Castaic Lake Water Agency

Transcription

FINAL
Environmental Impact Report
California State Clearinghouse No. 2005041138
Recycled Water Master Plan
FINAL EIR
Response to Comments
Prepared for
27234 Bouquet Canyon Road
Santa Clarita, CA 91350
March 2007
Prepared by
BonTerra Consulting
3452 E. Foothill Blvd., Suite 420
Pasadena, CA 91107
Final RWMP Program EIR
TABLE OF CONTENTS
1
2
1.0
Introduction
3
2.0
Public Comments Letters on Draft PEIR
4
3.0
Responses to Comments
5
4.0
Changes to the Draft PEIR Text
R:\PAS\Projects\CLWA\J001\RTC\Final R2C-032007.doc
i
1
1.0 INTRODUCTION
2
3
4
5
6
7
8
9
10
11
The purpose of this document is to present public comments received during the public review
period and the responses to those comments received on the Draft Program Environmental
Impact Report (PEIR) for the Castaic Lake Water Agency (CLWA) Recycled Water Master Plan
(RWMP) project located in the Santa Clarita Valley in Los Angeles County, California. The
Draft PEIR was initially available for a 45-day public review and comment period from
November 15, 2006 through January 3, 2007. The public review period was extended for an
additional 30 days to February 2, 2007. In accordance with the State of California
Environmental Quality Act (CEQA) Guidelines §15088, the CLWA, as the lead agency, has
evaluated the comments received on the Draft PEIR and has prepared written responses to
these comments.
12
13
14
15
16
17
The Final PEIR for the RWMP contains three volumes. Volume I of the Final PEIR, incorporated
herein by reference, comprises the Draft PEIR, published in November 2006. Volume II of the
Final PEIR contains the technical appendices to the Draft PEIR. Volume III (this volume)
contains the public comments received on the Draft PEIR during the public review period
(November 15, 2006 to February 2, 2007), CLWA’s responses to those public comments, and
subsequent changes to the text of the Draft PEIR.
18
As required by CEQA Guidelines §15132, the Final PEIR shall consist of:
19
(a)
The draft EIR or a revision of the draft.
20
21
(b)
Comments and recommendations received on the draft EIR either verbatim or in
summary.
22
23
(c)
A list of persons, organizations, and public agencies commenting on the draft
EIR.
24
25
(d)
The responses of the Lead Agency to significant environmental points raised in
the review and consultation process.
26
(e)
Any other information added by the Lead Agency.
27
28
29
30
31
32
33
Comments submitted on the Draft PEIR include questions about potential impacts to water
quality, traffic, cultural resources, and biological resources that would result from the
implementation of the RWMP. Each comment letter received is included in Section 2 and each
question/comment is manually numbered on the letter and corresponds to CLWA’s responses
in Section 3. Volume III must be read in conjunction with Volumes I and II and is not intended
to be a “stand-alone” document. Information contained within Volume III is summarized
below.
34
Section 1 – Introduction
35
36
37
Section 2 – Public Comments contains the list of agencies and individuals that submitted
comment letters on the Draft PEIR and copies of those letters. Each substantive comment is
numbered and corresponds to CLWA’s responses in Section 3.
2
1
2
3
Section 3 – Responses to Comments contains a matrix including each of the public comments
received and individual responses to those comments. The comments in the matrix were
excerpted directly from the comment letters.
4
5
Section 4 – Changes to the Text of the EIR presents text changes since publication of the Draft
PEIR.
6
7
8
9
10
Copies of Volume III of the Draft PEIR and a Notice of Availability identifying the date of the
public meeting at which the CLWA Board of Directors is scheduled to consider certification of
the Draft PEIR were mailed to those agencies who provided comments on the Draft PEIR.
Copies of the Final PEIR are available at CLWA, 27234 Bouquet Canyon Road, Santa Clarita,
California 93150-2173 and are available for public review at the following local public libraries:
11
12
13
Los Angeles County Public Library, Newhall
22704 W. 9th Street
Newhall, CA 91321
14
15
16
Los Angeles County Public Library, Canyon Country Jo Anne Darcy Library
18601 Soledad Canyon Road
Canyon Country, CA 91351
17
18
19
Los Angeles County Public Library, Valencia
23743 West Valencia Boulevard
Valencia, CA 91355
20
21
22
Ventura County Library
646 County Square Drive, Ste. 150
Ventura, CA 93001
23
24
If the CLWA Board of Directors acts to certify the Final PEIR, a Notice of Determination will be
filed with Los Angeles County and Ventura County and the California State Clearinghouse.
3
2.0 PUBLIC COMMENT LETTERS ON DRAFT PEIR
1
Name
Agency
Department
Date of
Correspondence
Captain S.V. Bernard
State of California
Department of California Highway Patrol
January 2, 2007
Cheryl J. Powell
State of California
Department of Transportation
December 8, 2006
Samuel Unger
State of California
Los Angeles Regional Water Quality
Control Board
February 2, 2007
Dave Singelton
State of California
Native American Heritage Commission
December 6, 2006
Scott Morgan
State of California
OPR- State Clearinghouse
November 14, 2006
Scott Morgan
State of California
December 21, 2006
Terry Roberts
State of California
February 5, 2007
Kim Wittorff
State of California
State Water Resources Control Board
December 27, 2006
James F. Stahl
County of Los Angeles
County Sanitation Districts
January 3, 2007
Bryan Moscardini
Department of Parks and Recreation
January 3, 2007
Donald L. Wolfe
Department of Public Works
February 1, 2007
Carl Morehouse
County of Ventura
Watershed Protection District
December 22, 2006
Ron Bottorff
Friends of the Santa Clara River
N/A
February 2, 2007
David Lutness
SCOPE
N/A
February 1, 2007
Jennifer Robinson
Sierra Club
Angeles Chapter
November 28, 2006
Jennifer Robinson
Sierra Club
Angeles Chapter
February 2, 2007
James Chuang
Southern California Gas Company
N/A
January 3, 2007
Dana L. Wisehart
United Water Conservation
District
N/A
January 31, 2007
Ed and Joan Dunn
N/A
N/A
February 2, 2007
2
4
State of Califomia-Business, Transportation and Housing Agency
ARNOLD SCHWARZENEGGER, Governor
DEPARTMENT OF CALIFORNIA HIGHWAY PATROL
28648 The Old Road
Valencia, CA 91355
(661)294-5540
(800) 735-2929 (TTITDD)
(800) 735-2922 (Voice)
January 2, 2007
File No.: 540.9107.13086
Jeff Ford, Water Resources Planner
Dear Mr. Ford:
This is in response to the Notice of Availability for the Castaic Lake Water Agency's Recycled
Water Master Plan (SCH #2005041138). In reviewing this project, our concern was what effect
CHP-1
this project will have on traffic. It appears the traffic impact will be minimal. Sergeant G.
Jacobs will be our Department's contact person for the project. If you have any questions or
concerns, she may be reached at the above address or telephone number. Thank you for allowing
us the opportunity to comment on this project.
Sincerely,
A~
~
S. V. BERNARD, Captain
Commander
Newhall Area
Cc:
Southern Division
Special Projects Section
Safety, Service, and Security
STATE OF CALIFORNIA-BUSINESS, TRANSPORTATION AND HOUSING AGENCY
ARNOLD SCHWARZENEGGER, Governor
DEPARTMENT OF TRANSPORTATION
DISTRICT 7, OFFICE OF PUBLIC
TRANSPORTATION AND REGIONAL PLANNING
IGRlCEQA BRANCH
100 SOUTH MAIN STREET
LOS ANGELES, CA 90012
PHONE (213) 897-3747
FAX
(213) 897-1337
Flex your power!
Be energy efficient!
December 8, 2006
IGRlCEQA DEIR CS/061126
City of Santa Clarita
Castaic Lake Water Agency's Recycled Water
MasterPlan
Vic. LA-5-53.69, SCH# 2005041138
Mr. Jeff Ford
27234 Bouquet Canyon Rd.
Dear Mr. Ford:
Thank you for including the California Department of Transportation (Caltrans) in the environmental
review process for the proposed Master Plan. Based on the information received, we have the following
comments:
Any work to be performed within the State Right-of-way will need a Caltrans Encroachment
Permit. We recommend that construction related truck trips on State highways be limited to offpeak commute periods. Transport of over-size or over-weight vehicles on State highways will
need a Caltrans Transportation Permit.
If you have any questions regarding our comments, you may reach me at (213) 897-3747 and please refer
to our record number 061126/CS.
~,SiDCG:L8 [y
CHERYL J. POWELL
IGRlCEQA Program Manager
Office of Regional Planning
cc: Scott Morgan, State Clearinghouse
"Caltrans improves mobility across California"
Caltrans
-2
B-02-2007
~
14:15
CRWQCB-L8
213 576 6686
P.01/01
l~
California Regional Water-Quality Control Board
~
Los Angeles Region
¥
no w. 4th Street, Suite: 200, los Angeles. California 90013
Phone (213) 576~600 FAX (213) 576-6640 - mlcmct Address: http://www,watcrbcards.ca.gov/Josangeles
Arnold Scawaraenegger
Linda S. Adams
Col/EPA Secretary
~
GrlVenror
February 2,2007
JeffFord, Water Resources Planner
27234BouquetCanyonRoad
Santa Clarita, CA, 91350
COMMENTS ON DRAFT ENVIRONMENTAL IMPACT REPORT FOR THE CASTAIC
LAKE WATER AGENCY RECYCLED WATER MASTER PLAN SCH NO. 2005041138
Dear Mr. Ford:
Thank you for the opportunity to comment on the Draft Environmental Impact Report (DEIR) for
the Castaic Lake Water Agency Recycled Water Master Plan. The Castaic Lake Water Agency
Recycled Water Master Plan project site is located within the Santa Clara River watershed, and
lies within the jurisdiction of the Los Angeles Regional Water Quality Control Board (Regional
Board). Please address the following comments on the water quality section (Chapter 3.8) ofthe
DEIR:
The DEIR should include a detailed impact analysis of salt loadings to the Santa Clara River by
surface runoff from the use of recycled water. Currently, wastewater treatment does not routinely
include the removal ofsalts; therefore. recycled water generally contains high amounts of salts.
When recycled water is applied to land for irrigation purposes, water will be transpired into the
air while salts will stay in surface soil. Salts accumulated in surface soil can be transported to the
LARWQCB-3
Santa Clara River by stonnwater runoffor by incidental runoff, which poses water quality
problems. The DEIR states that release of enriched salts from soils will be diluted to the extent
that the impacts to receiving water bodies would be less than significant; however, no detailed
impact analysis and no mitigation measures were provided. Please provide detailed quantitative
analyses and mitigation to address these foreseeable impacts.
If you have any questions, please contact Regional Board staff Dr. Yanjie Chu at (213) 576-6681.
Sincerely,
Samuel Unger
Chief, Regional Programs
Cali/om;" Eltvironmental Protection Agency
1")
:
.,
_
_.1 •• _,
6
.'0 __.._,:_.. , __,.,Recycled
., Popel'
TomL P.01
STATE OF CALIFORNIA
Arnold Scbwarzenegger. Go vernor
NATIVE AMERICAN HERITAGE COMMISSION
915 CAPITOL MALL, ROOM 364
SACRAMENTO, CA 95814
(916) 653-6251
Fax (916) 657-5390
Web Site WWw nabc ca gOY
e-mail: [email protected]
December 6, 2006
Mr. Jeff Ford
Re: SCH#2005041138 CEQA Notice of Completion: draft Environmental Impact Report CDEIRl for Recycled Water
Master Plan for Castaic Lake Water Agency; Los Angeles County, Califomia
Dear Mr. Ford:
Thank you for the opportunity to comment on the above-referenced document. The Native American
Heritage Commission is the state's Trustee Agency for Native American Cultural Resources. The Califomia
Environmental Quality Act (CEQA) requires that any project that causes a substantial adverse change in the
significance of an historical resource, that includes archeological resources, is a 'significant effecf requiring the
preparation of an Environmental Impact Report (EIR) per CEQA guidelines§ 15064.5(b)(c). In order to comply with
this provision, the lead agency is required to assess whether the project will have an adverse impact on these
resources within the 'area of potential effect (APE)', and if so, to mitigate that effect. To adequately assess the
project-related impacts on historical resources, the Commission recommends the following action:
..J Contact the appropriate Califomia Historic Resources Information Center (CHRIS) .. The record search will
determine:
•
If a part or the entire APE has been preViously surveyed for cultural resources.
•
If any known cultural resources have already been recorded in or adjacent to the APE.
•
If the probability is low, moderate, or high that cultural resources are located in the APE.
•
If a survey is required to determine whether preViously unrecorded cultural resources are present.
..J If an archaeological inventory survey is required, the final stage is the preparation of a professional report detailing
the findings and recommendations of the records search and field survey.
•
The final report containing site forms, site significance, and mitigation measurers should be submitted
immediately to the planning department. All information regarding site locations, Native American human
remains, and associated funerary objects should be in a separate confidential addendum, and not be made
available for pubic disclosure.
•
The final written report should be submitted within 3 months after work has been completed to the appropriate
regional archaeological Information Center.
..J Contact the Native American Heritage Commission (NAHC) for:
*
A Sacred Lands File (SLF) search of the project area and information on tribal contacts in the project
vicinity who may have additional cultural resource information. Please provide this office with the following
citation format to assist with the Sacred Lands File search request: USGS 7.5-minute quadrangle citation
with name, township, range and section; ,
•
The NAHC advises the use of Native American Monitors to ensure proper identification and care given cultural
resources that may be discovered. The NAHC recommends that contact be made with Native American
Contacts on the attached list to get their input on potential project impact, particularly the contacts of the on the
list.
..J Lack of surface evidence of archeological resources does not preclude their subsurface existence.
•
Lead agencies should include in their mitigation plan provisions for the identification and evaluation of
accidentally discovered archeological resources, per Califomia Environmental Quality Act (CEQA) § 15064.5 (f).
In areas of identified archaeological sensitivity, a certified archaeologist and a culturally affiliated Native
American, with knowledge in cultural resources, should monitor all ground-disturbing activities.
•
Lead agencies should include in their mitigation plan provisions for the disposition of recovered artifacts, in
consultation with culturally affiliated Native Americans.
..J Lead agencies should include provisions for discovery of Native American human remains or unmarked cemeteries
in their mitigation plans.
NAHC-4
*
CEQA Guidelines, Section 15064.5(d) requires the lead agency to work with the Native Americans identified
by this Commission if the initial Study identifies the presence or likely presence of Native American human
remains within the APE. CEQA Guidelines provide for agreements with Native American, identified by the
NAHC, to assure the appropriate and dignified treatment of Native American human remains and any associated
grave liens.
" Health and Safety Code §7050.5, Public Resources Code §5097.98 and Sec. §15064.5 (d) ofthe CEQA
Guidelines mandate procedures to be followed in the event of an accidental discovery of any human remains in a
location other than a dedicated cemetery.
" Lead agencies should consider avoidance, as defined in § 15370 of the CEQA Guidelines. when significant cultural
resources are discovered during the course of project planning.
Please feel free to contact me at (916) 653-6251 if you have any questions.
Cc: State Clearinghouse
Attachment: List of Native American Contacts
NAHC-4
S TAT E OF CAL I FOR N I A
Governor's Office of Planning and Research
State Clearinghouse and Planning Unit
Arnold Schwarzenegger
Governor
Sean Walsh
Director
Memorandum
Date:
November 16, 2006
To:
All Reviewing Agencies
From:
Scott Morgan, Senior Planner
Re:
SCH # 2005041138
Castaic Lake Water Agency's Recycled Water Master Plan (RWMP)
The State Clearinghouse forwarded the above-mentioned project to your agency for
review on November 14, 2006 with incorrect review dates. Please make note of the
following information for your files:
OPR-5
Review period began: November 14, 2006
Review period ends: December 28, 2006
We apologize for any inconvenience this may have caused. All other project information
remains the same.
cc:
Jeff Ford
Santa Clarita, CA 91350-2173
1400 TENTH STREET P.O. BOX 3044 SACRAMENTO, CALIFORNIA 95812-3044
TEL (916) 445-0613 FAX (916) 323-3018 www.opr.ca.gov
FormA
Notice of Completion & Environmental Document Transmittal
SCH# 2005041138
Mail to: State Clearinghouse, 1400 Tenth Street, Sacramento, CA 95812-3044
916/445-0613
Project Title:
Lead Agency:
Street Address: 27234 Bouquet Canyon Road
City: Santa Clarita
Zip:
-
'P~oieci
Location: - --See pige-j" -..--. _.-
Comect Person: _J"e"'ff'-'F"'o"'rd"-?-9~13~5:l!0==·2c'.1.!.c73~
-
_~ _ u _ " • • • • • • • • • • _
Le s A: n.se.le~ Iventuro..
County:
~~~~~;~;,eSe~~rcei
o
o
o
NA
General Plan Update
General Plan Amendment
General Plan Element
Community Plan
0
t8I
0
0
Twp:
-., -
o
o
Specific Plan
MasterPlan
•• -
Planned Unit Development
o
Oland
Use P
--.
_ •••• ',-'- -- .-.-
n
••• n
-_.-.-
AII wIthtn CLWA
service area
NOV 1 4 2006 0
0
Prezo
Site:Plan
- •• ,
S1li'Tt" C:..iet:.. .:. .n:.:.tlV_·
::=_
Total Acres: 1-"1 '2 sq. ""'i.
Range: ..l:!L......... Base: NA
NA
Rezon
_
(661) 297-t600
Los Angeles
Santa Clara River and tributaries
All WIthm CLWA
service area
Schools:
Slate Hwy#:
Local Action Type:
o
0- -pO • • _ . 0 -
Zip: _N=A'-~_ _
NA
Airports:
.-.¥-
City/Nearest Community:
See page I
No.
Within 2 Miles:
Phone:
County:
Annexation
Redevelopment
f.&TATE CLEARING H04§l: Coastal Permit
, ~, .
L.J
Other
Development Type:
~
Federal --"CS.!,ON",A,-__
Funding (approx,):
State
Other:
$ NA
Recycled water distribution projccl
Total
$ NA
Project Issues Discussed in Document:
~
Aesthetic/Visual
~
Flood PlainIFJooding
~
Schools/Universities
181
~
Agricultural Land
~
Forest LendIFire Hazard
0
Septic Systems
~
~
Air Quality
~
Geologic/Seismic
~
Sewer Capacity
~
Archenlogical'Historical
~
Minerals
~
Soil Erosion/Cornpacticn/Greding
Cumulative Effects
Other
0
Coastol Zone
~
Noise
~
Solid Waste
~
Drainage/Absorption
Population/Housing
~
Toxic/Hazardous
0
0
~
~
Public Scrviccsf'acilities
~
Traffic/Circulation
181
181
181
181
181
FiJ;:cal
~
Recreeucn/perks
~
vegctetion
0
Economic/Johs
...... -.-.- ... - ... _--.... - .. _--..-.--._---- .. _--..
Slate Clearinghouse Contact: ~
(916) 445-0613
State Review Began:
--ll.-~- 2006
SCH COMPLIANCE
~. 2i,
State/Consumer Svcs
_X_ Resources
_ _ Boating & Waterways
Coastal Comm
Colorado Rvr Bd
Conservation
_X_ Fish & Game # _ _
Delta Protection Comm
Forestry & Fire Prot
Historic Preservation
5
=
Reclamation Board
SCH#:
20 0 5 0 4 11 3 8
Please forward late comments directly 10 the
Lead Agency'
AQMDIAPCD
'~ '1J 2PI
'_/~
(Resources: _ \
Growth Inducing
LandUse
Project Sent to the following State Agencies
~Parks&Rec
Please note State Clearinghouse Number
(SCH#) on all Comments
WcllandfRiparian
Wildlife
--._--._._ .... _- ..... _--... -..... - .... --.- ... _.
.:«:
-2006
Water Quality
Water
Supply/Groundwater
General Services
---Cal EPA
ARB - Airport Projects
- - ARB - T ransportation Projects
- - ARB - Major Industrial Projects
- - Integrated \va.te Mgmt sa
- L SWRCB: Clean Wtr Prog
_ _ SWRCB: Wtr Quality
SWRCB: Wtr Rights
X Reg. WQCB
#--=:L
_ _ Bay Cons & Dev Cornrn
~ Toxic Sub Ctrl-CTC
-lCDWR
_ _. OES (Emergency Svcs)
Yth/Adlt Corrections
Corrections
Independent Comm
Energy Commission
X NAHC
Public Utilities Cornm
...k.. Stale Lands Comm
. Tahoe Rgi Plan Agency
Bus Transp Hous
Aeronautics
CHP
X Caltrans#l
_ _ Trans Planning
_ _ Housing & Com Dev
_ _ Food & Agriculture
~ Health Services
-.-k
~m M,-...rc"MJr- s
Conservancy
Other:
_
S TAT E OF CAL I FOR N I A
Governor's Office of Planning and Research
State Clearinghouse and Planning Unit
Arnold Schwarzenegger
Governor
Memorandum
Date:
December 21,2006
To:
All Reviewing Agencies
From:
Scott Morgan, Senior Planner
Re:
SCH # 2005041138
Pursuant to the attached letter, the. Lead Agency has extended the review period forthe
above referenced project to February 2, 2007 to accommodate the review process; .All
other project information remains the same.
cc:
Jeff Ford
1400 TENTH STREET P.O. BOX 3044 SACRAMENTO, CALIFORNIA 95812·3044
TEL (916) 445-0613 FAX (916) 323-3018 www.opr.ca.gov
OPR-6
Notice of Extension of the Public Review Period of the
Draft Program Environmental Impact Report
State Clearinghouse # 2005041138
On November 15,2006, a Notice of Availability/Completion for the above-referenced Draft Program
Environmental Impact Report (Draft EIR) was issued. This notice is being issued in order to provide notification
of an extension of the public review period for the Draft EIR. The review period was formerly from November
15, 2006 until January 3, 2007 and has now been extended for an additional 30 days. The last day to submit
comments is now February 2,2007.
Project Title:
Lead Agency:
DEC 1 2006
STA
Contact: Jeff Ford, Water Resources Planner
I
TE CLEARING HOUSI=
Revised Review Period:
...J
November IS, 2006 through February 2,2007. During this public review period, the public has the opportunity to
review the Draft EIR and make written comments. Please send all written comments to the address listed below
on or before February 2, 2007.
r
REC.E/VED'
.2
Paper copies of the Draft EIR and all documents referenced in the Draft EIR are available for review at the CLWA
address listed below. Copies of the Draft EIR are also available for review at the public libraries listed below.
Paper copies and/or electronic copies on CD of the Draft EIR are available for purchase at the CLWA address
listed below.
December 15, 2006
Libraries where Draft EIR will be available for review:
Canyon Country [o Anne Darcy Library
18601 Soledad Canyon Road
Los Angeles County Library, Newhall
22704 West 9th Street
Newhall, CA 91321
Los Angeles County Library, Valencia
23743 West Valencia Boulevard
Valencia, CA 91355
Ventura County Library
Hall of Administration
646 County Square Drive, Ste 150
Ventura, CA 93001
Page 1 of 1
,
Form A
Notice of Completion & Environmental Document Transmittal
SCH# 2005041138
Moil to: Stole Clearinghouse, 1400TenthStreet,Sacramento, CA 95812·3044
916/445-0613
Costaic LakeWaterAgency's Recycled WalerMeslerPlan(RWMP)
Project Title:
Lead Agency:
CastaicLakeWaler Agenoy
ContactPerson: ....:::Je~ff'"'F"'o~rd"-StreetAddress: 27234BouquetConyonRood
Phone:
(661)297·1600
City: Santa Clarila
Zip: ....:::9-"13<:5"'0"'-2'-'1.!-73"County: Los Angeles
··ProjiiciLUcnilon:········S•• p..ge·j···················
-
Ltl·S A-l\~ele~1 Vem-um
County:
-.--.-
Within 2 Miles:
----..--.---.-- .
..5-'tI'rtLl Q;..la.~h:...:.:.nu~
_
Total Acres: \.'1? sq. Wli.
CitylNearesl Community:
Cross Streets:
See poge 1
Asscssor's Parcel
No.
NA
Zip: NA
Section: ~ __ Twp: _~N",A
Range: NA
lntarstste S,
Slate Hwy#: -"-'SR"--"14'--_ _ Waterways:
SantaClaraRiverand tributaries
All Within CLWA
service area
NA
Airports:
Schools:
NA
All Within CLwA
servicearea
.·.~~~~~~~~:~y.~~.;:.@::!ii~:~i~::::::::::::::::::.·:::::::::::::::::::::::::::::. ::J~ECEIVED:::
LocalAction Type:
D General PI.n Update
D General Plan Amendment
D General PI.nElement
o
Community Plan
o
Spr:cificPlan
I:8l
MoslerPion
o
o
o
PlannedUnitDevelopment
Site Plan
NOV 1 4 2006 0
Reznn
_
::::::::::::.-.-.-::::::.-:.-.-:::
Annexation
o
o
Prezon
0 Redeveleprnent
UscP f,sTATE CLEARING HOt&: Coastal Permit
OLand
,"'"
'-' Other
DevelopmentType:
I:8l
Federal ~S.!.:!NDA,--_
Funding (Rppro.,).
Stotc $ NA
Project Issues Dlscussodin Documenl1
Acs\helidVisU81
I:8l Flood PlolnlFloodlng
I:8l
I:8l
181
I:8l
AirQuolity
Archeologlcfli/Hisiorical
0
Ccnstul Zone
181
Dralnage/Abmrptiun
0
0
Economlc/Jchs
Flscal
Agricultural Land
I:8l
Forest LandfFlre Hazard
I8J
GeologloiScismlc
I:8l
I:8l
I:8l
I:8l
I:8l
Minerals
Noise
PopulationlHousi ng
PublicServlces'Fecillues
RecreationIParkR
•••••••••••••• " , . ' 0 ••••••••••• ,_. _ •• _ •• _.0_' 0
"' •••••••• _.,
State Clearinghouse Contact: .......
(916) 445·06 I 3
State Review Began:
-ft.~. 2006
~. 2- ·,200'+
SCH COMPLIANCE
~~•.~nM
~Please note State Clearinghouse Number
(SCH#) on all Comments
SCH#:
20 0 {) 0 4. 11 3 8
Please (omori! late comments directly to the
Lead Aganey'
AQMD/APCD
1I'?12>'1
,_/J1.J
(Resources: _ '
.~._
Recycled waterdistribution project
Other:
Totel SNA
Toxic/Hazardous
TmmclCircul8tion
I:8l WaterQuality
Water
I:8l Supply/Groundweter
I:8l We1landIRlparian
I:8l Wlldilfe
I:8l GrowthInducing
I:8l Lend Use
I:8l Cumulative Effect;
Vog~8tion
0
I:8l
Schools/Universities
0
I:8l
I:8l
I:8l
I:8l
I:8l
I:8l
SeprleSyslems
SewerCapacity
Soil Erosion/Compaction/Grading
SolidWftSlC
• • • _ • • • • _. _. " . " "
Olher
• • • • _. __ • • • • • • • • • • • • • • • • • • • • • • __ e • • __ - - - - , • • " _ • • • •
•
-.'
Project Sent to the following State Agencies.
X Resources
_ _ Boating & Waterways
Coastal Comm
ColoradoRvr Bd
~ Conservation
---lL Fish & Game # _ _
Delta Protection Comm
Forestry & Fire Prot
Historic Preservation
--..1L. Parks & Rec
Reclamation Board
_ _ Bay Cons & Dev Comm
State/Coosumar.Sves
General Services
---Cal EPA
_ _ ARB- Airport Projects
_ _ ARB -Transportation Projects
_ _ ARB- Major Industrial Projects
_ _ Integrated Waste Mgmt Bd
....k.... SWRCB: Clean Wtr Prog
_ _ SWRCB: Wtr Quality
_ _ SWRCB: Wtr Rights
-K DWR
. ytblAdlt Corrections
Corrections
Independent Comm
Energy Commission
X NARC
Public Utilities Comm
.....k.. State Lands Comm
__
. Tahoe Rgl Plan Agency
5
=
_ _. OES (Emergency Svcs)
Bus Transp Hous
Aeronautics
CHP
X Caltrans #
_ _ Trans Planning
_ _ Housing'& Com Dev
_ _ Food & Agriculture
~ Health Services
l
---1L Reg. WQCB #....!::i-
---f-- Toxic Sub Ctrl·CTC
--k
~T?9 M""'OZ'1MJ-s
Conservancy
Other:
_
OPR-7
Division of Financial Assistance
Linda S. Adams
Secretary for
Environmental Protection
1001 I Street - Sacramento, California 95814' (916) 341-5700 FAX (916) 341-5707
Mailing Address: P.O. Box 944212· Sacramento, California' 94244-2120
Internet Address: http://www.waterboards.ca.goY
Arnold Schwarzenegger·
Governor
DEC 27 2006
Mr. Jeff Ford
Water Resources Planner
Santa Clarita, CA 91350-2173
Dear Mr. Ford:
DRAFT ENVIRONMENTAL IMPACT REPORT (EIR); CASTAIC LAKE WATER AGENCY
(AGENCY); CASTAIC LAKE WATER AGENCY'S RECYCLED WATER MASTER PLAN (RWMP);
STATE CLEARINGHOUSE NO, 2005041138
Thank you for the opportunity to review the above document. State Water Resources Control
Board (State Water Board) staff has reviewed the Draft EIR and has several specific comments.
As a state agency with jurisdiction by law to preserve, enhance and restore the quality of
California's water resources, the State Water Board is providing the followinq comments on the
environmental document prepared for the Project.
We understand that the Agency is not presently pursuing a State Revolving Fund (SRF) loan for
this Project. The Agency may want to consider this loan program to provide funding for future
construction. The SRF program offers a low interest loan for building or improving wastewater
treatment plants, sewers, water reclamation facilities, and storm water drainage. The State Water
Board, Division of Financial Assistance is currently responsible for administering SRF loans.
Please refer to the State Water Board's SRF website
http://www.waterboards.ca.gov/funding/srf.htmlfor additional information.
It is important to note that SRF loan projects are subject to provisions of the Federal Endangered
Species Act and must obtain Section 7 clearance from the U.S. Fish and Wildlife Service prior to a
loan commitment. SRF projects also must comply with federal laws pertaining to cultural
resources, particularly Section 106 of the National Historic Preservation Act. Please contact the
State Water Board's Cultural Resources Officer, Ms. Cookie Him, at (916) 341-5690 to initiate the
Section 106 process if the Agency decides to pursue an SRF loan.
Following are my specific comments on the EIR:
1. The Project may indirectly fosterfuture economic or population growth or the construction
of additional housing within the Agency service area. The potential effects of the proposed
Project could increase impervious surface area that could have a significant impact by
affecting peak flow rates of floodwaters, and increase flooding on or off site of future
development. For the purposes of future development within the Agency area, consider
SWRCB-8
measures that would reduce storm water and urban runoff, such as Low Impact
Development (LID). These sustainable practices benefit water supply and contribute toward
water quality protection. For more information on LID, please refer to the State Water
Board's website at http://www.waterboards.ca.gov/lid/index.html.
California Environmental Protection Agency
o
Recycled Paper
Mr. Jeff Ford
-2-
DEC 2 7 2006
2. Section 4.3 (p. 4-17) concludes that the implementation of the RWMP would result in
significant and unavoidable indirect impacts to aesthetics, air quality, biological resources,
transportation and traffic, and utilities/service systems. This statement contradicts Table
ES-1: Summary of Environmental Impacts and Mitigation Measures and does not identify
the specific impacts. Please correct the statement on p. 4-17 to identify significant and
unavoidable indirect impacts resulting from the RWMP Project.
Thank you once again for the opportunity to review the document. If you have any questions,
please contact me at (916) 327-9117 or [email protected].
Sincerely,
Kim Wit orff •
Environmental Scientist
cc:
State Clearing House
(Re: SCH# 2005041138)
P. O. Box 3044
Sacramento, CA 95812-3044
California Environmental.Protection Agency
a
Recycled Paper
SWRCB-9
COUNTY SANITATION DISTRICTS
OF LOS ANGELES COUNTY
1955 Workman Mill Road, Whittier, CA 90601- 1400
Mailing Address: P.O. Box 4998, Whittier, CA 90607-4998
Telephone: (562) 699-7411, FAX: (562) 699-5422
www.lacsd.org
JAMES F. STAHL
Chief Engineer and General Manager
January 3, 2007
File No. 31-370-40.4A
Mr. Jeff Ford
Dear Mr. Ford:
Comments-on Castaic Lake Water Agency's Draft Program
Environmental Impact Report - Recycled Water Master Plan
The Santa Clarita Valley Sanitation District (District) appreciates this opportunity to comment on
Castaic Lake Water Agency's (CLWA) Draft Program Environmental Impact Report (DPEIR) for its Recycled
Water Master Plan (RWMP). As the owner and operator of the Santa Clarita Valley's only wastewater
treatment facilities, the District currently produces over 21 million gallons per day of tertiary treated recycled
water that meets Title 22 drinking water standards. The District fully supports your planned projects and
agrees with CLWA that recycled water is a valuable water resource that will serve to reduce the present and
future demands on Santa Clarita Valley's potable water supplies. We believe that this water resource should
be utilized to its fullest potential and look forward to working with CLWA in the future as the RWMP is
implemented.
The District has a number of comments on the DPEIR organized first by major issues, followed by
page specific issues to correct some minor inaccuracies found in the DPEIR.
Future Discharges to the Santa Clara River by the Saugus and Valencia WRPs
Pages 2-8 (lines 25-35), 2-9 (lines 1-22),3.4-23 (lines 32-45), 3.4-24 (linesl-lO), 3.8-22 (lines 25-45),
3.8-23 (lines 27), and 3.8-25 (lines 2-8) include discussions on potential flow impacts to the Santa Clara River,
due to the diversion and use of recycled water from the Valencia WRP. The District agrees with CLWA's
analysis that the RWMP would not impact the biological resources or hydrology of the Santa Clara River
system, because the combined existing discharges to the Santa Clara River would be maintained. However,
the District does not believe that the existing combined discharge condition of 18.4 MGD, as identified in the
RWMP, is the de-facto minimum discharge that must be maintained to the Santa Clara River to prevent LACSD-10
significant impacts. The District, in its 2015 Santa Clarita Valley Joint Sewerage System Facilities Plan and
Environmental Impact Report (2015 Plan and EIR), previously analyzed biological and hydrological impacts
from multiple discharge scenarios including a no discharge scenario and a reduced discharge scenario. The no
discharge scenario assumed a combined discharge of 0.0 MGD to the Santa Clara River from the Saugus and
Valencia WRPs, and the reduced discharge scenario assumed that a significant amount of the recycled water
would be used by water purveyors resulting in a combined discharge of 9.6 MGD to the river. The District
concluded in the 2015 Plan and EIR that the no discharge scenario would result in significant impacts to
biological resources and hydrology, and that the reduced discharge scenario would result in less than
Recycled Paper
0
Mr. Jeff Ford
-2-
January 3, 2007
significant impacts. The 2015 Plan and EIR also determined that the reduced discharge scenario would
LACSD-10
maintain the gap in perennial flows between Los Angeles and Ventura counties, thereby preventing the
hybridization and loss of the endangered unarmored three-spine stickle back CUTS). The conclusions of the
District's 2015 Plan and EIR are further supported by the U.S. Fish & Wildlife Service's 1985 Unarmored
Threespine Stickleback Recovery Plan - Revised, which found that the then-existing combined discharges of LACSD-11
8.0 MGD supported the recovery of the fish species. Overall, there is evidence in the record to support the
conclusion that biological resources, including special status fish species (i.e., Santa Ana Sucker and UTS),
could be supported by a minimum combined discharge of 9.6 MGD, which is significantly below existing
combined discharge condition of 18.4 MGD.
Legal Owner and Operator of the Saugus and Valencia WRPs
The Santa Clarita Valley Sanitation District is the legal owner and operator of the Saugus and Valencia WRPs.
As such, there are instances where Los Angeles County Sanitation Districts, Sanitation Districts of Los
Angeles County and/or LACSD are utilized in the DPEIR in relationship to ownership/operation of the Saugus
and Valencia WRPs. The District requests that the DPEIR properly reference the District as Santa Clarita
Valley Sanitation District or SCVSD. The following are specific page numbers where such changes are
requested:
•
•
•
•
•
•
•
•
ES-l, Line 26
Page 2-2, Line 3
Page 2-7, Line 36
Page 3.8-6, lines 28, 32 and 34
Page 3.8-9, lines 13 and Lines 22
Page 3.8-17, line 7
Page 3.16-1, lines 8-37
Page 6-9, lines 8-9
LACSD-12
Page Specific Comments
Page 2-7, Lines 39-40
• Change text as follows: " ... the Valencia WRP is a publicly owned treatment works (POTW) that is owned
and operated by the Santa Clarita Valley Sanitation District, and is located on the Old Road near SFMM."
LACSD-13
Page 2-8, lines 1-2
• Change text as follows: "According to the 2015.Santa Clarita Valley Joint Sewerage System Facilities
Plan and Environmental Impact Report ..."
LACSD-14
Page 2-9, line 40
• The District believes that the ultimate design capacity for the Newhall WRP is 6.8 MGD, and request that
CLWA confirm this with Newhall Land and Farm.
LACSD-15
Page 3.4-23, line 32
• The sentence should read: "The Valencia and Saugus WRPs"
LACSD-16
Page 3.8-6, lines 13-16
• Change text as follows: " ... the Valencia WRP is a publicly owned treatment works (POTW) that is owned
and operated by the Santa Clarita Valley Sanitation District."
LACSD-17
Page 3.8-7, lines 3-10
• The District requests that language related to reported cyanide exceedances be revised as follows:
LACSD-18
Mr. Jeff Ford
-3-
January 3, 2007
"As shown in Table 3.8-2 above, the Valencia WRP had apparently exceeded the effluent limitation
requirements for cyanide at least once in the years 2002, 2003, and 2004. As a result of these
exceedances, as well as cyanide exceedances at other WRPs owned and operated by LACSD, extensive
research on cyanide was performed and it was determined that the apparent historical cyanide exceedances
were not actual exceedances but rather artifacts of the preservation method used in the collection of
cyanide samples taken in the field. Standard Methods recommends that cyanide samples be analyzed
within fifteen minutes, and if not possible, then preserved for later analysis by raising the pH of the
LACSD-18
samples. Because the District has not historically had the laboratory infrastructure at the Valencia WRP to
analyze cyanide samples within fifteen minutes, the historical practice was to preserve these samples via
pH adjustment. Further research has revealed that this preservation step causes positive interferences in the
cyanide test. When the samples were analyzed immediately without preservation, as is recommended in
Standard Methods, no exceedances of cyanide effluent limitations were found at the Valencia WRP. In
December 2005, the Valencia WRP treatment plant laboratory was ELAP certified in order to immediately
measure cyanide after sample collection. There have been no exceedances of cyanide effluent limitations
at the Valencia WRP since 2005."
Page 3.8-7, lines 29-31
• According to the District's records, in 2004 and in 2005, a total of 137 MG and 136 MG of recycled water
had been utilized.
Page 6-9, line 6
• Change "Phase I expansion of9 mgd in 2002... " to "Stage 5 expansion of9 mgd in 2003."
LACSD-19
LACSD-20
Page 6-9, lines 6-13
• The District requests that language related to future expansions be revised as follows:
"To accommodate anticipated growth in the Santa Clarita Valley area and to ensure compliance with
discharge requirements from the Regional Water Quality Control Board (RWQCB), the Santa Clarita
Valley Sanitation District has plans to expand the capacity of the Valencia WRP, as discussed in the
District's 2015 SCVJSS Facilities Plan and EIR. The Stage VI expansion will increase the capacity of the
Valencia WRP by another 6 mgd, for a total capacity of 27.6 mgd. No expansion of the Saugus WRP is
planned; thus total capacity for both WRPs is 34.1 mgd (38,200 aflyr)."
Page 6-10, line 7
• The District believes that the ultimate design capacity for the Newhall WRP is 6.8 MGD, and request that
CLWA confirm this with Newhall Land and Farm.
If you have any questions concerning this letter, please contact Brian Louie at (562) 908-4288,
extension 2802.
Very truly yours,
James F. Stahl
.------
~
.:
;
7
rian LOUIe
Supervising Engineer
Water Quality Section
BL:nm
LACSD-21
LACSD-22
01/04/2007 13:08 FAX
141 002/002
PLANNING DIVISION
213 838 3858
. COUNTY OF LOS ANGELES
DEPARTMENT OF PARKS AND RECREATION
"Creating Community Through People, Parks and Programs"
Russ Guiney, Director
January 3, 2007
Jeff Ford
Water Reeources Planner
Dear Mr. Ford:
NOTICE OF AVAILABILITY OF A DRAFT PROGRAM ENVIRONMENTAL IMPACT
REPORT (DEIR) FOR THE CASTAIC LAKE WATER AGENCY
RECYCLED WATER MASTER PLAN
The Notice of Preparation for a Program EIR for the Castaic Lake Water Agency
Recycled Water Master Plan has been reviewed for potential impact on the facilities of
this Department. The above project may impact facility under the jurisdiction of this
Department which we offer the following comments:
CoLADPR
•
Proposed reservoirs 2 and 3 may have visual impacts to portions of County Trail
-23
#68 (William S. Hark Park Trail, as well as William S. Hart Regional Park) and
#76 (Cliffie Stone Trail), Vegetative screening or other means of mitigating
aesthetic impacts must be used.
•
Proposed pipelines may traverse County Trail #71 (Santa Clara River Trail) and
#77 (Bouquet Canyon Trail) which will require coordination with our Department. CoLADPR
For trails inquiries please contact Mr. Ken SlUr Trails Coordinator at -24
213351-5135.
Thank you for including this Department in the review of this environmental document.
If we may be of further assistance, please contact me at (213) 351-5133.
8
oscardini,
Department Facility Planner I
C:
Olene Ewell-White, DPR
Kathleen Ritner, DPR
Ken siu, DPR
Planning and Development Agency • 510 Vermont Ave· Los Angeles, CA 90020· (213) 35]-5198
COUNTY OF LOS ANGELES
DEPARTMENT OF PUBLIC WORKS
"To Enrich Lives Through Effective and Caring Service"
900 SOUTH FREMONT A VENUE
DONALD L. WOLFE, Director
ALHABRA, CALIFORNIA 91803-1331
Telephone: (626) 458-5100
http://dpw.lacounty.gov
ADDRESS ALL CORRESPONDENCE TO:
P.O. BOX 1460
ALHAMBRA, CALIFORNIA 9 I 802- I 460
February 1, 2007
IN REPLY PLEASE LD A
REFER TO FilE: -
Mr. Jeff Ford
Water Resource Planner
Dear Mr. Ford:
DRAFT PROGRAM ENVIRONMENTAL IMPACT REPORT
CASTAIC LAKE WATER AGENCY'S RECYCLED WATER MASTER PLAN
SANTA CLARITA VALLEY
Thank you for the opportunity to review the Draft Program Environmental Impact
Report for your agency's proposed Recycled Water Master Plan. We offer the
following comments for your consideration as you finalize the document:
Recycled Water Master Plan Components, startinq on paqe 3.4-23:
This section appears to assume there will always be end users of all additional
recycled water. This may not be the case should the production increase faster
than the demand for recycled water or during very wet years. There should be a CoLADPW-25
provision for this situation in the permit to discharge the reclaimed water. Also,
the Aquifer Storage Recovery wells will occasionally need to be re-developed or
upgraded. The wastewater produced during this process would need to be
treated and properly disposed.
Section 2.6.2, paqe 2-16, Lines 1 throuqh 9:
This paragraph indicates that the pipeline crossing the Santa Clara River at the
Old Road will be placed underground. Discussions elsewhere indicate the depth
of the pipeline between six to nine feet. Discussion of the SR-126 crossing
indicates that the pipeline will be attached to the bridge. Please clarify the
pipeline crossing at the Santa Clara River. If it is to be placed underground
below the riverbed, the risks associated with washing out at the crossing need to
be addressed.
CoLADPW-26
Mr. Jeff Ford
February 1, 2007
Page 2
If you have any questions, please contact Mr. Suk Chong at (626) 458-7150.
Very truly yours,
DONALD L. WOLFE
Director of Public Works
D'ANTONIO
Assistan Division Engineer
Land Development Division
SPC:ca
P:\ldpub\CEQA\SUK\Castaic Lake Water Agency Recycled Water Master Plan_DPEIR.doc
:::::.2<DE0. 29, 20 C6, 10: 02,\M.,.,! puC LWA.,s
~ESOURCE
MA
I
TO:661 297
DEPT
~~O,
898
AGE;MENT AGENCY
) 1. 1 '"3
Planning Division
Kimbe1iy L. Rodriguez
COlI1ty ----- ventura
Director
December 28, 2006
Castaic Lake
ater Agency
Attention: Dati Masnada, General Manager
27234 Bouqud Canyo~ Road
Santa Clarita, A 913$0-2173
,,
FAX#: (661) 97-1611
SUBJECT~
eCyeled;Water Master Plan Program: Draft Program EIR
!
Thank you for the opportunity to review and comment on the above subject
document, AJChed are the comments that we have
Intra-county re iew of t~e projects.
received resulting from
an
Any res pons to thesJ comments should be sent directly to the commenter, with
a copy to Carl Moreho~se, Venture County Planning Division. L#1740, 800 S.
Victoria Avenue, Ventura, CA 93009.
If you have anJ questions regarding any of the comments, please contact ths
appropriate re!lponden~. Overall questions may be directed to Carl Morehouse at
(805) 65+247$.
:
Sincerely,
Attachment
County RMA
ferenc~ Number 05-033-1
800 South Victoria Avenue. ~" 740. Ventura, CA 93009
(805) 854-2481
FQJl; (BOS) 654~2S0e
D~c-zDEC.
TO~661 297 ~O.
29. 20C6310:02AM.MA F'LCLWA NG DEPT
898
) 2. 2 .... 3
Ventura County
Groundwater section
MEMORANDUM
DATE:
TO:
~r22,_
earl M~_ ~MA • Plllllning DMsiun
David pararo. WP.D - Groundwater Section
SUBJeCT:
CAST~ LAKE \VATER AGENCY'S RECYCLED WATER MASTER PLAN PROGRAM,
VENTURt COUNTY RMA Re=eRENCE NO. 05-033·1, DEJR (SCH # 2005041138)
Project Deacliption
\
.
The Castaro Lake Waler;Agency (-cLWA) is proposing to develop and construct a recycled water system
to serve the Santa ClaritB VaJJey (n an attempt to reduce the present and future dernands on its potable
water suppDes. CLWA i a contract With the State of California 10purchase water from the State Water
Project (SWP). The pu se of this project is to offset reliabilitY and availability concerns with SWP
water supply and project new pppulation growth in the Santa Clarita area. The proposed project would
provide reoyoled water r irrigatton, thereby decreasing demands on the potable water supply. This
Recycled Water Master '~Plan (RWMP) is a planning docutrlent that c.pdates the 1993 Draft Recycled
Water System Master PI n. The RWMP is also a part of the CLWA's Urban Water Management Plan~
most recently updated in Novem~1' 2005.
Recycled water in the ~anta Cl~a Valley area of Los Angeles County would primarly be used for
landscape irrigation at g' If courses, parks, schools, comme~cjaJfJndustfiaJ landscaping. cemeteries, and
freeway medians, as w I as any other appropriate appli~ons 01' customers that might be available.
. The main source 01 the !\ecycled water would be the Valencia Water Reclamation Plant (WRP) which is
primarily urban wastewa.ter oIean~d to tertiary-leVel standards. ThEln~ are no plans to recycle effluent
discharge from the sm ler nearby Saugus WRP plant, so that fac:ility is not included in the AWMP.
other potential sources f recycte<J water would be the Placenta (Berry Petroleum) oil field, the newly
constructed Newhall Ran h WRP,:orthe Shangri La dewatering system.
Comments
Recyding of treated wa tewatar ~ a beneficial and necess~ry method for decreasing dependence on
potable water. It is mU9'" better lo utilize recycled water fo.r irrigation and industrial needs instead of
divening a valuable SU~1y of potable water for such needs. CLWA's goal ot 17,40() AFfyr of recycled
water use is based on ~~leeted fu~re growth in population.
Page :l_8-14. SUrfac:e Waler Qualitl
e~t9bllshed
The Los Angeles RWQcb has
Ii Total Maximum Daily Load (TMDL) of 100 milligrams per
liter (mgll) chloride for ff0f.' Fk!ach~s 5 and 6 of the Santa Clara River. No discussion has been included
regarding whether or not \the effluetnt released from the Saugus and Valencia WAP's will be brought into
compliance with this requIrement
I
Ventura
-WPD-27
805 654 2509
TO;6G1 297 ~O.
898
Project Review - AMA 05-033--1
Groundwater Su
Pa
tion ln~icates that by 2030, the planned effluent discharge to the Santa Clata
River from the combine Saugus and Valencia WRP's will be 18.4 miflion gallons per day (mgd); the
average as measured ft:
2001 ihrough .2005. It also sta.t~s, "Therefore, implemenlation of the AWMP
would not impac1 the hy rology 01 ecology of the Santa Clal'a River system sinoe the existing discharge
conditions from both W pIS woul~ be essentially maintained".
The discussion in this s
No discussion has bee incJud~
Ventura
regarding the water quality and quantity of discharges to the river -WPD-28
system during the int
between the present time and year 2030 When the project is completed. The
amount of effluent disch gad to lIhe river has not been stated and the expansion of the Valencia WRP
plant may. affect future djscharg~s.
RWMP does not affect
DP:bc
Care should he taken to assure that the implementation of the
wnstre:am basins in the areas of both waterqualityand water quantity.
J
07 01:19p
805-498-4323
None
p,1
660 Randy Drive, Newbury Park, California 91320-3036 • (805) 498-4323
February 2, 2007
Board of Directors
Saugus, CA 91350
Fax 661297-]611
Re: Castaic Lake Water Agency Recycled Water Master Plan EIR
Ron Bottorff
Chair
Barbara Wampole
Vice-Chr:ir
Ginnie Bottorff
Secretary
Affiliated
Organizations
California Native
Plant Society
LA.lSarl/a MOllica
},'loulllai1l5 Chapter
San ta Clarita
Organization for
Planning the
Environment
(SCOPE)
Sierra Club
Angeles Chapter
LosPadres Chapler
Surlrider Foundation
Audubon Society
Ve'lJura Glapler
Ventura County
Environmen tal
Coalitlon
Wishtoyo
Foundation
Dear Sirs,
Friends of the Santa Clara River submits the following comments on the
subject document.
There is considerable controversy around the concept of using recycled
water for Aquifer Storage and Recovery projects (ASR). Recycled water
should not be used for this purpose without more detailed studies beyond
the discussion provided in the DEIR.
Friends-29
"VIle note that water agencies and the City of Santa Clarita are in the early
stages of an Integrated Regional Water Management Plan effort. Bringing
recycled water projects under the aegis this plan would seem to be
highly appropriate, and we recommend that course.
Friends-30
It appears that the.Saugus.aquifer.is the.most.likely recipientbasin for
recharge, If so, this needs to be re-thought due to the ammonium
perchlorate plume in this aquifer that continues to migrate westward.
Friends-31
More detailed studies need to be carried out to determine impacts to
endangered or threatened species for recharge facilities sited in any
sensitive biological area. Information in the DEIR is not sufficient for this
purpose.
Friends-32
of
Thank you for your consideration of these comments.
SCOPE
Santa Clarita Organization for Planning and the Environment
TO PROMOTE, PROTECT AND PRESERVE THE ENVIRONMENT, ECOLOGY
AND QUALITY OF LIFE IN THE SANTA CLARITA VALLEY
POST OFFICE BOX 1182, SANTA CLARITA, CA 91386
2-1-07
Saugus, CA 91350
Fax 661 297-1611
Dear Sirs:
SCOPE strongly supports the use of recycled for some uses, specifically landscaping and
industrial uses (cooling towers, etc.). However, we note that there is considerable
controversy and are substantial permitting issues involved in using recycled water for
Aquifer Storage and Recovery projects (ASR ) such as are described only in a very general
way by this DEIR. We do not support the use of recycled water for that purpose unless and
until there is a more detailed overview and a process in place for public involvement. Such
an overview and disclosure of health and water quality impacts is not found in the current
document.
SCOPE-33
Recycled water projects are appropriate for grant funding. Since the water agencies and the
City of Santa Clarita are just beginning an “Integrated Water Resource Plan” with the
intention of making grant applications to the current State funding mechanisms, we strongly
recommend that this document be delayed to include ideas and projects that may evolve
from that process. We believe that such a delay would save the Agency time and money in
any future environmental review that may be required as a result of projects proposed for
grants through the IRWMP process.
SCOPE-34
Issues surrounding proposed use for Aquifer Recharge
The Agency is aware of the Regional Water Quality Board’s concern over aquifer recharge
with State Water Project water in the Santa Ana area, due to the degradation of the existing
ground water quality from such a process. We believe that a similar degradation could occur
in the Santa Clarita area as well, should such a process be allowed here. This degradation
could result from increased chloride levels, that are already a problem in this watershed, and
potential health risks from viruses and pharmaceuticals, currently found in recycled water
and not removed by the tertiary process now used by the Sanitation District. The DEIR does
not fully disclose these impacts and impediments to the project so that the public and the
decision-makers are fully aware of these issues. We believe that this is a serious flaw in the
current document.
SCOPE-35
SCOPE Comments on Castaic Lake Water Agency Recycled Water DEIR
2
Previous documents (not discussed in this DEIR) indicated that the Saugus Aquifer would be
the target basin for any recharge activity. This should be reviewed in light of the continued
migration of the ammonium perchlorate plume in a westerly direction and the discovery of
over contamination, including VOC’s, in this aquifer. Prior reports indicated that the Santa
Clara River alluvium was not an appropriate storage area since the water moved quickly
through the eastern reaches.
SCOPE-36
Further, this document may not serve for an environmental review of the impacts of the ASR
proposal for the Saugus Aquifer. Such a project needs a full review, circulation to all
interested parties and agencies including the Regional Water Quality Board, and public
disclosure so that the above briefly described impacts can be publicly disclosed and
evaluated.
SCOPE-37
Validity of Previous reviews
In 1988 the Castaic Lake Water Agency (CLWA) approved a Program EIR for a Recycled
Water Plan. In 1993, The Agency developed and circulated a Recycled Water Master Plan,
tiering on that old EIR. It is unclear whether this document replaces these old Environmental
Documents and Plans or merely adds to them. Due to the enormous amount of new
information regarding water quality, permitting requirements, growth in number and location
of land use permits and biological impacts, we believe that this report must be a replacement
for those earlier documents. We request that this fact be clearly indicated in the FEIR.
SCOPE-38
Also, we do not believe that this document provides sufficient environmental review to allow
the amendment of the Natural River Management Plan (NRMP) to provide for siting of
facilities in sensitive habitat areas. Such an amendment of the Plan was not contemplated
when that plan was approved. We would regard such a use as an inappropriate manipulation
of that Federal review process and would proceed to object to any such amendment
accordingly.
SCOPE-39
Biological Impacts
As previously stated, we believe site specific review must be conducted for any facilities
sited in a sensitive biological area. This document does not give adequately detailed
information to provide the extent of any such impacts or to suggest sufficient mitigation.
Providing lists of endangered and threatened species in the whole service area without
indicating which species might be found on any specific facility site does not provide
adequate information for reasonable assessment.
SCOPE-40
It is unclear from this document whether any additional water is contemplated to be removed
from flows emanating from the Saugus treatment plant. The Saugus and Valencia treatment
plants are considered jointly by the Sanitation Districts and your document. Since a flow is
required to maintain endangered species in the reach of the Santa Clara River below the
Saugus plant, we oppose any further use of water from the Saugus plant that would disrupt
SCOPE-41
SCOPE Comments on Castaic Lake Water Agency Recycled Water DEIR
3
the surface flow in this area. Such a diversion would be a significant impact and require
SCOPE-41
consultation under the Endangered Species Act. This fact should be disclosed in the DEIR.
Alternatives
We believe the Recycled Water Plan should include an alternative that promotes re-piping of
individual homes to supply landscape water from gray water uses in the home. Although
such a proposal is not currently allowed under State law, we believe it is time that such a
proposal, and the laws that preclude it, be re-evaluated. This system is used extensively in
Europe where it saves energy and money by eliminated the transport costs of recycled water,
substituting the recycled water for potable water and changing the landscape habitats of
residents to accommodate the recycled water in their gardens. It also eliminates most of the
health concerns that occur when large quantities of recycled water are used for any large
public purpose because the local environment has a chance to absorb and decompose and
chemicals or bacteria found in the gray water through absorption by the landscape plantings.
SCOPE-42
We request that such an option be listed in the alternatives section of this document and that
this idea be introduced to the watershed council that is currently being formed.
SCOPE-43
Conclusion
Thank you for the opportunity to comment of this project. We request that we receive a copy
of the FEIR prior to any project approval and that no amendments to the NRMP or approvals
for site facilities located in sensitive biological areas be granted without additional review.
We request that the DEIR be augmented in the areas indicated in this correspondence.
Sincerely,
David Lutness
Board Secretary
Cc: US Army Corps of Engineers
Los Angeles Regional Water Quality Control Board
Nov 28 2006 6:46PM
SIERRA CLUB ANGELES CHAPT
3435 W:tl.shu:e Boulevard
Suite 320
. Los Angeles, CA ·90010-1904
.SIERRA'
.,:cli;'B··
213 387 5383
p.2
(213) 387-6528 phone
(213) 387-5383 fax
www.sien:aclub.org
... i'~;ll NcJ:l~~j,l!,n';
November 28,2006
27234 Bouquet Cyn Rd.
Saugus, CA 91350
Fax 661 297-1611
To Whom It May Concern:
The Sierra Club, Angeles Chapter has not received a copy of Draft EIR for the recycled water
Sierra
project. Nonnallywe receive these documents, and would like to review the document for comments. -44
Please forward a copy of the document to: .
Jennifer Robinson
Sierra Club. Angeles Chapter
3435 Wilshire Blvd., Suite 320
Los Angeles, CA 90068
Please include this request as a comment on the Draft EIR.
Thank you for your attention to this matter.
~~.incere1Y'·I~
l
i
,f
I
I
..
.
\ / Jennifer Robinson
V Conservation Program Coordinator
Sierra Club, Angeles Chapter
Feb 02 2007 2:58PM
SIERRA CLUB ANGELES CHAPT
3435 Wilshire Boulevard
Suite 320
Los Angeles. CA 90010-1904
Angeles Chapter
213 387 5383
p.2
(213) 387-4287 phone
(213) 387-5383 fax
www.angeles.sierracIub.org
Saugus, CA 91350
Fax 661 297-1611
Dear Sirs:
Thank you for granting additional time to review this document.
Sierra Club supports recycled water for some uses, specifically landscaping and industrial uses (cooling
towers, etc.). But there has been considerable controversy and discussion over the health and water Sierra
quality issues involved in pumping recycled water into a ground water basin as described in your -45
"Aquifer Storage and Recovery Program". We therefore recommend that any such project be covered
by a separate review process.
We are also concerned about statements made in this document that would seem to indicate that
specific site facilities would receive environmental review through an amendment of the Natural River
Management Plan (NRMP). We believe this process would not satisfy the required CEQA review and Sierra
such uses of the NRMP were not contemplated when that plan was approved. Such an amendment
-46
process may be viewed as an abuse Federal review process. We therefore request to receive
notification of all plans to site facilities within the NRMP along with any applications for
amendments to the plan. ._
Recyled water is currently an important source of in stream flow in the area immediately below the
Saugus treatment plant. Any proposed diversion from this area must meet the requirements of the Sierra
Endangered Species Act. This impact and the related permitting requirements do not seem to be -47
covered in the EIR.
Please send us a copy of the FEIR prior to any project approval. Again, we request to be notified of
any proposed amendments to the NRMP and for approvals for site facilities located in sensitive
biological areas.
;4j]J)~
Unnifer Robinson
V~~nservation
Coordinator
Angeles Chapter
Cc: Aaron Allen, US Army Corps of Engineers
m
JAmes Chuilnr;!
Environrnentat SpeciOllist/Lend Planner
SUlItflem
Califllmia
GasCom,•..,.
~ Sempra Energy' utilities
Land Planninq & NilturOlI Resources
Moll Location Gn6G3
555 W. Filth Street
Los Anqeles. CA 90013-1036
Tel: 213.244.5817
Fall: 213.Z44.6046
[-mOl" : [email protected]
January 3, 2007
Mr. Jeff Ford
Water Resources Planner
Santa Clarita, CA 91350·2173
Re: Castaic Lake Water Agency - Recycled Water Mater Plan DRAFT Program Envtronmentallmpact
Report
Dear Mr. Masnada:
Southern California Gas Company (SCG) appreciatesthe opportunityto review and respond to the Draft Program
EnvironmentalImpact Report. We respectfullyrequest that the following commentsbe incorporatedin the
subsequent Final Program EnvironmentalImpact Report (Final EIR).
SCG recommends that the Final EIR include a discussion of activities associatedwith the extension of new recycled
water service that might have an affect on existing natural gas facilities. At present, there is no mention of any
potential to relocate existing facilities. This additional discussion should include:
•
Identificationof any exiting natural gas infrastructurethat would need to be relocated and/or abandoned, in
order to allow for the constructionof the new recycled water service.
•
Identificationand description of any temporaryareas required for constructionand/or staging of material
related to natural gas service relocation or construction.
•
Identificationof any actions that would require permittingor acquisitionof new right-or-way or easements
for natural gas services.
•
Any proposed grading and/or drainage improvements that would redirect drainage in a manner that would
increase the potential for erosion around SCG facilities.
SCGC-48
The Final EIR should also recognize that a discussionof these issues may help to reduce the time and cost
associated with the relocation of natural gas services.
In addition, if any field monitoring for cultural or biological resources is required during constructionof the natural
gas facilities,the monitoring should be mentioned in the Final EIR as a requirementand responsibility of the Castaic
Lake Water Agency. Likewise, any environmentalmitigationrequired for the potential impacts associated with the SCGC-49
constructionof gas service should also be addressed as part of the responsibilityof the Castaic Lake Water Agency
paoe2of 2
Once again, we appreciate the opportunity to comment on the DRAFT Program ElR. If you have any questions,
please feel freeto contact me at (213) 244~5817 or [email protected].
Sincerely,
..
./
,/
..
,/
,-'
.
,."
:;,,~.>/ . . ~
. ,.. . _..-
;<;.
It'
0""1
./'
L-·· .....;::;:::-.:... ,'_,_.
_---....•..
James Chuang
-.
Environmental Specialist
Cc: Jae Yi (Technical ServicesAdvisor, Environmental)
Board of Directors
Roger E. Orr, President
Bruce E. Dandy,Vice President
RobertEranio, Secretary!Treasurer
SheldonG. Berger
Lynn Maulhardt
DanielC. Naumann
F.W. Richardson
Legal Counsel
Philip C. Drescher
General Manager .
Dana L. Wisehart
UNITED WATER CONSERVATION DISTRICT
"Conserving Water Since 1927"
January 31, 2007
Mr. Jeff Ford
Water Resources Manager
Reference:
Draft Program EIR, Castaic Lake Water Agency's Recycled Water
Master Plan
Dear Mr. Ford,
United Water Conservation District has reviewed relevant hydrologic portions of the
Recycled Water Master Plan (RWMP).
United Water commends the Castaic Lake
Water Agency's effort to extend the potable supply of water by increasing the current
recycling of water by ten-fold over the next 23 years.
United Water was initially concerned how the proposed increase in reuse of water from
Water Reclamation Plants (WRPs) might influence Santa Clara River flow near the Los
While the Santa Clarita area has grown
Angeles CountyN entura County line.
substantially since the 1970s, in response to the build-up of SWP water deliveries to the
area, there has been a corresponding, albeit less dramatic, increased growth in down
stream basins within Ventura County. The perennial Santa Clara River flow created near UWCD-50
the County-line, because of upstream WRPs discharges, has become an integral portion
of the water supply for the basins within Ventura County. United Water and landowners
. within Ventura County acknowledge the importance of the flow across the County line
and have a vested interest in the continuance of the established flow. Review of Section
3.8 of the Draft EIR for the RWMP has essentially resolved United Water's initial
concern with respect to impacts to flow at the County line.
The analyses presented in Section 3.8, page 23 shows that even with a ten-fold increase
in the recycling of water within the Santa Clarita Valley there will still be increased (18.6
MGD) discharge to the Santa Clara River by 2030, as compared to the discharge during
UWCD-51
the base period 2001 through 2005 (18.1 MGD). The analysis in Section 3.8 is premised
on projected discharge to the river and projected recycled water by 2030. From Ventura
County's perspective it is important that the actual amounts of recycled water and
•
•
106 N. 8th Street • Santa Paula, California 93060 • Phone (805) 525-4431 • FAX: (805) 525-2661
UNITED WATER CONSERVATION DISTRICT
discharges to the river be well monitored, in the event that future amounts are
significantly different than those projected in the Draft EIR. Because the water purveyors
within Los Angeles County and United Water have developed a good working UWCD-51
relationship now and into the foreseeable future, the annual discharges to the river and
recycled water will be closely monitored, by all parties, along with other groundwater
and surface hydrologic data.
If you have any questions please contact myself or Ken Turner at (805) 525-4431 or
alternatively at [email protected] or [email protected] respectively.
Sincerely,
V~d:4M
Dana L. Wisehart
General Manager
Cc:
BDRF
File: Castaic Lake Water Agency
) 2-02 -200 7 PO 1 : 57
Ed and Joan Dunn
15414 Rhododendron Dr.
February 2, 2007
Jeff Ford, Water Resources Planner
Dear Jeff Ford:
Re: Draft Program Environmental Impact Report, CLWA's Recycled Water Master Plan
Santa Clarita's Central Park should be the first user of recycled water. The purple pipes
were installed years ago as required by Castaic Lake Water Agency.
Dunn-52
Newhall Ranch is not developed and therefore no water customers have contributed to
this water source. The present population has purchased, produced, and paid for the
recycled water through the water rates, the sewer fees, and the connection fees. This is an
inequity of huge proportions that the public should not accept. We oppose any plan that
suggests that Newhall Ranch should receive any of this water.
Dunn-53
The plan shows that Canyon Country is one of the last areas to be considered for recycled
water. This is wrong. We believe CLWA's intention is to state in the future there will be
no recycled water left for the late planned areas (the producers of the recycled water) like
Canyon Country. Equitable quantities should be set aside, in this plan now, for the
producers of recycled water.
Dunn-54
&2e~
~
Joan Dunn
1
3.0 RESPONSES TO COMMENTS
2
3
4
5
6
7
8
9
10
11
12
As set forth in California Public Resources Code Section 21061, the purpose of an EIR is to
provide public agencies and the public in general with detailed information about the effect that
a proposed project is likely to have on the environment. As set forth in CEQA Guidelines
Section 15204(a), when making comments, persons and public agencies should focus on the
sufficiency of the document in identifying and analyzing the possible impacts of the project.
CEQA Guidelines Section 15204(a) also states that when responding to comments, “lead
agencies need only respond to significant environmental issues and do not need to provide all
information requested by reviewers, as long as a good faith effort at full disclosure is made in
the EIR.” With these general principles in mind, this section includes excerpted comments from
the letters included in Section 2 and responses to those comments in tabular format. The
acronyms used to define the commentators are as indicated in Section 2.
6
Comments Received From:
Name
Agency
Department
Abbreviation
CHP
Date of Correspondence
Captain S.V. Bernard
State of California
Department of California Highway Patrol
January 2, 2007
Cheryl J. Powell
State of California
Department of Transportation
Caltrans
December 8, 2006
Samuel Unger
State of California
Los Angeles Regional Water Quality Control Board
LARWQCB
February 2, 2007
Dave Singelton
State of California
Native American Heritage Commission
NAHC
December 6, 2006
Scott Morgan
State of California
OPR
November 14, 2006
Scott Morgan
State of California
OPR
December 21, 2006
Terry Roberts
State of California
OPR
February 5, 2007
Kim Wittorff
State of California
SWRCB
December 27, 2006
James F. Stahl
County Sanitation Districts
LACSD
January 3, 2007
Bryan Moscardini
Department of Parks and Recreation
CoLADPR
January 3, 2007
Donald L. Wolfe
Department of Public Works
CoLADPW
February 1, 2007
Carl Morehouse
County of Ventura
Ventura- WPD
December 22, 2006
Ron Bottorff
N/A
Friends
February 2, 2007
David Lutness
SCOPE
N/A
SCOPE
February 1, 2007
Jennifer Robinson
Sierra Club
Angeles Chapter
Sierra
November 28, 2006
Jennifer Robinson
Sierra Club
Angeles Chapter
Sierra
February 2, 2007
James Chuang
N/A
SCGC
January 3, 2007
Dana L. Wisehart
United Water Conservation District
N/A
UWCD
January 31, 2007
Ed and Joan Dunn
N/A
N/A
Dunn
February 2, 2007
Ed and Joan Dunn
N/A
N/A
Dunn
December 13, 2006
7
Comments and Responses Matrix:
Commenter
Comment
No.
Comment
Response
CHP
1
In reviewing this project, our concern was what effect this project
will have on traffic. It appears the traffic impact will be minimal.
As stated in Section 3.15, (p. 3-15.1 through p. 3-15.5) of the
Draft PEIR, the proposed project’s only impacts to traffic would
be during short-term construction activities, with the exception
of minimal and periodic traffic related to maintenance
activities. The project would have no long-term operational
impacts because the RWMP would not be traffic-generating.
For short-term construction related traffic diversions,
Mitigation Measure 3.15-1 (p. 3.15-4) states that prior to
construction activities for any phase of the RWMP that would
require the diversion of traffic, the CLWA shall prepare a
Traffic Control Plan and implement traffic control measures in
compliance with the Work Area Traffic Control Handbook
(WATCH) Manual or the Manual on Uniform Traffic Control
Device (MUTCD) standards. If project construction requires
special measures outside the WATCH Manual or MUTCD
standards, then the Traffic Control Plan shall be prepared by,
stamped and signed by a registered Traffic Engineer. No
changes to the Draft PEIR are required.
Caltrans
2
Any work to be performed within the State Right-of-way will
need a Caltrans Encroachment Permit. We recommend that
construction related truck trips on State highways be limited to
off-peak commute periods. Transport of over-size or over-weight
vehicles on State highways will need a Caltrans Transportation
Permit.
As stated in Section 3.15.2 (p. 3.15-2), there would be no
increase in traffic associated with the operation of the RWMP
and the construction-related impacts would be minor and
would not significantly affect street capacity, volume-tocapacity ratios, or congestion at intersections. Additionally, the
analysis presented in the Draft PEIR is on a programmatic level.
As stated in Section 1.3 (p. 1-3 and 1-4), if activities that
implement the RWMP are found to have impacts beyond those
analyzed in the Draft PEIR, then additional CEQA compliance
would be required.
As stated in Section 3.15 (p. 3.15-4) of the Draft PEIR,
Regulatory Requirement 3.15-1 mandates that prior to
commencement of construction activities on any phase of the
8
Comments and Responses Matrix (Continued)
Commenter
Comment
No.
Comment
Response
RWMP that would impact Caltrans right-of-way jurisdiction, a
Caltrans Encroachment Permit must be obtained. This
requirement also states that transport of over-sized and overweight vehicles on state highways will require a Caltrans
Transportation Permit. No changes to the Draft PEIR are
required.
LARWQCB
3
The DEIR should include a detailed impact analysis of salt
loadings to the Santa Clara River by surface runoff from the use
of recycled water. Currently, wastewater treatment does not
routinely include the removal of salts; therefore, recycled water
generally contains high amounts of salts.
When recycled water is applied to land for irrigation purposes,
water will be transpired into the air while salts will stay in
surface soil. Salts accumulated in surface soil can be transported
to the Santa Clara River by stormwater runoff or by incidental
runoff, which poses water quality problems. The DEIR states that
release of enriched salts from soils will be diluted to the extent
that the impacts to receiving water bodies would be less than
significant; however, no detailed impact analysis and no
mitigation measures were provided. Please provide detailed
quantitative analyses and mitigation to address these foreseeable
impacts.
All of the attributes of salt migration in irrigation water noted
by the commentator are true for both recycled water and
potable water. However, with this project, recycled water that
would have been discharged to the Santa Clara River would
instead be beneficially reused. The recycled water would be
used for landscape irrigation, replacing an equal amount of
potable water that has historically been used for these same
purposes. While this recycled water would have incrementally
more salt than the potable water it replaces, the overall effect of
the project would be a net reduction in the loading of salt from
WRP discharges and irrigation with potable water to the Santa
Clara River.
It should also be noted that within the area served by the Santa
Clarita Valley water reclamation plants, a number of source
control programs have been implemented by the recycled water
provider to reduce salt loadings from residential selfregenerating water softeners. CLWA has supported these
programs because they reduce salts in recycled water and are
necessary to help comply with water quality objectives for the
Santa Clara River. These efforts are ongoing and will be
expanded in the future and will continue to only further reduce
the amount of salt in the water that will be used for the RWMP.
Therefore, because of these overall reductions in salt loadings
(associated with reduced WRP discharges to river, reduced salt
loadings from water softeners and reduced salt loading from
9
Commenter
Comment
No.
Comment
Response
imported water), the impacts from stormwater runoff and/or
incidental runoff are expected to be less than significant as
compared to what already occurs with respect to landscape
irrigation with potable water. However, Regional Board
continues to retain its authority to approve specific recycled
water projects that are implemented under this programmatic
EIR. As such, should there exist future water quality concerns
related to specific projects, these concerns can still be addressed
at the project level. Before re-use is allowed, both the Regional
Board and CA Department of Health Services must approve
the engineering reports for specific projects that implement the
RWMP. As such, the Regional Board has the authority to
regulate the use of recycled water, at the project level and
address any relevant concerns as necessary, at that time.
Notwithstanding the issues discussed above, it should be also
noted that the discussion of “salt” within the Santa Clara River
watershed is normally in terms of chloride. As stated in
Regulatory Requirement 3.8-3 (p. 3.8-36), the RWMP would be
implemented in compliance with all applicable federal, state,
and local regulations, including the California Water Code,
CCR Title 22, CCR Title 17, DHS Guidelines, and the Los
Angeles County Department of Health Services CrossConnection and Water Pollution Control Program. Recycled
water obtained by CLWA for use will comply with all
requirements for that use imposed by the provider of the
recycled water for the RWMP. The provider of the recycled
water sets the terms of its use, in part, in accordance with
regulatory programs under the authority of the Regional Board,
such as the issuance of waste discharge requirements (i.e.
NPDES permits) that contain effluent limits for salts. As set
forth in Table 3.8-6 in Section 3.8.1 (p. 9.8-14) a Total Maximum
Daily Load (TMDL) in the Santa Clara River watershed for
10
Commenter
Comment
No.
Comment
Response
chloride has been established by the LARWQCB, which will
determine future wasteload allocations and NPDES permit
limits for salt.
Under the Porter Cologne Water Quality Control Act, the
Regional Board is required to adopt water quality control plans
that establish water quality objectives for surface water and
groundwater. Water quality objectives are set to protect
beneficial uses and are the maximum allowable concentration
of pollutants for specified water bodies. When establishing
water quality objectives in basin plans, Regional Boards must
take into consideration the need to recycle water. Basin plans
and their water quality objectives are implemented through
waste discharge requirements issued by the Regional Boards.
Waste discharge requirements must also implement the State
Board Antidegradation Policy. In short, waste discharge
requirements for projects such as the RWMP that recycle water
may contain effluent limits on discharges of salts as necessary
to meet water quality objectives, comply with the
Antidegradation Policy, or otherwise protect beneficial uses.
Thus, the recycled water provider’s compliance with NPDES
permits and waste discharge requirements issued by the
Regional Board will inherently ensure that the use of recycled
water will be protective of surface waters in the Santa Clara
River watershed, which would ensure a less than significant
impact.
11
Commenter
NAHC
Comment
No.
4
Comment
Response
To adequately assess the project-related impacts on historical
resources, the Commission recommends the following actions:
This letter recommends actions to be taken to adequately assess
project-related impacts to the significance of a historical
resource. These actions include contacting the appropriate
California Historic Resources Information Center (CHRIS) for a
records search, conducting an archaeological survey of the
project area, contacting the Native American Heritage
Commission (NAHC) for a sacred lands file search and
preparation of a Native American contacts list, and provisions
for accidental discoveries of archaeological resources and/or
Native American human remains during ground disturbance.
The Cultural Resource Assessment, located in Appendix D of
the CLWA RWMP PEIR Volume II prepared for the proposed
project, documents the results of the CHRIS records search, the
archaeological survey, and the results of the sacred lands file
check and list of Native American contacts for the Northwest
Spur Pipeline study area.
Contact the appropriate California Historic
Information Center (CHRIS). The record search will
determine:
Resources
• If a part or the entire APE has been previously surveyed for
cultural resources.
• If any known cultural resources have already been recorded in
or adjacent to the APE.
• If the probability is low, moderate, or high that cultural
resources are located in the APE.
• If a survey is required to determine whether previously
unrecorded cultural resources are present.
If an archaeological inventory survey is required, the final stage
is the preparation of a professional report detailing the findings
and recommendations of the records search and field survey.
• The final report containing site forms, site significance, and
mitigation measurers should be submitted immediately to the
planning department. All information regarding site locations,
Native American human remains, and associated funerary
objects should be in a separate confidential addendum, and not
be made available for pubic disclosure.
• The final written report should be submitted within 3 months
after work has been completed to the appropriate regional
archaeological Information Center.
Contact the Native American Heritage Commission (NAHC) for:
• A Sacred Lands File (SLF) search of the project area and
information on tribal contacts in the project vicinity who may
12
The Cultural Resource Assessment also includes recommended
studies for each subsequent RWMP phase. Recommended
studies, as described in Regulatory Requirement 3.5-2 (p. 3.5-9)
and Mitigation Measure 3.5-1 (p. 3.5-10) include a records
search at the appropriate CHRIS center, a sacred lands file
check and consultation with local Native American
representatives if there is potential to impact Native American
resources, an archaeological survey, and the results of these
studies should be prepared in an cultural resource technical
report. No changes to the EIR are necessary.
Commenter
Comment
No.
Comment
Response
have additional cultural resource information. Please provide this
office with the following citation format to assist with the Sacred
Lands File search request: USGS 7.5-minute quadrangle citation
with name, township, range and section.
• The NAHC advises the use of Native American Monitors to
ensure proper identification and care given cultural resources
that may be discovered. The NAHC recommends that contact be
made with Native American Contacts on the attached list to get
their input on potential project impact, particularly the contacts
of the on the list.
Lack of surface evidence of archeological resources does not
preclude their subsurface existence.
• Lead agencies should include in their mitigation plan
provisions for the identification and evaluation of accidentally
discovered archeological resources, per California Environmental
Quality Act (CEQA) §15064.5 (f).
In areas of identified archaeological sensitivity, a certified
archaeologist and a culturally affiliated Native American, with
knowledge in cultural resources, should monitor all grounddisturbing activities.
• Lead agencies should include in their mitigation plan
provisions for the disposition of recovered artifacts, in
consultation with culturally affiliated Native Americans.
Lead agencies should include provisions for discovery of Native
American human remains or unmarked cemeteries in their
mitigation plans.
• CEQA Guidelines, Section 15064.5 (d) requires the lead agency
to work with the Native Americans identified by this
Commission if the initial Study identifies the presence or likely
13
Commenter
Comment
No.
Comment
Response
presence of Native American human remains within the APE.
CEQA Guidelines provide for agreements with Native American,
identified by the NAHC, to assure the appropriate and dignified
treatment of Native American human remains and any associated
grave liens.
Health and Safety Code §7050.5, Public Resources Code §5097.98
and Sec. §15064.5 (d) of the CEQA Guidelines mandate
procedures to be followed in the event of an accidental discovery
of any human remains in a location other than a dedicated
cemetery.
Lead agencies should consider avoidance, as defined in § 15370
of the CEQA Guidelines, when significant cultural resources are
discovered during the course of project planning.
OPR
5
The State Clearinghouse forwarded the above-mentioned project
to your agency for review on November 14, 2006 with incorrect
review dates. Please make note of the following information for
your files:
Review period began: November 14, 2006
Review period ends: December 28, 2006
This letter is intended to clarify the CLWA Draft PEIR public
review period. The State Clearinghouse (SCH) public review
period began November 14, 2006 and ended December 28, 2006.
However, CLWA allowed for an extended public review period
to allow for additional time to comment on the RWMP DEIR.
The original CLWA review period ended January 3, 2007. The
public review period was subsequently extended until
February 2, 2007.
OPR
6
Pursuant to the attached letter, the Lead Agency has extended the
review period for the above referenced project to February 2,
2007 to accommodate the review process. All other project
information remains the same.
The letter acknowledges the receipt of CLWA’s request to
extend the public review period from January 3, 2007 to
February 2, 2007.
OPR
7
On the enclosed Document Details Report, please note that the
Clearinghouse has listed the state agencies that reviewed your
document. The review period closed on February 2, 2007, and the
comments from the responding agency (ies) is (are) enclosed.
This letter includes the following comment letters, which are
included in this Response to Comments document:
14
• Native American Heritage Commission
• California Department of Transportation (Caltrans)
Commenter
Comment
No.
Comment
Response
• State Water Resources Control Board
SWRCB
8
The Project may indirectly foster future economic or population
growth or the construction of additional housing within the
Agency service area. The potential effects of the proposed project
could increase impervious surface area that could have a
significant impact by affecting peak flow rates of floodwaters,
and increase flooding on or off site of future development. For
the purposes of future development within the Agency area,
consider measures that would reduce storm water and urban
runoff, such as Low Impact Development (LID). These
sustainable practices benefit water supply and contribute toward
water quality protection. For more information on LID, please
refer
to
the
State
Water
Board's
website
at
http://www.waterboards.ca.gov/lid/index.html.
As stated in Section 4.1.2 (p. 4-2) of the Draft PEIR, the
proposed project would be considered growth-inducing
because the availability of new potable water supplies would
remove an obstacle to population growth. As discussed in
Section 3.8 (p. 3.8-26 and 3.8-27) of the Draft PEIR, none of the
RWMP components have the potential to result in a direct
significant impact due to increased flooding on or off-site.
However, the increased development that may indirectly result
from the RWMP could significantly increase urban runoff due
to increased impervious cover, as discussed on p. 4-11 of the
Draft PEIR.
However, the CLWA has no regulatory authority over the
location, type or character of new development within its
service area. As stated in Section 4.2 (p. 4-2) of the Draft PEIR,
the local city and county planning agencies are responsible for
creating land use plans that direct where development should
occur and these agencies are responsible for approving and
enforcing those plans. In summary, the CLWA does not have
the authority to mandate Low Impact Development (LID).
As discussed in Section 3.8 (p. 3.8-26 and 3.8-27) of the Draft
PEIR, the direct impacts of the project would not result in
significant impacts related to increased runoff. RWMP project
components are generally small in size and would therefore not
be required to comply with SUSMP, as discussed on page 3.8-25
of the Draft PEIR.
15
Commenter
Comment
No.
Comment
Response
SWRCB
9
Section 4.3 (p. 4-17) concludes that the implementation of the
RWMP would result in significant and unavoidable indirect
impacts to aesthetics, air quality, biological resources,
transportation and traffic, and utilities/service systems. This
statement contradicts Table ES-1: Summary of Environmental
Impacts and Mitigation Measures and does not identify the
specific impacts. Please correct the statement on p. 4-17 to
identify significant and unavoidable indirect impacts resulting
from the RWMP Project.
Table ES-1 in the Executive Summary correctly corresponds to
the summary of impacts as stated in Section 4.3 (p. 4-17) of the
Draft PEIR. The indirect impacts (growth related) are addressed
separately within each impact category in Table ES-1. The
discussion of the significant and unavoidable growth-related
impacts is presented within Section 4.2, Growth-Related
Impacts, which is a summary of the individual impact topics
discussed within the following subsections; Section 4.2.1
(Aesthetics), 4.2.3 (Air Quality), 4.2.4 (Biological Resources),
4.2.15 (Transportation), and 4.2.16 (Utilities/Service Systems).
The statement in Section 4.3 (p. 4-17) is correct and does not
require revision. No changes to the Draft PEIR are required.
LACSD
10
Pages 2-8 (lines 25-35), 2-9 (lines 1-22), 3.4-23 (lines 32-45), 3.4-24
(linesl-10), 3.8-22 (lines 25-45), 3.8-23 (lines 27), and 3.8-25 (lines 28) include discussions on potential flow impacts to the Santa
Clara River, due to the diversion and use of recycled water from
the Valencia WRP. The District agrees with CLWA's analysis that
the RWMP would not impact the biological resources or
hydrology of the Santa Clara River system because the combined
existing discharges to the Santa Clara River would be
maintained. However, the District does not believe that the
existing combined discharge condition of 18.4 MGD, as identified
in the RWMP, is the de-facto minimum discharge that must be
maintained to the Santa Clara River to prevent significant
impacts. The District, in its 2015 Santa Clarita Valley Joint
Sewerage System Facilities Plan and Environmental Impact
Report (2015 Plan and EIR), previously analyzed biological and
hydrological impacts from multiple discharge scenarios
including a no discharge scenario and a reduced discharge
scenario. The no discharge scenario assumed a combined
discharge of 0.0 MGD to the Santa Clara River from the Saugus
and Valencia WRPs, and the reduced discharge scenario assumed
None of the statements made by the commentator conflict with
those in the Draft Program EIR. The analysis in the Draft PEIR
in Section 2.5, Recycled Water Supply (p. 2-7 through 2-9) states
that the proposed RMWP would not reduce effluent levels
below the 18.4 mgd that has been the annual average for the
years 2001-2005. The most recent average effluent levels
available at the time of the issuance of the NOP were used for
the purposes of the Draft PEIR, which serves as the “existing
condition” baseline for the purposes of CEQA. This does not
imply that a different effluent level would necessarily result in
a significant environmental impact, only that such a change
might require additional analysis to determine the level of the
significance of the effect.
16
Since the RWMP would not reduce the level of effluent in the
Santa Clara River when compared to the existing condition, the
Draft PEIR does not make a determination as to the level of
effluent flow necessary from the WRPs to avoid a significant
environmental impact to downstream hydrology or biology. It
may be that the Santa Clara River would not experience a
significant impact if diversions resulted in an effluent flow of
Commenter
Comment
No.
Comment
Response
that a significant amount of the recycled water would be used by
water purveyors resulting in a combined discharge of 9.6 MGD to
the river. The District concluded in the 2015 Plan and EIR that the
no discharge scenario would result in significant impacts to
biological resources and hydrology, and that the reduced
discharge scenario would result in less than significant impacts.
less than 18.4 mgd. As described in Section 2.5 (p. 2-9), if at a
future time the recycled water facilities should require more
diversions to achieve the RWMP goal of 17,400 af/yr,
additional CEQA analyses and a determination as to the
impacts of any additional effluent diversion would be
completed. Therefore, it may be determined at a later date
through subsequent CEQA analysis that additional diversions
are possible without significantly impacting the hydrology or
biological resources of the Santa Clara River.
LACSD
11
The 2015 Plan and EIR also determined that the reduced
discharge scenario would maintain the gap in perennial flows
between Los Angeles and Ventura counties, thereby preventing
the hybridization and loss of the endangered unarmored threespine stickle back (UTS). The conclusions of the District's 2015
Plan and EIR are further supported by the U.S. Fish & Wildlife
Service's 1985 Unarmored Threespine Stickleback Recovery Plan Revised, which found that the then-existing combined discharges
of 8.0 MGD supported the recovery of the fish species. Overall,
there is evidence in the record to support the conclusion that
biological resources, including special status fish species (i.e.,
Santa Ana Sucker and UTS), could be supported by a minimum
combined discharge of 9.6 MGD, which is significantly below
existing combined discharge condition of 18.4 MGD.
As stated in Response 10 above, the Draft PEIR does not
conclude that additional diversions from the Valencia WRP
would result in significant impacts to the Santa Clara River and
its associated biological resources. It may be determined at a
later date through subsequent CEQA analysis that additional
diversions are possible without significantly impacting the
endangered UTS. Since the RWMP would not reduce flows
below the 2001-2005 annual average, there would not be an
affect on the UTS.
LACSD
12
The Santa Clarita Valley Sanitation District is the legal owner and
operator of the Saugus and Valencia WRPs. As such, there are
instances where Los Angeles County Sanitation Districts,
Sanitation Districts of Los Angeles County and/or LACSD are
utilized in the DPEIR in relationship to ownership/operation of
the Saugus and Valencia WRPs. The District requests that the
DPEIR properly reference the District as Santa Clarita Valley
Sanitation District or SCVSD. The following are specific page
All revisions that change the Sanitation Districts of Los Angeles
County (LACSD) to the Santa Clarita Valley Sanitation District
(SCVSD) are hereby incorporated by reference into the Final
PEIR.
17
Commenter
Comment
No.
Comment
Response
numbers where such changes are requested:
• ES-l, Line 26
• Page 2-2, Line 3
• Page 2-7, Line 36
• Page 3.8-6, lines 28, 32 and 34
• Page 3.8-9, lines 13 and Lines 22
• Page 3.8-17, line 7
• Page 3.16-1, lines 8-37
• Page 6-9, lines 8-9
LACSD
13
Page 2-7, Lines 39-40
• Change text as follows: " ... the Valencia WRP is a publicly
owned treatment works (POTW) that is owned and operated by
the Santa Clarita Valley Sanitation District, and is located on the
Old Road near SFMM."
LACSD
14
Page 2-8, lines 1-2
• Change text as follows: "According to the 2015.Santa Clarita
Valley Joint Sewerage System Facilities Plan and Environmental
Impact Report..."
LACSD
15
Page 2-9, line 40
• The District believes that the ultimate design capacity for the
Newhall WRP is 6.8 MGD, and request that CLWA confirm this
with Newhall Land and Farm.
LACSD
16
Page 3.4-23, line 32
• The sentence should read: "The Valencia and Saugus WRPs"
LACSD
17
Page 3.8-6, lines 13-16
• Change text as follows: " ... the Valencia WRP is a publicly
owned treatment works (POTW) that is owned and operated by
the Santa Clarita Valley Sanitation District."
18
This text revision is hereby incorporated by reference into the
Final PEIR.
Final PEIR.
According to the Landmark Village Draft Environmental
Impact Report, the capacity of the Newhall Ranch WRP
(November, 2006, page 4.11-8) would be 6.8 MGD. This text
revision is hereby incorporated by reference into the Final PEIR.
Final PEIR.
Final PEIR.
Commenter
LACSD
Comment
No.
18
Comment
Response
Page 3.8-7, lines 3-10
• The District requests that language related to reported cyanide
exceedances be revised as follows:
Final PEIR.
"As shown in Table 3.8-2 above, the Valencia WRP had
apparently exceeded the effluent limitation requirements for
cyanide at least once in the years 2002, 2003, and 2004. As a result
of these exceedances, as well as cyanide exceedances at other
WRPs owned and operated by LACSD, extensive research on
cyanide was performed and it was determined that the apparent
historical cyanide exceedances were not actual exceedances but
rather artifacts of the preservation method used in the collection
of cyanide samples taken in the field. Standard Methods
recommends that cyanide samples be analyzed within fifteen
minutes, and if not possible, then preserved for later analysis by
raising the pH of the samples. Because the District has not
historically had the laboratory infrastructure at the Valencia WRP
to analyze cyanide samples within fifteen minutes, the historical
practice was to preserve these samples via pH adjustment.
Further research has revealed that this preservation step causes
positive interferences in the cyanide test. When the samples were
analyzed immediately without preservation, as is recommended
in Standard Methods, no exceedances of cyanide effluent
limitations were found at the Valencia WRP. In December 2005,
the Valencia WRP treatment plant laboratory was ELAP certified
in order to immediately measure cyanide after sample collection.
There have been no exceedances of cyanide effluent limitations at
the Valencia WRP since 2005."
LACSD
19
Page 3.8-7, lines 29-31
• According to the District's records, in 2004 and in 2005, a total
of 137MG and 136MG of recycled water had been utilized.
19
Final PEIR.
Commenter
LACSD
Comment
No.
20
Comment
Response
Page 6-9, line 6
• Change "Phase I expansion of 9 mgd in 2002..." to "Stage 5
expansion of 9 mgd in 2003."
LACSD
21
Page 6-9, lines 6-13
• The District requests that language related to future expansions
be revised as follows:
Final PEIR.
Final PEIR.
"To accommodate anticipated growth in the Santa Clarita Valley
area and to ensure compliance with discharge requirements from
the Regional Water Quality Control Board (RWQCB), the Santa
Clarita Valley Sanitation District has plans to expand the capacity
of the Valencia WRP, as discussed in the District's 2015 SCVJSS
Facilities Plan and EIR. The Stage VI expansion will increase the
capacity of the Valencia WRP by another 6 mgd, for a total
capacity of 27.6 mgd. No expansion of the Saugus WRP is
planned; thus total capacity for both WRPs is 34.1 mgd (38,200
af/yr)."
LACSD
22
Page 6-10, line 7
• The District believes that the ultimate design capacity for the
Newhall WRP is 6.8 MGD, and request that CLWA confirm this
with Newhall Land and Farm.
CoLADPR
23
The above project may impact facility under the jurisdiction of
this Department which we offer the following comments:
• Proposed reservoirs 2 and 3 may have visual impacts to
portions of County Trail #68 (William S. Hark Park Trail, as well
as William S. Hart Regional Park) and #76 (Cliffie Stone Trail).
Vegetative screening or other means of mitigating aesthetic
impacts must be used.
20
According to the Landmark Village Draft Environmental
Impact Report, the capacity of the Newhall Ranch WRP
(November, 2006, page 4.11-8) would be 6.8 MGD. This text
revision is hereby incorporated by reference into the Final PEIR.
The visual impacts resulting from the visible aboveground
RWMP components, such as the reservoir tanks, would be
mitigated through several requirements. As discussed in
Section 3.1 (p. 3.1-10 and 3.1-11) of the Draft PEIR, Mitigation
Measure 3.1-1 states that prior to commencement of grading
activities for each phase of development, CLWA shall prepare a
Landscape Plan that identifies measures to reduce the visual
impacts associate with the visible above ground RWMP
facilities, including the strategic planting of native trees shrubs,
Commenter
Comment
No.
Comment
Response
and other vegetation to buffer the views of structures.
As stated in Section 3.1 (p. 3.1-11) of the Draft PEIR, Mitigation
Measure 3.1-2 states that reservoir tanks and booster pump
stations shall be painted with low-reflective paint in a
camouflaging color that blends with the surrounding
environment.
Measure 3.1-3 states that prior to the commencement of grading
activities, CLWA’s Engineer for the grading and construction of
the reservoir tanks shall provide a Grading Plan that
incorporates landform grading techniques and minimizes
changes to topography. If bench-cuts into hillsides are required
to locate some reservoir tanks or other RWMP facilities, then
landform grading techniques shall be incorporated that
preserve as much of the natural topography as possible and
that create cuts which blend into the surrounding hillside areas.
Measure 3.1-4 states that prior to the commencement of grading
activities for any component of the RWMP, a qualified
Biologist/Arborist shall be consulted to determine the
biological/aesthetic value of potentially impacted trees. All
impacted native trees shall be replaced at a minimum of 1:1 to
mitigate for the loss of biological value, and all impacted
ornamental trees shall be replaced at a minimum ratio of 1:1 to
mitigate for aesthetic impacts. All impacted trees shall be
replaced with appropriate native species at an ultimate ratio to
be determined by a qualified Biologist/Arborist. Therefore,
aesthetic impacts shall be adequately mitigated and no changes
to the Draft PEIR are required.
21
Commenter
Comment
No.
Comment
Response
CoLADPR
24
• Proposed pipelines may traverse County Trail #71 (Santa Clara
River Trail) and #77 (Bouquet Canyon Trail) which will require
coordination with our Department. For trails inquiries please
contact Mr. Ken Siu Trails Coordinator at 213 351-5135.
If the proposed pipelines for RWMP impact County Trail # 71
(Santa Clara River Trail) and County Trail #77 (Bouquet Canton
Trail), Mitigation Measures 3.1-1 through 3.1-4 as summarized
above will be implemented to minimize aesthetic impacts to
less than significant levels. Per standard CLWA protocol,
LADPR would be contacted to coordinate construction
activities that may traverse any County trails, should they
occur.
CoLADPW
25
Recycled Water Master Plan Components, starting on page 3.423: This section appears to assume there will always be end users
of all additional recycled water. This may not be the case should
the production increase faster than the demand for recycled
water or during very wet years. There should be a provision for
this situation in the permit to discharge the reclaimed water.
Also, the Aquifer Storage Recovery wells will occasionally need
to be re-developed or upgraded. The wastewater produced
during this process would need to be treated and properly
disposed.
The RWMP would be constructed in phases based on the
projected demand for the recycled water. Section 8 and Section
13 of the 2002 Draft Report Recycled Water Master Plan (p. 34)
states the background of the methodology for determining the
potential recycled water demand, and subsequent phasing
program, for RWMP implementation. The RWMP construction
would be phased in order to begin the return on the
investments as soon as possible. Infrastructure would not be
extended to areas where there is no demand or the costs of
extending the infrastructure are too high. Generally, supplies
of recycled water would be taken from sources only if recycled
water demand was sufficiently high to permit the use of the
recycled water. If demand was too low, the recycled water
would be discharged as it currently is, as effluent to the Santa
Clara River in the case of the Valencia Water Reclamation Plant.
Additionally, as discussed in Section 2.6.4 and 2.6.7, the
reservoir tanks and/or the ASR would be used to store recycled
water in times of excess supply. Therefore, it is not anticipated
that the recycled water would need to be discharged from the
RWMP system and no additional treatment or permitting
would be required.
As stated in Regulatory Requirement 3.8-5, the operation of the
ASR facilities must comply with all applicable state and federal
groundwater recharge regulations. Therefore, all maintenance
22
Commenter
Comment
No.
Comment
Response
activities will be in compliance with applicable regulations, as
is CLWA standard protocol.
CoLADPW
VenturaWPD
26
27
Section 2.6.2, page 2-16, Lines 1 through 9: This paragraph
indicates that the pipeline crossing the Santa Clara River at the
Old Road will be placed underground. Discussions elsewhere
indicate the depth of the pipeline between six to nine feet.
Discussion of the SR-126 crossing indicates that the pipeline will
be attached to the bridge. Please clarify the pipeline crossing at
the Santa Clara River. If it is to be laced underground below the
riverbed, the risks associated with washing out at the crossing
need to be addressed.
References to the “underground” pipeline in Section 2.6.2 (p. 216) are intended to refer to the pipeline within the roadways.
As stated throughout the biological analysis in Section 3.4.2,
(i.e. Lines 41-43 on p. 3.4-22) the Northwest Spur Pipeline
extension will be suspended above the Santa Clara River on the
SR-126 bridge crossing.
Recycling of treated wastewater is a beneficial and necessary
method for decreasing dependence on potable water. It is much
better to utilize recycled water for irrigation and industrial needs
instead of diverting a valuable supp1y of potable water for such
needs. CLWA's goal of 17,400 af/yr of recycled water use is
based on projected future growth in population. The Los
Angeles RWQCB has established a Total Maximum Daily Load
(TMDL) of 100 milligrams per liter (mg/l) chloride for flow
Reaches 5 and 6 of the Santa Clara River. No discussion has been
included regarding whether or not the effluent released from the
Saugus and Valencia WRP's will be brought into compliance with
this requirement.
The proposed water quality objective of 100 mg/L for chlorides
will go into effect in 2015 according to LARWQCB. This
objective is a requirement that, as currently proposed, would
need to be met at monitoring locations of point dischargers
including the Valencia Water Reclamation Plant which will be
the primary source of recycled water for the Recycled Water
Master Plan.
Therefore, regulatory requirements would
mandate that the objective will be met in the year 2015 and that
progress from current levels of chloride in the Valencia WRP
effluent to the objective will be made prior to that date.
23
For clarification, the following sentence will be added by
reference to Final PEIR in Section 2.6.2, p. 2-16, beginning on
Line 9: “The Northwest Spur Pipeline will be suspended above
the Santa Clara River on the SR-126 bridge crossing.”
Water diverted for use in the RWMP would be reflective of
these changes in effluent water quality and would not alter the
quality of the remaining effluent to be discharged to the Santa
Clara River by the Valencia WRP. Therefore, the RWMP
project would not have an impact on the ability of the Valencia
WRP to meet the proposed chloride TMDL objective.
Commenter
VenturaWPD
Comment
No.
28
Comment
Response
The discussion in this section indicates that by 2030, the planned
effluent discharge to the Santa Clara River from the combine
Saugus and Valencia WRP's will be 18.4 million gallons per day
(mgd); the average as measured from 2001 through 2005. It also
states, "Therefore, implementation of the RWMP would not
impact the hydrology or ecology of the Santa Clara River system
since the existing discharge conditions from both WRP’s would
be essentially maintained".
The Draft PEIR documents in Section 2.5, Recycled Water
Supply (p. 2-7 through 2-9) that the proposed RMWP would
not reduce effluent levels below the 18.4 mgd that have been
the annual average for the years 2001-2005.
The effluent
required to supply the RMWP would come from the growth in
effluent that is forecast by the Santa Clarita Valley Sanitation
District at the Valencia Water Reclamation Plant. This growth
in effluent would precede the development of the RWMP and,
according to the schedule for construction of the phases of the
RWMP, the use of recycled water would lag the growth in
effluent so that the annual average effluent would not fall
below the 18.4 mgd figure for any of the intermediate years
between the start of construction of Phase 1B and the year 2030.
Additionally, this analysis did not rely on the potential for any
other sources of recycled water to contribute to the supply of
recycled water as identified in the RWMP. If such sources were
used, this would push the baseline flows from the Valencia
WRP even higher.
No discussion has been included regarding the water quality and
quantity of discharges to the river system during the interval
between the present time and year 2030 when the project is
completed. The amount of effluent discharged to the river has not
been stated and the expansion of the Valencia WRP plant may
affect future discharges. Care should he taken to assure that the
implementation of the RWMP does not affect downstream basins
in the areas of both water quality and water quantity.
The proposed project would not affect the quality of the
effluent at the Valencia Water Reclamation Plant because the
intent is to divert a portion of the effluent flow, and as noted
above, this would be a portion of the future increased effluent.
The concentration of any constituents in the remaining effluent,
therefore would be unaffected by the proposed project. Both
the total volume of effluent and the total amount of any
constituents in the effluent would be equally reduced, and
other than a reduction of total constituents at the point of
discharge, there would be no impacts to water quality at the
point of discharge. As noted in the paragraph above, the total
effluent would not fall below the annual average from 20012005 at anytime between start of construction of new phases of
the RWMP and buildout in the year 2030. Effluent water
24
Commenter
Comment
No.
Comment
Response
quality would also not be affected during this interval since a
uniform reduction in the effluent would be taken and there
would not be dilution or concentration of any constituents in
the effluent to be discharged to the Santa Clara River.
Friends
29
There is considerable controversy around the concept of using
recycled water for Aquifer Storage and Recovery projects (ASR).
Recycled water should not be used for this purpose without more
detailed studies beyond the discussion provided in the DEIR.
As required by Regulatory Requirement 3.8-5 (p. 3.8-36), all
groundwater recharge regulations, including the future Title 22
“Groundwater Recharge Reuse” regulations, should they be
adopted. Additionally, as required by Mitigation Measure 3.81, a hydrogeology analysis and/or water quality analysis of the
proposed location of the ASR facility must be conducted prior
to the implementation of any RWMP component that is
contingent upon the availability of a functioning ASR facility.
Therefore, the PEIR requires that more detailed studies be
performed prior to the implementation of the ASR facility, and
that these studies conclude prior to any ASR construction that
the ASR facility would not have the potential to impact
groundwater supplies that are designated as a potential source
of domestic water supply. No changes to the PEIR are
required.
Friends
30
We note that water agencies and the City of Santa Clarita are in
the early stages of an Integrated Regional Water Management
Plan effort. Bringing recycled water projects under the aegis of
this plan would seem to be highly appropriate, and we
recommend that course.
The Castaic Lake Water Agency is one of seven agencies within
Los Angeles County that are proposing to work together to
develop the Upper Santa Clara River Integrated Regional Water
Management Plan.
Therefore, CLWA intends to fully
participate in the development of the IRWMP and the
implementation of the RWMP will be included in the IRWMP,
as appropriate.
Friends
31
It appears that the Saugus aquifer is the most likely recipient
basin for recharge. If so, this needs to be rethought due to the
ammonium perchlorate plume in this aquifer that continues to
migrate westward.
As required by Mitigation Measure 3.8-1, a hydrogeology
analysis and/or water quality analysis of the proposed location
of the ASR facility must be conducted prior to the
implementation of any RWMP component that is contingent
upon the availability of a functioning ASR facility. Therefore,
25
Commenter
Comment
No.
Comment
Response
the Draft PEIR requires that more detailed studies are
performed prior to the implementation of the ASR facility.
Potential constraints to ASR development, such as
contamination due to ammonium perchlorate or other
pollutants, will be analyzed in the required studies. No
changes to the Draft PEIR are required.
Friends
32
More detailed studies need to be carried out to determine
impacts to endangered or threatened species for recharge
facilities sited in any sensitive biological area. Information in the
DEIR is not sufficient for this purpose.
Facilities associated with the ASR would include pumps and
wells to inject and extract stored recycled water and pipelines
to put the water into the recycled water system. The ASR
would not result in significant disturbance of surface areas and
would not result in the loss of substantial amounts of habitat or
open space. Though the exact locations of such facilities have
yet to be determined, they are most likely to be constructed
within urban areas in order to provide better access to the
recycled water system and to minimize pumping. Therefore,
only minimal impacts to vegetated open space areas are
anticipated as a result of the ASR facilities.
SCOPE
33
SCOPE strongly supports the use of recycled for some uses,
specifically landscaping and industrial uses (cooling towers, etc.).
However, we note that there is considerable controversy and are
substantial permitting issues involved in using recycled water for
Aquifer Storage and Recovery projects (ASR) such as are
described only in a very general way by this DEIR. We do not
support the use of recycled water for that purpose unless and
until there is a more detailed overview and a process in place for
public involvement. Such an overview and disclosure of health
and water quality impacts is not found in the current document.
Therefore, the PEIR requires that more detailed studies are
that these studies must conclude prior to any ASR construction
that the ASR facility would not have the potential to degrade
the quality of groundwater supplies that are designated as a
potential source of domestic water supply. As stated in Section
26
Commenter
Comment
No.
Comment
Response
1.3 (p. 1-3 and 1-4), if activities that implement the RWMP are
found to have impacts beyond those analyzed in the Draft
PEIR, then additional CEQA compliance would be required.
Additional CEQA compliance, if required, would allow for, at a
minimum, additional public review of relevant technical
analyses. No changes to the PEIR are required.
SCOPE
34
Recycled water projects are appropriate for grant funding. Since
the water agencies and the City of Santa Clarita are just
beginning an “Integrated Water Resource Plan” with the
intention of making grant applications to the current State
funding mechanisms, we strongly recommend that this document
be delayed to include ideas and projects that may evolve from
that process. We believe that such a delay would save the
Agency time and money in any future environmental review that
may be required as a result of projects proposed for grants
through the IRWMP process.
The Castaic Lake Water Agency is one of seven agencies within
Los Angeles County that are proposing to work together to
develop the Upper Santa Clara River Integrated Regional Water
Management Plan.
Therefore, CLWA intends to fully
participate in the development of the IRWMP and the
implementation of the RWMP will be included in the IRWMP,
as appropriate. The RWMP and the Draft PEIR assist the
CLWA to identify its priorities for recycled water facilities,
which will better allow CLWA to recommend projects for
inclusion in the IRWMP and for possible grant funding.
SCOPE
35
The Agency is aware of the Regional Water Quality Board’s
concern over aquifer recharge with State Water Project water in
the Santa Ana area, due to the degradation of the existing ground
water quality from such a process. We believe that a similar
degradation could occur in the Santa Clarita area as well, should
such a process be allowed here. This degradation could result
from increased chloride levels, that are already a problem in this
watershed, and potential health risks from viruses and
pharmaceuticals, currently found in recycled water and not
removed by the tertiary process now used by the Sanitation
District. The DEIR does not fully disclose these impacts and
impediments to the project so that the public and the decisionmakers are fully aware of these issues. We believe that this is a
serious flaw in the current document.
Therefore, the PEIR requires that more detailed studies be
that these studies must conclude that the ASR facility would
not have the potential to impact the quality of groundwater
supplies that are designated as a potential source of domestic
water supply. No changes to the PEIR are required. As stated
in Section 1.3 (p. 1-3 and 1-4), if activities that implement the
27
Commenter
Comment
No.
Comment
Response
RWMP are found to have impacts beyond what was analyzed
in the Draft PEIR, then additional CEQA compliance would be
required. Additional CEQA compliance, if required, would
allow for, at a minimum, additional public review of relevant
technical analyses.
SCOPE
36
Previous documents (not discussed in this DEIR) indicated that
the Saugus Aquifer would be the target basin for any recharge
activity. This should be reviewed in light of the continued
migration of the ammonium perchlorate plume in a westerly
direction and the discovery of over contamination, including
VOC’s, in this aquifer. Prior reports indicated that the Santa
Clara River alluvium was not an appropriate storage area since
the water moved quickly through the eastern reaches.
As stated in Section 2.6.7 (p. 2-20), the ASR is anticipated to
inject recycled water below the ground surface into the Saugus
Formation north of the San Gabriel Fault, which would serve to
isolate it from the remainder of the formation. Regulatory
Requirement 3.8-3 (p. 3.8-36) the RWMP would be
implemented in compliance with all applicable federal, state,
and local regulations, including the California Water Code,
CCR Title 22, CCR Title 17, DHS Guidelines, and the Los
Angeles County Department of Health Services CrossConnection and Water Pollution Control Program. Therefore,
all water used in the recycled water system would need to meet
all applicable water quality requirements. Additionally, as
required by Mitigation Measure 3.8-1, a hydrogeology analysis
and/or water quality analysis of the proposed location of the
ASR facility must be conducted prior to the implementation of
any RWMP component that is contingent upon the availability
of a functioning ASR facility. Therefore, the PEIR requires that
more detailed studies are performed prior to the
implementation of the ASR facility. Potential constraints to
ASR development will be analyzed in the required studies. No
changes to the PEIR are required.
SCOPE
37
Further, this document may not serve for an environmental
review of the impacts of the ASR proposal for the Saugus
Aquifer. Such a project needs a full review, circulation to all
interested parties and agencies including the Regional Water
Quality Board, and public disclosure so that the above briefly
described impacts can be publicly disclosed and evaluated.
28
Commenter
Comment
No.
Comment
Response
that these studies conclude that the ASR facility would not have
the potential to impact groundwater supplies that are
designated as a potential source of domestic water supply. No
changes to the PEIR are required.
SCOPE
38
In 1988 the Castaic Lake Water Agency (CLWA) approved a PEIR
for a Recycled Water Plan. In 1993, The Agency developed and
circulated a Recycled Water Master Plan, tiering on that old EIR.
It is unclear whether this document replaces these old
Environmental Documents and Plans or merely adds to them.
Due to the enormous amount of new information regarding
water quality, permitting requirements, growth in number and
location of land use permits and biological impacts, we believe
that this report must be a replacement for those earlier
documents. We request that this fact be clearly indicated in the
FEIR.
This Draft PEIR for the RWMP is intended to serve as the
stand-alone
environmental
documentation
for
the
implementation of the RWMP. For clarification, the following
sentence will be added by reference to Final PEIR in Section
1.3.1, p. 1-4, beginning on Line 33: “This Draft PEIR for the
RWMP is intended to serve as the stand-alone environmental
documentation for the implementation of the RWMP.”
SCOPE
39
Also, we do not believe that this document provides sufficient
environmental review to allow the amendment of the Natural
River Management Plan (NRMP) to provide for siting of facilities
in sensitive habitat areas. Such an amendment of the Plan was
not contemplated when that plan was approved. We would
regard such a use as an inappropriate manipulation of that
Federal review process and would proceed to object to any such
amendment accordingly.
The Draft PEIR does not state that the implementation of the
RWMP would amend the NRMP. As discussed in Section 3.4.2
(p.3.4-27), construction of some of the proposed RWMP
components may result in impacts to jurisdictional resources
within the NRMP area. Within these areas, the necessary
permits from the USACE and CDFG may be processed in
accordance with the NRMP or through application for separate
permits from these agencies. If the NRMP permits are utilized,
the conditions of the permit, as described in the Plan, would be
adhered to. Therefore, if there are RWMP components that
impact jurisdictional waters that are not able to be processed
under the NRMP, separate USACE and CDFG permits would
29
Commenter
Comment
No.
Comment
Response
be required.
SCOPE
40
As previously stated, we believe site specific review must be
conducted for any facilities sited in a sensitive biological area.
This document does not give adequately detailed information to
provide the extent of any such impacts or to suggest sufficient
mitigation. Providing lists of endangered and threatened species
in the whole service area without indicating which species might
be found on any specific facility site does not provide adequate
information for reasonable assessment.
As stated in Section 3.4.2 (p. 3.4-20 and 3.4-21), impacts to
special status vegetation types, plants, and wildlife would be
mitigated to less than significant levels with the
implementation of Mitigation Measures 3.4-1 and 3.4-2, which
require completion of a Biological Reconnaissance Survey prior
to implementation of any RWMP component. In addition,
consultation with CDFG and/or the USFWS would be required
for impacts to state or federally listed endangered or threatened
species. All restoration areas would be designated as open
space in perpetuity. As stated in Section 1.3 (p. 1-3 and 1-4), if
activities that implement the RWMP are found to have impacts
beyond what was analyzed in the Draft PEIR, then additional
CEQA compliance would be required.
SCOPE
41
It is unclear from this document whether any additional water is
contemplated to be removed from flows emanating from the
Saugus treatment plant. The Saugus and Valencia treatment
plants are considered jointly by the Sanitation Districts and your
document. Since a flow is required to maintain endangered
species in the reach of the Santa Clara River below the Saugus
plant, we oppose any further use of water from the Saugus plant
that would disrupt the surface flow in this area. Such a diversion
would be a significant impact and require consultation under the
Endangered Species Act. This fact should be disclosed in the
DEIR.
As stated in Section 2.5 (p. 2-9) on Lines 4 and 5 of the Draft
PEIR, no recycled water would be taken from the Saugus WRP.
SCOPE
42
We believe the Recycled Water Plan should include an alternative
that promotes re-piping of individual homes to supply landscape
water from gray water uses in the home. Although such a
proposal is not currently allowed under State law, we believe it is
time that such a proposal, and the laws that preclude it, be reevaluated. This system is used extensively in Europe where it
saves energy and money by eliminated the transport costs of
As noted in SCOPE’s comment, the re-piping of individual
homes to supply landscape water from gray water uses is not
currently allowed under State law. Consequently, CLWA has
no authority to encourage such activities. The re-use of
domestic gray water is outside of the scope of the RWMP.
30
Commenter
Comment
No.
Comment
Response
recycled water, substituting the recycled water for potable water
and changing the landscape habitats of residents to accommodate
the recycled water in their gardens. It also eliminates most of the
health concerns that occur when large quantities of recycled
water are used for any large public purpose because the local
environment has a chance to absorb and decompose and
chemicals or bacteria found in the gray water through absorption
by the landscape plantings.
SCOPE
43
We request that such an option be listed in the alternatives
section of this document and that this idea be introduced to the
watershed council that is currently being formed.
As stated in Section 7.1 (p. 7-1), CEQA Guidelines (Section
15126) require that a Draft PEIR describe a reasonable range of
feasible alternatives to the project or project location that could
feasibly attain most of the basic project objectives and would
avoid or substantially lessen any significant environmental
impacts of the proposed project. The re-use of domestic gray
water in residential homes is currently not allowed under State
law and therefore does not meet the definition of an
appropriate or feasible alternative to the RWMP pursuant to
CEQA.
Sierra
44
The Sierra Club, Angeles Chapter has not received a copy of
Draft PEIR for the recycled water project. Normally we receive
these documents, and would like to review the document for
comments.
A copy of the Draft PEIR was delivered to Sierra Club, Angeles
Chapter at 3435 Wilshire Blvd, Suite 320, Los Angeles, CA
90010 on November 13, 2006.
Sierra
45
Sierra Club supports recycled water for some uses, specifically
landscaping and industrial uses (cooling towers, etc.). But there
has been considerable controversy and discussion over the health
and water quality issues involved in pumping recycled water
into a ground water basin as described in your "Aquifer Storage
and Recovery Program". We therefore recommend that any such
project be covered by a separate review process.
31
Commenter
Comment
No.
Comment
Response
that these studies conclude that the ASR facility would not have
the potential to impact groundwater supplies that are
designated as a potential source of domestic water supply. As
stated in Section 1.3 (p. 1-3 and 1-4), if activities that implement
the RWMP are found to have impacts beyond what was
analyzed in the Draft PEIR, then additional CEQA compliance
would be required. Additional CEQA compliance, if required,
would allow for, at a minimum, additional public review of
relevant technical analyses. No changes to the PEIR are
required.
Sierra
46
We are also concerned about statements made in this document
that would seem to indicate that specific site facilities would
receive environmental review through an amendment of the
Natural River Management Plan (NRMP). We believe this
process would not satisfy the required CEQA review and such
uses of the NRMP were not contemplated when that plan was
approved. Such an amendment process may be viewed as an
abuse Federal review process. We therefore request to receive
notification of all plans to site facilities within the NRMP along
with any applications for amendments to the plan.
The Draft PEIR does not state that the implementation of the
RWMP would amend the NRMP. As discussed in Section 3.4.2
(p.3.4-27), construction of some of the proposed RWMP
components may result in impact to jurisdictional resources
within the NRMP area. Within these areas, the necessary
permits from the USACE and CDFG may be processed in
accordance with the NRMP or through application for separate
permits from these agencies. If the NRMP permits are utilized,
the conditions of the permit, as described in the Plan, would be
adhered to. This includes all requirements as they pertain to
public notification. If there are RWMP components that impact
jurisdictional waters are not able to be processed under the
NRMP, a separate USACE permit would be required.
Sierra
47
Recycled water is currently an important source of in stream flow
in the area immediately below the Saugus treatment plant. Any
proposed diversion from this area must meet the requirements of
the Endangered Species Act. This impact and the related
permitting requirements do not seem to be covered in the EIR.
The RWMP does not propose to use the Saugus WRP as a
source of recycled water. Therefore, the effluent flow between
the Saugus and the Valencia WRPs would not be affected by
the RWMP. The analysis in the Draft PEIR in Section 2.5,
Recycled Water Supply (p. 2-7 through 2-9) states that the
proposed RMWP would not reduce effluent levels below the
18.4 mgd that have been the annual average for the years 2001-
32
Commenter
Comment
No.
Comment
Response
2005. The most recent average effluent levels available at the
time of the issuance of the NOP was used for the purposes of
the Draft PEIR, which serves as the “existing condition”
benchmark for the purposes of CEQA.
Therefore, the
implementation of the RWMP would not impact the current
hydrology or biological resources of the Santa Clara River;
therefore, there would be no impacts or permitting
requirements related to the Endangered Species Act as it relates
to the diversion of flows from the Valencia WRP or other
sources of recycled water.
SCGC
48
SCG recommends that the Final EIR include a discussion of
activities associated with the extension of new recycled water
service that might have an affect on existing natural gas facilities.
At present, there is no mention of any potential to relocate
existing facilities. This additional discussion should include:
• Identification of any existing natural gas infrastructure that
would need to be relocated and/or abandoned in order to allow
for the construction of the new recycled water service.
• Identification and description of any temporary areas required
for construction and/or staging of material related to natural gas
service relocation or construction.
• Identification of any actions that would require permitting or
acquisition of new right-or-way or easements for natural gas
services.
• Any proposed grading and/or drainage improvements that
would redirect drainage in a manner that would increase the
potential for erosion around SCG facilities.
The Final EIR should also recognize that a discussion of these
issues may help to reduce the time and cost associated with the
33
The implementation of the RWMP is not anticipated to have
any impact on the location, construction, operation, or
provision of natural gas or associated infrastructure. Per
CLWA standard protocol, any unforeseen impacts to natural
gas facilities would be coordinated with SCG. As discussed in
Section 3.8.2 (p. 3.8-25 through 3.8-26), compliance with
Regulatory Requirement 3.8-1, which requires compliance with
the NPDES General Permit for Construction Activities, would
ensure that no component of the RWMP would result in
impacts to drainage patterns that could result in erosion or
siltation.
Commenter
Comment
No.
Comment
Response
relocation of natural gas services.
SCGC
49
In addition, if any field monitoring for cultural or biological
resources is required during construction of the natural gas
facilities, the monitoring should be mentioned in the Final EIR as
a requirement and responsibility of the Castaic Lake Water
Agency. Likewise, any environmental mitigation required for the
potential impacts associated with the construction of gas service
should also be addressed as part of the responsibility of the
Castaic Lake Water Agency.
The implementation of the RWMP would not require the
construction of any natural gas facilities. Therefore, there
would be no field monitoring for cultural or biological
resources applicable to the construction of natural gas facilities.
UWCD
50
United Water was initially concerned how the proposed increase
in reuse of water from Water Reclamation Plants (WRPs) might
influence Santa Clara River flow near the Los Angeles
County/Ventura County line. While the Santa Clarita area has
grown substantially since the 1970s, in response to the build-up
of SWP water deliveries to the area, there has been a
corresponding, albeit less dramatic, increased growth in down
stream basins within Ventura County. The perennial Santa Clara
River flow created near the County-line, because of upstream
WRPs discharges, has become an integral portion of the water
supply for the basins within Ventura County. United Water and
landowners within Ventura County acknowledge the importance
of the flow across the County line and have a vested interest in
the continuance of the established flow. Review of Section 3.8 of
the Draft PEIR for the RWMP has essentially resolved United
Water's initial concern with respect to impacts to flow at the
County line.
Comment noted.
UWCD
51
The analyses presented in Section 3.8, page 23 shows that even
with a ten-fold increase in the recycling of water within the Santa
Clarita Valley there will still be increased (18.6 MGD) discharge
to the Santa Clara River by 2030, as compared to the discharge
during the base period 2001 through 2005 (18.1 MGD). The
analysis in Section 3.8 is premised on projected discharge to the
CLWA will continue to coordinate with other water agencies
within Los Angeles County, the Sanitation Clarita Valley
Sanitation District and the United Water Conservation District
regarding annual discharges into the Santa Clara River.
34
Commenter
Comment
No.
Comment
Response
river and projected recycled water by 2030. From Ventura
County's perspective it is important that the actual amounts of
recycled water and discharges to the river be well monitored, in
the event that future amounts are significantly different than
those projected in the Draft PEIR. Because the water purveyors
within Los Angeles County and United Water have developed a
good working relationship now and into the foreseeable future,
the annual discharges to the river and recycled water will be
closely monitored, by all parties, along with other groundwater
and surface hydrologic data.
Dunn
52
Santa Clarita's Central Park should be the first user of recycled
water. The purple pipes were installed years ago as required by
Castaic Lake Water Agency.
Central Park is designated as a future user of recycled water in
the RWMP. However, there are numerous other identified
users of recycled water between the sources of recycled water
and Central Park along the paths of pipelines. As the RWMP is
built out, these recycled water users would be supplied as
recycled water becomes available prior to its being available to
Central Park. Central Park would receive recycled water well
before the completion of the RWMP, but it would not be the
first recipient.
Dunn
53
Newhall Ranch is not developed and therefore no water
customers have contributed to this water source. The present
population has purchased, produced, and paid for the recycled
water through the water rates, the sewer fees, and the connection
fees. This is an inequity of huge proportions that the public
should not accept. We oppose any plan that suggests that
Newhall Ranch should receive any of this water.
The CLWA RWMP is to be implemented in phases with the
earliest phases generally located closest to the sources of
recycled water. These phases are planned to coincide with
existing demand and future development with considerations
for the cost-effectiveness of the timing of recycled water
infrastructure expansions. The proposed RWMP infrastructure
spans across the majority of the CLWA service area and is not
preferential to one area over others.
The funding mechanisms for the implementation of the RWMP
will be through various sources, including capital reserves,
grants, low interest loans, and certificates of participation, as
described in Section 12 of the 2002 Draft Report RWMP.
35
Commenter
Dunn
Joan Dunn,
December
13, 2006,
Comment
No.
54
55
Comment
Response
The plan shows that Canyon Country is one of the last areas to be
considered for recycled water. This is wrong. We believe CLWA's
intention is to state in the future there will be no recycled water
left for the late planned areas (the producers of the recycled
water) like Canyon Country. Equitable quantities should be set
aside, in this plan now, for the producers of recycled water.
As discussed in Section 13.2.1 of the 2002 Draft Report RWMP,
RWMP phasing includes a breakdown of anticipated annual
demand for each phase of development. Future recipients of
recycled water in Canyon County will receive their allocated
amount when nearby phases of the RWMP are implemented.
The RWMP system has been sized to accommodate the delivery
of approximately 17,400 AF/yr, which is based on projected
demand. Although the phasing of RWMP implementation as
well as the projected users may be adjusted over time to
account for changes in development plans, as stated in Section
1.2 (p. 1-1 and 1-2), the objectives of the RWMP are as follows:
Yes, I really would like to see another plant on the east side of
town. I know years ago Jan Heidt had mentioned that in a
meeting when she was on the Board of the Sanitation District.
36
•
To satisfy the legislative mandates, as set forth in the
Water Recycling Act of 1991, which encourage the
production and use of recycled water through the
established statewide goal of recycling a total of 700,000
af/yr of water by the year 2000 and 1,000,000 af/yr by
the year 2010.
•
To conserve potable water supplies by making recycled
water available for various non-potable uses, including
irrigation, industrial processes, and recreational
enhancement, where feasible and appropriate.
•
To develop a cost-effective system for the delivery of
recycled water.
•
To create a recycled water system that can produce
enough water to meet the recycled water demands of
its existing and future customers.
The RWMP is a long-term plan for the use of recycled water
within the Santa Clarita Valley. The determination as to the
location of Water Reclamation Plants is under the jurisdiction of
Commenter
Comment
No.
Public
Hearing
Comment
Ed Dunn,
December
13, 2006,
Public
Hearing
Comment
56
Comment
Response
And I think that we still should get that on the east side.
the Santa Clarita Valley Sanitation District and not the CLWA.
Also, I think that I would like to suggest that you take the
chlorides out before they are distributed in the water when you
go to send the water out through your system. It would probably
be a much better way to take care of the chloride problem. And I
think that you really should take that into consideration.
Removal of chlorides is currently underway and will continue
as the sources of recycled water attempt to meet the water
quality objective for chloride in the Santa Clara River.
As I have mentioned before in the past, the Recycled Water Plan
that you have seems to be very lopsided. In fact, at present the
recycled water that is produced by the residents of the City of
Santa Clarita is going outside the city, the people that have not
contributed to the recycled water plant. The recycled water is
water purchased by the homeowners on the east side and
throughout Canyon Country and city proper, and they pay to
process that water. And the water is then used for the benefit of
a private company.
The RWMP has identified potential users of recycled water
based on need and on the feasibility of supplying the water
given the constraints of the location of the supply of recycled
water and other engineering factors. Though some areas are
more likely to receive recycled water, the entire CLWA service
are will benefit due to the greater availability of potable water
that the use of recycled water will permit. To pump recycled
water from its limited source locations to all areas of the service
area would greatly increase its cost and decrease its benefits
relative to potable water.
And as we see pipes coming into this area, it looks like it will
continue to be to the benefit of the same private corporation. I
think there needs to be an equitable balance in the use of the
recycled water. We know that the price of potable water is going
to continue to rise, and the price will become higher and higher,
yet the stability for the recycled water, because it’s going to cost
for processing it. And the same people who are purchasing the
potable water, sending it to the plants for processing, are paying
for the processing of that water, that’s going to the benefit of the
private corporation.
I think that the recycled water – oh, and also the same people
that’s producing the water are also the areas are paying
connection fees for it. There’s no benefit from that at all. I
believe that – I know there’s one mistake made by the attorney
tonight, but unknowing to him that the Castaic Lake Water
37
The CLWA is the lead agency for the RWMP EIR since the
RWMP was prepared by CLWA and CLWA would be
responsible for the construction of the facilities in the RWMP.
Additionally, the entire current backbone infrastructure for
recycled water within CLWA’s service area is owned and
operated by CLWA and it is this same infrastructure that will
be incorporated into the RWMP facilities.
As noted in the answer to comment 55 above, the ability to
determine the location of Water Reclamation Plants is not
within the jurisdiction of the CLWA. CLWA must use the
sources of recycled water that exist or are likely to exist in the
future and cannot compel the creation of new sources of
recycled water in planning for the supply of recycled water.
As noted earlier in this response, the design of the facilities in
Commenter
Comment
No.
Comment
Response
Agency was not the lead agency for recycled water. The Newhall
County Water District is the lead agency per a resolution adopted
in the late ‘90s when the Newhall County Water District was
getting involved with recycled water, and some of it was the plan
for that east side plant.
the RWMP is based on a number of factors including the
sources of recycled water. In addition, the delivery of recycled
water to one portion of the CLWA service area would have
benefits to the entire service area by making more potable
water available.
The east side plant is needed because as the growth goes on in
this community, they can’t keep pushing the sewage water,
sanitation water to the same pipe. In fact the Sanitation District
out in the Pinetree area, the Los Angeles County Sanitation
District is using a Newhall County Water District sewer pipe and
paying nothing for it. So, again, the Newhall County Water
District is paying additional costs for all of this that’s going on.
All of this should be thought out, and there should be a more
equitable distribution of the water, the recycled water in this
valley. It shouldn’t be a case of just pandering to the private
corporation continually to give them the benefits of this resource
of water.
38
4.0 CHANGES TO THE DRAFT PEIR TEXT
1
2
Executive Summary
3
The following text from the Draft PEIR page ES-1, lines 25 and 26 should be deleted:
4
5
6
7
8
9
10
11
12
13
14
15
16
The main source of recycled water would be the Valencia Water Reclamation Plant
(WRP), which is owned and operated by the Los Angeles County Sanitation Districts.
The above text should be replaced with the following:
The main source of recycled water would be the Valencia Water Reclamation Plant
(WRP), which is owned and operated by the Santa Clarita Valley Sanitation Districts
(SCVSD).
The following text from the Draft PEIR page ES-18, in the “Level of Significance After
Mitigation” column should be deleted:
Significant unavoidable adverse impacts to wastewater treatment and landfill capacity,
unless additional capacity is constructed and approved.
Significant unavoidable adverse growth-related impacts to wastewater treatment and
landfill capacity, unless additional capacity is constructed and approved.
17
18
The following text from the Draft PEIR page ES-18, in the “Potential Impacts” column should be
deleted:
19
20
21
22
Indirect Impact: There is a potential increase in wastewater generation and demand for
wastewater treatment; and a potential need for new stormwater drainage facilities or the
expansion of existing facilities. There is also potential for increased demand for solid
disposal services and increased need for potable water treatment.
23
24
25
26
27
28
Indirect Impact: There is a potential increase in wastewater generation and demand for
wastewater treatment and a potential need for new stormwater drainage facilities or the
expansion of existing facilities due to growth-related impacts. There is also potential for
increased demand for solid disposal services and increased need for potable water
treatment due to growth-related impacts.
29
Project Description
30
The following text from the Draft PEIR page 2-2, lines 3 through 5 should be deleted:
31
32
33
34
The Sanitation Districts of Los Angeles County (LACSD) own and operate two water
reclamation plants (WRPs), the Saugus WRP and Valencia WRP, within the CLWA
service area.
39
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
The Santa Clarita Valley Sanitation District (SCVSD) own and operate two water
reclamation plants (WRPs), the Saugus WRP and Valencia WRP, within the CLWA
service area.
On July 24, 1996, the CLWA executed an agreement with the LACSD to purchase up to
1,700 af/yr of recycled water from the Valencia WRP.
On July 24, 1996, the CLWA executed an agreement with the SCVSD to purchase up to
1,700 af/yr of recycled water from the Valencia WRP.
The following text from the Draft PEIR page 2-7, lines 39 and 40 should be deleted:
The Valencia WRP is one of eleven publicly owned treatment works (POTWs) that are
owned and operated by the LACSD, and it is located within District No. 32 on The Old
Road near SFMM.
The Valencia WRP is one of eleven publicly owned treatment works (POTWs) that is
owned and operated by the SCVSD, and it is on The Old Road near SFMM.
According to the 2015 Joint Sewage Facility Plan, the Phase II expansion of the Valencia
WRP is expected to be constructed and operational in 2010 and would involve an
additional increase of 6 mgd, which would result in a capacity of 27.6 mgd.
According to the 2015 Santa Clarita Joint Sewerage System Facility Plan and
Environmental Impact Report, the Phase II expansion of the Valencia WRP is expected
to be constructed and operational in 2010 and would involve an additional increase of 6
mgd, which would result in a capacity of 27.6 mgd
The following text from the Draft PEIR page 2-9, Lines 39 and 40 should be deleted:
The plant will be constructed in stages, with an ultimate capacity of 7.7 mgd.
The plant will be constructed in stages, with an ultimate capacity of 6.8 mgd.
30
31
32
The second phase of the RWMP (Phase 1B) includes the construction of the Northwest
Spur Pipeline.
40
1
2
3
The third phase of the RWMP (Phase 3) includes the construction of the Northwest Spur
Pipeline.
4
Biological Resources
5
The following text from the Draft PEIR page 3.4-23, lines 32 through 34 should be deleted:
6
7
8
9
10
11
12
Saugus WRP discharged an annual average of 13.7 mgd (15,348 af/yr) and 4.7 mgd
(5,265 af/yr), respectively, of effluent to the Santa Clara River, for a combined effluent
discharge of 18.4 mgd (20,614 af/yr).
The Valencia and Saugus WRPs discharged an annual average of 13.7 mgd (15,348
af/yr) and 4.7 mgd (5,265 af/yr), respectively, of effluent to the Santa Clara River, for a
combined effluent discharge of 18.4 mgd (20,614 af/yr).
13
Hydrology and Water Quality
14
15
16
17
18
19
20
21
22
23
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The Valencia WRP is one of eleven publicly owned treatment works (POTWs) owned
and operated by LACSD.
The Valencia WRP is a publicly owned treatment works (POTW) that is owned and
operated by the Santa Clarita Valley Sanitation District (SCVSD).
LACSD discharges tertiary-treated wastewater from its Valencia WRP under the waste
discharge requirements contained in Order No. R4-2003-0145, which was adopted by the
RWQCB on November 11, 2003.
SCVSD discharges tertiary-treated wastewater from its Valencia WRP under the waste
discharge requirements contained in Order No. R4-2003-0145, which was adopted by the
RWQCB on November 11, 2003.
Details regarding the LACSD laboratories, quality assurance activities, wastewater
monitoring data methodology, permit limits, performance goals, and long-term
wastewater monitoring summaries are included in the LACSD’s Annual Monitoring
Reports.
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Details regarding the SCVSD laboratories, quality assurance activities, wastewater
monitoring data methodology, permit limits, performance goals, and long-term
wastewater monitoring summaries are included in the SCVSD’s Annual Monitoring
Reports.
As shown in Table 3.8-2 above, the Valencia WRP has exceeded the limitation
requirements for cyanide at least once in the years 2002, 2003, and 2004. As described in
the Annual Monitoring Report for 2004, the LACSD has expressed concerns to the
RWQCB that the measured cyanide concentrations may be impacted by interferences
associated with the analytical technique. Additionally, because cyanide is currently
believed to be a chlorination byproduct, the LACSD is investigating ultraviolet (UV)
radiation as an alternative means of disinfection. Additional studies are also being
conducted to determine formation and destruction of cyanide in the treatment process.
As shown in Table 3.8-2 above, the Valencia WRP had apparently exceeded the effluent
limitation requirements for cyanide at least once in the years 2002, 2003, and 2004. As a
result of these exceedances, as well as cyanide exceedances at other WRPs owned and
operated by LACSD, extensive research on cyanide was performed and it was
determined that the apparent historical cyanide exceedances were not actual
exceedances but rather artifacts of the preservation method used in the collection of
cyanide samples taken in the field. Standard Methods recommends that cyanide samples
be analyzed within fifteen minutes, and if not possible, then preserved for later analysis
by raising the pH of the samples. Because the SCVSD has not historically had the
laboratory infrastructure at the Valencia WRP to analyze cyanide samples within fifteen
minutes, the historical practice was to preserve these samples via pH adjustment.
Further research has revealed that this preservation step causes positive interferences in
the cyanide test. When the samples were analyzed immediately without preservation, as
is recommended in Standard Methods, no exceedances of cyanide effluent limitations
were found at the Valencia WRP. In December 2005, the Valencia WRP treatment plant
laboratory was ELAP certified in order to immediately measure cyanide after sample
collection. There have been no exceedances of cyanide effluent limitations at the
Valencia WRP since 2005."
During 2004, a total of 136 MG (417.4 af) of recycled water was used to irrigate the 96acre golf course in the Westridge development. There were no violations of the water
reclamation requirements during 2004 (LACSD 2004a).
According to the SCVSD’s records, in 2004 and 2005, a total of 136 MG and 137 MG of
recycled water (respectively) was used to irrigate the 96-acre golf course in the
Westridge development. There were no violations of the water reclamation
requirements during 2004 (LACSD 2004a).
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The following text from the Draft PEIR page 3.8-9, lines 12 and 13 should be deleted:
Additionally, the Santa Clara River receives treated wastewater discharges from the
Saugus and Valencia WRPs, which are owned and operated by the LACSD.
Additionally, the Santa Clara River receives treated wastewater discharges from the
Saugus and Valencia WRPs, which are owned and operated by the SCVSD.
Based on available data provided by the County of Los Angeles Department of Public
Works, LACSD and USGS, combined effluent flows from both treatment facilities
contribute more than 90 percent of the total river flow from August through September.
Based on available data provided by the County of Los Angeles Department of Public
Works, SCVSD and USGS, combined effluent flows from both treatment facilities
contribute more than 90 percent of the total river flow from August through September.
According to the LACSD, effluent from the Valencia WRP does not meet the standard
for disinfection of tertiary recycled water for unrestricted access uses (refer to Section
60304 [a] of Title 22), as stated in Section 60301 of Title 22 of the California Code of
Regulations.
According to the SCVSD, effluent from the Valencia WRP does not meet the standard for
disinfection of tertiary recycled water for unrestricted access uses (refer to Section 60304
[a] of Title 22), as stated in Section 60301 of Title 22 of the California Code of Regulations.
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Utilities and Service Systems
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Two wastewater treatment facilities managed by the Los Angeles County Sanitation
Districts (LACSD) service the Santa Clarita Valley and vicinity: the Saugus Water
Reclamation Plant (WRP) and the Valencia WRP.
Two wastewater treatment facilities managed by the Santa Clarita Valley Sanitation
District (SCVSD) service the Santa Clarita Valley and vicinity: the Saugus Water
Reclamation Plant (WRP) and the Valencia WRP.
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On July 24, 1996, the CLWA executed an agreement with the Los Angeles County
Sanitation Districts (LACSD) to purchase up to 1,700 af/yr of recycled water from the
Valencia WRP.
On July 24, 1996, the CLWA executed an agreement with the Santa Clarita Valley
Sanitation District (SCVSD) to purchase up to 1,700 af/yr of recycled water from the
Valencia WRP.
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Cumulative Impacts
9
The following text from the Draft PEIR page 6-9, lines 3 through 6 should be deleted
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The existing capacity is 21.6 mgd following 3 subsequent expansions: (1) construction of
a 4.4 MG flow equalization tank in February 1995; (2) the Stage 4 expansion completed
in June 1996; (3) and the Santa Clarita Valley Joint Sewerage System (SCVJSS) Phase I
expansion of 9 mgd in 2002.
The existing capacity is 21.6 mgd following 3 subsequent expansions: (1) construction of
a 4.4 MG flow equalization tank in February 1995; (2) the Stage 4 expansion completed
in June 1996; (3) and the Santa Clarita Valley Joint Sewerage System (SCVJSS) Stage 5
expansion of 9 mgd in 2003.
To accommodate anticipated growth in the Santa Clarita Valley area and to ensure
compliance with discharge requirements form the Regional Water Quality Control
Board (RWQCB), the Los Angeles County Sanitation Districts (LACSD) have begun an
expansion of the Valencia WRP as part of the 2015 Joint Sewerage System Facilities Plan.
The Phase II expansion is expected to be completed in 2020 and involves an increase of 6
mgd. The ultimate capacity of the WRP is planned to be 27.6 mgd.
To accommodate anticipated growth in the Santa Clarita Valley area and to ensure
compliance with discharge requirements from the Regional Water Quality Control
Board (RWQCB), the Santa Clarita Valley Sanitation District (SCVSD) has plans to
expand the capacity of the Valencia WRP, as discussed in the District's 2015 SCVJSS
Facilities Plan and EIR. The Stage VI expansion will increase the capacity of the Valencia
WRP by another 6 mgd, for a total capacity of 27.6 mgd.
It would likely be built in stages, as the Specific Plan is developed, and would ultimately
be sized to treat up to 7.7 mgd.
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It would likely be built in stages, as the Specific Plan is developed, and would ultimately
be sized to treat up to 6.8 mgd.
45

Castaic Lake Water Agency

Transcription

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