The Modified Project, therefore, would not result in new significant impacts or a substantial increase in previously identified significant impacts pertaining to public
services.
Recreation
The potential recreation impacts associated with the temporary use of the Adjacent Pump Station Work Area for construction staging purposes were analyzed in the Draft EIR. (Draft EIR, p. 3-12, 3-13, 8-1).
The potential recreation impacts associated with the temporary use of OC San Plant No. 2 for construction staging purposes were analyzed in Addendum No. 1. (Addendum No. 1, p. 24.) Overall, temporary construction staging activities would result in less than significant impacts related to recreation.
As discussed above under Population and Housing analysis, the Modified Project
would not result in unplanned population growth in the area. As such, it is not anticipated that the Modified Project would result in new residents using existing recreational facilities or requiring additional recreational facilities. Additionally, during construction staging, including truck ingress and egress to the staging site, public access to the marina, including rented areas for RV storage and boat slips, would remain accessible. Impacts would be less
than significant. The Modified Project would not result in any new significant impacts or a substantial increase in previously identified significant impacts during construction.
The Modified Project would not change operational aspects of the previously analyzed project.
The Modified Project, therefore, would not result in new significant impacts or a
substantial increase in previously identified significant impacts pertaining to recreation.
Addendum No. 2 to the Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project (Project No. 5-67)
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Transportation
The potential transportation impacts associated with the temporary use of the
Adjacent Pump Station Work Area for construction staging purposes were analyzed in the
Draft EIR. Draft EIR, p. 3-12, 3-13, 5.11-6, 5.11-7, 5.11-8, 5.11-9, 5.11-10, 5.11-11).
The potential transportation impacts associated with the temporary use of OC San Plant No. 2 for construction staging purposes were analyzed in Addendum No. 1. (Addendum No. 1, p. 24, 25, 26, 27.) Identified changes since the Draft EIR are limited to
the increase in haul trips (approximately 1,674 trips), which could result in impacts related to the existing roadway circulation system, transit/bicycle/pedestrian access, hazardous design features, and emergency access. The previously analyzed project determined that implementation of Draft EIR Mitigation Measure TRA-1, as modified by Addendum No. 1, would reduce such impacts to less than significant levels. Specifically, Mitigation
Measure TRA-1 would require implementation of a CMP that would include a variety of measures to minimize traffic safety impacts. Within implementation of Draft EIR Mitigation Measure TRA-1, as modified by Addendum No. 1, it was determined that the previously analyzed project would result in less than significant transportation impacts.
As depicted in Exhibit 1, the Modified Project would require truck access to the
Bayside Village Marina Staging Area, similar to that considered by the previously analyzed project as part of the Draft EIR. The Modified Project proposes ingress and egress for project construction vehicles would be provided via the existing driveway to the property along the west side of Bayside Drive. For larger truck loads, both ingress and egress would occur at the vehicle ingress of the driveway, as depicted in Exhibit 1. As larger trucks are
unable to complete the exit turn in the egress lane, larger trucks would exit through the guard shack ingress point and utilize a flagger at that time. All other vehicles would exit through the egress point of the guard shack. In order to ensure that these activities occur, Draft EIR Mitigation Measure TRA-1, as modified by Addendum No. 1, would require a Construction Management Plan (CMP) to identify necessary traffic controls and detours,
and a construction phasing plan to reduce impacts to local streets and plan for traffic control signage and detours along identified haul routes. The CMP would also specify the hours during which hauling activities could occur and would require traffic control barricades, cones, flaggers, and/or warning signs to reduce construction-related impacts to adjacent streets. With compliance with TRA-1, emergency access would be maintained.
The Modified Project would also allow nighttime hauling of oversized loads at the project driveway at East Coast Highway subject to applicable Caltrans permit(s). Nighttime hauling of oversized loads would reduce potential traffic hazard conflicts with vehicles, bicyclists, and pedestrians, as oversized hauling would occur in the nighttime hours when these activities are less likely to occur. This aspect of the Modified Project would result in
less impacts than those considered as part of the Draft EIR, where these activities occurred solely during daytime hours. As such, the Modified Project would not result in new significant impacts or a substantial increase in previously identified significant impacts pertaining to transportation during construction.
The Modified Project would not change any operational aspects of the previously
analyzed project.
Addendum No. 2 to the Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project (Project No. 5-67)
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With implementation of Draft EIR TRA-1, as modified by Addendum No. 1, the Modified Project would not result in new significant impacts or a substantial increase in
previously identified significant impacts pertaining to transportation.
TRA-1 Prior to initiation of construction activities, engineering drawings and
specifications, and/or contractor shop drawings shall be prepared by the Project
Engineer, or designee, and submitted for review and approval by the Orange
County Sanitation District, California Department of Transportation (Caltrans),
City of Huntington Beach Public Works Department, and the City of Newport
Beach Public Works Department. These documents shall, at a minimum,
address the following:
• Traffic control protocols shall be specified for any lane closure, detour,
or other disruption to traffic circulation, including bicycle and
pedestrian trails. Disruption to traffic circulation shall be minimized to
the greatest extent feasible. Bicycle and pedestrian trails shall remain
open, to the greatest extent feasible, during construction or shall be re-
routed to ensure continued connectivity.
• Bus stop access impacts shall be coordinated with, and approved by, the
Orange County Transportation Authority.
• At least one week before any construction activities that would affect
travel on nearby roadways, the construction contractor shall notify the
City of Huntington Beach Public Works Department, City of Newport
Beach Public Works Department and Caltrans, as applicable, of
construction activities that could impede movement (such as lane
closures) along roadways, to allow for planning temporary detours or
identifying alternative emergency access routes where appropriate.
Surrounding property owners shall also be notified of project activities
through advanced mailings.
• Identify construction vehicle haul routes for the delivery of construction
materials (i.e., lumber, tiles, piping, windows, etc.) to the site; necessary
traffic controls and detours; and a construction phasing plan for the
project to reduce impacts to local streets and plan for traffic control
signage and detours along identified haul routes to minimize impacts to
existing traffic flow.
• Specify the hours during which hauling activities can occur and methods
to mitigate construction-related impacts to adjacent streets such as
traffic control barricades, cones, flaggers, and warning signs.
• Require the contractor to keep all haul routes clean and free of debris,
including but not limited to gravel and dirt resulting from project
construction. The Contractor shall clean adjacent streets, as directed by
the Orange County Sanitation District, of any project material which
Addendum No. 2 to the Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project (Project No. 5-67)
23
may have been spilled, tracked, or blown onto adjacent City of Newport
Beach, City of Huntington Beach, and Caltrans streets or areas.
• Hauling of oversize loads shall be allowed between the hours of 9:00
a.m. and 3:00 p.m. only, Monday through Friday. No hauling or
transport shall be allowed during nighttime hours (10:00 p.m. to 7:00
a.m.), weekends, or Federal holidays, with the exception of overside
loads for the purpose of minimizing safety risk. Oversized hauling
activities may occur along Coast Highway in the nighttime hours subject
to the applicable Caltrans permit. All oversized loads shall not occur
during peak traffic hours of 7:00 a.m. to 9:00 a.m. and 5:00 p.m. to 7:00
p.m. on weekdays. Any oversized loads utilizing Coast Highway shall
obtain a Caltrans permit for such activities.
• Use of local streets shall be prohibited, except when required to provide
direct access to the project site and in compliance with the approved
project haul routes.
• Haul trucks entering or exiting public streets shall yield to public traffic
at all times.
• If hauling operations cause any damage to existing pavement, streets,
curbs, and/or gutters along the haul route, the contractor shall be fully
responsible for repairs. The repairs shall restore the damaged property
to its original condition.
• All construction-related staging of vehicles shall be kept out of the
adjacent public roadways and shall occur on the project site or within
additional off-street staging areas previously identified and arranged.
• Construction-related lane closures would only occur between the hours
of 8:30 a.m. and 3:30 p.m., Monday through Friday, with the exception
of oversized hauling activities. More or less restrictive closure hours
may be prescribed by the City.
• Use of a construction flagperson (as deemed appropriate by the Orange
County Sanitation District) to assist in maintaining efficient vehicle
travel in both directions (particularly during peak travel hours) and use
of construction signage and safe detour routes for pedestrians and
bicyclists when travel lanes and sidewalks along Coast Highway are
affected.
• The engineering drawings and specifications shall meet standards
established in the current California Manual on Uniform Traffic Control
Device (MUTCD).
Addendum No. 2 to the Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project (Project No. 5-67)
24
Tribal Cultural Resources
The potential tribal cultural resources impacts associated with the temporary use of
the Adjacent Pump Station Work Area for construction staging purposes were analyzed in
the Draft EIR. (Draft EIR, p. 3-12, 3-13, 5.4-15, 5.4-16.)
The potential tribal cultural resources impacts associated with the temporary use of OC San Plant No. 2 for construction staging purposes were analyzed in Addendum No. 1. (Addendum No. 1, p. 27.) Overall, as no tribal cultural resources are located within the
project area, and as no grading or excavation is proposed at project staging areas, impacts to tribal cultural resources for the previously analyzed project were determined to be less than significant.
The Modified Project would include the Bayside Village Marina Staging Area, the majority of which was considered for staging in the Draft EIR. Activities at construction
staging areas under the Modified Project would be temporary during construction, would
cease when construction is completed, and would not require any new ground disturbing activities, compared to the Draft EIR, that could impact previously undiscovered tribal cultural resources. Last, the nighttime hauling of oversized loads would not change any construction-related aspects of the previously analyzed project pertaining to tribal cultural
resources. The Modified Project would not result in new significant impacts or a substantial
increase in previously identified significant impacts during construction.
The Modified Project would not change any operational aspects of the previously analyzed project.
The Modified Project, therefore, would not result in new significant impacts or a
substantial increase in previously identified significant impacts pertaining to tribal cultural resources.
Utilities
The potential utilities impacts associated with the temporary use of the Adjacent Pump Station Work Area for construction staging purposes were analyzed in the Draft EIR.
(Draft EIR, p. 3-12, 3-13, 6.1, 6.2, 6-14).
The potential utilities impacts associated with the temporary use of OC San Plant No. 2 for construction staging purposes were analyzed in Addendum No. 1. (Addendum No. 1, p. 28.) The previously analyzed project determined that temporary construction staging activities would result in less than significant impacts related to utilities.
The Modified Project would include the Bayside Village Marina Staging Area, the majority of which was considered for staging in the Draft EIR. Staging activities at this location would include storage of equipment and materials, loading and unloading of equipment and material, limited employee parking, and truck ingress/egress access. These
proposed activities would be temporary and would cease when construction is completed. The Modified Project would also allow nighttime hauling of oversized loads. Such activities would not require any increases in the use of water, electrical, natural gas, or telecommunications facilities, generation of solid waste, or increased stormwater,
Addendum No. 2 to the Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project (Project No. 5-67)
25
compared to that considered under the previously analyzed project in the Draft EIR. As such, no new physical changes to the environment would result in this regard.
The Modified Project would not change any operational aspects of the previously
analyzed project.
The Modified Project, therefore, would not result in new significant impacts or a substantial increase in previously identified significant impacts pertaining to utilities and service systems.
Wildfire
The potential wildfire impacts associated with the temporary use of the Adjacent Pump Station Work Area for construction staging purposes were analyzed in the Draft EIR. (Draft EIR p. 8-11 and 8-12.)
The potential wildfire impacts associated with the temporary use of OC San Plant
No. 2 for construction staging purposes were analyzed in Addendum No. 1. (Addendum No. 1, p. 28, 29.) The previously analyzed project determined that temporary construction staging areas would not be located within very high, high, or moderate fire hazard severity zones, and therefore impacts related to wildland fire hazards would be less than significant.
As the Modified Project would include a new staging area located within a work
area considered under the previously analyzed project, the Modified Project would not be
located within a very high, high, or moderate fire hazard severity zone and would not result in new significant impacts or a substantial increase in the severity of previously identified significant impacts pertaining to wildfires. Further, the nighttime hauling of oversized loads would not change any construction-related aspects of the previously analyzed project
pertaining to wildfire resources.
Other CEQA Considerations/Energy
The potential energy impacts associated with the temporary use of the Adjacent Pump Station Work Area for construction staging purposes were analyzed in the Draft EIR. (Draft EIR p. 6-1, 6-2, and 6-7 through 6-18.)
The potential energy impacts associated with the temporary use of OC San Plant No. 2 for construction staging purposes were analyzed in Addendum No. 1. (Addendum No. 1, p. 29.) Identified changes since the Draft EIR were limited to the addition of new haul truck trips (approximately 1,674) to and from the new staging area. Truck trips from soil hauling activities would generate an increase in short-term vehicle trips on the
circulation system during construction. The total fuel consumption is anticipated to have a nominal effect on the local and regional energy supplies. Additionally, haul trips and drying/stockpiling activities would be temporary during construction and would cease when construction is completed. Further, all construction activities would adhere to Federal, State, and local requirements for fuel efficiency (e.g., low carbon fuel standards,
as applicable). Overall, impacts related to energy were determined to be less than significant.
Addendum No. 2 to the Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project (Project No. 5-67)
26
The Modified Project would include the Bayside Village Marina Staging Area, the
majority of which was considered for staging in the Draft EIR. The Modified Project would
allow nighttime hauling of oversized loads at the project driveway at East Coast Highway.
However, the Modified Project would not require additional hauling, compared to that
analyzed in the Draft EIR, and would not change any staging/hauling activities at Lower
Castaways Park or OC San Plant No. 2. Rather, by adding an additional staging area in
proximity to construction activities, the Modified Project has the potential to reduce energy
use due to fewer/shorter construction truck trips. As such, the Modified Project would not
change the effects on the local and regional energy supplies, compared to the previously
analyzed project, and therefore would not result in new significant impacts or a substantial
increase in previously identified significant impacts pertaining to energy.
ATTACHMENT 1
ORANGE COUNTY SUPERIOR COURT CASE NO. 30-2021-00194238 RULING
SUPERIOR COURT OF CALIFORNIA, COUNTY OF ORANGE
Civil Complex Center
751 W. Santa Ana Blvd
Santa Ana, CA 92701
SHORT TITLE: BAYSIDE VILLAGE MARINA, LLC vs. ORANGE COUNTY SANITATION DISTRICT
CLERK'S CERTIFICATE OF MAILING/ELECTRONIC
SERVICE
CASE NUMBER:
30-2021-01194238-CU-WM-CXC
I certify that I am not a party to this cause. I certify that the following document(s), dated , have been transmitted
electronically by Orange County Superior Court at Santa Ana, CA. The transmission originated from Orange County
Superior Court email address on December 16, 2022, at 2:21:32 PM PST. The electronically transmitted document(s) is in
accordance with rule 2.251 of the California Rules of Court, addressed as shown above. The list of electronically served
recipients are listed below:
Clerk of the Court, by: , Deputy
NOSSAMAN LLP
JERSKINE@NOSSAMAN.COM
NOSSAMAN LLP
JFLYNN@NOSSAMAN.COM
WOODRUFF, SPRADLIN & SMART, APC
BHOGIN@WSS-LAW.COM
WOODRUFF, SPRADLIN & SMART, APC
BPATTERSON@WSS-LAW.COM
WOODRUFF, SPRADLIN & SMART, APC
RHAGER@WSS-LAW.COM
CLERK'S CERTIFICATE OF MAILING/ELECTRONIC SERVICE
V3 1013a (June 2004) Code of Civ. Procedure , § CCP1013(a)
JUDICIAL OFFICER PRESIDING:William Claster
COUNTY OF ORANGE
CIVIL COMPLEX CENTER
DATE:12/16/2022 DEPT:CX104TIME:02:16:00 PM
CLERK:G.HernandezREPORTER/ERM:NoneBAILIFF/COURT ATTENDANT:.None
CASE INIT.DATE:04/01/2021CASENO:30-2021-01194238-CU-WM-CXCCASETITLE:BAYSIDE VILLAGE MARINA,LLC vs.ORANGE COUNTY SANITATIONDISTRICTCASE CATEGORY: Civil - Unlimited CASE TYPE:Writ of Mandate
EVENT ID/DOCUMENT ID: 73909236
EVENT TYPE:Under Submission Ruling
RE PETITIONER'S WRIT OF MANDATE There are no appearances by any party.
The Court,having taken the above-entitled matter under submission on 12/14/2022 and having fullyconsideredtheargumentsofallparties,both written and oral,as well as the evidence presented,nowissues its ruling. The Court's ruling is attached hereto and incorporated herein by reference.
Court orders clerk to give notice.
DATE: 12/16/2022
DEPT: CX104 Calendar No.
Page 1
BAYSIDE VILLAGE MARINA LLC v. ORANGE COUNTY SANITATION DISTRICT 21-
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Ruling Page 1
Petitioner Bayside Village Marina LLC (Bayside) seeks a writ of mandate
compelling Respondent Orange County Sanitation District (“OCSD” or the
“District”) to vacate and set aside its approval of (1) the OCSD’s Bay Bridge Pump
Station and Force Mains (“BBPS”) replacement project (“Project”) located on East
Coast Highway in Newport Beach, and (2) the certification of the Recirculated
Environmental Impact Report (“REIR”) for the Project. For the reasons set forth
below, the Court GRANTS a limited writ as set forth below.
I. BACKGROUND
Bayside is the owner of 31.4 acres of property located at East Coast Highway in
the City of Newport Beach, California between Newport Channel and Bayside
Drive. (ROA 25, First Amended Verified Petition (Petition), ¶ 9; AR230.)
Approximately 24 acres of Bayside’s property are developed with mobile homes,
and the remaining seven acres contain an outdoor storage space of RVs and small
boats, parking and restrooms facilities for the Bayside Marina, a kayak rental and
launch facility, parking and access to Pearson’s Port seafood market, and marine
service equipment storage under the Coast Highway Bridge (“BVM Property”).
(AR230, 011290.)
The seven acres are being developed as the “Back Bay Landing” Project, which is a
mixed-use development that will be implemented pursuant to the Newport
Beach- and Coastal Commission-approved Back Bay Planned Community
Development Plan (“PCDP”). It will have a boat storage facility, retail stores and
recreational marine-related facilities and residential units. (AR226, 230, 3274,
7539-97; Petition, ¶ 9.) Bayside is also the developer of this Back Bay project.
(Petition, ¶ 9.)
OCSD owns and operates the BBPS, which is located at 300 East Coast Highway in
Newport Beach, just east of the Newport Bay Channel. (ROA 103, Opp., p. 8;
AR186.) BBPS transports sewage or wastewater through pipelines to OCSD’s
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Ruling Page 2
sewage treatment plant in Huntington Beach and is a piece of critical
infrastructures that conveys 50-60% of the total wastewater flow generated in
Newport Beach. (ROA 103, Opp., p. 8; AR186.) BBPS is located on the southern
boundary of Bayside’s property, is surrounded on three sides by that property,
and is adjacent to the Back Bay Landing Project. (AR230, 3206.)
The District’s Project involves the construction of a new, larger pump station
extending 100 feet to the west of the existing pump station and the installation of
new force mains. (AR186 and 237.) The new pump station facilities will include a
pump station, generator and odor control facilities. (AR186, 230.)
Planning on the Project started in 2013. (AR3206.) Since the Bayside Property, and
particularly the Back Bay Landing Project, surrounds the Project, from 2014-2016,
Bayside and OCSD exchanged information and worked together to discuss
alternatives for the Project. (See e.g., AR3206, 6371-72, 7040-43,7090, 7324,
7342-43, 15667, 16128-131.)
In June 2017, OCSD published a draft EIR that analyzed a version of the Project
involving the demolition of the existing facility, construction of a new and larger
facility adjacent to Bayside Drive and installation of force main improvements
beneath the Newport Bay Channel north of the Bay Bridge. (AR236, AR9383-84.)
The District never presented the 2017 Final EIR to its Board of Directors for
approval due to conflicts with the planned development of the Back Bay Landing
Project. (AR236, AR1501-1506.)
In July 2019, OCSD published a recirculated EIR with three alternatives for the
Project. (AR236, AR11613-14.) During the public comment period, there were
concerns regarding the three conceptual site plans, including confusion about one
of the alternatives known as the South Pump Station. (AR236.) OCSD did not
present the 2019 EIR to the OCSD Board.
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Instead, OCSD decided to select one conceptual site plan and construction
method and update the EIR in its entirety. (AR236.) The concept chosen and
analyzed in the 2020 recirculated EIR (REIR) is the Adjacent Pump Station, which is
essentially the South Pump Station alternative in the 2019 REIR. (AR237.)
The Final EIR (FEIR) was published in January 2021 and approved on March 1,
2021. (AR1-3.)
II. OVERVIEW OF CEQA PROCESS
“CEQA is a comprehensive scheme designed to provide long-term protection to
the environment. [Citation.]” (Mountain Lion Foundation v. Fish & Game Com.
(1997) 16 Cal.4th 105, 112.) It applies to “discretionary projects proposed to be
carried out or approved by public agencies.” (Pub. Resources Code, § 21080(a).)
“In enacting CEQA, the Legislature declared its intention that all public agencies
responsible for regulating activities affecting the environment give prime
consideration to preventing environmental damage when carrying out their
duties. [Citations.] CEQA is to be interpreted ‘to afford the fullest possible
protection to the environment within the reasonable scope of the statutory
language.’ [Citation.]” (Mountain Lion Foundation, supra, 16 Cal.4th at p. 112.)
An EIR, which has been described as “the heart of CEQA” (Citizens of Goleta Valley
v. Board of Supervisors (1990) 52 Cal.3d 553, 564), “is required for any project
that a public agency proposes to carry out or approve that may have a significant
effect on the environment. [Citations.] An EIR must describe the proposed project
and its environmental setting, state the objectives sought to be achieved, identify
and analyze the significant effects on the environment, state how those impacts
can be mitigated or avoided, and identify and analyze alternatives to the project,
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among other requirements. [Citations.]” (Ballona Wetlands Land Trust v. City of
Los Angeles (2011) 201 Cal.App.4th 455, 465-66 (Ballona).)
Once a draft EIR is prepared, the public must be notified, and the draft and all
documents it references must be made available for public review and comment.
(Pub. Resources Code, §§ 21091(a), 21092; CEQA Guidelines, § 15087. 1) The
public agency acting as the lead agency then prepares a final EIR, which must
include comments received from the public and from other agencies concerning
the draft EIR, responses to those comments, and any revisions to the draft EIR.
(CEQA Guidelines, §§ 15088, 15132; Ballona, supra, 201 Cal.App.4th at p. 466.)
III. PROJECT DESCRIPTION
A. Overview
Bayside asserts that the EIR description of the Project and its environmental
setting is “inaccurate and unstable.” “The fundamental goal of an EIR is to inform
decision makers and the public of any significant adverse effects a project is likely
to have on the physical environment. [Citations.] To make such an assessment, an
EIR must delineate environmental conditions prevailing absent the project,
defining a baseline against which predicted effects can be described and
quantified. [Citation.]” (Neighbors for Smart Rail v. Exposition Metro Line
Construction Authority (2013) 57 Ca1.4th 439, 447.) This generally includes
providing “a description of the physical environmental conditions in the vicinity of
the project, as they exist at the time the notice of preparation is published, or if
no notice of preparation is published, at the time environmental analysis is
commenced, from both a local and regional perspective.” (Id., at p. 448; see CEQA
Guidelines, § 15125(a).)
1 References to the CEQA Guidelines are to Cal. Code Regs., tit. 14, § 15000 et seq.
BAYSIDE VILLAGE MARINA LLC v. ORANGE COUNTY SANITATION DISTRICT 21-
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“Without accurate and complete information pertaining to the setting of the
project and surrounding uses, it cannot be found that the [EIR] adequately
investigated and discussed the environmental impacts of the development
project.” (San Joaquin Raptor/Wildlife Rescue Center v. County of Stanislaus
(1994) 27 Cal.App.4th 713, 729 (San Joaquin Raptor).) Thus, [i]f the description of
the environmental setting of the project site and surrounding area is inaccurate,
incomplete or misleading, the EIR does not comply with CEQA.” (Cadiz Land Co. v.
Rail Cycle (2000) 83 Cal.App.4th 74, 87.)
B. Failure to Identify Neighboring Commercial Operations
Bayside contends that repeated use of the phrase “RV Storage facility” obscures
“the site’s coastal-dependent, visitor serving uses.” (Pet. Supp. Br. at p. 16.)
Indeed, a number of businesses on the west side of the Project site (e.g.,
Southwind Kayaks, Gondola Adventures) are not mentioned by name anywhere in
any EIR.
While it is true that these businesses are not referenced by name and that the site
is referred to as an RV Storage facility (presumably since RVs are stored near
where the actual construction will take place), those references do not create an
inaccurate picture of the Project. In fact, the EIR refers to these businesses on the
west side of the Project as “commercial” or “commercial recreation marine uses”
in a number of places. (AR230, 234, 260, 392, 436.) The businesses also are listed
on Table 3-1 under “General Commercial.“ (AR235.)
The fact that the site is called an RV Storage facility is not misleading when
considering the EIR as a whole. The above-cited references to commercial activity
and the various maps/photos of the Project site overcome this alleged
shortcoming.
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A related purported flaw in the EIR’s Project description is the failure to address
the potential adverse physical impacts Project construction would have on these
businesses. On the contrary, such analysis is found at AR 473-482 regarding noise
and vibrations during construction, and at AR 302-305 with respect to air quality.
In terms of traffic, the EIR makes clear that access to the Project site will be
shared via Bayside Drive by construction vehicles and users of the commercial
facilities. As to the added construction and operational traffic, the EIR addresses
these issues at AR499 and in Impact Statement TRA-4.
C. Construction Staging Area Description
Bayside contends that the Project description is inaccurate and, indeed, is an
“unstable moving target” by virtue of the failure to describe and evaluate a
construction staging area. The Court agrees. The 2020 REIR includes several
references to construction staging. Page 3-11 states: “Portions of the adjacent
private property (currently a RV storage area) and Lower Castaways Park could be
temporarily utilized for construction staging, if these areas are available during
construction of the proposed project.” (AR241.) Then, in response to a letter from
the City of Newport Beach stating that the Lower Castaways would not be
available (AR1120), the 2021 FEIR noted: “Should Lower Castaways not be
available, construction staging would occur within other proposed areas of
disturbance (as identified in the project boundary shown on 2020 Recirculated
Draft EIR Exhibit 3-4).” (AR1127.)
Exhibit 3-4 is a Proposed Conceptual Site Plan that shows the areas (highlighted in
yellow) where the proposed project construction will take place as well as the
Lower Castaways. (AR238.) A virtually identical site plan (also highlighted in
yellow) is found at Exhibit 3-6 which is entitled Adjacent Pump Station Work
Areas. (AR243.) According to OCSD’s supplemental brief, based on the
unavailability of the Lower Castaways, “the construction staging will occur
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somewhere in this Adjacent Pump Station Work Area.” (OCSD Supp. Br. at p. 12.)
Based on this statement, the District argues in its supplemental brief that it
satisfied CEQA since the EIR “considered all potential impacts that could occur in
the Adjacent Area.”
However, based on a review of Exhibits 3-4 and 3-6, it is unclear whether creating
a staging area in the limited designated space is even possible. With the exception
of the Lower Castaways, the Coast Highway and the Newport channel, it appears
that the areas highlighted in yellow are where virtually all of the construction
actually will take place. Certainly, no specific location with adequate square
footage is identified, nor is there any analysis as to whether Mitigation Measures
AES-1 and TRA-1 would apply to any area other than the Lower Castaways.
Perhaps a more significant problem with the statements in both the FEIR and
supplemental brief about an alternative site in the project area is that they may
well be inaccurate. Indeed, TRA-1 tends to contradict OCSD’s supplemental brief
by virtue of acknowledging that future staging areas may be located off-site:
“[construction drawings shall] identify any and all construction staging or material
storage sites located outside of the project site.” (AR206 [emphasis added].)
Compounding this problem, counsel for the District told the Court at an earlier
hearing that the lowest responsible bidder on the Project will have complete
discretion to decide where staging will occur and how many staging sites will be
necessary. (August 4, 2022 Transcript at pp. 11-12.) Importantly, by not limiting
that comment to sites within the yellow-highlighted boundaries of Exhibits 3-4 or
3-6, the District appears to acknowledge that staging sites not identified in either
the REIR or FEIR might be utilized. Given that uncertainty, Bayside’s argument
regarding a lack of a complete, accurate and stable project description has merit.
More specifically, the District’s argument (OCSD Supp. Br. at p. 12) that the EIR
considered all environmental impacts (biological, noise, aesthetics, etc.) in the
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Adjacent Area fails to account for any potential impacts that might occur if the
construction staging area occurs elsewhere. Without identifying the area or areas
where staging will occur, the public is left in the dark about whether that staging
will have any effects on the environment at location(s) yet to be identified.
Counsel’s statement that the lowest responsible bidder will have complete
discretion with regard to construction staging also renders the mitigation
measures of AES-1 toothless. AES-1 purports to minimize aesthetic impacts of
construction by requiring the District’s Director of Engineering to personally
approve construction staging areas, transport routes, etc. before grading or
demolition permits are issued. To the extent AES-1 actually imposes enforceable
standards (which the Court questions), it cannot be reconciled with the vesting of
complete discretion in the lowest responsible bidder.
IV. CONSIDERATION OF ALTERNATIVES
“An EIR shall describe a range of reasonable alternatives to the project, or to the
location of the project, which would feasibly attain most of the basic objectives of
the project but would avoid or substantially lessen any of the significant effects of
the project, and evaluate the comparative merits of the alternatives. An EIR need
not consider every conceivable alternative to a project. Rather it must consider a
reasonable range of potentially feasible alternatives that will foster informed
decisionmaking and public participation. An EIR is not required to consider
alternatives which are infeasible. The lead agency is responsible for selecting a
range of project alternatives for examination and must publicly disclose its
reasoning for selecting those alternatives. There is no ironclad rule governing the
nature or scope of the alternatives to be discussed other than the rule of reason.”
(CEQA Guidelines, § 15126.6(a).)
The EIR identified five alternatives to the Project to analyze in detail: the “no
project” scenario, the “adjacent project/microtunneling” scenario, the “original
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northeast pump station with horizontal directional drilling” scenario, the
“rehabilitate in place with microtunneling” scenario, and the “pump station south
relocation with microtunneling” scenario. (AR539-540.) Nearly 40 pages of
analysis are devoted to comparing each of these alternatives to the Project.
(AR540-578.)
Bayside does not challenge the analysis presented. Rather, it faults the EIR for
failing to discuss two additional alternatives: the “Expand-in-Place” scenario and
alternative alignments for the dual force mains south of East Coast Highway.
“Courts will defer to an agency’s selection of alternatives unless the petitioners
(1) demonstrate that the chosen alternatives are “ ‘ “manifestly unreasonable and
... do not contribute to a reasonable range of alternatives,” ’ ” and (2) submit
evidence showing the rejected alternative was both “feasible” and “adequate,”
because it was capable of attaining most of the basic objectives of the project,
taking into account site suitability, economic viability, availability of
infrastructure, general plan consistency, and other relevant factors. [Citation.]”
(South of Market Community Action Network v. City and County of San Francisco
(2019) 33 Cal.App.5th 321, 345.)
The Court assumes for the sake of argument that the “Expand-in-Place” scenario
and the alternative alignments for the dual force mains are both feasible and
adequate. That is, the Court assumes Bayside has met the second prong of its
burden.
However, Bayside fails to meet the first prong of its burden. “The ‘key issue’ is
whether the range of alternatives discussed fosters informed decisionmaking and
public participation. [Citation.]” (Cherry Valley Pass Acres & Neighbors v. City of
Beaumont (190 Cal.App.4th 316, 354.) Bayside complains that two alternatives
were not considered, but it identifies no authority holding that the failure to
consider a specific alternative or alternatives automatically renders the range of
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alternatives considered “manifestly unreasonable” or insufficient to “foster
informed decisionmaking.” (Compare id., at p. 355 [“Though one or more of these
328 imaginable alternatives may have represented the optimum number of
residences that could have profitably been built while minimizing the agricultural
impacts of the project to the fullest extent possible, the range of alternatives
discussed in the EIR was sufficient to foster informed decisionmaking on this very
question.”].)
V. INCONSISTENCIES WITH PLANS
A. Overview
Bayside contends the EIR is fatally flawed because it fails to disclose the Project’s
inconsistencies with the PCDP, the Newport Beach Local Coastal Program (“LCP”),
and the Coastal Act.
An EIR must discuss “any inconsistencies between the proposed project and
applicable general plans, specific plans and regional plan.” (CEQA Guidelines
§ 15125(d).) This includes inconsistencies with the Coastal Act. (Banning Ranch
Conservancy v. City of Newport Beach (2012) 211 Cal.App.4th 1209, 1233.) A
determination of consistency “comes to this [C]ourt with a strong presumption of
regularity. [Citation.] To overcome that presumption, an abuse of discretion must
be shown. [Citations.] An abuse of discretion is established only if the city council
has not proceeded in a manner required by law, its decision is not supported by
findings, or the findings are not supported by substantial evidence. [Citation].”
(Sequoyah Hills Homeowners Assn. v. City of Oakland (1993) 23 Cal.App.4th 704,
717.) “It is, emphatically, not the role of the courts to micro-manage these
development decisions. Our function is simply to decide whether the city
officials considered the applicable policies and the extent to which the proposed
project conforms with those policies, whether the city officials made appropriate
BAYSIDE VILLAGE MARINA LLC v. ORANGE COUNTY SANITATION DISTRICT 21-
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Ruling Page 11
findings on this issue, and whether those findings are supported by substantial
evidence.” (Id., at pp. 719-20 [emphasis in original].)
In addition, Bayside’s opening brief suggests the EIR is inadequate to the extent it
fails to explain why the District found the Project consistent with applicable plans.
(Pet. Opening Br. at p. 19, lines 6-8.) Because EIRs need only evaluate
inconsistencies with plans, no analysis is required if the project is consistent with
plans. (North Coast Rivers Alliance v. Marin Municipal Water Dist. Bd. of Directors
(2013) 216 Cal.App.4th 614, 632 [citing City of Long Beach v. Los Angeles Unified
School Dist. (2009) 176 Cal.App.4th 889, 918-19].) Insofar as Bayside argues the
explanation of consistency is inadequate (as opposed to arguing the finding of
consistency is an abuse of discretion), this challenge fails.
B. PCDP Inconsistency
The PCDP contains zoning regulations that dictate acceptable land uses in each
“Planning Area” it covers. It is undisputed that both the current pump station and
the new pump station to be built as part of the Project are in Planning Area 1.
According to the PCDP, “Wastewater Pump Station” is a permitted land use in
Planning Area 1. (AR7615.)
Bayside nevertheless contends the Project is inconsistent with the PCDP. It argues
that the PCDP “identifies the existence of the BBPS, however, only at its current
size and location, not the expanded size and altered location contemplated by the
Final EIR.” (Pet. Opening Br. at p. 18.) The claimed inconsistency apparently arises
from conceptual drawings attached to the PCDP (for parking plans, public spaces,
etc.) that show the BBPS in its current location in the context of the larger
planning area. (See AR7650-7663.) That is, as the Court understands the
argument, because the conceptual drawings show the current BBPS, any
deviation is an inconsistency.
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As the District points out in opposition, the PCDP imposes specific numeric limits
on the square footage of commercial, residential, marina, and dry dock use in
Planning Area 1, but not wastewater pump use. (AR7612.) The conceptual
drawings do not on their face appear to limit the size or the location of the
pumping station, only to show it in relation to other then-existing uses for
planning purposes. The only explicit limitation placed on a wastewater pump
station by the PCDP is that it must be in Planning Area 1. As to Bayside’s
contention that AR7549 allows the pump station also to be in Planning Area 2 (a
contention that the Court will accept even though it does not appear that AR7549
is in the record filed with the Court), that fact does not establish PCDP
inconsistency. Accordingly, the Court cannot say the finding of consistency is
unsupported by substantial evidence.
C. LCP Consistency
Bayside contends the Project is inconsistent with policy 2.1.9 of the LCP because
that policy “mandate[s] protection and expansion of coastal-dependent over
commercial/industrial uses.” (Pet.’s Opening Br. at p. 17.) As the District points
out, nothing in policy 2.1.9 or its associated sub-policies discusses the relative
priority of coastal-dependent uses vis-à-vis utility uses like the Project.
(Furthermore, it appears the only hard-and-fast priority is that coastal-dependent
uses are prioritized over residential uses, not over commercial/industrial uses.
See policy 2.1.9-1, at AR11289.)
In any event, the City correctly notes that relative priority matters only if the Back
Bay Landing development and the Project are a zero-sum game in terms of
developed square footage. Under the PCDP, square footage for a wastewater
pump station does not count against commercial, residential, marina, or dry dock
square footage. (See AR7612.) The Court cannot say the finding of consistency is
unsupported by substantial evidence.
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Ruling Page 13
D. Coastal Act Consistency
Bayside contends the Project is inconsistent with multiple sections of the Coastal
Act, in particular Pub. Resources Code §§ 30213, 30221, 30222, 30224, and
30253(e), and policy 3.2.1-1 of the LCP, which similarly requires protection of
coastal recreation opportunities.
The Court agrees with the District that § 30222 is inapplicable. On its face, that
statute prioritizes “visitor-serving commercial recreational facilities designed to
enhance public opportunities for coastal recreation . . . over private residential,
general industrial, or general commercial development, but not over agriculture
or coastal-dependent industry.” Again, the Project is a utility use, not one of the
categories enumerated in this statute.
Of the remaining provisions, the only one discussed in any detail in Bayside’s
briefing (opening, reply, or supplemental) is § 30253(e) of the Coastal Act. The
remainder are simply referred to in laundry lists without discussion of any
particular alleged inconsistencies. Because Bayside bears the burden of showing
an abuse of discretion, the Court finds the failure to specifically discuss §§ 30123,
30221, and 30224 of the Coastal Act, as well as policy 3.2.1-1 of the LCP, means
Bayside has not shown an abuse of discretion in the District’s finding of
consistency.
As to § 30253(e), it provides: “New development shall . . . [w]here appropriate,
protect special communities and neighborhoods that, because of their unique
characteristics, are popular visitor destination points for recreational use.”
“Where appropriate” is an important qualifier here, as the District flags a
competing provision of the Coastal Act, § 30231, which provides: “The biological
productivity and the quality of coastal waters, streams, wetlands, estuaries, and
lakes appropriate to maintain optimum populations of marine organisms and for
the protection of human health shall be maintained and, where feasible, restored
BAYSIDE VILLAGE MARINA LLC v. ORANGE COUNTY SANITATION DISTRICT 21-
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Ruling Page 14
through, among other means, minimizing adverse effects of waste water
discharges and entrainment . . . .”
The administrative record contains evidence that the current pump station is
deteriorating and does not meet current standards for construction, electrical
equipment, or maintenance. (AR187.) The record also contains evidence that
failure of the system could result in the release of sewage into Newport Bay.
(AR187, 245.) Section 30231 of the Coastal Act imposes a mandatory policy for
protecting water quality (it “shall be maintained”), while § 30253(e) only imposes
a duty to protect recreational use “where appropriate.” On this record, the Court
cannot say the District lacked substantial evidence to conclude its duties under §
30231 prevailed over its duties under § 30253(e), and thereby to conclude the
Project is consistent with the Coastal Act. Put another way, Bayside must show
the District abused its discretion in finding the “where appropriate” qualifier in §
30253(e) inapplicable here, and it has not met its burden to do so.
VI. ADEQUACY OF RESPONSES TO COMMENTS
Bayside contends the District’s response to comments prior to certification of the
FEIR is inadequate. The Court agrees with the District that Bayside failed to
exhaust its administrative remedies on this issue. “[T]he time for complaining
about the inadequacy of [the District’s] responses was when the issue was before
the agency and any alleged deficiency could be explained or corrected.” (Towards
Responsibility in Planning v. City Council (1988) 200 Cal.App.3d 671, 682.) Bayside
points to nothing in the record indicating that the alleged inadequacy of the
District’s responses was raised at the administrative stage. As a result, this
challenge is barred.
Bayside responds that the foregoing statement from Towards Responsibility is
dictum unnecessary to the holding. This is true enough, as the Court of Appeal in
that case found the agency’s response to comments adequate on the merits. But
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Ruling Page 15
“[t]o say that dicta are not controlling [citation] does not mean that they are to be
ignored; on the contrary, dicta are often followed.” (9 Witkin, Cal. Procedure (6th
ed. 2022) Appeal § 532.) And while Bayside cites a number of cases on page 21 of
its supplemental brief holding that inadequate responses to comments may
render an EIR defective, none of those cases discusses the effect of the
challenger’s failure to raise the inadequacy issue before the agency.
VII. REMEDIES AND CONCLUSION
For the reasons set forth above, Bayside’s petition is GRANTED on the ground that
the description of the construction staging area is inadequate, and for the related
reason that AES-1 is a toothless mitigation measure as a result.
Bayside asks the Court to set aside the District’s Project approvals and EIR
certification. Public Resources Code § 21168.9 gives the Court discretion to
fashion a narrower remedy. “The 1993 amendments to section 21168.9 expanded
the trial court’s authority and ‘expressly authorized the court to fashion a remedy
that permits some part of the project to go forward while an agency seeks to
remedy its CEQA violations. In other words, the issuance of a writ need not always
halt all work on a project.’ [Citation.]” (San Bernardino Valley Audubon Soc. V.
Metropolitan Water Dist. of Southern California (2001) 89 Cal.App.4th 1097, 1104-
1105.) “The choice of a lesser remedy involves the trial court’s consideration of
equitable principles.” (Id., at p. 1104.)
As discussed above, Bayside’s challenge is largely unsuccessful. And the vast
majority of Bayside’s challenge has little, if anything, to do with construction
staging issues. The Court therefore finds the remainder of the Project severable
from the construction staging issues. The Court further finds severance will not
prejudice full and complete compliance with CEQA, because the remainder of the
Project is CEQA-compliant. (Pub. Resources Code § 21168.9(b).)
BAYSIDE VILLAGE MARINA LLC v. ORANGE COUNTY SANITATION DISTRICT 21-
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Ruling Page 16
In considering equitable principles to fashion a remedy, the Court is especially
mindful of the severe risk to the environment that would be posed by the
outdated pumping station and force mains failing and spilling raw sewage into
Newport Bay. Furthermore, as explained in the District’s filings in the companion
eminent domain case, permitting from the relevant authorities is expected to take
9-12 months, with construction not starting for another six months after that.
(See OC Superior Court case no. 2022-01251890, ROA 92, at pp. 2-3.) Based on
representations made at the hearing, it appears that the City will not allow the
permitting process to start without OCSD approval of the Project and its
certification of the EIR. Of course, stalling that already lengthy process increases
the risk of the very sewage spill the Project seeks to prevent.
Because the issues with construction staging are both severable and appear to be
readily correctable, and given the overriding need for the Project, OCSD will not
be required to withdraw its approvals for the Project and certification of the EIR.
As explained by the court in Preserve Wild Santee v. City of Santee (2012) 210 Cal.
App. 4th 260, 287-88:
In our view, a reasonable, commonsense reading of section 21168.9 plainly
forecloses plaintiffs' assertion that a trial court must mandate a public
agency decertify the EIR and void all related project approvals in every
instance where the court finds an EIR violates CEQA. Such a rigid
requirement directly conflicts with the “in part” language in section
21168.9, subdivision (a)(1), which specifically allows a court to direct its
mandates to parts of determinations, parts of findings, or parts of
decisions. Such a rigid requirement also conflicts with the language
in section 21168.9, subdivision (b), limiting the court's mandates to only
those necessary to achieve CEQA compliance and, if the court makes
specified findings, to only “that portion of a determination, finding, or
decision” violating CEQA. (Italics added.)
BAYSIDE VILLAGE MARINA LLC v. ORANGE COUNTY SANITATION DISTRICT 21-
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Ruling Page 17
Accordingly, the Court will impose the limited remedy of requiring OCSD to bring
the EIR into CEQA compliance with respect to the construction staging issue and
the related question of the enforceability of AES-1. Because the District’s CEQA
noncompliance involves construction issues, this means no construction or other
physical activity may take place at the Project site until the District is in
compliance with CEQA. Whether bringing the EIR into compliance can be
accomplished via a supplemental EIR (CEQA Guidelines § 15163) or an addendum
(CEQA Guidelines § 15164) will be left to OCSD to decide.
Note that the Court’s order includes only these mandates, which are necessary to
achieve compliance with CEQA. (See Pub. Resources Code § 21168.9(b).) In order
to avoid unnecessary delay that increases the risk of a sewage spill, the District
may continue to seek the necessary permits from the City, Coastal Commission,
etc. to move forward with the Project, and it may continue to pursue the
companion eminent domain action.
Bayside shall prepare a proposed order in accordance with this ruling and provide
it to OCSD for comments before submitting it to the Court.
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Bay Bridge Addendum
I. Summary
As Lead Agency, the Orange County Sanitation District (“OC San”) prepared an
Environmental Impact Report (“EIR”) for the Bay Bridge Pump Station and Force Mains
Replacement Project (the “previously analyzed project”). The OC San’s Board of Directors
ultimately certified an EIR for the previously analyzed project on February 24, 2021. On March
1, 2021, OC San submitted a Notice of Determination (“NOD”) for the Final EIR to both the
State Clearinghouse and the Orange County Clerk’s Office (“County Clerk’s Office”). The
County Clerk’s Office posted the NOD on March 1, 2021, and the State Clearinghouse posted
the NOD on March 2, 2021.
On April 1, 2021, Bayside Village Marina filed a Verified Petition for Writ of Mandate
against OC San in Orange County Superior Court alleging that the EIR failed to comply with
CEQA on numerous grounds. (Orange County Superior Court Case No. 30-2021-01194238.)
On December 16, 2022, Judge William Claster of the Orange County Superior Court issued a
ruling that upheld the EIR in all respects except one. The Court issued a limited writ directing
OC San to correct deficiencies in the EIR’s description of the project’s proposed construction
staging areas. (Minute Order, pp. 1, 16.) The Court’s December 16, 2022, ruling is attached
hereto as Attachment 1 (the “Ruling”).
The EIR explained that construction staging will occur somewhere in the “Adjacent
Pump Station Work Area” (“Adjacent Area”) shown in yellow on Exhibit 3-6 of the EIR. The
EIR considered all potential impacts that could occur in the Adjacent Area including, among
others, impacts on biological resources, aesthetics, cultural resources, archeological resources,
transportation, noise, land use plan consistency, and emergency response. Lower Castaways
Park is within the Adjacent Area. (Draft EIR, p. 3-12, 5.1-17, 5.3-2, 5.3-15, 5.3-21, 5.4-14, 5.5-
1, 5.5-3, 5.9-8, 5.9-9, 5.9-12, 5.9-14, 5.9-15, 5.9-16, 5.9-17, 8-9.)
The City of Newport Beach submitted a comment letter to OC San stating that the “City
will likely neither support a permanent nor temporary easement through Lower Castaways Park”
because the City plans to develop the site with park facilities. In responses to comments, OC
San stated that, should Lower Castaways not be available, construction staging would occur
elsewhere within the Adjacent Area.
The Court found that, assuming Lower Castaways is not available, “it is unclear whether
creating a staging area in the limited, designated space is even possible.” (Ruling, p. 7.) The
Court concluded that no specific location with adequate square footage had been identified in the
EIR, nor was there any analysis as to whether Mitigation Measures AES-1 and TRA-1 would
apply to any area other than the Lower Castaways. (Ruling, p. 7.)
The Court also noted that Mitigation Measure TRA-1 implies that construction staging
could occur outside the Adjacent Areas. Mitigation Measure TRA-1 states in relevant part,
“[construction drawings shall] identify any and all construction staging or material storage sites
located outside of the project area.” (Ruling, p. 7.) The Court further noted that counsel for the
District stated in a prior hearing that the lowest responsible bidder will have complete discretion
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to decide where staging will occur and how many staging sites will be necessary. (Ruling, p. 7.)
The Court explained that because the EIR’s analysis failed to account for impacts that could
occur elsewhere, and the low bidder could place the project elsewhere, it would make Mitigation
Measure AES-1 “toothless.” (Ruling, p. 8.) The Court also questioned whether AES-1 imposes
enforceable standards. (Ruling, p. 8.)
OC San has prepared this Addendum to the EIR in response to the Ruling. This
Addendum provides additional information regarding the proposed use of the Lower Castaways
as a construction staging area and adds a new construction staging area at OC San Plant No. 2
located in the City of Huntington Beach for soil storage/drying activities. The Addendum also
modifies TRA-1 to eliminate any reference to additional construction staging or material storage
areas and, per a new condition of project approval, states that the construction contractor will not
have discretion to select staging areas. Finally, the Addendum modifies and addresses the
enforceability of Mitigation Measure AES-1. Mitigation measures for public projects are
considered enforceable when they are incorporated into the project design. (Public Resources
Code § 21081.6(b); 14 Cal. Code Regs. § 15126.4(a)(2).) A resolution incorporating AES-1 into
the project design will be considered contemporaneously with this Addendum. Collectively,
these clarifications and additions are referred to as the “Modified Project.”
As set forth in detail below, the Modified Project would not result in new significant
impacts or a substantial increase in the severity of previously identified significant impacts. As a
result, an addendum is appropriate. (CEQA Guidelines §§ 15162, 15164.)
II. Applicable CEQA Principles
When an EIR has been certified or a negative declaration adopted for a project, no
subsequent or supplemental environmental review documentation shall be required unless one or
more of the following events occurs:
1) Substantial changes are proposed in the project, which will require major revisions of
the previous EIR or negative declaration due to the involvement of new significant
environmental effects or a substantial increase in the severity of previously identified
significant effects;
2) Substantial changes occur with respect to the circumstances under which the project
is undertaken, which will require major revisions of the previous EIR or negative
declaration due to the involvement of new significant environmental effects or a
substantial increase in the severity of previously identified significant effects; or
3) New information of substantial importance, which was not known and could not have
been known with the exercise of reasonable diligence at the time the previous EIR
was certified as complete or the negative declaration was adopted, shows any of the
following:
A. The project will have one or more significant effects not discussed in the previous
EIR or negative declaration;
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B. Significant effects previously examined will be substantially more severe than
shown in the previous EIR;
C. Mitigation measures or alternatives previously found not to be feasible would in
fact be feasible, and would substantially reduce one or more significant effects of
the project, but the project proponents decline to adopt the mitigation measure or
alternative; or
D. Mitigation measures or alternatives which are considerably different from those
analyzed in the previous EIR would substantially reduce one or more significant
effects on the environment, but the project proponents decline to adopt the
mitigation measure or alternative.
When none of the above events has occurred, yet minor technical changes or additions to
the previously adopted negative declaration are necessary, an addendum may be prepared
(CEQA Guidelines § 15164(b).) Circulation of an addendum for public review is not necessary
(CEQA Guidelines § 15164(c)); however, the addendum must be considered in conjunction with
the adopted Final EIR by the agency’s decision-making body (CEQA Guidelines § 15164(d).)
III. Project Description: The Modified Project
A. Construction Staging
1. Lower Castaways Park
On May 22, 2023, the City of Newport Beach (“City”) signed a Letter of Intent For
Entering Into a Licensing Agreement – Lower Castaways Park (“Letter of Intent”) attached
hereto as Attachment 2. Per the Letter of Intent, OC San would lease 18,000 square feet of the
lower portion of Castaways Park, located at 100 Dover Drive, Newport Beach, CA 92660, from
the City for use as a construction staging area in connection with the project. The City and OC
San intend to memorialize these details in a licensing agreement at a future date.
OC San will use a designated staging area at Lower Castaways Park, shown on Exhibit 1,
for the following activities: staff parking; construction office trailers; storage, loading, and
unloading of equipment and material; and refueling. The staged construction materials would
include piping, conduits, shoring, formwork, rebar, and other materials necessary for
construction. Equipment such as pumps, HVAC equipment, cranes, and electrical panels will be
stored on raised mobile platforms, pallets, or other protective barriers to protect the equipment
and prevent spills or the spread of materials. Staged construction equipment at this location may
include trucks, lifts, excavators, loaders, cranes, and other equipment necessary for the
construction. In addition, it is anticipated that the contractor will use a mobile diesel storage unit
onsite to refuel the construction equipment. Soil and dredged materials will not be stored on the
property.
2. OC San Plant No. 2
The Modified Project will utilize an approximately 30,000 square foot portion of OC
San’s Plant No. 2 as an additional construction staging area (Plant No. 2.). Plant No.2 is located
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at 22212 Brookhurst Street, in the southernmost part of the City of Huntington Beach, and
adjacent to Huntington State Beach. Plant No. 2 is triangular in shape and bounded by
Brookhurst Street on the west, the Santa Ana River Channel on the east, and a lagoon on the
South where Talbert Channel discharges into the Pacific Ocean. Residential development is
located west and north of the site across Brookhurst Street. The Talbert Regional Park and
Banning Ranch are located east of the site across the Santa Ana River channel. Plant No. 2 is
approximately 111 acres in size and is developed with facilities related to various aspects of the
wastewater treatment and disposal process, offices, and internal access roads.
Under the Modified Project, excavated soil will be hauled from the project site to Plant
No. 2 where it will be stockpiled and dried. Once dried, loaders would be utilized to stow
stockpiles onto hauling trucks and either be hauled back to the project site or to a permitted
landfill for disposal. Construction materials/equipment at Plant No. 2 would include, but not be
limited to, hauling trucks, construction worker vehicles, loaders, and soil stockpiles. It should be
noted that hauling trucks would not typically be stored overnight at Plant No. 2. Exhibit 2
shows the Plant No. 2 construction staging area.
The Modified Project’s soil hauling assumptions, based on the addition of a construction
staging area at Plant No. 2, are set forth in Tables 1-1 through 1-3. Hauling is anticipated to
commence in the Fall of 2025 and conclude in the Fall of 2028.
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Table 1-1
Soil Hauling Schedule From Project Site to OC San Plant No. 2
Soil Hauling to Plant Number 2
Soil Hauling Schedule
Activity Quantity Unit Number of Trucks1 Start Complete Duration (Calendar Days)
Pump Station 8,281 cy 828 9/3/2025 12/9/2025 97
Existing Pump Station Demolition and Odor Control 89 cy 9 4/12/2028 5/28/2028 46
TOTAL 8,370 cy 837 - - -
Note: 1. Assume each truck carries 10 cubic yards. 2. CalEEMod included assumption of construction commencement in the Fall of 2024. This is a conservative assumption, as the model assumes that as time progresses, technology improves, reducing emissions.
Table 1-2
Soil Hauling Schedule From OC San Plant No. 2 Back to the Project Site for Backfill
Soil Hauled from Plant Number 2 Back to the Project Site for Backfill
Soil Hauling Schedule
Activity Quantity Unit Number of Trucks1
Start Complete Duration (Calendar Days)
Pump Station 200 cy 20 9/19/2025 9/26/2025 7 Existing Pump Station Demolition and Odor Control 219 cy 22 11/1/2027 12/3/2027 32
TOTAL 419 cy 42 - - -
Note: 1. Assume each truck carries 10 cubic yards. 2. CalEEMod included assumption of construction commencement in the Fall of 2024. This is a conservative assumption, as the model assumes that as time progresses, technology improves, reducing emissions.
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Table 1-3
Soil Hauling Schedule From OC San Plant No. 2 to Olinda Alpha Landfill
Soil Hauling from Plant Number 2 Off-Site for Disposal
Soil Hauling Schedule
Activity Quantity Unit Number of Trucks1
Start Complete Duration (Calendar Days) Pump Station 7,863 cy 786 6/2/2025 9/19/2025 109 Existing Pump Station Demolition and Odor Control
9 cy 9 12/20/2027 1/28/2028 39
TOTAL 7,872 cy 795 - - -
Note: 1. Assume each truck carries 10 cubic yards. 2. CalEEMod included assumption of construction commencement in the Fall of 2024. This is a conservative assumption, as the model assumes that as time progresses, technology improves, reducing emissions.
3. Mitigation Measure TRA-1
In response to the Ruling, Mitigation Measure TRA-1 is modified below to: (1) eliminate
the previous reference to, “Identify any and all construction staging or material storage sites
located outside of the project site;” and (2) to add references to the “City of Huntington Beach”
due to the addition of a construction staging area at Plant No. 2 which is located in the City of
Huntington Beach. Mitigation Measure TRA-1 appeared in full on pages 1-20 to 23 and 5.11-7
to 9 of the EIR. TRA-1 is hereby edited as reflected below in each of the places it appeared in
the EIR. Strikethrough indicates deleted text and double underline indicates an addition:
TRA-1 Prior to initiation of construction activities, engineering drawings and
specifications, and/or contractor shop drawings shall be prepared by the
Project Engineer, or designee, and submitted for review and approval by
the Orange County Sanitation District, California Department of
Transportation (Caltrans), City of Huntington Beach Public Works
Department, and the City of Newport Beach Public Works Department.
These documents shall, at a minimum, address the following:
• Traffic control protocols shall be specified for any lane closure, detour,
or other disruption to traffic circulation, including bicycle and
pedestrian trails. Disruption to traffic circulation shall be minimized to
the greatest extent feasible. Bicycle and pedestrian trails shall remain
open, to the greatest extent feasible, during construction or shall be re-
routed to ensure continued connectivity.
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• Bus stop access impacts shall be coordinated with, and approved by,
the Orange County Transportation Authority.
• At least one week before any construction activities that would affect
travel on nearby roadways, the construction contractor shall notify the
City of Huntington Beach Public Works Department, City of Newport
Beach Public Works Department and Caltrans, as applicable, of
construction activities that could impede movement (such as lane
closures) along roadways, to allow for planning temporary detours or
identifying alternative emergency access routes where appropriate.
Surrounding property owners shall also be notified of project activities
through advanced mailings.
• Identify construction vehicle haul routes for the delivery of
construction materials (i.e., lumber, tiles, piping, windows, etc.) to the
site; necessary traffic controls and detours; and a construction phasing
plan for the project to reduce impacts to local streets and plan for
traffic control signage and detours along identified haul routes to
minimize impacts to existing traffic flow.
• Identify any and all construction staging or material storage sites
located outside of the project site.
• Specify the hours during which hauling activities can occur and
methods to mitigate construction-related impacts to adjacent streets
such as traffic control barricades, cones, flaggers, and warning signs.
• Require the contractor to keep all haul routes clean and free of debris,
including but not limited, to gravel and dirt resulting from project
construction. The Contractor shall clean adjacent streets, as directed by
the Orange County Sanitation District, of any project material which
may have been spilled, tracked, or blown onto adjacent City of
Newport Beach, City of Huntington Beach, and Caltrans streets or
areas.
• Hauling of oversize loads shall be allowed between the hours of 9:00
a.m. and 3:00 p.m. only, Monday through Friday. No hauling or
transport shall be allowed during nighttime hours, weekends, or
Federal holidays. Any oversized loads utilizing Coast Highway shall
obtain a Caltrans permit for such activities.
• Use of local streets shall be prohibited, except when required to
provide direct access to the project site and in compliance with the
approved project haul routes.
• Haul trucks entering or exiting public streets shall yield to public
traffic at all times.
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• If hauling operations cause any damage to existing pavement, streets,
curbs, and/or gutters along the haul route, the contractor shall be fully
responsible for repairs. The repairs shall restore the damaged property
to its original condition.
• All construction-related staging of vehicles shall be kept out of the
adjacent public roadways and shall occur on the project site or within
additional off-street staging areas previously identified and arranged.
• Construction-related lane closures would only occur between the hours
of 8:30 a.m. and 3:30 p.m., Monday through Friday. More or less
restrictive closure hours may be prescribed by the City.
• Use of a construction flagperson (as deemed appropriate by the Orange
County Sanitation District) to assist in maintaining efficient vehicle
travel in both directions (particularly during peak travel hours) and use
of construction signage and safe detour routes for pedestrians and
bicyclists when travel lanes and sidewalks along Coast Highway are
affected.
• The engineering drawings and specifications shall meet standards
established in the current California Manual on Uniform Traffic
Control Device (MUTCD).
4. Condition of Approval: the Construction Contractor Does Not Have
Discretion to Select Staging Areas
In response to the Ruling, OC San has prepared a condition of approval for the Modified
Project (“Condition”). The Condition will be considered for approval contemporaneously with
this Addendum. The Condition states, “The constructor contractor will not have discretion to
select any construction staging or material storage sites. The construction staging or material
storage sites for this project are identified in the Addendum to the certified Bay Bridge Pump
Station and Force Mains Replacement Project Environmental Impact Report.”
B. Mitigation Measure AES-1
The EIR for the previously analyzed project included the following mitigation measure to
address potentially significant short-term visual impacts. (EIR, p. 1-2.) Specifically, the EIR
concluded that project construction activities could temporarily degrade the visual character/
quality of the site and its surroundings. (EIR, p. 1-2.) The EIR concluded that these impacts
would ultimately be less than significant with incorporation of Mitigation Measure AES-1.
AES-1 is modified for clarity below. Mitigation Measure AES-1 appeared in full on pages 1-2 to
3 and 5.1-16 of the EIR. AES-1 is hereby edited as reflected below in each of the places it
appeared in the EIR. Strikethrough indicates deleted text and double underline indicates an
addition:
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AES-1 Prior to issuance of any grading and/or demolition permits, whichever
occurs first, engineering drawings and specifications shall be prepared by
the Project Engineer, or their designee, and submitted for review and
approval by the Orange County Sanitation District Director of
Engineering. These documents shall, at a minimum, indicate the
equipment and vehicle staging areas, stockpiling of materials,
screening/fencing (, and haul route(s). Staging areas shall be sited away
from public views, to the extent feasible and reasonable. and/or screened
utilizing temporary fencing with opaque materials. Construction haul
routes shall minimize impacts to sensitive uses in the project area by
avoiding local residential streets. Staging areas shall be screened utilizing
temporary fencing with opaque materials to buffer views of construction
equipment and materials for the duration of construction.
In response to the Ruling, AES-1 will be incorporated into the project’s design pursuant
to Public Resources Code Section 21081.6(b) and California Code of Regulations, Title 14,
Section 15126.4(a)(2). (See Corresponding Resolution of the Orange County Sanitation District
Receiving and Filing the Addendum to the Environmental Impact Report for the Bay Bridge
Pump Station and Force Mains Replacement Project No. 5-67 and Approving the Modified
Project.)
IV. Environmental Assessment
A. Aesthetics/Light and Glare
The potential aesthetic/visual impacts associated with the temporary use of Lower
Castaways Park for construction staging purposes were analyzed in the EIR. (Draft EIR,
p. 3-12, 3-13, 5.1-16, 5.1-17, 5.1-18.). Plant No. 2 is a fully developed utility facility which contains numerous structures
that vary in height, mass, and function. The tallest structure at Plant No. 2 is Surge
Tower 2, which stands at 86 feet above-grade, located on the southeast portion of Plant
No. 2, adjacent to the Santa Ana River trail. Residential communities with views of Plant
No. 2 are located in the cities of Huntington Beach to the northwest and Newport Beach
to the southeast. Long distance views of Plant No. 2 can also be seen from the east in the
City of Costa Mesa.
Under existing conditions, Plant No. 2 is generally screened by fencing and
landscaping, including trees, partially blocking views into Plant No. 2 from the
surrounding areas. As a result of these visual barriers and the relatively flat topography
of the landscape surrounding Plant No. 2, the majority of the facilities within Plant No. 2.
are not publicly visible, beyond those facilities that are located along the Plant’s frontages
or that are multiple stories tall.
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A 17-mile portion of SR-1 from Jamboree Road in Newport Beach to the northern
city limit of Seal Beach is an eligible state scenic highway but has not been officially
designated. (Caltrans 2019). This portion of SR-1 provides prominent views of the
Pacific Ocean in the south, and occasional views of marshland and wetlands in the north,
when not interrupted by the urban development within the cities of Huntington Beach and
Seal Beach. Plant No. 2 is located approximately 500 feet north of SR-1.
The Modified Project would utilize an approximately 30,000 square foot portion of Plant No. 2 as a construction staging area for soil stockpiling and drying. Construction materials/equipment at Plant No. 2 would include, but not be limited to, hauling trucks, construction worker vehicles, loaders, and soil stockpiles. It should be noted that hauling
trucks would not typically be stored overnight at Plant No. 2. Although the proposed soil
stockpiles may be visible from outside of Plant No. 2, the staging and drying of these soils would be temporary and would cease upon completion of construction. Further, pursuant to AES-1, construction materials/equipment would be screened utilizing temporary fencing with opaque materials at the designated staging areas to limit public
views of staging activities. No nighttime lighting would be required for the soil
stockpiling/storage at Plant No. 2. The Modified Project would also require the operation of hauling vehicles that would be visible during hauling between the project site and Plant No. 2. These hauling
vehicles, however, would only operate temporarily during construction. At the
completion of construction, these vehicles would cease operations. The Modified Project would not change any operational aspects of the previously analyzed project, none of which would be located at Plant No. 2.
Based on AES-1 and the short-term duration of hauling and storage activities at OC San’s fully developed Plant No. 2, the Modified Project would not result in new significant impacts or a substantial increase in previously identified significant impacts pertaining to aesthetics.
B. Air Quality
The potential air quality impacts associated with the temporary use of Lower
Castaways Park for construction staging purposes were analyzed in the EIR. (Draft EIR,
p. 3-12, 3-13, 5.2-13, 5.2-14, 5.2-15, 5.2-16, 5.2-17, 5.2-19, 5.2-20, 5.2-24, 5.2-25.)
Plant No. 2 is located within the South Coast Air Basin and thus is within the
jurisdiction of the South Coast Air Quality Management District (“Air District”). The
Modified Project would be subject to the Air District’s rules and regulations including,
without limitation, Rule 401 (visible emissions); Rule 402 (nuisance); Rule 403 (fugitive
dust); and Rule 431.2 (sulfur content of liquid fuels).
The Modified Project’s soil hauling schedule is anticipated to commence in Fall
of 2025 and conclude in Winter of 2028. Soil hauling would include 8,370 cubic yards of
export from the project site to Plant No. 2. Approximately 419 cubic yards of the
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exported soil would be hauled back to the project site to be used for backfilling purposes.
The remaining 7,872 cubic yards of exported soil would be hauled from Plant No. 2 to a
permitted landfill facility for disposal. This would result in a total of 1,674 soil hauling
truck trips. These trips, however, would be temporary and would cease upon completion
of construction. The Modified Project’s potential air quality impacts were modeled and
compared to the applicable Air District thresholds as set forth in Table 1-4.
Table 1-4 Modified Project-Generated Construction Emissions
Emissions Source Pollutant (pounds/day)1,2
ROG NOX CO SO2 PM10 PM2.5
Year 1 4.50 40.7 40.0 0.08 2.36 1.75
Year 2 18.0 31.6 33.6 0.07 2.21 1.31
Year 3 2.70 23.2 25.4 0.05 1.83 0.99
Year 4 2.61 22.4 25.0 0.05 1.77 0.93
Year 5 0.33 2.90 3.85 0.01 0.31 0.09
Maximum Daily
Emissions
18.0 40.7 40.0 0.08 2.36 1.75
SCAQMD Thresholds 75 100 550 150 150 55
Threshold Exceeded? No No No No No No
Notes:
1. Emissions were calculated using CalEEMod version 2022.1. Emissions shown represent worst-case during summer and winter.
2. The reduction/credits for construction emissions are based on “mitigation” included in CalEEMod and are required by the SCAQMD
Rules. The adjustments applied in CalEEMod includes the following: properly maintain mobile and other construction equipment;
replace ground cover in disturbed areas quickly; water exposed surfaces three times daily; cover stockpiles with tarps; and limit speeds
on unpaved roads to 15 miles per hour. The emissions results in this table represent the “mitigated” emissions shown in Attachment 3.
3. CalEEMod included assumption of construction commencement in the Fall of 2024. This is a conservative assumption, as the model
assumes that as time progresses, technology improves reducing emissions.
Source: Refer to Attachment 3 for assumptions used in this analysis.
As indicated in Table 1-4, criteria pollutant emissions for ROG, NOX, CO, SO2, PM10,
and PM2.5 during construction of the Modified Project would not exceed the Air District’s
significance thresholds. Although odors could potentially be generated by vehicle
exhaust emissions during construction staging activities, such odors would disperse
rapidly and would not occur at magnitudes that would affect substantial numbers of
people.
The Modified Project would not change any operational aspects of the previously
analyzed project.
The Modified Project, therefore, would not result in new significant impacts or a
substantial increase in previously identified significant impacts pertaining to air quality.
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C. Biological Resources
The potential biological resources impacts associated with the temporary use of
Lower Castaways Park for construction staging purposes were analyzed in the EIR.
(Draft EIR, p. 3-12, 3-13, 5.3-13, 5.3-14, 5.3-15, 5.3-16, 5.3-17, 5.3-19, 5.3-20, 5.3-21,
5.3-23, 5.3-24, 5.3-25.)
Plant No. 2 is fully developed with buildings, utility infrastructure, and access
roads. The vast majority of the soils on site have been significantly altered due to
compaction and construction of the facility. There is no native or natural vegetation
within Plant No. 2; the only vegetation that exists on site consists of ornamental grass,
shrubs, and trees. Thus, Plant No. 2 does not present suitable habitat for
sensitive/special-status biological resources and the proposed soil drying and stockpiling
at Plant No. 2 would not adversely impact any sensitive/special-status biological
resources. Due to the presence of ornamental trees at Plant No. 2, there is a potential for
nesting birds to be present during the soil drying / stockpiling activities. As a result,
Mitigation Measure BIO-2 would apply to the Modified Project, with the following
modifications:
BIO-2 Should construction activities occur within the nesting season, all suitable
habitat surrounding the project site and Orange County Sanitation District (OC San) Plant No. 2 shall be thoroughly surveyed for the presence of nesting birds by a qualified biologist, defined as an individual with a bachelor’s degree or above in a biological science field and demonstrated field experience, within three days prior to commencement of site
disturbance activities. If an active avian nest is discovered in proximity to the project site or OC San Plant No. 2 during the nesting bird survey, construction activities
(those activities that could result in direct or indirect impacts to active
nests either through noise, light, or physical contact) shall stay outside of a 300- foot buffer around the active nest. For raptor species, this buffer shall be expanded to 500 feet. The qualified biologist shall be present to delineate the boundaries of the buffer area and to monitor the active nest
in order to ensure that nesting behavior is not adversely affected by
construction activities. If the qualified biologist determines that nesting behavior is adversely affected by construction activities, the qualified biologist shall halt construction activities that result in the adverse effect and file a written report to OCSDOC San and the construction contractor
stating the recommended course of action. The buffer area and limitations
on construction may be reduced upon approval by the California Department of Fish and Wildlife, and only if the nesting behaviors are not disrupted by construction activities, as determined by the qualified biologist. Once the young have fledged, normal construction activities
shall be allowed to occur.
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There are no riparian habitats or wetlands on Plant No. 2. While the Santa Ana River Trail adjacent to Plant No. 2 is a significant movement corridor for multiple species, all of the Modified Project’s soil drying and stockpiling activities would
be located exclusively within Plant No. 2. The ornamental trees within Plant No. 2 are not located on public rights of way and, therefore, would not be subject to any tree preservation ordinances. Although Plant No. 2 is located with the Orange County Transportation Authority Natural Communities Conservation Plan (NCCP), the site is designated as “Developed” in the NCCP, and is not within an area designated as Permit
Area, Natural Habitats, or Agriculture. (NCCP figure 1-2.) The NCCP does not impose any requirements on areas designated as “Developed.” Further, Plant No. 2 is not located within the plan areas of any habitat conservation plans other than the NCCP. The Modified Project would not change any operational aspects of the previously
analyzed project.
Based on BIO-2 and the short-term duration of hauling and storage activities at
Plant No. 2, the Modified Project would not result in new significant impacts or a
substantial increase in previously identified significant impacts pertaining to biological
resources.
D. Cultural Resources
The potential cultural resources impacts associated with the temporary use of Lower Castaways Park for construction staging purposes were analyzed in the EIR. (Draft EIR, p. 3-12, 3-13, 5.4-15, 5.4-16.)
No cultural resources, including historic or archeological resources, have been
recorded at Plant No. 2. Plant No. 2 is fully developed with buildings, utility
infrastructure, and access roads. The vast majority of the soils on site have been
significantly altered due to compaction and construction of the facility.
The Modified Project’s soil drying / stockpiling activities at Plant No. 2 would be
temporary during construction, would cease when construction is completed, and would
not require any ground disturbing activities that could impact previously undiscovered
cultural resources or human remains.
The Modified Project would not change any operational aspects of the previously analyzed project. The Modified Project, therefore, would not result in new significant impacts or a
substantial increase in previously identified significant impacts pertaining to cultural
resources.
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E. Geology and Soils
The potential geology and soils impacts associated with the temporary use of Lower Castaways Park for construction staging purposes were analyzed in the EIR.
(Draft EIR, p. 3-12, 3-13, 5.4-15, 5.4-16.) Plant No. 2 is fully developed with buildings, utility infrastructure, and access
roads. The vast majority of the soils on site have been significantly altered due to
compaction and construction of the facility. No paleontological resources have been
documented within Plant No. 2. Further, Plant No. 2 is not within a designated Alquist-
Priolo Earthquake Fault Zone or within potential earthquake-induced landslide zones as
designated by the California Geological Survey.
The proposed soil drying / stockpiling activities at Plant No. 2 under the Modified
Project would be temporary during construction, would cease when construction is
completed, and would not require any ground disturbing activities that could impact
previously undiscovered paleontological resources. The proposed soil drying /
stockpiling would not directly or indirectly exacerbate the existing potential for fault
rupture, ground shaking, liquefaction, landslides, lateral spreading, subsidence,
liquefaction or collapse.
The Modified Project would be required to comply with Air District Rule 403.
This Rule requires that excessive fugitive dust emissions be controlled with regular
watering or other dust prevention measures. Further, compliance with OC San
established protocols and existing regulations, including the implementation of
stormwater best management practices (BMPs) per the California Stormwater Quality
Association (CASQA) Construction Stormwater standards (e.g., sediment traps, straw
bale barriers, wind erosion/dust control, and filter berms, among others) would minimize
the potential of erosion at Plant No. 2 during construction.
The Modified Project would not change any operational aspects of the previously analyzed project. The Modified Project, therefore, would not result in new significant impacts or a
substantial increase in previously identified significant impacts pertaining to geology and
soils.
F. Greenhouse Gas Emissions
The potential greenhouse gas emissions impacts associated with the temporary use
of Lower Castaways Park for construction staging purposes were analyzed in the EIR. (Draft EIR, p. 3-12, 3-13, 5.6-11, 5.6-12, 5.6-13.). The Modified Project calls for hauling of soils both to and from Plant No. 2
during project construction. These proposed hauling activities are summarized in Tables
1-1, 1-2, and 1-3. Additionally, the Modified Project calls for soil drying / stockpiling at
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Plant No. 2 during project construction. The Modified Project’s soil haul trips and drying
/ stockpiling activities at Plant No. 2 would be temporary during construction and would
cease when construction is completed.
The Modified Project’s GHG emissions would be created by off-road construction
equipment and on-road vehicles (haul trucks and worker vehicles). The Modified Project
would generate a total of 1,743 MTCO2eq during construction, which is equivalent to
approximately 58.11 MTCO2eq/yr when amortized over 30 years; refer to Attachment 3,
Air Quality/Greenhouse Gas/Energy Data. As such, the Modified Project would not
result in GHG emissions in exceedance of the Air District’s 3,000 MTCO2eq/yr
significance threshold. Consequently, the Modified Project would not result in any
potentially adverse construction related GHG impacts.
The Modified Project would not interfere with implementation of any GHG reduction goals for 2030 or 2050 set forth in Assembly Bill (AB) 32, Senate Bill (SB) 32, Executive Order (EO) B-30-15, and EO S-3-05 because the Modified Project would not
exceed the Air District’s 3,000 MTCO2eq/yr significance threshold. Therefore, the
Modified Project would not conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs. The Modified Project would not change any operational aspects of the previously
analyzed project. The Modified Project, therefore, would not result in new significant impacts or a
substantial increase in previously identified significant impacts pertaining to greenhouse
gas emissions.
G. Hazards and Hazardous Materials
The potential hazards and hazardous materials impacts associated with the
temporary use of Lower Castaways Park for construction staging purposes were analyzed
in the EIR. (Draft EIR, p. 3-12, 3-13, 5.5-15, 5.7-13, 5.7-14, 5.7-15, 4.7-16, 5.7-17, 5.7-
20.).
Plant No. 2 is located within the City of Huntington Beach. The Huntington
Beach Fire Department includes the Emergency Management and Homeland Security
Division, which is responsible for coordinating the City’s emergency preparedness and
response activities. Additionally, Plant No. 2 is located within a Tsunami Hazard Zone.
Evacuation routes for the Tsunami Hazard Zone near Plant No. 2 include northbound
Bushard Street and northbound Brookhurst Street. It should be noted that no existing or
proposed K–12 schools are located within 0.25-mile of Plant No. 2. Also, Plant No. 2 is
not located within a wildland fire hazard area or within an airport land use plan or within
two miles of an airport.
Five underground storage tanks (USTs) are currently in use at Plant No. 2.
Further, multiple structures at Plant No. 2 contain asbestos-containing materials (ACM)
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and lead-based paint (LBP). In addition to ACM and LBPs, universal waste may be
present on-site including, but not limited to, polychlorinated biphenyls (PCBs), mercury
thermometers, and fluorescent light bulbs. Storage of hazardous materials on-site for
Plant No. 2 operations also include, but are not limited to, compressed gasses, diesel fuel,
and water treatment chemicals (hydrogen peroxide, sulfuric acid, salts, and flocculants).
Plant No. 2 is not listed on the California Environmental Protection Agency’s
Cortese List pursuant to California Government Code Section 65962.5. However,
multiple closed leaking underground storage tanks (LUST) cases and UST removals have
been documented with the Orange County Health Care Agency, Environmental Health
Department.
Multiple plugged oil and gas wells are located within the Plant No. 2 boundary.
Additionally, multiple active oil and gas wells are located within 0.25-mile of Plant No.
2.
The Modified Project’s proposed soil drying / stockpiling activities at Plant No. 2
would be temporary during construction, would cease when construction is completed,
and would not involve any demolition of on-site structures or ground disturbing
activities. Further, the Modified Project’s use of potentially hazardous materials
associated with truck hauling operations, including oils, lubricants, and vehicle fuels,
would comply with applicable Federal, State and local regulatory requirements. It is
acknowledged, however, that Plant No. 2 is situated in the proximity of identified
evacuation routes for the Tsunami Hazard Zone, and there is a potential for impacts
related to interference with an adopted emergency response or evacuation plan due to
hauling activities. As a result, Draft EIR Mitigation Measure TRA-1 would apply to the
Modified Project, with the following modifications:
TRA-1 Prior to initiation of construction activities, engineering drawings and
specifications, and/or contractor shop drawings shall be prepared by the
Project Engineer, or designee, and submitted for review and approval by
the Orange County Sanitation District, California Department of
Transportation (Caltrans), City of Huntington Beach Public Works
Department, and the City of Newport Beach Public Works Department.
These documents shall, at a minimum, address the following:
• Traffic control protocols shall be specified for any lane closure, detour,
or other disruption to traffic circulation, including bicycle and
pedestrian trails. Disruption to traffic circulation shall be minimized to
the greatest extent feasible. Bicycle and pedestrian trails shall remain
open, to the greatest extent feasible, during construction or shall be re-
routed to ensure continued connectivity.
• Bus stop access impacts shall be coordinated with, and approved by,
the Orange County Transportation Authority.
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• At least one week before any construction activities that would affect
travel on nearby roadways, the construction contractor shall notify the
City of Huntington Beach Public Works Department, City of Newport
Beach Public Works Department and Caltrans, as applicable, of
construction activities that could impede movement (such as lane
closures) along roadways, to allow for planning temporary detours or
identifying alternative emergency access routes where appropriate.
Surrounding property owners shall also be notified of project activities
through advanced mailings.
• Identify construction vehicle haul routes for the delivery of
construction materials (i.e., lumber, tiles, piping, windows, etc.) to the
site; necessary traffic controls and detours; and a construction phasing
plan for the project to reduce impacts to local streets and plan for
traffic control signage and detours along identified haul routes to
minimize impacts to existing traffic flow.
• Identify any and all construction staging or material storage sites
located outside of the project site.
• Specify the hours during which hauling activities can occur and
methods to mitigate construction-related impacts to adjacent streets
such as traffic control barricades, cones, flaggers, and warning signs.
• Require the contractor to keep all haul routes clean and free of debris,
including but not limited, to gravel and dirt resulting from project
construction. The Contractor shall clean adjacent streets, as directed by
the Orange County Sanitation District, of any project material which
may have been spilled, tracked, or blown onto adjacent City of
Newport Beach, City of Huntington Beach, and Caltrans streets or
areas.
• Hauling of oversize loads shall be allowed between the hours of 9:00
a.m. and 3:00 p.m. only, Monday through Friday. No hauling or
transport shall be allowed during nighttime hours, weekends, or
Federal holidays. Any oversized loads utilizing Coast Highway shall
obtain a Caltrans permit for such activities.
• Use of local streets shall be prohibited, except when required to
provide direct access to the project site and in compliance with the
approved project haul routes.
• Haul trucks entering or exiting public streets shall yield to public
traffic at all times.
• If hauling operations cause any damage to existing pavement, streets,
curbs, and/or gutters along the haul route, the contractor shall be fully
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responsible for repairs. The repairs shall restore the damaged property
to its original condition.
• All construction-related staging of vehicles shall be kept out of the
adjacent public roadways and shall occur on the project site or within
additional off-street staging areas previously identified and arranged.
• Construction-related lane closures would only occur between the hours
of 8:30 a.m. and 3:30 p.m., Monday through Friday. More or less
restrictive closure hours may be prescribed by the City.
• Use of a construction flagperson (as deemed appropriate by the Orange
County Sanitation District) to assist in maintaining efficient vehicle
travel in both directions (particularly during peak travel hours) and use
of construction signage and safe detour routes for pedestrians and
bicyclists when travel lanes and sidewalks along Coast Highway are
affected.
• The engineering drawings and specifications shall meet standards
established in the current California Manual on Uniform Traffic
Control Device (MUTCD).
With compliance with TRA-1, temporary construction-related impacts would be
less than significant. The Modified Project would not change any operational aspects of the previously analyzed project. Based on TRA-1 and the short-term duration of hauling and storage activities at
Plant No. 2, the Modified Project would not result in new significant impacts or a
substantial increase in previously identified significant impacts pertaining to hazards and
hazardous materials.
H. Hydrology & Water Quality
The potential hydrology and water quality impacts associated with the temporary use of Lower Castaways Park for construction staging purposes were analyzed in the EIR. (Draft EIR, p. 3-12, 3-13, 5.8-16, 5.8-17, 5.8-18, 5.8-19.).
Plant No. 2 is located within the Santa Ana Region Basin Plan (“Basin Plan”) and,
thus, is within the jurisdiction of the Santa Ana Regional Water Quality Control Board
(“RWQCB”). The Modified Project would be subject to the Basin Plan’s water quality
objectives, plans, and policies for surface water quality. Additionally, Plant No. 2 is
located within the Orange County Groundwater Basin and, therefore, is within the
jurisdiction of the Orange County Water District (“OCWD”). As such, the Modified
Project would also be subject to the OCWD Management Plan’s goals to protect and
enhance the groundwater quality of the Orange County Groundwater Basin, protect and
increase the sustainable yield of the basin in a cost-effective manner, and increase the
efficiency of OCWD’s operation.
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Plant No. 2 is fully developed with buildings, utility infrastructure, and access
roads. The vast majority of the soils on site have been significantly altered due to
compaction and construction of the facility. Plant No. 2 is located in a 500-year flood
zone or an area protected from the 100-year flood by an adjoining levee or dike, thus, the
Modified Project would be located outside a Special Flood Hazard Area and would not
impede or redirect flood flows.
The Modified Project’s soil drying / stockpiling activities would be temporary
during construction, cease when construction is completed, and would not require any
ground disturbing activities that could interfere with groundwater recharge or
substantially alter the existing drainage pattern of the site or area. Nevertheless,
compliance with OC San’s established protocols and existing regulations, including the
implementation of stormwater best management practices (BMPs) per the California
Stormwater Quality Association (CASQA) Construction Stormwater standards (e.g.,
sediment traps, straw bale barriers, wind erosion/dust control, and filter berms, among
others) would ensure the Modified Project would not violate any water quality standards
or waste discharge requirements, or otherwise substantially degrade surface quality from
construction activities. No new significant impacts pertaining to potential soil
erosion/runoff would result in this regard.
The Modified Project would not result in any new significant impacts pertaining to increased water demand during construction, compared to that considered in the Draft EIR.
The Modified Project would not change any operational aspects of the previously analyzed
project. The Modified Project, therefore, would not result in new significant impacts or a
substantial increase in previously identified significant impacts pertaining to hydrology
and water quality.
I. Land Use and Planning
The potential land use and planning impacts associated with the temporary use of
Lower Castaways Park for construction staging purposes were analyzed in the EIR.
(Draft EIR, p. 3-12, 3-13, 5.9-8., 5.9-9, 5.9-12, 5.9-14, 5.9-15, 5.9-16, 5.9-17).
Plant No. 2 is designated as Public (P) land use and zoned Industrial Limited (IL) and Residential Agriculture with an Oil Overlay (RA-O). (City of Huntington Beach 2015). The Public land use designation provides for government administrative and
related facilities, such as public utilities, public parking lots, and similar uses. The IL zoning designation allows for sites of moderate- to low-intensity industrial uses, commercial services, and light manufacturing. The RA-O zoning designation is intended to serve as a transition or holding zone for property with current agricultural activities and as a zone where restricted residential development is permitted. The RA-O also
provides areas to accommodate oil operations without drilling.
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The Modified Project’s proposed soil drying / stockpiling activities at Plant No. 2
would be temporary during construction, would cease when construction is completed,
would not require or result in changes to land uses or zoning designations at Plant No. 2,
and would not physically divide an established community. Additionally, the proposed
soil drying / stockpiling activities are a permitted activity/use within the RA-O zone and,
as such, would not conflict with the goals, objectives, and policies outlined in the City of
Huntington Beach’s Local Coastal Program and General Plan Coastal Element Land Use
Plan.
The Modified Project would not change any operational aspects of the previously
analyzed project.
Overall, the Modified Project would be consistent with applicable land use plans,
policies, and regulations, including the Local Coastal Program, General Plan and
Municipal Code. The Modified Project, therefore, would not result in new significant
impacts or a substantial increase in previously identified significant impacts pertaining to
land use and planning.
J. Noise
The potential noise impacts associated with the temporary use of Lower Castaways Park for construction staging purposes were analyzed in the EIR. (Draft EIR, p. 3-12, 3-13, 5.10-12, 5.10-13, 5.10-14, 5.10-15, 5.10-16, 5.10-17, 5.10-18). Also, Plant No. 2 is not located within an airport land use plan or within two miles of an airport.
The Modified Project calls for hauling of soils both to and from Plant No. 2
during project construction. These proposed hauling activities are summarized in Tables
1-1, 1-2, and 1-3. Additionally, the Modified Project calls for soil drying / stockpiling at
Plant No. 2 during project construction. Construction hauling activities at Plant No. 2
would occur between 7:00 AM and 5:00 PM and no activities would occur in the
nighttime hours. As such, these activities would not result in substantial noise increases
in the vicinity, compared to the existing condition. The hauling / soil drying / and
stockpiling activities at Plant No. 2 will not call for any equipment that could result in
vibration impacts (such as pile driving equipment).
The Modified Project, however, could result in short-term construction noise
impacts associated with off-road construction equipment and on-road vehicles (haul
trucks and worker vehicles). The Modified Project would generate up to 40 hauling trips
per day; refer to Attachment 3, Air Quality/Greenhouse Gas/Energy Data. Hauling trips
involving the placement at, and removal of, soil from Plant No. 2 would avoid sensitive
residential communities and would be along freeways and major roadways, except when
directly accessing Plant No. 2. Hauling trips would occur during daytime hours (and
would cease after 5:00 PM), would not significantly increase existing traffic noise levels
along the hauling routes, and would not result in a substantive temporary or long-term
increase in noise. Further, implementation of Mitigation Measure NOI-1 would require
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all construction equipment, including haul trucks, to be equipped with properly operating
and maintained mufflers to reduce noise.
Overall, noise impacts associated with the additional haul truck trips would be
temporary and cease upon completion of construction. Mitigation Measures NOI-1
would apply to the Modified Project, with the following modifications:
NOI-1 Prior to the initiation of construction, the Orange County Sanitation District
shall confirm that the Grading Plan, Building Plans, and specifications
require that:
• All construction equipment, fixed or mobile, shall be equipped with
properly operating and maintained mufflers and other State required
noise attenuation devices.
• The Orange County Sanitation District shall provide a “Community
LiaisonNoise Disturbance Coordinator.” The Community LiaisonNoise
Disturbance Coordinator shall be responsible for responding to any
local complaints about construction noise. When a complaint is
received, the Community LiaisonNoise Disturbance Coordinator shall
determine the cause of the noise complaint (e.g., starting too early, bad
muffler, etc.) and shall implement measures to resolve the complaint
and comply with the City of Huntington Beach and City of Newport
Beach Noise Ordinances. The construction hotline telephone number
shall be clearly posted on-site.
• Construction haul routes shall be designed to avoid noise sensitive uses
(e.g., residences, schools, hospitals, etc.) to the greatest extent possible.
• During construction, stationary construction equipment shall be placed
such that emitted noise is directed away from sensitive noise receivers.
• Construction activities that produce noise shall not take place outside of
the allowable hours specified by the City of Huntington Beach and City
of Newport Beach Municipal Codes, with the exception of the 24 hour
per day operation of microtunneling (pursuant to Mitigation Measure
NOI-2). Alternative work hours may be designated by the City to reduce
other impacts, such as traffic.
The Modified Project would not change any operational aspects of the previously analyzed project.
23
1780344.1
The Modified Project, therefore, would not result in new significant impacts or a
substantial increase in previously identified significant impacts pertaining to noise.
K. Population and Housing
The potential population and housing impacts associated with the temporary use
of Lower Castaways Park for construction staging purposes were analyzed in the EIR.
(Draft EIR, p. 3-12, 3-13, 8-1).
Plant No. 2 is fully developed with buildings, utility infrastructure, and access
roads. OC San staff provide operational and maintenance activities at Plant No. 2.
Additionally, there are no existing residents or housing at Plant No. 2.
The Modified Project would require construction workers to haul soil, and to both
place and remove soil from Plant No. 2. It is anticipated that these construction workers
would be located within the greater Orange County / Los Angeles area. As a result, the
Modified Project would not cause a substantial change in the labor force resulting in
unplanned population growth in the area. Soil drying and stockpiling within Plant No. 2
would not require the relocation or displacement of any people or housing.
The Modified Project would not change any operational aspects of the previously analyzed project.
The Modified Project, therefore, would not result in new significant impacts or a
substantial increase in previously identified significant impacts pertaining to population
and housing.
L. Public Services
The public facilities impacts associated with the temporary use of Lower
Castaways Park for construction staging purposes were analyzed in the EIR. (Draft EIR,
p. 3-12, 3-13, 8-1).
Plant No. 2 is located within the City of Huntington Beach. The Huntington
Beach Fire Department and Huntington Beach Police Department provide fire and police
services to the City of Huntington Beach, respectively.
The Modified Project would require construction workers to haul soil, and to both
place and remove soil from Plant No. 2. It is anticipated that these construction workers
would be located within the greater Orange County / Los Angeles area. As a result, the
Modified Project would not cause a substantial change in the labor force resulting in
unplanned population growth in the area. Soil drying and stockpiling within Plant No. 2
would not result in the need for new or physically altered fire, police, school, parks and
recreational, or other public service facilities.
24
1780344.1
The Modified Project would not change any operational aspects of the previously analyzed project.
The Modified Project, therefore, would not result in new significant impacts or a substantial increase in previously identified significant impacts pertaining to public services. M. Recreation
The potential recreation impacts associated with the temporary use of Lower
Castaways Park for construction staging purposes were analyzed in the EIR. (Draft EIR,
p. 3-12, 3-13, 8-1).
Plant No. 2 is fully developed with buildings, utility infrastructure, and access
roads. There are no recreational, educational, or visitor-oriented opportunities at Plant
No. 2.
It is anticipated that these construction workers would be located within the greater Orange County / Los Angeles area. As a result, the Modified Project would not cause a substantial change in the labor force that could result in new residents using existing
recreational facilities or requiring additional recreational facilities.
The Modified Project would not change any operational aspects of the previously analyzed project.
The Modified Project, therefore, would not result in new significant impacts or a
substantial increase in previously identified significant impacts pertaining to recreation.
N. Transportation
The potential transportation impacts associated with the temporary use of Lower
Castaways Park for construction staging purposes were analyzed in the EIR. (Draft EIR,
p. 3-12, 3-13, 5.11-6, 5.11-7, 5.11-8, 5.11-9, 5.11-10, 5.11-11). Plant No. 2 is located within the City of Huntington Beach. Transit services near
Plant No. 2 are provided by the Orange County Transit Authority with the closest bus
stop approximately 0.5-mile north of Plant No. 2 at the intersection of Hamilton Avenue
and Brookhurst Street. Plant No. 2 is located near existing roadway facilities including
Brookhurst Street, Bushard Street, and Banning Street. Existing bicycle facilities include
Class 1 multi-use bike paths along the Santa Ana River Trail and Class 2 bike lanes along
Bushard Street and Banning Street. It should be noted that an additional Class 2 bike
lane is proposed along Brookhurst Street. Existing pedestrian facilities are provided
along the Santa Ana River Trail, Huntington Beach Bike Trail, Brookhurst Street,
Bushard Street, and Banning Street.
The Modified Project calls for hauling of soils both to and from Plant No. 2
during project construction. These proposed hauling activities are summarized in Tables
25
1780344.1
1-1, 1-2, and 1-3. Additionally, the Modified Project calls for soil drying / stockpiling at
Plant No. 2 during project construction. The proposed soil haul trips and drying /
stockpiling activities at Plant No. 2 under the Modified Project would be temporary
during construction and would cease when construction is completed. The Modified
Project would include a total of 1,674 truck trips from soil hauling activities, which
would generate an increase in short-term vehicle trips on the circulation system during
construction. Such hauling activities are not anticipated to require lane closures or to
interfere with existing pedestrian/transit/bike access. Mitigation Measure TRA-1 would
apply to the Modified Project, with the following modifications:
TRA-1 Prior to initiation of construction activities, engineering drawings and
specifications, and/or contractor shop drawings shall be prepared by the
Project Engineer, or designee, and submitted for review and approval by
the Orange County Sanitation District, California Department of
Transportation (Caltrans), City of Huntington Beach Public Works
Department, and the City of Newport Beach Public Works Department.
These documents shall, at a minimum, address the following:
• Traffic control protocols shall be specified for any lane closure, detour,
or other disruption to traffic circulation, including bicycle and
pedestrian trails. Disruption to traffic circulation shall be minimized to
the greatest extent feasible. Bicycle and pedestrian trails shall remain
open, to the greatest extent feasible, during construction or shall be re-
routed to ensure continued connectivity.
• Bus stop access impacts shall be coordinated with, and approved by,
the Orange County Transportation Authority.
• At least one week before any construction activities that would affect
travel on nearby roadways, the construction contractor shall notify the
City of Huntington Beach Public Works Department, City of Newport
Beach Public Works Department and Caltrans, as applicable, of
construction activities that could impede movement (such as lane
closures) along roadways, to allow for planning temporary detours or
identifying alternative emergency access routes where appropriate.
Surrounding property owners shall also be notified of project activities
through advanced mailings.
• Identify construction vehicle haul routes for the delivery of
construction materials (i.e., lumber, tiles, piping, windows, etc.) to the
site; necessary traffic controls and detours; and a construction phasing
plan for the project to reduce impacts to local streets and plan for
traffic control signage and detours along identified haul routes to
minimize impacts to existing traffic flow.
26
1780344.1
• Identify any and all construction staging or material storage sites
located outside of the project site.
• Specify the hours during which hauling activities can occur and
methods to mitigate construction-related impacts to adjacent streets
such as traffic control barricades, cones, flaggers, and warning signs.
• Require the contractor to keep all haul routes clean and free of debris,
including but not limited, to gravel and dirt resulting from project
construction. The Contractor shall clean adjacent streets, as directed by
the Orange County Sanitation District, of any project material which
may have been spilled, tracked, or blown onto adjacent City of
Newport Beach, City of Huntington Beach, and Caltrans streets or
areas.
• Hauling of oversize loads shall be allowed between the hours of 9:00
a.m. and 3:00 p.m. only, Monday through Friday. No hauling or
transport shall be allowed during nighttime hours, weekends, or
Federal holidays. Any oversized loads utilizing Coast Highway shall
obtain a Caltrans permit for such activities.
• Use of local streets shall be prohibited, except when required to
provide direct access to the project site and in compliance with the
approved project haul routes.
• Haul trucks entering or exiting public streets shall yield to public
traffic at all times.
• If hauling operations cause any damage to existing pavement, streets,
curbs, and/or gutters along the haul route, the contractor shall be fully
responsible for repairs. The repairs shall restore the damaged property
to its original condition.
• All construction-related staging of vehicles shall be kept out of the
adjacent public roadways and shall occur on the project site or within
additional off-street staging areas previously identified and arranged.
• Construction-related lane closures would only occur between the hours
of 8:30 a.m. and 3:30 p.m., Monday through Friday. More or less
restrictive closure hours may be prescribed by the City.
• Use of a construction flagperson (as deemed appropriate by the Orange
County Sanitation District) to assist in maintaining efficient vehicle
travel in both directions (particularly during peak travel hours) and use
of construction signage and safe detour routes for pedestrians and
bicyclists when travel lanes and sidewalks along Coast Highway are
affected.
27
1780344.1
• The engineering drawings and specifications shall meet standards
established in the current California Manual on Uniform Traffic
Control Device (MUTCD).
As required by Mitigation Measure TRA-1, the project’s construction management plan (CMP) would identify construction vehicle hauling routes, necessary traffic controls and detours, and a construction phasing plan to reduce impacts to local
streets and plan for traffic control signage and detours along identified haul routes. The CMP would also specify the hours during which hauling activities could occur and would require traffic control barricades, cones, flaggers, and/or warning signs to reduce construction-related impacts to adjacent streets. Hauling of oversized loads would be
limited between the hours of 9:00 a.m. and 3:00 p.m. only, Monday through Friday, and
no hauling would be allowed during nighttime hours, weekends, or Federal holidays. Further, use of local streets within residential communities for truck hauling activities would be prohibited, except when required to provide direct access to the project site or Plant No. 2.
The Modified Project would not change any operational aspects of the previously analyzed project. Based on TRA-1 and the short-term duration of hauling and storage activities at
Plant No. 2, the Modified Project would not result in new significant impacts or a
substantial increase in previously identified significant impacts pertaining to
transportation.
O. Tribal Cultural Resources
The potential tribal cultural resources impacts associated with the temporary use
of Lower Castaways Park for construction staging purposes were analyzed in the EIR.
(Draft EIR, p. 3-12, 3-13, 5.12-12, 5.12-13).
No tribal cultural resources have been identified within Plant No. 2 which is fully
developed with buildings, utility infrastructure, and access roads. The vast majority of
the soils on site have been significantly altered due to compaction and construction of the
facility.
The Modified Project’s proposed soil drying / stockpiling activities at Plant No. 2
would be temporary during construction, would cease when construction is completed,
and would not require any ground disturbing activities that could lead to the discovery of
previously unknown or undiscovered tribal cultural resources.
The Modified Project would not change any operational aspects of the previously analyzed project.
The Modified Project, therefore, would not result in new significant impacts or a
substantial increase in previously identified significant impacts pertaining to tribal
cultural resources.
28
1780344.1
P. Utilities
The potential utilities impacts associated with the temporary use of Lower
Castaways Park for construction staging purposes were analyzed in the EIR. (Draft EIR,
p. 3-12, 3-13, 6.1, 6.2, 6-14).
Plant No. 2 is serviced by existing infrastructure operated by various public and
private entities. Existing infrastructure includes OC San pipelines that run parallel to or
intersect with existing water transmission and delivery pipelines, stormwater drainage
pipelines and channels, overhead electrical wires and underground electrical conduit,
underground natural gas pipelines, and overhead and underground telecommunications
lines.
The Modified Project calls for hauling of soils both to and from Plant No. 2
during project construction. These proposed hauling activities are summarized in Tables
1-1, 1-2, and 1-3. Additionally, the Modified Project calls for soil drying / stockpiling at
Plant No. 2 during project construction. The Modified Project’s proposed soil haul trips
and drying / stockpiling activities at Plant No. 2 would be temporary during construction
and would cease when construction is completed. Such activities would not require any
increases in the use of water, electrical, natural gas, or telecommunications facilities,
compared to that analyzed in the EIR. As such, no new physical changes to the
environment would result in this regard. Further, these activities would not result in an
increase in the generation of wastewater or solid waste. Last, these activities would not
result in any changes in impervious surfaces or the need for additional stormwater
facilities. It is anticipated that these construction workers would be located within the
greater Orange County / Los Angeles area. Therefore, the Modified Project would not
result in population growth that could increase demand on utilities and service systems,
including demand for water, wastewater treatment, stormwater drainage, electricity,
natural gas, telecommunications, or solid waste services.
The Modified Project would not change any operational aspects of the previously analyzed project.
The Modified Project, therefore, would not result in new significant impacts or a
substantial increase in previously identified significant impacts pertaining to utilities.
Q. Wildfire
Wildland fire hazards were analyzed in the EIR (Draft EIR p. 8-11 and 8-12).
Plant No. 2 and surrounding areas are not located within very high, high, or
moderate fire hazard severity zones.
29
1780344.1
Therefore, the Modified Project would not result in new significant impacts or a
substantial increase in the severity of previously identified significant impacts pertaining
to wildfires.
R. Other CEQA Considerations / Energy
The potential energy impacts associated with the temporary use of Lower
Castaways Park for construction staging purposes were analyzed in the EIR (Draft EIR p.
6-1, 6-2, and 6-7 through 6-18).
Plant No. 2 is located within the City of Huntington Beach. Southern California
Edison and Southern California Gas Company provide electricity and natural gas services
to the City of Huntington Beach, respectively.
Construction-related energy usage at Plant No. 2 would not result in wasteful, inefficient, or unnecessary use of energy, electricity, natural gas, or petroleum. The Modified Project calls for hauling of soils both to and from Plant No. 2 during project construction. These proposed hauling activities are summarized in Tables 1-1, 1-2, and
1-3. Additionally, the Modified Project calls for soil drying / stockpiling at Plant No. 2
during project construction. The proposed soil haul trips and drying / stockpiling activities at Plant No. 2 under the Modified Project would be temporary during construction and would cease when construction is completed. The Modified Project would include a total of 1,674 truck trips from soil hauling activities, which would
generate an increase in short-term vehicle trips on the circulation system during
construction. However, the total fuel consumption of the Modified Project is estimated to increase the County’s annual energy consumption by less than 0.01 percent, which would have a nominal effect on the local and regional energy supplies. Further, the Modified Project would adhere to all Federal, State, and local requirements for fuel efficiency (e.g.,
low carbon fuel standards, as applicable).
The Modified Project would not change any operational aspects of the previously analyzed project.
The Modified Project, therefore, would not result in new significant impacts or a
substantial increase in previously identified significant impacts pertaining to energy.
30
1780172.1
Attachment 1
ORANGE COUNTY SUPERIOR COURT CASE NO. 30-2021-01194238 RULING
SUPERIOR COURT OF CALIFORNIA, COUNTY OF ORANGE
Civil Complex Center
751 W. Santa Ana Blvd
Santa Ana, CA 92701
SHORT TITLE: BAYSIDE VILLAGE MARINA, LLC vs. ORANGE COUNTY SANITATION DISTRICT
CLERK'S CERTIFICATE OF MAILING/ELECTRONIC
SERVICE
CASE NUMBER:
30-2021-01194238-CU-WM-CXC
I certify that I am not a party to this cause. I certify that the following document(s), dated , have been transmitted
electronically by Orange County Superior Court at Santa Ana, CA. The transmission originated from Orange County
Superior Court email address on December 16, 2022, at 2:21:32 PM PST. The electronically transmitted document(s) is in
accordance with rule 2.251 of the California Rules of Court, addressed as shown above. The list of electronically served
recipients are listed below:
Clerk of the Court, by: , Deputy
NOSSAMAN LLP
JERSKINE@NOSSAMAN.COM
NOSSAMAN LLP
JFLYNN@NOSSAMAN.COM
WOODRUFF, SPRADLIN & SMART, APC
BHOGIN@WSS-LAW.COM
WOODRUFF, SPRADLIN & SMART, APC
BPATTERSON@WSS-LAW.COM
WOODRUFF, SPRADLIN & SMART, APC
RHAGER@WSS-LAW.COM
CLERK'S CERTIFICATE OF MAILING/ELECTRONIC SERVICE
V3 1013a (June 2004) Code of Civ. Procedure , § CCP1013(a)
JUDICIAL OFFICER PRESIDING:William Claster
COUNTY OF ORANGE
CIVIL COMPLEX CENTER
DATE:12/16/2022 DEPT:CX104TIME:02:16:00 PM
CLERK:G.HernandezREPORTER/ERM:NoneBAILIFF/COURT ATTENDANT:.None
CASE INIT.DATE:04/01/2021CASENO:30-2021-01194238-CU-WM-CXCCASETITLE:BAYSIDE VILLAGE MARINA,LLC vs.ORANGE COUNTY SANITATIONDISTRICTCASE CATEGORY: Civil - Unlimited CASE TYPE:Writ of Mandate
EVENT ID/DOCUMENT ID: 73909236
EVENT TYPE:Under Submission Ruling
RE PETITIONER'S WRIT OF MANDATE There are no appearances by any party.
The Court,having taken the above-entitled matter under submission on 12/14/2022 and having fullyconsideredtheargumentsofallparties,both written and oral,as well as the evidence presented,nowissues its ruling. The Court's ruling is attached hereto and incorporated herein by reference.
Court orders clerk to give notice.
DATE: 12/16/2022
DEPT: CX104 Calendar No.
Page 1
BAYSIDE VILLAGE MARINA LLC v. ORANGE COUNTY SANITATION DISTRICT 21-
1194238
Ruling Page 1
Petitioner Bayside Village Marina LLC (Bayside) seeks a writ of mandate
compelling Respondent Orange County Sanitation District (“OCSD” or the
“District”) to vacate and set aside its approval of (1) the OCSD’s Bay Bridge Pump
Station and Force Mains (“BBPS”) replacement project (“Project”) located on East
Coast Highway in Newport Beach, and (2) the certification of the Recirculated
Environmental Impact Report (“REIR”) for the Project. For the reasons set forth
below, the Court GRANTS a limited writ as set forth below.
I. BACKGROUND
Bayside is the owner of 31.4 acres of property located at East Coast Highway in
the City of Newport Beach, California between Newport Channel and Bayside
Drive. (ROA 25, First Amended Verified Petition (Petition), ¶ 9; AR230.)
Approximately 24 acres of Bayside’s property are developed with mobile homes,
and the remaining seven acres contain an outdoor storage space of RVs and small
boats, parking and restrooms facilities for the Bayside Marina, a kayak rental and
launch facility, parking and access to Pearson’s Port seafood market, and marine
service equipment storage under the Coast Highway Bridge (“BVM Property”).
(AR230, 011290.)
The seven acres are being developed as the “Back Bay Landing” Project, which is a
mixed-use development that will be implemented pursuant to the Newport
Beach- and Coastal Commission-approved Back Bay Planned Community
Development Plan (“PCDP”). It will have a boat storage facility, retail stores and
recreational marine-related facilities and residential units. (AR226, 230, 3274,
7539-97; Petition, ¶ 9.) Bayside is also the developer of this Back Bay project.
(Petition, ¶ 9.)
OCSD owns and operates the BBPS, which is located at 300 East Coast Highway in
Newport Beach, just east of the Newport Bay Channel. (ROA 103, Opp., p. 8;
AR186.) BBPS transports sewage or wastewater through pipelines to OCSD’s
BAYSIDE VILLAGE MARINA LLC v. ORANGE COUNTY SANITATION DISTRICT 21-
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Ruling Page 2
sewage treatment plant in Huntington Beach and is a piece of critical
infrastructures that conveys 50-60% of the total wastewater flow generated in
Newport Beach. (ROA 103, Opp., p. 8; AR186.) BBPS is located on the southern
boundary of Bayside’s property, is surrounded on three sides by that property,
and is adjacent to the Back Bay Landing Project. (AR230, 3206.)
The District’s Project involves the construction of a new, larger pump station
extending 100 feet to the west of the existing pump station and the installation of
new force mains. (AR186 and 237.) The new pump station facilities will include a
pump station, generator and odor control facilities. (AR186, 230.)
Planning on the Project started in 2013. (AR3206.) Since the Bayside Property, and
particularly the Back Bay Landing Project, surrounds the Project, from 2014-2016,
Bayside and OCSD exchanged information and worked together to discuss
alternatives for the Project. (See e.g., AR3206, 6371-72, 7040-43,7090, 7324,
7342-43, 15667, 16128-131.)
In June 2017, OCSD published a draft EIR that analyzed a version of the Project
involving the demolition of the existing facility, construction of a new and larger
facility adjacent to Bayside Drive and installation of force main improvements
beneath the Newport Bay Channel north of the Bay Bridge. (AR236, AR9383-84.)
The District never presented the 2017 Final EIR to its Board of Directors for
approval due to conflicts with the planned development of the Back Bay Landing
Project. (AR236, AR1501-1506.)
In July 2019, OCSD published a recirculated EIR with three alternatives for the
Project. (AR236, AR11613-14.) During the public comment period, there were
concerns regarding the three conceptual site plans, including confusion about one
of the alternatives known as the South Pump Station. (AR236.) OCSD did not
present the 2019 EIR to the OCSD Board.
BAYSIDE VILLAGE MARINA LLC v. ORANGE COUNTY SANITATION DISTRICT 21-
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Ruling Page 3
Instead, OCSD decided to select one conceptual site plan and construction
method and update the EIR in its entirety. (AR236.) The concept chosen and
analyzed in the 2020 recirculated EIR (REIR) is the Adjacent Pump Station, which is
essentially the South Pump Station alternative in the 2019 REIR. (AR237.)
The Final EIR (FEIR) was published in January 2021 and approved on March 1,
2021. (AR1-3.)
II. OVERVIEW OF CEQA PROCESS
“CEQA is a comprehensive scheme designed to provide long-term protection to
the environment. [Citation.]” (Mountain Lion Foundation v. Fish & Game Com.
(1997) 16 Cal.4th 105, 112.) It applies to “discretionary projects proposed to be
carried out or approved by public agencies.” (Pub. Resources Code, § 21080(a).)
“In enacting CEQA, the Legislature declared its intention that all public agencies
responsible for regulating activities affecting the environment give prime
consideration to preventing environmental damage when carrying out their
duties. [Citations.] CEQA is to be interpreted ‘to afford the fullest possible
protection to the environment within the reasonable scope of the statutory
language.’ [Citation.]” (Mountain Lion Foundation, supra, 16 Cal.4th at p. 112.)
An EIR, which has been described as “the heart of CEQA” (Citizens of Goleta Valley
v. Board of Supervisors (1990) 52 Cal.3d 553, 564), “is required for any project
that a public agency proposes to carry out or approve that may have a significant
effect on the environment. [Citations.] An EIR must describe the proposed project
and its environmental setting, state the objectives sought to be achieved, identify
and analyze the significant effects on the environment, state how those impacts
can be mitigated or avoided, and identify and analyze alternatives to the project,
BAYSIDE VILLAGE MARINA LLC v. ORANGE COUNTY SANITATION DISTRICT 21-
1194238
Ruling Page 4
among other requirements. [Citations.]” (Ballona Wetlands Land Trust v. City of
Los Angeles (2011) 201 Cal.App.4th 455, 465-66 (Ballona).)
Once a draft EIR is prepared, the public must be notified, and the draft and all
documents it references must be made available for public review and comment.
(Pub. Resources Code, §§ 21091(a), 21092; CEQA Guidelines, § 15087. 1) The
public agency acting as the lead agency then prepares a final EIR, which must
include comments received from the public and from other agencies concerning
the draft EIR, responses to those comments, and any revisions to the draft EIR.
(CEQA Guidelines, §§ 15088, 15132; Ballona, supra, 201 Cal.App.4th at p. 466.)
III. PROJECT DESCRIPTION
A. Overview
Bayside asserts that the EIR description of the Project and its environmental
setting is “inaccurate and unstable.” “The fundamental goal of an EIR is to inform
decision makers and the public of any significant adverse effects a project is likely
to have on the physical environment. [Citations.] To make such an assessment, an
EIR must delineate environmental conditions prevailing absent the project,
defining a baseline against which predicted effects can be described and
quantified. [Citation.]” (Neighbors for Smart Rail v. Exposition Metro Line
Construction Authority (2013) 57 Ca1.4th 439, 447.) This generally includes
providing “a description of the physical environmental conditions in the vicinity of
the project, as they exist at the time the notice of preparation is published, or if
no notice of preparation is published, at the time environmental analysis is
commenced, from both a local and regional perspective.” (Id., at p. 448; see CEQA
Guidelines, § 15125(a).)
1 References to the CEQA Guidelines are to Cal. Code Regs., tit. 14, § 15000 et seq.
BAYSIDE VILLAGE MARINA LLC v. ORANGE COUNTY SANITATION DISTRICT 21-
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Ruling Page 5
“Without accurate and complete information pertaining to the setting of the
project and surrounding uses, it cannot be found that the [EIR] adequately
investigated and discussed the environmental impacts of the development
project.” (San Joaquin Raptor/Wildlife Rescue Center v. County of Stanislaus
(1994) 27 Cal.App.4th 713, 729 (San Joaquin Raptor).) Thus, [i]f the description of
the environmental setting of the project site and surrounding area is inaccurate,
incomplete or misleading, the EIR does not comply with CEQA.” (Cadiz Land Co. v.
Rail Cycle (2000) 83 Cal.App.4th 74, 87.)
B. Failure to Identify Neighboring Commercial Operations
Bayside contends that repeated use of the phrase “RV Storage facility” obscures
“the site’s coastal-dependent, visitor serving uses.” (Pet. Supp. Br. at p. 16.)
Indeed, a number of businesses on the west side of the Project site (e.g.,
Southwind Kayaks, Gondola Adventures) are not mentioned by name anywhere in
any EIR.
While it is true that these businesses are not referenced by name and that the site
is referred to as an RV Storage facility (presumably since RVs are stored near
where the actual construction will take place), those references do not create an
inaccurate picture of the Project. In fact, the EIR refers to these businesses on the
west side of the Project as “commercial” or “commercial recreation marine uses”
in a number of places. (AR230, 234, 260, 392, 436.) The businesses also are listed
on Table 3-1 under “General Commercial.“ (AR235.)
The fact that the site is called an RV Storage facility is not misleading when
considering the EIR as a whole. The above-cited references to commercial activity
and the various maps/photos of the Project site overcome this alleged
shortcoming.
BAYSIDE VILLAGE MARINA LLC v. ORANGE COUNTY SANITATION DISTRICT 21-
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Ruling Page 6
A related purported flaw in the EIR’s Project description is the failure to address
the potential adverse physical impacts Project construction would have on these
businesses. On the contrary, such analysis is found at AR 473-482 regarding noise
and vibrations during construction, and at AR 302-305 with respect to air quality.
In terms of traffic, the EIR makes clear that access to the Project site will be
shared via Bayside Drive by construction vehicles and users of the commercial
facilities. As to the added construction and operational traffic, the EIR addresses
these issues at AR499 and in Impact Statement TRA-4.
C. Construction Staging Area Description
Bayside contends that the Project description is inaccurate and, indeed, is an
“unstable moving target” by virtue of the failure to describe and evaluate a
construction staging area. The Court agrees. The 2020 REIR includes several
references to construction staging. Page 3-11 states: “Portions of the adjacent
private property (currently a RV storage area) and Lower Castaways Park could be
temporarily utilized for construction staging, if these areas are available during
construction of the proposed project.” (AR241.) Then, in response to a letter from
the City of Newport Beach stating that the Lower Castaways would not be
available (AR1120), the 2021 FEIR noted: “Should Lower Castaways not be
available, construction staging would occur within other proposed areas of
disturbance (as identified in the project boundary shown on 2020 Recirculated
Draft EIR Exhibit 3-4).” (AR1127.)
Exhibit 3-4 is a Proposed Conceptual Site Plan that shows the areas (highlighted in
yellow) where the proposed project construction will take place as well as the
Lower Castaways. (AR238.) A virtually identical site plan (also highlighted in
yellow) is found at Exhibit 3-6 which is entitled Adjacent Pump Station Work
Areas. (AR243.) According to OCSD’s supplemental brief, based on the
unavailability of the Lower Castaways, “the construction staging will occur
BAYSIDE VILLAGE MARINA LLC v. ORANGE COUNTY SANITATION DISTRICT 21-
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Ruling Page 7
somewhere in this Adjacent Pump Station Work Area.” (OCSD Supp. Br. at p. 12.)
Based on this statement, the District argues in its supplemental brief that it
satisfied CEQA since the EIR “considered all potential impacts that could occur in
the Adjacent Area.”
However, based on a review of Exhibits 3-4 and 3-6, it is unclear whether creating
a staging area in the limited designated space is even possible. With the exception
of the Lower Castaways, the Coast Highway and the Newport channel, it appears
that the areas highlighted in yellow are where virtually all of the construction
actually will take place. Certainly, no specific location with adequate square
footage is identified, nor is there any analysis as to whether Mitigation Measures
AES-1 and TRA-1 would apply to any area other than the Lower Castaways.
Perhaps a more significant problem with the statements in both the FEIR and
supplemental brief about an alternative site in the project area is that they may
well be inaccurate. Indeed, TRA-1 tends to contradict OCSD’s supplemental brief
by virtue of acknowledging that future staging areas may be located off-site:
“[construction drawings shall] identify any and all construction staging or material
storage sites located outside of the project site.” (AR206 [emphasis added].)
Compounding this problem, counsel for the District told the Court at an earlier
hearing that the lowest responsible bidder on the Project will have complete
discretion to decide where staging will occur and how many staging sites will be
necessary. (August 4, 2022 Transcript at pp. 11-12.) Importantly, by not limiting
that comment to sites within the yellow-highlighted boundaries of Exhibits 3-4 or
3-6, the District appears to acknowledge that staging sites not identified in either
the REIR or FEIR might be utilized. Given that uncertainty, Bayside’s argument
regarding a lack of a complete, accurate and stable project description has merit.
More specifically, the District’s argument (OCSD Supp. Br. at p. 12) that the EIR
considered all environmental impacts (biological, noise, aesthetics, etc.) in the
BAYSIDE VILLAGE MARINA LLC v. ORANGE COUNTY SANITATION DISTRICT 21-
1194238
Ruling Page 8
Adjacent Area fails to account for any potential impacts that might occur if the
construction staging area occurs elsewhere. Without identifying the area or areas
where staging will occur, the public is left in the dark about whether that staging
will have any effects on the environment at location(s) yet to be identified.
Counsel’s statement that the lowest responsible bidder will have complete
discretion with regard to construction staging also renders the mitigation
measures of AES-1 toothless. AES-1 purports to minimize aesthetic impacts of
construction by requiring the District’s Director of Engineering to personally
approve construction staging areas, transport routes, etc. before grading or
demolition permits are issued. To the extent AES-1 actually imposes enforceable
standards (which the Court questions), it cannot be reconciled with the vesting of
complete discretion in the lowest responsible bidder.
IV. CONSIDERATION OF ALTERNATIVES
“An EIR shall describe a range of reasonable alternatives to the project, or to the
location of the project, which would feasibly attain most of the basic objectives of
the project but would avoid or substantially lessen any of the significant effects of
the project, and evaluate the comparative merits of the alternatives. An EIR need
not consider every conceivable alternative to a project. Rather it must consider a
reasonable range of potentially feasible alternatives that will foster informed
decisionmaking and public participation. An EIR is not required to consider
alternatives which are infeasible. The lead agency is responsible for selecting a
range of project alternatives for examination and must publicly disclose its
reasoning for selecting those alternatives. There is no ironclad rule governing the
nature or scope of the alternatives to be discussed other than the rule of reason.”
(CEQA Guidelines, § 15126.6(a).)
The EIR identified five alternatives to the Project to analyze in detail: the “no
project” scenario, the “adjacent project/microtunneling” scenario, the “original
BAYSIDE VILLAGE MARINA LLC v. ORANGE COUNTY SANITATION DISTRICT 21-
1194238
Ruling Page 9
northeast pump station with horizontal directional drilling” scenario, the
“rehabilitate in place with microtunneling” scenario, and the “pump station south
relocation with microtunneling” scenario. (AR539-540.) Nearly 40 pages of
analysis are devoted to comparing each of these alternatives to the Project.
(AR540-578.)
Bayside does not challenge the analysis presented. Rather, it faults the EIR for
failing to discuss two additional alternatives: the “Expand-in-Place” scenario and
alternative alignments for the dual force mains south of East Coast Highway.
“Courts will defer to an agency’s selection of alternatives unless the petitioners
(1) demonstrate that the chosen alternatives are “ ‘ “manifestly unreasonable and
... do not contribute to a reasonable range of alternatives,” ’ ” and (2) submit
evidence showing the rejected alternative was both “feasible” and “adequate,”
because it was capable of attaining most of the basic objectives of the project,
taking into account site suitability, economic viability, availability of
infrastructure, general plan consistency, and other relevant factors. [Citation.]”
(South of Market Community Action Network v. City and County of San Francisco
(2019) 33 Cal.App.5th 321, 345.)
The Court assumes for the sake of argument that the “Expand-in-Place” scenario
and the alternative alignments for the dual force mains are both feasible and
adequate. That is, the Court assumes Bayside has met the second prong of its
burden.
However, Bayside fails to meet the first prong of its burden. “The ‘key issue’ is
whether the range of alternatives discussed fosters informed decisionmaking and
public participation. [Citation.]” (Cherry Valley Pass Acres & Neighbors v. City of
Beaumont (190 Cal.App.4th 316, 354.) Bayside complains that two alternatives
were not considered, but it identifies no authority holding that the failure to
consider a specific alternative or alternatives automatically renders the range of
BAYSIDE VILLAGE MARINA LLC v. ORANGE COUNTY SANITATION DISTRICT 21-
1194238
Ruling Page 10
alternatives considered “manifestly unreasonable” or insufficient to “foster
informed decisionmaking.” (Compare id., at p. 355 [“Though one or more of these
328 imaginable alternatives may have represented the optimum number of
residences that could have profitably been built while minimizing the agricultural
impacts of the project to the fullest extent possible, the range of alternatives
discussed in the EIR was sufficient to foster informed decisionmaking on this very
question.”].)
V. INCONSISTENCIES WITH PLANS
A. Overview
Bayside contends the EIR is fatally flawed because it fails to disclose the Project’s
inconsistencies with the PCDP, the Newport Beach Local Coastal Program (“LCP”),
and the Coastal Act.
An EIR must discuss “any inconsistencies between the proposed project and
applicable general plans, specific plans and regional plan.” (CEQA Guidelines
§ 15125(d).) This includes inconsistencies with the Coastal Act. (Banning Ranch
Conservancy v. City of Newport Beach (2012) 211 Cal.App.4th 1209, 1233.) A
determination of consistency “comes to this [C]ourt with a strong presumption of
regularity. [Citation.] To overcome that presumption, an abuse of discretion must
be shown. [Citations.] An abuse of discretion is established only if the city council
has not proceeded in a manner required by law, its decision is not supported by
findings, or the findings are not supported by substantial evidence. [Citation].”
(Sequoyah Hills Homeowners Assn. v. City of Oakland (1993) 23 Cal.App.4th 704,
717.) “It is, emphatically, not the role of the courts to micro-manage these
development decisions. Our function is simply to decide whether the city
officials considered the applicable policies and the extent to which the proposed
project conforms with those policies, whether the city officials made appropriate
BAYSIDE VILLAGE MARINA LLC v. ORANGE COUNTY SANITATION DISTRICT 21-
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Ruling Page 11
findings on this issue, and whether those findings are supported by substantial
evidence.” (Id., at pp. 719-20 [emphasis in original].)
In addition, Bayside’s opening brief suggests the EIR is inadequate to the extent it
fails to explain why the District found the Project consistent with applicable plans.
(Pet. Opening Br. at p. 19, lines 6-8.) Because EIRs need only evaluate
inconsistencies with plans, no analysis is required if the project is consistent with
plans. (North Coast Rivers Alliance v. Marin Municipal Water Dist. Bd. of Directors
(2013) 216 Cal.App.4th 614, 632 [citing City of Long Beach v. Los Angeles Unified
School Dist. (2009) 176 Cal.App.4th 889, 918-19].) Insofar as Bayside argues the
explanation of consistency is inadequate (as opposed to arguing the finding of
consistency is an abuse of discretion), this challenge fails.
B. PCDP Inconsistency
The PCDP contains zoning regulations that dictate acceptable land uses in each
“Planning Area” it covers. It is undisputed that both the current pump station and
the new pump station to be built as part of the Project are in Planning Area 1.
According to the PCDP, “Wastewater Pump Station” is a permitted land use in
Planning Area 1. (AR7615.)
Bayside nevertheless contends the Project is inconsistent with the PCDP. It argues
that the PCDP “identifies the existence of the BBPS, however, only at its current
size and location, not the expanded size and altered location contemplated by the
Final EIR.” (Pet. Opening Br. at p. 18.) The claimed inconsistency apparently arises
from conceptual drawings attached to the PCDP (for parking plans, public spaces,
etc.) that show the BBPS in its current location in the context of the larger
planning area. (See AR7650-7663.) That is, as the Court understands the
argument, because the conceptual drawings show the current BBPS, any
deviation is an inconsistency.
BAYSIDE VILLAGE MARINA LLC v. ORANGE COUNTY SANITATION DISTRICT 21-
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Ruling Page 12
As the District points out in opposition, the PCDP imposes specific numeric limits
on the square footage of commercial, residential, marina, and dry dock use in
Planning Area 1, but not wastewater pump use. (AR7612.) The conceptual
drawings do not on their face appear to limit the size or the location of the
pumping station, only to show it in relation to other then-existing uses for
planning purposes. The only explicit limitation placed on a wastewater pump
station by the PCDP is that it must be in Planning Area 1. As to Bayside’s
contention that AR7549 allows the pump station also to be in Planning Area 2 (a
contention that the Court will accept even though it does not appear that AR7549
is in the record filed with the Court), that fact does not establish PCDP
inconsistency. Accordingly, the Court cannot say the finding of consistency is
unsupported by substantial evidence.
C. LCP Consistency
Bayside contends the Project is inconsistent with policy 2.1.9 of the LCP because
that policy “mandate[s] protection and expansion of coastal-dependent over
commercial/industrial uses.” (Pet.’s Opening Br. at p. 17.) As the District points
out, nothing in policy 2.1.9 or its associated sub-policies discusses the relative
priority of coastal-dependent uses vis-à-vis utility uses like the Project.
(Furthermore, it appears the only hard-and-fast priority is that coastal-dependent
uses are prioritized over residential uses, not over commercial/industrial uses.
See policy 2.1.9-1, at AR11289.)
In any event, the City correctly notes that relative priority matters only if the Back
Bay Landing development and the Project are a zero-sum game in terms of
developed square footage. Under the PCDP, square footage for a wastewater
pump station does not count against commercial, residential, marina, or dry dock
square footage. (See AR7612.) The Court cannot say the finding of consistency is
unsupported by substantial evidence.
BAYSIDE VILLAGE MARINA LLC v. ORANGE COUNTY SANITATION DISTRICT 21-
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Ruling Page 13
D. Coastal Act Consistency
Bayside contends the Project is inconsistent with multiple sections of the Coastal
Act, in particular Pub. Resources Code §§ 30213, 30221, 30222, 30224, and
30253(e), and policy 3.2.1-1 of the LCP, which similarly requires protection of
coastal recreation opportunities.
The Court agrees with the District that § 30222 is inapplicable. On its face, that
statute prioritizes “visitor-serving commercial recreational facilities designed to
enhance public opportunities for coastal recreation . . . over private residential,
general industrial, or general commercial development, but not over agriculture
or coastal-dependent industry.” Again, the Project is a utility use, not one of the
categories enumerated in this statute.
Of the remaining provisions, the only one discussed in any detail in Bayside’s
briefing (opening, reply, or supplemental) is § 30253(e) of the Coastal Act. The
remainder are simply referred to in laundry lists without discussion of any
particular alleged inconsistencies. Because Bayside bears the burden of showing
an abuse of discretion, the Court finds the failure to specifically discuss §§ 30123,
30221, and 30224 of the Coastal Act, as well as policy 3.2.1-1 of the LCP, means
Bayside has not shown an abuse of discretion in the District’s finding of
consistency.
As to § 30253(e), it provides: “New development shall . . . [w]here appropriate,
protect special communities and neighborhoods that, because of their unique
characteristics, are popular visitor destination points for recreational use.”
“Where appropriate” is an important qualifier here, as the District flags a
competing provision of the Coastal Act, § 30231, which provides: “The biological
productivity and the quality of coastal waters, streams, wetlands, estuaries, and
lakes appropriate to maintain optimum populations of marine organisms and for
the protection of human health shall be maintained and, where feasible, restored
BAYSIDE VILLAGE MARINA LLC v. ORANGE COUNTY SANITATION DISTRICT 21-
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Ruling Page 14
through, among other means, minimizing adverse effects of waste water
discharges and entrainment . . . .”
The administrative record contains evidence that the current pump station is
deteriorating and does not meet current standards for construction, electrical
equipment, or maintenance. (AR187.) The record also contains evidence that
failure of the system could result in the release of sewage into Newport Bay.
(AR187, 245.) Section 30231 of the Coastal Act imposes a mandatory policy for
protecting water quality (it “shall be maintained”), while § 30253(e) only imposes
a duty to protect recreational use “where appropriate.” On this record, the Court
cannot say the District lacked substantial evidence to conclude its duties under §
30231 prevailed over its duties under § 30253(e), and thereby to conclude the
Project is consistent with the Coastal Act. Put another way, Bayside must show
the District abused its discretion in finding the “where appropriate” qualifier in §
30253(e) inapplicable here, and it has not met its burden to do so.
VI. ADEQUACY OF RESPONSES TO COMMENTS
Bayside contends the District’s response to comments prior to certification of the
FEIR is inadequate. The Court agrees with the District that Bayside failed to
exhaust its administrative remedies on this issue. “[T]he time for complaining
about the inadequacy of [the District’s] responses was when the issue was before
the agency and any alleged deficiency could be explained or corrected.” (Towards
Responsibility in Planning v. City Council (1988) 200 Cal.App.3d 671, 682.) Bayside
points to nothing in the record indicating that the alleged inadequacy of the
District’s responses was raised at the administrative stage. As a result, this
challenge is barred.
Bayside responds that the foregoing statement from Towards Responsibility is
dictum unnecessary to the holding. This is true enough, as the Court of Appeal in
that case found the agency’s response to comments adequate on the merits. But
BAYSIDE VILLAGE MARINA LLC v. ORANGE COUNTY SANITATION DISTRICT 21-
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Ruling Page 15
“[t]o say that dicta are not controlling [citation] does not mean that they are to be
ignored; on the contrary, dicta are often followed.” (9 Witkin, Cal. Procedure (6th
ed. 2022) Appeal § 532.) And while Bayside cites a number of cases on page 21 of
its supplemental brief holding that inadequate responses to comments may
render an EIR defective, none of those cases discusses the effect of the
challenger’s failure to raise the inadequacy issue before the agency.
VII. REMEDIES AND CONCLUSION
For the reasons set forth above, Bayside’s petition is GRANTED on the ground that
the description of the construction staging area is inadequate, and for the related
reason that AES-1 is a toothless mitigation measure as a result.
Bayside asks the Court to set aside the District’s Project approvals and EIR
certification. Public Resources Code § 21168.9 gives the Court discretion to
fashion a narrower remedy. “The 1993 amendments to section 21168.9 expanded
the trial court’s authority and ‘expressly authorized the court to fashion a remedy
that permits some part of the project to go forward while an agency seeks to
remedy its CEQA violations. In other words, the issuance of a writ need not always
halt all work on a project.’ [Citation.]” (San Bernardino Valley Audubon Soc. V.
Metropolitan Water Dist. of Southern California (2001) 89 Cal.App.4th 1097, 1104-
1105.) “The choice of a lesser remedy involves the trial court’s consideration of
equitable principles.” (Id., at p. 1104.)
As discussed above, Bayside’s challenge is largely unsuccessful. And the vast
majority of Bayside’s challenge has little, if anything, to do with construction
staging issues. The Court therefore finds the remainder of the Project severable
from the construction staging issues. The Court further finds severance will not
prejudice full and complete compliance with CEQA, because the remainder of the
Project is CEQA-compliant. (Pub. Resources Code § 21168.9(b).)
BAYSIDE VILLAGE MARINA LLC v. ORANGE COUNTY SANITATION DISTRICT 21-
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Ruling Page 16
In considering equitable principles to fashion a remedy, the Court is especially
mindful of the severe risk to the environment that would be posed by the
outdated pumping station and force mains failing and spilling raw sewage into
Newport Bay. Furthermore, as explained in the District’s filings in the companion
eminent domain case, permitting from the relevant authorities is expected to take
9-12 months, with construction not starting for another six months after that.
(See OC Superior Court case no. 2022-01251890, ROA 92, at pp. 2-3.) Based on
representations made at the hearing, it appears that the City will not allow the
permitting process to start without OCSD approval of the Project and its
certification of the EIR. Of course, stalling that already lengthy process increases
the risk of the very sewage spill the Project seeks to prevent.
Because the issues with construction staging are both severable and appear to be
readily correctable, and given the overriding need for the Project, OCSD will not
be required to withdraw its approvals for the Project and certification of the EIR.
As explained by the court in Preserve Wild Santee v. City of Santee (2012) 210 Cal.
App. 4th 260, 287-88:
In our view, a reasonable, commonsense reading of section 21168.9 plainly
forecloses plaintiffs' assertion that a trial court must mandate a public
agency decertify the EIR and void all related project approvals in every
instance where the court finds an EIR violates CEQA. Such a rigid
requirement directly conflicts with the “in part” language in section
21168.9, subdivision (a)(1), which specifically allows a court to direct its
mandates to parts of determinations, parts of findings, or parts of
decisions. Such a rigid requirement also conflicts with the language
in section 21168.9, subdivision (b), limiting the court's mandates to only
those necessary to achieve CEQA compliance and, if the court makes
specified findings, to only “that portion of a determination, finding, or
decision” violating CEQA. (Italics added.)
BAYSIDE VILLAGE MARINA LLC v. ORANGE COUNTY SANITATION DISTRICT 21-
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Ruling Page 17
Accordingly, the Court will impose the limited remedy of requiring OCSD to bring
the EIR into CEQA compliance with respect to the construction staging issue and
the related question of the enforceability of AES-1. Because the District’s CEQA
noncompliance involves construction issues, this means no construction or other
physical activity may take place at the Project site until the District is in
compliance with CEQA. Whether bringing the EIR into compliance can be
accomplished via a supplemental EIR (CEQA Guidelines § 15163) or an addendum
(CEQA Guidelines § 15164) will be left to OCSD to decide.
Note that the Court’s order includes only these mandates, which are necessary to
achieve compliance with CEQA. (See Pub. Resources Code § 21168.9(b).) In order
to avoid unnecessary delay that increases the risk of a sewage spill, the District
may continue to seek the necessary permits from the City, Coastal Commission,
etc. to move forward with the Project, and it may continue to pursue the
companion eminent domain action.
Bayside shall prepare a proposed order in accordance with this ruling and provide
it to OCSD for comments before submitting it to the Court.
31
1780172.1
Attachment 2
LETTER OF INTENT FOR ENTERING INTO A LICENSING AGREEMENT –
LOWER CASTAWAYS PARK (“LETTER OF INTENT”)
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May 22, 2023
Orange County Sanitation District
Rob Thompson, General Manager
10844 Ellis Ave
Fountain Valley, CA 92708
CITY
100 Civic Center Drive
Newport Beach, California 92660
949 644-3001 I 949 644-3020 FAX
newportbeachca.gov
Re: Letter of Intent for Entering Into a Licensing Agreement -Lower Castaways Park
Dear Mr. Thompson:
This Letter of Intent reflects the City of Newport Beach (City) intent to enter into a Licensing
Agreement with the Orange County Sanitation District (OC SAN) to utilize portions of Lower
Castaways Park as construction staging area for the Bay Bridge Pump Station Replacement
project. The City understands as follows:
o WHEREAS, the City is the owner of the real property located at 700 Dover Drive, Newport
Beach, California, 92660 (the "Property"), known as "Castaways Park" and depicted in
yellow on Exhibit "A" attached hereto;
o WHEREAS, OC San wishes to lease 18,000 square feet of the lower portion of the
Property (as depicted on Exhibit "B" attached hereto) for use as a staging area in
connection with the future construction of the Bay Bridge Pump Station and Force Mains
Replacement Project ("Project"), a public infrastructure project; and
o WHEREAS, the City desires to lease the Property to OC SAN for the sole purpose of such
use.
o WHEREAS, the parties intend to enter into a licensing agreement at a future date to
memorialize the duties and obligations of each respective party for the use of the Property.
Based on this understanding and the mutual covenants and intentions stated herein, the City
intends as follows:
1. The City is preparing a licensing agreement for use of the Property as construction staging area
for the Project. The term of the licensing agreement will cover the construction period.
This document is a Letter of Intent only. It is not intended to be, and shall not constitute in any way,
a binding or legal agreement, or impose any legal obligation or duty on either of us. If this
document is not replaced by a valid binding contract signed by authorized representatives from
each company, it shall have no force or effect whatsoever.
City Manager's Office
Letter to OC Sanitation District
May 15, 2023
Page 2
If the foregoing reflects our mutual statement of intention, please sign, and return the enclosed
copy of this Letter of Intent.
Sincerely,
~~
"K.Leung
City Manager
City of Newport Beach
Orange County Sanitation District
Confirmed this ~ 3 r,1 day of ,441 y 2023
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32
1780172.1
Attachment 3
AIR QUALITY / GREENHOUSE GAS / ENERGY DATA
Bay Bridge (with Dredging) Detailed Report, 6/8/2023
1 / 194
Bay Bridge (with Dredging) Detailed Report
Table of Contents
1. Basic Project Information
1.1. Basic Project Information
1.2. Land Use Types
1.3. User-Selected Emission Reduction Measures by Emissions Sector
2. Emissions Summary
2.1. Construction Emissions Compared Against Thresholds
2.2. Construction Emissions by Year, Unmitigated
2.3. Construction Emissions by Year, Mitigated
2.4. Operations Emissions Compared Against Thresholds
2.5. Operations Emissions by Sector, Unmitigated
2.6. Operations Emissions by Sector, Mitigated
3. Construction Emissions Details
3.1. Demolition (2026) - Unmitigated
3.2. Demolition (2026) - Mitigated
Bay Bridge (with Dredging) Detailed Report, 6/8/2023
2 / 194
3.3. Demolition (2025) - Unmitigated
3.4. Demolition (2025) - Mitigated
3.5. Demolition (2026) - Unmitigated
3.6. Demolition (2026) - Mitigated
3.7. Demolition (2027) - Unmitigated
3.8. Demolition (2027) - Mitigated
3.9. Demolition (2028) - Unmitigated
3.10. Demolition (2028) - Mitigated
3.11. Demolition (2025) - Unmitigated
3.12. Demolition (2025) - Mitigated
3.13. Demolition (2026) - Unmitigated
3.14. Demolition (2026) - Mitigated
3.15. Demolition (2027) - Unmitigated
3.16. Demolition (2027) - Mitigated
3.17. Demolition (2028) - Unmitigated
3.18. Demolition (2028) - Mitigated
3.19. Grading (2024) - Unmitigated
Bay Bridge (with Dredging) Detailed Report, 6/8/2023
3 / 194
3.20. Grading (2024) - Mitigated
3.21. Grading (2025) - Unmitigated
3.22. Grading (2025) - Mitigated
3.23. Grading (2024) - Unmitigated
3.24. Grading (2024) - Mitigated
3.25. Grading (2025) - Unmitigated
3.26. Grading (2025) - Mitigated
3.27. Grading (2024) - Unmitigated
3.28. Grading (2024) - Mitigated
3.29. Grading (2025) - Unmitigated
3.30. Grading (2025) - Mitigated
3.31. Grading (2025) - Unmitigated
3.32. Grading (2025) - Mitigated
3.33. Grading (2025) - Unmitigated
3.34. Grading (2025) - Mitigated
3.35. Grading (2025) - Unmitigated
3.36. Grading (2025) - Mitigated
Bay Bridge (with Dredging) Detailed Report, 6/8/2023
4 / 194
3.37. Grading (2025) - Unmitigated
3.38. Grading (2025) - Mitigated
3.39. Demolition (2025) - Unmitigated
3.40. Demolition (2025) - Mitigated
3.41. Demolition (2026) - Unmitigated
3.42. Demolition (2026) - Mitigated
3.43. Demolition (2027) - Unmitigated
3.44. Demolition (2027) - Mitigated
3.45. Building Construction (2025) - Unmitigated
3.46. Building Construction (2025) - Mitigated
3.47. Building Construction (2026) - Unmitigated
3.48. Building Construction (2026) - Mitigated
3.49. Building Construction (2026) - Unmitigated
3.50. Building Construction (2026) - Mitigated
3.51. Building Construction (2027) - Unmitigated
3.52. Building Construction (2027) - Mitigated
3.53. Architectural Coating (2025) - Unmitigated
Bay Bridge (with Dredging) Detailed Report, 6/8/2023
5 / 194
3.54. Architectural Coating (2025) - Mitigated
3.55. Trenching (2024) - Unmitigated
3.56. Trenching (2024) - Mitigated
3.57. Trenching (2024) - Unmitigated
3.58. Trenching (2024) - Mitigated
3.59. Trenching (2025) - Unmitigated
3.60. Trenching (2025) - Mitigated
3.61. Trenching (2025) - Unmitigated
3.62. Trenching (2025) - Mitigated
3.63. Trenching (2025) - Unmitigated
3.64. Trenching (2025) - Mitigated
3.65. Trenching (2026) - Unmitigated
3.66. Trenching (2026) - Mitigated
3.67. Trenching (2027) - Unmitigated
3.68. Trenching (2027) - Mitigated
4. Operations Emissions Details
4.1. Mobile Emissions by Land Use
Bay Bridge (with Dredging) Detailed Report, 6/8/2023
6 / 194
4.1.1. Unmitigated
4.1.2. Mitigated
4.2. Energy
4.2.1. Electricity Emissions By Land Use - Unmitigated
4.2.2. Electricity Emissions By Land Use - Mitigated
4.2.3. Natural Gas Emissions By Land Use - Unmitigated
4.2.4. Natural Gas Emissions By Land Use - Mitigated
4.3. Area Emissions by Source
4.3.2. Unmitigated
4.3.1. Mitigated
4.4. Water Emissions by Land Use
4.4.2. Unmitigated
4.4.1. Mitigated
4.5. Waste Emissions by Land Use
4.5.2. Unmitigated
4.5.1. Mitigated
4.6. Refrigerant Emissions by Land Use
Bay Bridge (with Dredging) Detailed Report, 6/8/2023
7 / 194
4.6.1. Unmitigated
4.6.2. Mitigated
4.7. Offroad Emissions By Equipment Type
4.7.1. Unmitigated
4.7.2. Mitigated
4.8. Stationary Emissions By Equipment Type
4.8.1. Unmitigated
4.8.2. Mitigated
4.9. User Defined Emissions By Equipment Type
4.9.1. Unmitigated
4.9.2. Mitigated
4.10. Soil Carbon Accumulation By Vegetation Type
4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated
4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated
4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated
4.10.4. Soil Carbon Accumulation By Vegetation Type - Mitigated
4.10.5. Above and Belowground Carbon Accumulation by Land Use Type - Mitigated
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4.10.6. Avoided and Sequestered Emissions by Species - Mitigated
5. Activity Data
5.1. Construction Schedule
5.2. Off-Road Equipment
5.2.1. Unmitigated
5.2.2. Mitigated
5.3. Construction Vehicles
5.3.1. Unmitigated
5.3.2. Mitigated
5.4. Vehicles
5.4.1. Construction Vehicle Control Strategies
5.5. Architectural Coatings
5.6. Dust Mitigation
5.6.1. Construction Earthmoving Activities
5.6.2. Construction Earthmoving Control Strategies
5.7. Construction Paving
5.8. Construction Electricity Consumption and Emissions Factors
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5.9. Operational Mobile Sources
5.9.1. Unmitigated
5.9.2. Mitigated
5.10. Operational Area Sources
5.10.1. Hearths
5.10.1.1. Unmitigated
5.10.1.2. Mitigated
5.10.2. Architectural Coatings
5.10.3. Landscape Equipment
5.10.4. Landscape Equipment - Mitigated
5.11. Operational Energy Consumption
5.11.1. Unmitigated
5.11.2. Mitigated
5.12. Operational Water and Wastewater Consumption
5.12.1. Unmitigated
5.12.2. Mitigated
5.13. Operational Waste Generation
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5.13.1. Unmitigated
5.13.2. Mitigated
5.14. Operational Refrigeration and Air Conditioning Equipment
5.14.1. Unmitigated
5.14.2. Mitigated
5.15. Operational Off-Road Equipment
5.15.1. Unmitigated
5.15.2. Mitigated
5.16. Stationary Sources
5.16.1. Emergency Generators and Fire Pumps
5.16.2. Process Boilers
5.17. User Defined
5.18. Vegetation
5.18.1. Land Use Change
5.18.1.1. Unmitigated
5.18.1.2. Mitigated
5.18.1. Biomass Cover Type
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5.18.1.1. Unmitigated
5.18.1.2. Mitigated
5.18.2. Sequestration
5.18.2.1. Unmitigated
5.18.2.2. Mitigated
6. Climate Risk Detailed Report
6.1. Climate Risk Summary
6.2. Initial Climate Risk Scores
6.3. Adjusted Climate Risk Scores
6.4. Climate Risk Reduction Measures
7. Health and Equity Details
7.1. CalEnviroScreen 4.0 Scores
7.2. Healthy Places Index Scores
7.3. Overall Health & Equity Scores
7.4. Health & Equity Measures
7.5. Evaluation Scorecard
7.6. Health & Equity Custom Measures
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8. User Changes to Default Data
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1. Basic Project Information
1.1. Basic Project Information
Data Field Value
Project Name Bay Bridge (with Dredging)
Construction Start Date 7/1/2023
Operational Year 2028
Lead Agency —
Land Use Scale Project/site
Analysis Level for Defaults County
Windspeed (m/s)2.50
Precipitation (days)16.2
Location 33.61636544504624, -117.90701330233207
County Orange
City Newport Beach
Air District South Coast AQMD
Air Basin South Coast
TAZ 5917
EDFZ 7
Electric Utility Southern California Edison
Gas Utility Southern California Gas
App Version 2022.1.1.13
1.2. Land Use Types
Land Use Subtype Size Unit Lot Acreage Building Area (sq ft)Landscape Area (sq
ft)
Special Landscape
Area (sq ft)
Population Description
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General Light
Industry
14.5 1000sqft 0.33 14,500 1,000 ———
Other Asphalt
Surfaces
16.0 1000sqft 0.37 0.00 0.09 ———
1.3. User-Selected Emission Reduction Measures by Emissions Sector
Sector #Measure Title
Construction C-2*Limit Heavy-Duty Diesel Vehicle Idling
Construction C-10-A Water Exposed Surfaces
Construction C-10-C Water Unpaved Construction Roads
Construction C-11 Limit Vehicle Speeds on Unpaved Roads
Construction C-12 Sweep Paved Roads
Energy E-1 Buildings Exceed 2019 Title 24 Building Envelope Energy
Efficiency Standards
Waste S-1/S-2 Implement Waste Reduction Plan
* Qualitative or supporting measure. Emission reductions not included in the mitigated emissions results.
2. Emissions Summary
2.1. Construction Emissions Compared Against Thresholds
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Un/Mit.TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Unmit.5.37 4.50 40.7 40.0 0.08 1.74 0.96 2.36 1.60 0.21 1.75 —9,573 9,573 0.39 0.30 4.72 9,624
Mit.5.37 4.50 40.7 40.0 0.08 1.74 0.96 2.36 1.60 0.21 1.75 —9,573 9,573 0.39 0.30 4.72 9,624
%
Reduced
———————< 0.5%——————————
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Daily,
Winter
(Max)
——————————————————
Unmit.4.53 18.0 34.0 33.6 0.07 1.39 0.99 2.21 1.28 0.20 1.42 —8,134 8,134 0.34 0.20 0.09 8,177
Mit.4.53 18.0 34.0 33.6 0.07 1.39 0.99 2.21 1.28 0.20 1.42 —8,134 8,134 0.34 0.20 0.09 8,177
%
Reduced
——————————————————
Average
Daily
(Max)
——————————————————
Unmit.2.39 2.18 17.6 18.2 0.04 0.68 0.51 1.19 0.62 0.12 0.74 —5,011 5,011 0.21 0.11 0.92 5,051
Mit.2.39 2.18 17.6 18.2 0.04 0.68 0.51 1.18 0.62 0.12 0.74 —5,011 5,011 0.21 0.11 0.92 5,051
%
Reduced
——————< 0.5%< 0.5%——————————
Annual
(Max)
——————————————————
Unmit.0.44 0.40 3.22 3.32 0.01 0.12 0.09 0.22 0.11 0.02 0.14 —830 830 0.04 0.02 0.15 836
Mit.0.44 0.40 3.22 3.32 0.01 0.12 0.09 0.22 0.11 0.02 0.14 —830 830 0.04 0.02 0.15 836
%
Reduced
——————< 0.5%< 0.5%—< 0.5%< 0.5%———————
Exceeds
(Daily
Max)
——————————————————
Threshol
d
—75.0 100 550 150 ——150 ——55.0 ———————
Unmit.Yes No No No No Yes —No Yes —No ———————
Mit.Yes No No No No Yes —No Yes —No ———————
Exceeds
(Average
Daily)
——————————————————
Threshol
d
—75.0 100 550 150 ——150 ——55.0 ———————
Unmit.Yes No No No No Yes —No Yes —No ———————
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Mit.Yes No No No No Yes —No Yes —No ———————
2.2. Construction Emissions by Year, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Year TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily -
Summer
(Max)
——————————————————
2024 5.37 4.50 40.7 40.0 0.08 1.74 0.62 2.36 1.60 0.15 1.75 —9,573 9,573 0.38 0.13 2.88 9,624
2025 3.33 2.78 24.5 26.8 0.07 0.92 0.96 1.88 0.84 0.21 1.05 —8,543 8,543 0.39 0.30 4.72 8,646
2026 0.67 0.55 4.64 5.95 0.01 0.11 0.57 0.68 0.10 0.10 0.20 —931 931 0.04 0.03 0.54 940
2027 0.64 0.52 4.51 5.89 0.01 0.09 0.57 0.66 0.08 0.10 0.18 —928 928 0.04 0.03 0.49 937
Daily -
Winter
(Max)
——————————————————
2024 4.53 3.79 34.0 31.2 0.07 1.39 0.59 1.98 1.28 0.14 1.42 —8,134 8,134 0.33 0.12 0.07 8,177
2025 4.35 18.0 31.6 33.6 0.07 1.21 0.99 2.21 1.11 0.20 1.31 —7,892 7,892 0.34 0.20 0.09 7,959
2026 3.22 2.70 23.2 25.4 0.05 0.87 0.96 1.83 0.80 0.19 0.99 —5,212 5,212 0.20 0.08 0.05 5,241
2027 3.13 2.61 22.4 25.0 0.05 0.81 0.96 1.77 0.74 0.19 0.93 —5,201 5,201 0.20 0.08 0.05 5,230
2028 0.40 0.33 2.90 3.85 0.01 0.05 0.26 0.31 0.05 0.05 0.09 —587 587 0.02 0.01 0.01 592
Average
Daily
——————————————————
2024 1.74 1.46 13.1 12.3 0.03 0.54 0.21 0.76 0.50 0.05 0.55 —3,112 3,112 0.12 0.04 0.43 3,128
2025 2.39 2.18 17.6 18.2 0.04 0.68 0.51 1.19 0.62 0.12 0.74 —5,011 5,011 0.21 0.11 0.92 5,051
2026 0.82 0.68 5.80 6.92 0.01 0.18 0.46 0.64 0.16 0.08 0.25 —1,253 1,253 0.05 0.03 0.26 1,262
2027 0.66 0.54 4.71 5.93 0.01 0.12 0.42 0.55 0.11 0.08 0.19 —1,050 1,050 0.04 0.02 0.20 1,058
2028 0.02 0.02 0.16 0.21 < 0.005 < 0.005 0.01 0.02 < 0.005 < 0.005 < 0.005 —32.2 32.2 < 0.005 < 0.005 0.01 32.5
Annual ——————————————————
2024 0.32 0.27 2.39 2.25 < 0.005 0.10 0.04 0.14 0.09 0.01 0.10 —515 515 0.02 0.01 0.07 518
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2025 0.44 0.40 3.22 3.32 0.01 0.12 0.09 0.22 0.11 0.02 0.14 —830 830 0.04 0.02 0.15 836
2026 0.15 0.12 1.06 1.26 < 0.005 0.03 0.08 0.12 0.03 0.01 0.04 —207 207 0.01 < 0.005 0.04 209
2027 0.12 0.10 0.86 1.08 < 0.005 0.02 0.08 0.10 0.02 0.01 0.03 —174 174 0.01 < 0.005 0.03 175
2028 < 0.005 < 0.005 0.03 0.04 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —5.34 5.34 < 0.005 < 0.005 < 0.005 5.38
2.3. Construction Emissions by Year, Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Year TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily -
Summer
(Max)
——————————————————
2024 5.37 4.50 40.7 40.0 0.08 1.74 0.62 2.36 1.60 0.15 1.75 —9,573 9,573 0.38 0.13 2.88 9,624
2025 3.33 2.78 24.5 26.8 0.07 0.92 0.96 1.88 0.84 0.21 1.05 —8,543 8,543 0.39 0.30 4.72 8,646
2026 0.67 0.55 4.64 5.95 0.01 0.11 0.57 0.68 0.10 0.10 0.20 —931 931 0.04 0.03 0.54 940
2027 0.64 0.52 4.51 5.89 0.01 0.09 0.57 0.66 0.08 0.10 0.18 —928 928 0.04 0.03 0.49 937
Daily -
Winter
(Max)
——————————————————
2024 4.53 3.79 34.0 31.2 0.07 1.39 0.59 1.98 1.28 0.14 1.42 —8,134 8,134 0.33 0.12 0.07 8,177
2025 4.35 18.0 31.6 33.6 0.07 1.21 0.99 2.21 1.11 0.20 1.31 —7,892 7,892 0.34 0.20 0.09 7,959
2026 3.22 2.70 23.2 25.4 0.05 0.87 0.96 1.83 0.80 0.19 0.99 —5,212 5,212 0.20 0.08 0.05 5,241
2027 3.13 2.61 22.4 25.0 0.05 0.81 0.96 1.77 0.74 0.19 0.93 —5,201 5,201 0.20 0.08 0.05 5,230
2028 0.40 0.33 2.90 3.85 0.01 0.05 0.26 0.31 0.05 0.05 0.09 —587 587 0.02 0.01 0.01 592
Average
Daily
——————————————————
2024 1.74 1.46 13.1 12.3 0.03 0.54 0.21 0.76 0.50 0.05 0.55 —3,112 3,112 0.12 0.04 0.43 3,128
2025 2.39 2.18 17.6 18.2 0.04 0.68 0.51 1.18 0.62 0.12 0.74 —5,011 5,011 0.21 0.11 0.92 5,051
2026 0.82 0.68 5.80 6.92 0.01 0.18 0.46 0.64 0.16 0.08 0.25 —1,253 1,253 0.05 0.03 0.26 1,262
2027 0.66 0.54 4.71 5.93 0.01 0.12 0.42 0.55 0.11 0.08 0.19 —1,050 1,050 0.04 0.02 0.20 1,058
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2028 0.02 0.02 0.16 0.21 < 0.005 < 0.005 0.01 0.02 < 0.005 < 0.005 < 0.005 —32.2 32.2 < 0.005 < 0.005 0.01 32.5
Annual ——————————————————
2024 0.32 0.27 2.39 2.25 < 0.005 0.10 0.04 0.14 0.09 0.01 0.10 —515 515 0.02 0.01 0.07 518
2025 0.44 0.40 3.22 3.32 0.01 0.12 0.09 0.22 0.11 0.02 0.14 —830 830 0.04 0.02 0.15 836
2026 0.15 0.12 1.06 1.26 < 0.005 0.03 0.08 0.12 0.03 0.01 0.04 —207 207 0.01 < 0.005 0.04 209
2027 0.12 0.10 0.86 1.08 < 0.005 0.02 0.08 0.10 0.02 0.01 0.03 —174 174 0.01 < 0.005 0.03 175
2028 < 0.005 < 0.005 0.03 0.04 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —5.34 5.34 < 0.005 < 0.005 < 0.005 5.38
2.4. Operations Emissions Compared Against Thresholds
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Un/Mit.TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Unmit.0.13 0.44 0.17 0.77 < 0.005 0.01 0.00 0.01 0.01 0.00 0.01 16.1 438 454 1.66 0.02 3.77 504
Mit.0.13 0.44 0.16 0.76 < 0.005 0.01 0.00 0.01 0.01 0.00 0.01 11.3 385 396 1.17 0.02 3.77 434
%
Reduced
——4%1%———————30%12%13%29%——14%
Daily,
Winter
(Max)
——————————————————
Unmit.0.02 0.34 0.17 0.14 < 0.005 0.01 0.00 0.01 0.01 0.00 0.01 16.1 435 451 1.66 0.02 3.77 502
Mit.0.02 0.34 0.16 0.13 < 0.005 0.01 0.00 0.01 0.01 0.00 0.01 11.3 382 394 1.17 0.02 3.77 432
%
Reduced
——4%4%———————30%12%13%29%——14%
Average
Daily
(Max)
——————————————————
Unmit.0.10 0.41 0.17 0.57 < 0.005 0.01 0.00 0.01 0.01 0.00 0.01 16.1 437 453 1.66 0.02 3.77 503
Mit.0.09 0.41 0.16 0.57 < 0.005 0.01 0.00 0.01 0.01 0.00 0.01 11.3 384 395 1.17 0.02 3.77 434
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%
Reduced
——4%1%———————30%12%13%29%——14%
Annual
(Max)
——————————————————
Unmit.0.02 0.08 0.03 0.10 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 2.67 72.3 75.0 0.27 < 0.005 0.62 83.4
Mit.0.02 0.07 0.03 0.10 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 1.87 63.6 65.5 0.19 < 0.005 0.62 71.8
%
Reduced
1%< 0.5%4%1%4%4%—4%4%—4%30%12%13%29%2%—14%
Exceeds
(Daily
Max)
——————————————————
Threshol
d
—55.0 55.0 550 150 ——150 ——55.0 ———————
Unmit.—No No No No ——No ——No ———————
Mit.—No No No No ——No ——No ———————
Exceeds
(Average
Daily)
——————————————————
Threshol
d
—55.0 55.0 550 150 ——150 ——55.0 ———————
Unmit.—No No No No ——No ——No ———————
Mit.—No No No No ——No ——No ———————
2.5. Operations Emissions by Sector, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Sector TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Mobile 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Area 0.11 0.43 0.01 0.63 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —2.59 2.59 < 0.005 < 0.005 —2.60
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Energy 0.02 0.01 0.17 0.14 < 0.005 0.01 —0.01 0.01 —0.01 —402 402 0.03 < 0.005 —403
Water ———————————6.43 33.4 39.8 0.66 0.02 —61.1
Waste ———————————9.69 0.00 9.69 0.97 0.00 —33.9
Refrig.————————————————3.77 3.77
Total 0.13 0.44 0.17 0.77 < 0.005 0.01 0.00 0.01 0.01 0.00 0.01 16.1 438 454 1.66 0.02 3.77 504
Daily,
Winter
(Max)
——————————————————
Mobile 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Area —0.33 ————————————————
Energy 0.02 0.01 0.17 0.14 < 0.005 0.01 —0.01 0.01 —0.01 —402 402 0.03 < 0.005 —403
Water ———————————6.43 33.4 39.8 0.66 0.02 —61.1
Waste ———————————9.69 0.00 9.69 0.97 0.00 —33.9
Refrig.————————————————3.77 3.77
Total 0.02 0.34 0.17 0.14 < 0.005 0.01 0.00 0.01 0.01 0.00 0.01 16.1 435 451 1.66 0.02 3.77 502
Average
Daily
——————————————————
Mobile 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Area 0.08 0.40 < 0.005 0.43 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —1.78 1.78 < 0.005 < 0.005 —1.78
Energy 0.02 0.01 0.17 0.14 < 0.005 0.01 —0.01 0.01 —0.01 —402 402 0.03 < 0.005 —403
Water ———————————6.43 33.4 39.8 0.66 0.02 —61.1
Waste ———————————9.69 0.00 9.69 0.97 0.00 —33.9
Refrig.————————————————3.77 3.77
Total 0.10 0.41 0.17 0.57 < 0.005 0.01 0.00 0.01 0.01 0.00 0.01 16.1 437 453 1.66 0.02 3.77 503
Annual ——————————————————
Mobile 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Area 0.01 0.07 < 0.005 0.08 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —0.29 0.29 < 0.005 < 0.005 —0.30
Energy < 0.005 < 0.005 0.03 0.03 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —66.5 66.5 < 0.005 < 0.005 —66.7
Water ———————————1.06 5.52 6.59 0.11 < 0.005 —10.1
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Waste ———————————1.60 0.00 1.60 0.16 0.00 —5.61
Refrig.————————————————0.62 0.62
Total 0.02 0.08 0.03 0.10 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 2.67 72.3 75.0 0.27 < 0.005 0.62 83.4
2.6. Operations Emissions by Sector, Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Sector TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Mobile 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Area 0.11 0.43 0.01 0.63 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —2.59 2.59 < 0.005 < 0.005 —2.60
Energy 0.02 0.01 0.16 0.13 < 0.005 0.01 —0.01 0.01 —0.01 —349 349 0.03 < 0.005 —350
Water ———————————6.43 33.4 39.8 0.66 0.02 —61.1
Waste ———————————4.85 0.00 4.85 0.48 0.00 —17.0
Refrig.————————————————3.77 3.77
Total 0.13 0.44 0.16 0.76 < 0.005 0.01 0.00 0.01 0.01 0.00 0.01 11.3 385 396 1.17 0.02 3.77 434
Daily,
Winter
(Max)
——————————————————
Mobile 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Area —0.33 ————————————————
Energy 0.02 0.01 0.16 0.13 < 0.005 0.01 —0.01 0.01 —0.01 —349 349 0.03 < 0.005 —350
Water ———————————6.43 33.4 39.8 0.66 0.02 —61.1
Waste ———————————4.85 0.00 4.85 0.48 0.00 —17.0
Refrig.————————————————3.77 3.77
Total 0.02 0.34 0.16 0.13 < 0.005 0.01 0.00 0.01 0.01 0.00 0.01 11.3 382 394 1.17 0.02 3.77 432
Average
Daily
——————————————————
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Mobile 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Area 0.08 0.40 < 0.005 0.43 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —1.78 1.78 < 0.005 < 0.005 —1.78
Energy 0.02 0.01 0.16 0.13 < 0.005 0.01 —0.01 0.01 —0.01 —349 349 0.03 < 0.005 —350
Water ———————————6.43 33.4 39.8 0.66 0.02 —61.1
Waste ———————————4.85 0.00 4.85 0.48 0.00 —17.0
Refrig.————————————————3.77 3.77
Total 0.09 0.41 0.16 0.57 < 0.005 0.01 0.00 0.01 0.01 0.00 0.01 11.3 384 395 1.17 0.02 3.77 434
Annual ——————————————————
Mobile 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Area 0.01 0.07 < 0.005 0.08 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —0.29 0.29 < 0.005 < 0.005 —0.30
Energy < 0.005 < 0.005 0.03 0.02 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —57.8 57.8 < 0.005 < 0.005 —58.0
Water ———————————1.06 5.52 6.59 0.11 < 0.005 —10.1
Waste ———————————0.80 0.00 0.80 0.08 0.00 —2.81
Refrig.————————————————0.62 0.62
Total 0.02 0.07 0.03 0.10 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 1.87 63.6 65.5 0.19 < 0.005 0.62 71.8
3. Construction Emissions Details
3.1. Demolition (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Demolitio
n
——————0.00 0.00 —0.00 0.00 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
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Daily,
Winter
(Max)
——————————————————
Demolitio
n
——————0.00 0.00 —0.00 0.00 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Demolitio
n
——————0.00 0.00 —0.00 0.00 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Demolitio
n
——————0.00 0.00 —0.00 0.00 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
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Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.2. Demolition (2026) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Demolitio
n
——————0.00 0.00 —0.00 0.00 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Demolitio
n
——————0.00 0.00 —0.00 0.00 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Demolitio
n
——————0.00 0.00 —0.00 0.00 ———————
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0.000.000.000.000.000.00—0.000.000.000.000.000.000.000.000.000.000.00Onsite
truck
Annual ——————————————————
Demolitio
n
——————0.00 0.00 —0.00 0.00 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
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3.3. Demolition (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
0.23 0.19 1.54 1.85 < 0.005 0.04 —0.04 0.04 —0.04 —244 244 0.01 < 0.005 —245
Demolitio
n
——————0.09 0.09 —0.01 0.01 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
0.23 0.19 1.54 1.85 < 0.005 0.04 —0.04 0.04 —0.04 —244 244 0.01 < 0.005 —245
Demolitio
n
——————0.09 0.09 —0.01 0.01 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.04 0.04 0.29 0.35 < 0.005 0.01 —0.01 0.01 —0.01 —45.9 45.9 < 0.005 < 0.005 —46.1
Demolitio
n
——————0.02 0.02 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
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7.62—< 0.005< 0.0057.607.60—< 0.005—< 0.005< 0.005—< 0.005< 0.0050.060.050.010.01Off-Road
Equipment
Demolitio
n
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.01 0.01 0.01 0.14 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —33.2 33.2 < 0.005 < 0.005 0.13 33.7
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.03 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —20.9 20.9 < 0.005 < 0.005 0.04 22.0
Daily,
Winter
(Max)
——————————————————
Worker 0.01 0.01 0.01 0.12 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —31.6 31.6 < 0.005 < 0.005 < 0.005 31.9
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.03 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —20.9 20.9 < 0.005 < 0.005 < 0.005 22.0
Average
Daily
——————————————————
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 —6.01 6.01 < 0.005 < 0.005 0.01 6.09
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —3.93 3.93 < 0.005 < 0.005 < 0.005 4.13
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —1.00 1.00 < 0.005 < 0.005 < 0.005 1.01
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —0.65 0.65 < 0.005 < 0.005 < 0.005 0.68
3.4. Demolition (2025) - Mitigated
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Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
0.23 0.19 1.54 1.85 < 0.005 0.04 —0.04 0.04 —0.04 —244 244 0.01 < 0.005 —245
Demolitio
n
——————0.09 0.09 —0.01 0.01 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
0.23 0.19 1.54 1.85 < 0.005 0.04 —0.04 0.04 —0.04 —244 244 0.01 < 0.005 —245
Demolitio
n
——————0.09 0.09 —0.01 0.01 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.04 0.04 0.29 0.35 < 0.005 0.01 —0.01 0.01 —0.01 —45.9 45.9 < 0.005 < 0.005 —46.1
Demolitio
n
——————0.02 0.02 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.01 0.01 0.05 0.06 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —7.60 7.60 < 0.005 < 0.005 —7.62
Demolitio
n
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
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Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.01 0.01 0.01 0.14 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —33.2 33.2 < 0.005 < 0.005 0.13 33.7
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.03 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —20.9 20.9 < 0.005 < 0.005 0.04 22.0
Daily,
Winter
(Max)
——————————————————
Worker 0.01 0.01 0.01 0.12 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —31.6 31.6 < 0.005 < 0.005 < 0.005 31.9
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.03 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —20.9 20.9 < 0.005 < 0.005 < 0.005 22.0
Average
Daily
——————————————————
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 —6.01 6.01 < 0.005 < 0.005 0.01 6.09
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —3.93 3.93 < 0.005 < 0.005 < 0.005 4.13
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —1.00 1.00 < 0.005 < 0.005 < 0.005 1.01
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —0.65 0.65 < 0.005 < 0.005 < 0.005 0.68
3.5. Demolition (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
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Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
0.21 0.18 1.50 1.83 < 0.005 0.04 —0.04 0.03 —0.03 —244 244 0.01 < 0.005 —245
Demolitio
n
——————0.09 0.09 —0.01 0.01 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
0.21 0.18 1.50 1.83 < 0.005 0.04 —0.04 0.03 —0.03 —244 244 0.01 < 0.005 —245
Demolitio
n
——————0.09 0.09 —0.01 0.01 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.15 0.13 1.07 1.31 < 0.005 0.03 —0.03 0.02 —0.02 —174 174 0.01 < 0.005 —175
Demolitio
n
——————0.06 0.06 —0.01 0.01 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.03 0.02 0.20 0.24 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —28.9 28.9 < 0.005 < 0.005 —29.0
Demolitio
n
——————0.01 0.01 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
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Daily,
Summer
(Max)
——————————————————
Worker 0.01 0.01 0.01 0.13 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —32.6 32.6 < 0.005 < 0.005 0.11 33.0
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —20.6 20.6 < 0.005 < 0.005 0.04 21.6
Daily,
Winter
(Max)
——————————————————
Worker 0.01 0.01 0.01 0.11 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —31.0 31.0 < 0.005 < 0.005 < 0.005 31.3
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.03 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —20.6 20.6 < 0.005 < 0.005 < 0.005 21.6
Average
Daily
——————————————————
Worker 0.01 0.01 0.01 0.08 0.00 0.00 0.02 0.02 0.00 0.01 0.01 —22.4 22.4 < 0.005 < 0.005 0.03 22.7
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —14.7 14.7 < 0.005 < 0.005 0.01 15.4
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —3.71 3.71 < 0.005 < 0.005 0.01 3.76
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —2.43 2.43 < 0.005 < 0.005 < 0.005 2.55
3.6. Demolition (2026) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
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245—< 0.0050.01244244—0.03—0.030.04—0.04< 0.0051.831.500.180.21Off-Road
Equipment
Demolitio
n
——————0.09 0.09 —0.01 0.01 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
0.21 0.18 1.50 1.83 < 0.005 0.04 —0.04 0.03 —0.03 —244 244 0.01 < 0.005 —245
Demolitio
n
——————0.09 0.09 —0.01 0.01 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.15 0.13 1.07 1.31 < 0.005 0.03 —0.03 0.02 —0.02 —174 174 0.01 < 0.005 —175
Demolitio
n
——————0.06 0.06 —0.01 0.01 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.03 0.02 0.20 0.24 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —28.9 28.9 < 0.005 < 0.005 —29.0
Demolitio
n
——————0.01 0.01 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
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Worker 0.01 0.01 0.01 0.13 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —32.6 32.6 < 0.005 < 0.005 0.11 33.0
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —20.6 20.6 < 0.005 < 0.005 0.04 21.6
Daily,
Winter
(Max)
——————————————————
Worker 0.01 0.01 0.01 0.11 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —31.0 31.0 < 0.005 < 0.005 < 0.005 31.3
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.03 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —20.6 20.6 < 0.005 < 0.005 < 0.005 21.6
Average
Daily
——————————————————
Worker 0.01 0.01 0.01 0.08 0.00 0.00 0.02 0.02 0.00 0.01 0.01 —22.4 22.4 < 0.005 < 0.005 0.03 22.7
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —14.7 14.7 < 0.005 < 0.005 0.01 15.4
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —3.71 3.71 < 0.005 < 0.005 0.01 3.76
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —2.43 2.43 < 0.005 < 0.005 < 0.005 2.55
3.7. Demolition (2027) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
0.20 0.17 1.46 1.82 < 0.005 0.03 —0.03 0.03 —0.03 —244 244 0.01 < 0.005 —245
Demolitio
n
——————0.09 0.09 —0.01 0.01 ———————
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Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
0.20 0.17 1.46 1.82 < 0.005 0.03 —0.03 0.03 —0.03 —244 244 0.01 < 0.005 —245
Demolitio
n
——————0.09 0.09 —0.01 0.01 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.14 0.12 1.04 1.30 < 0.005 0.02 —0.02 0.02 —0.02 —174 174 0.01 < 0.005 —175
Demolitio
n
——————0.06 0.06 —0.01 0.01 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.03 0.02 0.19 0.24 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —28.9 28.9 < 0.005 < 0.005 —29.0
Demolitio
n
——————0.01 0.01 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.01 0.01 0.01 0.12 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —32.0 32.0 < 0.005 < 0.005 0.10 32.5
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —20.2 20.2 < 0.005 < 0.005 0.04 21.2
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Daily,
Winter
(Max)
——————————————————
Worker 0.01 0.01 0.01 0.11 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —30.5 30.5 < 0.005 < 0.005 < 0.005 30.8
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —20.2 20.2 < 0.005 < 0.005 < 0.005 21.2
Average
Daily
——————————————————
Worker 0.01 0.01 0.01 0.08 0.00 0.00 0.02 0.02 0.00 0.01 0.01 —22.1 22.1 < 0.005 < 0.005 0.03 22.3
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —14.4 14.4 < 0.005 < 0.005 0.01 15.1
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —3.65 3.65 < 0.005 < 0.005 0.01 3.70
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —2.38 2.38 < 0.005 < 0.005 < 0.005 2.51
3.8. Demolition (2027) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
0.20 0.17 1.46 1.82 < 0.005 0.03 —0.03 0.03 —0.03 —244 244 0.01 < 0.005 —245
Demolitio
n
——————0.09 0.09 —0.01 0.01 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
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——————————————————Daily,
Winter
(Max)
Off-Road
Equipment
0.20 0.17 1.46 1.82 < 0.005 0.03 —0.03 0.03 —0.03 —244 244 0.01 < 0.005 —245
Demolitio
n
——————0.09 0.09 —0.01 0.01 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.14 0.12 1.04 1.30 < 0.005 0.02 —0.02 0.02 —0.02 —174 174 0.01 < 0.005 —175
Demolitio
n
——————0.06 0.06 —0.01 0.01 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.03 0.02 0.19 0.24 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —28.9 28.9 < 0.005 < 0.005 —29.0
Demolitio
n
——————0.01 0.01 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.01 0.01 0.01 0.12 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —32.0 32.0 < 0.005 < 0.005 0.10 32.5
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —20.2 20.2 < 0.005 < 0.005 0.04 21.2
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——————————————————Daily,
Winter
(Max)
Worker 0.01 0.01 0.01 0.11 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —30.5 30.5 < 0.005 < 0.005 < 0.005 30.8
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —20.2 20.2 < 0.005 < 0.005 < 0.005 21.2
Average
Daily
——————————————————
Worker 0.01 0.01 0.01 0.08 0.00 0.00 0.02 0.02 0.00 0.01 0.01 —22.1 22.1 < 0.005 < 0.005 0.03 22.3
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —14.4 14.4 < 0.005 < 0.005 0.01 15.1
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —3.65 3.65 < 0.005 < 0.005 0.01 3.70
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —2.38 2.38 < 0.005 < 0.005 < 0.005 2.51
3.9. Demolition (2028) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
0.19 0.16 1.42 1.81 < 0.005 0.02 —0.02 0.02 —0.02 —244 244 0.01 < 0.005 —245
Demolitio
n
——————0.09 0.09 —0.01 0.01 ———————
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Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.01 0.01 0.08 0.10 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —13.4 13.4 < 0.005 < 0.005 —13.4
Demolitio
n
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
< 0.005 < 0.005 0.01 0.02 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —2.21 2.21 < 0.005 < 0.005 —2.22
Demolitio
n
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Worker 0.01 0.01 0.01 0.10 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —29.9 29.9 < 0.005 < 0.005 < 0.005 30.3
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —19.7 19.7 < 0.005 < 0.005 < 0.005 20.7
Average
Daily
——————————————————
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —1.66 1.66 < 0.005 < 0.005 < 0.005 1.68
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —1.08 1.08 < 0.005 < 0.005 < 0.005 1.13
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Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —0.28 0.28 < 0.005 < 0.005 < 0.005 0.28
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —0.18 0.18 < 0.005 < 0.005 < 0.005 0.19
3.10. Demolition (2028) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
0.19 0.16 1.42 1.81 < 0.005 0.02 —0.02 0.02 —0.02 —244 244 0.01 < 0.005 —245
Demolitio
n
——————0.09 0.09 —0.01 0.01 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.01 0.01 0.08 0.10 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —13.4 13.4 < 0.005 < 0.005 —13.4
Demolitio
n
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
< 0.005 < 0.005 0.01 0.02 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —2.21 2.21 < 0.005 < 0.005 —2.22
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Demolitio ——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Worker 0.01 0.01 0.01 0.10 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —29.9 29.9 < 0.005 < 0.005 < 0.005 30.3
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —19.7 19.7 < 0.005 < 0.005 < 0.005 20.7
Average
Daily
——————————————————
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —1.66 1.66 < 0.005 < 0.005 < 0.005 1.68
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —1.08 1.08 < 0.005 < 0.005 < 0.005 1.13
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —0.28 0.28 < 0.005 < 0.005 < 0.005 0.28
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —0.18 0.18 < 0.005 < 0.005 < 0.005 0.19
3.11. Demolition (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
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Off-Road
Equipment
0.23 0.19 1.54 1.85 < 0.005 0.04 —0.04 0.04 —0.04 —244 244 0.01 < 0.005 —245
Demolitio
n
——————0.09 0.09 —0.01 0.01 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
0.23 0.19 1.54 1.85 < 0.005 0.04 —0.04 0.04 —0.04 —244 244 0.01 < 0.005 —245
Demolitio
n
——————0.09 0.09 —0.01 0.01 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.04 0.04 0.29 0.35 < 0.005 0.01 —0.01 0.01 —0.01 —45.9 45.9 < 0.005 < 0.005 —46.1
Demolitio
n
——————0.02 0.02 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.01 0.01 0.05 0.06 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —7.60 7.60 < 0.005 < 0.005 —7.62
Demolitio
n
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
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Worker 0.01 0.01 0.01 0.14 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —33.2 33.2 < 0.005 < 0.005 0.13 33.7
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.03 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —20.9 20.9 < 0.005 < 0.005 0.04 22.0
Daily,
Winter
(Max)
——————————————————
Worker 0.01 0.01 0.01 0.12 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —31.6 31.6 < 0.005 < 0.005 < 0.005 31.9
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.03 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —20.9 20.9 < 0.005 < 0.005 < 0.005 22.0
Average
Daily
——————————————————
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 —6.01 6.01 < 0.005 < 0.005 0.01 6.09
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —3.93 3.93 < 0.005 < 0.005 < 0.005 4.13
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —1.00 1.00 < 0.005 < 0.005 < 0.005 1.01
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —0.65 0.65 < 0.005 < 0.005 < 0.005 0.68
3.12. Demolition (2025) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
0.23 0.19 1.54 1.85 < 0.005 0.04 —0.04 0.04 —0.04 —244 244 0.01 < 0.005 —245
Demolitio
n
——————0.09 0.09 —0.01 0.01 ———————
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Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
0.23 0.19 1.54 1.85 < 0.005 0.04 —0.04 0.04 —0.04 —244 244 0.01 < 0.005 —245
Demolitio
n
——————0.09 0.09 —0.01 0.01 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.04 0.04 0.29 0.35 < 0.005 0.01 —0.01 0.01 —0.01 —45.9 45.9 < 0.005 < 0.005 —46.1
Demolitio
n
——————0.02 0.02 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.01 0.01 0.05 0.06 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —7.60 7.60 < 0.005 < 0.005 —7.62
Demolitio
n
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.01 0.01 0.01 0.14 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —33.2 33.2 < 0.005 < 0.005 0.13 33.7
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.03 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —20.9 20.9 < 0.005 < 0.005 0.04 22.0
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Daily,
Winter
(Max)
——————————————————
Worker 0.01 0.01 0.01 0.12 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —31.6 31.6 < 0.005 < 0.005 < 0.005 31.9
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.03 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —20.9 20.9 < 0.005 < 0.005 < 0.005 22.0
Average
Daily
——————————————————
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 —6.01 6.01 < 0.005 < 0.005 0.01 6.09
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —3.93 3.93 < 0.005 < 0.005 < 0.005 4.13
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —1.00 1.00 < 0.005 < 0.005 < 0.005 1.01
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —0.65 0.65 < 0.005 < 0.005 < 0.005 0.68
3.13. Demolition (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
0.21 0.18 1.50 1.83 < 0.005 0.04 —0.04 0.03 —0.03 —244 244 0.01 < 0.005 —245
Demolitio
n
——————0.09 0.09 —0.01 0.01 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
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——————————————————Daily,
Winter
(Max)
Off-Road
Equipment
0.21 0.18 1.50 1.83 < 0.005 0.04 —0.04 0.03 —0.03 —244 244 0.01 < 0.005 —245
Demolitio
n
——————0.09 0.09 —0.01 0.01 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.15 0.13 1.07 1.31 < 0.005 0.03 —0.03 0.02 —0.02 —174 174 0.01 < 0.005 —175
Demolitio
n
——————0.06 0.06 —0.01 0.01 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.03 0.02 0.20 0.24 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —28.9 28.9 < 0.005 < 0.005 —29.0
Demolitio
n
——————0.01 0.01 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.01 0.01 0.01 0.13 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —32.6 32.6 < 0.005 < 0.005 0.11 33.0
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —20.6 20.6 < 0.005 < 0.005 0.04 21.6
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——————————————————Daily,
Winter
(Max)
Worker 0.01 0.01 0.01 0.11 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —31.0 31.0 < 0.005 < 0.005 < 0.005 31.3
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.03 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —20.6 20.6 < 0.005 < 0.005 < 0.005 21.6
Average
Daily
——————————————————
Worker 0.01 0.01 0.01 0.08 0.00 0.00 0.02 0.02 0.00 0.01 0.01 —22.4 22.4 < 0.005 < 0.005 0.03 22.7
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —14.7 14.7 < 0.005 < 0.005 0.01 15.4
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —3.71 3.71 < 0.005 < 0.005 0.01 3.76
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —2.43 2.43 < 0.005 < 0.005 < 0.005 2.55
3.14. Demolition (2026) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
0.21 0.18 1.50 1.83 < 0.005 0.04 —0.04 0.03 —0.03 —244 244 0.01 < 0.005 —245
Demolitio
n
——————0.09 0.09 —0.01 0.01 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
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——————————————————Daily,
Winter
(Max)
Off-Road
Equipment
0.21 0.18 1.50 1.83 < 0.005 0.04 —0.04 0.03 —0.03 —244 244 0.01 < 0.005 —245
Demolitio
n
——————0.09 0.09 —0.01 0.01 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.15 0.13 1.07 1.31 < 0.005 0.03 —0.03 0.02 —0.02 —174 174 0.01 < 0.005 —175
Demolitio
n
——————0.06 0.06 —0.01 0.01 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.03 0.02 0.20 0.24 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —28.9 28.9 < 0.005 < 0.005 —29.0
Demolitio
n
——————0.01 0.01 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.01 0.01 0.01 0.13 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —32.6 32.6 < 0.005 < 0.005 0.11 33.0
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —20.6 20.6 < 0.005 < 0.005 0.04 21.6
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——————————————————Daily,
Winter
(Max)
Worker 0.01 0.01 0.01 0.11 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —31.0 31.0 < 0.005 < 0.005 < 0.005 31.3
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.03 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —20.6 20.6 < 0.005 < 0.005 < 0.005 21.6
Average
Daily
——————————————————
Worker 0.01 0.01 0.01 0.08 0.00 0.00 0.02 0.02 0.00 0.01 0.01 —22.4 22.4 < 0.005 < 0.005 0.03 22.7
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —14.7 14.7 < 0.005 < 0.005 0.01 15.4
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —3.71 3.71 < 0.005 < 0.005 0.01 3.76
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —2.43 2.43 < 0.005 < 0.005 < 0.005 2.55
3.15. Demolition (2027) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
0.20 0.17 1.46 1.82 < 0.005 0.03 —0.03 0.03 —0.03 —244 244 0.01 < 0.005 —245
Demolitio
n
——————0.09 0.09 —0.01 0.01 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
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——————————————————Daily,
Winter
(Max)
Off-Road
Equipment
0.20 0.17 1.46 1.82 < 0.005 0.03 —0.03 0.03 —0.03 —244 244 0.01 < 0.005 —245
Demolitio
n
——————0.09 0.09 —0.01 0.01 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.14 0.12 1.04 1.30 < 0.005 0.02 —0.02 0.02 —0.02 —174 174 0.01 < 0.005 —175
Demolitio
n
——————0.06 0.06 —0.01 0.01 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.03 0.02 0.19 0.24 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —28.9 28.9 < 0.005 < 0.005 —29.0
Demolitio
n
——————0.01 0.01 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.01 0.01 0.01 0.12 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —32.0 32.0 < 0.005 < 0.005 0.10 32.5
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —20.2 20.2 < 0.005 < 0.005 0.04 21.2
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——————————————————Daily,
Winter
(Max)
Worker 0.01 0.01 0.01 0.11 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —30.5 30.5 < 0.005 < 0.005 < 0.005 30.8
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —20.2 20.2 < 0.005 < 0.005 < 0.005 21.2
Average
Daily
——————————————————
Worker 0.01 0.01 0.01 0.08 0.00 0.00 0.02 0.02 0.00 0.01 0.01 —22.1 22.1 < 0.005 < 0.005 0.03 22.3
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —14.4 14.4 < 0.005 < 0.005 0.01 15.1
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —3.65 3.65 < 0.005 < 0.005 0.01 3.70
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —2.38 2.38 < 0.005 < 0.005 < 0.005 2.51
3.16. Demolition (2027) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
0.20 0.17 1.46 1.82 < 0.005 0.03 —0.03 0.03 —0.03 —244 244 0.01 < 0.005 —245
Demolitio
n
——————0.09 0.09 —0.01 0.01 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
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——————————————————Daily,
Winter
(Max)
Off-Road
Equipment
0.20 0.17 1.46 1.82 < 0.005 0.03 —0.03 0.03 —0.03 —244 244 0.01 < 0.005 —245
Demolitio
n
——————0.09 0.09 —0.01 0.01 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.14 0.12 1.04 1.30 < 0.005 0.02 —0.02 0.02 —0.02 —174 174 0.01 < 0.005 —175
Demolitio
n
——————0.06 0.06 —0.01 0.01 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.03 0.02 0.19 0.24 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —28.9 28.9 < 0.005 < 0.005 —29.0
Demolitio
n
——————0.01 0.01 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.01 0.01 0.01 0.12 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —32.0 32.0 < 0.005 < 0.005 0.10 32.5
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —20.2 20.2 < 0.005 < 0.005 0.04 21.2
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——————————————————Daily,
Winter
(Max)
Worker 0.01 0.01 0.01 0.11 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —30.5 30.5 < 0.005 < 0.005 < 0.005 30.8
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —20.2 20.2 < 0.005 < 0.005 < 0.005 21.2
Average
Daily
——————————————————
Worker 0.01 0.01 0.01 0.08 0.00 0.00 0.02 0.02 0.00 0.01 0.01 —22.1 22.1 < 0.005 < 0.005 0.03 22.3
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —14.4 14.4 < 0.005 < 0.005 0.01 15.1
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —3.65 3.65 < 0.005 < 0.005 0.01 3.70
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —2.38 2.38 < 0.005 < 0.005 < 0.005 2.51
3.17. Demolition (2028) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
0.19 0.16 1.42 1.81 < 0.005 0.02 —0.02 0.02 —0.02 —244 244 0.01 < 0.005 —245
Demolitio
n
——————0.09 0.09 —0.01 0.01 ———————
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Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.01 0.01 0.08 0.10 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —13.4 13.4 < 0.005 < 0.005 —13.4
Demolitio
n
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
< 0.005 < 0.005 0.01 0.02 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —2.21 2.21 < 0.005 < 0.005 —2.22
Demolitio
n
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Worker 0.01 0.01 0.01 0.10 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —29.9 29.9 < 0.005 < 0.005 < 0.005 30.3
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —19.7 19.7 < 0.005 < 0.005 < 0.005 20.7
Average
Daily
——————————————————
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —1.66 1.66 < 0.005 < 0.005 < 0.005 1.68
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —1.08 1.08 < 0.005 < 0.005 < 0.005 1.13
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Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —0.28 0.28 < 0.005 < 0.005 < 0.005 0.28
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —0.18 0.18 < 0.005 < 0.005 < 0.005 0.19
3.18. Demolition (2028) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
0.19 0.16 1.42 1.81 < 0.005 0.02 —0.02 0.02 —0.02 —244 244 0.01 < 0.005 —245
Demolitio
n
——————0.09 0.09 —0.01 0.01 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.01 0.01 0.08 0.10 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —13.4 13.4 < 0.005 < 0.005 —13.4
Demolitio
n
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
< 0.005 < 0.005 0.01 0.02 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —2.21 2.21 < 0.005 < 0.005 —2.22
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Demolitio ——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Worker 0.01 0.01 0.01 0.10 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —29.9 29.9 < 0.005 < 0.005 < 0.005 30.3
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —19.7 19.7 < 0.005 < 0.005 < 0.005 20.7
Average
Daily
——————————————————
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —1.66 1.66 < 0.005 < 0.005 < 0.005 1.68
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —1.08 1.08 < 0.005 < 0.005 < 0.005 1.13
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —0.28 0.28 < 0.005 < 0.005 < 0.005 0.28
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —0.18 0.18 < 0.005 < 0.005 < 0.005 0.19
3.19. Grading (2024) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
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Off-Road
Equipment
1.46 1.22 10.9 9.21 0.03 0.43 —0.43 0.40 —0.40 —2,834 2,834 0.11 0.02 —2,843
Dust
From
Material
Movement
——————0.00 0.00 —0.00 0.00 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
1.46 1.22 10.9 9.21 0.03 0.43 —0.43 0.40 —0.40 —2,834 2,834 0.11 0.02 —2,843
Dust
From
Material
Movement
——————0.00 0.00 —0.00 0.00 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.52 0.44 3.92 3.32 0.01 0.16 —0.16 0.14 —0.14 —1,020 1,020 0.04 0.01 —1,024
Dust
From
Material
Movement
——————0.00 0.00 —0.00 0.00 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.10 0.08 0.71 0.61 < 0.005 0.03 —0.03 0.03 —0.03 —169 169 0.01 < 0.005 —170
Dust
From
Material
Movement
——————0.00 0.00 —0.00 0.00 ———————
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Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.07 0.06 0.07 1.05 0.00 0.00 0.23 0.23 0.00 0.05 0.05 —237 237 < 0.005 0.01 0.97 241
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Worker 0.07 0.06 0.08 0.91 0.00 0.00 0.23 0.23 0.00 0.05 0.05 —226 226 < 0.005 0.01 0.03 228
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Worker 0.03 0.02 0.03 0.34 0.00 0.00 0.08 0.08 0.00 0.02 0.02 —82.4 82.4 < 0.005 < 0.005 0.15 83.5
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker < 0.005 < 0.005 0.01 0.06 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 —13.6 13.6 < 0.005 < 0.005 0.03 13.8
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.20. Grading (2024) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
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Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
1.46 1.22 10.9 9.21 0.03 0.43 —0.43 0.40 —0.40 —2,834 2,834 0.11 0.02 —2,843
Dust
From
Material
Movement
——————0.00 0.00 —0.00 0.00 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
1.46 1.22 10.9 9.21 0.03 0.43 —0.43 0.40 —0.40 —2,834 2,834 0.11 0.02 —2,843
Dust
From
Material
Movement
——————0.00 0.00 —0.00 0.00 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.52 0.44 3.92 3.32 0.01 0.16 —0.16 0.14 —0.14 —1,020 1,020 0.04 0.01 —1,024
Dust
From
Material
Movement
——————0.00 0.00 —0.00 0.00 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.10 0.08 0.71 0.61 < 0.005 0.03 —0.03 0.03 —0.03 —169 169 0.01 < 0.005 —170
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Dust
From
Material
Movement
——————0.00 0.00 —0.00 0.00 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.07 0.06 0.07 1.05 0.00 0.00 0.23 0.23 0.00 0.05 0.05 —237 237 < 0.005 0.01 0.97 241
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Worker 0.07 0.06 0.08 0.91 0.00 0.00 0.23 0.23 0.00 0.05 0.05 —226 226 < 0.005 0.01 0.03 228
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Worker 0.03 0.02 0.03 0.34 0.00 0.00 0.08 0.08 0.00 0.02 0.02 —82.4 82.4 < 0.005 < 0.005 0.15 83.5
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker < 0.005 < 0.005 0.01 0.06 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 —13.6 13.6 < 0.005 < 0.005 0.03 13.8
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.21. Grading (2025) - Unmitigated
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Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
1.39 1.17 10.1 9.05 0.03 0.40 —0.40 0.37 —0.37 —2,834 2,834 0.11 0.02 —2,844
Dust
From
Material
Movement
——————0.00 0.00 —0.00 0.00 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
1.39 1.17 10.1 9.05 0.03 0.40 —0.40 0.37 —0.37 —2,834 2,834 0.11 0.02 —2,844
Dust
From
Material
Movement
——————0.00 0.00 —0.00 0.00 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.49 0.41 3.58 3.21 0.01 0.14 —0.14 0.13 —0.13 —1,004 1,004 0.04 0.01 —1,007
Dust
From
Material
Movement
——————0.00 0.00 —0.00 0.00 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
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Annual ——————————————————
Off-Road
Equipment
0.09 0.08 0.65 0.59 < 0.005 0.03 —0.03 0.02 —0.02 —166 166 0.01 < 0.005 —167
Dust
From
Material
Movement
——————0.00 0.00 —0.00 0.00 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.07 0.06 0.06 0.98 0.00 0.00 0.23 0.23 0.00 0.05 0.05 —232 232 < 0.005 0.01 0.88 236
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Worker 0.07 0.06 0.07 0.85 0.00 0.00 0.23 0.23 0.00 0.05 0.05 —221 221 < 0.005 0.01 0.02 224
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Worker 0.02 0.02 0.02 0.31 0.00 0.00 0.08 0.08 0.00 0.02 0.02 —79.4 79.4 < 0.005 < 0.005 0.13 80.4
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 0.06 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 —13.1 13.1 < 0.005 < 0.005 0.02 13.3
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
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3.22. Grading (2025) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
1.39 1.17 10.1 9.05 0.03 0.40 —0.40 0.37 —0.37 —2,834 2,834 0.11 0.02 —2,844
Dust
From
Material
Movement
——————0.00 0.00 —0.00 0.00 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
1.39 1.17 10.1 9.05 0.03 0.40 —0.40 0.37 —0.37 —2,834 2,834 0.11 0.02 —2,844
Dust
From
Material
Movement
——————0.00 0.00 —0.00 0.00 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.49 0.41 3.58 3.21 0.01 0.14 —0.14 0.13 —0.13 —1,004 1,004 0.04 0.01 —1,007
Dust
From
Material
Movement
——————0.00 0.00 —0.00 0.00 ———————
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Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.09 0.08 0.65 0.59 < 0.005 0.03 —0.03 0.02 —0.02 —166 166 0.01 < 0.005 —167
Dust
From
Material
Movement
——————0.00 0.00 —0.00 0.00 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.07 0.06 0.06 0.98 0.00 0.00 0.23 0.23 0.00 0.05 0.05 —232 232 < 0.005 0.01 0.88 236
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Worker 0.07 0.06 0.07 0.85 0.00 0.00 0.23 0.23 0.00 0.05 0.05 —221 221 < 0.005 0.01 0.02 224
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Worker 0.02 0.02 0.02 0.31 0.00 0.00 0.08 0.08 0.00 0.02 0.02 —79.4 79.4 < 0.005 < 0.005 0.13 80.4
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 0.06 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 —13.1 13.1 < 0.005 < 0.005 0.02 13.3
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
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Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.23. Grading (2024) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
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Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.02 < 0.005 0.21 0.09 < 0.005 < 0.005 0.04 0.04 < 0.005 0.01 0.01 —166 166 0.01 0.03 0.35 175
Daily,
Winter
(Max)
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.02 < 0.005 0.21 0.09 < 0.005 < 0.005 0.04 0.04 < 0.005 0.01 0.01 —166 166 0.01 0.03 0.01 174
Average
Daily
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.01 < 0.005 0.08 0.03 < 0.005 < 0.005 0.02 0.02 < 0.005 < 0.005 < 0.005 —59.8 59.8 < 0.005 0.01 0.05 62.8
Annual ——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —9.90 9.90 < 0.005 < 0.005 0.01 10.4
3.24. Grading (2024) - Mitigated
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Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
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0.000.000.000.000.000.00—0.000.000.000.000.000.000.000.000.000.000.00Onsite
truck
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.02 < 0.005 0.21 0.09 < 0.005 < 0.005 0.04 0.04 < 0.005 0.01 0.01 —166 166 0.01 0.03 0.35 175
Daily,
Winter
(Max)
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.02 < 0.005 0.21 0.09 < 0.005 < 0.005 0.04 0.04 < 0.005 0.01 0.01 —166 166 0.01 0.03 0.01 174
Average
Daily
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.01 < 0.005 0.08 0.03 < 0.005 < 0.005 0.02 0.02 < 0.005 < 0.005 < 0.005 —59.8 59.8 < 0.005 0.01 0.05 62.8
Annual ——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —9.90 9.90 < 0.005 < 0.005 0.01 10.4
3.25. Grading (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
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Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
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Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.02 < 0.005 0.21 0.09 < 0.005 < 0.005 0.04 0.04 < 0.005 0.01 0.01 —163 163 0.01 0.03 0.01 171
Average
Daily
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 —18.8 18.8 < 0.005 < 0.005 0.02 19.8
Annual ——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —3.12 3.12 < 0.005 < 0.005 < 0.005 3.28
3.26. Grading (2025) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
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———————< 0.005< 0.005—< 0.005< 0.005——————Dust
From
Material
Movement
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.02 < 0.005 0.21 0.09 < 0.005 < 0.005 0.04 0.04 < 0.005 0.01 0.01 —163 163 0.01 0.03 0.01 171
Average
Daily
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 —18.8 18.8 < 0.005 < 0.005 0.02 19.8
Annual ——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —3.12 3.12 < 0.005 < 0.005 < 0.005 3.28
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3.27. Grading (2024) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
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———————< 0.005< 0.005—< 0.005< 0.005——————Dust
From
Material
Movement
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.01 < 0.005 0.10 0.04 < 0.005 < 0.005 0.02 0.02 < 0.005 0.01 0.01 —80.7 80.7 0.01 0.01 0.17 84.8
Daily,
Winter
(Max)
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.01 < 0.005 0.10 0.04 < 0.005 < 0.005 0.02 0.02 < 0.005 0.01 0.01 —80.7 80.7 0.01 0.01 < 0.005 84.7
Average
Daily
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.04 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —27.9 27.9 < 0.005 < 0.005 0.03 29.4
Annual ——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —4.63 4.63 < 0.005 < 0.005 < 0.005 4.86
3.28. Grading (2024) - Mitigated
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Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
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0.000.000.000.000.000.00—0.000.000.000.000.000.000.000.000.000.000.00Onsite
truck
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.01 < 0.005 0.10 0.04 < 0.005 < 0.005 0.02 0.02 < 0.005 0.01 0.01 —80.7 80.7 0.01 0.01 0.17 84.8
Daily,
Winter
(Max)
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.01 < 0.005 0.10 0.04 < 0.005 < 0.005 0.02 0.02 < 0.005 0.01 0.01 —80.7 80.7 0.01 0.01 < 0.005 84.7
Average
Daily
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.04 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —27.9 27.9 < 0.005 < 0.005 0.03 29.4
Annual ——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —4.63 4.63 < 0.005 < 0.005 < 0.005 4.86
3.29. Grading (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
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Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
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Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.01 < 0.005 0.10 0.04 < 0.005 < 0.005 0.02 0.02 < 0.005 0.01 0.01 —79.3 79.3 0.01 0.01 < 0.005 83.3
Average
Daily
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —10.2 10.2 < 0.005 < 0.005 0.01 10.8
Annual ——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —1.70 1.70 < 0.005 < 0.005 < 0.005 1.78
3.30. Grading (2025) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
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———————< 0.005< 0.005—< 0.005< 0.005——————Dust
From
Material
Movement
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.01 < 0.005 0.10 0.04 < 0.005 < 0.005 0.02 0.02 < 0.005 0.01 0.01 —79.3 79.3 0.01 0.01 < 0.005 83.3
Average
Daily
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —10.2 10.2 < 0.005 < 0.005 0.01 10.8
Annual ——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —1.70 1.70 < 0.005 < 0.005 < 0.005 1.78
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3.31. Grading (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Dust
From
Material
Movement
——————0.01 0.01 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Dust
From
Material
Movement
——————0.01 0.01 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
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———————< 0.005< 0.005—< 0.005< 0.005——————Dust
From
Material
Movement
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.08 0.02 0.95 0.42 0.01 0.01 0.20 0.21 0.01 0.06 0.07 —778 778 0.06 0.13 1.64 819
Daily,
Winter
(Max)
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.07 0.02 0.98 0.42 0.01 0.01 0.20 0.21 0.01 0.06 0.07 —778 778 0.06 0.13 0.04 818
Average
Daily
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.05 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —40.5 40.5 < 0.005 0.01 0.04 42.6
Annual ——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —6.71 6.71 < 0.005 < 0.005 0.01 7.05
3.32. Grading (2025) - Mitigated
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Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
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0.000.000.000.000.000.00—0.000.000.000.000.000.000.000.000.000.000.00Onsite
truck
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.08 0.02 0.95 0.42 0.01 0.01 0.20 0.21 0.01 0.06 0.07 —778 778 0.06 0.13 1.64 819
Daily,
Winter
(Max)
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.07 0.02 0.98 0.42 0.01 0.01 0.20 0.21 0.01 0.06 0.07 —778 778 0.06 0.13 0.04 818
Average
Daily
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.05 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —40.5 40.5 < 0.005 0.01 0.04 42.6
Annual ——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —6.71 6.71 < 0.005 < 0.005 0.01 7.05
3.33. Grading (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
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Daily,
Summer
(Max)
——————————————————
Dust
From
Material
Movement
——————0.01 0.01 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Average
Daily
——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.07 0.02 0.88 0.39 < 0.005 0.01 0.19 0.20 0.01 0.05 0.06 —722 722 0.06 0.12 1.52 760
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——————————————————Daily,
Winter
(Max)
Average
Daily
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.02 < 0.005 0.20 0.09 < 0.005 < 0.005 0.04 0.04 < 0.005 0.01 0.01 —158 158 0.01 0.03 0.14 166
Annual ——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.04 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —26.2 26.2 < 0.005 < 0.005 0.02 27.5
3.34. Grading (2025) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Average
Daily
——————————————————
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———————< 0.005< 0.005—< 0.005< 0.005——————Dust
From
Material
Movement
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.07 0.02 0.88 0.39 < 0.005 0.01 0.19 0.20 0.01 0.05 0.06 —722 722 0.06 0.12 1.52 760
Daily,
Winter
(Max)
——————————————————
Average
Daily
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.02 < 0.005 0.20 0.09 < 0.005 < 0.005 0.04 0.04 < 0.005 0.01 0.01 —158 158 0.01 0.03 0.14 166
Annual ——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.04 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —26.2 26.2 < 0.005 < 0.005 0.02 27.5
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3.35. Grading (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Dust
From
Material
Movement
——————0.01 0.01 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Average
Daily
——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
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——————————————————Daily,
Summer
(Max)
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.07 0.01 0.83 0.37 < 0.005 0.01 0.18 0.19 0.01 0.05 0.06 —685 685 0.06 0.11 1.44 721
Daily,
Winter
(Max)
——————————————————
Average
Daily
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.01 < 0.005 0.19 0.08 < 0.005 < 0.005 0.04 0.04 < 0.005 0.01 0.01 —150 150 0.01 0.02 0.14 158
Annual ——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.03 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —24.9 24.9 < 0.005 < 0.005 0.02 26.1
3.36. Grading (2025) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Bay Bridge (with Dredging) Detailed Report, 6/8/2023
87 / 194
0.000.000.000.000.000.00—0.000.000.000.000.000.000.000.000.000.000.00Onsite
truck
Daily,
Winter
(Max)
——————————————————
Average
Daily
——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.07 0.01 0.83 0.37 < 0.005 0.01 0.18 0.19 0.01 0.05 0.06 —685 685 0.06 0.11 1.44 721
Daily,
Winter
(Max)
——————————————————
Average
Daily
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Bay Bridge (with Dredging) Detailed Report, 6/8/2023
88 / 194
Hauling 0.01 < 0.005 0.19 0.08 < 0.005 < 0.005 0.04 0.04 < 0.005 0.01 0.01 —150 150 0.01 0.02 0.14 158
Annual ——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.03 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —24.9 24.9 < 0.005 < 0.005 0.02 26.1
3.37. Grading (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Average
Daily
——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Bay Bridge (with Dredging) Detailed Report, 6/8/2023
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———————< 0.005< 0.005—< 0.005< 0.005——————Dust
From
Material
Movement
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.02 < 0.005 0.28 0.13 < 0.005 < 0.005 0.06 0.06 < 0.005 0.02 0.02 —233 233 0.02 0.04 0.49 245
Daily,
Winter
(Max)
——————————————————
Average
Daily
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —3.83 3.83 < 0.005 < 0.005 < 0.005 4.03
Annual ——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —0.63 0.63 < 0.005 < 0.005 < 0.005 0.67
3.38. Grading (2025) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Bay Bridge (with Dredging) Detailed Report, 6/8/2023
90 / 194
Daily,
Summer
(Max)
——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Average
Daily
——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Dust
From
Material
Movement
——————< 0.005 < 0.005 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.02 < 0.005 0.28 0.13 < 0.005 < 0.005 0.06 0.06 < 0.005 0.02 0.02 —233 233 0.02 0.04 0.49 245
Bay Bridge (with Dredging) Detailed Report, 6/8/2023
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——————————————————Daily,
Winter
(Max)
Average
Daily
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —3.83 3.83 < 0.005 < 0.005 < 0.005 4.03
Annual ——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —0.63 0.63 < 0.005 < 0.005 < 0.005 0.67
3.39. Demolition (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
0.23 0.19 1.54 1.85 < 0.005 0.04 —0.04 0.04 —0.04 —244 244 0.01 < 0.005 —245
Demolitio
n
——————0.26 0.26 —0.04 0.04 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
0.23 0.19 1.54 1.85 < 0.005 0.04 —0.04 0.04 —0.04 —244 244 0.01 < 0.005 —245
Bay Bridge (with Dredging) Detailed Report, 6/8/2023
92 / 194
Demolitio ——————0.26 0.26 —0.04 0.04 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.04 0.04 0.29 0.35 < 0.005 0.01 —0.01 0.01 —0.01 —45.9 45.9 < 0.005 < 0.005 —46.1
Demolitio
n
——————0.05 0.05 —0.01 0.01 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.01 0.01 0.05 0.06 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —7.60 7.60 < 0.005 < 0.005 —7.62
Demolitio
n
——————0.01 0.01 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.01 0.01 0.01 0.14 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —33.2 33.2 < 0.005 < 0.005 0.13 33.7
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.01 < 0.005 0.07 0.03 < 0.005 < 0.005 0.02 0.02 < 0.005 < 0.005 0.01 —61.4 61.4 < 0.005 0.01 0.13 64.6
Daily,
Winter
(Max)
——————————————————
Worker 0.01 0.01 0.01 0.12 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —31.6 31.6 < 0.005 < 0.005 < 0.005 31.9
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.01 < 0.005 0.08 0.03 < 0.005 < 0.005 0.02 0.02 < 0.005 < 0.005 0.01 —61.4 61.4 < 0.005 0.01 < 0.005 64.5
Bay Bridge (with Dredging) Detailed Report, 6/8/2023
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——————————————————Average
Daily
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 —6.01 6.01 < 0.005 < 0.005 0.01 6.09
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —11.5 11.5 < 0.005 < 0.005 0.01 12.1
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —1.00 1.00 < 0.005 < 0.005 < 0.005 1.01
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —1.91 1.91 < 0.005 < 0.005 < 0.005 2.01
3.40. Demolition (2025) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
0.23 0.19 1.54 1.85 < 0.005 0.04 —0.04 0.04 —0.04 —244 244 0.01 < 0.005 —245
Demolitio
n
——————0.26 0.26 —0.04 0.04 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
0.23 0.19 1.54 1.85 < 0.005 0.04 —0.04 0.04 —0.04 —244 244 0.01 < 0.005 —245
Demolitio
n
——————0.26 0.26 —0.04 0.04 ———————
Bay Bridge (with Dredging) Detailed Report, 6/8/2023
94 / 194
0.000.000.000.000.000.00—0.000.000.000.000.000.000.000.000.000.000.00Onsite
truck
Average
Daily
——————————————————
Off-Road
Equipment
0.04 0.04 0.29 0.35 < 0.005 0.01 —0.01 0.01 —0.01 —45.9 45.9 < 0.005 < 0.005 —46.1
Demolitio
n
——————0.05 0.05 —0.01 0.01 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.01 0.01 0.05 0.06 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —7.60 7.60 < 0.005 < 0.005 —7.62
Demolitio
n
——————0.01 0.01 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.01 0.01 0.01 0.14 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —33.2 33.2 < 0.005 < 0.005 0.13 33.7
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.01 < 0.005 0.07 0.03 < 0.005 < 0.005 0.02 0.02 < 0.005 < 0.005 0.01 —61.4 61.4 < 0.005 0.01 0.13 64.6
Daily,
Winter
(Max)
——————————————————
Worker 0.01 0.01 0.01 0.12 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —31.6 31.6 < 0.005 < 0.005 < 0.005 31.9
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.01 < 0.005 0.08 0.03 < 0.005 < 0.005 0.02 0.02 < 0.005 < 0.005 0.01 —61.4 61.4 < 0.005 0.01 < 0.005 64.5
Average
Daily
——————————————————
Bay Bridge (with Dredging) Detailed Report, 6/8/2023
95 / 194
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 —6.01 6.01 < 0.005 < 0.005 0.01 6.09
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —11.5 11.5 < 0.005 < 0.005 0.01 12.1
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —1.00 1.00 < 0.005 < 0.005 < 0.005 1.01
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —1.91 1.91 < 0.005 < 0.005 < 0.005 2.01
3.41. Demolition (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
0.21 0.18 1.50 1.83 < 0.005 0.04 —0.04 0.03 —0.03 —244 244 0.01 < 0.005 —245
Demolitio
n
——————0.26 0.26 —0.04 0.04 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
0.21 0.18 1.50 1.83 < 0.005 0.04 —0.04 0.03 —0.03 —244 244 0.01 < 0.005 —245
Demolitio
n
——————0.26 0.26 —0.04 0.04 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Bay Bridge (with Dredging) Detailed Report, 6/8/2023
96 / 194
——————————————————Average
Daily
Off-Road
Equipment
0.15 0.13 1.07 1.31 < 0.005 0.03 —0.03 0.02 —0.02 —174 174 0.01 < 0.005 —175
Demolitio
n
——————0.19 0.19 —0.03 0.03 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.03 0.02 0.20 0.24 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —28.9 28.9 < 0.005 < 0.005 —29.0
Demolitio
n
——————0.03 0.03 —0.01 0.01 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.01 0.01 0.01 0.13 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —32.6 32.6 < 0.005 < 0.005 0.11 33.0
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.01 < 0.005 0.07 0.03 < 0.005 < 0.005 0.02 0.02 < 0.005 < 0.005 0.01 —60.3 60.3 < 0.005 0.01 0.12 63.4
Daily,
Winter
(Max)
——————————————————
Worker 0.01 0.01 0.01 0.11 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —31.0 31.0 < 0.005 < 0.005 < 0.005 31.3
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.01 < 0.005 0.07 0.03 < 0.005 < 0.005 0.02 0.02 < 0.005 < 0.005 0.01 —60.3 60.3 < 0.005 0.01 < 0.005 63.3
Average
Daily
——————————————————
Worker 0.01 0.01 0.01 0.08 0.00 0.00 0.02 0.02 0.00 0.01 0.01 —22.4 22.4 < 0.005 < 0.005 0.03 22.7
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Bay Bridge (with Dredging) Detailed Report, 6/8/2023
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Hauling < 0.005 < 0.005 0.05 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —43.1 43.1 < 0.005 0.01 0.04 45.2
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —3.71 3.71 < 0.005 < 0.005 0.01 3.76
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —7.13 7.13 < 0.005 < 0.005 0.01 7.49
3.42. Demolition (2026) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
0.21 0.18 1.50 1.83 < 0.005 0.04 —0.04 0.03 —0.03 —244 244 0.01 < 0.005 —245
Demolitio
n
——————0.26 0.26 —0.04 0.04 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
0.21 0.18 1.50 1.83 < 0.005 0.04 —0.04 0.03 —0.03 —244 244 0.01 < 0.005 —245
Demolitio
n
——————0.26 0.26 —0.04 0.04 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.15 0.13 1.07 1.31 < 0.005 0.03 —0.03 0.02 —0.02 —174 174 0.01 < 0.005 —175
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Demolitio ——————0.19 0.19 —0.03 0.03 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.03 0.02 0.20 0.24 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —28.9 28.9 < 0.005 < 0.005 —29.0
Demolitio
n
——————0.03 0.03 —0.01 0.01 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.01 0.01 0.01 0.13 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —32.6 32.6 < 0.005 < 0.005 0.11 33.0
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.01 < 0.005 0.07 0.03 < 0.005 < 0.005 0.02 0.02 < 0.005 < 0.005 0.01 —60.3 60.3 < 0.005 0.01 0.12 63.4
Daily,
Winter
(Max)
——————————————————
Worker 0.01 0.01 0.01 0.11 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —31.0 31.0 < 0.005 < 0.005 < 0.005 31.3
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.01 < 0.005 0.07 0.03 < 0.005 < 0.005 0.02 0.02 < 0.005 < 0.005 0.01 —60.3 60.3 < 0.005 0.01 < 0.005 63.3
Average
Daily
——————————————————
Worker 0.01 0.01 0.01 0.08 0.00 0.00 0.02 0.02 0.00 0.01 0.01 —22.4 22.4 < 0.005 < 0.005 0.03 22.7
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.05 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —43.1 43.1 < 0.005 0.01 0.04 45.2
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —3.71 3.71 < 0.005 < 0.005 0.01 3.76
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Bay Bridge (with Dredging) Detailed Report, 6/8/2023
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Hauling < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —7.13 7.13 < 0.005 < 0.005 0.01 7.49
3.43. Demolition (2027) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
0.20 0.17 1.46 1.82 < 0.005 0.03 —0.03 0.03 —0.03 —244 244 0.01 < 0.005 —245
Demolitio
n
——————0.26 0.26 —0.04 0.04 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
0.20 0.17 1.46 1.82 < 0.005 0.03 —0.03 0.03 —0.03 —244 244 0.01 < 0.005 —245
Demolitio
n
——————0.26 0.26 —0.04 0.04 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.13 0.11 0.96 1.20 < 0.005 0.02 —0.02 0.02 —0.02 —161 161 0.01 < 0.005 —161
Demolitio
n
——————0.17 0.17 —0.03 0.03 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
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Annual ——————————————————
Off-Road
Equipment
0.02 0.02 0.18 0.22 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —26.6 26.6 < 0.005 < 0.005 —26.7
Demolitio
n
——————0.03 0.03 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.01 0.01 0.01 0.12 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —32.0 32.0 < 0.005 < 0.005 0.10 32.5
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.01 < 0.005 0.07 0.03 < 0.005 < 0.005 0.02 0.02 < 0.005 < 0.005 0.01 —59.1 59.1 < 0.005 0.01 0.11 62.2
Daily,
Winter
(Max)
——————————————————
Worker 0.01 0.01 0.01 0.11 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —30.5 30.5 < 0.005 < 0.005 < 0.005 30.8
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.01 < 0.005 0.07 0.03 < 0.005 < 0.005 0.02 0.02 < 0.005 < 0.005 0.01 —59.2 59.2 < 0.005 0.01 < 0.005 62.1
Average
Daily
——————————————————
Worker 0.01 < 0.005 0.01 0.07 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 —20.4 20.4 < 0.005 < 0.005 0.03 20.6
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.05 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —39.0 39.0 < 0.005 0.01 0.03 41.0
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —3.37 3.37 < 0.005 < 0.005 < 0.005 3.42
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —6.46 6.46 < 0.005 < 0.005 0.01 6.79
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3.44. Demolition (2027) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
0.20 0.17 1.46 1.82 < 0.005 0.03 —0.03 0.03 —0.03 —244 244 0.01 < 0.005 —245
Demolitio
n
——————0.26 0.26 —0.04 0.04 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
0.20 0.17 1.46 1.82 < 0.005 0.03 —0.03 0.03 —0.03 —244 244 0.01 < 0.005 —245
Demolitio
n
——————0.26 0.26 —0.04 0.04 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.13 0.11 0.96 1.20 < 0.005 0.02 —0.02 0.02 —0.02 —161 161 0.01 < 0.005 —161
Demolitio
n
——————0.17 0.17 —0.03 0.03 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Bay Bridge (with Dredging) Detailed Report, 6/8/2023
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26.7—< 0.005< 0.00526.626.6—< 0.005—< 0.005< 0.005—< 0.005< 0.0050.220.180.020.02Off-Road
Equipment
Demolitio
n
——————0.03 0.03 —< 0.005 < 0.005 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.01 0.01 0.01 0.12 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —32.0 32.0 < 0.005 < 0.005 0.10 32.5
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.01 < 0.005 0.07 0.03 < 0.005 < 0.005 0.02 0.02 < 0.005 < 0.005 0.01 —59.1 59.1 < 0.005 0.01 0.11 62.2
Daily,
Winter
(Max)
——————————————————
Worker 0.01 0.01 0.01 0.11 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —30.5 30.5 < 0.005 < 0.005 < 0.005 30.8
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.01 < 0.005 0.07 0.03 < 0.005 < 0.005 0.02 0.02 < 0.005 < 0.005 0.01 —59.2 59.2 < 0.005 0.01 < 0.005 62.1
Average
Daily
——————————————————
Worker 0.01 < 0.005 0.01 0.07 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 —20.4 20.4 < 0.005 < 0.005 0.03 20.6
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.05 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —39.0 39.0 < 0.005 0.01 0.03 41.0
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —3.37 3.37 < 0.005 < 0.005 < 0.005 3.42
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —6.46 6.46 < 0.005 < 0.005 0.01 6.79
3.45. Building Construction (2025) - Unmitigated
Bay Bridge (with Dredging) Detailed Report, 6/8/2023
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Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
0.56 0.47 4.50 5.70 0.01 0.18 —0.18 0.16 —0.16 —1,137 1,137 0.05 0.01 —1,141
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
0.56 0.47 4.50 5.70 0.01 0.18 —0.18 0.16 —0.16 —1,137 1,137 0.05 0.01 —1,141
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.20 0.17 1.62 2.05 < 0.005 0.06 —0.06 0.06 —0.06 —409 409 0.02 < 0.005 —411
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.04 0.03 0.30 0.37 < 0.005 0.01 —0.01 0.01 —0.01 —67.8 67.8 < 0.005 < 0.005 —68.0
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.02 0.02 0.02 0.34 0.00 0.00 0.08 0.08 0.00 0.02 0.02 —80.8 80.8 < 0.005 < 0.005 0.31 82.0
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Vendor 0.01 < 0.005 0.08 0.04 < 0.005 < 0.005 0.02 0.02 < 0.005 0.01 0.01 —75.8 75.8 < 0.005 0.01 0.21 79.2
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Worker 0.02 0.02 0.02 0.29 0.00 0.00 0.08 0.08 0.00 0.02 0.02 —76.9 76.9 < 0.005 < 0.005 0.01 77.8
Vendor 0.01 < 0.005 0.08 0.04 < 0.005 < 0.005 0.02 0.02 < 0.005 0.01 0.01 —75.8 75.8 < 0.005 0.01 0.01 79.1
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Worker 0.01 0.01 0.01 0.11 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —28.1 28.1 < 0.005 < 0.005 0.05 28.4
Vendor < 0.005 < 0.005 0.03 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —27.3 27.3 < 0.005 < 0.005 0.03 28.5
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 —4.65 4.65 < 0.005 < 0.005 0.01 4.71
Vendor < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —4.52 4.52 < 0.005 < 0.005 0.01 4.72
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.46. Building Construction (2025) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
0.56 0.47 4.50 5.70 0.01 0.18 —0.18 0.16 —0.16 —1,137 1,137 0.05 0.01 —1,141
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Bay Bridge (with Dredging) Detailed Report, 6/8/2023
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——————————————————Daily,
Winter
(Max)
Off-Road
Equipment
0.56 0.47 4.50 5.70 0.01 0.18 —0.18 0.16 —0.16 —1,137 1,137 0.05 0.01 —1,141
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.20 0.17 1.62 2.05 < 0.005 0.06 —0.06 0.06 —0.06 —409 409 0.02 < 0.005 —411
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.04 0.03 0.30 0.37 < 0.005 0.01 —0.01 0.01 —0.01 —67.8 67.8 < 0.005 < 0.005 —68.0
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.02 0.02 0.02 0.34 0.00 0.00 0.08 0.08 0.00 0.02 0.02 —80.8 80.8 < 0.005 < 0.005 0.31 82.0
Vendor 0.01 < 0.005 0.08 0.04 < 0.005 < 0.005 0.02 0.02 < 0.005 0.01 0.01 —75.8 75.8 < 0.005 0.01 0.21 79.2
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Worker 0.02 0.02 0.02 0.29 0.00 0.00 0.08 0.08 0.00 0.02 0.02 —76.9 76.9 < 0.005 < 0.005 0.01 77.8
Vendor 0.01 < 0.005 0.08 0.04 < 0.005 < 0.005 0.02 0.02 < 0.005 0.01 0.01 —75.8 75.8 < 0.005 0.01 0.01 79.1
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
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Worker 0.01 0.01 0.01 0.11 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —28.1 28.1 < 0.005 < 0.005 0.05 28.4
Vendor < 0.005 < 0.005 0.03 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 —27.3 27.3 < 0.005 < 0.005 0.03 28.5
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 —4.65 4.65 < 0.005 < 0.005 0.01 4.71
Vendor < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —4.52 4.52 < 0.005 < 0.005 0.01 4.72
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.47. Building Construction (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
0.53 0.45 4.25 5.68 0.01 0.16 —0.16 0.15 —0.15 —1,137 1,137 0.05 0.01 —1,141
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.03 0.03 0.26 0.34 < 0.005 0.01 —0.01 0.01 —0.01 —69.0 69.0 < 0.005 < 0.005 —69.2
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.01 < 0.005 0.05 0.06 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —11.4 11.4 < 0.005 < 0.005 —11.5
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Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Worker 0.02 0.02 0.02 0.28 0.00 0.00 0.08 0.08 0.00 0.02 0.02 —75.5 75.5 < 0.005 < 0.005 0.01 76.4
Vendor 0.01 < 0.005 0.08 0.04 < 0.005 < 0.005 0.02 0.02 < 0.005 0.01 0.01 —74.6 74.6 < 0.005 0.01 < 0.005 77.8
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —4.64 4.64 < 0.005 < 0.005 0.01 4.70
Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —4.52 4.52 < 0.005 < 0.005 0.01 4.72
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —0.77 0.77 < 0.005 < 0.005 < 0.005 0.78
Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —0.75 0.75 < 0.005 < 0.005 < 0.005 0.78
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.48. Building Construction (2026) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
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——————————————————Daily,
Winter
(Max)
Off-Road
Equipment
0.53 0.45 4.25 5.68 0.01 0.16 —0.16 0.15 —0.15 —1,137 1,137 0.05 0.01 —1,141
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.03 0.03 0.26 0.34 < 0.005 0.01 —0.01 0.01 —0.01 —69.0 69.0 < 0.005 < 0.005 —69.2
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.01 < 0.005 0.05 0.06 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —11.4 11.4 < 0.005 < 0.005 —11.5
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Worker 0.02 0.02 0.02 0.28 0.00 0.00 0.08 0.08 0.00 0.02 0.02 —75.5 75.5 < 0.005 < 0.005 0.01 76.4
Vendor 0.01 < 0.005 0.08 0.04 < 0.005 < 0.005 0.02 0.02 < 0.005 0.01 0.01 —74.6 74.6 < 0.005 0.01 < 0.005 77.8
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —4.64 4.64 < 0.005 < 0.005 0.01 4.70
Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —4.52 4.52 < 0.005 < 0.005 0.01 4.72
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
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Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —0.77 0.77 < 0.005 < 0.005 < 0.005 0.78
Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —0.75 0.75 < 0.005 < 0.005 < 0.005 0.78
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.49. Building Construction (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
0.53 0.45 4.25 5.68 0.01 0.16 —0.16 0.15 —0.15 —1,137 1,137 0.05 0.01 —1,141
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.06 0.05 0.51 0.68 < 0.005 0.02 —0.02 0.02 —0.02 —136 136 0.01 < 0.005 —136
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.01 0.01 0.09 0.12 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —22.5 22.5 < 0.005 < 0.005 —22.5
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
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Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Worker 0.02 0.02 0.02 0.28 0.00 0.00 0.08 0.08 0.00 0.02 0.02 —75.5 75.5 < 0.005 < 0.005 0.01 76.4
Vendor 0.01 < 0.005 0.08 0.04 < 0.005 < 0.005 0.02 0.02 < 0.005 0.01 0.01 —74.6 74.6 < 0.005 0.01 < 0.005 77.8
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Worker < 0.005 < 0.005 < 0.005 0.03 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 —9.13 9.13 < 0.005 < 0.005 0.01 9.25
Vendor < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —8.90 8.90 < 0.005 < 0.005 0.01 9.30
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —1.51 1.51 < 0.005 < 0.005 < 0.005 1.53
Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —1.47 1.47 < 0.005 < 0.005 < 0.005 1.54
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.50. Building Construction (2026) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
0.53 0.45 4.25 5.68 0.01 0.16 —0.16 0.15 —0.15 —1,137 1,137 0.05 0.01 —1,141
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Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.06 0.05 0.51 0.68 < 0.005 0.02 —0.02 0.02 —0.02 —136 136 0.01 < 0.005 —136
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.01 0.01 0.09 0.12 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —22.5 22.5 < 0.005 < 0.005 —22.5
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Worker 0.02 0.02 0.02 0.28 0.00 0.00 0.08 0.08 0.00 0.02 0.02 —75.5 75.5 < 0.005 < 0.005 0.01 76.4
Vendor 0.01 < 0.005 0.08 0.04 < 0.005 < 0.005 0.02 0.02 < 0.005 0.01 0.01 —74.6 74.6 < 0.005 0.01 < 0.005 77.8
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Worker < 0.005 < 0.005 < 0.005 0.03 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 —9.13 9.13 < 0.005 < 0.005 0.01 9.25
Vendor < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —8.90 8.90 < 0.005 < 0.005 0.01 9.30
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —1.51 1.51 < 0.005 < 0.005 < 0.005 1.53
Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —1.47 1.47 < 0.005 < 0.005 < 0.005 1.54
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
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3.51. Building Construction (2027) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
0.52 0.44 4.08 5.67 0.01 0.15 —0.15 0.13 —0.13 —1,137 1,137 0.05 0.01 —1,141
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.09 0.08 0.72 1.00 < 0.005 0.03 —0.03 0.02 —0.02 —200 200 0.01 < 0.005 —201
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.02 0.01 0.13 0.18 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —33.2 33.2 < 0.005 < 0.005 —33.3
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
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Worker 0.02 0.02 0.02 0.26 0.00 0.00 0.08 0.08 0.00 0.02 0.02 —74.2 74.2 < 0.005 < 0.005 0.01 75.1
Vendor 0.01 < 0.005 0.08 0.04 < 0.005 < 0.005 0.02 0.02 < 0.005 0.01 0.01 —73.2 73.2 < 0.005 0.01 < 0.005 76.3
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Worker < 0.005 < 0.005 < 0.005 0.05 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 —13.2 13.2 < 0.005 < 0.005 0.02 13.4
Vendor < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —12.9 12.9 < 0.005 < 0.005 0.01 13.4
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —2.19 2.19 < 0.005 < 0.005 < 0.005 2.22
Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —2.13 2.13 < 0.005 < 0.005 < 0.005 2.23
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.52. Building Construction (2027) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
0.52 0.44 4.08 5.67 0.01 0.15 —0.15 0.13 —0.13 —1,137 1,137 0.05 0.01 —1,141
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
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201—< 0.0050.01200200—0.02—0.020.03—0.03< 0.0051.000.720.080.09Off-Road
Equipment
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.02 0.01 0.13 0.18 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —33.2 33.2 < 0.005 < 0.005 —33.3
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Worker 0.02 0.02 0.02 0.26 0.00 0.00 0.08 0.08 0.00 0.02 0.02 —74.2 74.2 < 0.005 < 0.005 0.01 75.1
Vendor 0.01 < 0.005 0.08 0.04 < 0.005 < 0.005 0.02 0.02 < 0.005 0.01 0.01 —73.2 73.2 < 0.005 0.01 < 0.005 76.3
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Worker < 0.005 < 0.005 < 0.005 0.05 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 —13.2 13.2 < 0.005 < 0.005 0.02 13.4
Vendor < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —12.9 12.9 < 0.005 < 0.005 0.01 13.4
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —2.19 2.19 < 0.005 < 0.005 < 0.005 2.22
Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —2.13 2.13 < 0.005 < 0.005 < 0.005 2.23
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.53. Architectural Coating (2025) - Unmitigated
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Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
0.15 0.13 0.88 1.14 < 0.005 0.03 —0.03 0.03 —0.03 —134 134 0.01 < 0.005 —134
Architect
ural
Coatings
—14.3 ————————————————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
< 0.005 < 0.005 0.01 0.02 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —1.83 1.83 < 0.005 < 0.005 —1.84
Architect
ural
Coatings
—0.20 ————————————————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —0.30 0.30 < 0.005 < 0.005 —0.30
Architect
ural
Coatings
—0.04 ————————————————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
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Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Worker 0.01 0.01 0.01 0.12 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —30.8 30.8 < 0.005 < 0.005 < 0.005 31.1
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —0.43 0.43 < 0.005 < 0.005 < 0.005 0.43
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —0.07 0.07 < 0.005 < 0.005 < 0.005 0.07
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.54. Architectural Coating (2025) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
0.15 0.13 0.88 1.14 < 0.005 0.03 —0.03 0.03 —0.03 —134 134 0.01 < 0.005 —134
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Architect
Coatings
—14.3 ————————————————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
< 0.005 < 0.005 0.01 0.02 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —1.83 1.83 < 0.005 < 0.005 —1.84
Architect
ural
Coatings
—0.20 ————————————————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —0.30 0.30 < 0.005 < 0.005 —0.30
Architect
ural
Coatings
—0.04 ————————————————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Worker 0.01 0.01 0.01 0.12 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —30.8 30.8 < 0.005 < 0.005 < 0.005 31.1
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
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Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —0.43 0.43 < 0.005 < 0.005 < 0.005 0.43
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —0.07 0.07 < 0.005 < 0.005 < 0.005 0.07
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.55. Trenching (2024) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
2.89 2.42 22.7 19.8 0.04 0.96 —0.96 0.88 —0.88 —4,537 4,537 0.18 0.04 —4,553
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
2.89 2.42 22.7 19.8 0.04 0.96 —0.96 0.88 —0.88 —4,537 4,537 0.18 0.04 —4,553
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
1.04 0.88 8.20 7.16 0.02 0.35 —0.35 0.32 —0.32 —1,641 1,641 0.07 0.01 —1,647
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0.000.000.000.000.000.00—0.000.000.000.000.000.000.000.000.000.000.00Onsite
truck
Annual ——————————————————
Off-Road
Equipment
0.19 0.16 1.50 1.31 < 0.005 0.06 —0.06 0.06 —0.06 —272 272 0.01 < 0.005 —273
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.09 0.08 0.09 1.35 0.00 0.00 0.29 0.29 0.00 0.07 0.07 —305 305 < 0.005 0.01 1.25 309
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Worker 0.09 0.08 0.10 1.17 0.00 0.00 0.29 0.29 0.00 0.07 0.07 —290 290 < 0.005 0.01 0.03 294
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Worker 0.03 0.03 0.04 0.44 0.00 0.00 0.11 0.11 0.00 0.02 0.02 —106 106 < 0.005 < 0.005 0.20 108
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker 0.01 0.01 0.01 0.08 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 —17.6 17.6 < 0.005 < 0.005 0.03 17.8
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
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3.56. Trenching (2024) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
2.89 2.42 22.7 19.8 0.04 0.96 —0.96 0.88 —0.88 —4,537 4,537 0.18 0.04 —4,553
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
2.89 2.42 22.7 19.8 0.04 0.96 —0.96 0.88 —0.88 —4,537 4,537 0.18 0.04 —4,553
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
1.04 0.88 8.20 7.16 0.02 0.35 —0.35 0.32 —0.32 —1,641 1,641 0.07 0.01 —1,647
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.19 0.16 1.50 1.31 < 0.005 0.06 —0.06 0.06 —0.06 —272 272 0.01 < 0.005 —273
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
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——————————————————Daily,
Summer
(Max)
Worker 0.09 0.08 0.09 1.35 0.00 0.00 0.29 0.29 0.00 0.07 0.07 —305 305 < 0.005 0.01 1.25 309
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Worker 0.09 0.08 0.10 1.17 0.00 0.00 0.29 0.29 0.00 0.07 0.07 —290 290 < 0.005 0.01 0.03 294
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Worker 0.03 0.03 0.04 0.44 0.00 0.00 0.11 0.11 0.00 0.02 0.02 —106 106 < 0.005 < 0.005 0.20 108
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker 0.01 0.01 0.01 0.08 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 —17.6 17.6 < 0.005 < 0.005 0.03 17.8
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.57. Trenching (2024) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
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1,384—0.010.061,3791,379—0.32—0.320.35—0.350.018.286.670.690.82Off-Road
Equipment
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Average
Daily
——————————————————
Off-Road
Equipment
0.10 0.09 0.82 1.02 < 0.005 0.04 —0.04 0.04 —0.04 —170 170 0.01 < 0.005 —171
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.02 0.02 0.15 0.19 < 0.005 0.01 —0.01 0.01 —0.01 —28.1 28.1 < 0.005 < 0.005 —28.2
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.01 0.01 0.01 0.15 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —33.9 33.9 < 0.005 < 0.005 0.14 34.4
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Average
Daily
——————————————————
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —4.03 4.03 < 0.005 < 0.005 0.01 4.08
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
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Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —0.67 0.67 < 0.005 < 0.005 < 0.005 0.68
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.58. Trenching (2024) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
0.82 0.69 6.67 8.28 0.01 0.35 —0.35 0.32 —0.32 —1,379 1,379 0.06 0.01 —1,384
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Average
Daily
——————————————————
Off-Road
Equipment
0.10 0.09 0.82 1.02 < 0.005 0.04 —0.04 0.04 —0.04 —170 170 0.01 < 0.005 —171
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.02 0.02 0.15 0.19 < 0.005 0.01 —0.01 0.01 —0.01 —28.1 28.1 < 0.005 < 0.005 —28.2
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
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Daily,
Summer
(Max)
——————————————————
Worker 0.01 0.01 0.01 0.15 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —33.9 33.9 < 0.005 < 0.005 0.14 34.4
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Average
Daily
——————————————————
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —4.03 4.03 < 0.005 < 0.005 0.01 4.08
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —0.67 0.67 < 0.005 < 0.005 < 0.005 0.68
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.59. Trenching (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
1.64 1.37 12.6 12.7 0.04 0.49 —0.49 0.45 —0.45 —3,837 3,837 0.16 0.03 —3,850
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Bay Bridge (with Dredging) Detailed Report, 6/8/2023
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Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
1.64 1.37 12.6 12.7 0.04 0.49 —0.49 0.45 —0.45 —3,837 3,837 0.16 0.03 —3,850
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.58 0.48 4.44 4.50 0.01 0.17 —0.17 0.16 —0.16 —1,356 1,356 0.06 0.01 —1,361
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.11 0.09 0.81 0.82 < 0.005 0.03 —0.03 0.03 —0.03 —225 225 0.01 < 0.005 —225
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.07 0.06 0.06 0.98 0.00 0.00 0.23 0.23 0.00 0.05 0.05 —232 232 < 0.005 0.01 0.88 236
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Worker 0.07 0.06 0.07 0.85 0.00 0.00 0.23 0.23 0.00 0.05 0.05 —221 221 < 0.005 0.01 0.02 224
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
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Worker 0.02 0.02 0.02 0.31 0.00 0.00 0.08 0.08 0.00 0.02 0.02 —79.2 79.2 < 0.005 < 0.005 0.13 80.2
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 0.06 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 —13.1 13.1 < 0.005 < 0.005 0.02 13.3
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.60. Trenching (2025) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
1.64 1.37 12.6 12.7 0.04 0.49 —0.49 0.45 —0.45 —3,837 3,837 0.16 0.03 —3,850
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
1.64 1.37 12.6 12.7 0.04 0.49 —0.49 0.45 —0.45 —3,837 3,837 0.16 0.03 —3,850
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.58 0.48 4.44 4.50 0.01 0.17 —0.17 0.16 —0.16 —1,356 1,356 0.06 0.01 —1,361
Bay Bridge (with Dredging) Detailed Report, 6/8/2023
127 / 194
0.000.000.000.000.000.00—0.000.000.000.000.000.000.000.000.000.000.00Onsite
truck
Annual ——————————————————
Off-Road
Equipment
0.11 0.09 0.81 0.82 < 0.005 0.03 —0.03 0.03 —0.03 —225 225 0.01 < 0.005 —225
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.07 0.06 0.06 0.98 0.00 0.00 0.23 0.23 0.00 0.05 0.05 —232 232 < 0.005 0.01 0.88 236
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Worker 0.07 0.06 0.07 0.85 0.00 0.00 0.23 0.23 0.00 0.05 0.05 —221 221 < 0.005 0.01 0.02 224
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Worker 0.02 0.02 0.02 0.31 0.00 0.00 0.08 0.08 0.00 0.02 0.02 —79.2 79.2 < 0.005 < 0.005 0.13 80.2
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 0.06 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 —13.1 13.1 < 0.005 < 0.005 0.02 13.3
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Bay Bridge (with Dredging) Detailed Report, 6/8/2023
128 / 194
3.61. Trenching (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
1.94 1.62 14.6 13.5 0.03 0.61 —0.61 0.56 —0.56 —2,781 2,781 0.11 0.02 —2,790
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Average
Daily
——————————————————
Off-Road
Equipment
0.35 0.29 2.64 2.44 < 0.005 0.11 —0.11 0.10 —0.10 —503 503 0.02 < 0.005 —505
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.06 0.05 0.48 0.44 < 0.005 0.02 —0.02 0.02 —0.02 —83.2 83.2 < 0.005 < 0.005 —83.5
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.09 0.08 0.08 1.26 0.00 0.00 0.29 0.29 0.00 0.07 0.07 —299 299 < 0.005 0.01 1.13 303
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Bay Bridge (with Dredging) Detailed Report, 6/8/2023
129 / 194
Daily,
Winter
(Max)
——————————————————
Average
Daily
——————————————————
Worker 0.02 0.01 0.02 0.21 0.00 0.00 0.05 0.05 0.00 0.01 0.01 —52.1 52.1 < 0.005 < 0.005 0.09 52.8
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 0.04 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 —8.63 8.63 < 0.005 < 0.005 0.01 8.74
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.62. Trenching (2025) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
1.94 1.62 14.6 13.5 0.03 0.61 —0.61 0.56 —0.56 —2,781 2,781 0.11 0.02 —2,790
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Average
Daily
——————————————————
Off-Road
Equipment
0.35 0.29 2.64 2.44 < 0.005 0.11 —0.11 0.10 —0.10 —503 503 0.02 < 0.005 —505
Bay Bridge (with Dredging) Detailed Report, 6/8/2023
130 / 194
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.06 0.05 0.48 0.44 < 0.005 0.02 —0.02 0.02 —0.02 —83.2 83.2 < 0.005 < 0.005 —83.5
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.09 0.08 0.08 1.26 0.00 0.00 0.29 0.29 0.00 0.07 0.07 —299 299 < 0.005 0.01 1.13 303
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Average
Daily
——————————————————
Worker 0.02 0.01 0.02 0.21 0.00 0.00 0.05 0.05 0.00 0.01 0.01 —52.1 52.1 < 0.005 < 0.005 0.09 52.8
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 0.04 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 —8.63 8.63 < 0.005 < 0.005 0.01 8.74
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.63. Trenching (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Bay Bridge (with Dredging) Detailed Report, 6/8/2023
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Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
2.80 2.35 21.3 19.3 0.05 0.87 —0.87 0.80 —0.80 —4,763 4,763 0.19 0.04 —4,779
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.51 0.42 3.84 3.49 0.01 0.16 —0.16 0.15 —0.15 —861 861 0.03 0.01 —864
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.09 0.08 0.70 0.64 < 0.005 0.03 —0.03 0.03 —0.03 —143 143 0.01 < 0.005 —143
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Worker 0.09 0.08 0.09 1.09 0.00 0.00 0.29 0.29 0.00 0.07 0.07 —284 284 < 0.005 0.01 0.03 288
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Bay Bridge (with Dredging) Detailed Report, 6/8/2023
132 / 194
——————————————————Average
Daily
Worker 0.02 0.01 0.02 0.21 0.00 0.00 0.05 0.05 0.00 0.01 0.01 —52.1 52.1 < 0.005 < 0.005 0.09 52.8
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 0.04 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 —8.63 8.63 < 0.005 < 0.005 0.01 8.74
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.64. Trenching (2025) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
2.80 2.35 21.3 19.3 0.05 0.87 —0.87 0.80 —0.80 —4,763 4,763 0.19 0.04 —4,779
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.51 0.42 3.84 3.49 0.01 0.16 —0.16 0.15 —0.15 —861 861 0.03 0.01 —864
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Bay Bridge (with Dredging) Detailed Report, 6/8/2023
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Off-Road
Equipment
0.09 0.08 0.70 0.64 < 0.005 0.03 —0.03 0.03 —0.03 —143 143 0.01 < 0.005 —143
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Worker 0.09 0.08 0.09 1.09 0.00 0.00 0.29 0.29 0.00 0.07 0.07 —284 284 < 0.005 0.01 0.03 288
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Worker 0.02 0.01 0.02 0.21 0.00 0.00 0.05 0.05 0.00 0.01 0.01 —52.1 52.1 < 0.005 < 0.005 0.09 52.8
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 0.04 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 —8.63 8.63 < 0.005 < 0.005 0.01 8.74
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.65. Trenching (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Bay Bridge (with Dredging) Detailed Report, 6/8/2023
134 / 194
——————————————————Daily,
Summer
(Max)
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
1.91 1.60 14.1 12.5 0.03 0.60 —0.60 0.55 —0.55 —2,720 2,720 0.11 0.02 —2,729
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.23 0.19 1.69 1.49 < 0.005 0.07 —0.07 0.07 —0.07 —325 325 0.01 < 0.005 —326
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.04 0.03 0.31 0.27 < 0.005 0.01 —0.01 0.01 —0.01 —53.8 53.8 < 0.005 < 0.005 —53.9
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Worker 0.08 0.08 0.08 1.02 0.00 0.00 0.29 0.29 0.00 0.07 0.07 —279 279 < 0.005 0.01 0.03 282
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Bay Bridge (with Dredging) Detailed Report, 6/8/2023
135 / 194
Worker 0.01 0.01 0.01 0.13 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —33.7 33.7 < 0.005 < 0.005 0.05 34.2
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 —5.59 5.59 < 0.005 < 0.005 0.01 5.66
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.66. Trenching (2026) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
1.91 1.60 14.1 12.5 0.03 0.60 —0.60 0.55 —0.55 —2,720 2,720 0.11 0.02 —2,729
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.23 0.19 1.69 1.49 < 0.005 0.07 —0.07 0.07 —0.07 —325 325 0.01 < 0.005 —326
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.04 0.03 0.31 0.27 < 0.005 0.01 —0.01 0.01 —0.01 —53.8 53.8 < 0.005 < 0.005 —53.9
Bay Bridge (with Dredging) Detailed Report, 6/8/2023
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Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Worker 0.08 0.08 0.08 1.02 0.00 0.00 0.29 0.29 0.00 0.07 0.07 —279 279 < 0.005 0.01 0.03 282
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Worker 0.01 0.01 0.01 0.13 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —33.7 33.7 < 0.005 < 0.005 0.05 34.2
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 —5.59 5.59 < 0.005 < 0.005 0.01 5.66
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.67. Trenching (2027) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Bay Bridge (with Dredging) Detailed Report, 6/8/2023
137 / 194
——————————————————Daily,
Winter
(Max)
Off-Road
Equipment
1.87 1.57 13.6 12.3 0.03 0.57 —0.57 0.52 —0.52 —2,720 2,720 0.11 0.02 —2,729
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.11 0.10 0.83 0.74 < 0.005 0.03 —0.03 0.03 —0.03 —165 165 0.01 < 0.005 —166
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.02 0.02 0.15 0.14 < 0.005 0.01 —0.01 0.01 —0.01 —27.3 27.3 < 0.005 < 0.005 —27.4
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Worker 0.07 0.06 0.07 0.96 0.00 0.00 0.29 0.29 0.00 0.07 0.07 —274 274 < 0.005 0.01 0.02 277
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Worker < 0.005 < 0.005 < 0.005 0.06 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 —16.9 16.9 < 0.005 < 0.005 0.02 17.1
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
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Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —2.79 2.79 < 0.005 < 0.005 < 0.005 2.83
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.68. Trenching (2027) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
1.87 1.57 13.6 12.3 0.03 0.57 —0.57 0.52 —0.52 —2,720 2,720 0.11 0.02 —2,729
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.11 0.10 0.83 0.74 < 0.005 0.03 —0.03 0.03 —0.03 —165 165 0.01 < 0.005 —166
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.02 0.02 0.15 0.14 < 0.005 0.01 —0.01 0.01 —0.01 —27.3 27.3 < 0.005 < 0.005 —27.4
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
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Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Worker 0.07 0.06 0.07 0.96 0.00 0.00 0.29 0.29 0.00 0.07 0.07 —274 274 < 0.005 0.01 0.02 277
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Worker < 0.005 < 0.005 < 0.005 0.06 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 —16.9 16.9 < 0.005 < 0.005 0.02 17.1
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —2.79 2.79 < 0.005 < 0.005 < 0.005 2.83
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
4. Operations Emissions Details
4.1. Mobile Emissions by Land Use
4.1.1. Unmitigated
Mobile source emissions results are presented in Sections 2.6. No further detailed breakdown of emissions is available.
4.1.2. Mitigated
Mobile source emissions results are presented in Sections 2.5. No further detailed breakdown of emissions is available.
4.2. Energy
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4.2.1. Electricity Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
General
Light
Industry
————————————203 203 0.01 < 0.005 —203
Other
Asphalt
Surfaces
————————————0.00 0.00 0.00 0.00 —0.00
Total ————————————203 203 0.01 < 0.005 —203
Daily,
Winter
(Max)
——————————————————
General
Light
Industry
————————————203 203 0.01 < 0.005 —203
Other
Asphalt
Surfaces
————————————0.00 0.00 0.00 0.00 —0.00
Total ————————————203 203 0.01 < 0.005 —203
Annual ——————————————————
General
Light
Industry
————————————33.6 33.6 < 0.005 < 0.005 —33.7
Other
Asphalt
Surfaces
————————————0.00 0.00 0.00 0.00 —0.00
Total ————————————33.6 33.6 < 0.005 < 0.005 —33.7
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4.2.2. Electricity Emissions By Land Use - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
General
Light
Industry
————————————158 158 0.01 < 0.005 —159
Other
Asphalt
Surfaces
————————————0.00 0.00 0.00 0.00 —0.00
Total ————————————158 158 0.01 < 0.005 —159
Daily,
Winter
(Max)
——————————————————
General
Light
Industry
————————————158 158 0.01 < 0.005 —159
Other
Asphalt
Surfaces
————————————0.00 0.00 0.00 0.00 —0.00
Total ————————————158 158 0.01 < 0.005 —159
Annual ——————————————————
General
Light
Industry
————————————26.2 26.2 < 0.005 < 0.005 —26.3
Other
Asphalt
Surfaces
————————————0.00 0.00 0.00 0.00 —0.00
Total ————————————26.2 26.2 < 0.005 < 0.005 —26.3
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4.2.3. Natural Gas Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
General
Light
Industry
0.02 0.01 0.17 0.14 < 0.005 0.01 —0.01 0.01 —0.01 —199 199 0.02 < 0.005 —199
Other
Asphalt
Surfaces
0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 —0.00 —0.00 0.00 0.00 0.00 —0.00
Total 0.02 0.01 0.17 0.14 < 0.005 0.01 —0.01 0.01 —0.01 —199 199 0.02 < 0.005 —199
Daily,
Winter
(Max)
——————————————————
General
Light
Industry
0.02 0.01 0.17 0.14 < 0.005 0.01 —0.01 0.01 —0.01 —199 199 0.02 < 0.005 —199
Other
Asphalt
Surfaces
0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 —0.00 —0.00 0.00 0.00 0.00 —0.00
Total 0.02 0.01 0.17 0.14 < 0.005 0.01 —0.01 0.01 —0.01 —199 199 0.02 < 0.005 —199
Annual ——————————————————
General
Light
Industry
< 0.005 < 0.005 0.03 0.03 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —32.9 32.9 < 0.005 < 0.005 —33.0
Other
Asphalt
Surfaces
0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 —0.00 —0.00 0.00 0.00 0.00 —0.00
Total < 0.005 < 0.005 0.03 0.03 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —32.9 32.9 < 0.005 < 0.005 —33.0
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4.2.4. Natural Gas Emissions By Land Use - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
General
Light
Industry
0.02 0.01 0.16 0.13 < 0.005 0.01 —0.01 0.01 —0.01 —190 190 0.02 < 0.005 —191
Other
Asphalt
Surfaces
0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 —0.00 —0.00 0.00 0.00 0.00 —0.00
Total 0.02 0.01 0.16 0.13 < 0.005 0.01 —0.01 0.01 —0.01 —190 190 0.02 < 0.005 —191
Daily,
Winter
(Max)
——————————————————
General
Light
Industry
0.02 0.01 0.16 0.13 < 0.005 0.01 —0.01 0.01 —0.01 —190 190 0.02 < 0.005 —191
Other
Asphalt
Surfaces
0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 —0.00 —0.00 0.00 0.00 0.00 —0.00
Total 0.02 0.01 0.16 0.13 < 0.005 0.01 —0.01 0.01 —0.01 —190 190 0.02 < 0.005 —191
Annual ——————————————————
General
Light
Industry
< 0.005 < 0.005 0.03 0.02 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —31.5 31.5 < 0.005 < 0.005 —31.6
Other
Asphalt
Surfaces
0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 —0.00 —0.00 0.00 0.00 0.00 —0.00
Total < 0.005 < 0.005 0.03 0.02 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —31.5 31.5 < 0.005 < 0.005 —31.6
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4.3. Area Emissions by Source
4.3.2. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Source TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Consum
er
Products
—0.31 ————————————————
Architect
ural
Coatings
—0.02 ————————————————
Landsca
pe
Equipme
nt
0.11 0.10 0.01 0.63 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —2.59 2.59 < 0.005 < 0.005 —2.60
Total 0.11 0.43 0.01 0.63 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —2.59 2.59 < 0.005 < 0.005 —2.60
Daily,
Winter
(Max)
——————————————————
Consum
er
Products
—0.31 ————————————————
Architect
ural
Coatings
—0.02 ————————————————
Total —0.33 ————————————————
Annual ——————————————————
Consum
er
Products
—0.06 ————————————————
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————————————————< 0.005—Architect
ural
Landsca
pe
Equipme
nt
0.01 0.01 < 0.005 0.08 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —0.29 0.29 < 0.005 < 0.005 —0.30
Total 0.01 0.07 < 0.005 0.08 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —0.29 0.29 < 0.005 < 0.005 —0.30
4.3.1. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Source TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Consum
er
Products
—0.31 ————————————————
Architect
ural
Coatings
—0.02 ————————————————
Landsca
pe
Equipme
nt
0.11 0.10 0.01 0.63 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —2.59 2.59 < 0.005 < 0.005 —2.60
Total 0.11 0.43 0.01 0.63 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —2.59 2.59 < 0.005 < 0.005 —2.60
Daily,
Winter
(Max)
——————————————————
Consum
er
Products
—0.31 ————————————————
Architect
ural
Coatings
—0.02 ————————————————
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Total —0.33 ————————————————
Annual ——————————————————
Consum
er
Products
—0.06 ————————————————
Architect
ural
Coatings
—< 0.005 ————————————————
Landsca
pe
Equipme
nt
0.01 0.01 < 0.005 0.08 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —0.29 0.29 < 0.005 < 0.005 —0.30
Total 0.01 0.07 < 0.005 0.08 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —0.29 0.29 < 0.005 < 0.005 —0.30
4.4. Water Emissions by Land Use
4.4.2. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
General
Light
Industry
———————————6.43 33.4 39.8 0.66 0.02 —61.1
Other
Asphalt
Surfaces
———————————0.00 < 0.005 < 0.005 < 0.005 < 0.005 —< 0.005
Total ———————————6.43 33.4 39.8 0.66 0.02 —61.1
Daily,
Winter
(Max)
——————————————————
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General
Light
Industry
———————————6.43 33.4 39.8 0.66 0.02 —61.1
Other
Asphalt
Surfaces
———————————0.00 < 0.005 < 0.005 < 0.005 < 0.005 —< 0.005
Total ———————————6.43 33.4 39.8 0.66 0.02 —61.1
Annual ——————————————————
General
Light
Industry
———————————1.06 5.52 6.59 0.11 < 0.005 —10.1
Other
Asphalt
Surfaces
———————————0.00 < 0.005 < 0.005 < 0.005 < 0.005 —< 0.005
Total ———————————1.06 5.52 6.59 0.11 < 0.005 —10.1
4.4.1. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
General
Light
Industry
———————————6.43 33.4 39.8 0.66 0.02 —61.1
Other
Asphalt
Surfaces
———————————0.00 < 0.005 < 0.005 < 0.005 < 0.005 —< 0.005
Total ———————————6.43 33.4 39.8 0.66 0.02 —61.1
Daily,
Winter
(Max)
——————————————————
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61.1—0.020.6639.833.46.43———————————General
Light
Industry
Other
Asphalt
Surfaces
———————————0.00 < 0.005 < 0.005 < 0.005 < 0.005 —< 0.005
Total ———————————6.43 33.4 39.8 0.66 0.02 —61.1
Annual ——————————————————
General
Light
Industry
———————————1.06 5.52 6.59 0.11 < 0.005 —10.1
Other
Asphalt
Surfaces
———————————0.00 < 0.005 < 0.005 < 0.005 < 0.005 —< 0.005
Total ———————————1.06 5.52 6.59 0.11 < 0.005 —10.1
4.5. Waste Emissions by Land Use
4.5.2. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
General
Light
Industry
———————————9.69 0.00 9.69 0.97 0.00 —33.9
Other
Asphalt
Surfaces
———————————0.00 0.00 0.00 0.00 0.00 —0.00
Total ———————————9.69 0.00 9.69 0.97 0.00 —33.9
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——————————————————Daily,
Winter
(Max)
General
Light
Industry
———————————9.69 0.00 9.69 0.97 0.00 —33.9
Other
Asphalt
Surfaces
———————————0.00 0.00 0.00 0.00 0.00 —0.00
Total ———————————9.69 0.00 9.69 0.97 0.00 —33.9
Annual ——————————————————
General
Light
Industry
———————————1.60 0.00 1.60 0.16 0.00 —5.61
Other
Asphalt
Surfaces
———————————0.00 0.00 0.00 0.00 0.00 —0.00
Total ———————————1.60 0.00 1.60 0.16 0.00 —5.61
4.5.1. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
General
Light
Industry
———————————4.85 0.00 4.85 0.48 0.00 —17.0
Other
Asphalt
Surfaces
———————————0.00 0.00 0.00 0.00 0.00 —0.00
Total ———————————4.85 0.00 4.85 0.48 0.00 —17.0
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——————————————————Daily,
Winter
(Max)
General
Light
Industry
———————————4.85 0.00 4.85 0.48 0.00 —17.0
Other
Asphalt
Surfaces
———————————0.00 0.00 0.00 0.00 0.00 —0.00
Total ———————————4.85 0.00 4.85 0.48 0.00 —17.0
Annual ——————————————————
General
Light
Industry
———————————0.80 0.00 0.80 0.08 0.00 —2.81
Other
Asphalt
Surfaces
———————————0.00 0.00 0.00 0.00 0.00 —0.00
Total ———————————0.80 0.00 0.80 0.08 0.00 —2.81
4.6. Refrigerant Emissions by Land Use
4.6.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
General
Light
Industry
————————————————3.77 3.77
Total ————————————————3.77 3.77
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——————————————————Daily,
Winter
(Max)
General
Light
Industry
————————————————3.77 3.77
Total ————————————————3.77 3.77
Annual ——————————————————
General
Light
Industry
————————————————0.62 0.62
Total ————————————————0.62 0.62
4.6.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
General
Light
Industry
————————————————3.77 3.77
Total ————————————————3.77 3.77
Daily,
Winter
(Max)
——————————————————
General
Light
Industry
————————————————3.77 3.77
Total ————————————————3.77 3.77
Annual ——————————————————
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0.620.62————————————————General
Light
Industry
Total ————————————————0.62 0.62
4.7. Offroad Emissions By Equipment Type
4.7.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Equipme
nt
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Total ——————————————————
Daily,
Winter
(Max)
——————————————————
Total ——————————————————
Annual ——————————————————
Total ——————————————————
4.7.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Equipme
nt
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Total ——————————————————
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Daily,
Winter
(Max)
——————————————————
Total ——————————————————
Annual ——————————————————
Total ——————————————————
4.8. Stationary Emissions By Equipment Type
4.8.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Equipme
nt
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Total ——————————————————
Daily,
Winter
(Max)
——————————————————
Total ——————————————————
Annual ——————————————————
Total ——————————————————
4.8.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Equipme
nt
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
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——————————————————Daily,
Summer
(Max)
Total ——————————————————
Daily,
Winter
(Max)
——————————————————
Total ——————————————————
Annual ——————————————————
Total ——————————————————
4.9. User Defined Emissions By Equipment Type
4.9.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Equipme
nt
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Total ——————————————————
Daily,
Winter
(Max)
——————————————————
Total ——————————————————
Annual ——————————————————
Total ——————————————————
4.9.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
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Equipme
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Total ——————————————————
Daily,
Winter
(Max)
——————————————————
Total ——————————————————
Annual ——————————————————
Total ——————————————————
4.10. Soil Carbon Accumulation By Vegetation Type
4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Vegetatio
n
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Total ——————————————————
Daily,
Winter
(Max)
——————————————————
Total ——————————————————
Annual ——————————————————
Total ——————————————————
4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated
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Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Total ——————————————————
Daily,
Winter
(Max)
——————————————————
Total ——————————————————
Annual ——————————————————
Total ——————————————————
4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Species TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Avoided ——————————————————
Subtotal ——————————————————
Sequest
ered
——————————————————
Subtotal ——————————————————
Remove
d
——————————————————
Subtotal ——————————————————
———————————————————
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——————————————————Daily,
Winter
(Max)
Avoided ——————————————————
Subtotal ——————————————————
Sequest
ered
——————————————————
Subtotal ——————————————————
Remove
d
——————————————————
Subtotal ——————————————————
———————————————————
Annual ——————————————————
Avoided ——————————————————
Subtotal ——————————————————
Sequest
ered
——————————————————
Subtotal ——————————————————
Remove
d
——————————————————
Subtotal ——————————————————
———————————————————
4.10.4. Soil Carbon Accumulation By Vegetation Type - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Vegetatio
n
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Total ——————————————————
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Daily,
Winter
(Max)
——————————————————
Total ——————————————————
Annual ——————————————————
Total ——————————————————
4.10.5. Above and Belowground Carbon Accumulation by Land Use Type - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Total ——————————————————
Daily,
Winter
(Max)
——————————————————
Total ——————————————————
Annual ——————————————————
Total ——————————————————
4.10.6. Avoided and Sequestered Emissions by Species - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Species TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Avoided ——————————————————
Subtotal ——————————————————
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Sequest ——————————————————
Subtotal ——————————————————
Remove
d
——————————————————
Subtotal ——————————————————
———————————————————
Daily,
Winter
(Max)
——————————————————
Avoided ——————————————————
Subtotal ——————————————————
Sequest
ered
——————————————————
Subtotal ——————————————————
Remove
d
——————————————————
Subtotal ——————————————————
———————————————————
Annual ——————————————————
Avoided ——————————————————
Subtotal ——————————————————
Sequest
ered
——————————————————
Subtotal ——————————————————
Remove
d
——————————————————
Subtotal ——————————————————
———————————————————
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5. Activity Data
5.1. Construction Schedule
Phase Name Phase Type Start Date End Date Days Per Week Work Days per Phase Phase Description
Pump Station Demolition Demolition 7/1/2026 10/31/2026 5.00 88.0 —
Exist. PS Demolition &
Odor Control - Soil Hauling
to Plant Number 2
Demolition 9/27/2025 01/28/2028 5.00 30.0 —
Exist. PS Demolition &
Odor Control - Soil Hauled
from Plant 2 Offsite for
Disposal
Demolition 9/27/2025 1/28/2028 5.00 30.0 —
Pump Station Earthwork &
Below Grade Concrete
Construction
Grading 7/1/2024 06/30/2025 5.00 261 —
Micro tunneling - Soil
Hauling to Plant Number 2
Grading 07/01/2024 02/28/2025 5.00 175 —
Micro tunneling - Soil
Hauled from Plant 2 Offsite
for Disposal
Grading 07/08/2024 03/07/2025 5.00 175 —
Micro tunneling - Soil
Hauled from Plant 2 back to
Project Site for Backfill
Grading 03/25/2025 04/18/2025 5.00 19.0 —
Pump Station - Soil Hauling
to Plant Number 2
Grading 05/26/2025 09/12/2025 5.00 80.0 —
Pump Station - Soil Hauled
from Plant 2 Offsite for
Disposal
Grading 06/02/2025 09/19/2025 5.00 80.0 —
Pump Station - Soil Hauled
from Plant 2 back to Project
Site for Backfill
Grading 09/19/2025 09/26/2025 5.00 6.00 —
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—25.05.0012/3/20279/27/2025DemolitionExist. PS Demolition &
Odor Control - Soil Hauled
from Plant 2 back to Project
Site for Backfill
Pump Station Above Grade
Building Construction
including MEP
Building Construction 07/1/2025 1/31/2026 5.00 154 —
Generator and Odor
Control Building
Construction
Building Construction 11/01/2026 3/31/2027 5.00 108 —
Pump Station Architectural
Coating
Architectural Coating 11/1/2025 11/7/2025 5.00 5.00 —
Force Main Pipeline
Trenching East of Newport
Bay
Trenching 7/1/2024 12/31/2024 5.00 132 —
Micro tunneling Only Trenching 07/01/2024 9/1/2024 5.00 45.0 —
Dredging Only Trenching 01/01/2025 6/30/2025 5.00 129 —
Force Main Pipeline
Trenching West of Newport
Bay
Trenching 07/01/2025 9/30/2025 5.00 66.0 —
Temporary Gravity Sewer
Trenching
Trenching 10/1/2025 12/31/2025 5.00 66.0 —
Permanent Gravity Sewer
Trenching
Trenching 11/01/2026 1/31/2027 5.00 65.0 —
5.2. Off-Road Equipment
5.2.1. Unmitigated
Phase Name Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor
Exist. PS Demolition &
Odor Control - Soil
Hauling to Plant
Number 2
Concrete/Industrial
Saws
Diesel Average 1.00 8.00 33.0 0.73
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0.7333.08.001.00AverageDieselExist. PS Demolition &
Odor Control - Soil
Hauled from Plant 2
Offsite for Disposal
Concrete/Industrial
Saws
Pump Station
Earthwork & Below
Grade Concrete
Construction
Cranes Diesel Average 1.00 6.00 367 0.29
Pump Station
Earthwork & Below
Grade Concrete
Construction
Excavators Diesel Average 1.00 6.00 36.0 0.38
Pump Station
Earthwork & Below
Grade Concrete
Construction
Other Construction
Equipment
Diesel Average 1.00 6.00 475 0.50
Pump Station
Earthwork & Below
Grade Concrete
Construction
Pumps Diesel Average 3.00 6.00 11.0 0.74
Pump Station
Earthwork & Below
Grade Concrete
Construction
Rollers Diesel Average 1.00 8.00 36.0 0.38
Exist. PS Demolition &
Odor Control - Soil
Hauled from Plant 2
back to Project Site for
Backfill
Concrete/Industrial
Saws
Diesel Average 1.00 8.00 33.0 0.73
Pump Station Above
Grade Building
Construction including
MEP
Cranes Diesel Average 1.00 4.00 367 0.29
Pump Station Above
Grade Building
Construction including
MEP
Tractors/Loaders/Backh
oes
Diesel Average 2.00 8.00 84.0 0.37
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0.7411.06.001.00AverageDieselPumpsPump Station Above
Grade Building
Construction including
MEP
Generator and Odor
Control Building
Construction
Cranes Diesel Average 1.00 4.00 367 0.29
Generator and Odor
Control Building
Construction
Tractors/Loaders/Backh
oes
Diesel Average 2.00 8.00 84.0 0.37
Generator and Odor
Control Building
Construction
Pumps Diesel Average 1.00 6.00 11.0 0.74
Pump Station
Architectural Coating
Air Compressors Diesel Average 1.00 6.00 37.0 0.48
Force Main Pipeline
Trenching East of
Newport Bay
Other Construction
Equipment
Diesel Average 1.00 6.00 475 0.50
Force Main Pipeline
Trenching East of
Newport Bay
Pumps Diesel Average 3.00 6.00 11.0 0.74
Force Main Pipeline
Trenching East of
Newport Bay
Rollers Diesel Average 1.00 8.00 36.0 0.38
Force Main Pipeline
Trenching East of
Newport Bay
Rubber Tired Dozers Diesel Average 1.00 8.00 367 0.40
Force Main Pipeline
Trenching East of
Newport Bay
Cranes Diesel Average 1.00 6.00 367 0.29
Force Main Pipeline
Trenching East of
Newport Bay
Excavators Diesel Average 1.00 8.00 36.0 0.38
Force Main Pipeline
Trenching East of
Newport Bay
Tractors/Loaders/Backh
oes
Diesel Average 1.00 8.00 84.0 0.37
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Micro tunneling Only Other Construction
Equipment
Diesel Average 1.00 24.0 118 0.42
Dredging Only Cranes Diesel Average 1.00 6.00 367 0.29
Dredging Only Other Construction
Equipment
Diesel Average 1.00 8.00 500 0.50
Dredging Only Pumps Diesel Average 3.00 6.00 11.0 0.74
Dredging Only Tractors/Loaders/Backh
oes
Diesel Average 2.00 8.00 84.0 0.37
Force Main Pipeline
Trenching West of
Newport Bay
Cranes Diesel Average 1.00 6.00 367 0.29
Force Main Pipeline
Trenching West of
Newport Bay
Excavators Diesel Average 1.00 8.00 36.0 0.38
Force Main Pipeline
Trenching West of
Newport Bay
Other Construction
Equipment
Diesel Average 1.00 8.00 475 0.05
Force Main Pipeline
Trenching West of
Newport Bay
Pumps Diesel Average 3.00 8.00 11.0 0.74
Force Main Pipeline
Trenching West of
Newport Bay
Rollers Diesel Average 1.00 6.00 36.0 0.38
Force Main Pipeline
Trenching West of
Newport Bay
Rubber Tired Dozers Diesel Average 1.00 6.00 367 0.40
Force Main Pipeline
Trenching West of
Newport Bay
Tractors/Loaders/Backh
oes
Diesel Average 1.00 8.00 84.0 0.37
Temporary Gravity
Sewer Trenching
Cranes Diesel Average 1.00 6.00 367 0.29
Temporary Gravity
Sewer Trenching
Excavators Diesel Average 1.00 8.00 36.0 0.38
Temporary Gravity
Sewer Trenching
Other Construction
Equipment
Diesel Average 1.00 8.00 475 0.42
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Temporary Gravity
Sewer Trenching
Pumps Diesel Average 3.00 8.00 11.0 0.74
Temporary Gravity
Sewer Trenching
Rollers Diesel Average 1.00 6.00 36.0 0.38
Temporary Gravity
Sewer Trenching
Rubber Tired Dozers Diesel Average 1.00 8.00 367 0.40
Temporary Gravity
Sewer Trenching
Tractors/Loaders/Backh
oes
Diesel Average 1.00 8.00 84.0 0.37
Permanent Gravity
Sewer Trenching
Cranes Diesel Average 1.00 6.00 367 0.29
Permanent Gravity
Sewer Trenching
Excavators Diesel Average 1.00 6.00 36.0 0.38
Permanent Gravity
Sewer Trenching
Other Construction
Equipment
Diesel Average 1.00 6.00 475 0.05
Permanent Gravity
Sewer Trenching
Pumps Diesel Average 3.00 6.00 11.0 0.74
Permanent Gravity
Sewer Trenching
Rollers Diesel Average 1.00 6.00 36.0 0.38
Permanent Gravity
Sewer Trenching
Rubber Tired Dozers Diesel Average 1.00 8.00 367 0.40
Permanent Gravity
Sewer Trenching
Tractors/Loaders/Backh
oes
Diesel Average 1.00 1.00 84.0 0.37
5.2.2. Mitigated
Phase Name Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor
Exist. PS Demolition &
Odor Control - Soil
Hauling to Plant
Number 2
Concrete/Industrial
Saws
Diesel Average 1.00 8.00 33.0 0.73
Exist. PS Demolition &
Odor Control - Soil
Hauled from Plant 2
Offsite for Disposal
Concrete/Industrial
Saws
Diesel Average 1.00 8.00 33.0 0.73
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Pump Station
Earthwork & Below
Grade Concrete
Construction
Cranes Diesel Average 1.00 6.00 367 0.29
Pump Station
Earthwork & Below
Grade Concrete
Construction
Excavators Diesel Average 1.00 6.00 36.0 0.38
Pump Station
Earthwork & Below
Grade Concrete
Construction
Other Construction
Equipment
Diesel Average 1.00 6.00 475 0.50
Pump Station
Earthwork & Below
Grade Concrete
Construction
Pumps Diesel Average 3.00 6.00 11.0 0.74
Pump Station
Earthwork & Below
Grade Concrete
Construction
Rollers Diesel Average 1.00 8.00 36.0 0.38
Exist. PS Demolition &
Odor Control - Soil
Hauled from Plant 2
back to Project Site for
Backfill
Concrete/Industrial
Saws
Diesel Average 1.00 8.00 33.0 0.73
Pump Station Above
Grade Building
Construction including
MEP
Cranes Diesel Average 1.00 4.00 367 0.29
Pump Station Above
Grade Building
Construction including
MEP
Tractors/Loaders/Backh
oes
Diesel Average 2.00 8.00 84.0 0.37
Pump Station Above
Grade Building
Construction including
MEP
Pumps Diesel Average 1.00 6.00 11.0 0.74
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0.293674.001.00AverageDieselCranesGenerator and Odor
Control Building
Construction
Generator and Odor
Control Building
Construction
Tractors/Loaders/Backh
oes
Diesel Average 2.00 8.00 84.0 0.37
Generator and Odor
Control Building
Construction
Pumps Diesel Average 1.00 6.00 11.0 0.74
Pump Station
Architectural Coating
Air Compressors Diesel Average 1.00 6.00 37.0 0.48
Force Main Pipeline
Trenching East of
Newport Bay
Other Construction
Equipment
Diesel Average 1.00 6.00 475 0.50
Force Main Pipeline
Trenching East of
Newport Bay
Pumps Diesel Average 3.00 6.00 11.0 0.74
Force Main Pipeline
Trenching East of
Newport Bay
Rollers Diesel Average 1.00 8.00 36.0 0.38
Force Main Pipeline
Trenching East of
Newport Bay
Rubber Tired Dozers Diesel Average 1.00 8.00 367 0.40
Force Main Pipeline
Trenching East of
Newport Bay
Cranes Diesel Average 1.00 6.00 367 0.29
Force Main Pipeline
Trenching East of
Newport Bay
Excavators Diesel Average 1.00 8.00 36.0 0.38
Force Main Pipeline
Trenching East of
Newport Bay
Tractors/Loaders/Backh
oes
Diesel Average 1.00 8.00 84.0 0.37
Micro tunneling Only Other Construction
Equipment
Diesel Average 1.00 24.0 118 0.42
Dredging Only Cranes Diesel Average 1.00 6.00 367 0.29
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0.505008.001.00AverageDieselDredging Only Other Construction
Equipment
Dredging Only Pumps Diesel Average 3.00 6.00 11.0 0.74
Dredging Only Tractors/Loaders/Backh
oes
Diesel Average 2.00 8.00 84.0 0.37
Force Main Pipeline
Trenching West of
Newport Bay
Cranes Diesel Average 1.00 6.00 367 0.29
Force Main Pipeline
Trenching West of
Newport Bay
Excavators Diesel Average 1.00 8.00 36.0 0.38
Force Main Pipeline
Trenching West of
Newport Bay
Other Construction
Equipment
Diesel Average 1.00 8.00 475 0.05
Force Main Pipeline
Trenching West of
Newport Bay
Pumps Diesel Average 3.00 8.00 11.0 0.74
Force Main Pipeline
Trenching West of
Newport Bay
Rollers Diesel Average 1.00 6.00 36.0 0.38
Force Main Pipeline
Trenching West of
Newport Bay
Rubber Tired Dozers Diesel Average 1.00 6.00 367 0.40
Force Main Pipeline
Trenching West of
Newport Bay
Tractors/Loaders/Backh
oes
Diesel Average 1.00 8.00 84.0 0.37
Temporary Gravity
Sewer Trenching
Cranes Diesel Average 1.00 6.00 367 0.29
Temporary Gravity
Sewer Trenching
Excavators Diesel Average 1.00 8.00 36.0 0.38
Temporary Gravity
Sewer Trenching
Other Construction
Equipment
Diesel Average 1.00 8.00 475 0.42
Temporary Gravity
Sewer Trenching
Pumps Diesel Average 3.00 8.00 11.0 0.74
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0.3836.06.001.00AverageDieselRollersTemporary Gravity
Sewer Trenching
Temporary Gravity
Sewer Trenching
Rubber Tired Dozers Diesel Average 1.00 8.00 367 0.40
Temporary Gravity
Sewer Trenching
Tractors/Loaders/Backh
oes
Diesel Average 1.00 8.00 84.0 0.37
Permanent Gravity
Sewer Trenching
Cranes Diesel Average 1.00 6.00 367 0.29
Permanent Gravity
Sewer Trenching
Excavators Diesel Average 1.00 6.00 36.0 0.38
Permanent Gravity
Sewer Trenching
Other Construction
Equipment
Diesel Average 1.00 6.00 475 0.05
Permanent Gravity
Sewer Trenching
Pumps Diesel Average 3.00 6.00 11.0 0.74
Permanent Gravity
Sewer Trenching
Rollers Diesel Average 1.00 6.00 36.0 0.38
Permanent Gravity
Sewer Trenching
Rubber Tired Dozers Diesel Average 1.00 8.00 367 0.40
Permanent Gravity
Sewer Trenching
Tractors/Loaders/Backh
oes
Diesel Average 1.00 1.00 84.0 0.37
5.3. Construction Vehicles
5.3.1. Unmitigated
Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix
Pump Station Earthwork & Below
Grade Concrete Construction
————
Pump Station Earthwork & Below
Grade Concrete Construction
Worker 17.5 18.5 LDA,LDT1,LDT2
Pump Station Earthwork & Below
Grade Concrete Construction
Vendor —10.2 HHDT,MHDT
Pump Station Earthwork & Below
Grade Concrete Construction
Hauling 0.00 20.0 HHDT
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Pump Station Earthwork & Below
Grade Concrete Construction
Onsite truck ——HHDT
Force Main Pipeline Trenching East of
Newport Bay
————
Force Main Pipeline Trenching East of
Newport Bay
Worker 22.5 18.5 LDA,LDT1,LDT2
Force Main Pipeline Trenching East of
Newport Bay
Vendor —10.2 HHDT,MHDT
Force Main Pipeline Trenching East of
Newport Bay
Hauling 0.00 20.0 HHDT
Force Main Pipeline Trenching East of
Newport Bay
Onsite truck ——HHDT
Pump Station Demolition ————
Pump Station Demolition Worker 0.00 18.5 LDA,LDT1,LDT2
Pump Station Demolition Vendor —10.2 HHDT,MHDT
Pump Station Demolition Hauling 0.00 20.0 HHDT
Pump Station Demolition Onsite truck ——HHDT
Pump Station Above Grade Building
Construction including MEP
————
Pump Station Above Grade Building
Construction including MEP
Worker 6.09 18.5 LDA,LDT1,LDT2
Pump Station Above Grade Building
Construction including MEP
Vendor 2.38 10.2 HHDT,MHDT
Pump Station Above Grade Building
Construction including MEP
Hauling 0.00 20.0 HHDT
Pump Station Above Grade Building
Construction including MEP
Onsite truck ——HHDT
Generator and Odor Control Building
Construction
————
Generator and Odor Control Building
Construction
Worker 6.09 18.5 LDA,LDT1,LDT2
Generator and Odor Control Building
Construction
Vendor 2.38 10.2 HHDT,MHDT
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Generator and Odor Control Building
Construction
Hauling 0.00 20.0 HHDT
Generator and Odor Control Building
Construction
Onsite truck ——HHDT
Pump Station Architectural Coating ————
Pump Station Architectural Coating Worker 2.44 18.5 LDA,LDT1,LDT2
Pump Station Architectural Coating Vendor —10.2 HHDT,MHDT
Pump Station Architectural Coating Hauling 0.00 20.0 HHDT
Pump Station Architectural Coating Onsite truck ——HHDT
Micro tunneling Only ————
Micro tunneling Only Worker 2.50 18.5 LDA,LDT1,LDT2
Micro tunneling Only Vendor —10.2 HHDT,MHDT
Micro tunneling Only Hauling 0.00 20.0 HHDT
Micro tunneling Only Onsite truck ——HHDT
Dredging Only ————
Dredging Only Worker 17.5 18.5 LDA,LDT1,LDT2
Dredging Only Vendor —10.2 HHDT,MHDT
Dredging Only Hauling 0.00 20.0 HHDT
Dredging Only Onsite truck ——HHDT
Force Main Pipeline Trenching West of
Newport Bay
————
Force Main Pipeline Trenching West of
Newport Bay
Worker 22.5 18.5 LDA,LDT1,LDT2
Force Main Pipeline Trenching West of
Newport Bay
Vendor —10.2 HHDT,MHDT
Force Main Pipeline Trenching West of
Newport Bay
Hauling 0.00 20.0 HHDT
Force Main Pipeline Trenching West of
Newport Bay
Onsite truck ——HHDT
Temporary Gravity Sewer Trenching ————
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Temporary Gravity Sewer Trenching Worker 22.5 18.5 LDA,LDT1,LDT2
Temporary Gravity Sewer Trenching Vendor —10.2 HHDT,MHDT
Temporary Gravity Sewer Trenching Hauling 0.00 20.0 HHDT
Temporary Gravity Sewer Trenching Onsite truck ——HHDT
Permanent Gravity Sewer Trenching ————
Permanent Gravity Sewer Trenching Worker 22.5 18.5 LDA,LDT1,LDT2
Permanent Gravity Sewer Trenching Vendor —10.2 HHDT,MHDT
Permanent Gravity Sewer Trenching Hauling 0.00 20.0 HHDT
Permanent Gravity Sewer Trenching Onsite truck ——HHDT
Micro tunneling - Soil Hauling to Plant
Number 2
————
Micro tunneling - Soil Hauling to Plant
Number 2
Worker 0.00 18.5 LDA,LDT1,LDT2
Micro tunneling - Soil Hauling to Plant
Number 2
Vendor —10.2 HHDT,MHDT
Micro tunneling - Soil Hauling to Plant
Number 2
Hauling 2.34 20.0 HHDT
Micro tunneling - Soil Hauling to Plant
Number 2
Onsite truck ——HHDT
Micro tunneling - Soil Hauled from Plant
2 Offsite for Disposal
————
Micro tunneling - Soil Hauled from Plant
2 Offsite for Disposal
Worker 0.00 18.5 LDA,LDT1,LDT2
Micro tunneling - Soil Hauled from Plant
2 Offsite for Disposal
Vendor —10.2 HHDT,MHDT
Micro tunneling - Soil Hauled from Plant
2 Offsite for Disposal
Hauling 1.14 20.0 HHDT
Micro tunneling - Soil Hauled from Plant
2 Offsite for Disposal
Onsite truck ——HHDT
Micro tunneling - Soil Hauled from Plant
2 back to Project Site for Backfill
————
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LDA,LDT1,LDT218.50.00WorkerMicro tunneling - Soil Hauled from Plant
2 back to Project Site for Backfill
Micro tunneling - Soil Hauled from Plant
2 back to Project Site for Backfill
Vendor —10.2 HHDT,MHDT
Micro tunneling - Soil Hauled from Plant
2 back to Project Site for Backfill
Hauling 11.2 20.0 HHDT
Micro tunneling - Soil Hauled from Plant
2 back to Project Site for Backfill
Onsite truck ——HHDT
Pump Station - Soil Hauling to Plant
Number 2
————
Pump Station - Soil Hauling to Plant
Number 2
Worker 0.00 18.5 LDA,LDT1,LDT2
Pump Station - Soil Hauling to Plant
Number 2
Vendor —10.2 HHDT,MHDT
Pump Station - Soil Hauling to Plant
Number 2
Hauling 10.3 20.0 HHDT
Pump Station - Soil Hauling to Plant
Number 2
Onsite truck ——HHDT
Pump Station - Soil Hauled from Plant
2 Offsite for Disposal
————
Pump Station - Soil Hauled from Plant
2 Offsite for Disposal
Worker 0.00 18.5 LDA,LDT1,LDT2
Pump Station - Soil Hauled from Plant
2 Offsite for Disposal
Vendor —10.2 HHDT,MHDT
Pump Station - Soil Hauled from Plant
2 Offsite for Disposal
Hauling 9.82 20.0 HHDT
Pump Station - Soil Hauled from Plant
2 Offsite for Disposal
Onsite truck ——HHDT
Pump Station - Soil Hauled from Plant
2 back to Project Site for Backfill
————
Pump Station - Soil Hauled from Plant
2 back to Project Site for Backfill
Worker 0.00 18.5 LDA,LDT1,LDT2
Pump Station - Soil Hauled from Plant
2 back to Project Site for Backfill
Vendor —10.2 HHDT,MHDT
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Pump Station - Soil Hauled from Plant
2 back to Project Site for Backfill
Hauling 3.34 20.0 HHDT
Pump Station - Soil Hauled from Plant
2 back to Project Site for Backfill
Onsite truck ——HHDT
Exist. PS Demolition & Odor Control -
Soil Hauling to Plant Number 2
————
Exist. PS Demolition & Odor Control -
Soil Hauling to Plant Number 2
Worker 2.50 18.5 LDA,LDT1,LDT2
Exist. PS Demolition & Odor Control -
Soil Hauling to Plant Number 2
Vendor —10.2 HHDT,MHDT
Exist. PS Demolition & Odor Control -
Soil Hauling to Plant Number 2
Hauling 0.30 20.0 HHDT
Exist. PS Demolition & Odor Control -
Soil Hauling to Plant Number 2
Onsite truck ——HHDT
Exist. PS Demolition & Odor Control -
Soil Hauled from Plant 2 Offsite for
Disposal
————
Exist. PS Demolition & Odor Control -
Soil Hauled from Plant 2 Offsite for
Disposal
Worker 2.50 18.5 LDA,LDT1,LDT2
Exist. PS Demolition & Odor Control -
Soil Hauled from Plant 2 Offsite for
Disposal
Vendor —10.2 HHDT,MHDT
Exist. PS Demolition & Odor Control -
Soil Hauled from Plant 2 Offsite for
Disposal
Hauling 0.30 20.0 HHDT
Exist. PS Demolition & Odor Control -
Soil Hauled from Plant 2 Offsite for
Disposal
Onsite truck ——HHDT
Exist. PS Demolition & Odor Control -
Soil Hauled from Plant 2 back to
Project Site for Backfill
————
Exist. PS Demolition & Odor Control -
Soil Hauled from Plant 2 back to
Project Site for Backfill
Worker 2.50 18.5 LDA,LDT1,LDT2
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Exist. PS Demolition & Odor Control -
Soil Hauled from Plant 2 back to
Project Site for Backfill
Vendor —10.2 HHDT,MHDT
Exist. PS Demolition & Odor Control -
Soil Hauled from Plant 2 back to
Project Site for Backfill
Hauling 0.88 20.0 HHDT
Exist. PS Demolition & Odor Control -
Soil Hauled from Plant 2 back to
Project Site for Backfill
Onsite truck ——HHDT
5.3.2. Mitigated
Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix
Pump Station Earthwork & Below
Grade Concrete Construction
————
Pump Station Earthwork & Below
Grade Concrete Construction
Worker 17.5 18.5 LDA,LDT1,LDT2
Pump Station Earthwork & Below
Grade Concrete Construction
Vendor —10.2 HHDT,MHDT
Pump Station Earthwork & Below
Grade Concrete Construction
Hauling 0.00 20.0 HHDT
Pump Station Earthwork & Below
Grade Concrete Construction
Onsite truck ——HHDT
Force Main Pipeline Trenching East of
Newport Bay
————
Force Main Pipeline Trenching East of
Newport Bay
Worker 22.5 18.5 LDA,LDT1,LDT2
Force Main Pipeline Trenching East of
Newport Bay
Vendor —10.2 HHDT,MHDT
Force Main Pipeline Trenching East of
Newport Bay
Hauling 0.00 20.0 HHDT
Force Main Pipeline Trenching East of
Newport Bay
Onsite truck ——HHDT
Pump Station Demolition ————
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Pump Station Demolition Worker 0.00 18.5 LDA,LDT1,LDT2
Pump Station Demolition Vendor —10.2 HHDT,MHDT
Pump Station Demolition Hauling 0.00 20.0 HHDT
Pump Station Demolition Onsite truck ——HHDT
Pump Station Above Grade Building
Construction including MEP
————
Pump Station Above Grade Building
Construction including MEP
Worker 6.09 18.5 LDA,LDT1,LDT2
Pump Station Above Grade Building
Construction including MEP
Vendor 2.38 10.2 HHDT,MHDT
Pump Station Above Grade Building
Construction including MEP
Hauling 0.00 20.0 HHDT
Pump Station Above Grade Building
Construction including MEP
Onsite truck ——HHDT
Generator and Odor Control Building
Construction
————
Generator and Odor Control Building
Construction
Worker 6.09 18.5 LDA,LDT1,LDT2
Generator and Odor Control Building
Construction
Vendor 2.38 10.2 HHDT,MHDT
Generator and Odor Control Building
Construction
Hauling 0.00 20.0 HHDT
Generator and Odor Control Building
Construction
Onsite truck ——HHDT
Pump Station Architectural Coating ————
Pump Station Architectural Coating Worker 2.44 18.5 LDA,LDT1,LDT2
Pump Station Architectural Coating Vendor —10.2 HHDT,MHDT
Pump Station Architectural Coating Hauling 0.00 20.0 HHDT
Pump Station Architectural Coating Onsite truck ——HHDT
Micro tunneling Only ————
Micro tunneling Only Worker 2.50 18.5 LDA,LDT1,LDT2
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Micro tunneling Only Vendor —10.2 HHDT,MHDT
Micro tunneling Only Hauling 0.00 20.0 HHDT
Micro tunneling Only Onsite truck ——HHDT
Dredging Only ————
Dredging Only Worker 17.5 18.5 LDA,LDT1,LDT2
Dredging Only Vendor —10.2 HHDT,MHDT
Dredging Only Hauling 0.00 20.0 HHDT
Dredging Only Onsite truck ——HHDT
Force Main Pipeline Trenching West of
Newport Bay
————
Force Main Pipeline Trenching West of
Newport Bay
Worker 22.5 18.5 LDA,LDT1,LDT2
Force Main Pipeline Trenching West of
Newport Bay
Vendor —10.2 HHDT,MHDT
Force Main Pipeline Trenching West of
Newport Bay
Hauling 0.00 20.0 HHDT
Force Main Pipeline Trenching West of
Newport Bay
Onsite truck ——HHDT
Temporary Gravity Sewer Trenching ————
Temporary Gravity Sewer Trenching Worker 22.5 18.5 LDA,LDT1,LDT2
Temporary Gravity Sewer Trenching Vendor —10.2 HHDT,MHDT
Temporary Gravity Sewer Trenching Hauling 0.00 20.0 HHDT
Temporary Gravity Sewer Trenching Onsite truck ——HHDT
Permanent Gravity Sewer Trenching ————
Permanent Gravity Sewer Trenching Worker 22.5 18.5 LDA,LDT1,LDT2
Permanent Gravity Sewer Trenching Vendor —10.2 HHDT,MHDT
Permanent Gravity Sewer Trenching Hauling 0.00 20.0 HHDT
Permanent Gravity Sewer Trenching Onsite truck ——HHDT
Micro tunneling - Soil Hauling to Plant
Number 2
————
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Micro tunneling - Soil Hauling to Plant
Number 2
Worker 0.00 18.5 LDA,LDT1,LDT2
Micro tunneling - Soil Hauling to Plant
Number 2
Vendor —10.2 HHDT,MHDT
Micro tunneling - Soil Hauling to Plant
Number 2
Hauling 2.34 20.0 HHDT
Micro tunneling - Soil Hauling to Plant
Number 2
Onsite truck ——HHDT
Micro tunneling - Soil Hauled from Plant
2 Offsite for Disposal
————
Micro tunneling - Soil Hauled from Plant
2 Offsite for Disposal
Worker 0.00 18.5 LDA,LDT1,LDT2
Micro tunneling - Soil Hauled from Plant
2 Offsite for Disposal
Vendor —10.2 HHDT,MHDT
Micro tunneling - Soil Hauled from Plant
2 Offsite for Disposal
Hauling 1.14 20.0 HHDT
Micro tunneling - Soil Hauled from Plant
2 Offsite for Disposal
Onsite truck ——HHDT
Micro tunneling - Soil Hauled from Plant
2 back to Project Site for Backfill
————
Micro tunneling - Soil Hauled from Plant
2 back to Project Site for Backfill
Worker 0.00 18.5 LDA,LDT1,LDT2
Micro tunneling - Soil Hauled from Plant
2 back to Project Site for Backfill
Vendor —10.2 HHDT,MHDT
Micro tunneling - Soil Hauled from Plant
2 back to Project Site for Backfill
Hauling 11.2 20.0 HHDT
Micro tunneling - Soil Hauled from Plant
2 back to Project Site for Backfill
Onsite truck ——HHDT
Pump Station - Soil Hauling to Plant
Number 2
————
Pump Station - Soil Hauling to Plant
Number 2
Worker 0.00 18.5 LDA,LDT1,LDT2
Pump Station - Soil Hauling to Plant
Number 2
Vendor —10.2 HHDT,MHDT
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Pump Station - Soil Hauling to Plant
Number 2
Hauling 10.3 20.0 HHDT
Pump Station - Soil Hauling to Plant
Number 2
Onsite truck ——HHDT
Pump Station - Soil Hauled from Plant
2 Offsite for Disposal
————
Pump Station - Soil Hauled from Plant
2 Offsite for Disposal
Worker 0.00 18.5 LDA,LDT1,LDT2
Pump Station - Soil Hauled from Plant
2 Offsite for Disposal
Vendor —10.2 HHDT,MHDT
Pump Station - Soil Hauled from Plant
2 Offsite for Disposal
Hauling 9.82 20.0 HHDT
Pump Station - Soil Hauled from Plant
2 Offsite for Disposal
Onsite truck ——HHDT
Pump Station - Soil Hauled from Plant
2 back to Project Site for Backfill
————
Pump Station - Soil Hauled from Plant
2 back to Project Site for Backfill
Worker 0.00 18.5 LDA,LDT1,LDT2
Pump Station - Soil Hauled from Plant
2 back to Project Site for Backfill
Vendor —10.2 HHDT,MHDT
Pump Station - Soil Hauled from Plant
2 back to Project Site for Backfill
Hauling 3.34 20.0 HHDT
Pump Station - Soil Hauled from Plant
2 back to Project Site for Backfill
Onsite truck ——HHDT
Exist. PS Demolition & Odor Control -
Soil Hauling to Plant Number 2
————
Exist. PS Demolition & Odor Control -
Soil Hauling to Plant Number 2
Worker 2.50 18.5 LDA,LDT1,LDT2
Exist. PS Demolition & Odor Control -
Soil Hauling to Plant Number 2
Vendor —10.2 HHDT,MHDT
Exist. PS Demolition & Odor Control -
Soil Hauling to Plant Number 2
Hauling 0.30 20.0 HHDT
Exist. PS Demolition & Odor Control -
Soil Hauling to Plant Number 2
Onsite truck ——HHDT
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Exist. PS Demolition & Odor Control -
Soil Hauled from Plant 2 Offsite for
Disposal
————
Exist. PS Demolition & Odor Control -
Soil Hauled from Plant 2 Offsite for
Disposal
Worker 2.50 18.5 LDA,LDT1,LDT2
Exist. PS Demolition & Odor Control -
Soil Hauled from Plant 2 Offsite for
Disposal
Vendor —10.2 HHDT,MHDT
Exist. PS Demolition & Odor Control -
Soil Hauled from Plant 2 Offsite for
Disposal
Hauling 0.30 20.0 HHDT
Exist. PS Demolition & Odor Control -
Soil Hauled from Plant 2 Offsite for
Disposal
Onsite truck ——HHDT
Exist. PS Demolition & Odor Control -
Soil Hauled from Plant 2 back to
Project Site for Backfill
————
Exist. PS Demolition & Odor Control -
Soil Hauled from Plant 2 back to
Project Site for Backfill
Worker 2.50 18.5 LDA,LDT1,LDT2
Exist. PS Demolition & Odor Control -
Soil Hauled from Plant 2 back to
Project Site for Backfill
Vendor —10.2 HHDT,MHDT
Exist. PS Demolition & Odor Control -
Soil Hauled from Plant 2 back to
Project Site for Backfill
Hauling 0.88 20.0 HHDT
Exist. PS Demolition & Odor Control -
Soil Hauled from Plant 2 back to
Project Site for Backfill
Onsite truck ——HHDT
5.4. Vehicles
5.4.1. Construction Vehicle Control Strategies
Non-applicable. No control strategies activated by user.
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5.5. Architectural Coatings
Phase Name Residential Interior Area Coated
(sq ft)
Residential Exterior Area Coated
(sq ft)
Non-Residential Interior Area
Coated (sq ft)
Non-Residential Exterior Area
Coated (sq ft)
Parking Area Coated (sq ft)
Pump Station Architectural
Coating
0.00 0.00 21,750 7,250 960
5.6. Dust Mitigation
5.6.1. Construction Earthmoving Activities
Phase Name Material Imported (Cubic Yards)Material Exported (Cubic Yards)Acres Graded (acres)Material Demolished (Ton of
Debris)
Acres Paved (acres)
Pump Station Demolition 0.00 0.00 0.00 0.00 —
Exist. PS Demolition & Odor
Control - Soil Hauling to Plant
Number 2
0.00 0.00 0.00 125 —
Exist. PS Demolition & Odor
Control - Soil Hauled from Plant
2 Offsite for Disposal
0.00 0.00 0.00 125 —
Pump Station Earthwork &
Below Grade Concrete
Construction
0.00 0.00 0.00 0.00 —
Micro tunneling - Soil Hauling to
Plant Number 2
—4,114 0.00 0.00 —
Micro tunneling - Soil Hauled
from Plant 2 Offsite for Disposal
—1,994 0.00 0.00 —
Micro tunneling - Soil Hauled
from Plant 2 back to Project Site
for Backfill
2,120 0.00 0.00 0.00 —
Pump Station - Soil Hauling to
Plant Number 2
—8,281 0.00 0.00 —
Pump Station - Soil Hauled from
Plant 2 Offsite for Disposal
—7,863 0.00 0.00 —
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Pump Station - Soil Hauled from
Plant 2 back to Project Site for
Backfill
200 —0.00 0.00 —
Exist. PS Demolition & Odor
Control - Soil Hauled from Plant
2 back to Project Site for Backfill
0.00 0.00 0.00 307 —
5.6.2. Construction Earthmoving Control Strategies
Non-applicable. No control strategies activated by user.
5.7. Construction Paving
Land Use Area Paved (acres)% Asphalt
General Light Industry 0.00 0%
Other Asphalt Surfaces 0.37 100%
5.8. Construction Electricity Consumption and Emissions Factors
kWh per Year and Emission Factor (lb/MWh)
Year kWh per Year CO2 CH4 N2O
2025 0.00 532 0.03 < 0.005
2024 0.00 532 0.03 < 0.005
2026 0.00 532 0.03 < 0.005
2027 0.00 532 0.03 < 0.005
2028 0.00 532 0.03 < 0.005
5.9. Operational Mobile Sources
5.9.1. Unmitigated
Land Use Type Trips/Weekday Trips/Saturday Trips/Sunday Trips/Year VMT/Weekday VMT/Saturday VMT/Sunday VMT/Year
Total all Land Uses 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
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5.9.2. Mitigated
Land Use Type Trips/Weekday Trips/Saturday Trips/Sunday Trips/Year VMT/Weekday VMT/Saturday VMT/Sunday VMT/Year
Total all Land Uses 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
5.10. Operational Area Sources
5.10.1. Hearths
5.10.1.1. Unmitigated
5.10.1.2. Mitigated
5.10.2. Architectural Coatings
Residential Interior Area Coated (sq ft)Residential Exterior Area Coated (sq ft)Non-Residential Interior Area Coated
(sq ft)
Non-Residential Exterior Area Coated
(sq ft)
Parking Area Coated (sq ft)
0 0.00 21,750 7,250 960
5.10.3. Landscape Equipment
Season Unit Value
Snow Days day/yr 0.00
Summer Days day/yr 250
5.10.4. Landscape Equipment - Mitigated
Season Unit Value
Snow Days day/yr 0.00
Summer Days day/yr 250
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5.11. Operational Energy Consumption
5.11.1. Unmitigated
Electricity (kWh/yr) and CO2 and CH4 and N2O and Natural Gas (kBTU/yr)
Land Use Electricity (kWh/yr)CO2 CH4 N2O Natural Gas (kBTU/yr)
General Light Industry 139,095 532 0.0330 0.0040 620,628
Other Asphalt Surfaces 0.00 532 0.0330 0.0040 0.00
5.11.2. Mitigated
Electricity (kWh/yr) and CO2 and CH4 and N2O and Natural Gas (kBTU/yr)
Land Use Electricity (kWh/yr)CO2 CH4 N2O Natural Gas (kBTU/yr)
General Light Industry 108,730 532 0.0330 0.0040 594,240
Other Asphalt Surfaces 0.00 532 0.0330 0.0040 0.00
5.12. Operational Water and Wastewater Consumption
5.12.1. Unmitigated
Land Use Indoor Water (gal/year)Outdoor Water (gal/year)
General Light Industry 3,353,125 12,960
Other Asphalt Surfaces 0.00 1.10
5.12.2. Mitigated
Land Use Indoor Water (gal/year)Outdoor Water (gal/year)
General Light Industry 3,353,125 12,960
Other Asphalt Surfaces 0.00 1.10
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5.13. Operational Waste Generation
5.13.1. Unmitigated
Land Use Waste (ton/year)Cogeneration (kWh/year)
General Light Industry 18.0 —
Other Asphalt Surfaces 0.00 —
5.13.2. Mitigated
Land Use Waste (ton/year)Cogeneration (kWh/year)
General Light Industry 8.99 —
Other Asphalt Surfaces 0.00 —
5.14. Operational Refrigeration and Air Conditioning Equipment
5.14.1. Unmitigated
Land Use Type Equipment Type Refrigerant GWP Quantity (kg)Operations Leak Rate Service Leak Rate Times Serviced
General Light Industry Other commercial A/C
and heat pumps
R-410A 2,088 0.30 4.00 4.00 18.0
5.14.2. Mitigated
Land Use Type Equipment Type Refrigerant GWP Quantity (kg)Operations Leak Rate Service Leak Rate Times Serviced
General Light Industry Other commercial A/C
and heat pumps
R-410A 2,088 0.30 4.00 4.00 18.0
5.15. Operational Off-Road Equipment
5.15.1. Unmitigated
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Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor
5.15.2. Mitigated
Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor
5.16. Stationary Sources
5.16.1. Emergency Generators and Fire Pumps
Equipment Type Fuel Type Number per Day Hours per Day Hours per Year Horsepower Load Factor
5.16.2. Process Boilers
Equipment Type Fuel Type Number Boiler Rating (MMBtu/hr)Daily Heat Input (MMBtu/day)Annual Heat Input (MMBtu/yr)
5.17. User Defined
Equipment Type Fuel Type
——
5.18. Vegetation
5.18.1. Land Use Change
5.18.1.1. Unmitigated
Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres
5.18.1.2. Mitigated
Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres
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5.18.1. Biomass Cover Type
5.18.1.1. Unmitigated
Biomass Cover Type Initial Acres Final Acres
5.18.1.2. Mitigated
Biomass Cover Type Initial Acres Final Acres
5.18.2. Sequestration
5.18.2.1. Unmitigated
Tree Type Number Electricity Saved (kWh/year)Natural Gas Saved (btu/year)
5.18.2.2. Mitigated
Tree Type Number Electricity Saved (kWh/year)Natural Gas Saved (btu/year)
6. Climate Risk Detailed Report
6.1. Climate Risk Summary
Cal-Adapt midcentury 2040–2059 average projections for four hazards are reported below for your project location. These are under Representation Concentration Pathway (RCP) 8.5 which assumes GHG
emissions will continue to rise strongly through 2050 and then plateau around 2100.
Climate Hazard Result for Project Location Unit
Temperature and Extreme Heat 8.66 annual days of extreme heat
Extreme Precipitation 3.25 annual days with precipitation above 20 mm
Sea Level Rise 0.00 meters of inundation depth
Wildfire 0.00 annual hectares burned
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Temperature and Extreme Heat data are for grid cell in which your project are located. The projection is based on the 98th historical percentile of daily maximum/minimum temperatures from observed
historical data (32 climate model ensemble from Cal-Adapt, 2040–2059 average under RCP 8.5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.
Extreme Precipitation data are for the grid cell in which your project are located. The threshold of 20 mm is equivalent to about ¾ an inch of rain, which would be light to moderate rainfall if received over a full
day or heavy rain if received over a period of 2 to 4 hours. Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.
Sea Level Rise data are for the grid cell in which your project are located. The projections are from Radke et al. (2017), as reported in Cal-Adapt (2040–2059 average under RCP 8.5), and consider different
increments of sea level rise coupled with extreme storm events. Users may select from four model simulations to view the range in potential inundation depth for the grid cell. The four simulations make
different assumptions about expected rainfall and temperature are: Warmer/drier (HadGEM2-ES), Cooler/wetter (CNRM-CM5), Average conditions (CanESM2), Range of different rainfall and temperature
possibilities (MIROC5). Each grid cell is 50 meters (m) by 50 m, or about 164 feet (ft) by 164 ft.
Wildfire data are for the grid cell in which your project are located. The projections are from UC Davis, as reported in Cal-Adapt (2040–2059 average under RCP 8.5), and consider historical data of climate,
vegetation, population density, and large (> 400 ha) fire history. Users may select from four model simulations to view the range in potential wildfire probabilities for the grid cell. The four simulations make
different assumptions about expected rainfall and temperature are: Warmer/drier (HadGEM2-ES), Cooler/wetter (CNRM-CM5), Average conditions (CanESM2), Range of different rainfall and temperature
possibilities (MIROC5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.
6.2. Initial Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score
Temperature and Extreme Heat 1 0 0 N/A
Extreme Precipitation N/A N/A N/A N/A
Sea Level Rise 1 0 0 N/A
Wildfire 1 0 0 N/A
Flooding N/A N/A N/A N/A
Drought N/A N/A N/A N/A
Snowpack Reduction N/A N/A N/A N/A
Air Quality Degradation 0 0 0 N/A
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest
exposure.
The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5 representing the
greatest ability to adapt.
The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores do not include implementation of climate risk reduction measures.
6.3. Adjusted Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score
Temperature and Extreme Heat 1 1 1 2
Extreme Precipitation N/A N/A N/A N/A
Bay Bridge (with Dredging) Detailed Report, 6/8/2023
189 / 194
Sea Level Rise 1 1 1 2
Wildfire 1 1 1 2
Flooding N/A N/A N/A N/A
Drought N/A N/A N/A N/A
Snowpack Reduction N/A N/A N/A N/A
Air Quality Degradation 1 1 1 2
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest
exposure.
The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5 representing the
greatest ability to adapt.
The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores include implementation of climate risk reduction measures.
6.4. Climate Risk Reduction Measures
7. Health and Equity Details
7.1. CalEnviroScreen 4.0 Scores
The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state.
Indicator Result for Project Census Tract
Exposure Indicators —
AQ-Ozone 51.9
AQ-PM 53.4
AQ-DPM 21.9
Drinking Water 32.3
Lead Risk Housing 27.7
Pesticides 0.00
Toxic Releases 82.9
Traffic 53.1
Effect Indicators —
Bay Bridge (with Dredging) Detailed Report, 6/8/2023
190 / 194
CleanUp Sites 17.1
Groundwater 22.1
Haz Waste Facilities/Generators 22.0
Impaired Water Bodies 77.3
Solid Waste 2.52
Sensitive Population —
Asthma 2.59
Cardio-vascular 0.54
Low Birth Weights 39.9
Socioeconomic Factor Indicators —
Education 3.87
Housing 50.7
Linguistic 13.3
Poverty 14.0
Unemployment 51.3
7.2. Healthy Places Index Scores
The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.
Indicator Result for Project Census Tract
Economic —
Above Poverty 88.70781471
Employed 45.27139741
Median HI 83.11305017
Education —
Bachelor's or higher 92.82689593
High school enrollment 100
Preschool enrollment 20.87771077
Bay Bridge (with Dredging) Detailed Report, 6/8/2023
191 / 194
Transportation —
Auto Access 72.44963429
Active commuting 16.25818042
Social —
2-parent households 66.14910817
Voting 61.02912871
Neighborhood —
Alcohol availability 47.26036186
Park access 81.35506224
Retail density 67.93276017
Supermarket access 57.84678558
Tree canopy 26.26716284
Housing —
Homeownership 40.39522649
Housing habitability 62.49197998
Low-inc homeowner severe housing cost burden 49.21083023
Low-inc renter severe housing cost burden 59.77158989
Uncrowded housing 82.07365584
Health Outcomes —
Insured adults 70.40934172
Arthritis 71.8
Asthma ER Admissions 92.4
High Blood Pressure 71.3
Cancer (excluding skin)17.3
Asthma 83.3
Coronary Heart Disease 74.7
Chronic Obstructive Pulmonary Disease 89.8
Bay Bridge (with Dredging) Detailed Report, 6/8/2023
192 / 194
Diagnosed Diabetes 95.3
Life Expectancy at Birth 88.6
Cognitively Disabled 87.2
Physically Disabled 84.3
Heart Attack ER Admissions 98.1
Mental Health Not Good 92.6
Chronic Kidney Disease 85.5
Obesity 92.8
Pedestrian Injuries 42.0
Physical Health Not Good 95.9
Stroke 84.7
Health Risk Behaviors —
Binge Drinking 3.2
Current Smoker 92.8
No Leisure Time for Physical Activity 97.5
Climate Change Exposures —
Wildfire Risk 0.0
SLR Inundation Area 61.5
Children 92.8
Elderly 46.6
English Speaking 88.0
Foreign-born 9.9
Outdoor Workers 81.8
Climate Change Adaptive Capacity —
Impervious Surface Cover 37.9
Traffic Density 39.9
Traffic Access 23.0
Bay Bridge (with Dredging) Detailed Report, 6/8/2023
193 / 194
Other Indices —
Hardship 9.2
Other Decision Support —
2016 Voting 81.5
7.3. Overall Health & Equity Scores
Metric Result for Project Census Tract
CalEnviroScreen 4.0 Score for Project Location (a)12.0
Healthy Places Index Score for Project Location (b)76.0
Project Located in a Designated Disadvantaged Community (Senate Bill 535)No
Project Located in a Low-Income Community (Assembly Bill 1550)No
Project Located in a Community Air Protection Program Community (Assembly Bill 617)No
a: The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state.
b: The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.
7.4. Health & Equity Measures
No Health & Equity Measures selected.
7.5. Evaluation Scorecard
Health & Equity Evaluation Scorecard not completed.
7.6. Health & Equity Custom Measures
No Health & Equity Custom Measures created.
8. User Changes to Default Data
Screen Justification
Land Use Provided by the applicant
Construction: Construction Phases As provided by the applicant
Construction: Off-Road Equipment Per construction questionnaire. "Other Construction Equipment" = vibratory hammer pile driver
Bay Bridge (with Dredging) Detailed Report, 6/8/2023
194 / 194
Construction: Dust From Material Movement As per the information provided by the applicant.
Construction: Trips and VMT As per the information provided by the applicant.
Construction: Architectural Coatings As per SCAQMD Rule 1113.
Operations: Architectural Coatings As per SCAQMD Rule 1113
Bay Bridge Pump Station and
Force Mains Replacement Project
(Project No. 5-67)
ENVIRONMENTAL IMPACT REPORT
FINAL | JANUARY 2021
FINAL ENVIRONMENTAL IMPACT REPORT
Bay Bridge Pump Station and
Force Mains Replacement Project
State Clearinghouse No. 2016111031
Lead Agency:
ORANGE COUNTY SANITATION DISTRICT
10844 Ellis Avenue
Fountain Valley, California 92708 Contact: Mr. Kevin Hadden
Principal Staff Analyst 714.962.2411
Prepared by:
MICHAEL BAKER INTERNATIONAL 5 Hutton Centre Drive, Suite 500
Santa Ana, California 92707 Contact: Ms. Kristen Bogue
949.472.3505
January 2021
JN 168975
This document is designed for double-sided printing to conserve natural resources.
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 i Table of Contents
TABLE OF CONTENTS
Section 1.0: Introduction ........................................................................................................................ 1-1
Section 2.0: Responses to Comments ................................................................................................... 2-1
Section 3.0: Errata .................................................................................................................................... 3-1
Section 4.0: Mitigation Monitoring and Reporting Program ............................................................. 4-1
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 ii Table of Contents
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1.0 INTRODUCTION
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Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 1-1 Introduction
1.0 INTRODUCTION
In June 2017, the Orange County Sanitation District (OCSD), as the California Environmental Quality Act (CEQA) Lead Agency (defined herein pursuant to CEQA Guidelines Section 15367), considered
a project proposing an upgrade to the existing pump station/force main infrastructure in the Bay Bridge Pump Station and Force Mains Replacement Project Draft Environmental Impact Report (2017 Bay Bridge EIR)
(State Clearinghouse No. 2016111031). The 2017 Bay Bridge EIR analyzed a version of the project involving the demolition of the existing facility, construction of a new and larger facility adjacent to
Bayside Drive, and installation of force main improvements beneath the Newport Bay Channel north of Bay Bridge. The 2017 Bay Bridge EIR was circulated for public review from June 21, 2017 through
August 4, 2017. OCSD received 14 comment letters during the public review period and a Final EIR was prepared, which included responses to comments, revisions to the 2017 Bay Bridge EIR, and a
mitigation monitoring and reporting program. However, the Final EIR was not certified due to conflicts with the planned development of the adjacent Back Bay Landing Project.
Since then, OCSD has been in negotiations with the City of Newport Beach and adjacent property
owner (Bayside Village Marina, LLC) to identify potential site plan alternatives to the project analyzed in the 2017 Bay Bridge EIR. As a result, the 2019 Recirculated EIR was prepared, dated July 2019.
The 2019 Recirculated EIR analyzed three conceptual site plans with two different construction methods. The 2019 Recirculated EIR was circulated for public review from July 3, 2019 through
August 16, 2019. OCSD received 11 comment letters during the public review period. However, OCSD did not publish the Final EIR or approve the project at that time.
Upon further project evaluation by OCSD and negotiations with Bayside Village Marina, LLC, OCSD
selected one conceptual site plan and one construction method to be analyzed under CEQA. A Recirculated Draft Environmental Impact Report (2020 Recirculated Draft EIR) analyzing the revised
project was prepared and distributed to responsible and trustee agencies, interested groups, and organizations. The 2020 Recirculated Draft EIR was made available for a 45-day public review period.
The public review period for the 2020 Recirculated Draft EIR, established by the California Environmental Quality Act Guidelines (CEQA Guidelines) Section 15105, commenced on August 7, 2020
and closed on September 21, 2020. In accordance with CEQA Guidelines Section 15088, OCSD, as the Lead Agency, has evaluated the comments received on the 2020 Recirculated Draft EIR.
The Final EIR consists of the following components:
• Section 1.0 – Introduction;
• Section 2.0 – Responses to Comments;
• Section 3.0 – Errata; and
• Section 4.0 – Mitigation Monitoring and Reporting Program.
Due to its length, the text of the 2020 Recirculated Draft EIR is not included in this Final EIR document; however, it is included by reference in this Final EIR. As explained in detail in this Final
EIR, none of the corrections or clarifications of the 2020 Recirculated Draft EIR identified in this document constitute “significant new information” pursuant to Section 15088.5 of the CEQA
Guidelines. As a result, recirculation of the 2020 Recirculated Draft EIR is not required.
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 1-2 Introduction
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2.0 RESPONSES TO COMMENTS
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Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 2-1 Responses to Comments
2.0 RESPONSES TO COMMENTS
2.1 CEQA REQUIREMENTS
Before approving a project, CEQA requires the Lead Agency to prepare and certify a Final
Environmental Impact Report (Final EIR).
In accordance with CEQA Guidelines Sections 15120 through 15132 and Section 15163, the Orange
County Sanitation District (OCSD), as the Lead Agency, prepared a 2020 Recirculated Draft
Environmental Impact Report (2020 Recirculated Draft EIR) for the Bay Bridge Pump Station and
Force Mains Replacement Project (State Clearinghouse No. 2016111031). This document includes all
components required by CEQA Guidelines Section 15120. The Responses to Comments, combined
with the Errata and Mitigation Monitoring and Reporting Program, comprise the Final EIR.
2.2 PUBLIC REVIEW PROCESS – DRAFT EIR
The 2020 Recirculated Draft EIR was circulated for review and comment to the public, agencies, and
organizations. The 2020 Recirculated Draft EIR was also circulated to State agencies for review through the State Clearinghouse, Office of Planning and Research. The 45-day public review period
ran from August 7, 2020 to September 21, 2020. Comments regarding the 2020 Recirculated Draft EIR, received in writing during this period, from the public, local, and State agencies have been
incorporated into this section. It should be noted that OCSD recirculated the entire Draft EIR and required reviewers to submit new
comments on the 2020 Recirculated Draft EIR, pursuant to CEQA Guidelines Section 15088.5(f)(1). As provided by CEQA Guidelines Section 15088.5(f)(1), OCSD is not required to respond to those
comments received during the earlier circulation period for the Bay Bridge Pump Station and Force Mains Replacement Project Draft Environmental Impact Report (2017 Bay Bridge EIR) or Bay Bridge Pump Station and
Force Mains Replacement Project Draft Recirculated Environmental Impact Report (2019 Recirculated EIR). Although the prior comments are part of the administrative record, the previous comments do not
require a written response in this Final EIR. Notwithstanding, it is acknowledged that the 2020 Recirculated Draft EIR was revised to address concerns raised during the public review period of the
2019 Recirculated EIR and also reflects concerns raised during the public review period of the 2017 Bay Bridge EIR. Further, where previous comment letters were resubmitted/attached and
commented on as part of the 2020 Recirculated Draft EIR public review period, these comments have been responded to accordingly in the subsequent sections herein (Response to Comments A4-10, O4-
1, and O4-7 below).
2.3 FINAL EIR
The Final EIR allows the public and OCSD (as the CEQA Lead Agency) an opportunity to review
revisions to the 2020 Recirculated Draft EIR, the responses to comments, and other components of
the EIR, such as the Mitigation Monitoring and Reporting Program, before project approval. The
Final EIR serves as the environmental document to support a decision by the Lead Agency (in this
case, OCSD) on whether to approve a proposed project.
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 2-2 Responses to Comments
After completing the Final EIR, and before approving the project, the Lead Agency must make the
following three certifications as required by CEQA Guidelines Section 15090:
• That the Final EIR has been completed in compliance with CEQA;
• That the Final EIR was presented to the decision-making body of the Lead Agency, and that
the decision-making body reviewed and considered the information in the Final EIR prior to
approving the project; and
• That the Final EIR reflects the Lead Agency’s independent judgment and analysis.
These certifications and the Findings of Fact, are included in a separate Findings document. Both the Final EIR and the Findings of Fact will be considered by OCSD’s decision-making body.
2.4 WRITTEN COMMENT LETTERS
AND RESPONSES
All written correspondence from those agencies or individuals commenting on the 2020 Recirculated Draft EIR is provided on the following pages. The individual comments on each letter have been
consecutively numbered for ease of reference. Following each comment letter are responses to each numbered comment. A response is provided for each comment raising substantive environmental
issues. (See, e.g., Citizens for East Shore Parks v. State Lands Com. (2011) 202 Cal.App.4th 549, 568, as modified on denial of reh'g (Jan. 27, 2012) [ “ ‘[A] lead agency need not respond to each comment
made during the review process, however, it must specifically respond to the most significant environmental questions presented....’ ”].)
Responses to comments need not be exhaustive; they need only demonstrate a “good faith, reasoned
analysis.” (Eureka Citizens for Responsible Government v. City of Eureka (2007) 147 Cal.App.4th 357, 378, as modified (Feb. 1, 2007).) The sufficiency of the lead agency's responses to comments on the draft
EIR turns upon the detail required in the responses, and where a general comment is made, a general response is sufficient. (Eureka Citizens for Responsible Government v. City of Eureka (2007) 147 Cal.App.4th
357, 378, as modified (Feb. 1, 2007).) Satisfactory responses to comments may also be provided by reference to the EIR itself. (Eureka Citizens for Responsible Government v. City of Eureka (2007) 147
Cal.App.4th 357, 378, as modified (Feb. 1, 2007).)
Absolute perfection is not required; what is required is the production of information sufficient to permit a reasonable choice of alternatives so far as environmental aspects are concerned. It is only
required that the officials and agencies make an objective, good-faith effort to comply. (Foundation for San Francisco's Architectural Heritage v. City and County of San Francisco (1980) 106 Cal.App.3d 893, 910.)
“CEQA does not require a lead agency to conduct every test or perform all research, study, and experimentation recommended or demanded by commentors.” (CEQA Guidelines Section 15204(a).)
A reviewing court does not decide whether the City acted wisely or unwisely, but simply determines “whether the EIR contained sufficient information about a proposed project, the site and surrounding
area and the projected environmental impacts arising as a result of the proposed project or activity to allow for an informed decision.” (Eureka Citizens for Responsible Government v. City of Eureka (2007) 147
Cal.App.4th 357, 378, as modified (Feb. 1, 2007).)
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 2-3 Responses to Comments
Changes to the 2020 Recirculated Draft EIR text may be required in response to the comment letters
received. Added or modified text is shown in double-underline, while deleted text is shown in strike
out; refer to Section 3.0, Errata, for a compilation of changes to the 2020 Recirculated Draft EIR.
COMMENT LETTERS
A total of 14 comment letters were received by OCSD, as outlined below.
Agencies
A1. State Clearinghouse, State of California Governor’s Office of Planning and Research, CEQAnet Database Summary, October 12, 2020.
A2. Scott Shelley, Branch Chief, Regional-IGR-Transit Planning, State of California Department
of Transportation, District 12, September 9, 2020.
A3. Lijin Sun, J.D. Program Supervisor, CEQA IGR, Planning, Rule Development and Area Sources, South Coast Air Quality Management District, September 17, 2020.
A4. Erinn Wilson-Olgin, Environmental Program Manager, South Coast Region, California
Department of Fish and Wildlife, September 17, 2020.
A5. Richard Vuong, Interim Deputy Director, OC Public Works Service Area/OC Development Services, September 21, 2020.
A6. Jaime Murillo, Principal Planner, City of Newport Beach, September 21, 2020.
Tribes
T1. Brandy Salas, Admin Specialist, Gabrieleno Band of Mission Indians – Kizh Nation, August
25, 2020.
Organizations
O1. Patricia Martz, PhD, President, California Cultural Resource Preservation Alliance, Inc., September 4, 2020.
O2. Jim Jordan, President, Linda Isle Community Association, September 16, 2020.
O3. Jack Teal, President, Bayshores Community Association, September 21, 2020.
O4. John P. Erskine, Nossaman LLP, September 21, 2020.
O5. Jeffrey S. Davis, Irvine Company, September 21, 2020.
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 2-4 Responses to Comments
Individual Persons
I1. Margo O’Connor, Resident, September 8, 2020.
I2. Leann and David Benvenuti, Resident, September 21, 2020.
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 2-8 Responses to Comments
RESPONSE TO COMMENT LETTER A1
State Clearinghouse
State of California Governor’s Office of Planning and Research
October 12, 2020
A1-1 This comment includes copy of the online State Clearinghouse CEQAnet database summary
for the project (SCH No. 2016111031). The summary acknowledges that public review started
on August 7, 2020 and ended on September 21, 2020. During the public review period, two
State agency letters were received by the Office of Planning and Research (OPR) by the
California Department of Transportation (Caltrans) and the California Department of Fish
and Wildlife (CDFW). Refer to Comment Letters A2 and A4, respectively.
COMMENT LETTER A2
A2-1
A2-2
A2-3
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 2-11 Responses to Comments
RESPONSE TO COMMENT LETTER A2
Scott Shelley, Branch Chief, Regional-IGR-Transit Planning
State of California Department of Transportation District 12
September 9, 2020
A2-1 The commenter includes an introductory statement with a brief project description. The
commenter goes on to state that the project is required to coordinate with Traffic Operations
Northwest during the design phase and requests submittal of the Traffic Management Plan,
Construction Staging, Traffic Handling Plan and Lane Closure Chart for review and comment
and evaluation on these activities on California Department of Transportation (Caltrans) right-
of-way.
As stated in the 2020 Recirculated Draft EIR, OCSD will comply with all Caltrans
requirements related to construction activities affecting Caltrans right-of-way, including
requirements during the design and construction phases. Specifically, on 2020 Recirculated
Draft EIR page 5.11-7, Mitigation Measure TRA-1 requires that, prior to initiation of
construction activities, engineering drawings and specifications, and/or contractor shop
drawings shall be prepared by the Project Engineer, or designee, and submitted for review and
approval by the Orange County Sanitation District, Caltrans, and the City of Newport Beach
Public Works Department. This includes detailed information involving proposed traffic
management/handling, construction staging, and lane closures during construction. As a
result, the action requested in this comment is already required by Mitigation Measure TRA-
1.
A2-2 Refer to Response to Comment A2-1.
A2-3 The commenter states that any work proposed within Caltrans right-of-way requires an
Encroachment Permit and that all environmental documentation for the project is required to
meet Caltrans requirements before approval of the Encroachment Permit. The commenter
also provides a link to Caltrans’ Encroachment Permits Manual for more details. The
commenter concludes the letter by requesting continued coordination with Caltrans for future
developments that could impact State transportation facilities and provides contact
information for questions.
OCSD will adhere to the applicable Caltrans Encroachment Permit approval requirements as
necessary. As stated in 2020 Recirculated Draft EIR page 3-16, the proposed project would
be required to obtain a Caltrans encroachment permit. This comment does not specifically
address significant environmental issues. No further response is necessary.
SENT VIA E-MAIL: September 17, 2020
CEQA@ocsd.com
Kevin Hadden, Principal Staff Analyst
Orange County Sanitation District
10844 Ellis Avenue
Fountain Valley, CA 92708
Recirculated Draft Environmental Impact Report (Draft EIR) for the Proposed
Bay Bridge Pump Station and Force Mains Replacement Project (SCH No.: 2016111031)
South Coast Air Quality Management District (South Coast AQMD) staff appreciates the
opportunity to comment on the above-mentioned document. The following comments include
recommended air quality mitigation measures that the Lead Agency should include the Final
EIR.
The Lead Agency is proposing to demolish an existing 4,800-square-foot pump station facility
and construct a new 14,500-square-foot pump station facility with an adjacent 1,300-square-foot
odor control facility and a 760-square-foot backup generator facility (Proposed Project). The
Proposed Project also includes installing force main and gravity sewer improvements. The
Proposed Project is located northwest corner of North Bayside Drive and East Coast Highway at
300 East Coast Highway within the City of Newport Beach. Construction of the Proposed
Project is anticipated to occur over a 36-month period, from 2023 through 20261. Once
operational, the Proposed Project will include operations of an odor control scrubber system and
emergency backup generator2. Upon review of Table 5.2-2: Sensitive Receptors in the
Recirculated Draft EIR, South Coast AQMD staff found that the closest residential sensitive
receptors are located 25 feet south of the Proposed Project3 .
In the Air Quality Analysis Section of the Recirculated Draft EIR, the Lead Agency quantified
the Proposed construction emissions and compared those emissions to South Coast
thresholds. Based
on the analyses, the Lead Agency found that t
construction air quality impacts would be less than significant4. The Lead Agency also found that
the Proposed Project would not result in net new mobile or stationary source emissions during
operation and that operational air quality impacts would be less than significant5. No mitigation
measures for construction or operation of the Proposed Project were included6. In the
1 Draft EIR. Section 5.2 Air Quality. Page 17; Appendix 11.2 Air Quality/Greenhouse Gas Emissions/Energy Data.
2 Draft EIR. Chapter 3 Project Description. Pages 8 to 12.
3 Draft EIR. Section 5.2 Air Quality. Page 6.
4 Ibid. Pages 13 to 17, 19 to 21.
5 Ibid. Page 18.
6 Ibid. Pages 13 to 25.
COMMENT LETTER A3
A3-1
Kevin Hadden September 17, 2020
2
Recirculated Draft EIR, the Lead Agency discussed applicable South Coast AQMD Rules7 402
Nuisance8, 403 Fugitive Dust9, and 1403- Asbestos Emissions from Demolition/Renovation
Activities10.
South Coast AQMD Rules and Permits
In addition to South Coast AQMD Rules 402, 403, and 1403, the Proposed Project may be
subject to the requirements of the following South Coast AQMD rules and regulations, which
should be discussed in the Final EIR to demonstrate that the Proposed Project will comply with
website at: https://www.aqmd.gov/home/rules-compliance/rules/scaqmd-rule-book.
Rule 1166 Volatile Organic Compound Emissions from Decontamination of Soil
Regulation 13 New Source Review
Rule 1401 New Source Review of Toxic Air Contaminants
In the Recirculated Draft EIR, the Lead Agency identified South Coast AQMD as a Responsible
Agency for the Proposed Project since implementation will require permits from South Coast
AQMD11. It is important to note that the assumptions in the air quality analysis in the Final EIR
will be used as the basis for evaluating the permits under CEQA and imposing permit conditions
ngineering and
Permitting staff at (909) 396-3385. Since the Proposed Project will include the operation of an
odor control scrubber system and a backup generator, the Proposed Project will be required to
submit complete and timely permit applications to South Coast AQMD for the following
equipment:
Applications for Permit to Construct and Permit to Operate will be required for the
proposed odor control scrubber system.
Applications for Permit to Construct and Permit to Operate will be required for any
chemical storage tanks not exempted by Rule 219.
Applications for Permit to Construct and Permit to Operate will be required for engines
powering the pumps at the pump station, if the engines are rated above 50 brake
horsepower (BHP).
Applications for Permit to Construct and Permit to Operate will be required for engines
powering the back-up electrical generator at the pump station, if the engine is rated above
50 BHP.
7 Draft EIR. Section 5.2 Air Quality. Pages 15, 17.
8 South Coast AQMD Rule 402 Nuisance. Accessed at: http://www.aqmd.gov/docs/default-source/rule-book/rule-iv/rule-
402.pdf
9 South Coast AQMD Rule 403 Fugitive Dust. Accessed at: http://www.aqmd.gov/docs/default-source/rule-book/rule-iv/rule-
403.pdf
10 South Coast AQMD Rule 1403 Asbestos Emissions from Demolition/Renovation Activities. Accessed at:
http://www.aqmd.gov/docs/default-source/rule-book/reg-xiv/rule-1403.pdf
11 Draft EIR. Chapter 2 Introduction and Purpose. Pages 6 to 7.
A3-1
cont'd
A3-2
A3-3
Kevin Hadden September 17, 2020
3
Conclusion
Pursuant to California Public Resources Code Section 21092.5(a) and CEQA Guidelines Section
15088(b), South Coast AQMD staff requests that the Lead Agency provide South Coast AQMD
staff with written responses to all comments contained herein prior to the certification of the
Final EIR. In addition, issues raised in the comments should be addressed in detail giving
reasons why specific comments and suggestions are not accepted. There should be good faith,
reasoned analysis in response. Conclusory statements unsupported by factual information will
not suffice (CEQA Guidelines Section 15088(c)). Conclusory statements do not facilitate the
purpose and goal of CEQA on public disclosure and are not meaningful, informative, or useful to
decision makers and to the public who are interested in the Proposed Project.
South Coast AQMD staff is available to work with the Lead Agency to address any air quality
questions that may arise from this comment letter. Please contact Alina Mullins, Air Quality
Specialist, at amullins@aqmd.gov if you have questions or wish to discuss the comments.
Sincerely,
Lijin Sun
Lijin Sun, J.D.
Program Supervisor, CEQA IGR
Planning, Rule Development & Area Sources
LS:AM/AS
ORC200811-03
Control Number
A3-4
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 2-15 Responses to Comments
RESPONSE TO COMMENT LETTER A3
Lijin Sun, J.D. Program Supervisor, CEQA IGR, Planning, Rule Development and Area Sources
South Coast Air Quality Management District
September 17, 2020
A3-1 This comment provides background information regarding the South Coast Air Quality
Management District (SCAQMD) and provides a general summary of the proposed project
and the 2020 Recirculated Draft EIR’s air quality analysis. As acknowledged in the letter,
SCAQMD Rule 402 – Nuisance and Rule 403 – Fugitive Dust were discussed under Impact
Statement AQ-1 of the 2020 Recirculated Draft EIR (page 5.2-15) while Rule 1403 – Asbestos
Emissions from Demolition/Renovation Activities, was discussed under Impact Statement HAZ-1 of
the 2020 Recirculated Draft EIR (page 5.7-13). This comment does not identify a specific
issue or comment specifically related to the 2020 Recirculated Draft EIR’s environmental
analysis. The commenter also lists applicable SCAQMD Rules. Responses to specific
comments are provided below.
A3-2 The commenter discusses additional SCAQMD Rules that the proposed project may be
subject to, including Rule 1166 – Volatile Organic Compound Emissions from Decontamination of Soil;
Regulation 13 – New Source Review; and Rule 1401 – New Source Review of Toxic Air Contaminants.
The commenter also provides a link to SCAQMD’s website for more details on each of the
rules and/or regulations.
Rule 1166 governs the emission of volatile organic compounds (VOCs) from excavating,
grading, handling, and treating VOC-contaminated soil as a result of leakage from storage or
transfer operations, accidental spillage, or other deposition. The requirements for excavating
an UST, transfer pipe, or VOC-contaminated soils include operating pursuant to an approved
mitigation plan, notification, VOC monitoring, and procedure for handling and transporting
contaminated soils.
As stated under Impact Statement HAZ-1 of the 2020 Recirculated Draft EIR (page 5.7-21),
no known soil contamination has been reported within the project site, with the exception of
soils present in the Newport Bay Channel bottom that have potentially elevated levels of
DDT/DDE pesticide contamination (not classified as VOCs). Further, no evidence of the
presence of USTs on the project site was found. As discussed on 2020 Recirculated Draft
EIR page 5.7-3, one UST is located at 301 Coast Highway (a Mobil gasoline service station)
not 301 East Coast Highway. As such, this UST was determined to be located off-site.
Nonetheless, the 2020 Recirculated Draft EIR acknowledged that implementation of
recommended Mitigation Measures HAZ-3 and HAZ-4 would minimize potential impacts in
this regard by requiring a soil management plan and establishing procedures if potentially
contaminated wastes are discovered during project construction. In addition, the project
would be required to comply with all applicable Federal, State, and local standards and
regulations, which may include SCAQMD Rule 1166, in order to reduce the potential for a
hazardous materials incident.
SCAQMD Regulation 13 (Rules 1300 – 1325) establishes pre-construction review
requirements for the installation or modification of a source facility (i.e., power plant, engine,
equipment) which may cause the issuance of nonattainment air contaminant, ozone-depleting
compounds (ODCs), or ammonia. Similarly, Rule 1401 governs any new, modified, or
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 2-16 Responses to Comments
relocation of permit units (article, machine, equipment, or facility) that emit toxic air
contaminants. The rule establishes allowable risks (maximum individual cancer risk, cancer
burden, and noncancer acute and chronic hazard index) from operating permit units.
As stated in Section 5.2, Air Quality, of the 2020 Recirculated Draft EIR, the project would be
required to comply with all applicable SCAQMD rules and regulations, as well as National
Emission Standards for Hazardous Air Pollutants (NESHAP) standards found in the Code of
Federal Regulations (CFR) Title 40, Part 61, Subpart M. These regulations call for the
maintenance of construction equipment, the use of non-polluting and non-toxic building
equipment, and minimizing fugitive dust during construction activities. Further, all pumps
(with the same capacity as the existing pumps) and generators associated with the project
would be electrically-powered, and would not directly generate air emissions.
In addition, the proposed project would replace an existing emergency backup generator with
a new 750-kilowatt diesel backup generator allowing the pump station to run on backup power
for approximately 24 hours of operational redundancy. As the backup generator would be
installed on-site permanently, OCSD would be required to obtain the applicable permits from
SCAQMD for operation of such equipment. Overall, the project would be required to comply
with all applicable regulations and standards, including the additional SCAQMD Rules
discussed herein.
A3-3 The commenter notes that SCAQMD has been identified as a Responsible Agency for the
proposed project as implementation of the project will require permits from SCAQMD (2020
Recirculated Draft EIR page 2-7). It is noted that the air quality analysis in the 2020
Recirculated Draft EIR will be used as the basis for evaluating the permits under CEQA as
well as imposing permit conditions and limits. The commenter directs questions on permits
to appropriate staff. The commenter also provides a summary of all permits required for
operation of an odor control scrubber system and a backup generator as currently proposed
for the project. OCSD will comply with the applicable SCAQMD permit requirements.
Nonetheless, a clarification has been made to Section 3.6, Permits and Approvals of the 2020
Recirculated Draft EIR (page 3-16).
Section 3.6, Page 3-16, Last Paragraph
The applicable agency approvals and related environmental review/consultation
requirements associated with the proposed project may include the following, among
others. It is not anticipated that any other agencies would require use of the EIR in their
decision making process.
• CEQA Clearance – OCSD;
• Site Development Review Permit – City of Newport Beach;
• Limited Term Permit – City of Newport Beach;
• Encroachment Permits – City of Newport Beach and Caltrans;
• Permanent/Temporary Easements – City of Newport Beach, Bayside Village
Marina, LLC, The Irvine Company, and Bay Shores Community Association;
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 2-17 Responses to Comments
• Traffic Control Plan Approval – City of Newport Beach and Caltrans;
• Coastal Development Permit – California Coastal Commission and City of Newport
Beach (as required under the California Coastal Act, Public Resources Code
Division 20);
• California State Lands Commission – Consultation with the County of Orange regarding implementation of Newport Bay Channel force main crossing through
tidelands and submerged lands;
• California Department of Fish and Wildlife – Consultation regarding implementation of Newport Bay Channel force main crossing;
• National Marine Fisheries Service – Dry dredging/shoring construction activities;
• Section 404 Permit – Army Corps of Engineers (required for dry dredging/shoring construction activities);
• Section 401 Permit – Santa Ana Regional Water Quality Control Board (required
for dry dredging/shoring construction activities);
• Permit R8-2015-0004 – Santa Ana Regional Water Quality Control Board; and
• General Construction Permit – Santa Ana Regional Water Quality Control Board
(as required under National Pollutant Discharge Elimination System [NPDES] General Permit for Storm Water Discharges Associated with Construction and
Land Disturbance Activities (Order No. 2009-0009-DWQ [as amended by 2010-0014-DWQ and 2012-006-DWQ], NPDES Number CAS000002). ; and
• Permit to Construct (P/C) and Permit to Operate (P/O) – South Coast Air Quality Management District
These changes provide a minor update, correction, or clarification and do not represent “significant new information” as defined in CEQA Guidelines Section 15088.5.
A3-4 The commenter requests written responses to all comments contained in this letter prior to
certification of the Final EIR. The commenter states that all issues raised in this comment letter shall be addressed in detail with reasoned analysis with no conclusory statements
unsupported by factual information. The commenter concludes the letter by providing staff contact information for questions. This comment is acknowledged; it does not raise a
significant environmental issue. As such, no further response is necessary.
State of California Natural Resources Agency GAVIN NEWSOM, Governor
DEPARTMENT OF FISH AND WILDLIFE CHARLTON H. BONHAM, Director
South Coast Region
3883 Ruffin Rd.
San Diego, CA 92123
www.wildlife.ca.gov
September 17, 2020
Kevin Hadden
Orange County Sanitation District
10844 Ellis Avenue
Fountain Valley, CA 92708
Dear Mr. Hadden:
Bay Bridge Pump Station and Force Mains Replacement Project (PROJECT)
RECIRCULATED ENVIRONMENTAL IMPACT REPORT (REIR)
SCH# 2016111031
The California Department of Fish and Wildlife (CDFW) received a Notice of Availability of a REIR
from Orange County Sanitation District (OCSD) for the Project pursuant the California
Environmental Quality Act (CEQA) and CEQA Guidelines.1 CDFW previously submitted comments
in response to the Notice of Availability of a Draft Recirculated EIR.
Thank you for the opportunity to provide comments and recommendations regarding those
activities involved in the Project that may affect California fish and wildlife. Likewise, we appreciate
the opportunity to provide comments regarding those aspects of the Project that CDFW, by law,
may be required to carry out or approve through the exercise of its own regulatory authority under
the Fish and Game Code.
CDFW ROLE
Trustee Agency for fish and wildlife resources and holds those resources in
trust by statute for all the people of the State. (Fish & G. Code, §§ 711.7, subd. (a) & 1802; Pub.
Resources Code, § 21070; CEQA Guidelines § 15386, subd. (a).) CDFW, in its trustee capacity,
has jurisdiction over the conservation, protection, and management of fish, wildlife, native plants,
and habitat necessary for biologically sustainable populations of those species. (Id., § 1802.)
Similarly, for purposes of CEQA, CDFW is charged by law to provide, as available, biological
expertise during public agency environmental review efforts, focusing specifically on Projects and
related activities that have the potential to adversely affect fish and wildlife resources.
CDFW is also submitting comments as a Responsible Agency under CEQA. (Pub. Resources
Code, § 21069; CEQA Guidelines, § 15381.) CDFW expects that it may need to exercise
regulatory authority as provided by the Fish and Game Code. As proposed, for example, the
Project regulatory authority. (Fish & G.
Code, § 1600 et seq.) Likewise, to the extent implementation of the Project as proposed may result
Species Act (CESA) (Fish & G. Code, § 2050 et seq.), the Project proponent may seek related take
authorization as provided by the Fish and Game Code.
PROJECT DESCRIPTION SUMMARY
Proponent: Orange County Sanitation District (OCSD)
Objective: The objective of the Project is to replace the existing Bay Bridge Pump Station and
associated force mains to bring the pump station facility and force mains to current design and
reliability standards. The proposed Project involves demolishing the existing pump station building
and constructing new pump station facilities including a pump station, generator, and odor control
facilities within and adjacent to the existing facility. The Project will abandon existing force mains
and install new force mains across the Newport Bay Channel south of Bay Bridge.
The draft EIR which analyzed the original Project; (Michael Baker International 2017) was not
certified due to conflicts with the planned development of the Back Bay Landing Project. Following
negotiations and consideration of site plan alternatives, the Bay Bridge Pump Station and Force
Mains Replacement Project Draft Recirculated Environmental Impact Report (2019) analyzed three
conceptual site plans. In response to comments received during the public review period for the
2019 document, OCSD selected one conceptual site plan and one construction method to analyze
in the 2020 Recirculated EIR. The concept originally labeled the,
renamed the, Project analyzed in the 2020 REIR.
1 CEQA is codified in the California Public Resources Code in section 21000 et seq
are found in Title 14 of the California Code of Regulations, commencing with section 15000.
COMMENT LETTER A4
A4-1
Mr. Kevin Hadden
Orange County Sanitation District
September 17, 2020
Page 2
Per the REIR, development of the Adjacent Pump Station would involve expanding the existing
pump station facility site approximately 100 feet to the west, constructing a new pump station
building, and installing force main improvements across the Newport Bay Channel south of Bay
Bridge. The Adjacent Pump Station would connect to the existing OCSD force main system to the
west by installing 1,500 LF of
Channel south of Bay Bridge. The REIR indicates that the Project will either microtunnel or open
trench cut under East Coast Highway toward the southside of the bridge, where the Project as
proposed will then open trench dredge under Newport Bay Channel to install the force mains.
Location: The Project is located within the southwestern portion of the City of Newport Beach,
within the County of Orange, California. The Project site is located at 300 East Coast Highway and
is developed with an OCSD sewer pump station, associated improvements, and a recreational
vehicle storage area. The Project site also includes sewer force main improvements that extend
from the existing pump station westerly beneath the Newport Bay Channel (south of Bay Bridge) to
connect an existing OCSD force main system and pipeline on the west side of Bay Bridge.
Biological Setting: Pump station improvements and portions of the force main improvements
outside of the Newport Bay Channel would occur primarily in developed paved areas or areas with
ornamental landscaping. No special-status plant species have been observed at the Project site
due to the developed nature of the terrestrial portions of the Project site and lack of suitable
habitat. An on-site terrestrial survey conducted on March 18, 2019 detected 18 common terrestrial
wildlife species. No special-status wildlife species were observed on site.
The Project site contains suitable habitat to support a variety of nesting bird species. The Marine
Resources Study Table 1 presented in the REIR identifies multiple sensitive bird species with the
potential to occur in the Project area, including California brown pelican (Pelecanus occidentalis
californicus; CDFW Fully Protected Species), osprey (Pandion haliaetus; CDFW Watch List),
American peregrine falcon (Falco peregrinus anatum; CDFW Fully Protected Species), California
least tern (Sterna antillarum browni; California Endangered Species Act (CESA)-listed Endangered
and Endangered Species Act (ESA)-listed Endangered, CDFW Fully Protected Species), and light-
Rallus obsoletus levipes; CESA-listed Endangered and ESA-listed
Endangered, CDFW Fully Protected Species).
Upper and Lower Newport Bay is an estuary and supports not only extensive eelgrass beds, but
also rare coastal lagoon habitats and wetlands; these wetland habitats are found within the Upper
Newport Bay State Marine Conservation Area (SMCA) which are protected under the State Marine
Life Protection Act. SMCAs protect tidal lands, wetlands up to the mean high tide line, fish and fish
habitat for many fish species that are both state and federally managed from the bay bridge to the
San Diego Creek Channel. The Project area is surrounded by sensitive areas to the north and
south of the highway bridge including eelgrass beds (Zostera marina and/or Zostera pacifica) and
shallow estuarine waters/wetland, which are essential foraging habitats for multiple species. Green
sea turtles (Chelonia mydas; ESA-listed threatened) may be found foraging in this area and
southern steelhead (Oncorhynchus mykiss; ESA-listed endangered) may be found during
migration periods (calfish.ucdavis.edu, 2019).
comment letter on the Availability of a DREIR (2019), our continued
recommendation is to select a force main alignment that is located outside of the upper Newport
Bay SMCA, and CDFW thanks OCSD for selecting a conceptual site plan which follows this
recommendation. CDFW also advocated for the use of microtunneling and/or horizontal directional
drilling (HDD) in our 2019 comments.
Timeframe: Microtunneling is anticipated and assumed in the 2020 REIR to occur 24 hours per
day and would take approximately two months to microtunnel across East Coast Highway.
Dredging and trenching activities across Newport Bay Channel would take approximately four
months. Force main improvements are anticipated to take approximately six months.
COMMENTS AND RECOMMENDATIONS
CDFW offers the comments and recommendations below to assist OCSD in adequately identifying
and/or mitigating the Project and indirect impacts on
fish and wildlife (biological) resources. Editorial comments or other suggestions may also be
included to improve the document.
I. Project Description and Related Impact Shortcoming
COMMENT #1: Force Main Improvement Method Selection
A4-1
cont'd
Mr. Kevin Hadden
Orange County Sanitation District
September 17, 2020
Page 3
Section 3.4, Page 3-13 and Section 5.3.4, Page 5.3-13
Issue: The Project as proposed involves dredging and trenching across the Newport Bay Channel
to install force mains between the new pump station and existing OCSD conveyance system.
CDFW does not support dredging within the Newport Bay Channel and continues to recommend
utilization of microtunneling or horizontal directional drilling (HDD) technologies to avoid impacts to
eelgrass, wetlands, fish, birds, benthic habitat, and invertebrates.
Specific impact: Dredging would involve direct removal of eelgrass habitat and marine
invertebrates, and habitat modification within the Newport Bay Channel. The REIR describes
[p]lacement of a dredge (boat) with a submersible pump to suction out sediments at
the bottom of the Newport Bay Channel (page 3-
install the force main improvements would require trenching approximately 580 feet long by 10 feet
wide by 18 feet deep across the Newport Bay Channel, draining the trench, shoring of the trench
walls, and possibly cofferdams within Newport Bay Channel. Accordingly, dredging would result in
disturbance to the Newport Bay Channel within the immediate vicinity of the dredged area.
Potential biological resource impacts associated with dredging may include construction-related
Why impact would occur: In addition to direct removal of eelgrass habitat and marine
invertebrates, dredging can result in underwater noise, causing behavioral responses such as
interruption of species movements between Lower Newport and Upper Newport Bay. Dredging
may also result in turbidity and sedimentation that could be carried by currents into the SMCA
resulting in indirect impacts. This may lead to poor water quality and indirect impacts to birds,
marine plants, fish, animals, and marine habitats.
Evidence impact would be significant: In alignment with our 2019 comments, CDFW is
concerned about potential impacts to the SMCA, as well as potential impacts to eelgrass due to its
historical presence throughout Upper and Lower Newport Bay. Eelgrass habitat areas are
designated Habitat Areas of Particular Concern (HAPC) under the federal Magnuson-Stevens
Fishery Conservation and Management Act, the primary law governing marine fisheries
management in U.S. waters. The National Marine Fisheries Service, in collaboration with CDFW
and other agencies, developed a statewide California eelgrass mitigation policy (CEMP, 2014) that
to help conserve eelgrass resources in California. Eelgrass
habitat is present within the project area and would likely be impacted by dredging. Additionally,
the importance of eelgrass protection and restoration, as well as the ecological benefits of eelgrass
is identified in the California Public Resources Code (PRC Section 35630).
Recommended Potentially Feasible Mitigation Measure(s) (Regarding Project Description
and Related Impact Shortcoming)
Mitigation Measure #1 and #2:
Selection and Associated Mitigation
To minimize significant impacts: CDFW recommends the use of microtunneling or HDD rather
than dredging to install force main improvements across the Newport Bay Channel, as well as
incorporation of a mitigation measure to address associated impacts.
The REIR analyzes multiple Project Alternatives, including the,
(Alternative) examined in Section 7.2. As described in the REIR, the
only difference between the proposed Project and this alternative is that installation of the force
main improvements across Newport Bay Channel would be executed via microtunneling rather
than dredging with the Alternative. The REIR descr a] remote-controlled,
continuously supported pipe jacking method. Microtunneling operations are managed by an
operator in an above ground control container alongside of the shaft. Soil excavation takes place
by way of infusing the soil with slurry at the face of the bore and cuttings are forced into slurry inlet
holes in the Microtunneling Bore Machines crushing cone for circulation to and from a separation
plant through a closed system. Areas where the pipe is microtunneled may require a casing pipe
as large as 72 inches in diameter, which has been evaluated throughout this EIR as a worst-case
scenario (page 3-
CDFW concurs with the biological analysis provided in Section 7.2 of the REIR, concluding that the
microtunneling Alternative would reduce the Projec
is environmentally superior to the proposed Project. Although trenchless technologies such as
microtunneling and HDD create fewer impacts than traditional dredging, associated impacts from
potential hydrofractures would still be considered significant. As indicated in our 2019 letter and
reiterated in the REIR, -en
A4-1
cont'd
A4-4
A4-5
A4-2
A4-3
Mr. Kevin Hadden
Orange County Sanitation District
September 17, 2020
Page 4
utilizing clay lubricants (i.e., bentonite slurry), which could adversely impact benthic invertebrates,
aquatic plants, fish, and their eggs if bentonite is discharged into waterways on accident.
In addition to selection of the
above, CDFW recommends incorporating the below language into a mitigation measure:
To minimize significant impacts associated with microtunneling:
a. drilling shall halt immediately when a hydrofracture is detected, and hydrofractures shall be
cleaned immediately after they occur, if feasible. Necessary response equipment shall be
readily accessible and in good working order;
b. borehole pressures should be monitored during gall drilling, boring, and reaming activities.
The monitor should be independent of and work closely with the drill operator during
operations. The drill operator and/or monitors shall have the authority to halt HDD without
reprisal;
c. all field personnel shall understand their responsibility for timely reporting of hydrofractures;
and,
d. techniques to reduce potential for hydrofracture and inadvertent returns such as:
i. sufficient earth cover for the given substrate should be used to increase resistance to
hydrofracture;
ii. an adequately dense drilling fluid should be used to avoid travel of drilling fluid in porous
sands;
iii. the bore should be conducted in a manner that avoids collapse;
iv. borehole pressure should be maintained low enough to avoid hydrofracture;
v. reaming and pullback rates should be maintained at rates slow enough to avoid over-
pressurization of the bore;
vi. the surface above the vicinity of the drill head should be visually monitored for surface
evidence of hydrofracture;
vii. drilling methods should be modified to suit site conditions such that hydrofracture does
not occur; and,
viii. Non-toxic dyes or markers should be utilized to aid hydrofracture detection.
COMMENT #2: Notification for Channel Impacts
Issue: The Project does not suitably address notification for impacts to the bed and bank of
Newport Bay Channel, per Fish & G. Code, section 1600 et seq.
Specific impact: Dredging and trenching as described involves direct impacts to the bed and bank
of Newport Bay Channel. If microtunneling is adopted in lieu of traditional trenching technologies,
per CDFW recommendation, then accidental frac-outs could possibly warrant notification (see
Comment 1).
Why impact would occur: The REIR addresses the need for notification in terms of jurisdictional
All proposed improvements have been designed to
remain outside of the top of active banks and the canopy/drip line of any associated riparian
vegetation, whichever is greater. Therefore, a Streambed Alteration Agreement (SAA) from CDFW
is not required for the proposed project (page 5.3-wever, CDFW does not regulate
wetlands. Instead, CDFW regulates the bed, bank, and channel of the stream.
Evidence impact would be significant: Fish & G. Code, section 1600 et seq. requires any
person, state or local government agency, or public utility to notify CDFW prior to beginning any
activity that may do one or more of the following: divert or obstruct the natural flow of any river,
stream, or lake; or deposit or dispose of material into any river, stream, or lake.
Recommended Potentially Feasible Mitigation Measure(s) (Regarding Project Description
and Related Impact Shortcoming)
Mitigation Measure #3: Notification for Channel Impacts
To minimize significant impacts: While CDFW acknowledges that it is the responsibility of the
Applicant and the Lead Agency under CEQA (e.g., OCSD) to ascertain as to whether the Project
activities described in the REIR are subject to wetland permitting requirements, we strongly
recommend that OCSD notify for impacts to Newport Bay Channel under Fish & G. Code, section
1600 et seq.
A4-5
cont'd
A4-6
Mr. Kevin Hadden
Orange County Sanitation District
September 17, 2020
Page 5
CDFW also recommends incorporating the below language into a mitigation measure:
OCSD will notify for impacts to Newport Bay Channel per Fish & G. Code, section 1600 et seq. All
wetland permitting requirements, including those which satisfy the United States Army Corps of
Engineers and the Regional Water Quality Control Board, will be in place prior to the
commencement of construction.
II. Coordination with CDFW
We app impact avoidance to biological resources through
-1, BIO-2, BIO-3, and HWQ-4. If any additional impacts to
the SMCA are anticipated, or if pre-construction surveys identify eelgrass, kelp, or any special-
status species, we request that the marine biologist coordinate with CDFW to establish a mitigation
plan. As indicated in our 2019 letter, should eelgrass mitigation and transplanting be required,
CDFW requires a Scientific Collecting Permit to collect eelgrass, and a Letter of Authorization for
eelgrass translocations. CDFW requests to be provided with any pre- and/or post-project survey
reports, and draft mitigation and monitoring plans, with an opportunity to comment and collaborate
prior to finalization.
ENVIRONMENTAL DATA
CEQA requires that information developed in environmental impact reports and negative
declarations be incorporated into a database which may be used to make subsequent or
supplemental environmental determinations. (Pub. Resources Code, § 21003, subd. (e).)
Accordingly, please report any special status species and natural communities detected during
Project surveys to the California Natural Diversity Database (CNDDB). The CNNDB field survey
form can be found at the following link:
http://www.dfg.ca.gov/biogeodata/cnddb/pdfs/CNDDB_FieldSurveyForm.pdf. The completed form
can be mailed electronically to CNDDB at the following email address: CNDDB@wildlife.ca.gov.
The types of information reported to CNDDB can be found at the following link:
http://www.dfg.ca.gov/biogeodata/cnddb/plants_and_animals.asp.
FILING FEES
The Project, as proposed, would have an impact on fish and/or wildlife, and assessment of filing
fees is necessary. Fees are payable upon filing of the Notice of Determination by the Lead Agency
and serve to help defray the cost of environmental review by CDFW. Payment of the fee is required
in order for the underlying Project approval to be operative, vested, and final. (Cal. Code Regs, tit.
14, § 753.5; Fish & G. Code, § 711.4; Pub. Resources Code, § 21089.)
CONCLUSION
CDFW appreciates the opportunity to comment on the REIR to assist OCSD in identifying and
mitigating Project impacts on biological resources.
Questions regarding this letter or further coordination should be directed to Jessie Lane,
Environmental Scientist at (858) 636-3159 or Jessie.Lane@wildlife.ca.gov. For marine species,
Marine Protected Areas and eelgrass, please contact Loni Adams, Environmental Scientist at (858)
627-3985 or Loni.Adams@wildlife.ca.gov.
Sincerely,
Erinn Wilson-Olgin
Environmental Program Manager
South Coast Region
ec: Office of Planning and Research, State Clearinghouse, Sacramento
Eric Wilkins, CDFW, Eric.Wilkins@wildlife.ca.gov
Christine Medak, USFWS, Christine_Medak@fws.gov
Attachments
A. Draft MMRP (CDFW 2020)
REFERENCES
A4-6
cont'd
A4-7
A4-8
A4-9
Mr. Kevin Hadden
Orange County Sanitation District
September 17, 2020
Page 6
California Department of Fish and Wildlife, Marine Life Protection Act,
https://www.wildlife.ca.gov/Conservation/Marine/MPAs/MLPA, accessed March 19, 2020.
California Department of Fish and Wildlife, Upper Newport Bay State Marine Conservation Area,
March 2016.
Michael Baker International, 2019. Bay Bridge Pump Station and Force Mains Replacement
Project Draft Recirculated Environmental Impact Report.
National Marine Fisheries Service, 2014. California Eelgrass Mitigation Policy. Accessed
September 2020 at
https://archive.fisheries.noaa.gov/wcr/publications/habitat/california_eelgrass_mitigation/Final%20
CEMP%20October%202014/cemp_oct_2014_final.pdf
Sevrens, G. K. 2016. California Department of Fish and Wildlife. Comments on the Availability of a
Draft Recirculated Environmental Impact Report for the Bay Bridge Pump Station and Force Mains
Replacement Project, Newport Beach, CA (SCH# 2016111031).
University of California, Davis, 2019. Fish -
http://calfish.ucdavis.edu/location/?ds=698&reportnumber=1293&catcol=4712&categorysearch=%
27Lower%20San%20Diego%20Creek%2D180702040103%27
A4-9
cont'd
Mr. Kevin Hadden
Orange County Sanitation District
September 17, 2020
Page 7
Attachment A:
CDFW Draft Mitigation, Monitoring, and Reporting Plan and Associated Recommendations
Biological
Resources
Mitigation Measures Timing Responsible
Party
MM BIO-1 The
the REIR shall be selected.
Before
Construction
Orange
County
Sanitation
District
MM BIO-2 To minimize significant impacts associated
with microtunneling:
a. drilling shall halt immediately when a
hydrofracture is detected, and
hydrofractures shall be cleaned
immediately after they occur, if feasible.
Necessary response equipment shall be
readily accessible and in good working
order;
b. borehole pressures should be monitored
during gall drilling, boring, and reaming
activities. The monitor should be
independent of and work closely with the
drill operator during operations. The drill
operator and/or monitors shall have the
authority to halt HDD without reprisal;
c. all field personnel shall understand their
responsibility for timely reporting of
hydrofractures; and,
d. techniques to reduce potential for
hydrofracture and inadvertent returns
such as:
i. sufficient earth cover for the given
substrate should be used to increase
resistance to hydrofracture;
ii. an adequately dense drilling fluid
should be used to avoid travel of
drilling fluid in porous sands;
iii. the bore should be conducted in a
manner that avoids collapse;
iv. borehole pressure should be
maintained low enough to avoid
hydrofracture;
v. reaming and pullback rates should be
maintained at rates slow enough to
avoid over-pressurization of the bore;
vi. the surface above the vicinity of the
drill head should be visually monitored
for surface evidence of hydrofracture;
vii. drilling methods should be modified to
suit site conditions such that
hydrofracture does not occur; and,
viii. Non-toxic dyes or markers should be
utilized to aid hydrofracture detection.
During
Construction
Orange
County
Sanitation
District
MM BIO-3 OCSD will notify for impacts to Newport Bay
Channel per Fish & G. Code, section 1600
et seq. All wetland permitting requirements,
including those which satisfy the United
States Army Corps of Engineers and the
Regional Water Quality Control Board, will
Prior to
Construction
Orange
County
Sanitation
District
A4-10
Mr. Kevin Hadden
Orange County Sanitation District
September 17, 2020
Page 8
be in place prior to the commencement of
construction.
A4-10
cont'd
A4-10
cont'd
A4-10
cont'd
A4-10
cont'd
A4-10
cont'd
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 2-30 Responses to Comments
RESPONSE TO COMMENT LETTER A4
Erinn Wilson-Olgin, Environmental Program Manager, South Coast Region
California Department of Fish and Wildlife
September 17, 2020
A4-1 The commenter has attached a California Department of Fish and Wildlife (CDFW) Draft
Mitigation, Monitoring, and Reporting Plan and Associated Recommendations, and a previous
comment letter submitted as part of the 2019 Recirculated Draft EIR (enclosed herein as
Comment A4-10). The Draft Mitigation, Monitoring, and Reporting Plan and Associated
Recommendations, would apply to microtunneling activities under Newport Bay Channel.
However, the proposed project does not call for any microtunneling activities under Newport
Bay Channel. As such, the Draft Mitigation, Monitoring, and Reporting Plan and Associated
Recommendations would not apply to the proposed project.
It should be noted that OCSD recirculated the entire Draft EIR and required reviewers to
submit new comments on the 2020 Recirculated Draft EIR, pursuant to CEQA Guidelines
Section 15088.5(f)(1) (2020 Recirculated Draft EIR page 2-4, first paragraph). OCSD is not
required to respond to those comments received during the earlier circulation period for the
Bay Bridge Pump Station and Force Mains Replacement Project Draft Recirculated Environmental Impact Report (2019 Recirculated EIR). Although the prior comments are part of the administrative
record, the previous comments do not require a formal written response in this Final EIR,
unless otherwise specified in the Response to Comments A4-1 through A4-9. Nonetheless,
it is acknowledged that the 2020 Recirculated Draft EIR was revised to address concerns raised
during the public review period of the 2019 Recirculated EIR and also reflects concerns raised
during the public review period of the 2017 Bay Bridge EIR. This information is included in
2020 Recirculated Draft EIR Section 5.3, Biological Resources. Refer to Response to Comment
A4-5.
The commenter provides a description of the California Department of Fish and Wildlife
(CDFW) roles and responsibilities, a brief project description summary, as well as a summary
of the biological setting of the project site. The commenter states that the project site contains
suitable habitat to support nesting bird species, and identifies Upper and Lower Newport Bay
as an estuary that supports extensive eelgrass beds, coastal lagoon habitats and wetlands, and
multiple sensitive species.
The commenter expresses appreciation that OCSD has selected a force main alignment that
is located outside of the Upper Newport Bay State Marine Conservation Area (SMCA). The
commenter then recommends the use of microtunneling or horizontal directional drilling
(HDD) instead of dredging to install the proposed force main improvements across the
Newport Bay Channel. The commenter states that dredging would involve direct removal of
eelgrass habitat and marine invertebrates, and habitat modification within the Newport Bay
Channel. Potential biological resource impacts associated with dredging may include
construction-related turbidity, light and noise, and increased workboat activity. OCSD
responds to these comments as follows.
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 2-31 Responses to Comments
Removal or Modification of Habitat and Marine Invertebrates
Impacts to special status plant or wildlife species associated with dredging activities are
analyzed under Impact Statements BIO-1 (page 5.3-13) and BIO-2 (page 5.3-17) of the 2020
Recirculated Draft EIR. As stated under Impact Statement BIO-1 of the 2020 Recirculated
Draft EIR, impacts to marine mammals and fish from potential dredging activities would be
reduced to less than significant levels with implementation of Mitigation Measure BIO-1.
Specifically, Mitigation Measure BIO-1 would require contractor awareness training for all
personnel working in the marine environment to educate contractor personnel on the
identification of marine wildlife in the project area and what procedures to take, should any
sensitive marine wildlife be encountered during project construction activities.
As stated under Impact Statement BIO-2 of the 2020 Recirculated Draft EIR, impacts to
eelgrass within the project site and vicinity from potential dredging activities would be reduced
to less than significant levels with implementation of Mitigation Measures BIO-3. Mitigation
Measure BIO-3 would require a qualified marine biologist to conduct a pre-construction
survey for presence of eelgrass and kelp species prior to the commencement of in-water
construction operations. In the event that pre-construction survey results indicate eelgrass or
kelp presence within the project site, OCSD would be required to incorporate additional
avoidance, protection, and/or replacement mitigation measures (e.g., reseeding) to achieve
California Eelgrass Mitigation Policy’s (CEMP’s) “no net loss” standard (2020 Recirculated
Draft EIR pages 5.3-8 and 5.3-18 [Mitigation Measure BIO-1]), and reduce impacts to eelgrass
or kelp species to the maximum extent practicable during project construction. As such,
impacts to eelgrass and kelp habitats during dredging activities would be minimized with
implementation of Mitigation Measure BIO-3 along with all applicable regulations.
A4-2 As stated in the 2020 Recirculated Draft EIR Impact Statement BIO-1, impacts associated
with dredging may include construction-related noise. Page 5.3-14 goes on to state marine
mammals and fish located near the dredging activities are anticipated to avoid the area of
construction due to the increased noise/vibration and nighttime lighting levels from the
trenching machinery; refer to page 13 of the Updated Biological Resources Assessment for the Bay Bridge Pump Station and Force Mains Replacement Project – Newport Beach, Orange County, California
(Biological Resources Assessment), prepared by Michael Baker International, dated April 15,
2020, provided in 2020 Recirculated Draft EIR Appendix 11.3, Biological Resources Reports).
Nonetheless, the 2020 Recirculated Draft EIR acknowledges the sensitivity of marine wildlife
in the project area and includes Mitigation Measure BIO-1, which requires contractor
awareness training for all personnel working in the marine environment. The purpose of the
training is to educate contractor personnel on the identification of marine wildlife in the
project area and what procedures to take, should any sensitive marine wildlife be encountered
during project construction activities. The training would include identification of common
types of marine wildlife; potential activities which could affect the marine wildlife; an overview
and procedures to follow during waterside construction activities; and reporting requirements
if marine wildlife are injured. As such, with implementation of Mitigation Measure BIO-1,
noise-related impacts to marine mammals and fish from dredging activities within the
Newport Bay Channel would be reduced to less than significant levels.
A4-3 Construction-related impacts to water quality associated with dredging activities are analyzed
under Impact Statements BIO-1 and HWQ-1 of the 2020 Recirculated Draft EIR. Based on
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Final ● January 2021 2-32 Responses to Comments
this analysis, impacts to turbidity associated with potential dredging activities would be reduced
to less than significant levels with implementation of Mitigation Measure HWQ-4.
Mitigation Measure HWQ-4 requires OCSD to obtain Department of the Army permit(s)
from the U.S. Army Corps of Engineers (Corps) in compliance with the Clean Water Act,
which may involve obtaining an individual or nationwide permit. Standard best management
practices (BMPs) for dredging operations and Federal permit requirements as required under
Mitigation Measure HWQ-4 would minimize water quality impacts and turbidity resulting
from dredging operations. Examples of standard BMPs to reduce turbidity include silt curtain
deployment around active dredging, reduction in dredging rate, modification of clamshell
operation, use of favorable tidal conditions to minimize spread of turbidity plumes, and
temporary suspension of dredging when necessary.
As such, implementation of Mitigation Measure HWQ-4 along with all applicable regulations
would minimize water quality impacts and turbidity resulting from dredging operations to less
than significant levels.
A4-4 The commenter reiterates the CDFW’s concerns regarding potential impacts to the Upper
Newport Bay SMCA and to the eelgrass community. The commenter provides information
regarding eelgrass habitat, its designation as Habitat Areas of Particular Concern (HAPC), its
protection under the Federal Magnuson-Stevens Fishery Conservation and Management Act,
applicable California Eelgrass Mitigation Policy (CEMP) “no net loss of habitat” standards
established by the National Marine Fisheries Services (NMFS), and the ecological benefits of
eelgrass as identified in the California Public Resources Code Section 35630.
As stated by the commenter, as well as noted in Response to Comment A4-1, the project site
is located outside of SMCA. Further, the 2020 Recirculated Draft EIR includes Mitigation
Measure BIO-3, which requires OCSD to retain a qualified marine biologist to conduct a
comprehensive pre-construction survey for the presence of eelgrass and kelp species prior to
commencement of in-water construction operations. Such survey would be consistent with
current NMFS California Eelgrass Mitigation Policy survey guidelines.
In the event that pre-construction survey results indicate eelgrass or kelp presence within the
project site, OCSD would be required to incorporate additional avoidance, protection, and/or
replacement mitigation measures (e.g., reseeding) to achieve CEMP’s “no net loss” standard
and reduce impacts to eelgrass or kelp species to the maximum extent practicable during
project construction. Specifically, in cases where avoidance and minimization of effects to
eelgrass have been implemented and further mitigation is required, the NMFS recommends
compensatory mitigation for vegetated and unvegetated eelgrass habitat to be completed at a
ratio of at least 1.2:1 (mitigation area to impact area).
Additionally, OCSD and the qualified marine biologist would be required to consult with
appropriate regulatory agencies, including the CDFW, NMFS, Corps, U.S. Fish and Wildlife
Service (USFWS), California Coastal Commission (CCC), and other resource and regulatory
agencies, as necessary, to ensure compensatory mitigation is established if the project results
in the loss of eelgrass or kelp habitat.
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 2-33 Responses to Comments
Although the 2020 Recirculated Draft EIR identifies potential impacts involving species of
concern, noise, and turbidity, the 2020 Recirculated Draft EIR concluded that with
recommended mitigation applied and compliance with existing Federal, State, and local laws
and regulations, these impacts would be reduced to less than significant levels. Nonetheless,
an alternative to the proposed project (the “Adjacent Pump Station with Microtunneling”
Alternative) was analyzed by the 2020 Recirculated Draft EIR in order to compare potential
impacts associated with dredging (the proposed project) versus microtunneling across the
Newport Bay Channel for the proposed force main improvement (as discussed in Section 7.2,
“Adjacent Pump Station with Microtunneling” Alternative, of the 2020 Recirculated Draft EIR); refer
to Response to Comment A4-5 below.
A4-5 The commenter reiterates CDFW’s preference in the use of microtunneling or HDD as
compared to dredging for the proposed force main improvement across the Newport Bay
Channel, as well as incorporation of a mitigation measure to address associated impacts. The
commenter summarizes “Adjacent Pump Station with Microtunneling” Alternative (as
discussed in Section 7.2, “Adjacent Pump Station with Microtunneling” Alternative, of the 2020
Recirculated Draft EIR) and indicates that CDFW concurs with the conclusion regarding such
alternative as detailed in the 2020 Recirculated Draft EIR. The commenter then raises
concerns regarding potential hydrofractures that could occur when utilizing clay lubricants
(i.e., bentonite slurry) during microtunneling activities. Hydrofractures, or “frac-outs”, could
adversely impact benthic invertebrates, aquatic plants, fish, and their eggs, if bentonite is
discharged into waterways on accident. As such, CDFW recommends incorporating the
mitigation measure regarding hydrofractures, as written in their comment letter (enclosed
herein as Comment A4-10), to minimize significant impacts associated with microtunneling.
As stated in the 2020 Recirculated Draft EIR page 3-12, the project proposes to microtunnel
(or open trench cut) under East Coast Highway to the southside of Bay Bridge. South of the
bridge, the project would dredge under Newport Bay Channel to install the proposed force
main pipes. As microtunneling would not occur in-water (in Newport Bay Channel), there is
no potential for “frac-outs” associated with the proposed project and the recommended
mitigation measures are not applicable.
Environmental impacts associated with the proposed dredging activities across Newport Bay
Channel have been analyzed throughout the 2020 Recirculated Draft EIR. All impacts
associated with the dredging technique employed under Newport Bay Channel were
determined to be less than significant with mitigation incorporated; refer to Section 1.4,
Environmental Issues/Mitigation Summary of the 2020 Recirculated Draft EIR for a summary of
mitigation measures proposed. Refer to Response to Comment A4-1 above for discussions
on specific biological impacts associated with the proposed dredging activities.
A4-6 The commenter states that the 2020 Recirculated Draft EIR does not suitably address
requirement for notification to CDFW regarding impacts to the bed and bank of Newport
Bay Channel, per Fish and Game Code Section 1600 et seq. However, 2020 Recirculated
Draft EIR page 2-7 and 3-17 identify the CDFW as a Responsible Agency for permits
requiring consultation regarding implementation of the Newport Bay Channel force main
crossing. The 2020 Recirculated Draft EIR goes on to state that the CDFW regulates activities
under California Fish and Game Code Sections 1600-1607 (pages 5.3-4 and 5.3-18), which
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 2-34 Responses to Comments
includes any notification requirements per existing law. OCSD will comply with all applicable
legal and permitting requirements, including any required consultation.
A4-7 Refer to Response to Comment A4-3 for a discussion on SMCA, eelgrass, kelp, and other
special status species. Further, it is acknowledged that the 2020 Recirculated Draft EIR
Mitigation Measure BIO-3 requires that a qualified marine biologist, defined as an individual
with a bachelor’s degree or above in marine biology, zoology, or a closely related area and
demonstrated field experience, shall coordinate with the appropriate regulatory agencies
including CDFW, as necessary, and OCSD, or designee, shall implement compensatory
mitigation, as required by the appropriate regulatory agencies, should the project result in the
loss of eelgrass and kelp habitat.
A4-8 The commenter indicates that information developed in EIRs and negative declarations would
be incorporated into a database which may be used to make subsequent or supplemental
environmental determinations pursuant to Public Resources Code, Section 21003, subdivision
(e). Additionally, the commenter requests that any special status species and natural
communities detected during project surveys shall be reported to the California Natural
Diversity Database (CNDDB) by completing the CNNDB field survey form and submitted
to a specific email address provided in the letter. As acknowledged in Response to Comment
A4-7, the CDFW will be consulted, as appropriate during dredging activities (as required
pursuant to 2020 Recirculated Draft EIR Mitigation Measure BIO-3).
A4-9 The commenter indicates that payment of a filing fee to the CDFW is necessary as the project
would have an impact on fish and/or wildlife, and that payment of such fee is required by
State Law. The commenter concludes the letter by providing staff contact information for
further questions. This comment is acknowledged; no further response is necessary.
A4-10 The commenter has attached a CDFW Draft Mitigation, Monitoring, and Reporting Plan and
Associated Recommendations, and a previous comment letter submitted as part of the 2019
Recirculated Draft EIR (enclosed herein as Comment A4-10). Mitigation and associated
recommendations listed on the attached CDFW Draft Mitigation, Monitoring, and Reporting
Plan and Associated Recommendations table are referenced by the commenter throughout
the letter and particularly, in Comment A4-5; thus, refer to Response to Comments A4-5 and
A4-6.
In regard to the attached previous comment letter submitted as part of the 2019 Recirculated
Draft EIR, it should be noted that OCSD recirculated the entire Draft EIR and required
reviewers to submit new comments on the 2020 Recirculated Draft EIR (refer to the 2020
Recirculated Draft EIR page 2-3), pursuant to CEQA Guidelines Section 15088.5(f)(1).
OCSD is not required to respond to those comments received during the earlier circulation
period for the 2019 Recirculated EIR. Although the prior comments are part of the
administrative record, the previous comments do not require a written response in this Final
EIR. It is acknowledged that many of these comments made no longer pertain to the
proposed project, as the project would no longer impact the channel north of Bay Bridge and
would no longer propose microtunneling under the Newport Bay Channel. Notwithstanding,
the 2020 Recirculated Draft EIR was revised to address concerns raised during the previous
public review periods for the 2019 Recirculated EIR and 2017 Bay Bridge EIR. CDFW
comments from the 2019 Recirculated Draft EIR pertaining to eelgrass impacts and applicable
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 2-35 Responses to Comments
mitigation have been incorporated into the 2020 Recirculated Draft EIR. Comments
pertaining to microtunneling under Newport Bay Channel have been incorporated into the
2020 Recirculated Draft EIR Section 7.0, Alternatives.
COMMENT LETTER A5
A5-1
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 2-37 Responses to Comments
RESPONSE TO COMMENT LETTER A5
Richard Vuong, Interim Deputy Director
OC Public Works Service Area/OC Development Services
September 21, 2020
A5-1 This letter acknowledges that the Orange County Public Works received and reviewed the
2020 Recirculated Draft EIR and has no comments. The commenter requests continued
communication of further developments and future notifications related to the project. An
Orange County Public Works’ staff contact information is provided. This comment is
acknowledged; no further response is necessary.
Community Development Department
CITY OF NEWPORT BEACH
100 Civic Center Drive
Newport Beach, California 92660
949 644-3200
newportbeachca.gov/communitydevelopment
September 21, 2020
Via Electronic & Regular Mail
CEQA@ocsd.com
Kevin Hadden, Principal Staff Analyst
Orange County Sanitation District
10844 Ellis Avenue
Fountain Valley, CA 92708
Re: The 2020 Recirculated Draft Environmental Impact Report for the Bay Bridge Pump
Station and Force Mains Rehabilitation Project
Dear Mr. Hadden,
Thank you for the opportunity to comment on the 2020 Recirculated Draft Environmental Impact
Report for the Bay Bridge Pump Station and Force Mains Rehabilitation Project. The City of
) submits the following comments:
Preferred Sewer Force Main Alignment
In response to the newly proposed sewer force main alignment, which is generally
acceptable, the City recommends the configuration be refined to reflect the prepared
fewer
construction impacts to adjacent property owners.
Lower Castaways
Lower Castaways is a 4-acre, bayfront, open space area owned by the City located at the
northeast corner of West Coast Highway and Dover Drive.
Throughout the 2020 recirculated DEIR, references to Lower Castaways suggest
the assumption the site is available construction staging. However,
the City has plans to improve Lower Castaways as a public park in the foreseeable
future and the project could inhibit its use and/availability. Because of this, the
City will likely neither support a permanent nor temporary easement through Lower
Castaways. Discussion of construction staging and other project activities
proposing the potential utilization of Lower Castaways should acknowledge the
and also convey that the City will
not likely endorse the use of Lower Castaways for purposes of the project. See
Exhibits 3-4, -6 and pages 1-26, -27; 3-12; 5.1-6, -14 -17; 5.3-2; 5.5-2; 7-20; 8-9.
A6-1
COMMENT LETTER A6
A6-2
County Tidelands
The County of Orange is responsible for managing tidelands and submerged lands in
the
is proposed. (See attached excerpt of tidelands map and reference location on Exhibit
6 of the .) As the project will extend through their tidelands and submerged
lands, the County of Orange should be consulted and listed as an applicable agency.
(See page 2-6.)
Land Use and Relevant Planning
Page 3-5. Under Table 3-Existing Land Use Back Bay
Landing project is out of date, since the City has already approved this
land use amendments. Now pending is the site development review and coastal
development permit for the final project design.
Exhibit 5.1-1c. The updated Adjacent Pump Station Layout repositions the
electrical room more south, closer to East Coast Highway, and more west, toward
Bay Bridge that could block views of the coastal bluffs when traveling northwest
on East Coast Highway. Coastal Land Use Policy 4.4.1-6 directs for the protection
of public coastal views from these road segments of Bay Bridge and East Coast
Highway. To this end, provide a view analysis traveling west on East Coast
Highway, looking northwest towards Upper Newport Bay Bluffs to thoroughly
analyze potential public view impacts to the Upper Newport Bay viewshed. (See
comment 3.c.ii below for more information.)
Pages 5.1-15.
Clarify if the proposed 31-foot high building will have a flat roof or sloped.
The Back Bay Landing Planned Community Development Plan (BBL
PCDP) allows 30 feet height limit for flat roofs and 35 feet for sloping roofs.
Impact analysis assesses views of Upper Newport Bay bluffs, but the
supporting exhibit of View Corridor 1 is taken from the corner an of
intersection and does not support the discussion. Along portions of East
Coast Highway, the current pump station blocks views of the bluffs, but
once traveling west past the pump station, these views begin to open up.
Provide a corridor view analysis from the point in the attached clarification
analyzing impacts of expanded pump station location.
Page 5.1-19 (AES-2). Revise Mitigation Measure AES-2 to include that a Site
Development Review will be required from City of Newport Beach to ensure
consistency with surrounding development and the Back Bay Landing Planned
Community Development Plan.
Page 5.9-24.
Development Standards discussion references heights limits from the
outdated version of BBL PCDP. Maximum height limits within Planning
Area 1 is 30 feet for flat roofs and 35 feet for sloping roofs with at least a
3:12 pitch.
A6-3
A6-4
A6-5
A6-6
A6-7
A6-8
A6-9
ii. Design Guidelines discussion references architectural theme from old
version of BBL PCDP. The current adopted version requires a Coastal
architectural theme, not Mediterranean.
5. Transportation/Traffic
It does not appear all City comments from the prior letter were incorporated in the
recirculated 2020 DEIR.
a) Page 1-22. Revise description regarding damage from hauling operations to
with the following underlined text: age to
existing pavement, streets, curbs, and/or gutters along the haul route, the
contractor shall be fully responsible for repairs and shall obtain an
encroachment permit from the City of Newport Beach or CalTrans depending
on location. The repairs shall restore the damaged property to its original
condition.
Please feel free to contact me at 949-644-3209 or jmurillo@newportbeachca.gov if you have any
questions.
Sincerely,
Exhibits
City Preferred Sewer Force Main Alignment
Excerpt of Tidelands Survey
View Corridor Clarification
A6-10
A6-11
A6-12
A6-12
cont'd
A6-12
cont'd
A6-12
cont'd
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 2-45 Responses to Comments
RESPONSE TO COMMENT LETTER A6
Jaime Murillo, Principal Planner
City of Newport Beach
September 21, 2020
A6-1 The commenter has attached several exhibits including the City’s Preferred Sewer Force Main
Alignment, excerpt of tideland map, reference location on Exhibit 3-6 of the 2020 Recirculated
Draft, and a view corridor clarification photograph to supplement the City’s comments. All
attachments are enclosed herein as Comment A6-12.
The commenter states that the proposed force main alignment is generally acceptable.
However, the commenter recommends an alternative force main alignment, as illustrated on
Letter A6’s first attachment, that the commenter alleges would result in fewer construction
impacts to adjacent property owners.
OCSD will consider this comment when finalizing project design and construction plans. It
should be noted that in the event that these suggested alternative force main alignment
adjustments are made during project design by OCSD, such alignment is similar to the force
main alignment currently proposed (refer to Exhibit 3-4, Proposed Conceptual Site Plan of the
2020 Recirculated Draft EIR) and these changes provide a minor update, correction, or
clarification and do not represent “significant new information” as defined in CEQA
Guidelines Section 15088.5. As this comment does not raise an issue specifically related to
the 2020 Recirculated Draft EIR’s environmental analysis, no further response is required.
A6-2 The commenter states that the City will likely not support the use of Lower Castaways Park
as a construction staging area for the project based on the City’s plans to improve Lower
Castaways as a public park in the foreseeable future. The commenter requests that discussion
of construction staging and other project activities proposing the potential utilization of Lower
Castaways should acknowledge the City’s plans to improve the site as a public park and also
convey that the City will not likely endorse the use of Lower Castaways for purposes of the
project.
The potential impacts of proposed construction staging at Lower Castaways were analyzed,
should this property be available from the City of Newport Beach. Temporary construction
impacts were assessed based on the existing condition of the Lower Castaways. Future plans
for Lower Castaways, as a park, are not listed on the City of Newport Beach, Cumulative
Projects List, as of March 19, 2020 (2020 Recirculated Draft EIR page 4-4). Thus, these future
activities were not considered in the 2020 Recirculated Draft EIR. Nonetheless, the 2020
Recirculated Draft EIR page 3-12 acknowledges that Lower Castaways Park would only be
utilized for construction staging if this area is available during construction. Should Lower
Castaways not be available, construction staging would occur within other proposed areas of
disturbance (as identified in the project boundary shown on 2020 Recirculated Draft EIR
Exhibit 3-4).
A6-3 The commenter indicates that the project would extend through County of Orange’s tidelands
and submerged lands in the area south of the Bay Bridge. As detailed on page 3-17 of the
2020 Recirculated Draft EIR, implementation of the proposed force main crossing would
require consultation with the California State Lands Commission and CDFW, which could
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 2-46 Responses to Comments
identify other required permit/approvals, including an easement to cross the Newport Bay
tidelands. As such, the requested clarification has been made to Section 2.5, Responsible and
Trustee Agencies (page 2-6) and Section 3.6, Permits and Approvals (page 3-16) of the 2020
Recirculated Draft EIR.
Section 2.5, Page 2-6, Last Paragraph
Responsible and Trustee Agencies and other entities that may use this 2020 Recirculated
Draft EIR in their decision-making process or for informational purposes include, but may
not be limited to, the following:
• City of Newport Beach;
• California Department of Transportation;
• Santa Ana Regional Water Quality Control Board;
• State Water Resources Control Board;
• California Department of Fish and Wildlife;
• California Coastal Commission;
• California State Lands Commission/County of Orange;
• South Coast Air Quality Management District;
• U.S. Army Corps of Engineers; and
• National Marine Fisheries Service.
Section 3.6, Page 3-16, Last Paragraph
The applicable agency approvals and related environmental review/consultation
requirements associated with the proposed project may include the following, among others. It is not anticipated that any other agencies would require use of the EIR in their
decision making process.
• CEQA Clearance – OCSD;
• Site Development Review Permit – City of Newport Beach;
• Limited Term Permit – City of Newport Beach;
• Encroachment Permits – City of Newport Beach and Caltrans;
• Permanent/Temporary Easements – City of Newport Beach, Bayside Village Marina, LLC, The Irvine Company, and Bay Shores Community Association;
• Traffic Control Plan Approval – City of Newport Beach and Caltrans;
• Coastal Development Permit – California Coastal Commission and City of Newport Beach (as required under the California Coastal Act, Public Resources Code
Division 20);
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Final ● January 2021 2-47 Responses to Comments
• California State Lands Commission – Consultation with the County of Orange
regarding implementation of Newport Bay Channel force main crossing through tidelands and submerged lands;
These changes provide a minor update, correction, or clarification and do not represent “significant new information” as defined in CEQA Guidelines Section 15088.5.
A6-4 Please refer to Response to Comment O4-2 regarding consideration of existing baseline
conditions and cumulative considerations involving the Back Bay Landing Project as part of the 2020 Recirculated Draft EIR.
A6-5 The commenter indicates that the proposed electrical room could block views of the coastal
bluffs when travelling northwest on East Coast Highway. The commenter requests a view analysis travelling west on East Coast Highway and looking northwest towards Upper
Newport Bay bluffs to thoroughly analyze potential public view impacts to the Upper Newport Bay viewshed.
The 2020 Recirculated Draft EIR acknowledges that, in addition to designated public
viewpoints, Coast Highway is recognized as a coastal view road in the City’s General Plan and is designated as an eligible State Scenic Highway (page 5.1-2). Within the project area, Coast
Highway provides motorists, pedestrians, and bicyclists views of the Pacific Ocean, Newport Bay, coastal bluffs, and the San Joaquin Hills to the east. 2020 Recirculated Draft EIR page
5.1-16 considers potential view impacts of the proposed project to the public views along Coast Highway.
The Back Bay Landing Planned Community Development Plan (PCDP) establishes the
permissible building heights in this area. As shown on the Bay Back Landing PCDP Exhibit 2-3, Building Heights, and discussed on page 2-16, the central portion of PA 1 is identified as a
35-foot Building Height Zone, with the maximum allowable building height of 35 feet for structures with flat roofs and 40 feet for structures with sloped roofs (measured from a
finished baseline elevation of 14 feet). The environmental impacts of the PCDP, including the building heights allowed by the PCDP, were analyzed in the Back Bay Landing Draft EIR
which was certified in February 2014. The Back Bay Landing Draft EIR analyzed the proposed building heights presented in the PCDP and found that impacts in this regard to
public views of coastal bluffs were less than significant. Building heights considered in this EIR included a range from 20 to 35 feet (or 40 feet with rooftop architectural elements) as
well as an allowed coastal public view tower up to 65 feet in height, pursuant to Back Bay Landing PCDP Section B, Permitted Height of Structures, and Exhibit 3, Building Heights. As such,
the permitted building heights allowed by the City of Newport Beach are included in the findings presented in the Back Bay Landing EIR. The City of Newport Beach concluded in
the Back Bay Landing Draft EIR that although future development within the PCDP could
obstruct short‐, mid‐, and long‐range views of scenic resources from some locations in the
project area, such obstructions would not represent a significant portion of the overall
panoramic views currently available from public viewpoints.
As discussed, the only aboveground feature proposed by the project is the new 31-foot high
(from finished grade) pump station facility. As illustrated in 2020 Recirculated Draft EIR
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 2-48 Responses to Comments
Exhibit 5.1-1c, the proposed pump station facility would not result in any increased view
blockage to coastal bluffs compared to existing conditions given that the site is located at a
lower elevation than East Coast Highway. Upon completion of the project, the existing
western public views of the bluffs from East Coast Highway would remain, as the majority of
these views are experienced west of the project site. Further, the proposed 14,500-square foot
building (31 feet in height from finished grade and 34 feet in height from existing grade) is
consistent with the City of Newport Beach’s allowed building heights for the surrounding area
(allowed heights ranging from 20 to 35 feet [or 40 feet with rooftop architectural elements] as
well as an allowed coastal public view tower up to 65 feet in height) pursuant to Back Bay
Landing PCDP Section B, Permitted Height of Structures, and Exhibit 3, Building Heights).
Therefore, the proposed maximum pump station height of 34 feet from existing grade would
be consistent with the permitted height for the central portion of PA 1 as established in the
Back Bay Landing PCDP and as analyzed in the Back Bay Landing Draft EIR. As the building
would not exceed established building heights for the project site, the proposed building would
not significantly affect views along this corridor, including the coastal bluffs, Newport Bay
Channel, and Pacific Ocean.
The City of Newport Beach recently used similar vantage points to consider the view impacts
of the Back Bay Landing Project (Back Bay Landing Draft EIR Exhibits 4.A-2, Existing Views,
page 4.A-7, and 4.A-3, Existing Views, page 4.A-8), which completely surrounds the existing
pump station on all sides, except for the southern boundary that adjoins East Coast Highway.
Further, the City of Newport Beach included the existing pump station in the Back Bay
Landing PCDP, including regulations such as building heights for the project site. As shown
on Back Bay Landing Draft EIR Exhibits 4.A-2 and 4.A-3, the existing westward and
northward views, including the pump station facility, are depicted on references “D” and “E”.
As shown in Reference “G”, where visual resources are prominent at the Bay Bridge, the pump
station facility is not readily visible. Back Bay Landing Draft EIR Exhibits 4.A-6, View Simulation #1, page 4.A-17, and 4.A-12, View Simulation #7, pages 4.A-17 and 4.A-23,
respectively, further illustrate the vantage points of the project site in relation to the coastal
bluffs. The City of Newport Beach concluded in the Back Bay Landing Draft EIR that
although future development at the project site could obstruct short‐, mid‐, and long‐range views of scenic resources from some locations in the project area, such obstructions would
not represent a significant portion of the overall panoramic views currently available from public viewpoints. Most substantial view obstructions would occur along a limited segment
of East Coast Highway immediately adjacent to the project site and would only obscure views northward for a limited time as one travels along the roadway. As such, future development
at the project site would not have a substantial adverse effect on a scenic vista, and impacts in this regard would be less than significant (Back Bay Landing Draft EIR page 4.A-25).
With regards to the commenter’s request to conduct additional viewshed analysis, “CEQA
does not require a lead agency to conduct every test or perform all research, study, and experimentation recommended or demanded by commentors.” (CEQA Guidelines Section
15204(a).) CEQA states that absolute perfection in the analysis is not required so long as environmental impact analyses sufficient to permit a reasonable choice of alternatives is
provided. Additionally, it is only required that the officials and agencies make an objective, good-faith effort to comply. (Foundation for San Francisco's Architectural Heritage v. City and County
of San Francisco (1980) 106 Cal.App.3d 893, 910.) As such, similar to findings made by the City of Newport Beach in the Back Bay Landing Draft EIR, OCSD has determined that the
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 2-49 Responses to Comments
proposed pump station building would not result in significant view impacts of the nearby
coastal bluffs, as seen from the wider Coast Highway view corridor. Impacts in this regard
would be less than significant (2020 Recirculated Draft EIR page 5.1-16).
A6-6 The commenter indicates the Back Bay Landing PCDP has a 30-foot height limit for structures
with flat roofs and 35-foot limit for structures with slopping roofs. The commenter requests
clarification on whether the project proposes a flat roof or sloped roof. The proposed project,
considered in the 2017 Bay Bridge EIR and the 2019 Recirculated EIR included site plans
within the building height restrictions referenced in the comment. However, the revised
project, presented in the 2020 Recirculated Draft EIR is not situated within this height zone.
Based on the Back Bay Landing PCDP Figure 2-3, Planning Areas, the project site is located in
the central portion of Planning Area 1 (PA 1), one of the five planning areas under the Back
Bay Landing PCDP. As shown on the Bay Back Landing PCDP Exhibit 2-3, Building Heights,
and discussed on page 2-16, the central portion of PA 1 is identified as a 35-foot Building
Height Zone, with the maximum allowable building height of 35 feet for structures with flat
roofs and 40 feet for structures with sloped roofs (measured from a finished baseline elevation
of 14 feet). As discussed in Response to Comment 6-5, as well as on 2020 Recirculated Draft
EIR page 5.9-24, Development Standards, the proposed pump station would have a maximum
building height of 31 feet from finished grade. The finished grade is anticipated to be
approximately three feet higher than the existing building pad. Thus, the proposed building
would have a maximum height of 34 feet from existing grade. As such, the proposed
maximum pump station height of 34 feet from existing grade would be consistent with the
permitted height for the central portion of PA 1 as established in the Back Bay Landing PCDP,
whether or not a flat or sloped roof is proposed. The specific architectural design of the new
pump station will be conducted as part of the Site Development Review Permit process with
the City of Newport Beach (2020 Recirculated Draft EIR page 3-19). At this time, the City of
Newport Beach will have an opportunity to comment on the roof design.
A6-7 Refer to Response to Comment A6-5.
A6-8 The proposed project would be required to comply with all existing Federal, State, and local
laws and regulations, including existing permitting requirements imposed by the City of
Newport Beach. As obtaining a Site Development Review Permit with the City of Newport
Beach is already a regulation imposed on the project, which would ensure design standard
consistency, compliance with these permit requirements are not required to be included in a
mitigation measure. As such, these requested changes have not been made. Please note 2020
Recirculated Draft EIR page 3-16 states that the proposed project would be required to obtain
a Site Development Review Permit from the City of Newport Beach.
A6-9 Refer to Response to Comment A6-6.
A6-10 As discussed on 2020 Recirculated Draft EIR, page 5.1-13, Design Guidelines, A. Architectural
Theme, the development (within the Back Bay Landing PCDP, as amended April 26, 2016)
shall be designed with a Coastal architectural theme. (Back Bay Landing PCDP Section IV,
Design Guidelines) This architectural theme is influenced by the marine climate of the California
coastline, with varied historical vernacular and casually elegant palette, with building forms
and massing that define and create unique and often seamless indoor/outdoor spaces. The
project would follow principles of quality design, exhibiting a high level of architectural
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 2-50 Responses to Comments
standards and shall be compatible with the surrounding area, sensitive to scale, proportion,
and identity with a focus on place-making. Massing offsets, variation of roof lines, varied
textures, openings, recesses, and design accents on all building elevations shall be provided to
enhance the architectural design. The intent is not to select a historically specific or rigid
architectural style for the project, but to create an active, mixed-use village.
As discussed on 2020 Recirculated Draft EIR pages 5.1-18 and 5.1-19, the project would be
consistent with the Back Bay Landing PCDP design guidelines, particularly those involving
architectural theme, façade treatments, and public view considerations. Compliance with the
Site Development Review Permit from the City of Newport Beach would ensure the proposed
project is generally consistent with the design requirements for the site (including the
architectural theme). With compliance with the Site Development Review Permit, impacts in
this regard would be less than significant. Nevertheless, it is acknowledged that page 5.1-18
and page 5.9-24 of the 2020 Recirculated Draft EIR referenced “coastal Mediterranean
architectural theme” with “textured walls and terracotta colors”. As such, clarifications have
been made to pages 5.1-18 and 5.9-24 of the 2020 Recirculated Draft EIR.
Section 5.1.4, Page 5.1-18, Last Paragraph
As discussed in Section 5.9, Land Use and Relevant Planning, project development would be
consistent with the zoning and regulations governing scenic quality. The new facility would
be similar in character to the existing pump station facility. The new pump station structure
(up to 31 feet high from finished grade) would have nighttime security lighting, consistent
with the Back Bay Landing PCDP Height Limitation Zone requirements and lighting
standards (e.g., design parameters for shielding, light spill, and fixtures). The project would
also be consistent with the Back Bay Landing PCDP design guidelines, particularly those
involving architectural theme, façade treatments, and public view considerations. The new
pump station would include aspects of the future Back Bay Landing development’s coastal
Mediterranean architectural theme (e.g., textured walls and terracotta colors) Coastal
architectural theme (i.e., varied historical vernacular and casually elegant palette) to be
consistent with its coastal urban village character. All proposed pump station infrastructure
and mechanical equipment would be screened from public right-of-way views, and the new
pump station building would not obstruct existing coastal views and would be consistent
with the Back Bay Landing Height Limitation Zone requirements and PCDP design
guidelines. Therefore, the proposed project would not conflict with any applicable zoning
or regulations governing scenic quality within an urbanized area. Less than significant
impacts would occur in this regard.
Section 5.9.4, Page 5.9-24, Last Paragraph
• Design Guidelines: The Back Bay Landing PCDP includes design guidelines covering
a range of design features, including architecture, site planning, building massing, façade treatments, landscaping, and hardscaping. The new pump station would
include aspects of the future Back Bay Landing development’s coastal Mediterranean architectural theme (e.g., textured walls and terracotta colors) Coastal
architectural theme (i.e., varied historical vernacular and casually elegant palette) to
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 2-51 Responses to Comments
be consistent with its coastal urban village character. All proposed pump station
infrastructure and mechanical equipment would be screened from public right-of-
way views, and the new pump station building would not obstruct existing coastal
views and would be consistent with the Back Bay Landing Height Limitation Zone
requirements and PCDP design guidelines.
These changes provide a minor update, correction, or clarification and do not represent
“significant new information” as defined in CEQA Guidelines Section 15088.5.
A6-11 OCSD would adhere to the City of Newport Beach Encroachment Permit approval
requirements as applicable. As stated in 2020 Recirculated Draft EIR page 3-16, the proposed
project would be required to obtain an encroachment permit from the City of Newport Beach.
This comment does not raise a significant environmental issue. No further response is
necessary.
A6-12 Refer to Response to Comment A6-1.
From:Gabrieleno Administration <admin@gabrielenoindians.org>
Sent:Tuesday, August 25, 2020 12:02 PM
To:CEQA <ceqa@ocsd.com>
Subject:EXTERNAL: Bay Bridge Pump Station and Force Mains Replacement project
Warning:This email originated from outside OCSD.Do not click links or open attachments unless
you recognize the sender and are expecting the message.
Hello Kevin Hadden
Thank you for your letter dated August 7,2020. Our Tribal government would like to consult with you
regarding the above project.
Thank you
Sincerely,
Brandy Salas
Admin Specialist
Gabrieleno Band of Mission Indians - Kizh Nation
PO Box 393
Covina, CA 91723
Office: 844-390-0787
website: www.gabrielenoindians.org
The region where Gabrieleño culture thrived for more than eight centuries encompassed most of Los Angeles County,
more than half of Orange County and portions of Riverside and San Bernardino counties. It was the labor of
the Gabrieleño who built the missions, ranchos and the pueblos of Los Angeles. They were trained in the trades, and
they did the construction and maintenance, as well as the farming and managing
are the ones who did all this work, and th
he fact that in its early decades, without the Gabrieleño,
T1-1
COMMENT LETTER T1
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 2-53 Responses to Comments
RESPONSE TO COMMENT LETTER T1
Brandy Salas, Admin Specialist
Gabrieleno Band of Mission Indians – Kizh Nation
August 25, 2020
T1-1 The Assembly Bill (AB) 52 consultation period for this project began on April 6, 2020, when
the Orange County Sanitation District (OCSD) sent notification of the AB 52 consultation
process for the Bay Bridge Pump Station and Force Mains Replacement Project (project).
Pursuant to PRC 21080.3.1(d), the 30-day period to respond to the AB 52 request for
consultation notification began on April 10, 2020. On April 22, 2020, Governor Newsom
issued Executive Order N-54-20. This Executive Order suspended the timeframes within
which a California Native American tribe must request consultation, and the lead agency must
begin the consultation process, for a period of 60 days, effective April 22, 2020. The AB 52
consultation request period for the project, which was extended an additional 60 days, ended
on July 8, 2020. At that time, OCSD did not receive a response from the Gabrieleno Band of
Mission Indians – Kizh Nation regarding a request for consultation for the purpose of AB 52.
OCSD sent notification of the availability of the Draft EIR (the Notice of Availability [NOA])
on August 7, 2020. The public review period for the 2020 Recirculated Draft EIR for the
project ended on September 21, 2020. As the Gabrieleno Band of Mission Indians – Kizh
Nation has no specific comment on the content or findings of the 2020 Recirculated Draft
EIR, no further response is required.
California Cultural Resource Preservation Alliance, Inc.
P.O. Box 54132 An alliance of American Indian and scientific communities working for
Irvine, CA 92619-4132 the preservation of archaeological sites and other cultural resources.
September 4, 2020
Kevin Hadden
OCSD
Principal Staff Analyst
RE: 2020 Recirculated Draft Environmental Impact Report for the Bay Bridge Pump Station and Force
Mains Replacement Project
Dear Mr. Hadden:
Thank you for the opportunity to comment on the above-referenced Project. We appreciate that the City of
Newport Beach and Orange County Sanitation District (OCSD) acknowledge the fact that the Newport
Beach region has a long cultural history and is culturally sensitive. While we agree that the project has a
low potential to impact archaeological resources, we have the following concerns:
(1) The Environmental Issues/Mitigation Summary Page 1.9-11 lists CUL-1 for Historical Resources and
states that no mitigation is required. The table lists Cul-2 for archaeological resources and mitigation is
required. However, throughout the remainder of the document the reader is referred to CUL-1 for
archaeological and tribal cultural resources (see pg. 5.4-15 & 5.4-16 as an example). This inconsistency
should be corrected as it leads to the erroneous conclusion that no mitigation is required for archaeological
or tribal cultural resources.
(2) Pg. 5.4-16 refers to Section
mitigation measure. First, it should be codified in California Code of
Regulations (CCR) Title 14, Ch. 3 Sections 15000 et seq.
Second, Section 15126.4 (b) (3) states that Public agencies should, whenever feasible, seek to avoid
damaging effects on any historical resource of an archaeological nature. Avoidance and preservation of
significant archaeological resources when feasible is also stated in the City of Newport Beach General
plan HR. 2.1, Newport Beach City Council Policy Manual K-5, and CLUP Policies.
Finally, since the DEIR cites Section 106 of the National Historic Preservation Act, it should be noted that
the implementing regulations (36 CFR 800.5(a)(2) (iii) along with 800.5 (a) (2) (1), as amended May
1999, acknowledge the reality that the destruction of an archaeological site and recovery of its information
no longer considered to be sufficient mitigation to
reduce the impacts to a level of insignificance. Given all this, it is unfortunate that nowhere in this
document is there any mention that a good faith effort was made to consider the feasibility of avoidance
and preservation of significant archaeological resources should they be discovered. Instead, the outdated
ion measure considered.
COMMENT LETTER O1
O1-2
O1-1
California Cultural Resource Preservation Alliance, Inc.
P.O. Box 54132 An alliance of American Indian and scientific communities working for
Irvine, CA 92619-4132 the preservation of archaeological sites and other cultural resources.
(3) Why is the discovery of human remains and Section 7050.5 of the California Health and Safety Code
relegated to Section 8.0 Effects Not Found to Be Significant? While we concur with the determination that
the potential for impacts to buried archaeological resources and human remains is low, there is just as
much potential for the discovery of pre-contact human remains as there is for archaeological resources and
Native American descendants consider the remains of their ancestors to be of great significance. In
addition, it should be noted that recently human remains were discovered during construction of an
existing freeway ramp on the 405 freeway in Orange County, so the potential for the discovery of human
remains within this large construction area should not be totally discounted.
Please take these comments into consideration in the preparation of the final EIR.
Sincerely,
Patricia Martz, Ph.D.
President
O1-3
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 2-56 Responses to Comments
RESPONSE TO COMMENT LETTER O1
Patricia Martz, PhD, President
California Cultural Resource Preservation Alliance, Inc.
September 4, 2020
O1-1 The commenter acknowledges that the California Cultural Resources Preservation Alliance,
Inc. (CCRPA) received and reviewed the 2020 Recirculated Draft EIR. While the
commenter/CCRPA generally agrees with the findings related to cultural resources and that
the project has a low potential to impact archaeological resources, the commenter states that
there is an inconsistency in the impacts for historical resources (where no mitigation is
required) and impacts for archaeological/tribal cultural resources (where mitigation is
required).
As stated in 2020 Recirculated Draft EIR page 5.4-13, Impact Statement CUL-1, according to
the City of Newport Beach General Plan EIR, no known historic resources are located within the
project area. Further, based on the records search included in the Revised Cultural/Paleontological
Resources Assessment for the Proposed Bay Bridge Pump Station and Force Mains Rehabilitation Project
(Cultural/Paleontological Assessment), prepared by Duke CRM, dated March 20, 2019
(provided in the 2020 Recirculated Draft EIR Appendix 11.4, Cultural/Paleontological
Resources Assessment), no historical resources, including those listed by the National Register,
California Register, California Historical Landmarks (CHL), and California Points of
Historical Interest (CPHI), are present in the project area. Last, the existing structures
constructed in 1966 and 1995 do not appear to rise to the threshold of significance for
eligibility in either the National Register, California Register, or City of Newport Beach as an
exceptional, distinctive, outstanding, or singular example of their type or style either
individually or as a contributor to a district. As such, the proposed project is not anticipated
to have a significant adverse effect to a historical resource.
Nonetheless, the proposed project could uncover unknown archeological resources during
construction, as discussed in 2020 Recirculated Draft EIR Impact Statement CUL-2.
Mitigation Measure CUL-1 would reduce impacts by requiring construction awareness training
and would also require construction activity to cease work in that area until a qualified
archaeologist can assess the significance of a find. If warranted, the archaeologist would be
required to collect the resource, and prepare a technical report describing the results of the
investigation. The test-level report would evaluate the site including discussion of the
significance (depth, nature, condition, and extent of the resource), identify final mitigation
recommendations that OCSD or its designee shall incorporate into future construction plans,
and provide cost estimates. Last, with compliance with the Coastal Development Permit
(CDP), issued by the California Coastal Commission and City of Newport Beach, the project
would implement any CDP conditions required by the City of Newport Beach to demonstrate
compliance with the City of Newport Beach Local Coastal Program Coastal Land Use Plan (CLUP),
including CLUP Policies 4.5.1-2 and 4.5.1-3, written as follows:
CLUP Policy 4.5.1-2 (see 2020 Recirculated Draft EIR, page 5.4-11) – Require a
qualified paleontologist/archeologist to monitor all grading and/or excavation where
there is a potential to affect cultural or paleontological resources. If grading operations
or excavations uncover paleontological/archaeological resources, require the
paleontologist/archeologist monitor to suspend all development activity to avoid
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 2-57 Responses to Comments
destruction of resources until a determination can be made as to the significance of
the paleontological/ archaeological resources. If resources are determined to be
significant, require submittal of a mitigation plan. Mitigation measures considered may
range from in-situ preservation to recovery and/or relocation. Mitigation plans shall
include a good faith effort to avoid impacts to cultural resources through methods
such as, but not limited to, project redesign, in situ preservation/capping, and placing
cultural resource areas in open space.
CLUP Policy 4.5.1-3 (see 2020 Recirculated Draft EIR, page 5.4-11) – Notify cultural
organizations, including Native American organizations, of proposed developments
that have the potential to adversely impact cultural resources. Allow qualified
representatives of such groups to monitor grading and/or excavation of development
sites.
Therefore, with implementation of Mitigation Measure CUL-1, which would ensure the
project is consistent with the requirements of the CDP and CLUP, construction impacts to
archaeological resources (including historical resources if in the unlikely circumstance of being
uncovered) would be reduced to less than significant levels.
O1-2 Refer to Response to Comment O1-1 for a discussion on project’s compliance with Mitigation
Measure CUL-1, the CDP, and the CLUP. Further, the commenter states that implementing
regulations for Section 106 of the National Historic Preservation Act acknowledges that the
destruction of an archaeological site and recovery of its information and artifacts is adverse
and data recovery is no longer considered to be sufficient mitigation to reduce the impacts to
a level of insignificance. The commenter contends that no good faith effort was made to
consider the feasibility of avoidance and preservation of significant archaeological resources
should they be discovered and instead, the outdated terminology of “salvage archaeology” is
the only mitigation measure considered in the 2020 Recirculated Draft EIR.
It is acknowledged that there are no known tribal cultural resources present on-site and
sensitivity of such resources is considered low, as analyzed in Section 5.12, Tribal Cultural Resources, of the 2020 Recirculated Draft EIR. Notwithstanding, in the unlikely event that
unknown cultural and/or tribal cultural resources are uncovered during site disturbance
activities, compliance with Mitigation Measure CUL-1 would ensure that appropriate measures
are taken.
As such, the project must comply with the requirements of the CDP and CLUP. A qualified
archeologist must monitor all grading and/or excavation where there is a potential to affect
cultural or paleontological resources. If grading operations or excavations uncover
archaeological resources, the archeologist monitor must suspend all development activity to
avoid destruction of resources until a determination can be made as to the significance of the
archaeological resource. If resource(s) are determined to be significant, OCSD would be
required to submit a mitigation plan. Mitigation measures considered may range from in-situ
preservation to recovery and/or relocation. Mitigation plans must also include a good faith
effort to avoid impacts to cultural resources through methods such as, but not limited to,
project redesign, in situ preservation/capping, and placing cultural resource areas in open
space. Thus, in addition to Mitigation Measure CUL-1, compliance with the requirements of
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 2-58 Responses to Comments
the CDP and CLUP would also ensure preservation is considered should any unknown
archeological resources be uncovered during construction.
O1-3 The commenter contends that as the potential for impacts to human remains should be just
as much as the potential for impacts to archaeological resources and tribal cultural resources,
and the commenter argues that discussions on the potential for the discovery of human
remains shall not be “relegated” to Section 8.0, Effects Found Not To Be Significant of the 2020
Recirculated Draft EIR. The commenter adds that the recently discovered human remains on
the Interstate 405 (I-405) freeway shall be evidence that the potential for impacts to human
remains should not be “totally discounted”.
As discussed in Section 8.0 of the 2020 Recirculated Draft EIR, OCSD conducted an Initial
Study/Notice of Preparation in November 2016 to determine potentially significant effects of the
proposed project; refer to Appendix 11.1, Initial Study/Notice of Preparation and Comment Letters
of the 2020 Recirculated Draft EIR. Through the course of this evaluation and preparation
of the 2020 Recirculated Draft EIR, certain impacts were identified as “less than significant”
or “no impact” due to the inability of a project of this scope and nature to yield such impacts
or the absence of project characteristics producing effects of this type. Based on existing State
regulations, including the State of California Public Resources Health and Safety Code Section
7050.5-7055 and California Public Resources Code Section 5097.98, as well as conditions
present at the time the 2020 Recirculated Draft EIR was prepared, the project would result in
less than significant impacts to human remains.
As such, the project’s potential impacts to human remains were briefly discussed in Section
8.0 of the 2020 Recirculated Draft EIR in accordance with CEQA Guidelines Section 15128.
As discussed on 2020 Recirculated Draft EIR page 8-3, Cultural Resources, threshold (c), no
conditions exist that suggest human remains are likely to be found on the project site. Due to
the level of past disturbance on-site, it is not anticipated that human remains, including those
interred outside of dedicated cemeteries, would be encountered during earth removal or
disturbance activities.
If human remains are found, those remains would require proper treatment, in accordance
with all applicable laws. State of California Health and Safety Code Section 7050.5-7055
describe the general provisions applicable to the discovery of human remains. Specifically,
Health and Safety Code Section 7050.5 describes the actions that must be taken if any human
remains are accidentally discovered during excavation of a site. As required by State law, the
requirements and procedures set forth in Section 5097.98 of the California Public Resources
Code would be implemented, including notification of the County Coroner, notification of
the Native American Heritage Commission and consultation with the individual identified by
the Native American Heritage Commission to be the “most likely descendant (MLD).” The
MLD would have 48 hours, from when site access is granted, to make recommendations to
landowners for the disposition of any Native American human remains and grave goods
found.
If human remains are found during excavation, excavation must stop in the vicinity of the
find, as well as any area that is reasonably suspected to overlay adjacent remains, until the
County coroner has been notified, the remains have been investigated, and appropriate
recommendations have been made for the treatment and disposition of the remains. Following
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 2-59 Responses to Comments
compliance with existing State regulations, which detail the appropriate actions in the event
human remains are encountered, impacts in this regard would be considered less than
significant.
As such, implementation of existing laws and regulations governing human remains (i.e.,
Health and Safety Code Section 7050.5-7055) reduce potential impacts to encountering
unknown human remains to less than significant levels and no additional mitigation is
necessary. Notwithstanding, implementation of Mitigation Measure CUL-1 and compliance
with the requirements of the CDP and CLUP would also minimize potential impacts should
unknown human remains be uncovered during construction activities.
1
Bogue, Kristen
From:CEQA <ceqa@ocsd.com>
Sent:Thursday, September 17, 2020 11:02 AM
To:Ratto, Valerie; Bogue, Kristen; Lam, Tom; Aghanian, Harmik
Subject:FW: EXTERNAL: Bay Bridge Pump Station and Force Mains Replacement Project
See below for received public comment on draft 2020 REIR.
From:James Jordan <jimcjordan@gmail.com>
Sent:Wednesday, September 16, 2020 4:38 PM
To:CEQA <ceqa@ocsd.com>
Cc:Margo O'Connor <moconn949@gmail.com>
Subject:EXTERNAL: Bay Bridge Pump Station and Force Mains Replacement Project
Warning:This email originated from outside OCSD.Do not click links or open attachments unless you recognize the
sender and are expecting the message.
September 16, 2020
Orange County Sanitation District
10844 Ellis Avenue
Fountain Valley, CA 92708
Attn.: Mr. Kevin Hadden
Re: 2020 Draft EIR
Linda Isle is located South of Dover Bridge and includes 107 waterfront homes.
The Linda Isle Community Association is concerned that Linda Isle residents will be
adversely affected by this project.
Areas of Concern:
Noise and Glare due to the construction of the two Force Mains.
Silting of Linda Isle Docks and the Linda Isle Lagoon due to soil disturbance,
resulting from the harbor dredging and the Force Mains construction.
The Linda Isle Community Association Board of Directors feel that the 2020 Draft EIR
for this project does not address possible impacts to Linda Isle.
Respectfully,
Jim Jordan, President
O2-1
COMMENT LETTER O2
O2-2
2
Linda Isle Community Association
85 Linda Isle
Newport Beach, CA 92660
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 2-62 Responses to Comments
RESPONSE TO COMMENT LETTER O2
Jim Jordan, President
Linda Isle Community Association
September 16, 2020
O2-1 The commenter asserts that the Linda Isle residents will be adversely affected by the project
and specifically expresses concern regarding construction of the two force mains.
Noise/Glare
Construction-related noise impacts to the nearest sensitive receptors, including Linda Isle
residents (located approximately 380 feet south of the project site), are discussed in 2020
Recirculated Draft EIR Impact Statement N-1. As discussed on page 5.10-16, the force main
improvements would require dredging and shoring of the walls, specifically across the
Newport Bay Channel, to lay down the dual force mains. Dredging activities would require
the use of excavator clamshell dredge/backfill equipment which produce noise levels of
approximately 77 dBA at 50 feet. Shoring of the walls could involve sonic pile driving activities
which is estimated to be 96 dBA at 50 feet.
However, dredging and sonic pile driving activities would only occur within the City of
Newport Beach permitted construction hours (7:00 a.m. to 6:30 p.m. Monday through Friday,
and 8:00 a.m. to 6:00 p.m. on Saturdays). These activities will not require 24-hour per day
construction. Additionally, as dredging occurs segment by segment across the Newport Bay
Channel, noise would atmospherically attenuate by a factor of 6.0 dBA per doubling of
distance and thus, gradually reduce noise impacts to sensitive receptors along Bayshore Drive.
Further, Mitigation Measure NOI-1 would reduce short-term construction noise impacts by
requiring construction equipment to be fitted with properly operating and maintained
mufflers. A Noise Disturbance Coordinator would also be provided.
Construction-related glare impacts to the nearest sensitive receptors are discussed under
Impact Statement AES-4 of the 2020 Recirculated Draft EIR. As discussed under Impact
Statement AES-4 (page 5.1-19) of the 2020 Recirculated Draft EIR, short-term light and glare
impacts associated with construction activities would likely be limited to nighttime lighting
(for construction and security purposes), as proposed construction of the Newport Channel
force main crossing at East Coast Highway would require 24-hour operation for a period of
two months, if the force mains are constructed by microtunneling. Further, Mitigation
Measure AES-3 would require a construction safety lighting plan, which would require
nighttime security lighting, if necessary, to be oriented downward and away from adjacent
residential areas. With implementation of Mitigation Measure AES-3 of the 2020 Recirculated
Draft EIR, impacts in this regard would be reduced to less than significant levels.
O2-2 The commenter raises concerns regarding silting of Linda Isle Docks and the Linda Isle
Lagoon due to soil disturbance as a result of dredging and force mains construction. Refer to
Response to Comment A4-1. Construction-related silting/sedimentation impacts are
discussed under Impact Statement HWQ-1 of the 2020 Recirculated Draft EIR. As discussed
on page 5.8-17 of the 2020 Recirculated Draft EIR, the project would be required to comply
with the existing State and local permitting requirements during construction (including
dredging operations), all of which would minimize construction-related impacts to water
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 2-63 Responses to Comments
quality, such as underwater silting. Specifically, the project would be required to prepare and
submit a Notice of Intent (Mitigation Measure HWQ-1), a SWPPP (Mitigation Measure
HWQ-2), and a Notice of Termination (Mitigation Measure HWQ-3) to the SWRCB
demonstrating compliance with the NPDES General Construction Permit.
The NPDES General Construction Permit requires that non-storm water discharges from
construction sites be eliminated or reduced to the maximum extent practicable, that a SWPPP
be developed governing construction activities for the proposed project, and that routine
inspections be performed of all storm water pollution prevention measures and control
practices being used at the site, including inspections before and after storm events.
Specifically, the SWPPP would include best management practices to minimize soil erosion
and siltation (underwater) on- and off-site. Examples of construction-related BMPs include
installing silt fences (which may include underwater silt fencing), sediment traps, straw bale
barriers, wind erosion/dust control, and filter berms, among others. In addition, the project
would also comply with Municipal Code Chapter 14.36, Water Quality (which establishes
regulations for the improvement of water quality) and CLUP Policy 2.8.7-2 (which requires
new development to provide adequate erosion control).
As such, with implementation of Mitigation Measures HWQ-1 through HWQ-3 and
applicable Municipal Code and CLUP standards would ensure potential erosion and siltation
impacts associated with construction activities (including dredging) are reduced to less than
significant levels.
BAYSHORES COMMUNITY ASSOCIATION
A California nonprofit mutual benefit corporation
C/o BHE Management Corporation, P.O. Box 7736, Laguna Niguel, CA 92607 363-1963
www.bayshores.org www.BHEManagement.com
September 21, 2020
Orange County Sanitation District Sent via Electronic and US Mail
e
Fountain Valley, CA 92708
Attn: Mr. Kevin Hadden
CEQA@ocsd.com
Subject: Bay Bridge Pump Station and Force Mains Replacement Project, 2020 Draft EIR
Bayshores Community Association is located North of the Dover Bridge and includes 31
waterfront homes, as well as 218 additional homes whose primary amenity and objective of
home ownership in said community is the enjoyment of the primary Association waterfront
beaches and parks.
The Bayshores Community Association is concerned that Bayshores residents will be adversely
affected by this project.
Areas of Concern:
Noise and Glare due to the construction of the two Force Mains.
Silting of Bayshores Docks and the Bayshores bayfront areas due to soil disturbance,
resulting from the harbor dredging and the Force Mains construction.
The Bayshores Community Association Board of Directors feel that the 2020 Draft EIR for this
project does not address possible impacts to Bayshores.
Respectfully,
Jack Teal, President
Bayshores Community Association
COMMENT LETTER O3
O3-1
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 2-65 Responses to Comments
RESPONSE TO COMMENT LETTER O3
Jack Teal, President
Bayshores Community Association
September 21, 2020
O3-1 The commenter is concerned that the Bayshore community residents will be adversely affected
by the project and specifically expresses concern regarding noise, glare, and silting of the
Bayshore docks and bayfront areas as a result of the construction of the two force mains
(which includes dredging operations). Please refer to Response to Comments O2-1 and O2-
2 where similar concerns are addressed.
57668419.v1
September 21, 2020
Kevin Hadden
Principal Staff Analyst
Orange County Sanitation District
10844 Ellis Avenue
Fountain Valley, CA 97208
Re: 2020 Recirculated Draft Environmental Impact Report for the Bay Bridge
Pump Station and Force Mains Replacement Project
Dear Mr. Hadden:
Our firm represents Bayside Village Marina LLC (“BVM”) and provides the following
comments with regard to the 2020 Recirculated Draft Environmental Impact Report (“REIR”) for
the Bay Bridge Pump Station and Force Mains Replacement Project (“BBPS”) (“Project”)
prepared by Lead Agency Orange County Sanitation District (“OCSD”)
We also incorporate, by reference, our prior September 3, 2019 (“2019 REIR”)comments
as well as the technical comments provided by BVM’s engineering consultants, Fuscoe
Engineering, in their letter of September 5, 2019, as additional background and support for our
comments on this 2020 Draft REIR.
Our detailed comments are as follows:
1. Project Description Issues
1.1 “Adjacent Pump Station” Project Description Omits Critical Information
We appreciate that the Draft REIR improves on the prior 2019 REIR in that the Project
Description can now clearly be ascertained from among the identified alternatives. However, the
Project Description, contrary to the requirements of CEQA (see prior comment letter), remains
somewhat imprecise and, particularly with respect to 3.1.2 Project Setting (Existing Conditions),
fails to accurately describe the existing fully developed Bayside Village Marina site, throughout
the various sections of the REIR. Moreover, the descriptions/exhibits that should set forth
precise modes of access, maintenance, force main alignments, construction staging areas, etc.,
fail to do so.
Throughout the 2020 Draft REIR the “project setting/existing conditions” are described
simply in terms of development of the expanded BBPS within, or impacts to, recreational vehicle
(“RV”) storage area (see Section 3.1.1, 3.1.2, Table 3-1, Section 5.9.1, 5.9.4 and particularly
ATTORNEYS AT LAW
18101 Von Karman Avenue
Suite 1800
Irvine, CA 92612
T 949.833.7800
F 949.833.7878
John P. Erskine
D 949.477.7633
jerskine@nossaman.com
Refer To File # 400244-0001VIA E-MAIL AND U.S. MAIL
khadden@ocsd.com
2
COMMENT LETTER O4
O4-1
O4-2
Mr. Kevin Hadden
September 21, 2020
Page 2
57668419.v1
Tables 5.9-1, 5.9-2, 5.9-3 Land Use Consistency Analyses). This grossly understates the
construction period and long-term impacts on the coastal dependent uses both existing on, and
planned for the BVM site.
Because the Project Site boundaries and work areas (also known as Temporary
Construction Easement areas, or “TCE’s”) (see Exhibit 3-2 on page 3-3 Site Vicinity, and Exhibit
3-6 on page 3-14 Adjacent Pump Station Work Areas) include or are immediately contiguous to
existing coastal recreational marine commercial uses, including the existing 220-slip Bayside
Village Marina and adjacent marina parking, Gondola Adventures, Southwind Kayaks and SUP
rentals and the single access to these recreational and marine commercial uses, these existing
uses should be identified and throughout the REIR described and impacts to and consistency
with these uses need to be evaluated.
It is important to note that the City of Newport Beach (“City”) and California Coastal
Commission (“CCC”), in approving the Back Bay Landing Projects (“BBLP”) currently under
development on the Site, and the BBL Environmental Impact Report and 2016 Back Bay Landing
Planned Community Development Plan (now adopted as part of the 2017 CCC Certified City
Local Coastal Program (“LCP”), did not account for the Adjacent Pump Station/Expand-in-Place
Option as OCSD did not identify the need to expand the BBPS until after the BBL project was
approved and the PCDP incorporated into the Certified City LCP.
1.2 Key 2020 REIR Exhibits Need Revision to Reflect Omitted Project
Description Details
Exhibit 3-5 (page 3-10) should be revised to show how OCSD will access the pump
station via N. Bayside Drive (both ingress and egress) through the existing Bayside property and
planned BBLP site. The current Exhibit 3-5 is incomplete, omits critical information/graphics, and
should be labeled “Shared Access.”
Alternatively, a new exhibit should be created showing how the estimated 15
maintenance and service trucks per week will access the adjacent/expanded BBPS. This is an
important component of the BBPS Project, and without access from N. Bayside Drive via the
BBL site, OCSD will be required to utilize the existing and substantially less safe access off of
East Coast Highway.
The Project Description notes several times throughout the REIR that access off
N. Bayside Drive through a future shared driveway with the BBLP will be the primary access to
the Adjacent Pump Station Project.
Exhibit 3-6 (page 3-14), “Adjacent Pump Station Work Areas,” identifies construction
staging areas required to be located on BVM’s property during the implementation of the BBPS
Project which, based on the discussion in Section 3.4 Construction, would occur over a 36-month
period.
Exhibit 3-6 identifies both a significant portion of the BVM property, as well as the
Castaways City property to the west of the Newport Harbor channel. Since it is not clear that the
City has agreed or is willing to provide the Castaways site for construction staging, the REIR
should identify alternative staging areas, either on or off the BVM property, for the three years of
2
2
2
O4-2
cont'd
O4-3
O4-4
O4-5
O4-6
Mr. Kevin Hadden
September 21, 2020
Page 3
57668419.v1
planned construction. Moreover, the utilization of the existing narrow and long driveway lane into
the fully developed BVM site will have foreseeable impacts on the existing BVM marina, marina
parking, and, as discussed above, recreational and marine commercial uses on the BVM site.
Construction period impacts will be even more significant if they occur during construction of the
BBL project. The REIR should identify estimated dates for start and completion of all phases of
construction, including demolition and removal of the existing BBPS. The square footage of the
TCE areas needs to be specifically identified, including access areas, timing and duration of
occupation of the TCE’s, and the direct and indirect impacts of construction on adjoining
recreational and marine commercial uses.
Footage is considered conceptual and may be subject to downward refinement
during final design.
BVM requests that OCSD design the pump station (using the most current technology
and efficient design to minimize the required expansion of the BBPS and therefore acquisition of
the City and CCC-approved BBL mixed-use project site and replacement of coastal
dependent/coastal related uses with industrial use expansion.
Such an otherwise unnecessary expansion will exacerbate the conflicts with and impacts
to the baseline of existing recreational and marine commercial uses and the approved BBL
Project as set forth in the approved BBL PCDP and the City’s 2017 certified LCP. By
characterizing the BBL site as nothing more than an RV storage facility, the Section 5.9 land use
and Coastal Act consistency analysis underestimates the impacts on both the existing dveloped
BVM site and the approved BBL land uses, and remains woefully inadequate (see also
Comments 2 and 3, September 3, 2019 BVM REIR Comment Letter).
2. Force Mains Location Renders BBL South of East Coast Highway Site Unusable
Exhibit 3-7 (page 3-15) depicts the OCSD dual 24’ force mains alignment bisecting the
BBL property south of the E. Coast Highway bridge essentially in half. This approximate .60 acre
property is within BBL PCDP Planning Area 2 and allows 8,390 square feet of CM (recreational
and marine commercial) uses. Due to indicated restrictions on permanent structures above the
force mains and required setbacks, such an alignment would severely impact BVM’s ability to
develop anything on the site, consistent with its CM land use designation.
As previously discussed with OCSD staff, OCSD should identify an alternative alignment
closer to the south edge of the BBL property, adjacent to the Irvine Co. parking lot, which will
reduce impacts to this important CM-designated property.
3. OCSD Must Provide Greater Specificity Regarding Site Operations and Utilization
of Shared Access
Section 5.7.4 (page 5.7-20) briefly identifies “Operations” and notes a maximum of 15
trips for chemical deliveries, periodic maintenance and inspections per week (or 60 per month).
BVM recognizes the size and type of truck differs for various maintenance requirements. OCSD
must provide a more detailed breakdown of the anticipated maintenance frequency based on the
size and type of truck and projected hours/time of access through the BBL site. OCSD must not
2
2
2
&217
O4-6
cont'd
O4-7
O4-8
O4-9
Mr. Kevin Hadden
September 21, 2020
Page 4
57668419.v1
only acquire a permanent easement for this access, but must fund short- and long-term
maintenance of the amenitized BBL project access.
4. Consistency With Back Bay Landing Planned Community Development Plan
As set forth in our September 3, 2019 Comment Letter (page 7), Planning Area 1 of the
BBL PCDP permits the BBPS with its current size and location (see the PCDP Table 2, Exhs. 3,
5, 9, 12). The PCDP does not contemplate any expansion of relocation of the BBPS (ibid).
Moreover, the LU-5 (2020 REIR, page 5.9-24) discussion in the REIR incorrectly infers
that any pump station in any location within PA-1 is a permitted use as a matter of right, in
stating, “Accordingly, the pump station is a permitted use as a matter of right.” The BBPS
Adjacent Pump Station expansion project is subject to all of the discretionary permits and
regulatory approvals outlined in Section 3.6 Permits and Approvals (page 3-16 and 3-17 of the
REIR), and during Site Development Review, this Adjacent Expand-in-Place must be shown to
be consistent with all of the requirements of the BBL PCDP. Only the original Rehab-in-Place
alternative is identified in the BBL PCDP.
In regards to the Site Development Review process, and consistency with the PCDP,
Mitigation Measure AES-1 requiring engineering drawings and specifications prepared by the
Project Engineer or their designee to be “submitted for review and approval by the OCSD
Director of Engineering,”and AES 2-4 requiring only a similar internal review process for
assessment of visual and aesthetic impacts, are inadequate. These, and any other BBPS
project drawings, plans, operational programs and improvement documents must be submitted
to BVM at the earliest possible date, prior to any OCSD approval, and all mitigation measures
must be revised to assure their occurs.
We look forward to working with OCSD to address these and other BBPS Adjacent Pump
Station REIR and Project issues, and look forward to your agency’s response to these and other
comments.
Sincerely,
John P. Erskine
Nossaman LLP
JPE:dlf
cc: Valerie Ratto, P.E., OCSD (vratto@ocsd.com)
O4-9
cont'd
O4-10
O4-11
O4-12
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&217O4-13
cont'd
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A?PK:L?^UM^UB?^NPMF?=U^WIUEK:U?J[^:NNPMX?>^":U^N^ ^
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^
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:L:I[\?>^DL^UB?^ ^$:[^$PE>A?^'+3^ #! !*"!*!"& & "!*"'&" %*
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"
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:L:I[TDT^@MP^UB:U^NP?@?PP?>^:IU?PL:UEX?^5B?^@:DIWP?^UM^E>?LUD@[^:^NP?@?PP?>^NPMF?=U^:JU?PL:UDX?^
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%B:P:=U?PDTUD=T^DT^=ML@WTELA^?ZUP?K?I[^>E@@D=WIU^UM^@MIJMY^:L>^I:=HT^=PEUD=:I^DL@MPK:UDML^
L?=?TT:P[^UM^:JJMY^UB?^NW<IE=^:L>^P?XE?YELA^:A?L=E?T^UM^?X:IW:U?^:L>^P?XE?Y^DUT^?LXDPMLK?LU:I^
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NW<IE=^UM^WL>?PTU:L>^UC?^?LXDPMLK?LU:I^EKN:=UT^M@^UB?^NPMNMT?>^NPMF?=U^%'2#^)WE>?JDL?T^
] ^>ET=WTTEML^ +U^>M?T^LMU
5B?^1PMF?=U^&?T=PENUDML^ET^WL=J?:P^YEUB^P?A:P>^UM^UB?^:=UW:I^TD\?^TOW:P?^@MMU:A?^M@^UB?^
X:PEMWT^:JU?PL:UEX?T^NPMF?=U^:P?:^:L>^UB?^>DK?LTEMLT^:L>^IM=:UDML^M@^UB?^:LUE=EN:U?>^N?PK:L?LU^
>PEX?Y:[^:==?TT^?:T?K?LU^UB:U^/%4&^NWPNMR?>I[^ELU?L>T^UM^M<U:DL^ML^UC?^$:=H^$:[^,:L>DLA^
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^TOW:P?^@??U^EL^:P?:^YMWJ>^DL=IW>?^:^ ^TOW:P?^@MMU^
,&217O4-13
cont'd
N>NQ]=NMUQNJ]@;=DJDU[ ];]<;=IVO]B?M?Q;UNQ ];M>]YNWK>]Q?PWEQ?];] ]O?QL;M?MU]>QEX?Y;[];==?TT]
?;T?L?MU]@QNL]%%.] 5(+5];U]OO]
]
] 0N]<WDJ>EMB]@NNUOQEMU]@NQ]UC?]OWLO]TU;UDNM]DUT?K@]ET]
OQNXE>?>]@NQ];M[]N@]UC?]UCQ??];JU?QM;UEX?T]=NM=?OUV;J]TEU?]OK;MT] 5(+5];U]O] ]:UC?]OVLO]
TU;UENM]ELOQNX?L?MUT]@NQ]UC?]/N>D@D?>]0NQUC?;TU]3WLO]6U;UDNM];KU?QM;UEX?]YNVK>]<?]UC?]T;L?]
;T]UCNT?]OQNONT?>]@NQ]UC?]2QEBDM;K]0NQUC?;TU]3WLO]6U;UDNM ];JU?QM;UDX?
]YEUC]TNL?]=C;MB?T]UN]
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] 2@]?X?M]BQ?;U?Q]=NM=?QM ]UC?]>?T=QEOUENM]N@]UC?]6NWUC]3VLO]6U;UENM];KU?QM;UDX?]
@;DJT]?MUDQ?K[]UN]OQNXD>?]UC?]TPV;Q?]@NNU;B?]N@]UC?]TDU?
];B;EM]DM>D=;UEMB]NMJ[]UC;U]UC?]OWLO]TU;UENM]
ELORNX?L?MUT]YNVJ>]<?]UC?]T;L?];T]UCNT?]OQNONT?>]WM>?Q]UC?]2QDBDM;K]0NQUC?;TU]3VLO]
6U;UENM];M>]/N>E@D?>]0NQUC?;TU]3VLO]6U;UENM ]EM=KV>EMB];]O?QL;M?MU]>QEX?Y;[];==?TT]
?;T?L?MU]N@]VMTO?=D@D?>]TE\?] 5(,5];U]O]
] 7C?]
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OQNXD>?>]EM]UC?]0NUE=?]N@]3Q?O;Q;UENM]@NQ]UC?]5(,5];M>]@NQ]UC?]OQ?@?QQ?>];KU?QM;UDX?]DM]UC?] ]
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>?T=QE<?>]NUC?Q];Q?;T]N@]>ETUVQ<;M=?];M>]UC?]KN=;UENM];T]Y?KK];T]UC?]VT?];M>]DMBQ?TT];M>]
?BQ?TT]ONEMUT]@NQ]UC?]U?LONQ;Q[]=NMTUQV=UENM]?;T?L?MUT]7CET]EM@NQL;UDNM]DT]M?=?TT;Q[]UN];KKNY]
UC?]OV<KE=];M>]2&6']UN]?X;KV;U?]UC?]?MXDQNML?MU;K]DLO;=UT]N@]UC?]3QNG?=U];M>]UC?];X;EJ;<EKEU[]N@]
ONU?MUE;KK[]@?;TD<K?];KU?QM;UDX?T];M>]LDUEB;UENM]L?;TWQ?T ];T]EJJVTUQ;U?>]<?JNY
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&N;TU;K]3QNBQ;L].;M>]8T?]3K;M] .83
]
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EM>E=;U?>]UN]<?] ]LNMUCT ]UC?]5(,5]@;DJT]UN]>ET=JNT?]UC?];MUD=EO;U?>]>VQ;UENM]N@]=NMTUQV=UDNM]@NQ]
UC?]3VLO]6U;UDNM]ELOQNX?L?MUT]@NQ]UC?]2QDBEM;J]1NQUC?;TU]3VLO]6U;UDNM]OK;M],@]UC?]2QEBEM;J]
;M>]/N>E@E?>]0NQUC?;TU]3WLO]6U;UDNM]ELOQNX?L?MUT]YEKK]U;I?] ]LNMUCT]UN]=NLOK?U?] 5(,5];U]
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9NQI]$Q?;]@NQ]UC?]2QEBEM;K]0NQUC?;TU]3VLO]6U;UDNM] =NLO;Q?])DBVQ?] !]UN](ZCD<DUT] ]
]
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6NVUC]3WLO]6U;UDNM]YNWK>]<?]TELEK;Q]UN]UC;U]N@]UC?]2QDBEM;K]0NSC?;TU]3VLO]6U;UENM];M>]
/N>E@D?>]0NQUC?;TU]3VLO]6U;UDNM#] 5(,5];U]O]
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?;T?L?MUT]UN]?M;<K?]UC?]OW<KE=];M>]>?=ETDNML;I?QT]UN]?X;KW;U?]Q?TVKUEMB]?MXEQNML?MU;J]
DLO;=UT];M>]UC?]@?;TD<DJEU[]N@]LEUDB;UDNM];M>];JU?QM;UEX?T]7C?]TD\?];M>]=NM@EBWQ;UENM]N@]UC?]
TU;BDMB];Q?;T];M>]UC?]UDL?KEM?]@NQ]=NMTUQW=UDNM]YEKK]>EQ?=UK[];A@?=U]UC?]3QNF?=UT]?MXDQNML?MU;J]
DLO;=UT
]O;QUD=VJ;QK[]YEUC]Q?B;Q>]UN]MNDT?];M>]XE<Q;UDNM]ELO;=UT]NM];>H;=?MU]VT?T];M>]UC?]
,
&217
O4-13
cont'd
UDBNDAE>;OV_I;N?_WU@_>POAID>VU_YEVC_VC@_>P;UV;I?@Q@N?@NV_;O?_S@>S@;VDPO;J__M;SEO@_>PMM@S>D;J_
J;N?_WU@U_PO_VC@_&&/_QSPQ@SV[_
((
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>;Q;>EV[_PA_VC@_A;>EJEV[_;O?_EU_OPV_@ZQ@>V@?_VP_S@UWJV_DN_DN>S@;U@U_EO_Q@;H_AJPYU_5),5_;V_Q_
_)IU@YC@S@
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.WJ[_!_QW=JE>_S@XE@Y_M@@VENB_VC;V_?WSENB_VC@_(PX@SVP1@YQPSV_&PWJ@X;S?_APS>@_M;EN_@ZV@OUEPN_
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>;Q;>DV[_PA_VC@_A;>EJEV[ _;S@_QS@U@OV_7CWU _VC@_3SPG@>V_YPWI?_NPV_DO?W>@_BSPYVC_@DVC@S_?DS@>VJ[_PS_
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6PWVC_3WMQ_6V;VEPN_;IV@SO;VEX@U_6@@ _@B _ ! _ 7C@_WU@_PA_C[QPVC@VE>;I_>PN?EVDPOU_DN_VCDU_
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,&217
O4-13
cont'd
-CbIUj*=AACUj
5CX_CS>C\jj!j
1=FCj j
Y\WMD@` jdJ`Hj`HDj%%26jKVjJ`^j@a[[DV`jPW@=`JWV j=^j=V`K@KY=`DBjaVBD\j`HDj2&'2
j 7HDjEa`a[Dj^K`Dj
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DEED@`^jWEjDeY=VBJVGj=VBj\DPW@=`JVGj`HDj%%26j7HDj4(,4j^HWaPBj@PD=[QfjKBDV`KEfj`HDj?=^DQKVDjEW\j
D=@Hj@=`DGW[fjWEjDVcK\WVTDV`=PjKTY=@`^j=VBjDeYQ=KVjdHfjK`jJ^ja^KVGj`H=`j?=^DPJVDj
&
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O4-13
cont'd
'-+C1<;LL
#+-);.?<;DL6);,LBE2D)*6-L.<?L?-+?-)C2<;)6LEB-LB0)66L*-L=?<D-+C-,L.<?L?-+?-)C2<;)6L
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<?L+<9:-?+1)6L?-+?-)D1<;)7L)+C1F2C1-BLD0)CL+<E6,L*-L)++<::<,)C-,L<;LC0-L
=?<=-?DIL 2BL)6?-),IL ),->E)C-7IL =?<F1,-,L.<?L1;LC0-L)?-)
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&217O4-13
cont'd
7EB_5*,5_>KWR_C>FKW_XR_AFW@YWW_XEB_3URHB@XW_GP@RPWFWXBP@]_[FXE_(R>WX>K_&@X_WB@XFRP_
! _WY?AGZGWFRP_ B
_RC_XEB_(R>WX>K_&@X _[EG@E_SURZFABW_XE>X_PB[_ABZBKRSOBPX_WE>LL _[EBUB_
>SSURSUF>XB _SURXB@X_WSB@F>K_@ROOYPFXFBW_>PA_PBFDE?RUERRAW_XE>X _?B@>YWB_RC_XEBGU_YPGTYB_
@E>U>@XBUFWXG@W
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_
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CGWEGPD _J>]>JFQD _AGZFPD
_[FPA_WYUCGPD _W>FL?R>X_U>@FPD_B\@YUWGRP _>PA_BPXBUX>GPOBPX_?R>X_
>@XGZGXFBW _>W_[BLL_>W_ZFWGXRUWBUZFPD_@ROOBU@F>L_>PA_UB@UB>XGRP>L_YWBW_>PA_[>XBUCURPX_UBWFABP@BW_
6BB_5*,5_>X_S_ _
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O4-13
cont'd
6F6CQR:9TOGMC9T8C:6JDQTD:KK:FTL=:T:FN>JGFE:FL6DT>EH68LKTG;TL=:T.JG@:8L T7MLTL=:T.JG@:8LKT
HJGHGF:FLKT9:8D?F:TLGT69GHLT?L4 T
"
""
""
"
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G;TL=:THJGHGK:9THJGA:8LT
.M7T0:KGMJ8:KT&G9:
TSST T3HM7D>8T6<:F8>:KTK=GMD9TFGLT6HHJGN:T
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&217O4-13
cont'd
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,
&217O4-13
cont'd
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cont'd
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O4-13
cont'd
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O4-13
cont'd
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 2-83 Responses to Comments
RESPONSE TO COMMENT LETTER O4
John P. Erskine
Nossaman LLP
September 21, 2020
O4-1 The commenter has attached a previous comment letter and technical comments (prepared
by Fuscoe Engineering, dated September 5, 2019) submitted as part of the 2019 Recirculated
Draft EIR(both enclosed herein as Comment O4-13), as additional background and support
for the comments provided in Letter O4, which are responded to herein. It should be noted
that OCSD recirculated the entire Draft EIR and required reviewers to submit new comments
on the 2020 Recirculated Draft EIR (2020 Recirculated Draft EIR page 2-4, first paragraph),
pursuant to CEQA Guidelines Section 15088.5(f)(1). OCSD is not required to respond to
those comments received during the earlier circulation period for the Bay Bridge Pump Station and Force Mains Replacement Project Draft Environmental Impact Report (2017 Bay Bridge EIR) or
Bay Bridge Pump Station and Force Mains Replacement Project Draft Recirculated Environmental Impact Report (2019 Recirculated EIR). Although the prior comments are part of the administrative
record, the previous comments do not require a written response in this Final EIR, unless
otherwise specified in the Response to Comments O4-2 through O4-13.
O4-2 The commenter asserts that the “Adjacent Pump Station” Project Description (the entirety of
Section 3.0, Project Description, of the 2020 Recirculated Draft EIR) omits critical information.
The commenter alleges that, as stated in the 2019 comment letter (refer to Comment O4-13),
the Project Description “remains somewhat imprecise” because the 2020 Recirculated Draft
EIR in general, and 2020 Recirculated Draft EIR Section 3.1.2, Project Setting (Existing
Conditions) in particular, fail to “accurately describe the existing fully developed Bayside
Village Marina site.”
The comment does not specify which aspect of Section 3.1.2, Project Setting, is allegedly
inaccurate, or provide any specific references to those components of the “fully developed
Bayside Village Marina site” that it asserts have not been described accurately. To the extent
this comment refers to the existing recreational marine commercial uses, see Response to
Comment O4-3.
Nonetheless, at its most basic level, CEQA requires an analysis of how a proposed project will
change the existing environmental conditions, also known as the environmental baseline.
(CEQA Guidelines Section 15125(a); Neighbors for Smart Rail v. Exposition Metro Line Construction
Authority (2013) 57 Cal.4th 439, 447.) For these purposes, “the lead agency should describe physical environmental conditions as they exist at the time the notice of preparation is published.” (CEQA Guidelines
Section 15125(a)(1).) Here, at the time of the Notice of Preparation (NOP) was published
(November 2016), the project site consisted of an existing pump station facility and a
recreational vehicle (“RV”) storage area. As required by CEQA, these existing conditions are
documented in the 2020 Recirculated Draft EIR Section 3.1, Project Location and Setting, and
were utilized as the environmental baseline for analysis.
Though unclear, the commenter is potentially suggesting that the environmental baseline in
the 2020 Recirculated Draft EIR should be comprised by something other than the existing
environmental conditions at the time the NOP was published. For example, the commenter
is suggesting that the approved, but not yet constructed, Back Bay Landing Project plan should
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Final ● January 2021 2-84 Responses to Comments
have been utilized as the existing condition. The commenter provides no authority for this
proposition. To the contrary, CEQA Guidelines Section 15125(A)(3) states that, “An existing
conditions baseline shall not include hypothetical conditions, such as those that might be allowed, but have never actually occurred.”].) As a practical matter, the Back Bay Landing Project has been a publicly
known development since 2012. It is unclear when, if ever, the Back Bay Landing Project will
come to fruition despite OCSD’s repeated attempts to obtain this information from the
applicant team for the Back Bay Landing Project. For all of these reasons, OCSD was not
required to use the Back Bay Landing Project plan as the existing conditions environmental
baseline for this project as potentially implied by the comment.
On the other hand, CEQA requires an analysis of a project’s cumulative impacts when
“viewed in connection with the effects of past projects, the effects of other current projects,
and the effects of probable future projects.” (Public Resources Code Section 21083). For this
reason, the approved Back Bay Landing Project was included in the 2020 Recirculated Draft
EIR Cumulative Projects List, Project No. 5, as a “probable future project” (see 2020 Recirculated
Draft EIR page 4-2, Table 4-1). Pursuant to CEQA Guidelines Section 15130(a), Section 5.0,
Environmental Analysis, of the 2020 Recirculated Draft EIR assesses the potential cumulative
impacts for each applicable environmental issue, including each impact’s severity and
likelihood of occurrence.
Further, the 2020 Recirculated Draft EIR analyzes the project’s consistency with the approved
Back Bay Landing PCDP. As explained in great detail in the 2020 Recirculated Draft EIR
Section 5.9, the project would be consistent with the Coastal Act, LCP/CLUP, SCAG regional
plans, and the Back Bay Landing PCDP.
The commenter also states that the 2020 Recirculated Draft EIR descriptions/exhibits should
set forth precise modes of access, maintenance, force main alignments, construction staging
areas, etc., but fail to do so. The requested information, however, was provided in the 2020
Recirculated Draft EIR Section 3.3, Project Characteristics.
Specifically, page 3-8 of the 2020 Recirculated Draft states that the primary access to the
proposed pump station would be provided via a shared driveway from Bayside Drive through
Bayside Village Marina, LLC property with secondary access via the existing driveway from
East Coast Highway, as detailed on Exhibit 3-5, Adjacent Pump Station Layout. These access
points would be used by maintenance vehicles. As the pump station is an existing operating
facility, proposed maintenance activities would be similar to the existing condition. Force
main improvements are detailed on page 3-12, Force Main Improvements, and the proposed
alignment is shown on Exhibit 3-4, Proposed Conceptual Site Plan. Construction activities for the
force mains are also detailed on page 3-13, Force Main Improvements, and shown on Exhibit 3-7, Adjacent Pump Station Construction. Last, construction staging is described on page 3-12 and
depicted on Exhibit 3-6, Adjacent Pump Station Work Areas. Although specific staging areas are
not known at this time, existing surrounding properties that could possibly accommodate
staging were considered for the purposes of analyzing potential environmental impacts. These
areas include portions of the Back Bay Landing property (currently a RV storage area) and
Lower Castaways Park, should these areas be available during construction of the proposed
project.
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O4-3 The commenter alleges that the Project Description “remains somewhat imprecise” because
the 2020 Recirculated Draft EIR in general, and 2020 Recirculated Draft EIR Section 3.1.2,
Project Setting (Existing Conditions) in particular, fail to accurately describe the existing
recreational and marine commercial uses at the site. However, the 2020 Recirculated Draft
EIR Table 3-1, Surrounding Land Uses, on page 4-2, describes the surrounding land uses and
associated land use and zoning designations, including the surrounding recreational marine
uses. These existing uses are discussed, and impacts are analyzed, where relevant, throughout
Section 5.0, Environmental Analysis, of the 2020 Recirculated Draft EIR.
Further, the commenter suggests that existing coastal recreational marine commercial uses
(situated at the western terminus of the existing access road north of the project site) would
be impacted by project construction. As shown on Draft EIR Exhibit 3-6, Adjacent Pump
Station Work Areas, access to these off-site uses would be maintained during construction of
the proposed project, and as discussed above, impacts to these existing surrounding uses are
analyzed, where relevant, throughout Section 5.0 of the 2020 Recirculated Draft EIR. Further,
it is acknowledged that, although these uses are recreation in nature, these uses are marine
commercial uses and recreators would be using the Newport Bay Channel for recreating
purposes. Per the 2020 Recirculated Draft EIR, no significant impacts to these off-site uses
would result with implementation of recommended mitigation measures.
O4-4 The commenter states that the City of Newport Beach (City) and California Coastal
Commission (CCC), in approving the Back Bay Landing Project, the Back Bay Landing
Environmental Impact Report, and 2016 Back Bay Landing Planned Community
Development Plan (now adopted as part of the 2017 CCC Certified City Local Coastal
Program (“LCP”), did not account for the Adjacent Pump Station/Expand-in-Place Option
as OCSD did not identify the need to expand the existing pump station until after the Back
Bay Landing project was approved and the Planned Community Development Plan
incorporated into the Certified City LCP. The comment is noted. This comment does not
identify a significant environmental issue. No further response is required.
O4-5 OCSD currently utilizes the existing access to the pump station from East Coast Highway. As
discussed throughout the 2020 Recirculated Draft EIR, similar to existing conditions, the
project would require up to 15 maintenance vehicle trips per week for periodic maintenance
and inspections by OCSD staff, and no new vehicle maintenance trips would be required as a
result of the proposed project. No new employees would need to be hired as part of the
project.
The commenter is correct in that the proposed shared access from N. Bayside Drive (a future
shared driveway with the Back Bay Landing Project), depicted on Exhibit 3-5, Adjacent Pump Station Layout, would be the primary access to the proposed pump station (although secondary
access from East Coast Highway would also be available). The proposed shared access would
increase safety for OCSD Operations and Maintenance personnel, compared to the existing
condition.
The allegedly omitted information is already provided in the environmental document. 2020
Recirculated Draft EIR page 5.11-9, Operations, states that, “Currently, primary site ingress and
egress for OCSD maintenance vehicles is provided via a right turn only driveway from East
Coast Highway. Maintenance trucks must currently back into oncoming traffic on East Coast
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Highway to exit the site. As shown on 2020 Recirculated Draft EIR Exhibit 3-5, Adjacent Pump Station Layout, the project would increase transportation safety by redirecting OCSD vehicles
through the Bayside Village Marina, LLC property via Bayside Drive for primary site access,
both ingress and egress, with secondary site access provided via the existing driveway along
East Coast Highway. As such, impacts in this regard would be less than significant.”
Further, one of the project’s goals/objectives is to increase the safety for OCSD Operations
& Maintenance personnel by selecting an entry to and exit from the site that can be accessed
more easily and safely by maintenance crews and drivers. As such, these considerations are
also analyzed in the 2020 Recirculated Draft EIR Section 7.0, Alternatives, which concludes
that although the “Rehabilitate in Place with Microtunneling” Alternative is environmentally
superior to the proposed project, this alternative would not increase safety for OCSD
Operations & Maintenance personnel by providing safer access (a goal/objective of the
proposed project).
O4-6 Refer to Response to Comments O4-2 and O4-3. Existing surrounding properties that could
possibly accommodate staging, including portions of the Back Bay Landing property and
Lower Castaways Park, were analyzed for the purposes of potential environmental impacts.
If these areas are not available during construction of the proposed project, construction
staging would instead occur within proposed areas of disturbance (as identified by the project
boundary shown on 2020 Recirculated Draft EIR Exhibit 3-4, Proposed Conceptual Site Plan).
The 2020 Recirculated Draft EIR acknowledges that nearest cumulative projects to the project
site include the Back Bay Landing project, Balboa Marina West Expansion project, Bay
Crossing Water Main Replacement project, and Newport Dunes Hotel project. It is unknown
at this time when these projects would be constructed. Specifically, as discussed above under
Response to Comment O4-2, it is unclear when, if ever, the Back Bay Landing Project will
come to fruition despite OCSD’s repeated attempts to obtain this information from the
applicant team for the Back Bay Landing Project. As such, it would be speculative to identify
the estimated start and stop dates for construction of the Back Bay Landing Project.
Nevertheless, the 2020 Recirculated Draft EIR assumes that the project’s construction
activities could overlap with any or all of these projects, which is a conservative assumption
for construction activities. Section 5.0, Environmental Analysis, of the 2020 Recirculated Draft
EIR assesses the cumulative impacts for each applicable environmental issue, including each
impact’s severity and likelihood of occurrence. More specifically, the cumulative air quality,
noise, and transportation impacts from the proposed construction activities of project have
been addressed in Sections 5.2.5, Cumulative Impacts (pages 5.2-26 and 5.2-27), 5.10.5, Cumulative
Impacts (pages 5.10-21 through 5.10-23), and 5.11.5, Cumulative Impacts (pages 5.11-12 through
5.11-14), of the 2020 Recirculated Draft EIR, respectively. For the cumulative air quality,
noise, and transportation construction-related impacts from the Back Bay Landing Project,
refer to Section 4.B.4, Cumulative Impacts (pages 4.B-39 and 4.B-40), 4.J.3, Cumulative Impacts
(pages 4.J-34 and 4.J-35), and 4.M.4, Cumulative Impacts (pages 4.M-42 and 4.M-43) of the Back
Bay Landing EIR, respectively.
Further, the exact size and location of temporary construction easements may change as the
project design progresses. As such, the 2020 Recirculated Draft EIR intentionally identifies a
large work area as shown on 2020 Recirculated Draft EIR Exhibit 3-6, Adjacent Pump Station
Work Areas, to conservatively analyze the project’s potential temporary construction impacts.
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O4-7 The 2020 Recirculated Draft EIR analyzed the proposed pump station improvements
currently being considered by OCSD. The 2020 Recirculated Draft EIR also acknowledged
that the pump station’s square footage may be refined during the project design phase as part
of the final design process. The commenter requests that OCSD minimize the expansion of
the pump station. This comment is acknowledged and will be considered by OCSD during
the final design process.
Regarding the project’s consistency with the City and California Coastal Commission plans,
refer to Section 5.9, Land Use and Relevant Planning, Impact Statement LU-1 (California Coastal
Act, page 5.9-7), Impact Statement LU-2 (Local Coastal Program and Coastal Land Use Plan,
page 5.9-13), Impact Statement LU-4 (City of Newport Beach General Plan, page 5.9-21), and
Impact Statement LU-5 (Back Bay Landing PCDP, page 5.9-23). As demonstrated by the
2020 Recirculated Draft EIR, the proposed project would be consistent with the relevant
California Coastal Act policies, the City of Newport Beach Local Coastal Program and associated
City of Newport Beach Coastal Land Use Plan (CLUP), City of Newport Beach General Plan goals and
policies related to land use and planning, and the applicable provisions of the Back Bay
Landing PCDP Planned Community 9 (PC-9). A Site Development Review Permit, among
other discretionary approvals, would be required from the City to ensure consistency with the
site’s Back Bay Landing PCDP zoning, as stated on 2020 Recirculated Draft EIR page 3-16,
Section 3.6, Permits and Approvals. Impacts pertaining to land use consistency with applicable
plans were determined to be less than significant.
The 2020 Recirculated Draft EIR Table 5.9-2, Local Coastal Program/Coastal Land Use Plan Consistency Analysis, provides an analysis of the proposed project’s consistency with the relevant
CLUP policies, and Impact Statement LU-5 provides an analysis of the proposed project’s
consistency with the relevant Back Bay Landing PCDP development standards and design
guidelines. Per the consistency analysis presented on pages 5.9-14 and 5.9-25 of the 2020
Recirculated Draft EIR, the operations of the pump station facility are not anticipated to result
in significant impacts to existing recreational and marine commercial uses. Further, as stated
on page 5.9-25 of the 2020 Recirculated Draft EIR, a Site Development Review Permit, among
other discretionary approvals, would be required from the City to ensure consistency with the
site’s Back Bay Landing PCDP zoning. Refer to Response to Comments O4-2 and O4-3
regarding consideration of the existing condition and recreational and marine commercial uses.
In the 2019 Comment Letter No. 2 (Comment O4-13, pages 5 and 6), the commenter suggests
that the 2019 Recirculated Draft EIR fails to identify the baseline, uses inconsistent baselines,
and appears to improperly use an alternative as the baseline for measuring impacts. Refer to
Response to Comment O4-2 pertaining to the existing conditions baseline and cumulative
conditions analyzed in the 2020 Recirculated Draft EIR. The commenter also states that the
significance of environmental impacts of the project should be measured against existing
conditions and future site conditions under the City’s land use plan, including the Back Bay
Landing development project, with the pump station in its current location, as anticipated in
the Back Bay Landing PCDP. Please refer to Response to Comment O4-10 pertaining to
permitted uses for the project site.
Regarding the 2019 Comment Letter No. 3 (Comment O4-13, pages 6 through 11), the
commenter suggests that the 2019 Recirculated Draft EIR fails to adequately evaluate the land
use and coastal resources impacts of the project. Specifically, the commenter states that the
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Final ● January 2021 2-88 Responses to Comments
2019 Recirculated Draft EIR fails to discuss the inconsistencies between the proposed pump
station location and the policies in the Coastal Act and the City’s Coastal Land Use Plan
(CLUP) related to maximizing visitor-serving and coastal-dependent uses at the project site.
Section 5.9, Land Use and Relevant Planning, of the 2020 Recirculated Draft EIR, includes a
robust analysis of the project’s consistency with the Coastal Act and City’s Local Coastal
Program (LCP) and CLUP. 2020 Recirculated Draft EIR Table 5.9-2, Local Coastal Program/Coastal Land Use Plan Consistency Analysis, shows the proposed pump station site is
designated “Mixed-Use Water Related” (MU-W2). The MU-W2 category is intended to
provide for commercial development on or near the bay in a manner that will encourage the
continuation of coastal-dependent and coastal-related uses and visitor-serving uses, as well as
allow for the development of mixed-use structures with residential uses above the ground
floor.
As discussed on 2020 Recirculated Draft EIR page 5.9-14, the Municipal Code authorizes
Planned Community Development Plans (PCDPs) to address land use designations and
regulations in the City’s Planned Communities such as the Back Bay Landing Planned
Community (PC-9); refer to Municipal Code Section 20.56.010, et seq. The Back Bay Landing
PCDP serves as the controlling zoning for the Back Bay Landing Planned Community and is
authorized and intended to implement the provisions of the General Plan and Coastal Land
Use Plan (Back Bay Landing PCDP, page 1, section I[A]).
The Back Bay Landing Planned Community is comprised of five planning areas, including a
Mixed-Use Area (PA 1). The pump station is located within PA 1. As stated in the Back Bay
Landing PCDP, Table 2, Permitted Uses, a wastewater pump station is a permitted use within
PA 1. Accordingly, the proposed pump station facility is a permitted use as a matter of right,
and the project would be consistent with this policy. It should also be noted that the proposed
project would replace an existing pump station facility in the same general area to continue
operating like existing conditions. No new uses are proposed that would conflict with existing
and planned uses for the project area under the CLUP/LCP.
O4-8 Although the proposed project would require a permanent easement from Bayside Village
Marina, LLC (2020 Recirculated Draft EIR page 3-16, Section 3.6, Permits and Approvals),
OCSD maintains an existing permanent easement at the approximate 0.60-acre southern
portion of the Back Bay Landing property; refer to 2020 Recirculated Draft EIR Exhibit 3-6, Adjacent Pump Station Work Areas. This easement has been in-place since March 8, 1971, prior
to approval of the Back Bay Landing PCDP. This easement was established in order for
OCSD to maintain access to the site and includes the terms, “… any structures… placed upon,
over, across, or along, … said easement by Grantor which injures the sewer or interferes with
the use thereof, shall be removed by the Grantor at its expense…” These are existing
conditions imposed at the project site.
The commenter’s concerns regarding specific siting of the proposed permanent easement
through the Back Bay Landing Property is acknowledged and will be considered by the OCSD
as part of the project’s final design phase. This comment does not involve a significant
environmental issue. No further response is required by CEQA.
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 2-89 Responses to Comments
O4-9 Refer to Response to Comment O4-5 pertaining to proposed maintenance vehicles. The
proposed project would require permanent easement from Bayside Village Marina, LLC (2020
Recirculated Draft EIR page 3-16, Section 3.6, Permits and Approvals). As in the existing
condition, up to 15 maintenance vehicle trips per week may occur for periodic maintenance
and inspections by OCSD staff during OCSD’s current operational hours. It is acknowledged
that any permanent easement rights would be negotiated with Bayside Village Marina, LLC as
part of the permitting/design phase of the project. This comment does not raise an issue or
comment specifically related to the 2020 Recirculated Draft EIR’s environmental analysis.
Therefore, no further response is required by CEQA.
O4-10 The commenter states that Planning Area 1 (PA 1) of the Back Bay Landing PCDP “permits
the Back Bay Pump Station with its current size and location” and that the Back Bay Landing
PCDP “does not contemplate any expansion of [sic] relocation of the Back Bay Landing Pump
Station,” citing to the Back Bay Landing PCDP Table 2 and Exhibits 3, 5, 9, and 12 as support.
However, Table 2 of the Back Bay Landing PCDP simply notes that a Wastewater Pump
Station is a permitted use in Planning Areas 1 and 2, and makes no statement as to whether
that use is restricted to the existing location of the Back Bay Landing Pump Station. See Back
Bay Landing PCDP page 7. Thus, Table 2 of the Back Bay Landing PCDP by its plain terms
does not provide any restriction on the expansion or relocation of the Back Bay Landing Pump
Station.
Exhibits 3, 5, 9, and 12 of the Back Bay Landing PCDP also do not reflect any restriction.
The language of the Back Bay Landing PCDP makes clear that each exhibit is an illustration
and included as a visual aid, not a reflection of mandatory restrictions on further development.
See Back Bay Landing PCDP page 3 (“As illustrated on Exhibit 3”); page 16 (“as illustrated in
Exhibit 5”); page 19 (“as shown on Exhibit 9”); page 22 (“As illustrated in Exhibit 12”). As
such, each exhibit’s display of the “Existing [Sewer] Pump Station” (emphasis added) simply
illustrates the present location of the Back Bay Landing Pump Station, and does not reflect a
restriction on future movement of that facility.
Please also refer to Response to Comment O4-7 pertaining to consistency with the PCDP.
O4-11 The commenter states that the Impact Statement LU-5 discussion in the 2020 Recirculated
Draft EIR “incorrectly infers that any pump station in any location within PA-1 is a permitted
use as a matter of right.” The Impact Statement LU-5 discussion based this inference on Back
Bay Landing PCDP Table 2. As noted in Response O4-10 above, the plain terms of Back Bay
Landing PCDP Table 2 do not state any restriction on the expansion or relocation of the Back
Bay Landing Pump Station. Instead, it states that a Wastewater Pump Station is a permitted
use within Planning Areas 1 and 2 (See Back Bay Landing PCDP page 7).
The commenter states “[o]nly the original Rehab-in-Place alternative is identified in the BBL
PCDP.” However, the Back Bay Landing PCDP already contemplates a situation in which
the Back Bay Landing Pump Station is relocated. Back Bay Landing PCDP Section V, “Design
Guidelines,” specifically mentions that the Back Bay Landing Pump Station could be relocated
within the development: “Should the OCSD facility be relocated and/or reconstructed, the
architectural design of the structure shall be compatible with the architectural design of the
Back Bay Landing development…” (See Back Bay Landing PCDP, at page 24.) Thus, a
potential relocation of the Back Bay Landing Pump Station—not just a rehabilitation of the
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 2-90 Responses to Comments
existing facility—was clearly contemplated. The only restriction on a relocated Back Bay
Landing Pump Station is a requirement that its design reflect the architectural design standards
outlined in the Back Bay Landing PCDP.
Please also refer to the 2020 Recirculated Draft EIR Section 3.6, Permits and Approvals (page 3-
16) and Responses to Comments A6-10, A6-11, and O4-7 though O4-9 regarding required
permits for the project.
O4-12 As discussed in the 2020 Recirculated Draft EIR page 3-16, Section 3.6, Permits and Approvals,
in addition to OCSD approvals, the proposed project would be subject to approval of a Site
Development Review Permit and Coastal Development Permit by the City of Newport Beach
(Refer to Responses to Comment O4-7 though O4-9). Compliance with City requirements
would ensure consistency with the site’s Back Bay Landing PCDP zoning, and design
requirements for the site (including the architectural theme).
O4-13 Refer to Response to Comment O4-1.
COMMENT LETTER O5
O5-1
O5-1
cont'd
O5-2
O5-2
cont'd
O5-2
cont'd
O5-2
cont'd
O5-2
cont'd
O5-2
cont'd
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 2-98 Responses to Comments
RESPONSE TO COMMENT LETTER O5
Jeffrey S. Davis, Vice President
Irvine Company
September 21, 2020
O5-1 The comment expresses support for the proposed project and requests minor adjustments to
the proposed force mains alignment, particularly at the Irvine Company property boundaries,
to the south of the new pump station. Suggested refinement of the alignment is intended to
reduce encroachment on Irvine Company’s property. Last, the commenter requests a new
sewer line connection to be constructed within the slope and onto East Coast Highway as a
replacement to the existing sewer line. The commenter contends that a new sewer connection
would accommodate the existing marina support facilities and future development anticipated
for the Balboa Marina site.
This comment is noted; the Final EIR will be presented to the OCSD decision-making body,
and the decision-making body will review and consider the information in the Final EIR prior
to approving the project. Further, as noted on 2020 Recirculated Draft EIR page 3-12, the
project would require temporary and permanent easements for construction and operation of
the project with the Irvine Company, as well as the California Department of Transportation
(Caltrans). As such, negotiations regarding refinement of construction and design of the
project, particularly at the Irvine Company property and within Caltrans right-of-way, will be
made during the final design phase of the project. Consideration of avoidance of existing wall
features and existing laterals will be made at that time. It should be noted that in the event
that these suggested alternative force main alignment adjustments are made during project
design by OCSD, such alignment is similar to the force main alignment currently proposed
(refer to Exhibit 3-4, Proposed Conceptual Site Plan of the 2020 Recirculated Draft EIR) and these
changes would be a minor update, correction, or clarification and they would not represent
“significant new information” as defined in CEQA Guidelines Section 15088.5.
Further, it is acknowledged that the entire length of the existing force mains needs to be
replaced as part of the proposed project and, during construction, the existing force mains
must remain operational until the new force mains installation is complete. As such,
connecting to the existing force mains is not feasible. This comment does not specifically
address the adequacy of the 2020 Recirculated Draft EIR nor involve an environmental issue.
As such, no further response is necessary.
O5-2 The commenter attached several exhibits of street view and aerial photographs depicting the
existing wall location and the landscape areas. This comment does not specifically address the
adequacy of the 2020 Recirculated Draft EIR nor involve an environmental issue. As such,
no further response is necessary.
I1-1
COMMENT LETTER I1
I1-2
I1-5
I1-3
I1-4
I1-6
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Final ● January 2021 2-102 Responses to Comments
RESPONSE TO COMMENT LETTER I1
Margo O’Connor
Resident
September 8, 2020
I1-1 The commenter asserts that the 2020 Recirculated Draft EIR does not specifically address the
potential impacts to the Linda Isle community. Further, the commenter disagrees with the
conclusions regarding noise, glare, soil erosion, and seismic activity as discussed in the 2020
Recirculated Draft EIR. The commenter contends that the 2020 Recirculated Draft EIR relies
on analysis from the Back Bay Landing EIR, which is irrelevant to the construction of the
proposed force mains. Further, the commenter states that there are no sound studies nor soil
studies to support that there would not be significant noise or soil impacts for Linda Isle
residents as a result of the force mains construction.
The commenter claims that the Back Bay Landing EIR is irrelevant to the construction of the
proposed force mains project. Nonetheless, the Back Bay Landing Project, as analyzed under
the Back Bay Landing EIR, considers the environmental effects of the Back Bay Landing
Project, which includes the existing pump station facility as well as regulations imposed by the
City of Newport Beach at the Back Bay Landing site, which includes the project site (as part
of the adopted Back Bay Landing Planned Community Development Plan [PCDP]); refer to
Back Bay Landing EIR Figure 2-2, Existing Conditions and Project Boundary Map, and 2020
Recirculated Draft EIR Exhibit 3-2, Site Vicinity. Thus, the Back Bay Landing EIR is
incorporated by reference in accordance with CEQA Guidelines Section 15150 (2020
Recirculated Draft EIR page 2-10).
Noise
Microtunneling may be used as a construction method to install the force mains across East
Coast Highway. Should microtunneling be used, instead of trenching, these activities would
require a 24 hour per day construction hours of operation for two months, which would
require drilling outside of the City of Newport Beach hour limitations for construction. As
noise levels generated by microtunneling activity are estimated to be 82 dBA at 50 feet,
microtunneling activity would expose sensitive receptors to temporary elevated noise levels
(64 to 71 dBA).
Adherence to the Municipal Code Chapter 10.26 and 10.28 requirements (residential exterior
and interior noise levels should not exceed 50 dBA and 40 dBA, respectively, during nighttime
hours), and compliance with Mitigation Measures NOI-1 and NOI-2 of the 2020 Recirculated
Draft EIR would reduce short-term construction noise impacts by requiring mobile
equipment to be muffled and requiring a Construction Noise Control Plan to minimize
construction noise levels at off-site sensitive receptors. In addition, Mitigation Measure NOI-
1 of the 2020 Recirculated Draft EIR would also require a disturbance coordinator to respond
to construction noise complaints and direct equipment away from sensitive receptors to
further reduce construction-related noise.
Further, construction of the proposed project is anticipated to occur over a 36-month period
and would begin in one improvement area and subsequently move to the other improvement
areas as the construction process progresses. Therefore, sensitive receptors in a particular area
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 2-103 Responses to Comments
would not be exposed to significant construction noise levels over an extended period of time.
As construction would be limited to daytime hours, with the exception of microtunneling
(across the East Coast Highway if used instead of trenching), per Municipal Code Section
10.28.040 and due to the specific nature of construction activities, construction-related noise
would be less than significant with mitigation.
Glare
Construction-related glare impacts to the nearest sensitive receptors are discussed under
Impact Statement AES-4 of the 2020 Recirculated Draft EIR. As discussed under Impact
Statement AES-4 of the 2020 Recirculated Draft EIR, short-term light and glare impacts
associated with construction activities would likely be limited to nighttime lighting (for
construction and security purposes), as proposed construction of the Newport Channel force
main crossing at East Coast Highway would require 24-hour operation for a period of two
months, should the force mains be microtunneled. Further, Mitigation Measure AES-3 would
require a construction safety lighting plan, which would require nighttime security lighting, if
necessary, to be oriented downward and away from adjacent residential areas. With
implementation of Mitigation Measure AES-3 of the 2020 Recirculated Draft EIR, impacts in
this regard would be reduced to less than significant levels.
Soil Erosion
Refer to Responses to Comments A4-1 and O2-2 pertaining to potential construction-related
soil erosion and silting impacts. Furthermore, an in-depth study was conducted specifically
for the project, which included on-site soils, which was provided in the 2020 Recirculated
Draft EIR Appendix 11.5, Geology Report, prepared by Hushmand Associates, Inc., dated April
17, 2015.
Seismic Activity
The 2020 Recirculated Draft EIR Impact Statements GEO-1 (page 5.5-11), GEO-2 (page 5.5-
12), and Section 8.0, Effects Found Not To Be Significant (page 8-3), considered the project’s
impacts related to seismic ground shaking, seismic-related ground failure, and fault rupture,
respectively. The project site is not within an identified Alquist-Priolo Earthquake Fault Zone.
Therefore, potential substantial adverse effects involving rupture of a known earthquake fault
is not anticipated. The project would involve demolishing the existing pump station building
and constructing a new pump station and associated force mains. A moderate to large
magnitude earthquake on a regional fault could cause moderate to severe seismic shaking in
the City, thus exposing the proposed pump station and associated force mains to potential
substantial adverse effects during project construction and operations, including the risk of
loss. The project area is also susceptible to liquefaction and seismic settlement (although to a
lesser degree than liquefaction. However, since the proposed pump station would not include
any habitable structures, potential adverse effects to people and new structures from strong,
seismically-induced, vibratory ground motion would be sufficiently mitigated through proper
seismic design, including those recommended in the Geology Report, and conformance with
the CBSC and OCSD sewer pipeline design standards. Overall, less than significant impacts
would occur for these topical areas and no mitigation measures would be required.
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Final ● January 2021 2-104 Responses to Comments
Additionally, about it is acknowledged that construction-related vibration impacts could result
from construction of the proposed project. Potential groundborne vibration impacts are
discussed in 2020 Recirculated Draft EIR Section 5.10, Noise, and particularly, under Impact
Statement N-2 (starting on page 4.10-18). As demonstrated in the 2020 Recirculated Draft
EIR Table 5.10-8, Typical Vibration Levels for Construction Equipment, the anticipated vibration
levels at 25 feet or more would not exceed the 0.2 inch-per-second peak particle velocity (PPV;
defined as the maximum instantaneous peak or vibration signal usually used to describe
vibration amplitudes) significance threshold during construction established by the Federal
Transit Administration (FTA). It should be noted that 0.2 inch-per-second PPV is a
conservative threshold, as that is the construction vibration damage criteria for non-
engineered timber and masonry buildings. Further, construction vibration would not cause
excessive human annoyance as the highest groundborne vibration at the nearest sensitive
receptors (i.e. 0.170 inch-per-second PPV) would not exceed the 0.4 inch-per-second PPV
human annoyance criteria. Therefore, proposed construction activities associated with the
project would not expose sensitive receptors to excessive groundborne vibration levels.
Vibration impacts associated with construction would be less than significant.
I1-2 The commenter states that other EIRs exist and that the EIR prepared for the Balboa Marina
West Expansion Project found probably unacceptable noise and glare issues for Linda Isle
residents as a result of construction activities in an area overlapping part of the construction
area for the proposed force mains. However, according to the findings made by the Initial Study/Mitigation Negative Declaration – Balboa Marina West (Balboa Marina West IS/MND),
prepared by T&B Planning, Inc., approved on October 2, 2014 (State Clearinghouse Number
2014081044) and the Back Bay Landing Final Environmental Impact Report (Back Bay Landing
EIR), prepared by PCR Services Corporation, certified February 2014 (State Clearinghouse
Number 2012101003), no significant and unavoidable impacts would result from either
project.
As detailed on 2020 Recirculated Draft EIR, Table 4-1, Cumulative Project List (page 4-2), the
Balboa Marina West Project was determined as having the potential to interact with the
proposed project such that the proposed project’s incremental effect may be cumulatively
considerable. As such, this cumulative project, and the proposed project, were considered,
along with other cumulative projects throughout the 2020 Recirculated Draft EIR Section 5.0, Environmental Analysis.
As discussed in Section 5.10.5, Cumulative Impacts, of the 2020 Recirculated Draft EIR (page
5.10-21), construction activities associated with the proposed project and cumulative projects
may overlap, resulting in construction noise in the area. However, similar to the proposed
project, construction-related noise and vibration levels from the related projects would be
intermittent, temporary, and would comply with the City’s Municipal Code limitations on
allowable hours for construction, and noise limits outside of exempted construction hours.
Cumulative projects would also be required to mitigate potential noise exceedances to the
extent feasible. The proposed project would also implement Mitigation Measures NOI-1 and
NOI-2 to reduce construction noise impacts to less than significant levels. Therefore, the
project’s incremental contribution to cumulative noise impacts would not be cumulatively
considerable.
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 2-105 Responses to Comments
As discussed in Section 5.1.5, Cumulative Impacts (page 5.1-21) of the 2020 Recirculated Draft
EIR, the nearest cumulative projects to the project site are the Back Bay Landing project
(which is within and surrounding the project site), Balboa Marina West Expansion project
(which adjoins the project site to the south), Bay Crossing Water Main Replacement project
(south of the East Coast Highway/Newport Bay Bridge), and Newport Dunes Hotel (located
approximately 0.15 mile east of the project site). The potential impacts of the Back Bay
Landing project, Balboa Marina West Expansion project, Bay Crossing Water Main
Replacement project, and Newport Dunes Hotel, and other projects related to light and glare
would be evaluated by the City on a project-by-project basis.
Potential lighting impacts would be minimized through compliance with Municipal Code
Section 20.30.060, Back Bay Landing PCDP, and General Plan Policy LU 5.6.2 on a project-
by-project basis, which would ensure proper lighting fixtures, placement, and minimal
spillover. As discussed in Impact Statement AES-4 of the 2020 Recirculated Draft EIR, the
project’s short-term construction lighting impacts would be less than significant with
implementation of the recommended Mitigation Measure AES-3, ensuring construction-
related lighting remains on-site. Further, operational lighting would be reduced to less than
significant levels following compliance with Mitigation Measure AES-4. Thus, with
compliance with required mitigation measures, the project’s incremental effect on light or glare
would not be cumulatively considerable.
It is also acknowledged that the Draft Initial Study/Mitigation Negative Declaration – Balboa Marina
West, (Balboa Marina West IS/MND) prepared by T&B Planning, Inc., dated August 18, 2014,
indicates that noise (page 5-96) and glare (page 5-34) impacts were determined to be less than
significant with incorporation of recommended mitigation measures, including potential noise
impacts to the Linda Isle residents.
Refer to Response to Comment I1-1 above for a discussion on project’s potential impacts to
noise and glare.
I1-3 Refer to Responses to Comments O2-2 and I1-1 regarding potential impacts to soil
erosion/siltation, noise, and glare.
I1-4 Refer to Responses to Comments O2-2 and I1-1 regarding potential impacts to soil
erosion/siltation, noise, and glare.
I1-5 The 2020 Recirculated Draft EIR considered the project’s potential impacts regarding noise,
glare, silting, among other topical areas, to the Linda Isle community, as discussed in Response
to Comments I1-1 through I1-4. As shown on Table 5.10-2, Sensitive Receptors (page 5.10-6) of
the 2020 Recirculated Draft EIR, the closest existing sensitive receptors to the construction
areas are residential uses located approximately 25 feet to the south of the project site. Given
that the potential impacts regarding noise, glare, silting, among other topical areas, were
determined to be less than significant with incorporated mitigation measures to the closest
existing sensitive receptors (as discussed in Response to Comments I1-1 through I1-4),
impacts to other residents located further away from the project site (i.e., the Linda Isle
residents located at least 300 feet away) would be similar or less than the impacts to those
residents approximately 25 feet away.
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Final ● January 2021 2-106 Responses to Comments
I1-6 The commenter participated in the virtual public information meeting held via
videoconference by OCSD on Thursday, September 3, 2020. The commenter identified
technical difficulty experienced during public meeting. Due to the current COVID-19
pandemic and the closure of OCSD offices and public libraries/civic centers to the public, the
public information meeting had to be accommodated virtually. OCSD apologizes for any
technical difficulties the commenter encountered. OCSD appreciates the commenter’s
consideration of the project and acknowledged receipt of this written comment; refer to
Responses to Comments I1-1 through I1-5 for a response to the commenter’s comments
related to the environmental impacts of the proposed project.
From:Leann Benvenuti <leann.benvenuti@gmail.com>
Sent:Monday, September 21, 2020 12:14 PM
To:CEQA <ceqa@ocsd.com>
Subject:EXTERNAL: Sanitation Station
Warning:This email originated from outside OCSD.Do not click links or open attachments unless
you recognize the sender and are expecting the message.
Mr. Kevin Haddan,
My name is Leann Benvenuti and my husband David and I reside at 106 Linda Isle. First and foremost,
let me say that we understand the need to replace the 50 year old
pump station and the need to install two new force mains . Hopefully these improvements will
eliminate the foul odors that often permeate certain areas along PCH, Bayside Drive , and Jamboree
Road. We are, however, concerned about the implementation.
Our concerns are:
1. The existing station is 4500+ sq ft. Why is the new facility quadruple in size? Similar to when an
entire room was needed to house 1 computer system, which now fits into a microchip, why hasn't the
equipement become more compact, smaller, and efficient? Such a large building will look out of place
at that site..
2. The 3 years needed to complete the project with 24/7 of noise, dirt, soil shifting, and seismic activity
will be detrimental to the surrounding residential areas. Nothing in the report mentions the
potential damage and disturbance to Bayshore and LInda Isle residents and their property.
3. Silt. Many Linda Isle residents just paid a lot of money to dredge their docks within the past 3
years. Drilling and digging the soil to lay pipe will cause redistribution of the silt and shifting of the bay
floor, resulting in financial repercussions for residents. How are these damages going to be mitigated?
4. The report cites studies for the Back Bay Landing Project. This report is a flawed comparison because
the Back Bay area with the Marina and De Anza mobile home park is a completely different
site situation than the custom homes of Bayshores and LInda Isle, even though it is about only 1/4 of a
mile away.
So in closing, how does the OCSD plan on protecting the property of the residents of Bayshores and
LInda Isle, and limiting their daily disruption and nightly trauma from this project?
We respectively await your response.
Sincerely,
Leann and David Benvenuti
106 Linda Isle
949 233 7753
COMMENT LETTER I2
I2-1
I2-2
I2-3
I2-4
I2-5
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 2-108 Responses to Comments
RESPONSE TO COMMENT LETTER I2
Leann and David Benvenuti
Resident
September 21, 2020
I2-1 The project proposes a 14,500 square foot pump station facility. The additional square footage
(an increase of approximately 9,700 square feet compared to the existing pump station) would
accommodate a new below-grade dry pit mechanical room, an above-grade electrical room, a
760-square foot backup generator facility, and a new 1,300-square foot odor control facility.
The additional square footage will accommodate the necessary space for the proposed odor
control facility, as well as the increased space needed to accommodate maintenance personnel
to safely access the project site and equipment (2020 Recirculated Draft EIR page 1-1).
2020 Recirculated Draft EIR Impact Statement AES-3 (page 5.1-18) considers whether or not
the project would conflict with a policy governing scenic quality (such as building heights,
setbacks, etc.). As discussed, the project would be consistent with the Back Bay Landing
Planned Community Development Plan (PCDP) design guidelines, particularly those
involving architectural theme, façade treatments, and public view considerations. All
proposed pump station infrastructure and mechanical equipment would be screened from
public right-of-way views, and the new pump station building would not obstruct existing
coastal views and would be consistent with the Back Bay Landing Height Limitation Zone
requirements and PCDP design guidelines.
The project would be required to obtain a Site Development Review Permit from the City of
Newport Beach. As such, specific design requirements may be imposed by the City of
Newport Beach to ensure consistency with the applicable design guidelines. As such, with
compliance with existing regulations, impacts in this regard would be less than significant.
I2-2 Refer to Responses to Comments O2-1, O2-2, and I1-1 for a discussion on impacts related to
noise, glare, soil erosion/siltation, and seismic-related impacts.
I2-3 Refer to Response to Comment O2-2.
I2-4 Refer to Response to Comment I1-2 for a discussion on incorporation of other EIRs by
reference for the 2020 Recirculated Draft EIR, and Response to Comment I1-5 for a
discussion on project’s distance from sensitive receptors, including the Linda Isle community.
As the Back Bay Landing EIR was prepared at the same property as the proposed pump
station, this document is incorporated by reference into the 2020 Recirculated Draft EIR as
relevant. Notwithstanding, the 2020 Recirculated Draft EIR specifically analyzes the proposed
project’s potential impacts to the environment. It does not simply rely on the BBL EIR’s
analysis.
I2-5 The comment concludes with concerns regarding construction impacts to residents. Please
refer to Responses to Comments O2-1, O2-2, and I1-1.
3.0 ERRATA
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Final ● January 2021 3-1 Errata
3.0 ERRATA
Changes to the Bay Bridge Pump Station and Force Mains Replacement Project 2020 Recirculated Draft
Environmental Impact Report (2020 Recirculated Draft EIR) are noted below. A double-underline indicates additions to the text; strikeout indicates deletions to the text. These changes are considered
minor and editorial in nature, and do not affect the conclusions of the environmental document or require recirculation of the 2020 Recirculated Draft EIR.
SECTION 1.0, EXECUTIVE SUMMARY
Page 1-8, Last Row
BIO-3 Wetlands
Project implementation could have an adverse effect on State or Federally protected wetlands.
No mitigation measures are required.Refer to Mitigation Measures HWQ-4 and BIO-1 through BIO-3.
Less Than Significant Impact.
SECTION 2.0, INTRODUCTION AND PURPOSE
Section 2.5, Page 2-6, Last Paragraph
Responsible and Trustee Agencies and other entities that may use this 2020 Recirculated Draft EIR
in their decision-making process or for informational purposes include, but may not be limited to, the
following:
• City of Newport Beach;
• California Department of Transportation;
• Santa Ana Regional Water Quality Control Board;
• State Water Resources Control Board;
• California Department of Fish and Wildlife;
• California Coastal Commission;
• California State Lands Commission/County of Orange;
• South Coast Air Quality Management District;
• U.S. Army Corps of Engineers; and
• National Marine Fisheries Service.
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 3-2 Errata
SECTION 3.0, PROJECT DESCRIPTION
Section 3.6, Page 3-16, Last Paragraph
The applicable agency approvals and related environmental review/consultation requirements associated with the proposed project may include the following, among others. It is not anticipated
that any other agencies would require use of the EIR in their decision making process.
• CEQA Clearance – OCSD;
• Site Development Review Permit – City of Newport Beach;
• Limited Term Permit – City of Newport Beach;
• Encroachment Permits – City of Newport Beach and Caltrans;
• Permanent/Temporary Easements – City of Newport Beach, Bayside Village Marina, LLC, The Irvine Company, and Bay Shores Community Association;
• Traffic Control Plan Approval – City of Newport Beach and Caltrans;
• Coastal Development Permit – California Coastal Commission and City of Newport Beach (as required under the California Coastal Act, Public Resources Code Division 20);
• California State Lands Commission – Consultation with the County of Orange regarding
implementation of Newport Bay Channel force main crossing through tidelands and submerged lands;
• California Department of Fish and Wildlife – Consultation regarding implementation of Newport Bay Channel force main crossing;
• National Marine Fisheries Service – Dry dredging/shoring construction activities;
• Section 404 Permit – Army Corps of Engineers (required for dry dredging/shoring
construction activities);
• Section 401 Permit – Santa Ana Regional Water Quality Control Board (required for dry
dredging/shoring construction activities);
• Permit R8-2015-0004 – Santa Ana Regional Water Quality Control Board; and
• General Construction Permit – Santa Ana Regional Water Quality Control Board (as required
under National Pollutant Discharge Elimination System [NPDES] General Permit for Storm Water Discharges Associated with Construction and Land Disturbance Activities (Order No.
2009-0009-DWQ [as amended by 2010-0014-DWQ and 2012-006-DWQ], NPDES Number CAS000002). ; and
• Permit to Construct (P/C) and Permit to Operate (P/O) – South Coast Air Quality
Management District.
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 3-3 Errata
SECTION 5.3, BIOLOGICAL RESOURCES
Section 5.3, Page 5.3-20, First Sentence
Level of Significance: Less Than Significant Impact With Mitigation Incorporated.
MIGRATORY WILDLIFE SPECIES
BIO-4 PROJECT IMPLEMENTATION COULD INTERFERE WITH THE MOVEMENT OF A NATIVE RESIDENT OR MIGRATORY WILDLIFE SPECIES.
Impact Analysis:
The project proposes the construction of a new pump station and force mains, as well as replacement
of portions of the existing gravity sewer located within East Coast Highway. All proposed land areas of site disturbance are located within developed or highly disturbed areas and are not associated with
the movement of native resident or migratory wildlife species.
Construction
While dredging activities associated with the force main improvements across Newport Bay Channel would result in disturbances that could interfere with marine wildlife movement, dredging activities
would be temporary (approximately four months) and only impede the Newport Bay Channel within the immediate vicinity of active dredging operations. Dredging activities would require trenching the
length of the channel (approximately 700 feet) by 15 feet wide by 18 feet deep. Trenching would occur in two segments across the channel, a 400-foot segment and a 300-foot segment. Each segment
would be drained then trenched. This segmented approach to dredging across the Newport Bay Channel would not entirely block off or impede wildlife movement to and from the Back Bay.
Similarly, construction impacts associated with noise and lighting would be temporary and occur segment-by-segment across the Newport Bay Channel during dredging activities. The project would
also be required to implement Mitigation Measure HWQ-4 regarding Corps permitting requirements for dredging activities, BIO-1 pertaining to the protection of marine mammals, and BIO-3 related to
the protection of eelgrass and kelp species. Upon implementation of the applicable mitigation measures related to marine biological resources, impacts to the movement of native resident or
migratory marine wildlife would be less than significant.
Additionally, as discussed in Impact Statement BIO-1, implementation of Mitigation Measure BIO-2
would ensure construction activities do not adversely impact nesting birds protected by the MBTA. Mitigation Measure BIO-2 requires pre-construction nesting bird clearance surveys be conducted if
construction activities are anticipated during the nesting season. Should surveys determine that an active avian nest is present adjacent to the construction area, construction activities would be required
to stay outside of a 300-foot buffer around the active nest. For raptor species, this buffer is expanded to 500 feet. A biological monitor would be required to be present to delineate the boundaries of the
buffer area and to monitor the active nest in order to ensure that nesting behavior is not adversely affected by construction activities. Once the young have fledged, normal construction activities would
be allowed to continue. These requirements would reduce impacts to nesting birds to a less than significant level. As such, with implementation of Mitigation Measure BIO-2, potential impacts to
migratory wildlife species would be reduced to a less than significant level.
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 3-4 Errata
Operations
Upon completion of construction activities, the new pump station facility and associated force mains
would operate the same as under existing conditions. Thus, no operational impacts to migratory wildlife species would occur in this regard.
Mitigation Measures: Refer to Mitigation Measures HWQ-4 and BIO-1 through BIO-3.
Level of Significance: Less Than Significant Impact With Mitigation Incorporated.
SECTION 5.1, AESTHETICS/LIGHT AND GLARE
Section 5.1.4, Page 5.1-18, Last Paragraph
As discussed in Section 5.9, Land Use and Relevant Planning, project development would be consistent with the zoning and regulations governing scenic quality. The new facility would be similar in
character to the existing pump station facility. The new pump station structure (up to 31 feet high from finished grade) would have nighttime security lighting, consistent with the Back Bay Landing
PCDP Height Limitation Zone requirements and lighting standards (e.g., design parameters for shielding, light spill, and fixtures). The project would also be consistent with the Back Bay Landing
PCDP design guidelines, particularly those involving architectural theme, façade treatments, and public view considerations. The new pump station would include aspects of the future Back Bay
Landing development’s coastal Mediterranean architectural theme (e.g., textured walls and terracotta colors) Coastal architectural theme (i.e., varied historical vernacular and casually elegant palette) to be
consistent with its coastal urban village character. All proposed pump station infrastructure and mechanical equipment would be screened from public right-of-way views, and the new pump station
building would not obstruct existing coastal views and would be consistent with the Back Bay Landing Height Limitation Zone requirements and PCDP design guidelines. Therefore, the proposed project
would not conflict with any applicable zoning or regulations governing scenic quality within an urbanized area. Less than significant impacts would occur in this regard.
SECTION 5.9, LAND USE AND RELEVANT PLANNING
Section 5.9.4, Page 5.9-24, Last Paragraph
• Design Guidelines: The Back Bay Landing PCDP includes design guidelines covering a range of design features, including architecture, site planning, building massing, façade treatments,
landscaping, and hardscaping. The new pump station would include aspects of the future Back Bay Landing development’s coastal Mediterranean architectural theme (e.g., textured
walls and terracotta colors) Coastal architectural theme (i.e., varied historical vernacular and casually elegant palette) to be consistent with its coastal urban village character. All proposed
pump station infrastructure and mechanical equipment would be screened from public right-of-way views, and the new pump station building would not obstruct existing coastal views
and would be consistent with the Back Bay Landing Height Limitation Zone requirements and PCDP design guidelines.
4.0 MITIGATION MONITORING AND REPORTING PROGRAM
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Final ● January 2021 4-1 Mitigation Monitoring & Reporting Program
4.0 MITIGATION MONITORING
AND REPORTING PROGRAM
CEQA requires that when a public agency completes an environmental document which includes
measures to mitigate or avoid significant environmental effects, the public agency must adopt a reporting or monitoring plan. This requirement ensures that environmental impacts found to be
significant will be mitigated. The reporting or monitoring plan must be designed to ensure compliance during project implementation (Public Resources Code Section 21081.6).
In compliance with Public Resources Code Section 21081.6, a Mitigation Monitoring and Reporting
Program (MMRP) has been prepared for the proposed Bay Bridge Pump Station and Force Mains Replacement Project. This MMRP is intended to provide verification that all mitigation measures
identified in the 2020 Recirculated Draft EIR are monitored and reported. Monitoring will include 1) verification that each mitigation measure has been implemented; 2) recordation of the actions taken
to implement each mitigation; and 3) retention of records in the project file.
This MMRP delineates responsibilities for monitoring the project. Pursuant to CEQA Guidelines Section 15097(a), however, OCSD ultimately remains responsible for ensuring that implementation
of the mitigation measures occurs in accordance with the mitigation program. Monitoring procedures will vary according to the type of mitigation measure. Adequate monitoring consists of demonstrating
that monitoring procedures took place and that mitigation measures were implemented.
Reporting consists of establishing a record that a mitigation measure is being implemented, and generally involves the following steps:
• OCSD distributes reporting forms to the appropriate entities for verification of compliance.
• Departments/agencies with reporting responsibilities will review the 2020 Recirculated Draft EIR, which provides general background information on the reasons for including specified
mitigation measures.
• Issues related to compliance will be submitted to and reviewed by OCSD in accordance with
CEQA.
• Periodic meetings may be held during project implementation to report on compliance with mitigation measures.
• Responsible parties provide OCSD with verification that monitoring has been conducted and
ensure, as applicable, that mitigation measures have been implemented. Monitoring
compliance may be documented through existing review and approval programs such as field
inspection reports and plan review.
• OCSD prepares a reporting form periodically during the construction phase and an annual
report summarizing all project mitigation monitoring efforts.
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 4-2 Mitigation Monitoring & Reporting Program
• Appropriate mitigation measures will be included in construction documents and/or conditions of permits/approvals.
Minor changes to the MMRP, if required, would be made in accordance with CEQA and would be
permitted after further review and approval by OCSD. Such changes could include reassignment of monitoring and reporting responsibilities, plan redesign to make any appropriate improvements,
and/or modification, substitution or deletion of mitigation measures subject to conditions described in CEQA Guidelines Section 15162.
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 4-3 Mitigation Monitoring & Reporting Program
MITIGATION MONITORING AND REPORTING CHECKLIST
Mitigation Number Mitigation Measure Monitoring and Reporting Process
Monitoring Milestones Party Responsible for Monitoring VERIFICATION OF COMPLIANCE
Initials Date Remarks
5.1 Aesthetics/Light and Glare AES-1 Prior to issuance of any grading and/or demolition permits, whichever occurs first, engineering drawings and specifications shall be prepared by the Project Engineer, or their designee, and submitted for review and approval by the Orange County Sanitation District Director of Engineering. These documents shall, at a minimum, indicate the equipment and vehicle staging areas, stockpiling of materials, screening/fencing (i.e., temporary fencing with opaque material), and haul route(s). Staging areas shall be sited away from public views, to the extent feasible and reasonable, and/or screened utilizing temporary fencing with opaque materials. Construction haul routes shall minimize impacts to sensitive uses in the project area by avoiding local residential streets.
Review and Approval of Engineering Drawings and Specifications
Prior to Issuance of Grading/ Demolition Permits
Orange County Sanitation District
AES-2 Prior to construction of the new pump station facility, Orange County Sanitation District (OCSD) shall comply with the applicable requirements of the City of Newport Beach to ensure consistency with the surrounding development and Back Bay Landing PCDP design guidelines.
Engineering Draftings and Specifications; Final Review and Approval of Design Plans
Prior to Construction of Pump Station Facility
Orange County Sanitation District; City of Newport Beach
AES-3 Prior to any nighttime construction activities, a construction safety lighting plan shall be prepared by the Project Engineer, or their designee, and submitted to the Orange County Sanitation District Director of Engineering for review and approval. The plan shall include, but not be limited to, the following:
• Identify all required construction lighting fixtures, anticipated locations and heights, and maximum wattage required;
Review and Approval of Construction Safety Lighting Plan
Prior to Nighttime Construction Activities
Orange County Sanitation District; City of Newport Beach
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 4-4 Mitigation Monitoring & Reporting Program
Mitigation Number Mitigation Measure Monitoring and Reporting Process
Monitoring Milestones Party Responsible for Monitoring
VERIFICATION OF COMPLIANCE
Initials Date Remarks
• Ensure all construction-related lighting fixtures (including portable fixtures) are shielded and oriented downward and away from adjacent sensitive areas (including residential and biologically sensitive areas);
• Provide the minimal wattage necessary to provide adequate nighttime visibility and safety at the construction site; and
• Demonstrate that nighttime construction lighting does not spillover onto adjacent residential properties.
AES-4 Prior to construction of the proposed pump station, an operational lighting plan shall be prepared by the Project Engineer, or their designee, and provided to the Orange County Sanitation District (OCSD) Director of Engineering for review and approval. OCSD shall provide the lighting plan to the City of Newport Beach for review and comment, pertaining to the general consistency with the Back Bay Landing Planned Community Development Plan regulations for lighting. All outdoor lighting fixtures shall be designed, shielded, aimed, located, and maintained to minimize impacts to adjacent sites and to not produce glare onto adjacent sites or roadways. Final approval of the lighting plan shall be made by OCSD prior to start of project construction. OCSD, or designee, shall verify that the approved plans incorporate the reasonably suggested revisions and comments received from the City of Newport Beach.
Review and Approval of Outdoor Lighting Plan
Prior to Construction of the Pump Station
Orange County Sanitation District; City of Newport Beach
5.3 Biological Resources BIO-1 Prior to dredging operations, if conducted, Orange County Sanitation District, or designee, shall retain a qualified marine mammal biologist, defined as an
Completion of Contractor Prior to Dredging Operations Orange County Sanitation District;
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 4-5 Mitigation Monitoring & Reporting Program
Mitigation Number Mitigation Measure Monitoring and Reporting Process
Monitoring Milestones Party Responsible for Monitoring
VERIFICATION OF COMPLIANCE
Initials Date Remarks individual with a bachelor’s degree or above in marine biology, zoology, animal behavior, or a closely related area and demonstrated field experience, to conduct contractor awareness training for all personnel working in the marine environment. The purpose of the training is to educate contractor personnel on the identification of marine wildlife in the project area and to provide an overview of the wildlife mitigation that will be implemented during the project. Specifically, the training seminar shall include, but not be limited to, the following:
• Identification of most common types of marine wildlife likely to be encountered in the project area;
• Activities that have the most potential for affecting the animals;
• Overview of the Marine Mammal Protection Act (MMPA), the designated Environmental Study Area (ESA), agencies responsible for enforcement of the MMPA and ESA, and penalties associated with violations of the acts;
• Procedures to be followed during mobilization/demobilization, and transiting of project vessels, anchoring and throughout waterside construction activities (e.g., decreasing vessel speeds/engine power when at a determined distance from the shoreline, limiting vessel engine idling to five minutes or less, and utilizing minimum required engine power); and
Awareness Training Qualified Marine Mammal Biologist
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Final ● January 2021 4-6 Mitigation Monitoring & Reporting Program
Mitigation Number Mitigation Measure Monitoring and Reporting Process
Monitoring Milestones Party Responsible for Monitoring
VERIFICATION OF COMPLIANCE
Initials Date Remarks
• Reporting requirements in the event of an inadvertent collision and/or injury to marine wildlife.
BIO-2 Should construction activities occur within the nesting season, all suitable habitat surrounding the project site shall be thoroughly surveyed for the presence of nesting birds by a qualified biologist, defined as an individual with a bachelor’s degree or above in a biological science field and demonstrated field experience, within three days prior to commencement of site disturbance activities. If an active avian nest is discovered in proximity to the project site during the nesting bird survey, construction activities (those activities that could result in direct or indirect impacts to active nests either through noise, light, or physical contact) shall stay outside of a 300-foot buffer around the active nest. For raptor species, this buffer shall be expanded to 500 feet. The qualified biologist shall be present to delineate the boundaries of the buffer area and to monitor the active nest in order to ensure that nesting behavior is not adversely affected by construction activities. If the qualified biologist determines that nesting behavior is adversely affected by construction activities, the qualified biologist shall halt construction activities that result in the adverse effect and file a written report to OCSD and the construction contractor stating the recommended course of action. The buffer area and limitations on construction may be reduced upon approval by the California Department of Fish and Wildlife, and only if the nesting behaviors are not disrupted by construction activities, as determined by the qualified biologist.
Completion of Pre-Construction Clearance Survey for Nesting Birds
Prior to Initiation of Ground Disturbing Activities
Orange County Sanitation District; Qualified Biologist; California Department of Fish and Wildlife
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Final ● January 2021 4-7 Mitigation Monitoring & Reporting Program
Mitigation Number Mitigation Measure Monitoring and Reporting Process
Monitoring Milestones Party Responsible for Monitoring
VERIFICATION OF COMPLIANCE
Initials Date Remarks Once the young have fledged, normal construction activities shall be allowed to occur. BIO-3 The Orange County Sanitation District (OCSD), or designee, shall retain a qualified marine biologist, defined as an individual with a bachelor’s degree or above in marine biology, zoology, or a closely related area and demonstrated field experience, to conduct a comprehensive pre-construction survey for the presence of eelgrass and kelp species within the project survey area, as delineated by the qualified marine biologist, prior to the commencement of in-water construction operations. The pre-construction eelgrass and kelp surveys shall be consistent with current National Marine Fisheries Service (NMFS) California Eelgrass Mitigation Policy (CEMP) survey guidelines. If pre-construction survey results indicate eelgrass or kelp presence within the project survey area, the qualified marine biologist shall recommend, and OCSD, or designee, shall incorporate, appropriate avoidance measures, protection measures, and/or replacement mitigation (e.g., shifting dredging areas, relocating eelgrass, releasing buoy-deployed seed bags, and reseeding for no net loss) to be implemented during construction activities to avoid or reduce impacts to eelgrass or kelp species to the maximum extent practicable. The qualified marine biologist shall coordinate with the appropriate regulatory agencies including the NMFS, U.S. Army Corps of Engineers (Corps), U.S. Fish and Wildlife Service (USFWS), California Coastal Commission (CCC), the California Department of Fish and Wildlife (CDFW), and other resource and regulatory agencies, as necessary, and OCSD, or designee, shall implement compensatory mitigation, as required by the appropriate regulatory
Completion of Pre-Construction Survey for Eelgrass and Kelp Species
Prior to In-Water Construction Orange County Sanitation District; Qualified Marine Biologist
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 4-8 Mitigation Monitoring & Reporting Program
Mitigation Number Mitigation Measure Monitoring and Reporting Process
Monitoring Milestones Party Responsible for Monitoring
VERIFICATION OF COMPLIANCE
Initials Date Remarks agencies, should the project result in the loss of eelgrass and kelp habitat. 5.4 Cultural Resources CUL-1 Prior to ground-disturbing activities, Orange County Sanitation District (OCSD), or its designee, shall retain a qualified archaeologist who meets the requirements of the Secretary of the Interior’s Standards to prepare an Archaeological Monitoring Protocol Plan for the project that is consistent with all applicable requirements of the City of Newport Beach Local Coastal Program (CLUP) and Coastal Development Permit (CDP) as determined by the City of Newport Beach. The Archaeological Monitoring Protocol Plan shall include, but is not limited to, the following:
• Identification of the project’s area of potential effect;
• Training procedures regarding the Archaeological Monitoring Protocol Plan and the identification of potential archaeological resources. The training shall be open to Native American tribal representative(s), to assist the contractor’s representative in identifying potential tribal cultural resources.
• Procedures to follow in the event that potential archaeological resources are discovered during construction activities, including, without limitation, halting work in the area of the find and contacting the qualified archaeologist to evaluate the find.
• Procedures for proceeding with construction work after a significant find is inventoried, documented, and/or recovered.
Review of and Training Regarding Archaeological Monitoring Protocol Plan; Construction Inspections
Prior to Initiation of Ground Disturbing Activities; During Construction
Orange County Sanitation District; Qualified Archaeologist; Construction Contractor; City of Newport Beach; Affiliated Native American Groups (as applicable)
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 4-9 Mitigation Monitoring & Reporting Program
Mitigation Number Mitigation Measure Monitoring and Reporting Process
Monitoring Milestones Party Responsible for Monitoring
VERIFICATION OF COMPLIANCE
Initials Date Remarks OCSD, or designee, shall implement all recommended and required measures identified in the Archaeological Monitoring Protocol Plan approved by the City of Newport Beach. If evidence of potential subsurface archaeological resources is found during ground disturbance/excavation activities, these activities shall cease within 50 feet of that area and the construction contractor shall contact OCSD. Construction activities shall be allowed to continue in other areas of the site. OCSD, or designee, shall then retain a qualified archaeologist to evaluate the discovery prior to resuming grading/construction activities in the immediate vicinity of the find. If warranted based on the archaeologist’s evaluation of the find, the archaeologist shall collect the resource, and prepare a test-level report describing the results of the investigation. The test-level report shall evaluate the site including discussion of the significance (depth, nature, condition, and extent of the resource), identify final mitigation measures that OCSD or its designee shall incorporate into future construction plans, and provide cost estimates. If the qualified archaeologist determines that the find is prehistoric or includes Native American materials, affiliated Native American groups shall be invited to contribute to the assessment and recovery of the resource, as applicable. The qualified archaeologist and any applicable Native American contacts shall collect the resource and prepare a test-level report describing the results of the investigation. The test-level report shall evaluate the site including discussion of significance (depth, nature, condition, and extent of the resources), final mitigation recommendations, and cost estimates.
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 4-10 Mitigation Monitoring & Reporting Program
Mitigation Number Mitigation Measure Monitoring and Reporting Process
Monitoring Milestones Party Responsible for Monitoring
VERIFICATION OF COMPLIANCE
Initials Date Remarks Salvage operation requirements pursuant to Section 15064.5 of the CEQA Guidelines shall be followed. Work within the area of discovery shall resume only after the resource has been appropriately inventoried, documented, and/or recovered, as detailed in the test-level report(s). 5.5 Geology and Soils GEO-1 Prior to ground-disturbing activities, a qualified paleontologist shall provide a Monitoring Protocol Plan for the project. The plan shall identify procedures to be used in the event that potential recoverable fossils are discovered by the construction contractor. The qualified paleontologist shall have a B.S. or B.A. in geology and/or paleontology with demonstrated competence in research, fieldwork, reporting, and curation. The qualified paleontologist shall provide training to the contractor’s representative regarding the Monitoring Protocol Plan and the identification of paleontological resources. The Monitoring Protocol Plan shall state that in the event a fossil or suspected fossil is encountered during ground disturbing activities, the following steps shall be taken to ensure paleontological resource(s), if present, are properly preserved or salvaged in accordance with the recommendation of the qualified paleontologist and existing Federal, State, and local laws and regulations:
• The fossil site shall not be touched, moved, or disturbed in any way.
• Work shall stop in the immediate area, and a minimum 50-foot buffer shall be marked with brightly colored flagging. No further disturbance in the flagged area shall occur until the contractor has cleared the area.
Review of and Training Regarding Monitoring Protocol Plan; Inspections
Prior to Initiation of Ground Disturbing Activities; During Construction
Orange County Sanitation District; Qualified Paleontologist; Construction Contractor
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 4-11 Mitigation Monitoring & Reporting Program
Mitigation Number Mitigation Measure Monitoring and Reporting Process
Monitoring Milestones Party Responsible for Monitoring
VERIFICATION OF COMPLIANCE
Initials Date Remarks
• The contractor’s representative, construction foreman or supervisor, and a qualified paleontologist shall be immediately notified.
• The qualified paleontologist shall quickly examine the find and make a determination of significance. If the find is not significant, the foreman shall be informed when it is acceptable to resume work in the area.
• Should the qualified paleontologist determine the find is significant, the qualified paleontologist shall develop a plan of mitigation which would likely include salvage excavation and removal of the find, removal of sediment from around the specimen, research to identify and categorize the find, curation of the find in a local qualified repository, and preparation of a report summarizing the find. 5.7 Hazards and Hazardous Materials HAZ-1 Prior to demolition activities, an asbestos survey shall be conducted by an Asbestos Hazard Emergency Response Act (AHERA) and California Division of Occupational Safety and Health (Cal/OSHA) certified building inspector to determine the presence or absence of asbestos containing-materials (ACMs). If ACMs are determined to be present, abatement of asbestos shall be completed prior to any activities that would disturb ACMs or create an airborne asbestos hazard. Asbestos removal shall be performed by a State certified asbestos containment contractor in accordance with the South Coast Air Quality Management District (SCAQMD) Rule 1403. Asbestos wastes shall be handled and disposed of in accordance with the federal Toxic Substances Control
Completion of Asbestos Survey and Asbestos Abatement (if necessary)
Prior to and During Demolition Activities
Orange County Sanitation District; Certified Building Inspector; Asbestos Containment Contractor (if necessary)
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 4-12 Mitigation Monitoring & Reporting Program
Mitigation Number Mitigation Measure Monitoring and Reporting Process
Monitoring Milestones Party Responsible for Monitoring
VERIFICATION OF COMPLIANCE
Initials Date Remarks Act (TSCA), 40 Code of Federal Regulations (CFR) 763, the Clean Air Act (NESHAP), and California Code of Regulations, Title 22, Division 4.5. Contractors performing ACM removal shall provide documentation of abatement activities to the Orange County Sanitation District. HAZ-2 If paint is separated from building materials (chemically or physically) during demolition of the structures, the paint waste shall be evaluated independently from the building material by an EPA certified Lead Inspector. If lead-based paint is found, abatement shall be completed by an EPA qualified Lead Abatement Specialist prior to any activities that would create lead dust or a fume hazard. Lead-based paint removal and disposal shall be performed in accordance with California Code of Regulation Title 8, Section 1532.1, which specifies exposure limits, exposure monitoring and respiratory protection, and mandates good worker practices by workers exposed to lead. Contractors performing lead-based paint removal shall provide documentation of abatement activities to the Orange County Sanitation District.
Review and Approval of Paint Waste Evaluation and Lead Abatement (if necessary)
Prior to and During Demolition Activities
Orange County Sanitation District; Qualified Environmental Professional; Qualified Lead Specialist (if necessary)
HAZ-3 Prior to construction, a Soil Management Plan (SMP) shall be prepared and signed and stamped by a Professional Geologist or Engineer licensed in the State of California. The SMP shall be incorporated into project plans and specifications to be used by the contractor and the Orange County Sanitation District during construction activities. The SMP shall include guidelines for safety measures and soil management in the event that contaminated soils are to be disturbed, and for handling contaminated soil during any planned earthwork activities. Soil management practices could include the use of proper protective gear, waste profiling, landfill selection, and setting designated stockpiling
Completion of a Soil Management Plan; Spoils Sampling During Construction
Prior to and During Construction
Orange County Sanitation District; Phase II/Site Characterization Specialist; Construction Contractor
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 4-13 Mitigation Monitoring & Reporting Program
Mitigation Number Mitigation Measure Monitoring and Reporting Process
Monitoring Milestones Party Responsible for Monitoring
VERIFICATION OF COMPLIANCE
Initials Date Remarks location, among others. Additionally, the SMP shall include verification sampling for spoils/dredged material, soil import and export, as well as backfill to confirm that no hazardous materials are present. If hazardous materials are detected, the materials shall be properly disposed of in accordance with Federal and State requirements, such as the Resources Conservation and Recovery Act (RCRA) and Hazardous Materials Transportation Act (HMTA), among others. The SMP shall also include a decision framework and specific risk management measures for managing soil in a manner protective of human health and consistent with applicable regulatory requirements. HAZ-4 If unknown wastes are discovered during construction that are believed to involve hazardous waste or materials, the contractor shall comply with the following:
• Immediately cease work in the vicinity of the suspected contaminant, and remove workers and the public from the area;
• Notify the Orange County Sanitation District;
• Secure the area as directed by the Orange County Sanitation District; and
• Notify the Orange County Health Care Agency’s Hazardous Materials Division’s Hazardous Waste/ Materials Coordinator (or other appropriate agency specified by the Director of Engineering). The Hazardous Waste/Materials Coordinator shall advise the responsible party of further actions that shall be taken, if required. Any and all further actions shall be taken in compliance with the directions of the Hazardous Waste /
Observation During Construction; Construction Inspections
During Construction Orange County Sanitation District; Construction Contractor; Orange County Health Care Agency’s Hazardous Materials Division’s Hazardous Waste/Materials Coordinator (or other appropriate agency specified by the Director of Engineering)
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 4-14 Mitigation Monitoring & Reporting Program
Mitigation Number Mitigation Measure Monitoring and Reporting Process
Monitoring Milestones Party Responsible for Monitoring
VERIFICATION OF COMPLIANCE
Initials Date Remarks Materials Coordinator and Federal and State law. 5.8 Hydrology and Water Quality HWQ-1 Prior to site disturbance activities and as part of the project’s compliance with the National Pollutant Discharge Elimination System requirements, a Notice of Intent shall be prepared by the Orange County Sanitation District, or designee, and submitted to the State Water Resources Control Board and the Santa Ana Regional Water Quality Control Board, providing notification and intent to comply with the State of California Construction General Permit and the General Waste Discharge Requirements For Insignificant Threat Discharges to Surface Waters.
Preparation and submittal of a Notice of Intent (NOI)
Prior to Issuance of Construction General Permit; Prior to Site Disturbance Activities
Orange County Sanitation District; State Water Resources Control Board; Santa Ana Regional Water Quality Control Board
HWQ-2 The proposed project shall conform to the requirements of an approved Storm Water Pollution Prevention Plan (to be applied for by the Orange County Sanitation District, or designee, prior to site disturbance) and the National Pollutant Discharge Elimination System Permit for General Construction Activities No. CAS000002, Order No. 2009-0009-DWQ (as amended by 2010-014-DWQ and 2012-006-DWQ), including implementation of all recommended best management practices (e.g., straw bale barriers, sediment traps, wind erosion/dust control, silt fences, and filter berms), as approved by the State Water Resources Control Board.
Review of Compliance with Approved SWPPP and NPDES Permit; Construction Inspections
During Construction Orange County Sanitation District; Construction Contractor
HWQ-3 Upon completion of project construction, the Orange County Sanitation District, or designee, shall submit a Notice of Termination to the State Water Resources Control Board to indicate that construction is completed.
Preparation and Submittal of a Notice of Termination (NOT)
Following Completion of Construction
Orange County Sanitation District; State Water Resources Control Board
HWQ-4 In compliance with the Federal Clean Water Act, the proposed project shall conform to the requirements of the Department of the Army permit(s) (to be applied for
Review of Compliance with Department of the
Prior to Site Disturbance; Orange County Sanitation District; U.S. Army Corps of
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 4-15 Mitigation Monitoring & Reporting Program
Mitigation Number Mitigation Measure Monitoring and Reporting Process
Monitoring Milestones Party Responsible for Monitoring
VERIFICATION OF COMPLIANCE
Initials Date Remarks by the Orange County Sanitation District, or designee, for prior to site disturbance) from the U.S. Army Corps of Engineers Los Angeles District.
Army Permit; Construction Inspection
During Construction Engineers Los Angeles District
5.10 Noise NOI-1 Prior to the initiation of construction, the Orange County Sanitation District shall confirm that the Grading Plan, Building Plans, and specifications require that:
• All construction equipment, fixed or mobile, shall be equipped with properly operating and maintained mufflers and other State required noise attenuation devices.
• The Orange County Sanitation District shall provide a "Noise Disturbance Coordinator." The Disturbance Coordinator shall be responsible for responding to any local complaints about construction noise. When a complaint is received, the Disturbance Coordinator shall determine the cause of the noise complaint (e.g., starting too early, bad muffler, etc.) and shall implement measures to resolve the complaint and comply with the City Noise Ordinance. The construction hotline telephone number shall be clearly posted on-site.
• Construction haul routes shall be designed to avoid noise sensitive uses (e.g., residences, schools, hospitals, etc.) to the greatest extent possible.
• During construction, stationary construction equipment shall be placed such that emitted noise is directed away from sensitive noise receivers.
Review and Approval of Grading Plan, Building Plans, and Specifications; Construction Inspections
Prior to and During Construction
Orange County Sanitation District; Noise Disturbance Coordinator; City of Newport Beach
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 4-16 Mitigation Monitoring & Reporting Program
Mitigation Number Mitigation Measure Monitoring and Reporting Process
Monitoring Milestones Party Responsible for Monitoring
VERIFICATION OF COMPLIANCE
Initials Date Remarks
• Construction activities that produce noise shall not take place outside of the allowable hours specified by the City of Newport Beach Municipal Code, with the exception of the 24 hour per day operation of microtunneling (pursuant to Mitigation Measure NOI-2). Alternative work hours may be designated by the City to reduce other impacts, such as traffic.
NOI-2 Prior to issuance of Demolition or Building Permits, the Orange County Sanitation District, or designee, shall retain a qualified Acoustical Engineer, defined as an individual with a bachelor’s degree or above in acoustics, physics, or another closely related engineering discipline and demonstrated field experience, to prepare a Construction Noise Control Plan. The Construction Noise Control Plan shall identify the types, location, and duration of equipment to be used during project construction. Construction noise levels shall be quantified and estimated at the nearest sensitive uses (i.e., residences, schools, churches, recreation/park facilities, hospitals, libraries, etc.) within 1,000 feet of the project construction area. Based on proposed construction hours and equipment to be used, the Construction Noise Control Plan shall identify noise reduction measures to minimize construction noise levels at off-site sensitive uses, demonstrating compliance with the Newport Beach Municipal Code Chapter 10.26 and 10.28. Noise reduction measures may include the use of sound blankets, sound walls/barriers, noise shrouds, and/or limiting the use of heavy noise-emitting equipment to non-sensitive hours (during daytime work hours and not after 5:00 p.m., etc.). The noise reduction measures shall be included in the project engineering
Completion of Construction Noise Control Plan; Review and Approval of Engineering Drawings, Specifications, Project Designs, and Construction Plans; Construction Inspection
Prior to Issuance of Demolition or Building Permits; During Construction
Orange County Sanitation District; Acoustical Engineer; City of Newport Beach
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 4-17 Mitigation Monitoring & Reporting Program
Mitigation Number Mitigation Measure Monitoring and Reporting Process
Monitoring Milestones Party Responsible for Monitoring
VERIFICATION OF COMPLIANCE
Initials Date Remarks drawings and specifications, and/or contractor shop drawings for review by the City of Newport Beach Planning Division. All noise reduction measures identified in the Construction Noise Control Plan approved by the City of Newport Beach shall be included in all project designs and construction plans for the project. 5.11 Transportation TRA-1 Prior to initiation of construction activities, engineering drawings and specifications, and/or contractor shop drawings shall be prepared by the Project Engineer, or designee, and submitted for review and approval by the Orange County Sanitation District, California Department of Transportation (Caltrans), and the City of Newport Beach Public Works Department. These documents shall, at a minimum, address the following:
• Traffic control protocols shall be specified for any lane closure, detour, or other disruption to traffic circulation, including bicycle and pedestrian trails. Disruption to traffic circulation shall be minimized to the greatest extent feasible. Bicycle and pedestrian trails shall remain open, to the greatest extent feasible, during construction or shall be re-routed to ensure continued connectivity.
• Bus stop access impacts shall be coordinated with, and approved by, the Orange County Transportation Authority.
• At least one week before any construction activities that would affect travel on nearby roadways, the construction contractor shall notify the City of Newport Beach Public
Review and Approval of Engineering Drawings, Specifications, and/or Contractor Shop Drawings; Construction Inspection
Prior to and During Construction
Orange County Sanitation District; California Department of Transportation; City of Newport Beach Public Works Department; Orange County transportation Authority (if necessary); Construction Contractor
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 4-18 Mitigation Monitoring & Reporting Program
Mitigation Number Mitigation Measure Monitoring and Reporting Process
Monitoring Milestones Party Responsible for Monitoring
VERIFICATION OF COMPLIANCE
Initials Date Remarks Works Department and Caltrans, as applicable, of construction activities that could impede movement (such as lane closures) along roadways, to allow for planning temporary detours or identifying alternative emergency access routes where appropriate. Surrounding property owners shall also be notified of project activities through advanced mailings.
• Identify construction vehicle haul routes for the delivery of construction materials (i.e., lumber, tiles, piping, windows, etc.) to the site; necessary traffic controls and detours; and a construction phasing plan for the project to reduce impacts to local streets and plan for traffic control signage and detours along identified haul routes to minimize impacts to existing traffic flow.
• Identify any and all construction staging or material storage sites located outside of the project site.
• Specify the hours during which hauling activities can occur and methods to mitigate construction-related impacts to adjacent streets such as traffic control barricades, cones, flaggers, and warning signs.
• Require the contractor to keep all haul routes clean and free of debris, including but not limited, to gravel and dirt resulting from project construction. The Contractor shall clean adjacent streets, as directed by the Orange County Sanitation District, of any project material which may have been
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 4-19 Mitigation Monitoring & Reporting Program
Mitigation Number Mitigation Measure Monitoring and Reporting Process
Monitoring Milestones Party Responsible for Monitoring
VERIFICATION OF COMPLIANCE
Initials Date Remarks spilled, tracked, or blown onto adjacent City of Newport Beach and Caltrans streets or areas.
• Hauling of oversize loads shall be allowed between the hours of 9:00 a.m. and 3:00 p.m. only, Monday through Friday. No hauling or transport shall be allowed during nighttime hours, weekends, or Federal holidays. Any oversized loads utilizing Coast Highway shall obtain a Caltrans permit for such activities.
• Use of local streets shall be prohibited, except when required to provide direct access to the project site and in compliance with the approved project haul routes.
• Haul trucks entering or exiting public streets shall yield to public traffic at all times.
• If hauling operations cause any damage to existing pavement, streets, curbs, and/or gutters along the haul route, the contractor shall be fully responsible for repairs. The repairs shall restore the damaged property to its original condition.
• All construction-related staging of vehicles shall be kept out of the adjacent public roadways and shall occur on the project site or within additional off-street staging areas previously identified and arranged. Construction staging areas shall maintain public access to recreational activities.
• Construction-related lane closures would only occur between the hours of 8:30 a.m.
Final Environmental Impact Report Bay Bridge Pump Station and Force Mains Replacement Project
Final ● January 2021 4-20 Mitigation Monitoring & Reporting Program
Mitigation Number Mitigation Measure Monitoring and Reporting Process
Monitoring Milestones Party Responsible for Monitoring
VERIFICATION OF COMPLIANCE
Initials Date Remarks and 3:30 p.m., Monday through Friday. More or less restrictive closure hours may be prescribed by the City.
• Use of a construction flagperson (as deemed appropriate by the Orange County Sanitation District) to assist in maintaining efficient vehicle travel in both directions (particularly during peak travel hours) and use of construction signage and safe detour routes for pedestrians and bicyclists when travel lanes and sidewalks along Coast Highway are affected.
• The engineering drawings and specifications shall meet standards established in the current California Manual on Uniform Traffic Control Device (MUTCD).
OC SAN 25-18-1
RESOLUTION NO. OC SAN 25-18
RESOLUTION OF THE BOARD OF DIRECTORS OF THE
ORANGE COUNTY SANITATION DISTRICT APPROVING
AND ADOPTING ADDENDUM NO. 2 TO THE
ENVIRONMENTAL IMPACT REPORT FOR THE BAY
BRIDGE PUMP STATION AND FORCE MAINS
REPLACEMENT PROJECT (PROJECT NO. 5-67)
PURSUANT TO THE CALIFORNIA ENVIRONMENTAL
QUALITY ACT
WHEREAS, the Orange County Sanitation District (“OC San”) is the lead agency
under the California Environmental Quality Act (“CEQA”) for the Bay Bridge Pump Station
and Force Mains Replacement Project (“Project”);
WHEREAS, on February 24, 2021, OC San certified an environmental impact
report for the Project (the “Project EIR”) pursuant to CEQA (State Clearinghouse No.
2016111031);
WHEREAS, on July 26, 2023, OC San adopted Addendum No. 1 to the Project
EIR (“Addendum No. 1”) and approved certain modifications to the Project which were
analyzed in Addendum No. 1;
WHEREAS, Bayside Village Marina LLC has offered to allow for the staging of
construction materials for the Project on a portion of its property (“Bayside Village
Property”);
WHEREAS, the Project contractor, J.F. Shea, (“Contractor”) has informed OC San
that it is necessary to make nighttime deliveries of oversized loads to the Project site via
Coast Highway;
WHEREAS, TRA-1 in the Project EIR permits deliveries of oversized loads via
Coast Highway with a Caltrans permit but only during weekday hours of 9 a.m. to 3 p.m.;
WHEREAS, Caltrans permits deliveries of oversized loads via Coast Highway
during the nighttime hours; thus, in order to deliver all necessary equipment and loads to
the Project site safely, TRA-1 must be modified to permit nighttime deliveries of oversized
loads via Coast Highway with a Caltrans permit;
WHEREAS, OC San has analyzed the potential environmental impacts of using a
portion of the Bayside Village Property as a staging area for the Project and modifications
to TRA-1 to allow nighttime deliveries of oversized loads via Coast Highway with a
Caltrans permit (“Modified Project”) in Addendum No. 2 to the Project EIR (“Addendum
No. 2”) pursuant to State CEQA Guidelines section 15164; and
OC SAN 25-18-2
WHEREAS, the Modified Project, as further described in Addendum No. 2, would
not result in any new significant impacts or a substantial increase in the severity of
previously identified significant impacts and no further environmental review is thus
required pursuant to Public Resources Code Section 21166 and State CEQA Guidelines
sections 15162 and 15164; and
WHEREAS, the Board of Directors has reviewed and considered the Project EIR,
Addendum No. 1, Addendum No. 2, and all oral and written testimony submitted to OC
San in relation to the Modified Project, and all other information in the administrative
record; and
WHEREAS, all other legal prerequisites to the adoption of this Resolution have
occurred.
NOW, THEREFORE, the Board of Directors of OC San does hereby find,
determine, resolve, and order as follows:
Section 1. The above recitals are true and correct and incorporated herein by
reference.
Section 2. The Board of Directors has reviewed and considered the Project EIR,
Addendum No. 1, and Addendum No. 2, and the Board of Directors finds that these
documents, taken together, have been completed in compliance with CEQA and contain
a complete and accurate reporting of all of the potential environmental impacts associated
with the Modified Project.
Section 3. Based on the substantial evidence set forth in the record, including
but not limited to, the Project EIR, Addendum No. 1, Addendum No. 2, and all oral and
written testimony submitted to OC San in relation to the Modified Project, the Board of
Directors finds that an addendum is the appropriate document for disclosing the impacts
of the Modified Project, and that none of the conditions identified in Public Resources
Code section 21166 and State CEQA Guidelines section 15162 requiring subsequent
environmental review have occurred, because:
(a) The Modified Project does not constitute a substantial change that would
require major revisions of the Project EIR due to the involvement of new
significant environmental effects or a substantial increase in the severity of
previously identified significant effects.
(b) There is not a substantial change with respect to the circumstances under
which the Modified Project will be constructed that would require major
revisions of the Project EIR due to the involvement of new significant
environmental effects or a substantial increase in the severity of the
previously identified significant effects.
OC SAN 25-18-3
(c) The Board of Directors has not been presented with new information of
substantial importance, which was not known and could not have been
known with the exercise of reasonable diligence at the time the Project EIR
was certified, that shows any of the conditions set forth in State CEQA
Guidelines section 15162(a)(3).
Section 4. The Board of Directors hereby approves and adopts Addendum No.
2.
Section 5. The Board of Directors hereby approves the modifications to the
Project as identified and described in Addendum No. 2.
Section 6. The Project EIR, Addendum No. 1, Addendum No. 2, and all other
materials that constitute the record of proceedings upon which these findings have been
based are on file and available for public review at 18480 Bandilier Circle, Fountain Valley,
CA 92708.
PASSED, APPROVED, AND ADOPTED at a regular meeting of the Orange
County Sanitation District Board of Directors held on September 24, 2025.
______________________
Ryan P. Gallagher Board Chairman
ATTEST:
Kelly A. Lore, MMC
Clerk of the Board
OC SAN 25-18-4
STATE OF CALIFORNIA )
) ss
COUNTY OF ORANGE )
I, Kelly Lore, Clerk of the Board of Directors of the Orange County Sanitation District, do
hereby certify that the foregoing Resolution No. OC SAN 25-18 was passed and
adopted at a regular meeting of said Board on the 24th day of September 2025, by the
following vote, to wit:
AYES:
NOES:
ABSTENTIONS:
ABSENT:
IN WITNESS WHEREOF, I have hereunto set my hand and affixed the official seal of
Orange County Sanitation District this 24th day of September 2025.
_________________________________
Kelly A. Lore, MMC
Clerk of the Board of Directors
Orange County Sanitation District
STEERING COMMITTEE
Agenda Report
Headquarters
18480 Bandilier Circle
Fountain Valley, CA 92708
(714) 593-7433
File #:2025-4474 Agenda Date:9/24/2025 Agenda Item No:3.
FROM:Robert Thompson, General Manager
Originator: Mike Dorman, Director of Engineering
SUBJECT:
IRWD/OC SAN AGREEMENT DEAL POINTS
GENERAL MANAGER'S RECOMMENDATION
RECOMMENDATION: Recommend to the Board of Directors to:
Authorize the preparation of two new agreements and a resolution to streamline operations, better
align billing with services provided, and maximize the use of existing infrastructure in Orange County
as follows:
1.Agreement No. 1 between Orange County Sanitation District (OC San) and Irvine Ranch
Water District (IRWD) will realign boundaries and payment structures with current service
provisions. This agreement will consolidate many prior agreements that were created as
development occurred.
2.Agreement No. 2 between OC San, IRWD, and Orange County Water District (OCWD) will
replace the current Green Acres Project (GAP) Agreement which expires in January 2027.
3.An OC San Board of Directors resolution will support the Orange County Local Agency
Formation Commission (OC LAFCO) process to annex the former Los Alisos Water District
(LAWD) area into OC San’s service area.
BACKGROUND
Relating to the first agreement,IRWD and OC San have had cooperative agreements dating back to
the early 1960s.IRWD formally joined the Joint Powers Authority that defined the County Sanitation
Districts of Orange County (OC San’s predecessor agency)in 1986 as County Sanitation District of
Orange County #14.Map No.1,attached,shows the districts that cooperated to share the costs of
wastewater treatment via shared treatment works and outfall facilities before consolidation.
When the County Sanitation Districts of Orange County consolidated to form OCSD in 1998,IRWD,
through County Sanitation District of Orange County #14,chose not to be consolidated in the same
way as the other districts.IRWD owns and operates the Michelson Water Reclamation Plant
(MWRP),which has the capacity to recycle the majority of the wastewater generated within County
Sanitation District of Orange County #14 and is located within IRWD’s service area.
Orange County Sanitation District Printed on 9/16/2025Page 1 of 5
powered by Legistar™
File #:2025-4474 Agenda Date:9/24/2025 Agenda Item No:3.
For accounting purposes, OC San is now separated into two areas:
1.Consolidated Revenue Area (CRA)
2.Revenue Area 14 (RA14)
Businesses and residents in the CRA pay fees directly to OC San for regional wastewater treatment,
recycling,and disposal.Businesses and residents in RA14 pay wastewater fees to IRWD as the
majority of wastewater is treated at MWRP.There are some areas where direct payment and service
provision do not align well with the current boundaries thus there are four additional situations to
consider for realignment:
1.Wastewater from RA14 that flows to OC San Reclamation Plants No. 1 or No. 2
2.Wastewater from CRA that flows to MWRP
3.Wastewater that IRWD chooses to divert from MWRP to OC San; and
4.Wastewater that IRWD diverts from CRA to MWRP
For the first and second cases described above,IRWD and OC San have cooperated for many
years.In most cases,these areas exist to minimize the construction of pump stations.Associated
“flow credits”are traded between the agencies through a series of flow accommodation agreements
to properly account for costs of service.Map No.2 is attached showing these areas.Debit and credit
flow amounts are tracked to create a monthly “net flow” between CRA and RA14.
For the third case described above,IRWD will retain the right to divert wastewater attributable to
MWRP to OC San.This is necessary because IRWD does not have an ocean outfall and uses this
diversion as a last option when that wastewater flow cannot be utilized or treated by IRWD.OC San
bills IRWD for the treatment of these wastewater flows as OC San does not collect fees directly from
ratepayers in RA14.
The fourth case described above is also associated with an existing agreement as this wastewater is
attributable to CRA but flows through infrastructure owned and operated by IRWD.IRWD has
constructed facilities to divert this flow to MWRP for treatment and reclamation;however,this
wastewater could still flow to the CRA if the diversion was shut down.
The current arrangement where IRWD collects a fee for regional wastewater treatment service and
pays a different per gallon fee to OC San,though serviceable,is a challenge from an accounting
point of view.The staffs of IRWD and OC San have been working together to simplify the accounting
and reduce the number of flow accommodation agreements between the agencies.The guiding
principle is for wastewater to flow by gravity to existing facilities for treatment.Applying this principle
will minimize the costs of flow monitoring across boundary lines and will allow for system users to
directly pay the agency providing service.
For the second agreement,OC San,IRWD,OCWD,and the City of Newport Beach originally
partnered on the GAP agreement which provides IRWD the right to discharge treated wastewater into
OC San’s outfall system.IRWD is able to transport treated,reclaimed wastewater from MWRP to
either of OC San’s Reclamation Plants through the OCWD GAP pipeline.This capability is used
when IRWD’s reclaimed water storage facilities are at capacity and reclaimed water demand in both
IRWD’s and OCWD’s reclaimed water system is less than the reclaimed water produced by MWRP.
This agreement is ecologically beneficial because it is a superior alternative to discharging reclaimed
water into the Newport Back Bay estuary.The reclaimed water can also be made available to theOrange County Sanitation District Printed on 9/16/2025Page 2 of 5
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water into the Newport Back Bay estuary.The reclaimed water can also be made available to the
Groundwater Replenishment System (GWRS) as a feed water supply.
For the proposed resolution,in 2000,IRWD annexed the former LAWD area,which was previously
associated with the South Orange County Wastewater Authority.Currently,wastewater from within
the LAWD is not allowed to be brought into OC San’s service area for treatment.Annexing this area
into OC San’s service area will provide IRWD with operational flexibility between MWRP and its Los
Alisos Water Recycling Plant (LAWRP). This annexation will require OC LAFCO approval.
RELEVANT STANDARDS
·Sound engineering and accounting practices, complying with local, state, and federal laws
·Maintain collaborative and cooperative relationships with regulators,stakeholders,and
neighboring communities
·Maintain a culture of improving efficiency to reduce the cost to provide the current service level
or standard
PROBLEM
As Orange County has developed,there are multiple locations where flow accommodation
agreements have been entered into to simplify the handling of wastewater flows.These areas must
be routinely monitored and tracked to ensure accurate invoicing and require significant resources
from both OC San and IRWD.
In addition,the existing GAP agreement will expire in January 2027.Without a similar agreement in
place,the shared beneficial reuse of reclaimed water between OC San,IRWD,and OCWD will no
longer be available in its current form.
Lastly,IRWD has limited flexibility for the treatment of wastewater flows within their service area as
portions of these flows are generated outside of OC San’s service area.
PROPOSED SOLUTION
Authorize the development of a new agreement to adjust the boundary between CRA and RA14 and
supersede the existing flow accommodation agreements.
Authorize the development of a new agreement to replace the current GAP prior to its expiration in
2027.
Authorize the development of a resolution to support annexation of the former LAWD area into OC
San’s service area.
TIMING CONCERNS
Timely execution of the recommended agreements and annexation is important to facilitate their
processes.The boundary adjustment agreement will require performance of a comprehensive rate
study that will require Proposition 218 notification requirements to ratepayers.To complete this
process in advance of the next fiscal year,it is important to commence this process as soon as
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process in advance of the next fiscal year,it is important to commence this process as soon as
possible.
In addition,the GAP Agreement is set to expire in January 2027.Approving a replacement
agreement well in advance ensures continuity,prevents a contractual gap,and preserves the ability
to manage effluent discharges in an environmentally and fiscally responsible manner.
The annexation of the former LAWD area requires OC LAFCO approval,and early initiation of this
process is necessary to avoid unnecessary delays and to provide IRWD with the flexibility to optimize
operations between its facilities.
RAMIFICATIONS OF NOT TAKING ACTION
If no action is taken,OC San and IRWD would be required to continue relying on multiple flow
accommodation agreements to account for wastewater service responsibilities.This would
perpetuate a more complex and resource-intensive administrative process,increasing staff time
spent on accounting and reconciliation,and potentially creating confusion for ratepayers about
service costs.Maintaining the existing structure also limits opportunities to simplify cost allocation,
reduce administrative overhead, and improve transparency in financial management.
Upon expiration of the GAP Agreement,IRWD’s treated effluent cannot be provided to OC San or
OCWD for ocean discharge or beneficial reuse.This valuable resource would be discharged in a
less environmentally beneficial manner and could pose operational challenges.
Similarly,without approval of the annexation of the former LAWD area into OC San’s service
boundary,IRWD’s operational flexibility between MWRP and the LAWRP would remain constrained.
This could hinder regional efficiency,delay future opportunities for OC San to receive additional flows
and associated revenue and leave the service area with inconsistent cost-of-service alignment.
PRIOR COMMITTEE/BOARD ACTIONS
N/A
ADDITIONAL INFORMATION
The new agreement that will replace the existing flow accommodation agreements will result in
impacts on four zones as described below and as shown in Map No.3.Zones 1 through 3 will shift
from RA14 to the CRA while Zone 4 still covers wastewater generated in the CRA and is treated by
MWRP:
·Zone 1: The Orange Park Acres Agreement area.
·Zone 2:Portions of the Irvine Business Complex (IBC)and Tustin Marine Corps Air Facility
(MCAF)Agreement area;the United States Food and Drug Administration (USFDA)
Agreement area; and additional adjacent areas that were identified during review.
·Zone 3:The San Joaquin Hills Planned Community Agreement area and the Coyote
Canyon/Gas Recovery System (GRS) Agreement area.
·Zone 4: The Jamboree and Bison Agreement area.
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This boundary adjustment will shift approximately 3.8 million gallons per day of attributable flow from
RA14 to the CRA.
Wastewater from portions of Lemon Heights and Cowan Heights flows through IRWD’s Havard
Avenue Trunk Sewer (HATS)and then continued via gravity flow to OC San’s Reclamation Plant No.
1.IRWD has since built facilities to divert that wastewater to MWRP for reuse.IRWD may either
divert that wastewater to MWRP or allow that wastewater to continue to OC San facilities at no
charge and with no flow credit. These areas will remain in the CRA.
Annexation will provide IRWD additional treatment flexibility and provide IRWD and those it serves a
more robust system. The proposed annexation limits are shown in Map No. 4.
CEQA
N/A
FINANCIAL CONSIDERATIONS
The proposed boundary transfers will streamline financial administration by eliminating multiple flow
accommodation agreements,thereby reducing administrative costs and simplifying accounting.
Annexation of the former LAWD area into OC San’s service boundary will not create new short-term
costs but will provide long-term financial and operational benefits.
ATTACHMENT
The following attachment(s)may be viewed on-line at the OC San website (www.ocsan.gov)with the complete agenda
package:
·Map No. 1: Service Areas (Districts) Before Consolidation
·Map No. 2: OC San/IRWD Flow Accommodation Agreement Areas
·Map No. 3: Proposed Modifications
·Map No. 4: Proposed Annexation of Los Alisos Area
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0 4.52.25 Km
0 21Mi
Map 2: OC San/IRWD Flow
Accommodation Agreement Areas
ORANGE
VILLAPARK
SANTAANA
TUSTIN
IRVINE
COSTAMESA
NEWPORTBEACH
LAGUNAHILLS
LAGUNAWOODS
ALISOVIEJO
LAGUNABEACH
Orange Park AcresAgreement
IBC/Tustin MCAFAgreement
USFDAAgreement
San Joaquin HillsAgreement
Coyote Canyon/GRSAgreement
HATSAgreements
Jamboree& BisonAgreement
}þ133133
}þ2222
}þ5555
}þ7373
}þ5757
}þ261261
}þ241241
5
405
5
Rev.
9/04/2025Sewer
14
Consolidated
Revenue Areas
Service Area Boundary
Agreement
Flow Accommodation Area
Approximate Scale
OC San
0 4.52.25 Km
0 21Mi
Map 3: Proposed Modifications
ORANGE
VILLAPARK
SANTAANA
TUSTIN
IRVINE
COSTAMESA
NEWPORTBEACH
LAGUNAHILLS
LAGUNAWOODS
ALISOVIEJO
LAGUNABEACH
Zone 1
Zone 2
Zone 4
Zone 3
}þ133133
}þ2222
}þ5555
}þ7373
}þ5757
}þ261261
}þ241241
5
405
Rev.
9/04/2025
14 (RA14)
Consolidated (CRA)
Sewer
Transfer to CRA
Revenue Areas (RA)
Service Area Boundary
Revised Agreement
Proposed Modifications
Approximate Scale
OC San
Proposed CRA/RA14 Boundary
STEERING COMMITTEE
Agenda Report
Headquarters
18480 Bandilier Circle
Fountain Valley, CA 92708
(714) 593-7433
File #:2025-4512 Agenda Date:9/24/2025 Agenda Item No:4.
FROM:Robert Thompson, General Manager
Originator: Laura Maravilla, Director of Human Resources
SUBJECT:
SIDE LETTER TO THE MEMORANDUM OF UNDERSTANDING FOR THE INTERNATIONAL
UNION OF OPERATING ENGINEERS - LOCAL 501
GENERAL MANAGER'S RECOMMENDATION
RECOMMENDATION: Recommend to the Board of Directors to:
Authorize the execution of a Side Letter Modifying Article 19 -Standby Pay of the current
Memorandum of Understanding between Orange County Sanitation District and the International
Union of Operating Engineers Local 501 retroactive to the first pay period of July 2025.
BACKGROUND
The Memorandum of Understanding (MOU)between the Orange County Sanitation District (OC San)
and the International Union of Operating Engineers Local 501 (Local 501)became effective on July
1,2025.Since the signing of the MOU,the parties have identified the need for additional clarification
and modification to a specific provision of the MOU.
Specifically,Article 19 -Standby Pay includes a Special Risk Standby provision whereby employees
are compensated on a pro-rated basis for each day they are assigned to perform duties in support of
high-risk events,including seismic,weather,high flow and/or high impact events.The successor
agreement approved by the Board of Directors in July 2025,included an increase in Standby Pay
from $550 to $600 per week.The rate for the Special Risk Standby should have been updated to
reflect this increase from $78.57 to $85.71 per day.
The side letter will serve as a formal addendum to the MOU and will not alter any other provisions
that were agreed upon by both parties and approved by the Board.It will modify the Special Risk
Standby rate in alignment with the increase made to Standby Pay and ensure OC San can continue
to rely on this provision to achieve its work objectives.
RELEVANT STANDARDS
·Ensure the public’s money is wisely spent
·Negotiate fair and equitable labor agreements
·Maintain positive employer-employee relations
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PROBLEM
The successor agreement with Local 501 that was approved by the Board of Directors in July 2025
included an increase in Standby Pay from $550 to $600 per week.The associated Special Risk
Standby pro-rated of rate of $78.57 per day should have been updated to $85.71 per day to ensure
alignment with Standby Pay.
PROPOSED SOLUTION
Authorize the execution of a Side Letter Modifying Article 19 -Standby Pay of the current MOU OC
San and Local 501.
TIMING CONCERNS
It would be in the best interest of OC San to ensure the associated Special Risk Standby rate reflects
the accurate pro-rated rate following the approval and adoption of the MOU in July 2025.
RAMIFICATIONS OF NOT TAKING ACTION
Some of the impacts of not approving the updated pro-rated daily rate for Special Risk Standby may
include operational inefficiencies, employee satisfaction, and retention.
PRIOR COMMITTEE/BOARD ACTIONS
July 2025 -Adopted Resolution No.OC SAN 25-07,entitled “A Resolution of the Board of Directors
of the Orange County Sanitation District approving the Memorandum of Understanding (MOU)
between the Orange County Sanitation District and the International Union of Operating Engineers
Local 501,for Fiscal Years 2025/2026,2026/2027 &2027/2028”;and directed staff to finalize and
sign the Memorandum of Understanding (MOU)between Orange County Sanitation District and the
International Union of Operating Engineers Local 501 bargaining unit.
ADDITIONAL INFORMATION
N/A
CEQA
N/A
FINANCIAL CONSIDERATIONS
The anticipated cost is $6500 over the term of the 3-year agreement with Local 501 and will vary
based on the number of high-risk events.This request complies with the authority levels of OC San’s
Purchasing Ordinance. This item has been budgeted.
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ATTACHMENT
The following attachment(s)may be viewed on-line at the OC San website (www.ocsan.gov)with the complete agenda
package:
·Local 501 MOU Side Letter
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55880.00002\44188611.1
9-24-25
SIDE LETTER BY AND BETWEEN
THE ORANGE COUNTY SANITATION DISTRICT AND THE
INTERNATIONAL UNION OF OPERATING ENGINEERS – LOCAL 501
This Side Letter of Agreement (“Agreement” or “Side Letter”) is entered into by and
between the Orange County Sanitation District (“OC San”) and the International Union of
Operating Engineers Local 501 (“Local 501”) (collectively, the “Parties”) with respect to
the following:
WHEREAS, Local 501 is the recognized employee organization of 193 non-
exempt persons employed by OC San to perform skilled labor within the trades across
the Operations & Maintenance Department and General Manager’s Office; and
WHEREAS, on July 1, 2025, the Parties concluded a good-faith bargaining
process and entered into a Memorandum of Understanding (“MOU”) that set forth aspects
of employment, including wages, hours of work, and other terms and conditions; and
WHEREAS, among other changes, the MOU amended Article 19 - Standby Pay
whereby it was increased from $550 to $600 per week, but the “Special Risk Standby”
daily rate was not updated to reflect the agreed upon increase; and
WHEREAS, the “Special Risk Standby” pay provision compensates employees on
a pro-rated basis for each day they are assigned to perform duties in support of high-risk
events; and
WHEREAS, the Parties desire to enter into this Agreement to provide clarification
to provisions of the MOU in order to fully reflect the agreed upon terms.
NOW, THEREFORE, the Parties do hereby agree as follows:
1. Subsection 19.5 of Article 19 (“Standby Pay”) of the MOU is hereby amended as
follows, with additions in underline and deletions in strikethrough:
19.5. Special Risk Standby: In the event of a “special risk,” (e.g., based on
seismic, weather, high-flow, and/or high impact events), the Director of
Operations & Maintenance or his/her designee may designate specific
additional classifications to be on “Special Risk” standby. Employees on
Special Risk standby will be compensated on a pro-rated, daily basis,
$78.57 $85.71 for each day on Special Risk standby. All other terms and
conditions of the MOU between OC San and the Union not specifically
modified by this Side Letter shall remain unaffected and in full force and
effect.
55880.00002\44188611.1
9-24-25
APPROVAL:
___________________________________ ________________
Rob Thompson, General Manager – OC San Date
__________________________________ _________________
Reisee Salamero, Business Agent – Local 501 Date
STEERING COMMITTEE
Agenda Report
Headquarters
18480 Bandilier Circle
Fountain Valley, CA 92708
(714) 593-7433
File #:2025-4501 Agenda Date:9/24/2025 Agenda Item No:CS-1
FROM:Robert Thompson, General Manager
SUBJECT:
CONFERENCE WITH REAL PROPERTY NEGOTIATORS - GOVERNMENT CODE SECTION
54956.8
RECOMMENDATION: Convene in Closed Session:
A.Property: 10700 Spencer Street, Fountain Valley, CA - APN No.156-154-07 and 156-163-16.
Agency negotiators: General Manager Rob Thompson; Assistant General Manager Lorenzo
Tyner; and Director of Finance Wally Ritchie.
Negotiating parties: Shabtai Itzhak Tr Ins Tr
Under negotiation: Price and Terms of payment
B.Property: 18250 Euclid Street, Fountain Valley, CA - APN No.156-171-41.
Agency negotiators: General Manager Rob Thompson; Assistant General Manager Lorenzo
Tyner; and Director of Finance Wally Ritchie.
Negotiating parties: Rexford Industrial Realty LP
Under negotiation: Price and Terms of payment
BACKGROUND
During the course of conducting the business set forth on this agenda as a regular meeting of the
Board,the Chairperson may convene the Board in closed session to consider matters of pending real
estate negotiations, pending or potential litigation, or personnel matters.
Reports relating to (a)purchase and sale of real property;(b)matters of pending or potential
litigation;(c)employment actions or negotiations with employee representatives;or which are exempt
from public disclosure under the California Public Records Act,may be reviewed by the Board during
a permitted closed session and are not available for public inspection.At such time the Board takes
final action on any of these subjects, the minutes will reflect all required disclosures of information.
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RELEVANT STANDARDS
·Government Code Sections 54956.8, 54956.9, 54957, or 54957.6, as noted
ATTACHMENT
The following attachment(s)are included in hard copy and may also be viewed on-line at the OCSD website
(www.ocsd.com) with the complete agenda package:
·Memorandum from General Counsel
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Scott C. Smith
(949) 263-6561
scott.smith@bbklaw.com
18101 Von Karman Avenue.Suite 1000.Irvine, CA 92612
Phone: (949) 263-2600 | Fax: (949) 260-0972
bbklaw.com
Memorandum
To: Honorable Chair and Members of the Orange County Sanitation District Steering Committee
From: General Counsel
Date: September 24, 2025
Re: Closed Session Item
The Steering Committee will hold a closed session on September 24, 2025, for the purpose of holding a conference with its real property negotiators regarding the price and terms of payment for real property located at 10700 Spencer Street and 18250 Euclid Street in Fountain Valley,
California. The closed session will be held pursuant to the authority of California Government Code section 54956.8. Respectfully submitted,
SCOTT C. SMITH
ORANGE COUNTY SANITATION DISTRICT
COMMON ACRONYMS
ACWA Association of California
Water Agencies LOS Level Of Service RFP Request For Proposal
APWA American Public Works
Association MGD Million Gallons Per Day RWQCB Regional Water Quality
Control Board
AQMD Air Quality Management
District MOU Memorandum of
Understanding SARFPA Santa Ana River Flood
Protection Agency
ASCE American Society of Civil Engineers NACWA National Association of Clean Water Agencies SARI Santa Ana River Interceptor
BOD Biochemical Oxygen Demand NEPA National Environmental Policy
Act SARWQCB Santa Ana Regional Water
Quality Control Board
CARB California Air Resources
Board NGOs Non-Governmental
Organizations SAWPA Santa Ana Watershed
Project Authority
CASA California Association of
Sanitation Agencies NPDES National Pollutant Discharge
Elimination System SCADA Supervisory Control And
Data Acquisition
CCTV Closed Circuit Television NWRI National Water Research
Institute SCAP
Southern California
Alliance of Publicly Owned Treatment Works
CEQA California Environmental
Quality Act O & M Operations & Maintenance SCAQMD South Coast Air Quality
Management District
CIP Capital Improvement
Program OCCOG Orange County Council of
Governments SOCWA South Orange County
Wastewater Authority
CRWQCB California Regional Water
Quality Control Board OCHCA Orange County Health Care
Agency SRF Clean Water State
Revolving Fund
CWA Clean Water Act OCSD Orange County Sanitation District SSMP Sewer System Management Plan
CWEA California Water Environment Association OCWD Orange County Water District SSO Sanitary Sewer Overflow
EIR Environmental Impact Report OOBS Ocean Outfall Booster Station SWRCB State Water Resources
Control Board
EMT Executive Management Team OSHA Occupational Safety and
Health Administration TDS Total Dissolved Solids
EPA US Environmental Protection Agency PCSA
Professional
Consultant/Construction
Services Agreement
TMDL Total Maximum Daily Load
FOG Fats, Oils, and Grease PDSA Professional Design Services
Agreement TSS Total Suspended Solids
gpd gallons per day PFAS
Per- and Polyfluoroalkyl
Substances WDR Waste Discharge
Requirements
GWRS Groundwater Replenishment
System PFOA Perfluorooctanoic Acid WEF Water Environment
Federation
ICS Incident Command System PFOS Perfluorooctanesulfonic Acid WERF Water Environment & Reuse Foundation
IERP Integrated Emergency
Response Plan POTW Publicly Owned Treatment
Works WIFIA Water Infrastructure
Finance and Innovation Act
JPA Joint Powers Authority ppm parts per million WIIN Water Infrastructure Improvements for the
Nation Act
LAFCO Local Agency Formation
Commission PSA Professional Services
Agreement WRDA Water Resources
Development Act
ORANGE COUNTY SANITATION DISTRICT
GLOSSARY OF TERMS
ACTIVATED SLUDGE PROCESS – A secondary biological wastewater treatment process where bacteria reproduce at a high rate with the introduction of excess air or oxygen and consume dissolved nutrients in the wastewater.
BENTHOS – The community of organisms, such as sea stars, worms, and shrimp, which live on, in, or near the seabed, also known as the benthic zone.
BIOCHEMICAL OXYGEN DEMAND (BOD) – The amount of oxygen used when organic matter undergoes decomposition by microorganisms. Testing for BOD is done to assess the amount of organic matter in water.
BIOGAS – A gas that is produced by the action of anaerobic bacteria on organic waste matter in a digester tank that can be used
as a fuel.
BIOSOLIDS – Biosolids are nutrient rich organic and highly treated solid materials produced by the wastewater treatment process. This high-quality product can be recycled as a soil amendment on farmland or further processed as an earth-like product for
commercial and home gardens to improve and maintain fertile soil and stimulate plant growth.
CAPITAL IMPROVEMENT PROGRAM (CIP) – Projects for repair, rehabilitation, and replacement of assets. Also includes treatment improvements, additional capacity, and projects for the support facilities.
COLIFORM BACTERIA – A group of bacteria found in the intestines of humans and other animals, but also occasionally found elsewhere, used as indicators of sewage pollution. E. coli are the most common bacteria in wastewater.
COLLECTIONS SYSTEM – In wastewater, it is the system of typically underground pipes that receive and convey sanitary wastewater or storm water.
CERTIFICATE OF PARTICIPATION (COP) – A type of financing where an investor purchases a share of the lease revenues of a program rather than the bond being secured by those revenues.
CONTAMINANTS OF POTENTIAL CONCERN (CPC) – Pharmaceuticals, hormones, and other organic wastewater contaminants.
DILUTION TO THRESHOLD (D/T) – The dilution at which the majority of people detect the odor becomes the D/T for that air sample.
GREENHOUSE GASES (GHG) – In the order of relative abundance water vapor, carbon dioxide, methane, nitrous oxide, and ozone gases that are considered the cause of global warming (“greenhouse effect”).
GROUNDWATER REPLENISHMENT SYSTEM (GWRS) – A joint water reclamation project that proactively responds to Southern California’s current and future water needs. This joint project between the Orange County Water District and OCSD provides 70
million gallons per day of drinking quality water to replenish the local groundwater supply.
LEVEL OF SERVICE (LOS) – Goals to support environmental and public expectations for performance.
N-NITROSODIMETHYLAMINE (NDMA) – A N-nitrosamine suspected cancer-causing agent. It has been found in the GWRS
process and is eliminated using hydrogen peroxide with extra ultra-violet treatment.
NATIONAL BIOSOLIDS PARTNERSHIP (NBP) – An alliance of the NACWA and WEF, with advisory support from the EPA. NBP is committed to developing and advancing environmentally sound and sustainable biosolids management practices that go beyond regulatory compliance and promote public participation to enhance the credibility of local agency biosolids programs and improved communications that lead to public acceptance.
PER- AND POLYFLUOROALKYL SUBSTANCES (PFAS) – A large group (over 6,000) of human-made compounds that are resistant to heat, water, and oil and used for a variety of applications including firefighting foam, stain and water-resistant clothing, cosmetics, and food packaging. Two PFAS compounds, perfluorooctanesulfonic acid (PFOS) and perfluorooctanoic acid (PFOA) have been the focus of increasing regulatory scrutiny in drinking water and may result in adverse health effects including developmental effects to fetuses during pregnancy, cancer, liver damage, immunosuppression, thyroid effects, and other effects.
PERFLUOROOCTANOIC ACID (PFOA) – An ingredient for several industrial applications including carpeting, upholstery, apparel, floor wax, textiles, sealants, food packaging, and cookware (Teflon).
PERFLUOROOCTANESULFONIC ACID (PFOS) – A key ingredient in Scotchgard, a fabric protector made by 3M, and used in numerous stain repellents.
PLUME – A visible or measurable concentration of discharge from a stationary source or fixed facility.
PUBLICLY OWNED TREATMENT WORKS (POTW) – A municipal wastewater treatment plant.
SANTA ANA RIVER INTERCEPTOR (SARI) LINE – A regional brine line designed to convey 30 million gallons per day of non-reclaimable wastewater from the upper Santa Ana River basin to the ocean for disposal, after treatment.
SANITARY SEWER – Separate sewer systems specifically for the carrying of domestic and industrial wastewater.
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT (SCAQMD) – Regional regulatory agency that develops plans and
regulations designed to achieve public health standards by reducing emissions from business and industry.
SECONDARY TREATMENT – Biological wastewater treatment, particularly the activated sludge process, where bacteria and other microorganisms consume dissolved nutrients in wastewater.
SLUDGE – Untreated solid material created by the treatment of wastewater.
TOTAL SUSPENDED SOLIDS (TSS) – The amount of solids floating and in suspension in wastewater.
ORANGE COUNTY SANITATION DISTRICT
GLOSSARY OF TERMS
TRICKLING FILTER – A biological secondary treatment process in which bacteria and other microorganisms, growing as slime on the surface of rocks or plastic media, consume nutrients in wastewater as it trickles over them.
URBAN RUNOFF – Water from city streets and domestic properties that carry pollutants into the storm drains, rivers, lakes, and oceans.
WASTEWATER – Any water that enters the sanitary sewer.
WATERSHED – A land area from which water drains to a particular water body. OCSD’s service area is in the Santa Ana River Watershed.