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HomeMy WebLinkAbout14 - OCSD Draft EIR on Newport Trunk Sewer & Force Main ReplacementCITY OF NEWPORT BEACH CITY COUNCIL STAFF REPORT Agenda Item No. 14 January 11, 2005 TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL FROM: City Manager's Office Sharon Wood, Assistant City Manager 644 -3222, swood @city.newport- beach.ca.us SUBJECT: Comments on Orange County Sanitation District Draft EIR on Newport Trunk Sewer and Force Main Replacement RECOMMENDATION: Approve and authorize the Mayor to send comments on the Draft Environmental Impact Report (DEIR). DISCUSSION: The Orange County Sanitation District (OCSD) proposes to replace its existing Newport Trunk Sewer and force main system. This system runs from the Bitter Point Pump Station, located at the entrance of the West Newport oilfield on Coast Highway, to OCSD's plant in Huntington Beach. The DEIR prepared for the project studies seven alignments, which follow either of two basic routes: along PCH, or through the Santa Ana River Marsh and West Newport oilfield. OCSD's preferred alternative follows the latter route, minimizing disruption to residents and businesses along the Coast Highway corridor. This route, however, has greater impacts on coastal wetlands within the marsh. Comments on this DEIR were due to OCSD on January 3. Due to the meeting schedules for our Environmental Quality Affairs Committee (EQAC) and City Council, OCSD staff agreed to accept Newport Beach's comments on January 12. EQAC is considering DEIR comments at their meeting of January 10. Draft comments prepared by the EQAC subcommittee are attached for the City Council's information. Staff will provide the comments approved by the full Committee, and a recommended comment letter, at the Council meeting. Submitted by: Sharon Wood Assistant City Manager Attachments: Draft EQAC Comments MEMORANDUM DRAFT To: Mayor Steve Bromberg and Members of the City Council City of Newport Beach Cc: Homer Bludau, City Manager From: Orange County Sanitation District Subcommittee ( "EQAC ") City of Newport Beach Subject: Orange County Sanitation District Draft Environmental Impact Report for the Newport Trunk Sewer and Force Mains Replacement Project (the Project) Date: January 5, 2005 Thank you for the opportunity to provide these comments on the Drafl Environmental Impact Report ( "DE1R ") for the above - captioned Project prepared by the Orange County Sanitation District ( "District "). EQAC's comments are as follows: Chapter I Introduction As discussed below, the proposed Project is the replacement of the existing Newport Trunk Sewer and force mains with a new force main system from the Bitter Point Pump station, located at the entrance of the West Newport oilfield on Pacific Coast Highway ( "PCH ") in the City of Newport Beach, to the District's Treatment Plant No. 2, located in the City of Huntington Beach. Chapter 2 Project Description This chapter discusses alternate routes for the proposed Project — one along PCH and the other through the Santa Ana River ( "SAR ") Marsh and the West Newport Oil Field. Seven (7) alignments were studied, with the District's preferred alternative being Alternative 2C, which runs through SAR Marsh and West Newport Oil Field. The District's preferred alternative almost entirely eliminates disruption to residents and businesses along the PCH corridor during the construction of the proposed Project, and also assures that future maintenance and repair work will have minimum impact on residents and businesses in West Newport. However, Alternative 2C could have significant impacts on the coastal wetlands within the SAR Marsh. While some members of EQAC applaud the District for their thoroughness in the preparation of this DE1R, others felt that the extensive level of review given to so many alternatives made the document confusing and cumbersome. Because the District's preferred alternative is Alternative 2C, we recommend that the Final E1R provide a more focused, detailed review of the impacts and mitigation measures associated with Alternative 2C. Mayor Steve Bromberg Members of the City Council City of Newport Beach Page 2 January 5, 2005 "N Several issues are raised in Chapter 2 that are not addressed in the DE1R. Section 2.1.3 discusses Alternative 2C and states that "existing 8 and 10 -inch waste oil gravity lines .... would be abandoned inn place." if these abandoned lines are not sealed properly, this could pose a potentially hazardous situation. The Final EIR should provide a full discussion of the measures that will be taken to assure that the lines are properly sealed. This section (and others) also discusses "open trench" methods for installation of the new mains, but never discusses backfilling these open trenches after installation to return the area to its original appearance. The Final EIR should provide a full discussion of the measures that will be taken to assure that the areas where the new mains are installed are returned to their original appearance. Chapter 3 Environmental Setting, Impacts and Mitigation Section 3.2 Biological Resources The proposed Project is "located within the South Coast Bioregionn and, as a marine ecosystem, within the Southern California Bight." The DE1R makes note of the fact that most of the wetlands along the Southern California Bight are estuarine salt marshes, and "coastal wetlands have declined by 80 to 90 percent and those remaining are frequently degraded." The DE1R goes oil to state that the impact area for Project Alternative 2 is within a wetlands area that was restored by the U.S. Army Corps of Engineers ( "USACE ") in 1989 as mitigation for biological impacts. The restoration of 92 acres of the Marsh has been successful, and is functioning as intended for the target endangered plant communities and wildlife. Alternative 1, which is outside the SAR Marsh altogether, is the preferred Alternative of some members of EQAC for the very reason that its alignment is outside the sensitive areas of the SAR Marsh. Even though the proposed Project Alternative 2 would use the existing utility easement, which, according to the DEIR, "is assumed to be outside of the jurisdictional wetland area," members of EQAC we would like to propose that OCSD consider a wetlands enhancement program designed to provide mitigation beyond the impacts that will occur as a result of construction or operation of the pipeline. Alternative 2C appears to be the least expensive of the alternatives to build, as the route follows the existing easement, and little or no land acquisition expenditures appear to be required. Alternative 2C would allow the proposed Project to proceed without the impacts to land use and traffic that would result front the Alternative I alignment, but a wetlands enhancement program could help alleviate some of the concerts that the Alternative 2C alignment poses a risk to the fragile estuariue salt marsh. Mayor Steve Bromberg Members of the City Council City of Newport Beach Page 3 January 5, 2005 DRAFT The Final EIR should provide a detailed discussion of the measures that will be taken to prevent impacts to biological resources, as well a program for enhancement of wetlands within the SAR Marsh. Section 3.4 Geology and Soils Section 3.4.1 contains detailed descriptions of the seismology and local geology in the proposed Project area. It emphasizes that these sewer mains will be installed in an area which is seismically active (Newport- Inglewood Fault Zone) and subject to liquefaction, subsidence and landslides. Specifically, "Landslides and Spreading" defines the "cliffs at the edge of the utility road and oil field as seismic landslide hazard areas." However, there is no mention of any relevant hazards during the proposed Project construction and after completion. The Final EIR should discuss and analyze whether construction traffic and trenching along the utility road cause a risk of land slide from the cliffs adjacent to the utility road and propose necessary mitigation. Under the "California Building Code" and "General Plan" discussions (DEIR P. 3.4 -7) there are general references to UBC (Uniform Building Code), CBC (California Building Code) and city and county General Plans, but no specific references is made to what pipeline building standards will be utilized. (Note: The distinction between underground construction (i.e. pipeline) and surface construction (i.e., buildings) is never clarified. Therefore, it is not clear what construction codes and what hazards /mitigation should apply. The Final EIR should provide this clarification. Section 3.4.2, "Impacts and Mitigation" emphasizes exposure of "structures" to adverse effect due to seismic and other geological factors. The Final EIR should clarify that "structures" includes the underground portion of the proposed Project. The DEIR states that "Mitigation Measures 3.4 -1 and 7.6 -1 of the 1999 PEIR would reduce any potential landslide impacts to a less than significant level." DEIR P. 3.4 -9 However, neither of these mitigation measures discusses how to avoid /eliminate Project- induced landslides in the bluffs area during the construction of the proposed Project. The Final EIR should fully analyze the potential for Project - induced landslides and provide necessary mitigation. Impact 3.4 -3 deals with potential damage to bridge and /or channel foundations, but only discusses Alternative I near PCH under the Talbert Channel. The Final EIR should analyse possible damage to the SAR channel due to the very long tunneling associated with Alternative 2C, and any provide appropriate mitigation measures. DEIR P.3.4 — 13, 14 Table 2 -1 shows the need to remove 44,510 cubic yards of material due to Alternative 2C trenching and tunneling. Some of this material is coming from areas near old sewer mains and old oil fields and may be contaminated and in need of special handling. This should be fully addressed in the Final EIR. DEIR P. 2 -13 Mayor Steve Bromberg DRAFT Members of the City Council City of Newport Beach Page 4 January 5, 2005 Section 3.5 Hazards and Hazardous Materials Impact 3.5 -2 states that improperly abandoned oil wells may exist within the excavation for Alternative 2 alignments. The mitigation measure for this impact that prior to construction, the District will identify existing and abandoned oil wells, using the California Department of Conservation, Division of Oil, Gas and Geothermal Resources ( "DOGGR ") maps. In addition, if any unsnapped wells are uncovered during construction, the District will notify DOGGR, and the well will be abandoned following proper procedures. The Final EIR should discuss the steps that will be taken to ensure that no seepage or spillage for the wells occurs before the District advises DOGGR. Section 3.6 Hydrology and Water Quality Impact 3.6 -4 states that "the operation of the sewer could result in sewage spills." The DEIR further states that the Project is being proposed to minimize the potential for sewage spills; however, the DEIR does not provide any specific measures to that end. The Final EIR should fully discuss the measures being proposed to ensure that the existing sewer lines will not be breached or damaged during construction, creating a serious spill, particularly within the SAR Marsh. Section 3.7 Land Use and Recreation Alternative 2C traverses open space, marsh lands, and habitat conservation areas. The DEIR states the Friends of Harbors Beaches and Parks has developed plans to link currently undeveloped parcels along the south side of the SAR for use as a regional park, the Orange Coast River Park. The SAR Marsh area is planned to become a part of the park. Although the park "project is in the early stages of development and is not officially endorsed by the local cities or county," the Final EIR should provide a full analysis of the proposed Project impacts to the areas being planned for the River Park and propose necessary mitigation. Section 3.8 Noise Impact 3.8 -1 deals with construction - related noise impacts on nearby sensitive noise receptors. Since such noise receptors are farthest away from construction activities in Alignment 2C, the noise study reconfirms the choice of Alignment 2C. Mitigation measures 7.4 -1a to 7.4- I d are needed to assure mitigation to less than significant and should be strictly enforced. The DEIR states that the proposed Project would increase sewage pumping capacity from 240 to 480 million gallons per day. The Final EIR should address the issue of operational noise associated with this increase in capacity, including the increases in continuous noise due to Mayor Steve Bromberg DRAFT Members of the City Council City of Newport Beach Page 5 January 5, 2005 doubled flow rates and doubled pump capacity after Project completion. Impact 3.8 -2 deals with ground borne vibration impacts near the construction site and concludes that no mitigation measures are needed to assure less that significant impact on Alternative 2C residences. However, prolonged or intermittent vibration and /or shocking due to pile driving can have an effect on nearly slide -prone bluffs. An evaluation of this impact should be made. Section 3.10 Traffic This section addresses the impacts of the proposed Project on traffic. The DEIR states that the "(i)mplementation of Alternative I (Alignments IA, IB, and I C), would require lane Closures on PCH during construction of the proposed Project which would temporarily reduce roadway capacity." This would be highly disruptive to the community of West Newport, as well as commuters that use PCH. The only impacts on traffic for Alternative 2C would be those associated with dirt hauling operations. Mitigation Measure M- 3.10 -1 states that "(d)irt haul operations occurring during the peak summer months shall not occur during peak AM or PM periods (6:00 -9:00 AM and 3:00 -6:00 PM.)." The Final EIR should clarify "summer months" to be consistent with City of Newport Beach Department of Public Works definition, to insure a minimum of conflict with peak PCH usage. Chapter 4 Project Alternatives The District's preferred alternative is Alternative 2C: however, the text on Page 4 -10 is not complete in its discussion of this alternative. It appears that part of the text is missing. Conclusion EQAC supports the District's preferred alternative, Alternative 2C, because will have the least impacts with respect to land use and traffic issues to residents and businesses in West Newport. However, we strongly urge the District to prepare a wetlands enhancement program that will provide mitigation beyond the impacts identified in this DEIR to the SAR Marsh that would be associated with Alternative 2C. DRAFT "RECEIVED AFTER AGENDA PRINTED:" -A I `I 1-Ii -0S January 12, 2005 Mr. Jim Herberg, P.E., Engineering Manager c/o Angie Anderson Orange County Sanitation District 10844 Ellis Avenue Fountain Valley, CA 92708 VIA FACSIMILE Comments on DEIR for the Replacement of NewportTrunk Sewer and Force Mains Dear Mr. Herberg: Thank you for the opportunity to provide these comments on the Draft Environmental Impact Report (DEIR) for the above- captioned Project, as well as your courtesy in presenting the Project to the Newport Beach Environmental Quality Affairs Committee (EQAC), and allowing the City to submit comments after your deadline to allow for review by EQAC and the City Council. As you may know, EQAC reviews and prepares continents on DEIRs for the City Council's consideration. The continents in this letter are based on review of the DEIR by EQAC and City staff. and were approved by the City Council on January 11, 2005. Section 3.2 Biological Resources The proposed Project Alternative 2 would use the existing utility easement, which, according to the DEIR, "is assumed to be outside of the jurisdictional wetland area." Alternative 2C would allow the proposed Project to proceed without the impacts to land use and traffic that would result from the Alternative I alignment, but there is the possibility of impacts to the fragile estuarine salt marsh. Although the DEIR includes a number of mitigation measures to reduce these impacts, because of the significance of the wetlands, the City would like the District to consider a wetlands enhancement program designed to provide mitigation beyond the impacts that will occur as a result of construction or operation of the pipeline. Section 3.4 Geology and Soils Section 3.4.1 contains detailed descriptions of the seismology and local geology in the proposed Mr. Jim Herberg, P.E. Orange County Sanitation District Paget January 12, 2005 DRAFT Project area. It emphasizes that these sewer mains will be installed in an area which is seismically active (Newport - Inglewood Fault Zone) and subject to liquefaction, subsidence and landslides. Specifically, "Landslides and Spreading" defines the "cliffs at the edge of the utility road and oil Yield as seismic landslide hazard areas." The City urges the District to take these conditions into consideration in the final design of the pipeline, and follow recognized industry standards. Table 2 -1 shows the need to remove 44,510 cubic yards of material due to Alternative 2C trenching and tunneling. Some of this material is coming from areas near old sewer mains and old oil fields and may be contaminated and in need of special handling. This should be addressed in the Final EIR. Section 3.6 Hydrology and Water Quality Impact 3.6 -4 states that "the operation of the sewer could result in sewage spills." The DEIR further states that the Project is being proposed to minimize the potential for sewage spills; however, the DEIR does not provide any specific measures to that end. The Final EIR should discuss the measures being proposed to ensure that the existing sewer lines will not be breached or damaged during construction, creating a serious spill, particularly within the SAR Marsh. Section 3.8 Noise The DEIR states that the proposed Project would increase sewage pumping capacity from 240 to 480 million gallons per day. The Final EIR should address the issue of operational noise associated with this increase in capacity, including the increases in continuous noise due to doubled flow rates and doubled pump capacity after Project completion. Section 3.10 Traffic Mitigation Measure M -3.7 -2 regarding the rerouting of bicycle traffic on West Coast Highway is not realistic. Coast Highway is a major regional bicycle facility with hundreds of cyclists using it on peak days. Even on winter weekdays, groups of cyclists travel this road including during peak traffic periods. It is the City's experience that these cyclists will not divert to the proposed alternate route, but will occupy one of the 10' lanes, resulting in substantial traffic congestion and increased risk of collisions between vehicles and bicycles as well as between vehicles making last tninute lane changes to avoid slower moving cyclists. Mitigation Measure M- 3.10 -1 states that "(d)irt haul operations occurring during the peak summer months shall not occur during peak AM or PM periods (6:00 -9:00 AM and 3:00 -6:00 PM.)." The Final EIR should clarify "summer months" to be consistent with City of Newport Beach Department of Public Works definition, to insure a minimum of conflict with peak PCH usage. Mr. Jint Herberg, P.E. Orange County Sanitation District Page 3 January 12, 2005 Chapter 4 Project Alternatives DRAFT The District's preferred alternative is Alternative 2C; however, the text on Page 4 -10 is not complete in its discussion of this alternative. It appears that part of the text is missing. Conclusion The City of Newport Beach commends the District for the thoroughness of this DEIR, especially the analysis of a range of alternatives. The City supports the District's preferred alternative, Alternative 2C, because it will have the least impacts with respect to land use and traffic issues to residents and businesses in West Newport. However, we encourage the District to prepare a wetlands enhancement program that will provide mitigation beyond the impacts identified in this DEIR to the SAR Marsh. Thank you again for the opportunity to participate in the review of this project. If you have questions about the City's comments, please contact Assistant City Manager Sharon Wood at 949 -644 -3222. Sincerely, Steven Bromberg Mayor MEMORANDUM To: Mayor Steve Bromberg and Members of the City Council City of Newport Beach Cc: Homer Bludau, City Manager From: Orange County Sanitation District Subcommittee ("EQAC ") City of Newport Beach Subject: Orange County Sanitation District Draft Environmental Impact Report for the Newport Trunk Sewer and Force Mains Replacement Project (the AProjcct) Datc: January 5, 2005 Thank you for the opportunity to provide these comments on the Draft Enviromnental Impact Report ( "DEIR ") for the above- captioned Project prepared by the Orange County Sanitation District ( "District "). EQAC's comments are as follows: Chapter I Introduction As discussed below, the proposed Project is the replacement of the existing Newport Trunk Sewer and force mains with a new force main system from the Bitter Point Pump station, located at the entrance of the West Newport oilfield on Pacific Coast I lighway ( "PCH ") in the City of Newport Beach, to the District's Treatment Plant No. 2, located in the City of Huntington Beach. Chapter 2 Project Description This chapter discusses alternate routes for the proposed Project — one along PCH and the other through the Santa Ana River ("SAR ") Marsh and the West Newport Oil Field. Seven (7) alignments were studied, with the District's preferred alternative being Alternative 2C, which runs through SAR Marsh and West Newport Oil Field. The District's preferred alternative almost entirely eliminates disruption to residents and businesses along the PCH corridor during the construction of the proposed Project, and also assures that future maintenance and repair work will have minimum impact on residents and businesses in West Newport. However, Alternative 2C could have significant impacts on the coastal wetlands within the SAR Marsh. While some members of EQAC applaud the District for their thoroughness in the preparation of this DEIR others felt that the extensive level of review given to so many alternatives made the document confusing and cumbersome. Because the District's preferred alternative is Alternative 2C, we recommend that the Final EIR provide a more focused, detailed review of the impacts and mitigation measures associated with Alternative 2C. Several issues are raised in Chapter 2 that are not addressed in the DEIR. Section 2.1.3 Mayor Steve Bromberg Members of the City Council City of Newport Beach Page 2 January 5, 2005 discusses Alternative 2C and stales that "existing 8 and l0 -inch waste oil gravity lines .... would be abandoned in place." If these abandoned lines are not sealed properly, this could pose a potentially hazardous situation. The Final EIR should provide a hill discussion of the measures that will be taken to assure that the lines are properly sealed. This section (and others) also discusses 'open trench" methods for installation of the new mains, but never discusses backfilling these open trenches after installation to return the area to its original appearance. The Final EIR should provide a full discussion of the measures that will be taken to assure that the areas where the new mains are installed are returned to their original appearance. Chapter 3 Environmental Selling, Impacts and Mitigation Section 3.2 Biological Resources The DEIR stales that the impact area for Project Alternative 2 is within a wetlands area that was restored by the U.S. Army Corps of Engineers ( "USACE ") in 1989 as mitigation for biological impacts. The restoration of 92 acres of the Marsh has been largely successful, and is functioning as intended for the target endangered plant communities and wildlife. The proposed Project Alternative 2 would use the existing utility easement, which, according to the DEIR, "is assumed to be outside of lhejurisdiclional wetland area." As members of EQAC, we would like to propose that OCSD consider a wetlands enhancement program designed to provide mitigation beyond the impacts that will occur as a result of construction or operation of the pipeline. Alternative 2C appears to be the least expensive of the alternatives to build, as the route follows the existing easement, and little or no land acquisition expenditures appear to be required. Alternative 2C would allow the proposed Project to proceed without the impacts to land use and traffic that would result from the Alternative I alignment, but a wetlands enhancement program could help alleviate some of the concerns that the Alternative 2C alignment poses a risk to the fragile estuarine salt marsh. The Final EIR should provide a detailed discussion of the measures that will be taken to prevent impacts to biological resources, as well a program for enhancement of wetlands within the SAR Marsh. Section 3.4 Geology and Soils Section 3.4.1 contains detailed descriptions of the seismology and local geology in the proposed Project area. It emphasizes that these sewer mains will be installed in an area which is Mayor Steve Bromberg Members of the City Council City of Newport Beach Page 3 January 5, 2005 seismically active (Newport- Inglewood Fault Zone) and subject to liquefaction, subsidence and landslides. Specifically, "Landslides and Spreading' defines the "cliffs at the edge of the utility road and oil field as seismic landslide hazard areas." Under the "California Building Code' and "General Plan" discussions (DEIR P. 3.4 -7) there are general references to UBC (Uniform Building Code), CBC (California Building Code) and city and county General Plans. but no specific references is made to what pipeline building standards will be utilized. (Note: The distinction between underground construction (i.e. pipeline) and surface construction (i.e., buildings) is never clarified. Therefore. it is not clear what construction codes and what hazards /mitigation should apply. The Final FIR should provide this clarification, and pipeline construction should adhere to recognized industry standards. Section 3.4.2, "Impacts and Mitigation" emphasizes exposure of "structures" to adverse effect due to seismic and other geological factors. The Final EIR should clarify that "structures" includes the underground portion of the proposed Project. The DEIR states that "Mitigation Measures 3.4 -1 and 7.6 -1 of the 1999 PEIR would reduce any potential landslide impacts to a less than significant level." DEIR P. 3.4 -9 However, neither of these mitigation measures discusses how to avoid /eliminate Project- induced landslides in the bluffs area during the construction of the proposed Project. The Final EIR should fully analyze the potential for Project- induced landslides and provide necessary mitigation. Impact 3.4 -3 deals with potential damage to bridge and /or channel foundations, but only discusses Alternative I near PCH under the Talbert Channel. The Final EIR should analyse possible damage to the SAR channel due to the very long tunneling associated with Alternative 2C, and any provide appropriate mitigation measures. DEIR P.3.4 — 13, 14 Table 2 -1 shows the need to remove 44.510 cubic yards of material due to Alternative 2C trenching and tunneling. Some of this material is coming from areas near old sewer mains and old oil fields and may be contaminated and in need of special handling. This should be fully addressed in the Final EIR. DEIR P. 2 -13 Section 3.5 Hazards and Hazardous Materials Impact 3.5 -2 states that improperly abandoned oil wells may exist within the excavation for Alternative 2 alignments. The mitigation measure for this impact requires that prior to construction. the District will identify existing and abandoned oil wells. using the California Department of Conservation, Division of Oil, Gas and Geothermal Resources ("DOGGR ") maps. In addition, if any unmapped wells are uncovered during construction, the District will notify DOGGR, and the well will be abandoned following proper procedures. The Final EIR should discuss the steps that will be taken to ensure that no seepage or spillage for the wells occurs Mayor Steve Bromberg Members of the City Council City of Newport Beach Page 4 January 5, 2005 before the District advises DOGGR. Section 3.6 I lydrology and Water Quality Impact 3.6 -4 states that "the operation of the sewer could result in sewage spills." The DEIR further states that the Project is being proposed to minimize the potential for sewage spills; however, the DEIR does not provide any specific measures to that end. The Final EIR should fully discuss the measures being proposed to ensure that the existing sewer lines will not be breached or damaged during construction, creating a serious spill, particularly within the SAR Marsh. Section 3.7 Land Use and Recreation Alternative 2C traverses open space, marsh lands, and habitat conservation areas. The DEIR states the Friends of Harbors Beaches and Parks has developed plans to link currently undeveloped parcels along the south side of the SAR for use as a regional park, the Orange Coast River Park. Although the park "project is in the early stages of development and is not officially endorsed by the local cities or county," the proposed Project should not change conditions within the SAR Marsh to preclude the park use. Section 3.8 Noise Impact 3.8 -1 deals with construction - related noise impacts on nearby sensitive noise receptors. Since such noise receptors are farthest away from construction activities in Alignment 2C, the noise study reconfirms the choice of Alignment 2C. Mitigation measures 7.4 -1a to 7.4- I d are needed to assure mitigation to less than significant and should be strictly enforced. The DEIR states that the proposed Project would increase sewage pumping capacity from 340 to 480 million gallons per day. The Final EIR should address the issue of operational noise associated with this increase in capacity, including the increases in continuous noise due to doubled flow rates and doubled pump capacity after Project completion. Section 3.10 Traffic This section addresses the impacts of the proposed Project on traffic. The DEIR states that the `(i)mplemenlalion of Alternative I (Alignments IA, IB, and I C), would require lane closures on PCH during construction of the proposed Project which would temporarily reduce roadway capacity." This would be highly disruptive to the community of West Newport, as well as commuters that use PCH. The only impacts on traffic for Alternative 2C would be those associated with dirt hauling operations. Mayor Steve Bromberg Members of the City Council City of Newport Beach Page 5 January 5, 2005 Mitigation Measure M- 3.10 -1 states that "(d)irt haul operations occurring during the peak summer months shall not occur during peak AM or PM periods (6:00 -9:00 AM and 3:00 -6:00 PM.)." The Final EIR should clarify "summer months" to be consistent with City of Newport Beach Department of Public Works definition, to insure a minimum of conflict with peak PCH usage. Chapter 4 Project Alternatives The District's preferred alternative is Alternative 2C% however, the text on Page 4 -10 is not complete in its discussion of this alternative. It appears that part of the text is missing. Conclusion EQAC supports the District's preferred alternative, Alternative 2C, because it will have the least impacts with respect to land use and traffic issues to residents and businesses in West Newport. however, we strongly urge the District to prepare a wetlands enhancement program that will provide mitigation beyond the impacts identified in this DEIR to the SAR Marsh that would be associated with Alternative 2C.