Loading...
The URL can be used to link to this page
Your browser does not support the video tag.
Home
My WebLink
About
Reso 61-18 WRF EIR
RESOLUTION OF THE CITY COUNCIL OF THE CITY OF MORRO BAY, CALIFORNIA, CERTIFYING THE MORRO BAY WATER RECLAMATION FACILITY (WRF) FINAL ENVIRONMENTAL IMPACT REPORT, ADOPTING ENVIRONMENTAL FINDINGS OF FACT, A MITIGATION MONITORING AND REPORTING PROGRAM AND STATEMENT OF OVERRIDING CONSIDERATIONS, APPROVING THE WRF PROJECT AND DIRECTING STAFF TO PROCEED WITH OBTAINING ALL NECESSARY GOVERNMENTAL PERMITS, REAL PROPERTY INTERESTS AND FINANCING FOR THE WRF PROJECT WHEREAS, on August 8, 2016, the City issued a Notice of Preparation of an Environmental Impact Report (EIR) for a water reclamation facility to be constructed for the City of Morro Bay (Project), which provided for a 30-day project scoping period, from August 8, 2016, through September 7, 2016; WHEREAS, a public scoping meeting was held on August 8, 2016 at the Veterans Memorial Building at 209 Surf Street in Morro Bay; WHEREAS, on April 3, 2018, a Notice of Availability of the Draft EIR (SCH# 2016081027) for the Morro Bay Water Reclamation Facility (DEIR) was posted with the Clerk -Recorder for the County of San Luis Obispo. It was also circulated to federal, state and local agencies and interested parties requesting a copy. Copies of the Draft EIR were also made available to the public at the following locations: • City of Morro Bay WRF Web Site (http://morrobaywrf.com) • Morro Bay Public Library (625 Harbor Street, Morro Bay) • Cayucos Public Library (310 B Street, Cayucos) • Morro Bay Public Services Department (955 Shasta Avenue, Morro Bay) • Wastewater Treatment office (160 Atascadero Road, Morro Bay); WHEREAS, from April 3, 2018 through May 18, 2018, the DEIR, which analyzed the significant adverse environmental impacts that may result from the proposed Water Reclamation Facility (WRF); WHEREAS, during that period, the City held one CEQA public meeting to provide interested persons with an opportunity to comment orally or in writing on the Draft EIR and the proposed project. That public meeting was an item on the agenda at the Water Reclamation Facility Citizens Advisory Committee (WRFCAC) meeting held at the Veterans Memorial Hall in Morro Bay on May 1, 2018; WHEREAS, on June 25, 20187 (i) the responses to public agencies', private organizations' and individuals' comments on the Draft EIR were provided to those who filed written comments on the DEIR with the City and (ii) a Final EIR for the Morro Bay Water Reclamation Facility (SCH# 2016081027) (FEIR), which incorporates the DEIR and responses to written comments on the DEIR, was completed and released for public review; 01181.0001/495733.1 WHEREAS, on July 3, 2018, the City's Planning Commission and WRFCAC reviewed the FEIR and recommended the City Council certify it as being in compliance with the California Environmental Quality Act (California Public Resources Code, section 21000 et seq. and State CEQA Guidelines (14 California Code Regulations, section 15000 et seq.) (collectively, CEQA); WHEREAS, on August 14, 2018, the City Council held a duly noticed public meeting to consider the written and oral staff report, public testimony on the FEIR and the Project, and whether the FEIR should be certified and whether the Project should be approved; WHEREAS, the written staff report regarding the FEIR and the Project are found to be true and accurate in all respects and is incorporated herein by this reference; WHEREAS, prior to the final consideration and any possible approval of any and all physical aspects of the proposed Project, as analyzed by the FEIR, the City Council and all City legislative bodies involved with the proposed Project will consider the FOR and the City Council recommends all other governmental agencies and legislative bodies that must review or approve, if at all, the proposed Project do the same; and WHEREAS, the City Council has completed review of the FEIR and related materials. NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Morro Bay, California, as follows: SECTION 1: The foregoing recitals are true and correct and incorporated herein. SECTION 2: Based on substantial evidence, both written and oral, from the public meeting and in the record of proceedings, and the City Council's independent judgment, the City Council makes the following findings and takes the following actions with respect to the FEIR: A. The City Council has independently reviewed and considered the FEIR, including the comments received on the FEIR during the public review, and the responses to those comments. B. The FEIR reflects the City's and the City Council's independent judgment and is found and determined to have been completed in compliance with CEQA, and is adequate for the proposed Project. C. The FEIR is found and determined to have demonstrated, with implementation of the mitigation measures described in the FEIR, the proposed Project, if approved by the City Council and all other required governmental agencies and legislative bodies, will have no significant effect on the environment, except as discussed in Section 2. F., below. 01181.0001/495733.1 • • • . age 3 of ;' D. The FEIR is found and determined to have satisfied the requirements of CEQA and a Mitigation Monitoring and Reporting Program (MMRP) has been prepared to ensure effective implementation and enforcement of all adopted mitigation measures for the proposed Project. E. The MMRP for the proposed Project is hereby adopted, in order to mitigate or avoid significant effects on the environment, and further, the City Council: 1. commits the MMRP will be included, as conditions of approval, expressly or by reference, for all approvals, if any, of the proposed Project by the Morro Bay City Council, Planning Commission and other City legislative bodies and staff and 2. recommends all other governmental agencies and legislative bodies that must review, approve, or issue permits for, the proposed Project do so as well. F. As analyzed and determined in the FEIR, construction of conveyance pipelines and indirect potable reuse injection and monitoring wells, which are part of the proposed Project, would result in significant and unavoidable impacts to historic and archaeological resources and human remains that would not be reduced to less than significant levels even with mitigation. Based on that analysis, as required by CEQA section 15093, a statement of overriding considerations (SOC) has been prepared. SECTION 3: The documents and other materials that constitute the record of proceedings upon which adoption of this Resolution is based, are in the custody of the City of Morro Bay, Community Development Department, Planning Division, 955 Shasta Avenue, Morro Bay, CA 93442. The custodian of those documents is Scot Graham, Community Development Director, SECTION 4: Based upon all the foregoing, 4.4. o CEQA, the City Council adopts A. the CEQA Findings of Fact, attached hereto as Exhibit A and incorporated herein by this reference, B. the MMRP, attached hereto as Exhibit B and incorporated herein by this reference, and C. the SOC, attached hereto as Exhibit C and incorporated herein by this reference. SECTION 5: Based upon all the foregoing, the City Council hereby certifies the FEIR. SECTION 6: Based upon all the Project and directs staff to pursue property interests, financing, design, t foregoing, the City Council hereby approves the obtaining all necessary governmental permits, real c SECTION 7: This resolution will become [li[F�i�IZ1IlIILL�XI 7e�1 RESOLUTION NO. 61-18 Page 4 of 4 PASSED AND ADOPTED by the City Council of the City of Morro Bay at a special meeting thereof held on the 14th day of August, 2018 on the following vote: AYES: Irons, Davis, Headding, Makowetski, McPherson NOES: None ABSENT: None Jamie L. Irons! Mayor ATTEST �� ana Swanson, City Clerk Attachments: Exhibit A —Findings of Fact Exhibit B —Mitigation Monitoring and Reporting Program Exhibit C —Statement of Overriding Considerations 01181.0001/495733.1 • Resolution No. 61-18 Page Acronyms.................................................................................................................................. 2 1.0 CEQA Requirements for Findings of Fact.......................................................................... 4 2.0 Record of Proceedings....................................................................................................... 6 3.0 Description of the Project.................................................................................................... 7 3.1 Background and Need for Project........................................................................... 7 3.2 Project Objectives.................................................................................................... 9 3.3 Project Location..................................................................................................... 10 3.4 Project Components........................................................................................:..... 10 4.0 CEQA Environmental Review,.. ... 12 4.1 Environmental Review Process............................................................................. 13 5.0 Findings of Fact Regarding Project Impacts..,...,.""", ....... W ....... 15 5.1 Findings Regarding No Impacts............................................................................ 15 5.2 Findings Regarding Class IV Impacts, Beneficial .................................................. 17 5.3 Findings Regarding Class III Impacts, Not Significant .......................................... 17 5A Findings Regarding Class II Impacts, Significant but Mitigable ............................ 23 5.5 Findings Regarding Class I Impacts, Significant and Unavoidable ....................... 56 6.0 Findings Regarding Alternatives to the Project................................................................ 66 6.1 Alternative 1: No Project Alternative...................................................................... 66 6.2 Alternative 2: Pipeline Alignment Alternative,,,, 67 6.3 Alternative 3: WRF Design Alternative.................................................................. 67 6.4 Alternatives Rejected from Further Consideration ................................................ 69 6.5 Summary of Alternative Analysis. ... 110,01,101,111, ............... 699 01181.0001 /495768.1 Page 1 of �o Acronyms ADI Area of Direct Impact AFY acre-feet per year ARB Air Resources Board ARMR Archaeological Resource Management Reports AWTF advanced water treatment facility BACT best available control technology BOD biological oxygen demand CBC California Building Code CCC California Coastal Commission CCR California Code of Regulations CCRWQCB Central Coast Regional Water Quality Control Board CDFW California Department of Fish and Wildlife CDP Coastal Development Permit CEQA California Environmental Quality Act CFR Code of Federal Regulations CLUP Coastal Land Use Plan CIVIC California Men's Colony CNG compressed natural gas CRLF California red -legged frog CRMMP Cultural Resources Monitoring and Mitigation Program CRPR California Rare Plant Register CSD Cayucos Sanitary District DEIR Draft Environmental Impact Report DPM diesel particulate matter EIR Environmental Impact Report ESHA environmentally sensitive habitat area FGC California Fish and Game Code FMP Facility Master Plan GHG Greenhouse Gas Emissions HDD horizontal directional drilling IPR indirect potable reuse LACM Natural History Museum of Los Angeles County LCP Local Coastal Plan LESA Land Evaluation & Site Assessment Model LNG liquefied natural gas MBMC Morro Bay Municipal Code MBR membrane bioreactor MBTA Migratory Bird Treaty Act MGD million gallons per day 01181.0001/495768.1 EXHIBIT A Page 2 of 70 MMRP Mitigation Monitoring and Reporting Program MSS Morro shoulderband snail MWRP Master Water Reclamation Plan NOA Notice of Availability NOP Notice of Preparation NPDES National Pollutant Discharge Elimination System PM10 respirable particulate matter PRC Public Resources Code ROG reactive organic gases ROW public right-of-way SBR sequencing batch reactor SF square feet SLOAPCD San Luis Obispo County Air Pollution Control District SOI Sphere of Influence SVP Society of Vertebrate Paleontology SWP State Water Project SWPPP Stormwater Pollution Prevention Plan SWRCB State Water Resources Control Board TSS total suspended solids USEPA United States Environmental Protection Agency USFWS United States Fish & Wildlife Service USGS United States Geological Survey UV ultraviolet UWMP Urban Water Management Plan VOC volatile organic compounds WDR Waste Discharge Requirements WRF Water Reclamation Facility WRFCAC Water Reclamation Facility Citizen Advisory Committee WWTP Wastewater Treatment Plant 01181.0001/495768.1 EXHIBIT A Page 3 of 70 The California Environmental Quality Act (CEQA) requires that public agencies shall not approve or carry out a project for which an Environmental Impact Report (EIR) has been certified that identifies one or more significant adverse enviromnental effects of a project unless the public agency makes one or more written Findings for each of those significant effects, accompanied by a brief explanation of the rationale for each Finding (CEQA Guidelines, section 15091). This document presents the Findings made by the City of Morro Bay (the City), in its capacity as the CEQA lead agency, regarding the Morro Bay Water Reclamation Facility (WRF) Project, evaluated in the Final Environmental Impact Report (Final EIR) for the Project. This Exhibit A is organized into the following sections: Section 1.0 is an introduction. Section 2.0 describes the record of proceedings for the Project. Section 3.0 includes a summary and description of the Project. Section 4.0 provides an overview of the CEQA environmental review process. Section 5.0 contains the City of Morro Bay's Findings of Fact regarding impacts for the Proj ect. Section 6.0 contains the City of Morro Bay's Findings regarding alternatives to the Project. 1.0 CEQA Requirements for Findings of Fact CEQA requires public agencies to consider and identify the reasonably foreseeable and potentially significant adverse effects of their discretionary approvals of projects on the environment and, when feasible, to adopt and implement mitigation measures or alternatives that avoid or substantially lessen the significant effects of those projects. Specifically, Public Resources Code (PRC) section 21002 provides "public agencies should not approve projects as proposed if there are feasible alternatives or feasible mitigation measures available which would substantially lessen the significant environmental effects of such projects," and states the procedures required by CEQA are intended to assist public agencies in systematically identifying both the significant effects of Projects and the feasible alternatives or feasible mitigation measures which will avoid or substantially lessen such significant effects." PRC, section 21002 goes on to state "that in the event specific economic, social, or other conditions make infeasible such project alternatives or such mitigation measures, individual projects may be approved in spite of one or more significant effects thereof." Pursuant to the policy stated in PRC, sections 21002 and 21002.1, no public agency shall approve or carry out a project for which an EIR has been certified that identifies one or more significant effects on the environment that would occur if the project is approved or carried out unless both of the following occur: (a) The public approving agency makes one or more of the following findings with respect to each significant effect: 01181.0001/495768.1 EXHIBIT A Page 4 of 70 (1) Changes or alterations have been required in, or incorporated into, the project which mitigate or avoid the significant effects on the environment. (2) Those changes or alterations are within the responsibility and jurisdiction of another public agency and have been, or can and should be, adopted by that other agency. (3) Specific economic, legal, social, technological, other considerations, including considerations for the provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or alternatives identified in the E1R. (b) With respect to significant effects that were subject to Findings under paragraph (3) above, the public agency finds that specific overriding economic, legal, social, technological, or other benefits of the project outweigh the significant effects on the environment. PRC, section 21061.1 defines "feasible" to mean "capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, social and technological factors." CEQA Guidelines, section 15364 adds another factor in determining feasibility: "legal" considerations. (See, also, Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Cal.3d 553, 565 ("Goleta IF).) The concept of "feasibility" also encompasses the question of whether a particular alternative or mitigation measure promotes the underlying goals and objectives of a project (City of Del Mar v. City of San Diego (1982) 133 Cal.App.3d 410, 417 (City of Del Mar).); see, also, Sierra Club v. County of Napa (2004) 121 Cal.App.4th 1490, 15064509 [court upholds CEQA findings rejecting alternatives in reliance on applicant's project objectives]; California Native Plant Society v. City of Santa Cruz (2009) 177 Cal. App. 4th 957, 1001 ["an alternative `may be found infeasible on the ground it is inconsistent with the project objectives as long as the finding is supported by substantial evidence in the record"']; In re Bay -Delta Programmatic Environmental Impact Report Coordinated Proceedings (2008) 43 Ca1.4th 1143, 1165, 1166 ["feasibility is strongly linked to achievement of each of the primary [project] objectives"]). Moreover, "feasibility" under CEQA encompasses "desirability" to the extent desirability is based on a reasonable balancing of the relevant economic, environmental, social, and technological factors." (City of Del Mar, supra, 133 Cal.App.3d at p. 417; see also Sequoyah Hills Homeowners Assn. v. City of Oakland (1993) 23 Cal.App.4th 704, 715; California Native Plant Society v. City of Santa Cruz, supra, 177 Cal.App.4th at p. 1001 [after weighing "`economic, environmental, social, and technological factors' ... `an agency may conclude that a mitigation measure or alternative is impracticable or undesirable from a policy standpoint and reject it as infeasible on that ground"'].) With respect to a project for which significant impacts cannot be avoided or substantially lessened through feasible mitigation measures or alternatives, a public agency, after adopting proper findings, may nevertheless approve the project if the agency first adopts a statement of overriding considerations setting forth the specific reasons why the agency found the project's "benefits" rendered "acceptable" its "unavoidable adverse environmental effects." (CEQA Guidelines, section 15093 and subdivision 15043 (b); see, also, PRC, subdivision 21081 (b).) The California Supreme Court has stated, "[t]he wisdom of approving... any development project, a delicate task which requires a balancing of interests, is necessarily left to the sound discretion of 01181.0001/495768.1 EXHIBIT A Page 5 of 70 the local officials and their constituents who are responsible for such decisions. The law as we interpret and apply it simply requires that those decisions be informed, and therefore balanced." (Goleta H, supra, 52 Ca1.3d at page 576.) Because the Final EIR idened significant effects that may occur as a result of the Project, and in accordance with the provisions of CEQA and the CEQA Guidelines described above, the City of Morro Bay hereby adopts these Findings as part of the approval of the Project. In making these Findings and in adopting the Statement of Overriding Considerations, the City of Morro Bay has independently reviewed the Draft Environmental Impact Report (Draft EIR), and the Final EIR for the Project, as well as all other information in the record of proceedings (Record) on this matter. These Findings constitute the City of Morro Bay's best efforts to set forth the evidentiary and policy bases for its decision to approve the Project in a manner consistent with the requirements of CEQA. These Findings and the Statement of Overriding Considerations, in other words, are not merely informational, but rather constitute a binding set of obligations that come into effect with the City of Morro Bay's approval of the Project. 2.0 Record of Proceedings The record of proceedings for the City of Morro Bay's decision on the Project, including the substantial evidence supporting adoption of these Findings and the Statement of Overriding Considerations include, but are not limited to, the following documents: • The Notice of Preparation (NOP) and all other public notices issued by the City of Morro Bay in conjunction with the Project; • City of Morro Bay Draft EIR prepared for the City of Morro Bay through Environmental Science Associates (ESA), March 2018, and all appendices and supporting documents cited therein; • All comments submitted by agencies, NGOs, Tribes, or members of the public during the comment period on the Draft EIR; • The Mitigation Monitoring and Reporting Program (MMRP) for the Project and documents related thereto; • All Findings and resolutions adopted by the City of Morro Bay in connection with the Project and all documents cited or referred to therein; • All reports, studies, memoranda, maps, staff reports, or other planning documents relating to the Project prepared by the City of Morro Bay, consultants to the City of Morro Bay, or responsible or trustee agencies with respect to the City of Morro Bay's compliance with the requirements of CEQA and with respect to the Project; • All documents submitted to the City of Morro Bay by other public agencies or members of the public in connection with the Project, up through the approval of the Project; • Any documentary or other evidence submitted to City of Morro Bay, at such information sessions, public meetings, and public hearings; 01181.0001l495768.1 exHieiT a Page 6 of 70 ® Matters of common knowledge to the City of Morro Bay, including, but not limited to, federal, state, and local laws and regulations; ® Any documents expressly cited in these Findings or the Statement of Overriding, in addition to those cited above; and ® Any other materials required for the Record by Public Resources Code subdivision 21167.E (e). These Findings, the Statement of Overriding Considerations and the MMRP are based upon substantial evidence in the entire Record before the City of Morro Bay. The references to the Draft and Final EIR set forth herein are for ease of reference and are not intended to provide an exhaustive list of the evidence relied upon for these Findings, the Statement of Overriding Considerations and the MMRP. Pursuant to CEQA Guidelines, subdivision 15091 (e), City of Morro Bay is the official custodian of the documents and other materials that constitute the Record upon which the decisions related to the Project are based, and such documents and other materials are located at the offices of the City of Morro Bay, which are located at 595 Harbor Street, Morro Bay, CA 93442. Copies of the Draft and Final EIR are available at the Morro Bay Public Library (625 Harbor Street, Morro Bay), Cayucos Public Library (310 B Street, Cayucos), Morro Bay Public Services Department (955 Shasta Avenue, Morro Bay), Morro Bay's Wastewater Treatment office (160 Atascadero Road, Morro Bay), and online at the City of Morro Bay WRF website (http://morrobaywrf.com). 3.0 Description of the Project The following information is intended to provide a summary of the key components of the WRF Project. Additional detailed information concerning each component of the Project is set forth in Chapter 2, "Project Description," of the Final EIR. 3.1 Background and Need for Project The United States Environmental Protection Agency (USEPA) or the State Water Resources Control Board (SWRCB) regulate municipal wastewater discharges into the Pacific Ocean through National Pollutant Discharge Elimination System (NPDES) Permits in accordance with Section 402 of the federal Clean Water Act. USEPA or the California Regional Water Quality Control Boards issue (or reissue) NPDES permits to wastewater dischargers every five years. The existing wastewater treatment plant (WWTP) serves the City and the community of Cayucos, and is owned and operated jointly by the City and the Cayucos Sanitary District (CSD). Prior to the current 2017 NPDES Permit No. CA0047881 and Waste Discharge Requirements (WDR) Order No R3-2017-0050, the WWTP discharged to the Pacific Ocean under NPDES Permit No. CA0047881 and WDR Order No. R3-2008-0065, which was a Clean Water Act Section 301(h) modified NPDES permit that waived full secondary treatment requirements for biological oxygen demand (BOD) and total suspended solids (TSS). The existing WWTP has operated under that modified permit since its last upgrade in 1984. On July 7, 2003, the City submitted an application for renewal of the NPDES permit to USEPA and Central Coast Regional Water Quality Control Board (CCRWQCB), which expired in March 2014. The final renewed discharge permit was 01181.0001/495768.1 EXHIBIT A Page 7 of 70 adopted by the CCRWQCB on December 7, 2017. The 301(h) modifications were no longer included in the 2017 renewal. A time schedule order will be provided by CCRWQCB for compliance with full secondary treatment requirements. Based on an agreement with the CCRWQCB, the City and CSD had previously pursued bringing the existing facility to full secondary treatment in place of continued requests for a 301(h) modified discharge permit. The agreement allowed the City and CSD to pursue secondary treatment on a schedule that was mutually agreed upon by both agencies and the CCRWQCB. In February 2015, the CCRWQCB stated the new facility was expected to be fully operational by 2021 in order to meet its goals. The existirg WWTP is located in the Coastal Zone; as such, in order to upgrade the existing WWTP at its existing location, a Coastal Development Permit (CDP) would be required from the California Coastal Commission (CCC). However, in January 2013, the CCC denied the City and CSD's application for the CDP to demolish the existing WWTP and construct a new treatment facility on the same site. The basis for that denial included the CCC's assessment the new facilities would be inconsistent with the City's Local Coastal Plan (LCP) zoning provisions, failed to avoid coastal hazards, failed to include a sizeable reclaimed water component, and the project location was within an LCP-designated sensitive view area. Following that denial, the City began planning a new WRF and pursuing alternative locations for a new upgraded wastewater treatment plant. The City determined the denial presented an opportunity to design and construct a WRF to enhance the City's water supply portfolio through the production of recycled water. From 2013 to the beginning of 2014, the community defined goals to guide the planning and design process for the new WRF. Public outreach was conducted through stakeholder meetings, stakeholder interviews, and public workshops, which gathered input related to cost, environmental concerns, engineering and design issues, site -related issues, and logistics and process issues. Through that public outreach program, criteria were determined for the siting process, and various studies were conducted to examine the suitability of each site. Some of the criteria included, but were not limited to, compliance with NPDES Permit requirements, distance to the City sewer collection system, avoidance of coastal hazards, minimal visual impacts, and sustainable use of public resources. In order to ensure public involvement during this process, a Citizens Advisory Committee (WRFCAC) was created in July 2014 to help oversee and evaluate the siting process. Five comparative siting studies were performed between 2013 and 2017. Starting with the results of the Rough Screening Evaluation, 17 study sites were first examined for the potential location of the WRF. By December 2013, it was narrowed down to seven study sites (Chevron, Morro Valley, Chorro Valley, California Men's Colony (CMC) Wastewater Treatment Plant site, Morro Bay Power Plant — southern portion, Panorama, and Giannini), which ranged in size and number of properties included in each. Finally, the City Council narrowed the sites down to focus on the Morro Valley, Chorro Valley, and Giannini Property in May 2014. Within those three general areas, there were four specific locations: Rancho Colina and Righetti (both in Morro Valley), Tri- W (now called the "South Bay Boulevard" site, in Chorro Valley) and Giannini. It should be noted there was also a feasibility analysis performed for a regional facility at the CMC site that 01181.0001/495768.1 EXHIBIT A Page 8 of 70 could serve the needs of the City and partner agencies; however, that concluded not to be feasible. In April 2016, after direction to investigate other potential sites, the list of potential sites was revised to include Rancho Colina, Righetti, South Bay Boulevard, Chevron/Toro Creek, and Madonna. After the 2016 comparative study was completed, the South Bay Boulevard site, was found to be the final site preference, and preliminary planning efforts began at that location based on il City Councdirection at that time. The CCC supports the proposed new treatment plant location and has been supportive of working with the City and, as needed, San Luis Obispo County (County), on a CDP for a WRF at that location. lii Apri12015, the CSD decided to pursue an independent path from the City to build its own new wastewater facility, and unilaterally adopted a resolution to that effect on April 30, 2015. From that point forward, the City's efforts have been focused on finding a suitable site to build a WRF to serve only its customers, exclusive of CSD customers. Thus, current plans are for the City and CSD to build separate treatment facilities and, once operational, decommission the jointly -owned WWTP. The City has welcomed CSD to continue to participate in a joint venture since that time. CSD has consistently indicated it has no further interest in that approach, and, in fact, has found a site and made plans for a facility at a different location that would address its long-range wastewater disposal needs. 3.2 Project Objectives The Morro Bay City Council refined and adopted the project objectives for the Project on October 24, 2017. The primary goals of the Project have not changed. The following refined objectives reflect the input of the community and stakeholders since issuance of the NOP in 2016, demonstrating the purpose and value of the CEQA scoping process: • All aspects of the WRF project shall be completed ensuring economic value with a special emphasis on minimizing rate payer and City expense • Communicate WRF project progress including general project status, milestones, and budget/cost information to our community members regularly • Produce tertiary disinfected wastewater in accordance with the California Code of Regulations (CCR) Title 22 requirements for unrestricted urban irrigation • Design to produce reclaimed wastewater to augment the City's water supply, by either direct or indirect means, as described in a master water reclamation plan and to maximize funding opportunities • Include features in the WRF Project to maximize the City's opportunities to secure funding and maximize efficiencies, including energy generation and recovery. • Design to minimize the impacts from contaminants of emerging concern in the future • Ensure compatibility with neighboring land uses 01181.0001/495768.1 EXHIBIT A Page 9 of 70 The Project is located within the City of Morro Bay and in unincorporated area of the County of San Luis Obispo adjacent to the City boundaries. The WRF operations and maintenance buildings would be constructed on a 10- to 15-acre area within a 27.6-acre site to be purchased by the City. The 27.6-acre site would ultimately be annexed to the City. The WRF site is part of a greater 396- acre parcel that is located along Highway 1, north of the northern terminus of South Bay Boulevard. The City will pursue a modification to its Sphere of Influence (SOI) to include that 396-acre parcel. The existing WWTP that will be decommissioned is located at 160 Atascadero Road in the City of Morro Bay. The collection system would include a lift station adjacent to the existing WWTP and multiple pipelines running along a common alignment between the lift station and WRF site. The alignment would include: (1) a force main pipeline to convey raw wastewater from the lift station to the WRF site, (2) a waste discharge pipeline to convey brine or extreme wet weather flows to the ocean outfall and (3) a recycled water pipeline to injection wells, if the wells are constructed on the west side of Highway 1. The proposed lift station would be located within the City's existing Corporation Yard on Atascadero Road or adjacent to Atascadero Road along a public right- of -way. The WRF' would produce recycled water for reuse. A recycled water pipeline would run from the WRF, either along the same alignment described above or along a parallel alignment running east and north of Highway 1. The pipelines would lead to new groundwater injection wells at one of two locations. 3.4 Project Components The Project would include new wastewater treatment facilities at the WRF site that would produce advanced treated recycled water that meets or exceeds 22 CCR 60001 et seq. (Title 22) requirements for indirect potable reuse. The Project would allow the City to meet the SWRCB timeline requirements to upgrade the City's wastewater system to at least full secondary treatment, and would exceed that minimal requirement through development of an advanced water treatment facility (AWTF). Implementation of the Project would allow for the decommissioning of the existing WWTP, once CSD's new and independent wastewater facility is completed and operational. During operation, advanced treated recycled water produced at the WRF would be used for groundwater recharge. Brine produced by the treatment process will be discharged through the existing ocean outfall. The Project facilities are described in detail in the draft Water Reclamation Facility Master Plan (Black &Veatch, November 2016) and Master Water Reclamation Plan (MKN &Associates, March 2017). The pertinent details about the Project as they pertain to the analysis of environmental impacts are presented below. 01181.0001l495768.1 EXHIBIT A Page 10 of 70 kMMA %:7yA Treatment Facility The WRF would provide tertiary treatment to wastewater generated within the City's service area. The WRF would treat a maximum peak daily flow of 2.75 million gallons per day (MGD) and maximum average annual daily flow rate of 0.97 MGD. The resulting tertiary -treated recycled water would be in compliance with 22 CCR 60001 et seq. recycled water quality requirements for unrestricted use, and the majority of that water would be further treated and injected for indirect potable reuse. The facility design includes primary treatment; biological and tertiary treatment via or membrane bioreactor (MBR) or process that produces a similar level of water quality; advanced water treatment, including membrane filtration (if needed), reverse osmosis, ultraviolet (UV) radiation disinfection, and reverse osmosis; and solids dewatering with off -site solids disposal or on -site reuse. The City is proceeding with a design -build procurement process for the WRF that could allow construction of an alternative treatment technology that would meet the same water quality requirements as an MBR system. Regardless of the secondary and treatment process selected, advanced water treatment consistent with groundwater recharge requirements will be provided. All treatment processes would be covered or housed in one of the proposed WRF buildings Advanced Treatment Facility Implementation of the Project would include construction and operation of an AWTF at the WRF and associated infrastructure to convey advanced -treated recycled water to the ultimate end uses. Such facilities are described in the Master Reclamation Plan (MKN & Associates, April, 2017). That includes recycled water pipelines to deliver advanced treated water to new groundwater ection wells for groundwater replenishment then utilizing existing City wells to extract groundwater for treatment at the City's water treatment plant. Operations and Maintenance of Buildings Implementation would include construction of an approximately 7,000 SF single -story operations bung, a 5,600 SF maintenance bung, 17,610 SF of various vehicle storage facilities, and either a fixed track solar farm or a roof -mounted solar panel arrangement setup to offset energy usage and greenhouse gases produced by the WRF. 3.4.2 Collection System The Project would not require modification of the existing sewer collection system. All wastewater would continue to flow to a collection point near the existing WWTP site, where new offsite conveyance facilities would be built to connect the existing wastewater infrastructure to the proposed WRF site. As part of the Project, a new lift station and new conveyance pipelines would be installed. Lift Station A new lift station designed to convey up to 7.05 MGD would be constructed near the existing WWTP site to convey raw wastewater uphill through the proposed force main to the new WRF site. There are two potential sites for the proposed lift station. 01181.0001/495768.1 EXHIBIT A Page 11 of 70 ® Option 1A: The site is located directly adjacentto Atascadero Road, on the south side, partially within public right of way. It is located adjacent to the City's existing water treatment plant. ® Option 5A: The site is located directly adjacent to Atascadero Road, on the north side, partially within public right of way. It is located across from the City's existing water treatment plant. Conveyance Pipelines The offsite conveyance pipelines are comprised of a new force main to convey raw wastewater from the existing collection system and proposed lift station to the WRF site, a recycled water pI peline to convey treated water from the WRF to injection wells, and a waste discharge pipeline to convey brine or treated wet weather flows (compliant with California Ocean Plan discharge requirements) to the ocean outfall. 3.4.312ecycled Water Distribution System and Injection Wells One of the ultimate goals of the Project is to enhance the City's water supply portfolio. The proposed end use for recycled water produced at the WRF is indirect potable reuse (IPR), which would involve groundwater replenishment in the Morro Valley using subsurface application like injection wells. A recycled water distribution system would be built to convey water to one of two injection well areas. Project facilities may include, but not be limited to, the AWTF, recycled water conveyance pipeline, a pump station, injection wells and monitoring wells. Decommissioning of Current WWTP The existing WWTP would continue in operation until the new WRF is in full operation and the system is no longer delivering flow to the existing WWTP. The timing of decommissioning would also depend on when CSD's new wastewater facility is online and operational, since that agency also uses the current WWTP to treat wastewater. The decommissioning of the current WWTP would include the shutdown, demolition, and complete removal of all WWTP facilities and infrastructure such as the piping located four to five feet below grade. All materials would either be discarded and hauled to a nearby landfill or salvaged. 4.0 CEQA Environmental Review The basic purposes of CEQA are to (1) inform decision makers and the public about the potential, significant adverse environmental effects of proposed governmental decisions and activities, (2) identify the ways those environmental effects can be avoided or significantly reduced, (3) prevent significant, avoidable and adverse environmental effects by requiring changes in projects through the use of alternatives or mitigation measures when feasible, and (4) disclose to the public the reasons why an implementing agency may approve a project even if significant unavoidable environmental effects are involved. An EIR uses a multidisciplinary approach, applying social and natural sciences to make a qualitative and quantitative analysis of all the foreseeable environmental impacts that a Project would exert on the surrounding area. As stated in CEQA Guidelines section 15151: 01181.0001/495768.1 EXHIBIT A Page 12 of 70 An EIR should be prepared with a sufficient degree of analysis to provide decision makers with information which enables them to make a decision which intelligently takes account of environmental consequences. An evaluation of the environmental effects of a Project need not be exhaustive, but the sufficiency of an EIR is to be reviewed in the light of what is reasonably feasible. This Final Environmental Impact Report (Final EIR) has been prepared in accordance with the California Environmental Quality Act (CEQA) as amended (PRC section 21000 et seq.) and CEQA Guidelines (California: Code of Regulations, section 15000 et seq.). The Final EIR incorporates, by reference, the Draft EIR (State Clearinghouse No. 2016081027) prepared by City of Morro Bay (City) for the WRF (Project) as it was originally published. In accordance with Section 15132 of the CEQA Guidelines, the Final EIR shall consist of the following: (a) The Draft EIR or a revision of the draft. (b) Comments and recommendations received on the Draft EIR either verbatim or in suminary (c) A list of persons, organizations, and public agencies commenting on the Draft EIR. (d) The responses of the Lead Agency to significant environmental points raised in the review and consultation process. (e) Any other information added by the Lead Agency. Before the City may approve the Project, it must certify the Final EIR: a) has been completed in compliance with CEQA; b) was presented to the City Council who reviewed and considered it prior to approving the project; and c) reflects the City's independent judgment and analysis (CEQA Guidelines section 15090). Section 15004 of the CEQA Guidelines states before the approval) of any project subject to CEQA, the Lead Agency must consider the fmal environmental document, which in this case is the Final EIR. 4.1 Environmental Review Process 4. 4.1 Notice of Preparation and Public Scoping In accordance with Section 15082 of the CEQA Guidelines, a Notice of Preparation (NOP) of an EIR was prepared and circulated for review by applicable local, state and federal agencies and the public. The 30-day project scoping period, which began with the distribution of the NOP on August 8, 2016, remained open through September 7, 2016. A public scoping meeting was held on August 8, 2016 at the Veterans Memorial Building at 209 Surf Street in Morro Bay. The NOP provided the public and interested public agencies with the opportunity to review the Project and to provide comments or concerns on the scope and content of the environmental review document 1 The word "approval" is defined by Section 15352 of the CEQA Guidelines to mean "the decision by a public agency which commits the agency to a defmite course of action in regard to a project intended to be carried out by any person..." 01181.0001/495768.1 EXHIBIT A Page 13 of 70 including: the range of actions; alternatives; mitigation measures, and significant effects to be analyzed in depth in the EIR. 4.1.2 Notice of Availability of the Draft EIR The Notice of Availability (NOA) of the Draft EIR was posted on April 3, 2018 with the County Clerk -Recorder in San Luis Obispo County. The Draft EIR was circulated to federal, state, and local agencies and interested parties requesting a copy of the Draft EIR. Copies of the Draft EIR were made available to the public at the following locations: ® City of Morro Bay WRF Web Site (http://morrobaywrf.com) ® Morro Bay Public Library (625 Harbor Street, Morro Bay) ® Cayucos Public Library (310 B Street, Cayucos) ® Morro Bay Public Services Department (955 Shasta Avenue, Morro Bay) ® Wastewater Treatment office (160 Atascadero Road, Morro Bay) The Draft EIR was circulated for public review from Apri13, 2018 through May 18, 2018. During that period, the City held one CEQA public meeting to provide interested persons with an opportunity to comment orally or in writing on the Draft EIR. The CEQA public meeting was an item on the agenda at the Water Reclamation Facility Citizens Advisory Committee (WRFCAC) meeting held at the Veterans Memorial Hall in Morro Bay on May 1, 2018. There was one comment offered from the audience in addition to multiple comments offered from the WRFCAC members at the public meeting. 4.1.3 Responses to Comments and Final EIR CEQA Guidelines, section 15088 requires the City, as the Lead Agency, to evaluate comments on significant environmental issues received from parties that have reviewed the Draft EIR and to prepare a written response. As stated in CEQA Guidelines, sections 15132 and 15362, the Final EIR must contain the comments received on the Draft EIR, either verbatim or in summary, a list of persons commenting, and the response of the Lead Agency to the comments received. Thirty-five letters or emails were received by the City commenting on the Draft EIR. The Final EIR includes responses to all those comments, as well as comments made during the Draft EIR public meeting. The responses do not significantly alter the Project, change the Draft EIR's significance conclusions, or provide new information regarding substantial adverse environmental effects not already analyzed in the Draft EIR. Instead, the information presented in the responses to comments "merely clarifies or amplifies or makes insignificant modifications" in the Draft EIR, as is permitted by CEQA Guidelines, subdivision 15088.5(b). In the course of responding to comments, certain portions of the Draft EIR have been modified slightly for further clarification. The comments and modifications have not identified the existence o£ (1) a significant new environmental impact that would result from the Project or an adopted mitigation measure; (2) a substantial increase in the severity of an environmental impact; (3) a feasible project alternative or mitigation measure not adopted that is considerably different 01181.0001/495768.1 EXHIBIT A Page 14 of 70 from others analyzed in the Draft EIR that would clearly lessen the significant environmental impacts of the Project; or (4) information that indicates the public was deprived of a meaningful opportunity to review and comment on the Draft EIR (CEQA Guidelines, subdivision 15088.5(a). Consequently, the City finds the clarifications made to the Draft EIR in the Final EIR do not collectively or individually constitute significant new information within the meaning of PRC, section 21092.1 and CEQA Guidelines, section 15088.5. Recirculation of the DEIR or any portion thereof, is, therefore, not required. The written responses to commenting public agencies shall be provided at least ten (10) days prior to the certification of the Draft EIR (CEQA Guidelines § 15088(b)). The City provided the Final EIR to commenters on June 26, 2018, and made it available for review at the following locations: • City of Morro Bay WRF Web Site (http://morrobaywrf.com) • Morro Bay Public Library (625 Harbor Street, Morro Bay) • Cayucos Public Library (310 B Street, Cayucos) • Morro Bay Public Services Department (955 Shasta Avenue, Morro Bay) • Wastewater Treatment office (160 Atascadero Road, Morro Bay) 5.0 Findings of Fact Regarding Project Impacts 5.1 Findings Regarding No Impacts The Final EIR concludes the Project will result in no impacts to the following resource areas. The City finds, based on the Final EIR and the entire record, the Final EIR's conclusions regarding the Project's impacts to these resource areas are correct. • Agriculhtre (Impact 3.2-3, Forest Land and Timberland) —The Project is not located within forest an or timberland. Thus, the Project would not conflict with existing zoning for, or cause rezoning of, forest land, timberland or timberland zoned Timberland Production. There would be no impact. No mitigation is required. • Agriculture (Impact 3.2-4, Conversion of Forest Land) —The Project is not located within forest land so it would not result in the loss of forest land or conversion of forest land to non - forest use. There would be no impact. No mitigation is required. • Biological Resources (Impact 3.4-6, Habitat Conservation Plan) —The Project is not located within the boundaries of a habitat conservation plan or natural community conservation plan. There would be no impact. No mitigation is required. • Geology (Impact 3.6-5, Wastewater Disposal Systems) —The Project would not include septic tanks and would not result in impacts regarding soils incapable of supporting those alternative systems. There would be no impact. No mitigation is required. 01181.0001/495768.1 EXHIBIT A Page 15 of 70 • Hazards (Impact 3.8-4, Airport Land Use Plan) — The Project area is not within the boundaries of an airport land use plan. Construction and operation of the Project would not result in a safety hazard at a public airport. There would be no impact. No mitigation is required. • Hazards (hnpact 3.8-5, Private Airstrip) —The City does not include a private airstrip within its boundaries. Construction and operation of the Project would not affect a private airstrip or create a safety hazard. There would be no impact. No mitigation is required. • Land Use aild Planning (hnpact 3.10-1, Divide an Established Community) —The Project would not physically divide an established community. The Project's components are located in areas that are not established residential communities and would not disconnect any established communities. There would be no impact. No mitigation is required. • Land Use and Planning (hnpact 3.10-2, Land Use Plans and Policies) —The Project would not conflict with applicable land use plans, policies, or regulations adopted for the purpose of avoiding or mitigating an environmental effect, including the City or County General Plan, Local Coastal Plan, Coastal Zone Land Use Ordinance, or Zoning Ordinance. There would be no impact. No mitigation is required. • Land Use and Planning (Impact 3.10-3, Habitat Conservation Plan) —The Project would not be not located in or adjacent to a habitat conservation plan or a natural community conservation plan and therefore would not conflict with a habitat conservation plan or natural community conservation plan. There would be no impact. No mitigation is required. • Noise and Vibration (Impact 3.11-6, Airport Noise Levels) —The Project would not be located within an airport land use plan area or in the vicinity of a private airport. There would be no impact associated with noise levels at airports or airstrips. • Public Services (Impact 3.13-1b, Schools) —The Project would not induce population growth and would not require the construction of new schools. There would be no impact. No mitigation is required. • Public Services (Impact 3.13-1c, Parks and Public Facilities) —The Project would not induce population growth and would not require the construction of new parks or other public facilities. There would be no impact. No mitigation is required. • Traffic (Impact 3.14-2, Air Traffic Patterns) —Since there are no public or private airports within the City limits, implementation of the Project would not result in a change in air traffic patterns, including either an increase in air traffic levels or a change in location that results in substantial safety risks. There would be no impact. No mitigation is required. • Tribal Cultural (Impact 3.15-1, Historical Resources) —The Project would not cause a substantial adverse change in the significance of a tribal cultural resource listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources. There would be no impact. No mitigation is required. 01181.0001/495768.1 EXHIBIT A Page 16 of 70 ® Tribal Cultural (Impact 3.15-2, Tribal Cultural Resources) — The Project would not cause a substantial adverse change to a tribal cultural resource. There would be no impact. No mitigation is required. ® Tribal Cultural (CLunulative Impact 4-15, Tribal Cultural Resources The Project would not affect a Tribal Cultural Resource and when considered together with related projects, would not result in a cumulatively considerable impact to Tribal Cultural Resources. There would be no impact. . Findings earding Class I Impacts, Beneficial The Final EIR identifies the following environmental impacts as beneficial. The City finds, based on the Final EIR and the entire record, that the Final EIR's conclusions regarding the Project Is impacts to these resource areas are correct. ® Hydrology (Impact 3.9-6, Flood Hazard Areas) —The proposed lift station and IPR wells would be located within a 100-year flood hazard area; however, the relatively small footprint would be negligible and would not impede or redirect flood flows. This would be a Class III impact, Less than Significant. In addition, decommissioning of the WWTP would remove treatment facilities from the same I00-year flood hazard area, which is beneficial because it would remove a substantial impediment within the flood plain. Overall, the introduction of IPR wells combined with the removal of the existing WWTP would result less impervious surface than the current condition, which is a net beneficial impact (Class IV). ® Utilities (Impact 3.16-1, Wastewater Treatment Requirements) —Once operational, the proposed WRF would provide tertiary treatment and advanced treatment of wastewater, thereby exceeding the secondary treatment requirements mandated by the Central Coast Regional Water Quality Control Board. This would be a Class IV beneficial impact. • Utilities (Impact 3.16-4, Water Supply Entitlements) —Operation of the Project would allow foI the development of 650 to 825 AFY of advanced treated recycled water for indirect potable reuse, thereby enhancing water supplies in the project area and providing water supply reliability with a new local renewable water supply. This would be a Class IV beneficial impact. • Utilities (Impact 3.16-5, Wastewater Treatment Capacity) —The proposed WRF will be designed to accommodate the City's projected wastewater treatment capacity needs in the future based on buildout projections under the General Plan Update. The proposed WRF infrastructure would be more reliable than the existing WWTP, thereby reducing potential service interruptions. This would be a Class IV beneficial impact. 5.3 Findings Regarding Class III Impacts, Not Significant The Final EAR identifies the following environmental impacts as less than significant; no mitigation measures are required. The City finds, based on the Final EAR and the entire record, 01181.0001/495768.1 EXHIBIT A Page 17 of 70 that the Final EIR's conclusions regarding the Project's impacts to these resource areas are correct. • Aesthetics (Impact 3.1-1 Scenic Vistas) —The Project on not have an adverse effect on scenic vistas. The Project would not have sufficient scale or height to significantly affect scenic vistas. The WRF would be briefly visible from Highway 1, but would resemble rural agricultural buildings similar to others along the Highway I corridor. That impact would be Class III, Less than Significant. No mitigation is required. • Aesthetics (hnpact 3.1-2, State Scenic Highways) —The Project would be visible from Highway 1 and State Route 41 corridors, a State Scenic Highway and Eligible Scenic Highway, respectively. However, implementation of specific design criteria for development would ensure that scenic resources would not be adversely effected by implementation of proposed facilities. This impact would be Class III, Less than Significant. No mitigation is required. • Aesthetics (hnpact 3.1-3, Visual Character) —The proposed WRF would not degrade the visual character of the site due to implementation of specific design criteria for architectural treatments that blend with the surrounding rural and agricultural area. The remaining project components would also be similar in size and scale as surrounding development and would not degrade visual character. This impact would be Class III, Less than Significant. No mitigation is required. • Agriculture (Impact 3.2-1, Prime Farmland Conversion) —The proposed IPR East groundwater wells could potentially convert Prime Farmland to non-agricultural use. However, based on the results of the LESA model, the conversion of farmland to non- agricultural use would be considered less than significant. This impact would be Class III, Less than Significant. No mitigation is required. • Agriculture (Impact 3.2-2, Williamson Act Contract) —The Project would not conflict with a Williamson Act contract. Project components located on lands zoned for agricultural use would be consistent with applicable Land Use and zoning requirements through implementation of City and County policies and permit procedures. This impact would be Class III, Less than Significant. No mitigation is required. • Agriculture (Impact 3.2-5, Conversion to Non -Agricultural Use) —The proposed WRF would be located on a parcel that is currently rangeland and used for grazing. The majority of the parcel would continue to be used for grazing after implementation of the Project. The proposed WRF would implement City and County policies related to public services with agricultural lands, and would not substantially reduce the area available for grazing and rangeland, so impacts to this area are less than significant. In addition, agricultural impacts related to the location of IPR wells are considered Class III, Less than Significant. No mitigation is required. • Air Quality (Impact 3.3-1, Air Quality Standards) —The project would not conflict with the population and vehicle travel projections for the project area nor would it conflict with the 01181.0001/495768.1 EXHIBIT A Page 18 of 70 transportation control measures contained in the applicable air quality plan. This impact would be Class III, Less than Significant. No mitigation is required. • Air Quality (Impact 33-3, Air Quality Standards) —Proposed project operation out generate air pollutant emissions of ROG, NO,, and PM, but the increase would be less than the applicable SLOAPCD significance thresholds for operation and would therefore not lead to a violation of an air quality standard or contribute substantially to an existing or projected air quality violation. This impact would be Class III, Less than Significant. No mitigation is required. • Air Quality (hnpact 3.3-4, Sensitive Receptors) —The Project would not expose sensitive receptors to substantial pollutant concentrations that would lead to adverse health risks. This I mpact would be Class III, Less than Significant. No mitigation is required. • Air Quality (hnpact 33-5, Objectionable Odors) —Operation of the proposed WRF would generate odor, but the Project design includes odor control facilities to capture and treat air produced during the wastewater treatment process. A substantial number of people would not be affected by objectionable odor. This impact would be Class III, Less than Significant. No mitigation is required. • GHG and Energy (Impact 3.7-1, GHG Emissions) —The Project would generate GHG emissions, either directly or indirectly, that would not have a significant impact on the environment. This impact would be Class III, Less than Significant. No mitigation is required. • GHG and Energy (Impact 3.7-2, GHG Plans and Policies) —The Project would not conflict with any applicable plan, policy, or regulation of an agency adopted for the purpose of reducing the emissions of GHGs. This impact would be Class III, Less than Significant. No mitigation is required. • GHG and Energy (Impact 3.7-3, Energy) —The Project would not lead to wasteful, inefficient, or unnecessary consumption of energy, or wasteful use of energy resources, during project construction or operation, which would conflict with applicable energy efficiency policies or standards. This impact would be Class III, Less than Significant. No mitigation is required. • Hazards (Impact 3.8-1, Routine Use of Hazardous Materials) —Construction and operation of the Project would include the routine transport, use, and disposal of hazardous materials. However, the Project would be required to comply with all applicable federal, state, and local regulations regarding the use and disposal of hazardous materials and wastes which would reduce the potential for impacts to human health, public safety, and the environment. This impact would be Class III, Less than Significant. No mitigation is required. • Hazards (Impact 3.8-2, Proximity to Schools) —Although portions of the Project are located adjacent to Morro Bay High School, adherence to the applicable hazardous materials regulations would reduce potential impacts regarding hazardous materials emissions within 01181.0001/495768.1 EXHIBIT A Page 19 of 70 0.25 mile of a school. This impact would be Class III, Less than Significant. No mitigation is required. • Hazards (linpact 3.8-3, Cortese List) —The Project components on not be located on sites that are included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would not create a significant hazard to the public or the environment. This impact would be Class 11I, Less than Significant. No mitigation is required. • Hazards (hnpact 3.8-7, Wildfire) —The Project would not be located in a very high fire hazard severity zone and as such, the potential for wildfires is considered low. All project components would be designed to comply with all applicable fire codes and fire protection requirements established by the CCR and the City's building codes, would not be constructed of highly flammable materials, and would contain water thereby reducing flammability. This impact would be Class III, Less than Significant. No mitigation is required. • Hydrology (Impact 3.9-1, Water Quality Standards and Waste Discharge Requirements) — As a Groundwater Recharge Reuse Project, the Project would inject advanced treated recycled water into the Morro Valley Groundwater Basin for subsequent withdrawal as potable water supply. The Project would not result in violating water quality standards or waste discharge requirements or otherwise substantially degrade water quality. This would be a Class III impact, Less than Significant. No mitigation is required. • Hydrology (Impact 3.9-2) The Project could degrade surface water or groundwater quality in the event of pipeline rupture or accidental spill. Implementation of regulatory requirements, including a leak detection system and preventative maintenance program for new Project pipelines would ensure water quality in the project area is not adversely affected. This is a Class III impact, Less than Significant. No mitigation is required. • Hydrology (Impact 3.9-3, Groundwater Supplies) Groundwater Recharge Reuse Project, the Project would inject advanced treated recycled water into the Morro Valley Groundwater Basin for subsequent withdrawal as potable water supply. The project would not result in a net deficit in aquifer volume or lowering of the local groundwater table. This would be a Class III impact, Less than Significant. No mitigation is required. • Hydrology (Impact 3.9-5, Stormwater Runoff and Drainage Systems) —Installation of the Project components would add impervious surfaces that could increase stormwater runoff from Project sites. Compliance with the City's Storm Water Management Plan, Stormwater Ordinance, and other NPDES regulatory requirements would require drainage control features and LID features to be incorporated into Project design to control and prevent increases in stormwater runoff and minimize impacts to the existing capacity of the storm drain system. This is a Class III impact, Less than Significant. No mitigation is required. • Hydrology (Impact 3.9-7, Tsunami Hazard Zone) —The Project would remove the existing WWTP from the tsunami hazard zone, but construct a new lift station within the tsunami hazard zone. Floodproof design features and compliance with the City's Tsunami Emergency 01181.0001/495768.1 EXHIBIT A Page 20 of 70 Response Plan would minimize service disruptions to the wastewater system due to the potential effects of tsunami inundation of the lift station. This is a Class III impact, Less than Significant. No mitigation is required. ® Noise and Vibration (Impact 3.11-3, Groundborne Vibration) —The Project would not expose people to excessive groundborne vibration either during construction or operation. This would be a Class III impact, Less than Significant. No mitigation is required. ® Environmental Justice (hnpact 3.12-1) —The aboveground facilities of the Project would not be located near communities that are disproportionately comprised of low income or minority populations. This impact would be Class III, Less than Significant. No mitigation is required. ® Public Services (hnpact 3.13-1 a: Fire and Police Protection) —The number of workers required to construct and operate the Project would not be large enough to significantly affect the demand for housing. Thus, the Project would not affect service ratios or other performance objectives for fire and police protection. This impact would be Class III, Less than Significant. No mitigation is required. ® Utilities (hnpact 3.16-2, Construction of Treatment Facilities) —The Project includes the construction of a new wastewater treatment facility, which has been evaluated throughout the Draft EIR. No additional water or wastewater treatment facilities would be required to operate the Project. This would be a Class III impact, Less than Significant. No mitigation is required. ® Utilities (Impact 3.16-3, Stormwater Facilities) —Proposed project construction and operation would not generate excessive stormwater runoff such that new or expanded stormwater drainage facilities are required. This impact would be Class III, Less Than Significant. No mitigation is required. ® Utilities (Impact 3.16-6, Landfill Capacity and Solid Waste Regulation) -The Project would generate solid waste that could require disposal at a landfill, including construction debris "Al biosolids during WRF operation. Existing landfills have sufficient remaining capacity to accommodate construction -related solid waste; biosolids would be reused by a biosolids management firm rather than disposed at a landfill. The Project would comply with all federal, state, and local statutes and regulations related to solid waste. This impact would be Class III, Less Than Significant. No mitigation is required. 5.3.1 Cumulative Impacts All cumulative impacts are Class III, Less Than Significant with the exception of significant and unavoidable impacts to cultural resources, which are presented in Section 5.5 below. In addition, there would be no impact to tribal cultural resources, as described in Section 5.1 above. 5.3.2 Growth Inducing Impacts CEQA requires an EIR discuss ways in which the project could foster economic or population growth or the construction of additional housing, either directly or indirectly, in the surrounding 01181.0001/495768.1 EXHIBIT A Page 21 of70 area (CEQA Guidelines, Section 15126,4(11). Induced growth is any growth that exceeds planned growth and results from new development that would not have taken place in the absence of a project. A project can be determined to have a growth -inducing impact if it directly or indirectly causes economic or population expansion through the removal of obstacles to growth or encourages or facilitates other activities that could significantly affect the environment; actions that are sometimes referred to as "growth accommodating." Direct Growth Inducement Potential Implementation of the Project would not directly induce growth, as it does not propose development'of new housing that would attract additional population to the City. Further, implementation of the Project would not result in substantial permanent employment that could indirectly induce population growth. Construction activities would create some short-term construction employment opportunities over three years from 2019 to 2022; approximately 120 construction workers would be required for construction of the entire project, where each component would require approximately 12 to 20 construction workers depending on the facility. Construction workers would be drawn from the local and regional work force. The City's existing seasonal and occasional housing stocks would be sufficient to house temporary construction workers, if needed, in addition to local hotel establishments. On a long -tern basis, a maximum of four new employees would be required to operate the WRF, while existing City staff would operate the remaining O&M facilities. Thus, operation of the Project would be accommodated by the existing work force within the City and surrounding unincorporated areas of the County. Indirect Growth Inducement Potential Water Supply The local jurisdictions that govern land use and development within the Project area include the City and County (for unincorporated areas). Those jurisdictions' adopted General Plan documents guide the type, location, and level of land use and development within each respective jurisdiction. Those jurisdictions have assessed the growth -related impacts associated with planned land use and growth allowed under their General Plans and the CEQA EIRs they have prepared for those plans. Specifically, the City has already accounted for the development of the Project within the 2015 Urban Water Management Plan (UWMP), which used the same growth projections as the City's 2014-2019 Housing Element Update, as well as within the draft Facilities Master Plan (FMP) and Master Water Reclamation Plan (MWRP), which took into account the population projections of the General Plan Update. Thus, the City has taken into account the potential for indirect growth associated with implementation of the Project and has assessed and mitigated, as necessary, any growth -related impacts associated with the Project in the 2014-2019 Housing Element Update and its CEQA EIR as well as the General Plan Update and its CEQA EIR. In addition, San Luis Obispo Council of Governments (SLOCOG), the regional authority charged with providing a framework for coordination of orderly regional growth and development, has prepared the 2014 Regional Transportation Plan/Sustainable Communities Strategy (2014 RTP/SCS), which serves as a long-term planning and management plan for the regional transportation system, providing mitigation measures to off -set the impacts of growth projected in 01181.0001/495768.1 EXHIBIT A Page 22 of 70 the region. The 2014 RI P/SCS was prepared in coordination with the City and has also accounted for any indirect growth associated with the development of the Project. Therefore, the Project would provide future water system infrastructure within the City, which would support planned population growth that has been identified for the service area. As stated above, the City has already accounted for the Project's additional recycled water supply within the 2015 UWMP, and is required in the City's General Plan, and, therefore, does not represent an additional unanticipated source of supply. The Project would allow the City to increase the amount of groundwater used for potable water distribution and decrease its dependency on water supplied from the State Water Project (SWP). The addition of potable water resulting from the Project's indirect potable reuse component would reallocate the percentages of the water sources used by the City, but would not exceed the total amount of water supply the City has planned for in the 2015 UWMP. Thus, implementation of the Project would not create a new or expanded water supply that could create an indirect growth inducement potential. Wastewater Treatment In regards to wastewater treatment, the WRF would treat a maximum average annual daily flow rate of 0.97 MGD, which is a slight decrease in treatment capacity from the existing WWTP, which has average daily wastewater collection flow of 1.089 MGD. The draft FMP and MWRP for the Project took into consideration the planned population projections in the 2015 UWMP and General Plan Update and sized the plant to accommodate wastewater flows associated with the expected population of 12,000 in 2040 (see Final EIR Table 5-2). In addition, Measure F provides a cap on the City's population at 12,200 residents until increased by the voters. Thus, implementation of the Project would not result in additional growth greater than the City has already planned for within its land use planning documents. For those reasons, the Project would not remove any obstacles to growth and would not indirectly have a significant impact on growth inducement. As a result, impacts to growth inducement would be less than significant. 5.4 Findings Regarding Class II Impacts, Significant but Mitigable The City makes the Findings below in accordance with CEQA Guidelines, subdivision 15091 (a)(1): Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant effects on the environment. In the event there is any inconsistency between the descriptions of mitigation measures in these Findings or the MMRP and the Final EIR, the City will implement the measures as they are described in the Final EIR. In the event a mitigation measure recommended in the Final EIR has inadvertently been omitted from these Findings or from the MMRP, such a mitigation measure is hereby adopted and incorporated in the Findings and/or MIVIMRP as applicable. 5.4.1 Aesthetics Light or Glare • Impact 3.1-4: Construction of the proposed injection wells would require nighttinZe lighting during 24-hour drilling activities. Measures that require lighting to be shielded and directed 01181.0001/495768.1 EXHIBIT A Page 23 of 70 away from neighboring light sensitive land uses would reduce impacts associated with light and glare. This impact would be Class II, Less than Significant with Mitigation. Facts in Support of the Finding: Construction of the proposed injection wells would require daily 24-hour drilling for up to approximately one month. As such, temporary overhead nighttime lighting would be installed during the well drilling period. The IPR West wellfield area is largely surrounded by existing trees and vegetation surrounding the creek; therefore, the use of nighttime lighting would not substantially impact nearby uses. However, the IPR East wellfield area is located adjacent to light sensitive uses including the mobile home park. Therefore, implementation of overnight lighting within the IPR East wellfield area could result in potentially significant impacts. Mitigation Measure AES4 would ensure that lighting would be shielded and pointed away from surrounding light-sensitive land uses during nighttime construction. By doing so, light would not spill over to light-sensitive land uses. As a result, impacts associated with light and glare during construction activities would be reduced to a less than significant level with implementation of mitigation measures. Construction/operation of other project components would have less than significant or no impact associated with light and glare. Finding: The City has adopted and will implement the following mitigation measure that will reduce potentially significant Impact 3.14 to a less than significant level: AES-1: Nighttime Construction Lighting. Lighting used during nighttime construction, including any associated 24-hour well drilling, shall be shielded and pointed away from surrounding light-sensitive land uses. 5.4.2 Air Quality Air Quality Standards ® Impact 3.3-2: Project construction would cause temporary increases in localized air pollutant emissions of ROG, NOx and DPM in excess of SLOAPCD construction thresholds which could lead to a violation of an air quality standard. Implementation offugitive dust control measures and other standard control measures for construction equipment would reduce emissions. This impact would be Class II, Less Than Significant with Mitigation. Facts in Support of the Finding: The maximum daily construction emissions of reactive organic gases (ROG) and nitrogen oxides NOx generated by the Project would exceed San Luis Obispo County Air Pollution Control District's (SLOAPCD) Tier 1 significance thresholds in all three construction years of the Project. Quarterly diesel particulate matter (DPM) emissions would also exceed the Tier 1 thresholds in 2019 while fugitive respirable particulate matter (PMIo) emissions would be below the respective significance threshold for all three years. SLOAPCD requires construction projects that last more than one quarter and exceed the Tier 1 thresholds to implement Standard Mitigation Measures and best available control technology (BACT) for construction equipment. Those measures are detailed in Mitigation Measure AQ4b and Mitigation Measure AQ-lc. BACT requires all off -road construction equipment that exceeds 50 horsepower to be either certified as EPA Tier 4 where available to reduce the 01181.0001/495768.1 EXHIBIT A Page 24 of 70 pollutant emissions from the Projects construction equipment. Implementation of Mitigation Measures AQ4b, AQ4c and AQ4d would reduce all pollutant emissions associated with the Projeefs construction activities to below the Tier 1 significance thresholds. Therefore, with mitigation, air quality impacts associated with the project construction would be less than significant. Although the Project's fugitive dust emissions would not exceed Tier 1 or 2 thresholds, SLOAPCD requires any project with grading areas greater than 4.0 acres or that are within 1,000 feet of any sensitive receptor to implement standard fugitive dust mitigation measures. Therefore, 1VIitigation Measure AQ4a is also required. Finding: The City has adopted and will implement the following mitigation measures that will reduce potentially significant Impact 3.3-2 to a less than significant level: AQ-la: Fugitive Dust Control Measures. Construction projects shall implement the following dust control measures so as to reduce PM10 emissions in accordance with SLOAPCD requirements. • Reduce the amount of the disturbed area where possible; • Water trucks or sprinkler systems shall be used during construction in sufficient quantities to prevent airborne dust from leaving the site. Increased watering frequency shall be required whenever wind speeds exceed 15 mph. Reclaimed (non - potable) water shall be used whenever possible; • All dirt stock pile areas shall be sprayed daily as needed; • Permanent dust control measures identified in the approved project revegetation and landscape plans shall be implemented as soon as possible following completion of any soil disturbing activities; • Exposed ground areas that are planned to be reworked at dates greater than one month after initial grading shall be sown with a fast germinating, non-invasive grass seed and watered until vegetation is established; • All disturbed soil areas not subject to revegetation shall be stabilized using approved chemical soil binders, jute netting, or other methods approved in advance by SLOAPCD; • All roadways, driveways, sidewalks, etc. to be paved shall be completed as soon as possible after grading unless seeding or soil binders are used; • Vehicle speed for all construction vehicles shall not exceed 15 mph on any unpaved surface at the construction site; • All trucks hauling dirt, sand, soil, or other loose materials are to be covered or shall maintain at least two feet of freeboard (minimum vertical distance between top of load and top of trailer) in accordance with California Vehicle Code section 23114; 01181.0001/495768.1 EXHIBIT A Page 25 of 70 • Install wheel washers where vehicles enter and exit unpaved roads onto streets, or wash off trucks and equipment leaving the site; • Sweep streets at the end of each day if visible soil inaterial is carried onto adjacent paved roads. Water sweepers with reclaimed water shall be used where feasible; • All of these fugitive dust mitigation measures shall be shown on grading and building plans; and • The construction contractor shall designate a person or persons to monitor the fugitive dust emissions and enhance the implementation of the measures as necessary to minimize dust complaints, reduce visible emissions below 20 percent opacity, and to prevent transport of dust offsite. Their duties shall include holidays and weekend periods when work may not be in progress. The name and telephone number of such persons shall be provided to SLOAPCD Compliance Division prior to the start of any grading, earthwork or demolition. AQ-1 b: Standard Control Measures fo1^ Construction Equipment. Standard mitigation measures for reducing NOh, ROG, and DPM emissions from construction equipment are listed below: • Maintain all construction equipment in proper tune according to manufacturer's specifications; • Fuel all off -road and portable diesel powered equipment with ARB certified motor vehicle diesel fuel (non -taxed version suitable for use off -road); • Use diesel construction equipment meeting ARB's Tier 2 certified engines or cleaner off -road heavy-duty diesel engines, and comply with the State Off -Road Regulation; • Use on -road heavy-duty trucks that meet the ARB's 2007 or cleaner certification standard for on -road heavy-duty diesel engines, and comply with Lite State On -Road Regulation; • Construction or trucking companies with fleets that that do not have engines in their fleet that meet the engine standards identified in the above two measures (e.g. captive or NOX exempt area fleets) may be eligible by proving alternative compliance; • All on- and off -road diesel equipment shall not idle for more than 5 minutes. Signs shall be posted in the designated queuing areas and or job sites to remind drivers and operators of the 5-minute idling limit; • Diesel idling within 1,000 feet of sensitive receptors is not permitted; • Staging and queuing areas shall not be located wn 1,000 feet of sensitive receptors; • Electrify equipment when feasible; • Substitute gasoline -powered in place ofdiesel-powered equipment, where feasible; and, 01181.0001/495768.1 EXHIBIT A Page 26 of 70 • Use alternatively fueled construction equipment on -site where feasible, such as compressed natural gas (CNG), liquefied natural gas (LNG), propane or biodiesel. AQ-1 c: BACT for Construction Equipment. The following BACT for diesel -fueled construction equipment shall be implemented during construction activities at the project site, where feasible: • Further reducing emissions by expanding use of Tier 3 and Tier 4 off -road and 2010 on -road compliant engines where feasible; • Repowering equipment with the cleanest engines available; and • Installing California Verified Diesel Emission Control Strategies, such as level 2 diesel particulate filters. These strategies are listed at: http://www.arb.ca.gov/diesel/verdev/vt/cvt.htm AQ-Id: Architectural Coatings. To reduce ROG and NOx emissions during the architectural coating phase, low or no VOC emission paints and finishes shall be used with levels of 50 g/L or less. 5.4.3 t3iological Resources Special Status Species • Impact 3.4-1: Ground disturbing activities during construction of the Project could have impacts to special status plant and wildlife species, including Morro shoulderband snail, American badger, and nesting birds, as well as indirect impacts to special status plant species such as San Luis Obispo owl's clover. Pre -construction surveys will be conducted to determine presence or absence of species prior to initiation of construction activities. If species are present, measures to avoid or relocate individuals or avoid nests would be implemented to mitigate potential adverse impacts. This is a Class II impact, Less than Significant with Mitigation. Facts in Support of the Finding: Special Status Plants. The study area contains two occurrences of the San Luis Obispo owl's clover, a CRPR List 1B species, that are outside the proposed development footprint. Native bunchgrass grasslands observed on portions of the preferred WRF site are also outside the development footprint, and would not be impacted by the Project. The Cambria morning glory is present in annual grasslands throughout the eastern pipeline alignment as well as at the preferred WRF site. That is a watch list (CRPR 4) species and typically does not meet the CEQA thresholds used to define rarity (please refer to Section 15380 of CEQA). Although no direct impacts are expected, indirect impacts to special -status plants during construction of the )&W could result in potentially significant impacts. In order to minimize potential indirect impacts to special -status plant species, implementation of construction worker environmental awareness training and best management practices as described in Mitigation Measure BI04 and BI0-2 would ensure potential impacts to special status plants are less than significant. Special Status Wildlife. Aquatic species, such as California red -legged frog (CRLF), southern steelhead, tidewater goby, and western pond turtle, maybe present on a seasonal basis at the 01181.0001/495768.1 EXHIBIT A Page 27 of 70 pipeline crossings of Morro Creek. I renchless construction methods would be used to install the conveyance pipelines across sensitive features, including Morro Creek. Implementation of trenchless construction methods would avoid direct impacts to Morro Creek and to these aquatic species. As such, direct impacts to those special status wildlife species and their associated habitat are not expected. However, indirect impacts to special -status wildlife species could result due to construction activities in and around Morro Creek, which could result in potentially significant mpacts. In order to minimize potential indirect impacts to special -status wildlife and associated habitat, implementation of construction worker environmental awareness training and best management practices as described in Mitigation Measure BI04 and BIO-2 would ensure potential impacts to special status wildlife are less than significant. Mop ro ShouldeNband Snail. As currently designed, portions of the western and eastern proposed pipeline alignments, and the northwest corner of the proposed IPR West wellfields, contain Baywood fine sand soils or dunes, and areas of non-native plants along road shoulders that could provide habitat for the federally -protected Morro shoulderband snail (MSS). Suitable sandy soil conditions for the species are present along portions of Quintana Road and adjacent to the southeast corner of the WWTP intheproposed western pipeline alignment, small portions of the eastern pipeline alignment at Bolton Drive and Radcliffe Avenue a portion of the proposed eastern pipeline alignment at Drainage IA and the northwest corner of the proposed IPR West wellfield (see Final EIR Figure 3.4.7). Those areas are mostly developed and disturbed by urban development; however, areas with low growing vegetation growing on sandy soils could provide low quality habitat for the species such that MSS could potentially occur in these areas. Construction -related ground disturbance could result in take of MSS and would be a potentially significant impact. In addition, MSS have been previously identified in an undeveloped parcel near the existing WWTP, between Atascadero Road and the Morro Bay High School. That property is adjacent to, but outside, the Project impact area; however, an adjacent dirt parking area on Atascadero Road is likely to be used during project construction and is the location for the proposed lift station Option 5A. Construction on, or use of, the dirt parking area opposite the existing WWTP during wet weather could impact MSS if individuals enter the work area, and would be a potentially significant impact. To avoid take of MSS during project construction, Mitigation Measure BIO-3 outlines all steps to be taken to ensure impacts to MSS are avoided. During design of the project components, surveys would be conducted in areas with potential habitat. The survey information will be used to locate facilities to avoid MSS habitat. If avoidance of MSS habitat is not feasible, then protocol surveys would be conducted to determine if MSS are present. If MSS are present, then. consultation with the USFWS would be conducted as appropriate and MSS individuals would be relocated from project areas as necessary. Once project facilities are built, there would be no long-term impacts to MSS due to project operation. With implementation of Mitigation Measure 3I0-3, impacts would be less than significant. American Badger. The American badger was determined to have potential to occur on the preferred WRF site and in portions of the proposed eastern pipeline alignment, due to presence of 01181.0001/495768.1 EXHIBIT A Page 28 of 70 grassland habitats, water, and a prey base of California ground squirrels and pocket gophers in the general region. The American badger is a California Species of Special Concern. During initial ground disturbance, construction activities could result in direct harm to badger or destruction of badger dens due to the operation of heavy equipment for purposes of clearing and grading of the preferred WRF site and proposed pipeline alignments, which would be a potentially significant impact. To avoid impacts to the American badger during project construction, Mitigation Measure BIO-4 outlines all steps to be taken to ensure impacts to American badgers are avoided during project construction, including preconstruction surveys and avoidance of active dens if found. Once project facilities are built, there would be no long-term impacts to American badgers due to project operation. With implementation of Mitigation Measure BIO-4, impacts would be less than significant. Nesting Buds. The removal of vegetation during Project construction could result in direct impacts to nesting birds if any are present. In addition, indirect impacts to birds nesting in the vicinity of the proposed disturbance could result from construction activities. Nesting activity typically occurs from February 1 to August 31 for songbirds and from January 15 to August 31 for raptors. Disturbing or destroying active nests is a violation of the Migratory Bird Treaty Act. In addition, nests and eggs are protected under California Fish and Game Code (FGC) sections 3503 and 3503.5. As such, direct impacts (removal of active nests) and indirect impacts (e.g. by noise causing abandonment of the nest) to nesting birds would be considered a potentially significant impact. To avoid impacts to nesting birds, Mitigation Measure BIO-5 outlines all steps to be taken to ensure impacts to nesting birds are avoided during project construction. The initiation of construction activities within annual grassland habitat and the removal of any trees would occur outside of the nesting season if feasible. If not feasible, then preconstruction surveys for active nests would be required. If active nests are found, measures would be taken to establish a buffer around nests where no project construction activities would occur until nesting activities have ceased, as determined by a qualified biologist. Once Project facilities are built, there would be no long-term impacts to nesting birds due to project operation. With implementation of Mitigation Measure 13I0-5, impacts would be less than significant. Finding: The City has adopted and will implement the following mitigation measures that will reduce potentially significant Impact 3.4-1 to a less than significant level: BIO-1: Construction Worker Environmental Awareness Training and Education Program. Prior to the commencement, and for the duration of proposed construction activities, all construction workers shall attend an Environmental Awareness Training and Education Program, developed and presented by the Lead Biologist. The Training and Education shall include: 1. The program shall include information on San Luis Obispo owl's clover and the life history of steelhead, CRLF, MSS, and other raptors; nesting birds; as well as other wildlife and plant species that may be encountered during construction activities. The program will also include descriptions of sensitive habitats (drainages, riparian 01181.0001/495768.1 EXHIBIT A Page 29 of 70 habitat, and wetlands) and The program shall also discuss Lite legal protection status of each species and sensitive habitat, the definition of "take" under the Federal Endangered Species Act and California Endangered Species Act, measures the project proponent is implementing to protect each species and sensitive habitat, reporting requirements, specific measures that each worker shall employ to avoid take of wildlife species and sensitive habitats, and penalties for violation of the Federal Endangered Species Act or California Endangered Species Act. 2. An acknowledgement form signed by each worker indicating that Environmental Awareness Training and Education Program has been completed would be kept on recorA; 3. A sticker shall be placed on hard hats indicating that the worker has completed the Environmental Awareness Training and Education Program. Construction workers shall not be permitted to operate equipment within the construction areas unless they have attended the Environmental Awareness Training and Education Program and are wearing hard hats with the required sticker; A . A copy of the training transcript, training video or informational binder for specific procedures shall be kept available for all personnel to review and be familiar with as necessary. 5. The construction crews and contractors) shall be responsible for unauthorized impacts from construction activities to sensitive biological resources that are outside the areas defined as subject to impacts by project permits. BIO-2: Avoidance and Protection of Biological Resources. During proposed construction, operations and maintenance, and decommissioning the City and/or contractor shall implement the following general avoidance and protective measures: 1. All proposed impact areas, including staging areas, access routes, and disposal or temporary placement of spoils, shall be delineated with stakes and/or flagging prior to construction to avoid natural resources where possible. Construction -related activities outside of the impact zone shall be avoided. 2. The project proponent shall limit the areas of disturbance to the maximum extent that is practicable. Parking areas, new roads, staging, storage, excavation, and disposal site locations shall be confined to the smallest areas possible. These areas shall be flagged and disturbance activities, vehicles, and equipment shall be confined to these flagged areas. 3. Riparian habitat, drainages, and wetlands will be flagged and signed to restrict project access into these areas. 4. Spoils shall be stockpiled in disturbed areas that lack native vegetation. Best Management Practices shall be employed to prevent erosion in accordance with the project's approved Stormwater Pollution Prevention Plan (SWPPP; as described in Chapter 3.9). 01181.0001/495768.1 EXHIBIT A Page 30 of 70 5. To prevent inadvertent entrapment of American badgers or other wildlife during construction, all excavated, steep -walled holes or trenches shall be covered with plywood or similar materials at the close of each working day, or provided with one or more escape ramps constructed of earth fill or wooden planks. If trapped animals are observed, the appropriate agency shall be consulted and escape ramps or structures shall be installed immediately to allow escape. If a listed species is trapped, the U.S. Fish and Wildlife Service and/or California Department of Fish and Wildlife shall be contacted immediately. 6. Vehicular traffic to and from the project site shall use existing routes of travel. Cross country vehicle and equipment use outside designated work areas shall be prohibited. 7. Workers shall be prohibited from bringing pets and freanns to the project site and from feeding wildlife. 8. Intentional killing or collection of any plant or wildlife species shall be prohibited. BIO-3: Morro Shoulderband Snail. The following mitigation measures shall be implemented to avoid or minimize impacts to Morro shoulderband snail (MSS): 1. During project design, if project components would be located in areas determined to have soils and vegetation that could support MSS (e.g., see Final EIR Figure 3.4-7), then a qualified biologist shall conduct a survey to delineate the extent of potential habitat. The survey information shall be incorporated into the project design such that facilities are located to avoid potential MSS habitat. The following project components have either been mapped as Baywood fine sands or dunes, or are in areas adjacent to known populations (see Final EIR Figure 3.4.7): o Option SA lift station adjacent to Atascadero Road; o the western pipeline alignment adjacent to the southeast corner of the WWTP; o a portion of the eastern pipeline alignment at Drainage 1 A; and o the northwest corner of the IPR-West wellfield. 2. For pipeline alignments or other project components that are sited in areas adjacent to vegetated areas that have capacity to support MSS, silt fencing shall be installed, under the direction of a qualified biologist, to restrict project activities into these areas and to deter MSS movement into the project area. 3. If avoidance of MSS habitat is not feasible, then protocol levels surveys for MSS shall be conducted to determine presence/absence and distribution of MSS. Surveys shall be conducted by a biologist in possession of a valid recovery permit for the species. If the survey results are negative, the City shall request a concurrence determination for the project based on absence of the species. Coordination with USFWS during project design may facilitate receipt of a concurrence determination. 4. If survey results are negative and a concurrence authorization is granted, then vegetation shall be removed under supervision of the permitted biologist, and the 01181.0001/495768.1 EXHIBIT A Page 31 of 70 sites) shall be graded/grubbed down to bare mineral soil, and bordered with silt fence to preclude MSS from subsequently entering the area(s). live MSS are found within areas proposed for impact, then consultation with USFWS will be necessary and the issuance of a Biological Opinion (B.O.) may be required to allow individuals to be moved out of project areas prior to construction. A pennitted biologist must be retained to move MSS per the B.O. requirements, and to monitor vegetation clearing activities occurring within the MSS habitat area(s). 6. If equipment use, materials stockpiling, lift station construction, or any other uses are proposed on the north side of Atascadero Road opposite the existing WWTP, then all such areas shall be delineated by installation of silt fencing to create a barrier between potential MSS habitat and project activities. If fenced areas are utilized during or immediately following rain events or dense fog conditions, then a permitted biologist will survey and clear the work areas each morning prior to start of work to ensure that no MSS have entered the site. 7. Work crews will undergo an environmental training session conducted by a qualified biologist prior to start of construction activities in or adjacent to MSS habitat areas. Environmental training would inform project personnel of the constraints associated with working within and adjacent to MSS habitat, and the appropriate protocol should MSS be encountered during construction activities. BIO-4: American Badger. Apre-construction survey for active badger dens will be conducted within the proposed construction impact footprint and surrounding accessible areas of the mapped annual grassland portions of the eastern pipeline alignment (between the WRF and Downing Street on the west; see Figures 3.4-3 through 3.4-5 in the Final EIR) and the VW site at least two weeks prior to any ground disturbing activities. The survey will be conducted by a qualified biologist. In order to avoid potential direct impacts to adults and nursing young, no grading should occur within 50 feet of an active badger den as determined by the project biologist. Construction activities between July 1 and February 28 shall comply with the following measures to avoid direct take of adult and weaned juvenile badgers through the forced abandonment of dens: 1. A qualified biologist will conduct a focused survey at least two (2) weeks prior to the start of construction; 2. If a potential den is located that is too long to see the end, then a fiber optic scope (or other acceptable method such as using tracking medium for athree-night period) will be used to determine if the den is being actively used by a badger; 3. Inactive dens will be excavated by hand with a shovel or using a small excavator to prevent badgers from re -using them during construction. 4. Badgers will be discouraged from using currently active dens prior to the grading of the site by partially blocking the entrance of the den with sticks, debris and soil for three to five days. Access to the den shall be incrementally blocked to a greater 01181.0001/495768.1 EXHIBIT A Page 32 of 70 degree over this period. This should cause the badger to abandon the den and move elsewhere. After badgers have stopped using any den(s) within the project boundary, the den(s) will be hand ❑ excavated with a shovel or carefully excavated with the use of an excavator to prevent reC,] use. 5. The qualified biologist will be present during the initial clearing and grading activity. If additional badger dens are found, all work within the area will cease until the biologist can complete measures described above for inactive and active dens. Once the badger dens have been excavated, work in the area may resume. BIO-S: Nesting Birds. The following mitigation measures are recommended to avoid or minimize impacts to nesting bird species, including special -status species and species protected by the Migratory Bird Treaty Act, 1. Airy removal of trees and dist<irbance of annual grassland habitat will be limited to the time period between September 1 and February 14 if feasible. If tree removal and grassland impacts cannot be conducted during this time period, a qualified biologist shall conduct pre[ surveys for active bird nests within the limits of the project. 2. If active nest sites of bird species protected under the Migratory Bird Treaty Act and/or FGC section 3503 are observed within or adjacent to the study area, then the project shall be modified and/or delayed as necessary to avoid direct take of the identified nests, eggs, and/or young. Potential project modifications may include establishing appropriate "no activity" buffers around the nest site. The buffer will be 500 feet for raptors and 250 feet for other bird species, or as otherwise determined and documented by a qualified biologist. Construction activities shall not occur in the buffer until the project biologist has determined that the nesting activity has ceased. 3. Active nests shall be documented and monitored by the project biologist, and a letter report will be submitted to the USFWS and CDFW, documenting project compliance with the MBTA and applicable project mitigation measures. Sensitive Natural Communities • Impact 3.4-2: Construction of proposed conveyance pipelines could result in direct and indirect impacts to riparian habitat. Construction ofproposed wells could impact riparian habitat associated with Morro Creek and Little Morro Creek. The Project would use trenchless construction methods to install pipelines across Morro Creek to avoid direct impacts, and wells would be sited in upland areas to avoid riparian habitat. Implementation of best management practices during construction would minimize indirect impacts to adjacent riparian areas. This would be a Class II impact, Less than Significant with Mitigation. Facts in Support of the Finding: The riparian habitat south of Lila Keiser Park and north of Morro Creek could be indirectly impacted due to installation of the raw wastewater pipeline along the creek, including an area of restored riparian habitat consisting of planted willows, elderberry, and coast live oaks. Installation of the proposed pipeline across the creek could have direct impacts to the riparian habitat as well. In addition, the proposed IPR West and IPR East wellfield 01181.0001/495768.1 EXHIBIT A Page 33 of 70 areas may contain areas of riparian habitat associated with Morro Creek (see Final EIR Figure 3.4-2). Installation of proposed injection and monitoring wells and associated pipelines could directly and/or directly affect riparian habitat. These impacts would be considered potentially significant. Construction of the proposed pipeline south of Lila Keiser Park would be sited to avoid riparian habitat adjacent to Morro Creek, as required by Mitigation Measure BI0-6. That would avoid direct impacts to riparian habitat. Prior -to initiation of ground disturbance, measures would be implemented to identify the limits of construction adjacent to the creek and to delineate riparian areas to be avoided to prevent indirect impacts to riparian habitat. Mitigation Measure 13I0-6 identifies the measures to be implemented by a qualified biologist to avoid direct and indirect construction -related impacts to riparian habitat. With implementation of Mitigation Measure 3I0-6, impacts would be mitigated to less than significant levels. Trenchless construction methods would be used to cross sensitive surface features such as Morro Creek; or pipelines could be installed across the creek suspended on existing bridges. Mitigation Measure BI0-7 includes requirements for trenching to stop at least 50 feet away from jurisdictional features, such as riparian habitat, and for the remaining distance to be installed using trenchless methods such as horizontal directional drilling (HDD), to ensure impacts to riparian habitat are avoided. That measure would also ensure a buffer around riparian habitat during construction that complies with the City's Coastal Land Use Plan. With implementation of Mitigation Measure 13I0-6 and 13I0-7, impacts to riparian areas at the Morro Creek crossing would be less than significant. The proposed IPR West and IPR East wellfield areas contain Morro Creek and Little Morro Creek that support riparian habitat; however, the proposed injection and monitoring wells would be located on vacant, disturbed lands owned by the City and would be sited to avoid sensitive habitat areas like riparian habitat. With implementation of Mitigation Measures BIO-I, BI0-2, 3I0-6 and BI0-7, impacts to riparian areas within the proposed IPR-West and IPR-East wellfields would be less than significant. Construction operation of other project components would have less than significant or no impact associated with sensitive natural communities. Facts in Support of Finding: The City has adopted and will implement the following mitigation measures that will reduce potentially significant Impact 3.4-2 to a less than sign cant level: BIO-6.0 Riparian Habitat Avoidance. During Project design, a qualified biologist shall identify the project boundaries adjacent to Morro Creek and the allowable limits of construction activities to avoid direct and indirect impacts to riparian habitat. Those limits shall be used during Project design to identify a pipeline alignment that avoids impacts to riparian habitat as well as areas to be avoided for siting injection and monitoring wells. During construction, the riparian boundaries and limits shall be clearly flagged or fenced so that contractors are aware of the limits of allowable site access and disturbance. Areas to be preserved should be clearly flagged as offJ limits to avoid unnecessary damage and potential erosion. 01181.0001/495768.1 EXHIBIT A Page 34 of 70 BIO-7: Trenching Buffer for Jurisdictional Features. During construction of Project pipelines, trenching shall stop at least 50 feet away from jurisdictional features, such as the top of stream banks, riparian habitat and wetlands, and the remaining distance shall be installed using trenchless construction methods, such as horizontal directional drilling. Wetlands ® Impact 3.4-3: Construction of proposed conveyance pipelines could result in temporary impacts to wetlands associated with ephemeral drainages; construction of the proposed wells could impact adjacent wetlands associated with Morro Creek and Little Morro Creek. The Project would use trenchless construction methods to install pipelines across wetlands and avoid direct impacts. Siting of the wells in upland areas would avoid direct impacts to wetlands. Implementation of best management practices during construction would minimize indirect impacts to adjacent wetland areas. This would he a Class II impact, Less than Significant with Mitigation. Facts in Support of the Findings: Wetland habitat consistent with the Coastal and Valley Freshwater Marsh and Freshwater Seep described by Holland (1986) was mapped at the tenninus of Drainage 1 adjacent to the wester pipeline alignment as it travels along the bike path next to Quintana Road (refer to Final EIR Figure 3.4-2) and where Drainage 2A crosses the eastern pipeline alignment (refer to Final EIR Figure 3.44). Additionally, the proposed IPR West and IPR East wellfield areas contain Morro Creek and Little Morro Creek and could have adjacent wetlands that have not been identified. Trenching for pipeline installation and well construction could cause direct or indirect temporary impacts to a wetland area, which would be a potentially significant impact. Impacts would be avoided through construction best management practices (BMPs) that would ensure indirect impacts would not occur. The City would be required to prepare a stormwater pollution prevention plan (SWPPP) for the Project in compliance with the NPDES General Construction Permit. The SWPPP would include BMPs to control erosion, sedimentation, and hazardous materials release. In addition, construction of the Project is also subject to the BMPs included in the City's Storm Water Management Plan to control runoff and protect water quality during the construction period. Mitigation Measure BIO-8 includes specific BMPs to be incorporated into the SWPPP to minimize impacts to jurisdictional features. With implementation of Mitigation Measures BIO-1, 13I0-2, BIO-7, and BIO-8, indirect impacts to wetlands associated with Drainage 1 would be less than significant. Trenchless construction methods would be used to cross sensitive surface features such as wetlands. With implementation of such methods, impacts to wetlands at Drainage 2A would be avoided. Mitigation Measure BIO-7 includes requirements for trenching to stop at least 50 feet away from jurisdictional features, such as stream banks and wetlands, and for the remaining distance to be installed using trenchless methods such as HDD, to ensure impacts to wetlands are avoided. Mitigation Measure BIO-9 includes the preparation of a frac-out contingency plan to deal with any inadvertent return of drilling lubricant during HDD beneath wetlands and waterways. With implementation of Mitigation Measure BIO-I, BIO-2, BIO-7, BIO-8 and 3I0-9, impacts to wetlands at Drainage 2A would be less than significant. 01181.0001/495768.1 EXHIBIT A Page 35 of 70 The proposed IPR West and IPR East wellfield areas contain Morro Creek and Little Morro Creek that support riparian habitat and potential wetland areas; however, the proposed injection and monitoring wells would be located on vacant, disturbed lands owned by the City and would be sited to avoid sensitive habitat areas like riparian habitat and wetlands. With implementation of Mitigation Measures BIO-I, BI0-2, BI0-7, and BI0-8, avoidance of these features would be ensured and indirect impacts would be minimized. hnpacts to wetlands within the proposed IPR West and IPR East wellfields would be less than significant. Construction operation of other project components would have less than significant or no impact associated with wetlands. Finding: The City has adopted and will unplement the following mitigation measures that will reduce potentially significant Impact 3.4-3 to a less than significant level: BIO-8: Construction BMPs to Protect JuNisdictional Features and Aquatic Habitat. The following mitigation measures should be implemented prior to and during construction near Morro Creek and Little Morro Creek, as well as Drainages 1, 1A, 1B, 2, 2A, 213, 3, 3A, and 3B, and wetlands: 1. Prior to start of construction activities, the applicant should retain a qualified biological monitor to ensure compliance with all permit requirements and avoidance and minimization measures (i.e.: pre -construction surveys, worker environmental training, and construction monitoring) during work within and adjacent to drainage features. 2. The qualified biological monitor will conduct pre -construction surveys to identify any new wetland areas and the expansion of existing wetland to determine their limits. The results will be used in the implementation of Mitigation Measure BIO-7. 3. Prior to issuance of construction permits, an Erosion Control Plan incorporating up to date Best Management Practices should be prepared by the project engineer to minimize impacts to jurisdictional features and aquatic habitats. The plan should address installation and maintenance of both temporary and permanent measures to control erosion and dust, contain spills, protect stockpiles, and generally maintain good housekeeping practices within the worksite. All project plans should show that erosion, sediment, and dust control measures must be installed prior to start of any ground disturbing work. 4. All applicable plans should clearly show project stockpile and materials staging areas. These areas would be at least 50 feet from drainage features, wetlands, and active storm drain inlets, and must conform to BMPs applicable for storm drain protection. 5. Prior to start of work, the contractor should prepare and implement a Spill Prevention Plan to ensure prompt and effective response to any accidental spills. All workers shall be informed of the importance of preventing spills and of the appropriate measures to take should a spill occur. All project❑related hazardous materials spills 01181.0001/495768.1 EXHIBIT A Page 36 of 70 within the project site should be cleaned up immediately. Spill prevention and cleanup materials should be on ❑ site at all times during the course of the project. 6. All refueling, maintenance, and washing of equipment and vehicles should occur on paved areas in a location where a spill would not travel onto bare ground or to a storm drain inlet. This fueling/staging area will conform to BMPs applicable to i attaining zero discharge of stonnwater runoff. At a mnimum; all equipment and vehicles must be checked and maintained on a daily basis to ensure proper operation and avoid potential leaks or spills. Washing of equipment should occur only in a location where polluted water and materials can be contained for subsequent removal from the site. 7. A designated concrete washout location should be established onsite, in an area at least 50 feet from any drainage or stonn drain inlet. The washout should be maintained and inspected weekly, and will be covered prior to and during any rain event. Concrete debris should be removed whenever the washout container reaches the 1/2 full mark. 8. BMP's for dust abatement shall be a component of the project's construction documents. Dust control requirements should be carefully implemented to prevent water used for dust abatement from transporting pollutants to storm drains leading to the creek channel. 9. During project activities, all trash that may attract predators shall be properly contained, removed from the work site, and disposed of regularly. Following construction, all trash and construction debris shall be removed from work areas. BIO-9: Preparation of a Frac-Out Contingency Plan. AFrac-Out Contingency Plan shall be prepared prior to initiation of construction activities that involve horizontal direction drilling activities. The Frac- Out Plan shall be implemented during HDD construction activities. At a minimum, the Frac-Out Plan will include the following: 1. Minimize the potential for afrac-out associated with horizontal directional drilling activities 2. Provide for the timely detection of frac-outs 3. Protect areas that are considered environmentally sensitive (streams, wetlands, other biological resources, cultural resources) 4. Ensure an organized, timely, and "minimum -impact" response in the event afrac-out and release of drilling mud occurs 5. Ensure that all appropriate notifications are made to the appropriate environmental specialists immediately (e.g., qualified biological monitor), and to appropriate regulatory agencies in 24 hours and that documentation is completed. Migratory Species and Wildlife Corridors • Impact 3.4-4: Construction of the Project could affect southern steelhead, a migratory fish species, in Morro Creek and its critical habitat, as well as native wildlife nursery sites in 01181.0001/495768.1 EXHIBIT A Page 37 of 70 Morro Bay. Implementation of trenchless construction methods to install conveyance pipelines across Morro Creek would avoid direct impacts to steelhead and its habitat. Implementation of a Storm Water Pollution Prevent Plan and best management practices to protect water quality in ephemeral drainages that flow to Morro Creek, Chorro Creek, and Morro Bay would minimize indirect impacts to steelhead and its habitat. This is a Class II impact, Less than Significant with Mitigation. Facts in Support of tt►e Findings: Seasonal habitat is present in Morro Creek and Chorro Creek for southern steelhead, a migratory species, and Morro Creek is identified by USFWS as critical habitat for the species. As described above under Impacts 3.4-1 and 3.4-2, the Project would not have direct impacts to Morro Creek or aquatic species in Morro Creek because trenchless construction methods would be used to install the conveyance pipelines across the creek. Implementation of Mitigation Measures 13I0-7 would also ensure no indirect impacts to Morro Creek would occur during construction of the pipeline crossing by requiring trenching to stop at least 50 feet prior to the top of the stream bank. Southern steelhead is not expected. to occur in the small ephemeral drainages within the study area, but impacts to those features could have detrimental effects downstream in Morro Creek and potentially Chorro Creek and Morro Bay. Proposed project construction may temporarily affect these drainages, but no permanent alteration is expected post -construction. Construction -related impacts to ephemeral drainages could result in potentially significant impacts to aquatic habitat for southern steelhead downstream in Morro Creek or aquatic habitat for native wildlife in Morro Bay. Ensuring sediment -laden runoff does not leave the preferred and Project sites during construction, and that post -construction runoff is consistent with pre -construction conditions is essential to reduce impacts to water quality. The City would be required to prepare a SWPPP for the Project in compliance with the NPDES General Construction Permit. The SWPPP would include BMPs to control erosion, sedimentation, and hazardous materials release. In addition, construction of the Project is also subject to the BMPs included in the City's Storm Water Management Plan to control runoff and protect water quality during the construction period. Mitigation Measure 13I0- 8 includes specific BMPs to be incorporated into the SWPPP to minimize impacts to water quality and ensure there are no significant impacts to aquatic habitat downstream of the ephemeral drainages within the project area. With implementation of Mitigation Measures BIO- 19 BI0-29 BI0-79 BI0-8, and BI0-9, impacts to migratory wildlife or native wildlife nursery sites would be less than significant. Finding: The City has adopted and will implement Mitigation Measures BI04, BI0-2, BI0-7, BIO-8, and BIO-9 to reduce potentially significant Impact 3.4-4 to a less than significant level. These Mitigation Measures are included above for Impacts 3.4-1 (13I0-1 and 13I0-2), 3.4-2 (13I0- 7), and 3.4-3 (13I0-8 and 13I0-9) above. Local Policies and Ordinances • Impact 3.4-5: Construction of the Project could affect streams, which are designated as Environmentally Sensitive Habitat Areas. The Project would use trenchless construction methods to install pipelines across streams and avoid direct impacts. Implementation of best 01181.0001/495768.1 EXHIBIT A Page 38 of 70 management practices during construction would minimize indirect impacts to streams. While no trees are expected to be removed, construction of the Project could impact protected trees within the City limits. Protection measures would be put in place to avoid impacts from construction activities. This would be a Class II impact, Less than Significant with Mitigation. Facts in Support of the Findings: ESHA. The City Coastal Land Use Plan (CLUP) Chapter XII provides definitions of ESHA within the City limits, and identifies coastal streams and riparian areas as follows: "A Stream or a River is a natural watercourse as designated by a solid line or dash and three dots symbol as shown on the USGS Survey map most recently published, or any well ❑ defined channel with distinguishable bed and bank that shows evidence of having contained flowing water as indicated by scour or deposit of rock, sand, gravel, soil, or debris." The County also includes coastal streams and wetlands in its description of ESHA. As such, Morro Creek and the ephemeral drainages would be considered coastal stream ESHA. Construction of the proposed WU and conveyance pipelines have the potential to result in temporary direct and indirect significant impacts to Morro Creek, ephemeral drainages, and wetlands as described above under Impact 3.4- 2 and Impact 3.4-3. Implementation of Mitigation Measures BIO-I, BI0-2, 1[3I0-6, 13I0-7, 3I0-8, and BIO-9 would ensure there are no significant impacts to Morro Creek or ephemeral drainages, and as such, impacts to ESHA would be less than significant. While the County LCP does identify rare or unusual native plant communities as ESHA, it does not specifically state native perennial grasslands shall be protected. While native grasslands dominated by purple needlegrass are relatively common in the general area (KMA personal observation), the small occurrences of native bunchgrass grassland in the WRF site study area site were intermixed with San Luis Obispo owl's clover, a special -status plant, and therefore should be considered ESHA. However, the proposed WRF facility would be developed outside of the areas that support San Luis Obispo owl's clover and purple needlegrass, and as such its construction would not impact the ESHA. And no mitigation is required. Public Trees. Ornamental trees such as blue gum eucalyptus and Monterey cypress are present along the proposed western and eastern pipeline alignments within the City's limits. Depending on the location of the pipeline to the proposed WU, trees may or may not be impacted. It is anticipated all trees would be avoided by the Project, and those within 25 feet of the limits of disturbance would have protective measures put in place to ensure they remain uninjured during the course of construction. No direct removal of protected trees is expected from the operation of the Project. To minimize impacts during construction, Mitigation Measure BI040 will be implemented to protect any adjacent trees from construction activities. With implementation of Mitigation Measure 13I0-10, impacts to protected trees would be less than significant. Finding: The City has adopted and will implement Mitigation Measures BI04, BI0-2, BI0-69 BIO-7, BIO-8, BIO-9, and BIO-10 reduce Impact 3.4-5 to a less than significant level. These Mitigation Measures are included above for Impacts 3.44 (13I04 and 13I0-2), 3.4-2 (13I0-6 and 3I0-7), and 3.4-3 (BIO-8 and 13I0-9) above. Mitigation Measure BI040 is described below: 01181.0001/495768.1 EXHIBIT A Page 39 of 70 BI0-10: Tree Protection. For public trees, protection will be established at a minimum distance of 1.5 times the dripline (i.e.. the distance from the trunk to the outermost limits of leaves and branches). During development, orange construction fencing or sufficient staking to identify the protection area will surround each tree or clusters of trees. 5.4.4 Cultural Resources Paleontological Resources ® Impact 3. S-2: Construction -related excavation for the Project could affect a unique paleontological resource. Implementation of worker training and monitoring during construction would reduce the potential for adverse effects to paleontological resources. This would be a Class II impact, Less than Significant with Mitigation, facts in Support of the Finding: The proposed and preferred project sites are underlain by a variety of geologic units, all of which have low to no paleontological sensitivity (refer to Final EIR Table 3.5-1). However, the portions of those sites underlain by alluvial gravel (Qa) and each and dune sands (Qs) increase sensitivity at depth since higher sensitivity older sediments may underlie them. The LACM did not identify any fossil localities within the project site, but two fossil localities (LACM 5903 and 5790) were identified within older Quaternary deposits located approximately 2 miles and 22 miles from the project site, respectively. Fossil locality LACM 5903 produced a fossil specimen of mastodon (Mammutidae) in stream gravels at a depth of 6 feet below the ground surface. Fossil locality LACM 5790 produced a fossil specimen of mammoth (Mammuthus) at shallow but unstated depth (Draft EIR, page 3.5-30). WRF. The preferred WRF site is underlain by alluvial gravel (Qa), Franciscan rocks, melange (fm), and serpentine (sp), which have low or no paleontological sensitivity. The portions of the proposed WRF located on alluvial gravel (Qa) increase sensitivity at depth since higher sensitivity older sediments may underlie the younger deposits. If construction -related excavation for the proposed WRF extends into older deposits, then it could impact unique paleontological resources. Implementation of Mitigation Measures CUL40 through CUL43 would reduce impacts to less than significant. Lift Station. The proposed lift station is underlain by alluvial gravel (Qa), which has low paleontological sensitivity. However, sensitivity increases at depth since higher sensitivity older sediments may underlie the younger deposits. If construction -related excavation for the proposed lift station extends into older deposits, then it could impact unique paleontological resources. Implementation of Mitigation Measures CUL40 through CUL-13 would reduce impacts to less than significant. Conveyance Pipelines. The proposed conveyance pipelines are underlain by alluvial gravel (Qa), beach and dune sands (Qs), and Franciscan rocks, melange (fm), which have low or no paleontological sensitivity. The portions of the proposed conveyance pipelines located on alluvial gravel (Qa) and beach and dune sands (Qs) increase sensitivity at depth since higher sensitivity older sediments may underlie the younger deposits. If construction -related excavation for the conveyance pipelines extends into older deposits, then it could impact unique paleontological 01181.0001/495768.1 EXHIBIT A Page 40 of 70 resources. Implementation of Mitigation Measures CUL40 through CUL43 would reduce impacts to less than significant. Injection and Monitoring Wells. The proposed IPR East and IPR West wellfield areas are underlain by alluvial gravel (Qa), Franciscan rocks, greenstone (fg) and Franciscan rocks, graywacke sandstone (A), which have low or no paleontological sensitivity. The portions of the proposed IPR East and IPR West wellfield areas located on alluvial gravel (Qa) increase sensitivity at depth since higher sensitivity older sediments may underlie the younger deposits. If construction -related excavation for the proposed injection and monitoring wells extends into older deposits, then it could impact unique paleontological resources. Implementation of Mitigation Measures CUL40 through CUL43 would reduce impacts to less than significant. Decommissioning of Current WWTP. The WWTP is underlain by alluvial gravel (Qa) and beach and dune sands (Qs), which have low paleontological sensitivity. Those sediments increase sensitivity at depth since higher sensitivity older sediments may underlie the younger deposits. Ground -disturbance associated with decommissioning of the current WWTP includes removal of pipelines from at least 4-5 feet below ground surface. If construction -related excavation for the decommissioning of the WWTP extends into older deposits, then it could impact unique paleontological resources. Implementation of Mitigation Measures CUL40 through CUL43 would reduce impacts to less than significant. Operation -All Facilities. Although there is unlikely to be ground disturbance associated with the operation of the Project facilities, there is potential ground disturbance could occur during maintenance or repair of these facilities. If ground disturbance occurred within areas that have not been previously disturbed extend into paleontologically sensitive sediments, then there is the potential to impact unique paleontological resources. Implementation of Mitigation Measures CUL43 would reduce impacts to less than significant. Finding: The City has adopted and will implement Mitigation Measures CUL-10 through CUL-13 to reduce potentially significant Impact 3.5-2 to a less than significant level. These include: CUL-10: Retention of a Qualified Paleontologist. Within 60 days prior to the start of any ground -disturbing activity (i.e., demolition, pavement removal, pot -holing or auguring, boring, drilling, grubbing, vegetation removal, brush clearance, weed abatement, grading, excavation, trenching, or any other activity that has potential to disturb soil), the City shall retain a paleontologist who meets the SVP Standards (SVP, 2010) (Qualified Paleontologist) to carry out all mitigation measures related to paleontological resources. 7 UL41: Paleontological Resources Sensitivity Training. The Qualified Paleontologist, or .his/her designee, shall conduct construction worker paleontological resources sensitivity training prior to the start of ground disturbing activities. In the event construction crews are phased, additional trainings shall be conducted for new construction personnel. The training session shall focus on the recognition of the types of paleontological resources that could be encountered within the project site and the procedures to be followed if they are found. The City shall ensure construction personnel are made available for and attend the training and retain documentation demonstrating attendance. That training may be conducted in 01181.0001/495768.1 EXHIBIT A Page 41 of 70 coordination with construction worker cultural resources sensitivity training required by CUL- 6. CUL-12I Paleontological Resources Monitoring. All ground disturbance in excess of 5 feet within areas that are mapped as younger alluvial gravel (Qa) and beach and dune sands (Qs) shall be monitored on a full-time basis during initial ground disturbance. The Qualified Paleontologist shall spot check the excavation on an intermittent basis and recommend whether the depth of required monitoring should be revised based on his/her observations. If the Qualified Paleontologist determines full-time monitoring is no longer warranted, based on the specific geologic conditions at the surface or at depth, then the Qualified Paleontologist may recommend that monitoring be reduced to periodic spot-checking or cease entirely. Paleontological resources monitoring shall be performed by a qualified paleontological monitor (meeting the standards of the SVP, 2010) under the direction of the Qualified Paleontologist. Monitors shall have the authority to temporarily halt or divert work away from exposed fossils in order to recover the fossil specimens. Any significant fossils collected during project -related excavations shall be prepared to the point of identification and curated into an accredited repository with retrievable storage. Monitors shall prepare daily logs detailing the types of activities and soils observed, and any discoveries. The Qualified Paleontologist shall prepare a Paleontological Resources Monitoring Report detailing the locations of monitoring and any discoveries. The report shall be submitted to the City within 60 days after completion of the monitoring program, or treatment for significant discoveries should treatment extend beyond the cessation of monitoring. CUL-13: Inadvertent Discovery of Fossils. If construction or other Project personnel discover any potential fossils during construction, regardless of the depth of work or location, then work at the discovery location shall cease in a 50-foot radius of the discovery until the Qualified Paleontologist has assessed the discovery and made recommendations as to the appropriate treatment. If the find is deemed significant, it shall be salvaged following the standards of the SVP (2010) and curated with a certified repository. 5.4.5 Geology Earthquakes ® Impact 3.6-1: The geologic conditions at the Project sites include potential for seismic - induced ground shaking, liquefaction, and landslides that could damage structures or cause injury to employees at manned facilities. However, implementation of engineering design criteria as specified by required geotechnical investigations would reduce the risk of loss, injury, or death. This impact would be Class II, Less than Significant with Mitigation. Facts in Support of the Finding: Fault Rupture and Seismic Ground Shaking. None of the Project facilities would be located within an Alquist-Priolo Fault Zone and thus not located adjacent to an active fault that would be susceptible to fault rupture. However, the entire Project area lies within a region that is seismically active. Multiple "potentially active" faults are located near the Project area, such as the Cambria Fault; the closest "active fault" to the Project area is the Los Osos fault, approximately 8 miles southwest. Ground shaking could result in structural damage to new facilities, which in turn could affect operation of related systems. Most of the Project's facilities are non -habitable; however, full time employees would be on -site at the proposed WRF and may 01181.0001/495768.1 EXHIBIT A Page 42 of 70 need to access the various facilities for maintenance or manual control purposes. Therefore, structural and mechanical failure of Project facilities onset by seismic ground shaking could occur and would potentially threaten the safety of on -site workers. This would be a potentially significant impact. The City has prepared a Preliminary Geotechnical Investigation for the proposed WRF site (see Appendix E). During the design process for the proposed WRF and all other facilities, site - specific geotechnical investigations would be implemented to detennine the geologic conditions and associated design requirements needed to ensure the new facilities would withstand ground shaking. With implementation of Mitigation Measure GE04, which requires the preparation of site -specific geotechnical investigations and incorporation of structural recommendations into facility designs, potential impacts associated with ground shaking would be reduced to less than significant levels. Liquefaction. All project facilities except the WRF site would be located within a Seismic Hazard Zone for liquefaction and are areas designated as having moderate to high liquefaction potential (Draft EIR, page 3.6-15). Thus, in the event of a large earthquake with a high acceleration of seismic shaking, the potential for liquefaction exists. As a result, structural damage could occur to the lift station, conveyance pipelines, and injection and monitoring wells. This would be a potentially significant impact. There would be no impact to the WWTP once it is deconstructed and decommissioned. Mitigation Measure GEO-1 would require project components to undergo a design level geotechnical investigation and be designed to resist damage from seismic shaking. All geotechnical recommendations provided by the Project geotechnical engineer would be incorporated into Project designs in areas where liquefiable soils are identified, if applicable. Implementation of Mitigation Measures GEO-1 would reduce potential impacts related to liquefaction to less than significant levels. Landslides. According to the Project's Preliminary Geotechnical and Geologic Hazards Report, there is no evidence of landslides in the area to be developed for the proposed WRF. However, small superficial landslides have occurred just northwest of the proposed WRF site, and the proposed WRF site is located within a State -designated Seismic Hazard Zone for Earthquake Induced -Landslides (Draft EIR, page 3.6-16). Therefore, there is potential for seismically - induced landslides to occur within and around the proposed WRF site. As a result, structural damage could occur to the proposed WRF. This would be a potentially significant impact. Implementation of Mitigation Measure GE04 would require Project components undergo a final geotechnical investigation and be designed to resist damage from seismic shaking including seismically -induced landslides. All geotechnical recommendations provided by the Project geotechnical engineer would be incorporated into Project designs in areas where high landslide susceptibility is identified. Implementation of Mitigation Measure GEO-I would control the design and location of buildings and structures in order to safeguard the public and reduce potential impacts related to landslides to less than significant. 01181.0001/495768.1 exHierr a Page 43 of 70 Construction/operation of all other project components would have less than significant or no impact associated with earthquakes. Finding: The City has adopted and will implement the following mitigation measures to reduce potentially significant Impact 3.6-1 to a less than significant level: GEO-1: Geotechnical Investigation. A geotechnical investigation shall be prepared by a certified engineer for all facilities involving substantial ground disturbance or excavation. The investigation shall assess geologic and seismic hazards, including but not limited to, subsidence, liquefaction, landslide, expansive soil potential and collapsible soil potential of each facility site. Structural mitigation recommendations provided in the geotechnical investigation shall be incorporated into the design of the facility prior to construction. The contents of the geotechnical investigation shall vary depending on the jurisdiction and risks associated with each facility's location. Soil Erosion or Topsoil Loss ® Impact 3.6-2: Construction of Project facilities would result in ground disturbance and exposure of soils to erosion. Implementation of best management practices during construction and site restoration post- construction would minimize the potential for soil erosion or loss of top soil. This impact would be Class II, Less than Significant with Mitigation. Facts in Support of the Finding: For the conveyance pipelines, after construction is complete, the trenches would be backfilled with soils that could be subject to erosion at the surface. This would be a potentially significant impact. To prevent erosion from occurring after the construction of pipelines is complete, the area of disturbance would be restored to pre - construction conditions. Such restoration would minimize potential impacts associated with erosion. In addition, post -construction best management practices would be implemented as necessary in accordance with the NPDES General Construction Permit, to ensure erosion is controlled during project operation. Implementation of Mitigation Measure GEO-2 would require post -construction restoration. Impacts would be considered less than significant after implementation of Mitigation Measure GEO-2. Construction operation of all other project components would have less than significant or no impact associated with soil erosion or topsoil loss. Finding: The City has adopted and will implement the following mitigation measures to reduce potentially significant Impact 3.6-2 to a less than significant level: GEO-2: Post -Construction Site Restoration. After construction of project pipelines, disturbed areas shall be managed to control erosion, including without limitation: repaving areas within roadways, restoring vegetated areas, and regrading surfaces to minimize changes in drainage patterns. 01181.0001/495768.1 EXHIBIT A Page 44 of 70 Geologic Instability • Impact 3.6-3: The geologic conditions at various Project sites include potential for liquefaction, landslides, lateral spreading, and collapsible soils. However, implementation of engineering design criteria as specified by required geotechnical investigations would reduce the potential for the Project to result in unstable soils. This impact would be Class II, Less than Significant with Mitigation. Facts in Support of the Finding: WRF. There is potential for landslides at the WRF site. The Preliminary Geotechnical Report explained that the upper several feet of soils at the site are not considered suitable for supporting proposed improvements without modification (Draft EIR, page 3.6-16). Therefore, impacts related to landslides are potentially significant. hnplementation of Mitigation Measure GEO-1 would require Project components to undergo a final geotechnical investigation and be designed to resist damage from landslides. All geotechnical recommendations provided by the Project geotechnical engineer would be incorporated into Project designs in areas where high landslide susceptibility is identified. Implementation of Mitigation Measure GEO-1 would control the design and location of buildings and structures in order to safeguard the public and reduce potential impacts related to landslides to less than significant. L f Station, Conveyance Pipelines, Injection and Monitoring Wells, and Decommissioning of Current WWTP. The lift station, conveyance pipelines, injection and monitoring wells, and current WWTP site are subject to liquefaction as discussed under Impact 3.6-1, and could result in collapsible soils. Because these areas are subject to liquefaction, there is also a potential for lateral spreading. No on- or off -site landslides would occur within these areas because the sites are relatively flat. Due to the characteristics of the soils and geology, the Project could be exposed to liquefaction, collapsible soils and lateral spreading and result in damage from unstable soils if not designed appropriately. Thisssis a potentially significant impact. Implementation of Mitigation Measure GEO-1 would require that project components undergo a final geotechnical investigation and be designed to resist damage from geologic hazards, such as liquefaction, collapsible soils, and lateral spreading. All geotechnical recommendations provided by the Project geotechnical engineer would be incorporated into Project designs. Implementation of Mitigation Measure GEO-1 would control the design and location of buildings and structures in order to safeguard the public and reduce potential impacts related to liquefaction, collapsible soils, and lateral spreading to less than significant. Finding: The City has adopted and will implement Mitigation Measure GE04, which is included above for Impact 3.6-1; Mitigation Measure GEO-1 will reduce potentially significant Impact 3.6-3 to a less than significant level. Expansive Soils • Impact 3.6-4: The Project facilities could be located on expansive soils, which could create risks to life or structures. However, implementation of engineering design criteria as specified by required geotechnical investigations would reduce the risk of loss or injury. This impact would be Class II, Less than Significant with Mitigation. 01181,0001/495768.1 EXHIBIT A Page 45 of 70 Facts in Support of the Finding: WRF. When expansive soils swell, the change in volume can exert significant pressures on loads that are placed on them, such as loads resulting from structure foundations or underground utilities, and can result in structural distress and/or damage. Near -surface samples of soil from the proposed WRF site consists of sandy lean clay, sandy fat clay, decomposed greywacke, and clayey sand. The soils are characterized as having moderate shrink -swell potential (moderately expansive) (Draft EIR, page 3.6-8). The presence of expansive soils could decrease the structural stability of the proposed WRF facilities, which could result in structural or operational failure of proposed facilities and/or threaten the health and safety of on -site workers. This is a potentially significant impact. hnpacts associated with geologic site conditions are mitigated through engineering design criteria that ensure structures are built to withstand hazards such as expansive soils. Preparation of a site - specific geotechnical investigation would provide the appropriate geotechnical requirements to include in facility design criterial. Implementation of Mitigation Measure GE04 would require preparation of site -specific geotechnical investigations that would include corrective actions for potential expansive soils. In addition, the Project would be subject to the CBC which controls the design and location of facilities in order to safeguard the public. With implementation of Mitigation Measure GEO-1, impacts related to expansive soils would be less than significant. Lift Station, Conveyance Pipelines, Injection and Monitoring Wells, and Decommissioning of Current WWTP. The soils within the areas where the proposed lift station, conveyance pipelines, wells, and existing WWTP sites would be located consist of unconsolidated sands, clays and fill materials from prior development. Sandy soils and fill are not typically expansive; however, clay soils exhibit expansive properties and may also underlay areas of fill materials. If project components are located on expansive soils, the structural stability of proposed facilities could decrease, resulting in structural or operational failure. This is a potentially significant impact. As described above, impacts associated with geologic site conditions are mitigated through engineering design criteria that ensure structures are built to withstand hazards such as expansive soils. Preparation of a site -specific geotechnical investigation would provide the appropriate geotechnical requirements to include in facility design criterial. Implementation of Mitigation Measure GEO-1 would require preparation of site -specific geotechnical investigations that would include corrective actions for potential expansive soils. In addition, the Project would be subject to the CBC which controls the design and location of facilities in order to safeguard the public. With implementation of Mitigation Measure GEO-1, impacts related to expansive soils would be less than significant. Finding: The City has adopted and will implement Mitigation Measure GEO-1, which can be found above for Impact 3.6-1; Mitigation Measure GEO-1 will reduce Impact 3.6-4 to a less than significant level. 01181.0001/495768.1 EXHIBIT A Page 46 of 70 Emergency Response ® Impact 3.8-6: Construction of Project components within public Nights -of -way could result in partial or full lane closures and/or blocked access to roadways, which could physically interfere with an emergency response or evacuation plan. However, implementation of a Traffic Control Plan would require construction contractors to notify emergency responders including the City's Fire Department, Police Department and ambulances of planned road closures and roadway blockages. This impact would be Class II, Less than Significant with Mitigation. Facts in support of the Finding: Construction of the collection and distribution systems would occur within public right-of-way (ROW), adjacent to roadways, and on City -owned property. Construction activities within the roadway ROW would require either partial or full lane closures and/or blocked access to roadways, which could physically interfere with an emergency response or evacuation plan. Mitigation Measure TRAF4 would require construction contractors to notify emergency responders including the City's Fire Departments, Police Department and ambulances of planned road closures and roadway blockages as part of the Traffic Control Plan. With incorporation of Mitigation Measure TRAF-1, impacts related to interfering with emergency response or evacuation plans would be reduced to a less than significant level. Construction/operation of all other project components would have less than significant or no impact associated with emergency response. Finding: The City has adopted and will implement Mitigation Measure TRAF-1 to reduce potentially significant Impact 3.8-6 to a less than significant level. TRAF-1: Traffic Control Plan. Prior to the start of construction of project components that would occur within a roadway right -of --way, the City shall require the construction contractor to prepare a Traffic Control Plan. The Traffic Control Plan will show all signage, striping, delineated detours, flagging operations and any other devices that will be used during construction to guide motorists, bicyclists, and pedestrians safely through the construction area and allow for adequate access and circulation to the satisfaction of the City's Public Works Director and Fire and Police Chiefs. When construction activities disrupt travel on major collectors or arterials, electronic signing shall be used to provide the public, on all transportation modes, with current construction information and the availability of alternate travel routes. The Traffic Control Plan will be prepared in accordance with the City's traffic control guidelines and will be prepared to ensure that access will be maintained to individual properties, and that emergency access will not be restricted. Additionally, the Traffic Control Plan shall also include a scheduling plan showing the hours of operation to minimize congestion during the peak hours and special events. The scheduling plan will ensure that congestion and traffic delay are not substantially increased as a result of the construction activities. Further, the Traffic Control Plan will include detours or alternative routes for bicyclists using on -street bicycle lanes as well as for pedestrians using adjacent sidewalks. 01181.0001/495768.1 EXHIBIT A Page 47 of 70 In addition, the City shall provide written notice at least two weeks prior to the start of construction to owners/occupants along streets to be affected during construction. During construction, the City will maintain continuous vehicular and pedestrian access to any affected residential driveways from the public street to the private property line, except where necessary construction precludes such continuous access for reasonable periods of time. Access will be reestablished at the end of the workday. If a driveway needs to be closed or interfered with as described above, the City shall notify the owner or occupant of the closure of the driveway at least five working days prior to the closure. The Traffic Control Plan shall include provisions to ensure that the construction of the lift station, conveyance pipelines, and the IPR injection and monitoring wells do not interfere unnecessarily with the work of other agencies such as mail delivery, school buses, and municipal waste services. The City shall also notify local emergency responders of any planned partial or full lane closures or blocked access to roadways or driveways required for construction of the Project facilities. Emergency responders include fire departments, police departments, and ambulances that have jurisdiction within the Project area. Written notification and disclosure of lane closure location must be provided at least 30 days prior to the planned closure to allow for emergency response providers adequate time to prepare for lane closures. 5.4.7 Hydrology Alteration of ®rainage Patterns • Impact 3.94: Installation of the Project components would alter topography and drainage patterns at each site; however, compliance with the City's Storm Water Management Plan and other NPDES regulatory requirements would minimize erosion, siltation, and flooding onsite and offsite. Implementation of mitigation requiring post -construction restoration of conveyance pipeline alignments would also ensure long-term impacts associated with erosion, siltation or flooding during storm events would be minimized. This is a Class II impact, Less than Significant with Mitigation. Facts in Support of the Finding: Once constructed, Project pipelines would be underground. The trenches or tunnels that would be created to install the pipelines would be backfilled and the residual post -construction disturbance at the ground surface could alter the local topography and drainage, resulting in onsite and offsite erosion, siltation, or flooding during storm events. That is a potentially significant impact. To mitigate that potential impact, after construction is complete, the area of disturbance for conveyance pipelines would be restored in accordance with Mitigation Measure GEO-2 such that there would be negligible change to drainage patterns. The result would be a less than significant impact with mitigation related to erosion, siltation or flooding. Construction operation of all other project components would have less than significant or no impact associated with alteration of drainage patterns. 01181.0001/495768.1 EXHIBIT A Page 48 of 7D Finding: The City has adopted and will implement Mitigation Measure GEO-2 to reduce potentially significant hnpact 3.94 to a less than significant level. GE0-2: Post -Construction Site Restoration. After construction of project pipelines, disturbed areas shall be managed to control erosion, including without limitation: repaving areas within roadways, restoring vegetated areas, and regrading surfaces to minimize changes in drainage patterns. 5.4.8 ►Noise Compliance viiifh Noise Standards ® Impact 3.11-1: Construction of the proposed injection and monitoring wells would require continuous drilling for 24-hour periods, at noise levels in excess of standards established in the Morro Bay Municipal Code. Implementation of a Construction Noise Reduction Plan approved by the City's building official would reduce noise levels to acceptable levels. This would be a Class II impact, Less than Significant with Mitigation. Facts in Snpport of the Finding: The construction activities associated with the proposed injection/monitoring wells would occur within the jurisdiction of the City. The City's noise ordinance exempts activities associated with construction provided they occur from 7:00 a.m. to 7:00 p.m. Monday through Friday or from 8:00 a.m. to 7:00 p.m. Saturday or Sunday. Construction activities that occur outside of these construction exempt hours must submit an application to the City's building official requesting permission to work outside the allowed construction hours. Construction of injection wells would include site preparation, mobilization of equipment to the well site, well drilling, water quality testing, installation of the well casing, gravel packing and finishing with a cement seal. For approximately one month, daily 24-hour drilling would be required. To drill the well, the drill rig must run 24 hours -a -day. The nearest sensitive receptors to the wells sites could be exposed to construction -related noise levels outside of the allowed construction hours provided in the City's noise ordinance. This would be a potentially significant impact. To address potential impacts, the City would prepare and implement a Construction Noise Reduction Plan, that would be submitted and approved by the City's building official in accordance with Subdivision 9.28.030. I. of the Morro Bay Municipal Code (MBMC). The Construction Noise Reduction Plan would demonstrate that no loss or inconvenience would result to any party of interest as a result of project construction. Implementation of the Plan as required by Mitigation Measure NOISE-1 would ensure well drill activities would not result in a violation of the MBMC. Therefore, this impact would result in a less than significant impact after mitigation. Construction/operation of all other project components would have less than significant or no impact associated with noise standard compliance. Finding: The City of Morro Bay has adopted and will implement Mitigation Measure NOISE -I to reduce potentially significant Impact 3.11-1 to a less than significant level. 01181.0001/495768.1 EXHIBIT A Page 49 of 70 NOISE-1: Construction Noise Reduction Measures. The City shall develop and submit a Construction Noise Reduction Plan to the building official prior to initiating construction activities during hours that are not included in the exemption under the MBMC. The City or its contractor shall implement the Construction Noise Reduction Plan. A disturbance coordinator shall be designated for the project to implement the provisions of the Plan. At a minimum, the Construction Noise Reduction Plan shall implement the following measures: • Distribute to the potentially affected residences and other sensitive receptors within 150 feet of project construction boundary a "hotline" telephone mm�berwhich shall I be attended during active construction working hours, for use by the public to register complaints. The distribution shall identify a noise disturbance coordinator who would be responsible for responding to any local complaints about construction noise. The disturbance coordinator would determine the cause of the noise complaints and institute feasible actions warranted to correct the problem. All complaints shall be logged noting date, time, complainant's name, nature of complaint, and any corrective action taken. The distribution shall also notify residents adjacent to the project site of the construction schedule. • All construction equipment shall have intake and exhaust mufflers recommended by the manufacturers thereof, to meet relevant noise limitations. • Maintain maximum physical separation, as far as practicable, between noise sources (construction equipment) and sensitive noise receptors. Separation may be achieved by locating stationary equipment to minimize noise impacts on the community. • Impact tools (e.g., jack hammers, pavement breakers) used during construction activities will be hydraulically or electrically powered where feasible to avoid noise associated with compressed air exhaust from pneumatically powered tools. Where use of pneumatic tools is unavoidable, an exhaust muffler on the compressed air exhaust shall be used. • Use construction noise barriers- such as paneled noise shields, blankets, or enclosures adjacent to noisy stationary equipment. Noise control shields, blankets or enclosures shall be made featuring a solid panel and a weather -protected, sound -absorptive material on the construction -activity side of the noise shield. Compliance with Noise Standards • Impact 3.11-2: Operation of the proposed injection wells in close proximity to sensitive receptors could generate noise in excess of standards established in the Morro Bay Municipal Code. A qualified noise consultant will determine the noise reduction measures to be incorporated into project design to ensure noise levels would not exceed the City's daytime and nighttime noise standards. This would be a Class II impact, Less than Significant with Mitigation. 01181.0001/495768.1 EXHIBIT A Page 50 of 70 Facts in Support of the Finding: The stationary noise sources associated with the proposed injection wells in either the IPR West or IPR East areas would include the pump motors and emergency backup generators. Assuming both the pump motors and emergency backup generator are operating at the same time and are fully enclosed, the nearest sensitive receptor to one of the proposed injection wells could be exposed to a noise level of 63 dBA Leq during operation, which would exceed the City's daytime and nighttime noise standards. There would be a potentially significant impact with respect to exposure of persons to, or generation of, noise levels in excess of standards found in the General Plan. Prior to fugal design of the proposed injection wells, the City would prepare an Operational Noise Reduction Plan demonstrating the proposed wells would not expose the nearest sensitive receptor to noise levels that would exceed the City's daytime and nighttime noise standards (see Final EIR Table 3.11-4). The Operational Noise Reduction Plan would be prepared by a qualified noise consultant. Once all noise reduction measures outlined in the Operational Noise Reduction Plan are implemented, the City would measure noise at the nearest sensitive receptor property line to validate the effectiveness of the measures and to demonstrate that operational noise levels are below the City's noise standards. huplementation of the Operational Noise Reduction Plan, as required by Mitigation Measure NOISE-2, would reduce the Project's impact to a less than significant level. Construction/operation of all other project components would have less than significant or no impact associated with noise standard compliance. Finding: The City has adopted and will implement Mitigation Measure NOISE-2 to reduce potentially significant Impact 3.11-2 to a less than significant level. NOISE-2: Operational Noise Reduction Measures. Prior to final design of the proposed injection wells, the City shall prepare an Operational Noise Reduction Plan demonstrating that the proposed injection wells will not expose the nearest sensitive receptor to noise levels that would exceed the City's daytime and nighttime noise standards (see Final EIR Table 3.11-4). The operational noise reduction plan shall be prepared by a qualified noise consultant. Once all noise reduction measures outlined in the Operational Noise Reduction Plan are implemented, the City shall measure noise at the nearest sensitive receptor property line to validate the effectiveness of the measures and to demonstrate that operational noise levels are below the City's noise standards. Ambient Noise Levels ® Impact 3.11-4: Operation of the proposed injection wells in close proximity to sensitive receptors could result in a substantial permanent increase in ambient noise levels. A qualified noise consultant will determine the noise reduction measures to be incorporated into project design to ensure operational noise levels do not exceed the City's daytime and nighttime noise standards. This would be a Class II impact, Less than Significant with Mitigation. 01181.0001/495768.1 EXHIBIT A Page 51 of 70 Facts in Support of the Finding: The stationary noise sources associated with the proposed injection wells in either the IPR West or IPR East wellfield areas would include the pump motors and emergency backup generators. Assuming that both the pump motors and emergency backup generator are operating at the same time and are fully enclosed, the nearest sensitive receptor to the proposed injection/monitoring wells would be exposed to operational noise that would exceed the applied 5-0 substantial increase threshold. There would be a potentially significant impact with i respect to substantial permanent nicrease in ambient noise levels in the Project vicnity above levels existing without the Project. As described for Impact 3.11-2, prior to final design of the proposed injection wells, the City would prepare an Operational Noise Reduction Plan demonstrating that the proposed wells would not expose the nearest sensitive receptor to noise levels that would exceed the City's daytime and nI ghttime noise standards. The Operational Noise Reduction Plan would be prepared by a qualified noise consultant. Once all noise reduction measures outlined in the Operational Noise Reduction Plan are implemented, the City would measure noise at the nearest sensitive receptor property line to validate the effectiveness of the measures and to demonstrate that operational noise levels are below the City's noise standards, which would mitigate any increases in ambient noise. Implementation of the Operational Noise Reduction Plan, as required by Mitigation Measure NOISE-2, would reduce the Project's impact to a less than significant level. Construction operation of all other project components would have less than significant or no impact associated with ambient noise levels. Finding: The City has adopted and will implement Mitigation Measure Noise-2, included above for Impact 3.11-2, which will reduce potentially significant Impact 3.114 to a less than significant level. Permanent Increases in Ambient Noise Levels ® Impact 3.11-5: Construction of the proposed injection and monitoring wells would require continuous drilling for 24-hour periods, which would result in temporary increases in ambient noise levels. Implementation of a Construction Noise Reduction Plan_ approved by the City's building official would reduce noise levels to acceptable levels. This would be a Class II impact, Less than Significant with Mitigation. Facts in Support of the Finding: The sensitive receptors located within 50 feet of the proposed injections/monitoring wells would be exposed to noise levels of 80 dBA Leq during construction. Although construction noise levels would not exceed the applied 90 dBA Leq temporary substantial noise increase threshold, nighttime drilling at the proposed well sites could expose nearby sensitive receptors to levels that would interfere with sleep or result in human annoyance. There would be a potentially significant impact with respect to temporary substantial increase in ambient noise levels in the Project vicinity above levels existing without the Project. To reduce noise levels during drilling of the proposed injection and monitoring wells, the City would prepare and implement a Construction Noise Reduction Plan, that would be submitted and approved by the City's building official in accordance with Subdivision 9.28.030 I. of the 01181.0001/495768.1 exHiair a Page 52 of 70 MBMC. The construction Noise Reduction Plan would demonstrate that no loss or inconvenience would result to any party of interest, such as neighboring sensitive receptors. Measures to be implemented would include a noise disturbance coordinator responsible for fielding noise complaints and instituting feasible corrections; locating construction equipment as far away from sensitive receptors as possible; and using noise barriers such as acoustic shields, blankets or enclosures. Implementation of the Plan as required by Mitigation Measure NOISE -I would reduce temporary construction noise and minimize disturbance to sensitive receptors. Therefore, this impact would result in a less than significant impact after mitigation. Construction/operation of all other project components would have less than significant or no impact associated with ambient noise levels. Finding: The City has adopted and will implement Mitigation Measure NOISE -I, included above for Impact 3.11-1, which will reduce potentially significant Impact 3.11-5 to a less than significant level. 5.4.9 Traffic Circulation System and Congestion Management ® Impact 3.14-1: Construction of the Project would result in partial lane closures, which could significantly impact the operations of the local and regional circulation systems. However, implementation of a Traffic Control Plan would reduce impacts to a less than significant level. This impact would be Class II, Less than Significant with Mitigation. Facts in Support of the Finding: The Project would construct a new lift station near the existing WWTP, a raw wastewater and brine/wet weather discharge pipeline from the proposed lift station to the proposed WRF site, and IPR injection and monitoring wells with a proposed recycled water pipeline to the preferred WRF site. Construction of these project components may require partial closure of traffic lanes, which could significantly impact the performance of applicable roadways. This would be a potentially significant impact. In order to reduce impacts to roadway performance during construction of the lift station, conveyance facilities, and the IPR injection and monitoring wells, the City would be required to prepare and implement a Traffic Control Plan. The Traffic Control Plan would include, but not be limited to, signage, striping, delineated detours, flagging operations, changeable message signs, delineators, arrow boards, and K-Rails that will be used during construction to guide motorists, bicyclists, and pedestrians safely through the construction area and allow for adequate access and circulation to the satisfaction of the City Traffic Engineer. With implementation of the Traffic Control Plan, as required by Mitigation Measure TRAF-I, impacts to the local and regional circulation systems during construction would be reduced to less -than -significant levels. Construction/operation of all other project components would have less than significant or no impact associated with Morro Bay's circulation system and traffic congestion. 01181.0001/495768.1 exHisir a Page 53 of 70 Finding: The City has adopted and will implement Mitigation Measure 1111LAF-1, included above for Impact 3.8-6, which will reduce potentially significant Impact 3.14-1 to a less than significant level. hlazardous Design Features ® Impact 3.14-3: Construction of the Project would result in partial lane closures, which could significantly impact the operations of the local and regional circulation systems. However, implementation of a Traffic Control Plan would reduce impacts to a less than significant level. This impact would be Class II, Less than Significant with Mitigation. Facts in Support of the Finding: Construction of the lift station, conveyance facilities, and IPR injection and monitoring wells could require partial lane closures, which could introduce roadway hazards to passing motorists. This would be a potentially significant impact. Implementation of a Traffic Control Plan as mitigation for roadways which require partial closures during construction would minimize the effects on roadway safety. The Traffic Control Plan would include signage, striping, delineated detours, flagging operations and other devices to guide motorists, bicyclists, and pedestrians safely through the construction area and allow for adequate access and circulation to the satisfaction of the City of Morro Bay Traffic Engineer. With implementation of the Traffic Control Plan, as required by Mitigation Measure TRAF4, construction of the Project would not result in a hazardous design feature. Impacts during construction would be less than significant with mitigation. Construction operation of all other project components would have less than significant or no impact associated with hazardous design features. Finding: The City has adopted and will implement Mitigation Measure TRAF-1, included above for Impact 3.8-6, which will reduce potentially sign cant Impact 3.14-3 to a less than significant level. Emergency Access ® Impact 3.14-4: Construction of the Project would include temporary partial lane closures, which could significantly impact emergency access in proximity to the project components. However, implementation of the Traffic Control Plan would require coordination with emergency responders, which include the fire department, police department, and ambulances to ensure adequate emergency access is provided. This impact would be Class II, Less than Significant with Mitigation. Facts in Support of the Finding: Construction of the collection system and IPR injection and monitoring wells wouldn't significantly increase the amount of trucks and vehicles on the local and regional circulation systems; however, construction activities within roadways would require partially closure of traffic lanes, which could interfere with emergency access and result in potentially significant impacts. 01181.0001/495768.1 EXHIBIT A Page 54 of 70 In order to reduce impacts to emergency access, the City would be required to implement Mitigation Measure TRAF-1, which would require the preparation and implementation of a Traffic Control Plan. The Traffic Control Plan would include, but not limited to, signage, striping, delineated detours, flagging operations, changeable message signs, delineators, arrow boards, and K-Rails that will be used during construction to guide motorists, bicyclists, and pedestrians safely through the construction area and allow for adequate access. The Traffic Control Plan would be coordinated with emergency responders, which include the fire department, police department, and ambulances that have jurisdiction within the Project area. Therefore, with implementation of Mitigation Measure TRAF-1, impacts to emergency access during construction of the collection system and IPR injection and monitoring wells would be reduced to less than significant. Construction/operation of all other project components would have less than significant or no impact associated with emergency access. Finding: The City has adopted and will implement 1Vlitigation 1VIeasure TRAF-1, included above for Impact 3.8-6, which will reduce potentially significant Impact 3.14-4 to a less than significant level. Public Transportation and Pedestrian Facilities ® Impact 3.14-5: Construction of the Project would include temporary partial lane closures, which could significantly impact alternative transportation routes around the project components. However, implementation of the Traffic Control Plan would require include detours or alternative routes for transit, bicyclists using on -street bicycle lanes, and for pedestrians using adjacent sidewalks. This impact would be Class II, Less than Significant with Mitigation. Facts in Support of the Finding: Figure 3.14-2 in the Final EIR shows the bicycle and pedestrian facilities in proximity to the lift station, conveyance pipelines, and IPR injection and monitoring wells. Class II bike lanes are provided along the entire lengths of South Bay Boulevard, Quintana Road, and Main Street to Highway 41; a recreational bike route is provided along Atascadero Road and Embarcadero; a Class I bike path is located west of Highway 1 adjacent to the Power Plant and across Morro Creek to Atascadero Road. The Pacific Coast Bike Route is located along SR 1. In addition to the bicycle facilities near the project components, there are also sidewalks along Atascadero Road, near the proposed lift station and IPR injection and monitoring well areas. Further, there are numerous bus stops in the vicinity of these Project components primarily along Quintana Road, between Morro Bay Boulevard and Main Street, and Atascadero Road, between SR 1 and Embarcadero. While construction of the lift station, conveyance pipelines, and IPR injection and monitoring wells wouldn't significantly increase the amount of trucks and vehicles on the local and regional circulation systems, construction activities within roadways would require partial closure of traffic lanes, which would significantly impact bicycle lanes within the ROW, sidewalks, and transit routes and bus stops. Construction of the raw wastewater/brine pipeline and IPR West pipeline would directly impact the Class I bike path that runs between Main Street and Morro Creek to the west of SR 1. Pipelines would be installed at an average rate of 150 feet per day; so 01181.0001/495768.1 EXHIBIT A Page 55 of 70 the length of time particular bike paths and pedestrian facilities would be affected would be short in duration. However, this would be a potentially significant impact. In order Oleeduce impacts to alternative transportation facilities during construction of the conveyance facilities, the City would be required to implement a Traffic Control Plan, which includes measures specifically for alternative transportation facilities. The Traffic Control Plan would include, but not limited to, signage, striping, delineated detours, flagging operations, changeable message signs, delineators, arrow boards, and K-Rails that will be used during construction to guide motorists, bicyclists, and pedestrians safely through the construction area and allow for adequate. In addition, the Traffic Control Plan would include detours or alternative routes for bicyclists using on -street and off street bicycle lanes as well as for pedestrians using adjacent sidewalks. Therefore, with implementation of the Traffic Control Plan, as required by Mitigation Measure TRAF4, impacts to alternative transportation facilities during construction of the lift station, conveyance pipelines, and IPR injection and monitoring wells would be reduced to less than significant. Construction operation of all other project components have less than significant or no impact associated with public transportation and pedestrian facilities. Finding: The City has adopted and will implement Mitigation Measure TRAF-1, included above for Impact 3.8-6, which will reduce potentially significant Impact 3.14-5 to a less than significant level. 5.5 Findings Regarding Class I Impacts, Significant and Unavoidable 5.5.1 Cultural Resources Historic and Archaeological Resources ® Impact 3.5-1: The Project could cause a substantial adverse change in the significance of a historical or archaeological resource, as defined in CEQA Guidelines Section 15064.5. This would be a Class I impact, Significant and Unavoidable. Facts in Support of the Finding: WRF. No historic architectural resources or known archaeological resources are located within the preferred WRF location. The preferred WRF location was identified as having a Lowest to Low sensitivity for the presence of buried archaeological deposits. Nevertheless, ground disturbance related to construction of the proposed WRF has the potential to impact unknown archaeological resources that could qualify as historical or unique archaeological resources under CEQA. Implementation of Mitigation Measures CUL4 and CUL-5 through CUL-9 would reduce impacts to less than significant. Lift Station. No historic architectural resources or known archaeological resources are located within the proposed lift station options. Those lift station options were identified as having a High sensitivity for the presence of buried archaeological deposits. Ground disturbance related to construction of the lift station has the potential to impact unknown archaeological resources that could qualify as historical or unique archaeological resources under CEQA. Implementation of 01181.0001/495768.1 EXHIBIT A Page 56 of 70 Mitigation Measures CUL-1 and CUL-n through CUL-9 would reduce impacts to less than significant. Conveyance Pipelines. A total of five resources are located within %A immediately adjacent to the proposed conveyance pipelines, including CA-SLO-16, -239, -2222, -2845, and WRF-2. One resource, WRF-2, was recommended not eligible and is not considered a historical resource under CEQA. The remaining four resources have been discretionarily determined to be eligible by the City for the purposes of this Draft EIR pursuant to CEQA subdivision 15064.5(a)(3), and are considered historical resources. Ground disturbance related to construction of the conveyance pipelines has the potential to directly impact all of those resources, which would constitute a significant and unavoidable impact under CEQA. Additionally, some portions of the conveyance pipeline alignments were identified as having a High to Highest sensitivity for the presence of buried archaeological deposits. Ground disturbance related to construction of the conveyance pipelines has the potential to impact unknown archaeological resources that could qualify as historical or unique archaeological resources under CEQA. Implementation of Mitigation Measures CUL-1 through CUL-9 would reduce impacts to the degree feasible; however, since CA-SLO-16, -239, -2222, and -2845 are historical resources, pursuant to CEQA, and ground disturbance related to construction of the conveyance pipelines would directly impact those resources, even after mitigation, the impact would remain significant and unavoidable. Injection and Monitoring Wells. A total of three resources are located within the proposed IPR East and IPR West wellfield areas, including CA-SLO-16, CA-SLO-43, and CA-SLO-165. CA- SLO465 is listed in the California Register and is a historical resource. CA-SLO-16 and CA- SLO-43 have been discretionarily determined to be eligible by the City for the purposes of the FEIR, pursuant to CEQA subdivision 15064.5(a)(3), and they are considered historical resources. Since the exact locations of the wells within the wellfield areas have not been identified yet, ground disturbance related to construction of the injection and monitoring wells has the potential to directly impact all of these resources, which would constitute a significant and unavoidable impact under CEQA, even after feasible mitigation. Additionally, the IPR East and Il'R West wellfield areas were identified as having a High to Highest sensitivity for the presence of buried archaeological deposits. Ground disturbance related to construction of the injection and monitoring wells has the potential to impact unknown archaeological resources that could qualify as historical or unique archaeological resources under CEQA. Implementation of Mitigation Measures CUL-1 through and CUL-9 would reduce impacts to the degree feasible; however, since CA-SLO-16, CA-SLO-43, and CA-SLO-165 are historical resources pursuant to CEQA and ground disturbance related to construction of the injection and monitoring wells would potentially directly impact these resources, even after mitigation, the impact would remain significant and unavoidable. 01181.0001/495768.1 ExHieiT n Page 57 of 70 Decommissioning of Current WWTP. The decommissioning of the current WWTP would include the shutdown, demolition, and complete removal of all WWTP facilities and infrastructure such as the piping located four to five feet below grade. Since the existing WWTP is more than 45 years old (the California OUP's threshold for consideration as a historical resource) it was evaluated for listing in the National Register and California Register and was found not eligible. As such, it does not qualify as a historical resource and its shutdown, demolition, and removal would not constitute a significant impact. No known archaeological sites are located within the WWTP. The WWTP location was identified as having a High to Highest sensitivity for the presence of buried archaeological deposits. Ground disturbance related to the shutdown, demolition, and removal of all WWTP facilities and infrastructure such as the piping located four to five feet below grade, has the potential to impact archaeological resources that could qualify as historical or unique archaeological resources under CEQA. Implementation of Mitigation Measures CUL4 and CUL-5 through CUL-9 would reduce impacts to less than significant. Operation. Although there is unlikely to be ground disturbance associated with the operation of the proposed project facilities, there is potential ground disturbance could occur during maintenance or repair of those facilities. If ground disturbance occurred within areas that have not been previously disturbed, then there is the potential to impact archaeological resources that qualify as, or could qualify as, historical or unique archaeological resources under CEQA. Implementation of Mitigation Measures CUL4 and CUL-6 through CUL-9 would reduce impacts to less than significant. Facts in Support of Finding: The City has adopted and will implement the following mitigation measures; however, they will not reduce potentially significant Impact 3.5-1 to a less than significant level. Potential impacts on historic and archaeological resources for the conveyance pipelines and injection and monitoring wells remain significant and unavoidable after implementation of mitigation measures: CUL-1: Retention of a Qualified Archaeologist. Within 30 days after the City's approval of the final design plans and prior to start of any ground -disturbing actives (i.e., demolition, pavement removal, pot -holing or auguring, boring, drilling, grubbing, vegetation removal, brush clearance, weed abatement, grading, excavation, trenching, or any other activity that has potential to disturb soil), the City shall retain a Qualified Archaeologist meeting the Secretary of the Interior's Professional Qualifications Standards for archaeology (U.S. Department of the Interior, 1983) to carry out all mitigation related to archaeological resources. CUL-2: Pre -Construction Phase I Cultural Resources Survey. Within 30 days after the City's approval of the final design plans and prior to the start of any ground -disturbing activity (i.e., demolition, pavement removal, pot -holing or auguring, boring, drilling, grubbing, vegetation removal, brush clearance, weed abatement, grading, excavation, trenching, or any other activity that has potential to disturb soil), the Qualified Archaeologist shall conduct pre - construction Phase I Cultural Resources Survey of all areas that have not been previously surveyed within the last 5 years. 01181.0001/495768.1 ExNieir a Page 58 of 70 The survey shall document resources potentially qualifying as historical resources or unique archaeological under CEQA. The Qualified Archaeologist shall document the results of the survey in a Phase I Cultural Resources Survey Report that follows Archaeological Resource Management Reports (ARMR): Recommended Contents and Format (OHP, 1990). The Qualified Archaeologist shall also prepare Department of Parks and Recreation 523 forms for resources encountered during the survey, which shall be appended to the report. If historic architectural resources are encountered that could potentially be impacted by the project, the Qualified Archaeologist shall consult with a Qualified Architectural Historian meeting the Secretary of the Interior's Professional Qualifications Standards for architectural history (U.S. Department of the Interior, 1983). The Qualified Archaeologist shall submit the draft Phase I Cultural Resources Survey Report to the City within 30 days after completion of the survey. The final Phase I Cultural Resources Survey Report shall be submitted to the City within 10 days after receipt of City's comments. The Qualified Archaeologist shall also submit the final Phase I Cultural Resources Survey Report to the Central Coast Information Center. In the event resources potentially qualifying as historical resources or unique archaeological resources under CEQA are identified during the survey, avoidance and preservation in place shall be the preferred manner of mitigating impacts to the resources in accordance with Mitigation Measure CUL-3. If avoidance of the identified resources is determined by the City to be infeasible in light of factors such as the nature of the find, Project design, costs, and other considerations, then the portion of the resource within the Area of Direct Impact (ADI) shall be subject to presence/absence testing and if potentially significant deposits are identified, the resource shall be evaluated for significance under all four National Register/California Register Criteria (A/1-D/4). If a resource is found to be significant (i.e., meets the definition for historical resource in CEQA Guidelines subdivision 15064.5(a) or unique archaeological resource in PRC subdivision 21083.2(g)), then is shall be incorporated into the Archaeological Resources Data Recovery and Treatment Plan outlined in Mitigation Measure CUL4. CUL-3: Avoidance and Preservation in Place of Archaeological Resources. The City shall avoid and preserve in place resources CA-SLO-16, -43, -165, -239, -2222, and -2845, and any other resources that are identified as potentially qualifying as historical resources or unique archaeological resources under CEQA, through Project re -design. Avoidance and preservation in place is the preferred manner of mitigating impacts to archaeological resources. Preservation in place maintains the important relationship between artifacts and their archaeological context and also serves to avoid conflict with traditional and religious values of groups who may ascribe meaning to the resource. Preservation in place may be accomplished by, but is not limited to, avoidance, incorporating the resource into open space, capping, or deeding the site into a permanent conservation easement. In the event that avoidance and preservation in place of a resource is determined by the City to be infeasible in light of factors such as project design, costs, and other considerations, then Mitigation Measure CUL-4 shall be implemented for that resource. If avoidance and preservation in place of a resource is determined by the City to be feasible, then Mitigation Measures CUL-5 shall be implemented for that resource. 01181.0001/495768.1 EXHIBIT A Page 59 of 70 CUL4: Development of an Archaeological Resources Data Recovery and Treatment Plan. The Qualified Archaeologist shall prepare an Archaeological Resources Data Recovery and Treatment Plan for all significant resources that will be impacted by the Project. The plan shall be submitted to the City for review and approval prior to the start of field work for data recovery efforts for resources that are eligible under Criterion DA (data potential). Data recovery field work shall be completed prior to the start of any project -related ground - disturbing activity. Treatment for resources that are eligible under Criteria A/l (events), B/2 (persons), and/or C/3 design/workmanship) shall be completed within 3 years of completion of the project. The Archaeological Resources Data Recovery and Treatment Plan shall include: • Research Design. The plan shall outline the applicable cultural contexts) for the region, identify research goals and questions that are applicable to each resource or class of resources, and list the data needs (types, quantities, quality) required to answer each research question. The research design shall address all four National Register/California Register Criteria (A/1-D/4) and identify the methods that will be required to infonn treatment, such as subsurface investigation, documentary/archival research, and/or oral history, depending on the nature of the resource. • Data Recovery for Resources Eligible under Criterion D/4. The plan shall outline the field and laboratory methods to be employed, and any specialized studies that will be conducted, as part of the data recovery effort for resources that are eligible under National Register/California Register Criterion DA (data potential). If a resource is eligible under additional criteria, treatment beyond data recovery shall be implemented (see CUL4c). • Treatment for Resources Eligible under Criteria A/1, B/2, and/or C/3. In the event a resource is eligible under National Register/California Register Criteria A/1 (events), 13/2 (persons), or C/3 (design/workmanship), then resource -specific treatment shall be developed to mitigate project -related impacts to the degree feasible. That could include forms of documentation, interpretation, public outreach, ethnographic and language studies, publications, and educational programs, depending on the nature of the resource, and may require the retention of additional technical specialists. Treatment measures shall be generally outlined in the plan based on existing information on the resource. Once data recovery is completed and the results are available to better inform resource -specific treatment, the treatment measures shall be formalized and implemented. Treatment shall be developed by the Qualified Archaeologist in consultation with the City and Native American Tribal representatives for resources that are Native American in origin. • Security Measures. The plan shall include recommended security measures to protect archaeological resources from vandalism, looting, and non -intentionally damaging activities during field work. • Procedures for Discovery of Human Remains and Associated Funerary Objects. The plan shall outline the protocols and procedures to be followed in the event that human remains and associated funerary objects are encountered during field work. These shall include stop -work 01181.0001/495768.1 EXHIBIT A Page 60 of 70 and protective measures, notification protocols, and compliance with California Health and Safety Code section 7050.5 and PRC section 5097.98. See also CUL-14. • Reporting Requirements. Upon completion of data recovery for resources eligible under Criterion D/4, the Qualified Archaeologist shall document the findings in an Archaeological Data Recovery Report. The draft Archaeological Data Recovery Report shall be submitted to the City within 360 days after completion of data recovery, and the final Archaeological Data Recovery Report shall be submitted to the City within 60 days after the receipt of City comments. The Qualified Archaeologist shall also submit the final Archaeological Data Recovery Report to the Central Coast Information Center. Upon completion of all other treatment for resources eligible under Criteria A/1, B/2, and C/3, the Qualified Archaeologist shall document the resource -specific treatment that was implemented for each resource and verification that treatment has been completed in a technical document (report or memorandum). The document shall be provided to the City within 30 days after completion of treatment. • Curation Requirements. Disposition of Native American archaeological materials shall be determined through consultation between Native American representatives, the Qualified Archaeologist, and the City. Disposition of human remains and associated funerary objects shall be determined by the landowner in consultation with the City and Most Likely Descendant (see Mitigation Measure CUL44). Any historic -period archaeological materials that are not Native American in origin shall be curated at a repository accredited by the American Association of Museums that meets the standards outlined in 36 Code of Federal Regulations (CFR) 79.9. If no accredited repository accepts the collection, then it may be curated at a non -accredited repository as long as it meets the minimum standards set forth by 36 CFR 79.9. If neither an accredited nor a non -accredited repository accepts the collection, then it inay be offered to a public, non-profit institution with a research interest in the materials, or donated to a local school or historical society in the area for educational purposes, to be determined by the Qualified Archaeologist in consultation with the City. • Protocols for Native American Monitoring and Input. The plan shall outline the role and responsibilities of Native American Tribal representatives. It shall include communication protocols and an opportunity and timelines for review of cultural resources documents. The plan shall include provisions for full-time Native American monitoring during field work (see Mitigation Measure CUL-8). CUL-S: Development of a Cultural Resources Monitoring and Mitigation Program (CRMMP). Within 60 days of the award of the contractor's bid and prior to the start of any ground - disturbing activity (i.e., demolition, pavement removal, pot -holing or auguring, boring, drilling, grubbing, vegetation removal, brush clearance, weed abatement, grading, excavation, trenching, or any other activity that has potential to disturb soil), the Qualified Archaeologist 01181.0001/495768.1 EXHIBIT A Page 61 of 70 shall prepare a Cultural Resources Mitigation and Monitoring Program (CRIVIMP) based on the final City -approved project design plans. The CRMMP shall include: • Establishment of Environmentally Sensitive Areas. The CRMMP shall outline areas that will be designated Environmentally Sensitive Areas (including maps). Significant or unevaluated cultural resources that are being avoided and are within 50 feet of the construction zone shall be delineated with exclusion markers to ensure avoidance. These areas will not be marked as archaeologI cal resources, but will be designated as "exclusion zones" on project plans and protective fencing in order to discourage unauthorized disturbance or collection of artifacts. • Provisions for Archaeological Monitoring. Full-time archaeological monitoring shall be required for all ground disturbance. The CRMMP shall outline the archaeological monitor(s) responsibilities and requirements (see Mitigation Measure CUL-71 • Procedures for Discovery of Archaeological Resources. Procedures to be implemented in the event of an archaeological discovery shall be fully defined in the CRMMP, and shall include stop -work and protective measures, notification protocols, procedures for significance assessments, and appropriate treatment measures. The CRMIVIP shall state avoidance or preservation in place is the preferred manner of mitigating impacts to historical resources and unique archaeological resources, but shall provide procedures to follow should avoidance be infeasible in light of factors such as the nature of the find, project design, costs, and other considerations. See also Mitigation Measure CUL-9. If, based on the recommendation of the Qualified Archaeologist, it is determined a discovered archaeological resource constitutes a historical resource or unique archaeological resource pursuant to CEQA, then avoidance and preservation in place shall be the preferred manner of mitigating impacts to such a resource in accordance with Mitigation Measure CUL-3. In the event that preservation in place is determined to be infeasible and data recovery through excavation is the only feasible mitigation available, an Archaeological Resources Data Recovery and Treatment Plan shall be prepared and implemented following the procedures outlined in Mitigation Measure CUL4. The City shall consult with appropriate Native American representatives in determining treatment of resources that are Native American in origin to ensure cultural values ascribed to the resource, beyond those that are scientifically important, are considered. • Procedures for Discovery of Human Remains and Associated Funerary Objects. The CRNIlVII' shall outline the protocols and procedures to be followed in the event that human remains and associated funerary objects are encountered during construction. These shall include stop -work and protective measures, notification protocols, and compliance with California Health and Safety Code section 7050.5 and PRC section 5097.98 (see Mitigation Measure CUL44). • Reporting Requirements. The CRMMP shall outline provisions for weekly, monthly, and final reporting. The Qualified Archaeologist shall prepare weekly status reports detailing activities and locations observed (including maps) and summarizing any discoveries for the 01181.0001/495768.1 EXHIBIT A Page 62 of 70 duration of monitoring to be submitted to the City via email for each week in which monitoring activities occur. Monthly progress reports summarizing monitoring efforts shall be prepared and submitted to the City for the duration of ground disturbance. The Qualified Archaeologist shall prepare a draft Archaeological Resources Monitoring Report and submit it to the City within 180 days after completion of the monitoring program or treatment for significant discoveries should treatment extend beyond the cessation of monitoring. The final Archaeological Resources Monitoring Report shall be submitted to the City within 60 days after receipt of City comments. The Qualified Archaeologist shall also submit the final Archaeological Resources Monitoring Report to the Central Coast Information Center. If human remains are encountered, a confidential report documenting all activities shall be submitted to the California Native American Heritage Commission within 90 days after completion of any treatment (see Mitigation Measure CUL441. • Curation Requirements. Disposition of Native American archaeological materials shall be determined through consultation between Native American representatives, the Qualified Archaeologist, and the City. Disposition of human remains and associated funerary objects shall be determined by the landowner in consultation with the City and Most Likely Descendant (see Mitigation Measure CUL44). Any historic -period archaeological materials that are not Native American in origin shall be curated at a repository accredited by the American Association of Museums that meets the standards outlined in 36 CFR 79.9. If no accredited repository accepts the collection, then it may be curated at a non -accredited repository as long as it meets the minimum standards set forth by 36 CFR 79.9. If neither an accredited nor a non - accredited repository accepts the collection, then it may be offered to a public, non- profit institution with a research interest in the materials, or donated to a local school or historical society in the area for educational purposes, to be determined by the Qualified Archaeologist in consultation with the City. • Protocols for Native American Monitoring and Input. The CRMMP shall outline the role and responsibilities of Native American Tribal representatives. It shall include communication protocols, an opportunity and timelines for review of cultural resources documents related to discoveries that are Native American in origin, and provisions for Native American monitoring. The CRMMP shall include provisions for full-time Native American monitoring of all project -related ground disturbance, as well as during any subsurface investigation and data recovery for discovered resources that are Native American in origin (see Mitigation Measures CUL-8). CUL4: Construction Worker Cultural Resources Sensitivity Training. Prior to start of any ground -disturbing activities (i.e., demolition, pavement removal, pot -holing or auguring, boring, drilling, grubbing, vegetation removal, brush clearance, weed abatement, grading, excavation, trenching, or any other activity that has potential to disturb soil), the Qualified Archaeologist, or his/her designee, and a Native American representative shall conduct cultural resources sensitivity training for all construction personnel. In the event construction crews are phased, additional trainings shall be conducted for new construction personnel. 01181.0001/495768.1 EXHIBIT A Page 63 of 70 Construction personnel shall be informed of the types of archaeological resources that may be encountered, the proper procedures to be enacted in the event of an inadvertent discovery of archaeological resources or human remains, confidentiality of discoveries, and safety precautions to be taken when working with cultural resources monitors. The City shall ensure construction personnel are made available for and attend the training and retain documentation demonstrating attendance. That training may be conducted in coordination with paleontological sensitivity training required by Mitigation Measure CUL-11. CUL-7: Archaeological Resources Monitoring. All project -related ground dishrbance (i.e., demolition, pavement removal, pot -holing or auguring, boring, drilling, grubbing, vegetation removal, brush clearance, weed abatement, grading, excavation, trenching, or any other activity that has potential to disturb soil) shall be monitored by an archaeological monitor(s) familiar with the types of resources that could be encountered and shall work under the direct supervisor of the Qualified Archaeologist. The number of archaeological monitors required to be on -site during ground disturbing activities is dependent on the construction scenario, specifically the number of pieces of equipment operating at the same time, the distance between these pieces of equipment, and the pace at which equipment is working, with the goal of monitors being able to effectively observe soils as they are exposed. Generally, work areas more than 500 feet from one another will require additional monitors. The archaeological monitor(s) shall keep daily logs detailing the types of activities and soils observed, and any discoveries. Archaeological monitor(s) shall have the authority to halt and re -direct ground disturbing activities in the event of a discovery until it has been assessed for significance and treatment implemented, if necessary, based on the recommendations of the Qualified Archaeologist in coordination with the City, and the Native American representatives in the event the resource is Native American in origin, and in accordance with the protocols and procedures outlined in the CRMMP (see Mitigation Measure CUL-5). CUL-8: Native American Monitoring. The City shall retain a Native American monitors) from a Tribe that is culturally and geographically affiliated with the project site (according to the California Native American Heritage Commission). The Native American monitor shall monitor all project -related ground disturbance (i.e., demolition, pavement removal, pot -holing or auguring, boring, drilling, grubbing, vegetation removal, brush clearance, weed abatement, grading, excavation, trenching, or any other activity that has potential to disturb soil) and all ground disturbance related to subsurface investigation and data recovery efforts for discovered resources that are Native American in origin. The number of Native American monitors required to be on -site during ground disturbing activities is dependent on the construction scenario, specifically the number of pieces of equipment operating at the same time, the distance between these pieces of equipment, and the pace at which equipment is working, with the goal of monitors being able to effectively observe soils as they are exposed. Generally, work areas more than 500 feet from one another require additional monitors. Native American monitors shall have the authority to halt and re -direct ground disturbing activities in the event of a discovery until it has been assessed for significance. 7 UL4.• Inadvertent Discovery. In the event archaeological resources are encountered during construction of the Project, all activity in the vicinity of the find shall cease (within 100 feet), 01181.0001/495768.1 EXHIBIT A Page 64 of 70 and the protocols and procedures for discoveries outlined in the CRMMP (see Mitigation Measure CUL-5) shall be implemented. The discovery shall be evaluated for potential significance by the Qualified Archaeologist. If the Qualified Archaeologist determines that the resource may be significant (i.e., meets the definition for historical resource in CEQA Guidelines subdivision 15064.5(a) or unique archaeological resource in PRC subdivision 21083.2(g)), the Qualified Archaeologist shall develop an Archaeological Resources Data Recovery and Treatment Plan for the resource in accordance with the CRMMP (see Mitigation Measure CUL-5) and following the procedures outlined in Mitigation Measure CUL4. When assessing significance and developing treatment for resources that are Native American in origin, the Qualified Archaeologist and the City shall consult with the appropriate Native American representatives. The Qualified Archaeologist shall also detennine if work may proceed in other parts of the project site while data recovery and treatment is being carried out. Human Remains ® Impact 3.5-3: The Project could disturb human remains during construction, including those interred outside of formal cemeteries. This would be a Class I impact, Significant and Unavoidable. Facts in Support of the Finding: The proposed and preferred project sites and vicinity overlap with known locations of human remains. Ground disturbance associated with the Project has the potential to disturb human remains, including those interred outside of formal cemeteries. That would be a potentially significant impact. Implementation of Mitigation Measures CUL4 through CUL-9 and CUL44 would reduce impacts to the degree feasible, however, even after mitigation the impact would remain significant and unavoidable. Implementation of Mitigation Measure CUL44 would ensure operation of all the Project's components will have less than significant impacts associated with human remains. Finding: The City has adopted and will implement Mitigation Measures CUL-1 through CUL-9 as described above for Impact 3.5-1; the City also will implement Mitigation Measure CUL-14 as described below. However, they will not reduce potentially significant Impact 3.5-3 to a less than significant level. Impacts on human remains associated with construction of project components may remain significant and unavoidable. CUL44: Inadvertent Discovery of HunZan Remains: If human remains are encountered, then the City shall halt work in the vicinity (within 100 feet) of the discovery and contact the County Coroner in accordance with PRC section 5097.98 and Health and Safety Code section 7050.5. If the County Coroner determines the remains are Native American, then the Coroner will notify the California Native American Heritage Commission in accordance with Health and Safety Code subdivision 7050.5(c), and PRC section 5097.98. The California Native American Heritage Commission will designate a Most Likely Descendent for the remains per PRC section 5097.98. Until the landowner has conferred with the Most Likely Descendent, the contractor shall ensure the immediate vicinity where the discovery occurred is not disturbed by further activity, is adequately protected according to generally accepted cultural or archaeological standards or practices, and that further activities take into account the 01181.0001/495768.1 EXHIBIT A Page 65 of 70 possibility of multiple burials. If human remains are encountered, the Qualified Archaeologist, in consultation with the Most Likely Descendant shall prepare a confidential report documenting all activities and it shall be submitted to the California Native American Heritage Commission within 90 days after completion of any treatment. 5.5.2 Cumulative ►mpacfs Only cumulative impacts to cultural resources would be Class I, Significant and Unavoidable. All other cumulative impacts have less than significant or, in the case of cumulative impacts to tribal cultural resources, no impact, as presented above in Sections 5.3 and 5.1, respectively. .1 Alternative 1: ® r®sect Alternative Pursuant to Section 15126.6(e) of the CEQA Guidelines, the No Project Alternative shall be evaluated to allow decision makers to compare the impacts of approving the Project with the impacts of not approving the Project. The No Project Alternative shall: discuss the existing conditions at the time the notice of preparation is published, or if no notice of preparation is published, at the time the environmental analysis is commenced, as well as what would be reasonably expected to occur in the foreseeable future if the project were not approved, based on current plans and consistent with available infrastructure and community services. The No Project Alternative would result in the continued operation and maintenance of the existing WWTP and associated wastewater treatment infrastructure. Given the CSD is moving forward with its own treatment project, under the No Project Alternative the WWTP would provide treatment for influent wastewater only from the City's service area. However, operating the WWTP in accordance with the status quo would not comply with the effluent water quality criteria and the SWRCB/CCRWQCB order to upgrade the plant to meet discharge water quality criteria, resulting in increased costs associated with fines. As required to be considered by CEQA, what would be reasonably expected to occur in the foreseeable future if the project were not approved would be upgrades to the existing plant to provide full secondary treatment to meet the State's minimum water quality criteria for all discharges through the existing outfall. Upgrade of the WWTP was considered in the September 2007 WWTP Facility Master Plan Report. The Report recommended new headworks, oxidation ditch and secondary clarifiers, biosolids handling facilities, disinfection, and electrical and control facilities. Construction of those facilities would occur within the existing WWTP footprint and would provide full secondary treatment for influent at a capacity that meets the projections of the City's future wastewater generation without participation of the CSD. To mitigate for potential inundation during a 100-year flood event, the new facilities would be elevated at least one foot above the flood depth, which could be as great as six feet. Under the No Project Alternative, the Project would not be constructed, nor would the lift station, associated conveyance pipelines, or injection and monitoring wells. As a result, the significant 01181.0001/495768.1 EXHIBIT A Page 66 of 70 impacts to historic and archaeological resources, as well as human remains, would not occur. The No Project Alternative would avoid those significant and unavoidable impacts associated with the Project. However, the No Project Alternative also would not achieve the benefits of the Project, including removing critical community infrastructure from a coastal hazard area subject to flooding and sea level rise. In addition, the No Project Alternative would not meet any of the project objectives, including the ability to provide reclaimed wastewater to augment the City's water supply or to meet wastewater effluent conditions that reduce impacts from contaminants of emerging concern. The No Project Alternative is not feasible because it would require a CDP from the CCC, which previously denied the same permit for an upgrade to the WWTP. The basis for that denial included the CCC's assessment such upgraded facilities would be inconsistent with the City's Local Coastal Plan's zoning provisions, would fail to avoid coastal hazards and would fail to include a sizeable reclaimed water component; and the project location would be within an LCP- designated sensitive view area. It is likely the CCC would similarly deny a CDP for the proposed No Project Alternative. 6.2 Alternative 2: Pipeline Alignment Alternative Alternative 2 would result in construction of all the same facilities as the Project, except for a segment of the raw wastewater pipeline that would have a different alignment and result in the construction of approximately 2,500 linear feet of additional pipeline (see Final EIR Figure 6-2). The additional pipeline construction would be along Embarcadero Road to the west of the existing WWTP and proposed lift station, traveling south and then east along Pacific Street, and meeting with the currently proposed raw wastewater pipeline at Butte Street. The segment under Alternative 2 would result in construction near two different and known cultural resources sites, may result in geotechnical challenges along the waterfront, and would result in a significant increase of construction impacts related to traffic, air quality and noise due to the location of construction within higher traffic corridors (residential and commercial), and the location of construction equipment relative to sensitive receptors (residences). Further, this segment of pipeline under Alternative 2 would require additional rights of way through residential property. While there would be an increase in the severity of impacts related to the additional linear feet of construction, all impacts would be reduced to less than significant using the same mitigation measures presented for the Project. However, impacts to cultural resources, while reduced in number of impacted sites, would remain significant and unavoidable under Alternative 2, even with mitigation. Additionally, Alternative 2 would result in higher cost due to the additional length of construction and rights of way compensation. 6.3 Alternative 3: WRF Design Alternative During preparation of the draft FMP and MWRP, alternative treatment technologies and associated site plan configurations were considered. Under Alternative 3, the proposed level of treatment would be changed to either remove advanced treatment or implement full secondary treatment only. Removing advanced treatment would reduce the proposed WRF footprint by approximately 7,000 square feet (0.16 acres). Implementing full secondary treatment would be 01181.0001/495768.1 EXHIBIT A Page 67 of 70 achieved by either proceeding with the sequencing batch reactor kSBR) treatment train, but removing the filters or changing to the treatment process to a more traditional secondary treatment process, such as an activated sludge or oxidation ditch process. Proceeding with the SBR treatment train and removing the filters would have a small incremental reduction to the proposed WRF footprint in addition to removing advanced treatment. The footprint associated with a traditional secondary treatment process would be greater than that currently planned for the proposed WRF. The current preliminary design at the preferred South Bay Bouulevard WRF site is intended to minimize the proposed WRF footprint, while still providing the facilities required to provide the level of treatment that would meet the Project goals. As documented in this FUR, the preliminary design for the Project would not have significant effects to: • scenic resources due to architechural treatments to be included in the design and the restricted line of sight from Highway 1 and public vantage points to the low- lying WRF site which is partially screened by the hillside topography. • agriculture due to the small percentage of rangeland within the 396-acre parcel that would be occupied by the facilities. • neighboring land use due to the small percentage of rangeland within the 396-acre parcel that would be occupied by the facilities allowing the majority of the site to continue to be used for grazing. • riparian habitat due to the distance of the proposed WRF from jurisdictional features. • water quality in downstream drainages due to compliance with the requirements of the City's Storm Water Management Plan and NI -DES General Construction Permit that require retention and control of storm water onsite during both construction and operation As documented in this Draft EIR, the preferred WRF site would have benefits to: • coastal hazards and flooding due to the removal of the WWTP from the flood hazard zone and location of the WRF in an area that is not a flood hazard zone. Implementation of alternative treatment technologies at the preferred WRF site would have similar impacts and benefits as the Project. For example, removing advanced treatment would lessen the WRF footprint by 7,000 square feet or 0.16 acres, which is roughly 1 % of the 10- to 15-acre area of disturbance for the Project. Although a smaller footprint would have relative fewer impacts to agricultural lands, scenic resources, neighboring land use, and water quality, no impacts would be eliminated or avoided and the same mitigation measures and regulatory requirements would apply. Implementation of a traditional full secondary treatment process at the preferred WRF site may require a larger footprint; as such, relatively greater impacts to agricultural lands, scenic resources, neighboring land use, and water quality would occur. A greater footprint would have potential to encroach on riparian habitat, and could result in potentially significant impacts that would be greater than the Project. Otherwise, however, with application of the same mitigation measures and regulatory requirements as the Project, there would likely be no other significant impacts. 01181.0001/495768.1 EXHIBIT A Page 68 of 70 With regard to energy use, removing advanced treatment and the filters would lessen the amount of energy required during the treatment process; standard full secondary treatment also would use less energy relative to the Project. However, the Project would not result in significant impacts to energy or GHGs as a result of operational energy use. Alternative 3 would preclude the City from meeting key project objectives, including production of tertiary treated recycled water and augmenting the City's water supply. Removing advanced treatment would still produce recycled water that could be used for municipal and agricultural irrigation; however, the MWRP found that such urban and agricultural demands are not great enough to substantially offset potable water supply end uses, which limits the benefits of Alternative 3. CEQA requires an EIR briefly describe the rationale for selection and rejection of alternatives. The City may make an initial determination as to which alternatives are potentially feasible and, therefore, merit in-depth consideration, and which are clearly infeasible. Alternatives that are remote and speculative, or the effects of which cannot be reasonably predicted, need not be considered (CEQA Guidelines, section 15126.6(f)(3)). h1 Chapter 6, Alternatives Analysis, the Final EIR describes the various and extensive alternative screening processes that have been conducted for the WRF location and the lift station location, including criteria upon which the preferred locations were based and alternative locations rejected. In addition, the reasons for rejection of joint ventures with the CSD and Los Osos are described. The City Council's decision to remove the Corporation Yard from the proposed WRF site is explained, and an explanation of the assessment for recycled water reuse alternatives is also provided, including criteria upon which the decision to implement IPR was based and other beneficial uses (e.g., agricultural irrigation) were rejected. 6.5 Summary of Alternative Analysis The analysis of alternatives taken together with the analysis of the proposed project provide a basis to identify the envirommentally superior alternative under CEQA (CEQA Guidelines section 15126.6). The environmentally superior alternative is the alternative identified as meeting most of the basic project objectives and resulting in the fewest or least severe combination of significant environmental impacts. CEQA Guidelines section 15126.6 provides, if the No Project Alternative is the environmentally superior alternative, then the EIR shall also identify an environmentally superior alternative among the other alternatives. Here, the No Project Alternative may in some respects qualify as the environmentally superior alternative because it would avoid the significant and unavoidable impacts to historic and archaeological resources, and human remains. However, it would not meet any of the basic project objectives; it would have considerable economic and regulatory consequences in the future (e.g., mounting number of fines from the SWRCB/CCRWQCB or infeasibility due to CDP denial), and could result in different or more severe impacts than the proposed project or other possible alternatives given the failure of the No Project Alternative to meet water quality discharge criteria, to produce recycled water to augment 01181.0001/495768.1 EXHIBIT A Page 69 of 70 the Citys supply, and to move critical public infrastructure out of the coastal hazard zone. For that reason, the discussion below focuses on selecting another environmentally superior alternative from among Alternative 2, Alternative 3 and the Project. It is important to recognize the selection %J the environmentally superior alternative is not always a straightforward and formulaic exercise. In some cases, including here, no alternative can eliminate all significant and unavoidable, long -teen environmental effects. There are environmental tradeoffs among the alternatives and even within resource issue areas or topics, making it difficult to summarize the net effect of the alternatives. As such, considerable weighing among the severity of impacts of the alternatives and professional judgment as to the relative importance of topical impact areas is necessary. Such judgment, while based on reasoning grounded in the scientific study that comprises this Draft EIR, can be subjective. Comparison of Alternative 2 impacts to the proposed project impacts, above, indicate Alternative 2 would meet the proposed project's objectives, and would result in a reduction in impacts on number of cultural resources sites. However, Alternative 2 would increase the costs to the City related to construction and would result in more severe impacts on air quality, noise, and traffic. Alternative 3 overall would result in similar impacts to the proposed project, and would not avoid any potentially significant impacts. Depending on the alternate treatment process chosen, the relative impacts would be incrementally smaller or greater, and require similar mitigation measures. Under Alternative 3, many of the City's key project objectives would not be met. Therefore, the Final EIR identifies the Project as the environmentally superior alternative. 01181.0001/495768.1 EXHIBIT A Page 70 of 70 t0 Resolution No. 61-18 1 In accordance with Section 15091(d) and Section 15097 of the CEQA Guidelines, which require a public agency to adopt a program for reporting on or monitoring required changes or conditions of approval to substantially lessen significant environmental effects, the Mitigation Monitoring and Reporting Program (MMRP) is hereby adopted for this project. This MMRP summarizes the mitigation commitments identified in the Morro Bay WRF Final SIR (State Clearinghouse No. 2016081027). Mitigation measures are presented in the same order as they occur in the Final EIR. The columns in the MMRP table provide the following information: • Mitigation Measure(s): The actions) that will be taken to reduce the impact to a less - than -significant level. • Implementation, Monitoring, and Reporting Action: The appropriate steps to implement and document compliance with the mitigation measures. • Responsibility: The agency or private entity responsible for ensuring implementation of the mitigation measure. However, until the mitigation measures are completed, the City of Morro Bay, as the CEQA Lead Agency, remains responsible for ensuring implementation of the mitigation measures occur in accordance with the program (CEQA Guidelines, Section 15097(a)). • Monitoring Schedule: The general schedule for conducting each monitoring task, either prior to construction, during construction, and/or after construction. 01181.0001 /495736.1 Page 1 of 38 .0 C O C U 3 a+ O U C O � U m N c O U Q O O Q o 0 N U U a) U N 0 N c a) p o U O O a) N E 0 o O C t6 E 0 0 C m U fl_ w N .� 0 ._ _ N .- 0 ,� ._ •V O c Q M c 'U 00 c O Q a) Ea) '�.0-o c� — 0a) �o� �E — 7 3 w L U c 0 0 L a) 3 i0.3„ U C O O C a) C N O — 0 N O _ 0 — •L m m O C N m a) w>' N w m O N m a) w N w Eco 0.E_� cnro ao E0 c0 C wa) vo c �62 c -0a)a)o .�> 0o c �000 .cam 0o oIM,MM m o o a).5 a � c� E o 0 0 �� a) 0 �, � n O M w M U — Cl. i a) O) a) fa 0 "_ Q i a) O) a) C O _rn .. 0) m O F. _= c w 0) c m o E in "-• = c w O 0 E CL o � c 0 3 � `o — s0 c o N U m 3 o U c .a) " -o U m 3 0 0 c a) "� crn - ooc �E C: Mo m mo oa) ��m mo o y C 3. 3 U) 'm O m a) C O_ E. 3 N '(6 O� a) C O_ E E r o c c) 'o 'm 0— m 5 o 0 ;� d0 �� �0 �,EQ2w QE �0 �$EQ� Q� aQ — — T C a) O — Mo m 0 () a) m N T c:Umi com L 0) C) C U N m N 3 '0 a N c N ca C N 0 ?> N o)o a) U) 3 CU 0.5 � X� a)-0 N N C C O .� a) N. O c a) U a) a) > Q U 0'N E.E 54= c a) a m C N C O +N -o N O N MMMMM E ,� Q N U O O) O m N 7 'O to a) � C N M a) N m 0 0 0_ N N 'O :�..� E 3 y '36 (L c m C 3 m N 0 m�-o m m 3 a) E 0 Y oQs 3.3 °'aL �I� J U ,a) — 0 p 7 '0 c c a) 4 O —N> oo Mc Q (DN> aQ 0 0 �, N rn0 a) Q' � Q N �0Zin a) IL 0 IM.ca) c cm in:3CU UO�a 0 Ya�ia°)i �3�oEom y Q 3 O N 00 N N -� N mC) E N O � N X 0 -O O m C R Ea) >Eccna (D ofl-�aLsim O-3tm N mL m 3 �C N a) U Q �O }' C C C a) N o 2 Z•a)3 E �` LL N a) C � N m m cc CA 0 U)0 V E m Qa�N c Q m = O N 7 R U 3 CL cr N M (O N E� 3 U N CD N C C E C T m ca U O a) Q Q-0N o Q Q aE m • • § j) I0 0 a§ 2 % §Stft?_t\# $ES �E? ±{{ \ k� ]G ~tE§A9®�o$± #t70> $m\& 0 Z; Cl) 2m\743) 7k cb;?&2M= g &/cn(D.. �� ƒ�@ \0 \2 - CD 2b2&//{}E§®®�° «2 \2§\ cE°2 E (na) o>m��®oc �2a� {/ 7® �� b$?ƒf/2\73«-0a) ® __, �2 o_�i=> t%§p \G 2> o==o,cf>-0Ma) ;m, @%{, °� M.§ -2 \{\a$/$`ae9±®�\4ca GQG3 =!f (- g� 05¥«o®�k�=a®5 0=0� �a =a )ƒ ;Gcr �»3«aa�=�ca=aoa-o E3m7 \/§\ a& ;# -®a°n m(D 0°me o \f `227}*,]e- &6 a)0a) a±K =(D Gmoo )/ a� �0 )®wo0MC0 ®®m-\5§±2-e §§32 m-�® o \# m` 'a) C) 0>=Goo °°®f m2=, o= 72/ o\ )Em#oe�=o=c==�%&%ae °«�� =a\§ £�®=-e��cec®o� =oEm G ucu 3{ T oc-®- ° o@o\®»° g o = ` ® �So�G`fat\tc-c=MaE r-» d%f; Q° ;% ]7 ©M '00)$o7777=g-°°° ��[Q ® ®� \wg>o,n0, m tom»,-__ )_.,ca §\ ® s >,� o>e@�a)C:C: Ga m;±y 70 > `\? )\) \])/\/f�E=2�3om=- _ [e-= 05/ \y ƒ%§ -G$ §¥ oce)=3 x�[&$())a) (DCL /!ao [/=�o,_0000a=�o�� �m�o u�£c § ; 022 #{ �® ^® w w ® G� $fo .Q g §=5}2 =__ Co 20 2)& 3�0 # _,o�m j\ I. - §7 o00 !-{ atm - /3\ ¥- fD (D0 §E� )\® 0o )m°%_ %\ M. -- ±®) /)/ \G§ k\ \\(\\ �« M. /ca ��'0 EIN £ Qo$ ®�� = ��® \\ ��` //%)�Ea®I f§E 2§/ 22 ][fcu 2 '` m ��b )GG j! - \7 @& �(\ �� \/f�)a) 0m . b 7E f222= ®$/ ®'a /� - ea` 2 � .o a) =«o -7 \\®®- % £ \22 \> m>a»/ I$) (D `c-ES/f)\ _ %ffg £0.0 a) #E �0 # @qa� §\% %c a) a) )]- ao\ e\ § {(Da) * °�� ®Sm =o=o . 2(D _ %_ %of 2) / §000M j &2// as g&a �\\ƒ7 !§) $§&ƒ 7�\cn k\S\ƒ0 \\3n cum &\E JJatm ) @cn °$% %G ,o \ ¥2/2 \�\ C%\ \//0-0 %) L \\ )0):3 $ ®-®, 0(D »$t )-§of # (\$- »g G(nC/3 2 �k2> _m, ) fmG>88 7 c lmC'± -o °(D a) > < (a a=& >$o aEe,� _// =E4a a= 4=oE8== A� 0 Y d � L Q V) C O U m 15 s � � c � X C 7 N .i ❑ O O p .= U O c 0 � U L X N m C O U Y V) .0 O N T U N p U a r. N a) U V O C C 'C N 1.O O _ � 0 U O G -a C O C 7 U a) .c Q a)C Q U .0 R a) a) O 'o C E — C. U c 0 0 0 Ccn ul O U —_ L a)O C N a) a) w N V ME: O U O c N 70 a) ++ E N U .— c' O a) O O O C> O O O C N .c E U C 0 N Q is 0 U Q2 (D (D a) -C _ Ca O Ein 0) o+� ITc IMMMMM,° o0co 30 Loc O U a) S O U C OMID C L a ca U R3 O C me 5O :�0m Q.E� cUoa) CU p — Q Q. d `� N ca _ w c � O� a) .- MMMMM`MMMm T "oCU w a) �_ . c O . N U '�" a) c a) Q a)�,, _ O C -p wo '6 O "6 C "d Q (>a N O L (N N w L N 0 -p O L a) a) a) E p O c a) m C a) G y.. Q O O C ..0 a) 3@ Q N � as o a) 0 o m a) 0 '3 w� E �a c). N i Q 3p E wo p 0 U O a) O a) O T ,.., . a) U E 3 Q U) .O o ca L c 0 a> � E � E� p a)� E> cMID — `p`n 08 N O a) a) C U C L a) Q O C O MID O 0 a) O T E w Earn '�_ �'O QN aEQ CLI'D Q Y(a CL xa) : wo .0 cy =) C 0 T 0 0 C U) 1 m a) 3 U 0 L C p C -O Z a) a) O -p E O C m a) :� U O N a) 07 IMPIIMPN . U N Q� � L g Q� o o =3 c'�' > ca) 3 U w C � Y a) '0 3 ' E �� m 3 E n�Y aMMMMMIIEi aoi L'rn� a�i a�i L acid >� �a V) a) !n -6 Q N Q U U Q N O p o > N N .0 C a3 N +' a) p 6 CU d O C U a) d -o L 'O C rn.� N a p>@ 4 a) LO -p MID E ca -O () u) 3— .Otr Q U O' X U N CU C1. C L Q C W p, I— C U a3 �' a) y — O N 7 N Ca a) O C aS a) .O > ca � cn O UMID C CA _� +�.+ CD ~ `) C C O a) C (Od a) N a) C i� N 0 2)'p C tNA N aS C a) L Co m aj a) N C Q C y C 'O a3 E C -p O O T O m 7 S C O a) C c N > C V) C 0CL 0 of EE o"o £Oa) aa) of o Noaf))`° oc6c)a�) C a3 O >i a O_ O p) a O � m LL a) E- 0 2 N L Ci a) E E Q .� «� ^Z Q W Z N • • • • • s § $ % k/ . S o 2 . \ § 5 $ E \ L) k / %j �a 0 2 0 En /\ 0 rL / 0 )\yp <A . MMO . = c� ' )ƒ± ; \\\\"o E_ EZ\o jG{/ ( ) /)0c>00 �\ 0 G«$=75�a§& a0 a. /o0) Eo 0)C:M0F :£ k0M=300 CT k \ W)\ -a 2 2�� ' 1 o {E = Gf\ {&§5 E t a 0 a)0 a)cu �0 3o�3E&]aa� CL / D . . . . k ))/ }} \{ )ƒ » G MMO % (2 §\ \1. f / §]/ 55q ° %/0 $ &_� `2«s= ( � Q. \ba�22 ® = a 5 5 5 E y m— :3 — _ 2 j\ %c 2» )00 _ - �mzr o0 /cn ��2 )0 S�{E/�))/&5± c g Gy ,z Eta ec,o=c ( %-a aa� R2. ]/45(\ceZZ�/ $ \/ » \ cC /0 \)\ �G/ k/§/f\/2[&/� \ ®] t; §o° �87 $ cu /fG °,<0-2=2#2rm 2 a a 7e Gcn �_� ma _33�\/�%3-M)) k& _ °�k k(D \2® �{{±\}{�[\/G / \ b 2f ~k 2Rc %=o=��:\cemG - % &a eta2.ef § 'TMMMMM�Dma [&! Ee-Qf2fa) �» $§£ E §k ®2± f,=, oo, ®-200���2-, { $- ��m o�=m =�CD @ @�+±E®Sa=3 f gE °n(n %\ &ƒ . 2m{ 22]� �9®®\�® §_ cu - k� E CL , 5 . � - 0 ] - _ & CD /ao& eb S�\\ \®- (%)foRQ Em /�� �� 77? o_g-*-�£\)073 �/ t§�% e\§% I» ■ - 4 /7 0<- 02ME a) �» a «$R/ <m[/ 0 7 !\ tE «o C: a �E°77-' °� § $c �! �_%, 9¥E�a)a) M0efBE, a# ,_ / mf`2 \ a2 E\ ± /& Q5&5 0my 2A8 »ag£=\a)a)0) )% /j)y § . . . . . < � U) a 0 0 0 s i A C7 O a O z 0 a w O Z Q C9 z_ OL' O N Z O z O F a is F i6 C "O O � � N U e O . N W m > N N N N p > a)@ N ; 6 N L a) N m N (D > m� o m E- rn N OO) N _ m a) 4 m U ca c , a) rnU m m F U o� N QU Q �C: w U rn a) c O C U N i N C m O a) U � c c O � O O e _rn o E is E U 0 U l > o of c m .� U a C U O) 0 O m m E W Y c N O ._ c C U c ca U ca W m 0a) O c N m m N o 0 =�0 7 E~ O N CT m cep U c a) U a) c 21 m n = E Ch C E N CU co e U O c N m o C E ,a) s • o O N O) o N N O 70 N J N o Q 7 U •�- d O L a ..-� c M— N O" N N a) 0 m O O- N c ..O — U) c a) 0 .. a 0 U °' E m a) 0 m �6-0C c 0 0 0)o_mv Q E �� 0 0 m c) - ? cn O >, � z a) c a) m N (n U O. a) O. 0 a) O 0 .c a) O O O c6 C 0 o .� Q@ cn > en 0N N — ) oC 0 N 3 a) � ca 0) O N m N _O c) a) e Q N N .� N= W O= O N .0 _N @ m m Q N m 3 C m i C m -O .c a) -O w j m Q 70 r. O_ N O m W Ow ma-•3_c m 0).> W N. > NY a) y W o 3 Q' O) O-o uj 3 N > m N m O cn : n E ca O o� ° UQ c = mtq a) 3 a) my cc aci «L)70 c co— >c Esc m��Nmma)N00m m c m c6 a) Co —> 0 .0 o a) m e O u c 6 a) > N oc�.LL �E£a~i r. (n5W memo �Co momNo2 7 m E -> 0 ~ N N a) C •� a) E a) O O m L L e U ._ 3 -� 3 -O O O U -O O U •U a) Q-c t- c) m> D n 0)0 m N AM• N m c:_ 0 a) E m N oOWa'm 000mma)QN NON'p Nm N. c N O o o— E -'L. U O d E c c N N (h > U — .c -a) 0_.c UCELm.om La ° r „5a)a)n�mcucm caa)) o•c cn a)" aa) N N Om0ca)0ca k } a 2 ( w k 2 k k E k « 2 S § . }) � r 3 2 \ § _ Cl) x \ 2/ BOOM . . . � 2 § taa x . �a 0 \ ) ._ �G @ 0 �© 0 ° . \\2 .2 0 k ®E \}fm U.- ¢ tn 0 En 0 Comt0 . 8J ) 0o ��# ECU (n }§ \ 7 » \ LF— (D 0 ■o \,/acco2E / @£ =«0 R\ \< E m ®a2a\ 2 kE . 75m=-7k/{= §momom \§)\L) f \ CD. E } ® ) ) / c _ ± U ® r._ b-o U § r __ m / cc j\\® /\j ƒ/(\§/E \�-0 � j ®$ /E)@ k±\o G�3 5C) a) a§� amnia ay = E_® 0) en me\r o n 2 �0 \fƒ\)R/f f2* \®�2. ]£{Q Ch G _\§E 2G 7\%�7�§\ @&§ )\��{2$ 7[2kj@ « 2!b a) -&o _ ;@E _±_°°° ® ££� m cu �o- G/=~&»�`�� = oo�® b�.0 7=o-8mgg 77\ at�oo �. / omA-�. \w==G® / ®� ±�°o (nmc o-oQ =c=£=_ =]§_t. .0� .]_@ a ¥a G �#22�« @Ea\ ` [) %=�)f 7/E%G =o»E «« �7k 00co /}k` � 7°0®E /{0 G/ $/{ 7f& tm2jy£/7 m4A�J �C�7; {7&)}z ]f f%\k C:=3> ]��[a ®% §bƒy 5«0a &�s�o% 2{I�o,a= \Co L)_� ���-o e [± m® 8 ta® o (RE�m2 -)3%[4#% 0) 0. 2//0 a12 ems )5 $%/=m = 25»� w0 \/\m ��§]Tƒ§� 00; \//D 0(D )k§§\ a)0 �* ��~® \±§t§k§U ®% Gmee« o�§®� /®Eee/ °&70m m0 0 >4—�e oo:•- §m® %)m °2E§f ee\)2 00222/ 27 mM3:0CL e °aE( %7mm o \ LLw </<oo�<, <_e &�o U) §;Ef§ <ma §$_:§ k. mw%S, . . 0 . . m m Qw c 0 ir= c 0 U v c t O 'L N c 0 0 •F U 0 c 0 d � 0 m(n c 0 U N (9 0 O a w (n L c� z O a w � c z m Q � U C z i 0 O r 0 Z � O _c c 0 0 +� O �° Q p m Q E O _ ►FORMo a a E� w C O •- U a) N U ow 0 � O N c m m � a)w my�OY w a)o m m a c Ex 3 0 w m E m - N a- -O a a) IT .c E m MIDN 0) a) -O N X a) a) m 'o C m m m M a) c 0) a)E0)c0�mm c p0�,o —w Oar � > N L U N p_0d U•� N a).�. U U ai O > O m C Q U N U O m m a) a) Co a) m Q Q U O .Q a) O> L N i O L L •U O m F- -O Q N N F m U r N N (6 m w C N -O a) a (6 � (0 .N N 0 j V U ..-� O O c'0 .� N .0 N> Y 3N ma0oc (D0cn t_ wca)a)a)N �Z`o a v � C m d- E 'v � � '3 c 0 (D co v �, (nn C 3 �m �E'C� Q �c�ama)�ca0(D �0aa)) a) a) 0 m- O y� � m m 0 NU� Um 3•a) @ cn 3 (� C co f0'> o N 0M_ a)� N c o c c o E m m 0 o E o� m 0— m'c c ao.� c a n m m o-0 E o)cn CLa) E_Qt_-g m U aNi N ac U c— N �s .70 N N> N d C 'O L CO T -o L N N 'O l.L O> 'O m N m O N Nm QOQ.>a Ow O-O 0 aT.c. (n .h 4111 Y 0 0 fl_ > 0 m 0 C N m c i 3 N N .•OJ N O O 1.a om-omcO a)33o cCL min0L-E1.m oroN m n (D T c a) a) >i N a) O Co m O U 7. N O U m m .0 a) a Y (a 0� a E O c Ul MIC > a O D_ O N L U Q c cl _T a) O E N O) N Ca N L > a) a O O 3 (D Cm.) O- O CL N a) '=.'Ca -O ... = p_ N a) a) > N -O w N c Q N -O 'CIII. N c m x am a) N c m c a) m a) > a) m m 0. o a) CD O m U a) () (6 rnN > Q0)m a) N� Co m O-w a N a) Q O L •= O) O N X O O O m N E m m 0 N w C �w w U �° N 3� ri I— a a) U o E 3ME w.: U U > 0 m 0 4 O Q a) Q m w A O (� (D L W Q N C O U N 3 v c .c O C U O) � SpqX .i C O O :E U O c O d v 0r X N N m C O U w N >+ o U a m c a) C to U O N O C c 3 C a)N .ca 0 O O L 6 •N N O p O) 'a c pMOD c c .— c In a3 c N E c� a) C O O N UWWWWO� .MMOMM,Q ca O 0 U p '6 Q Q N N N X cc N U E O N O - N N "O L `p U C O O C p_ C a O O O U N C N N 0) p a3 a) c.o N Q" N.0 U •L O 0 N cn U C O) OL a) N O N c N .L.+ N C O C N N E O E c' N i U C a N O) U a C c N O (6 4 N 4 'O .C: p 0 can C> O.O cu C Om O N c WOO E O O U O C a) p L C U N 3: a) U N c �O N Q - w - O u- C O S -MMOM = i p a1 U p U - (n N O U C fD Q. •p O y 7 Q N p) N O 2)N �C �'O fn� O O)p C `O CU O E w C CU O Y 7 o o sod (a a) U 3 �(� 0 3 `0.5 N m c U ca 7 Q E �p c M O O D 'O C N N U N i T'� C cz � a) c. 1. U . .p O C N C 01 -6 -6 C C O N U O (/j C C C (a U O C N C O fn Fa O N C=" C a) 6 O O) N C O. E. E _O U U p 0 O> 0. C N .0 (6 a) U O al N— a) t' �U O �U O �Nnn�a)a)NU 7 0 a) O_ �. f� >.0 �2Ea �E a)p � Qa G. CL E • • • • e • • -O w -O ca C .— "a ca ca a) '— w I. U a3 O � O Fo (D .O Q @ � O C 't= N co IMMOM LL A-. p N O a) N N N Q (a L N LO N 3 O O n p O N — N w coL U aa)) E C a n cn > v Q. C-O O p •m N N 0) 1.o L N N N a) a3 aMMOM,) a) U N N _m — c N O) O C N U N c cn Q 'O U p N .0 i 0) w Q c O N-0 O (6 O c N 'O N O_ > I O N a) N N O a3 N p� O N E N 6 E L x a) C L c C a C N p Q C O.p C d MOD 0 Wo o c° lo H aa)) m 0 �� a) p �'0) cn a) � Qm.0 •� N O U N a3 _ O W10 .� _O CL CL L' co .0 '= Q N O N Q M O) ' N N '�'C 0 .N-� .O a) O -6 O O O� cu a) N a) a) O O N N E p O_ cr p p— {y Q. .L- 0 MOO .0 O ,4) Q ,6 0 CL N C .O m E c N N j N N U — !'_ (D 7 '— O. C O C O N MOD L a3 N Q N N N to E 0, O4) Q � a) WOO_O C N U WOMMOW OL �MOD N U p C N N N U (D a) (6 O Q ca ma&MM 1. O _L .L O-O O L Nt O N a)'-' OY Q O w N E O y N�= N a) N N O) N 'O N � a) N O U� O a) OL >. — C U O O) N.L.- Q N O¢ O) (6 N L '� _ 30 a) O @ (a d' OL a) pin t .N .0 +L. O N U N .0 O c C a) +L-' N N..L+ Y� m U O a3 L O tl) N .0 ..L.. N N N c c a) a) a) p N.N. a3 w .0 ai fn 0 N (D fn N UM O 'O C N L "3 N mWWWW% OI. 'O 3 L 'C c c C c 'O o. C Co co _ i N N O N Q O- a) op N O 'O O- N O_ Ca N N C N O E (IMMOM, O) U~ O a) O O N p -LUw. IMMOM,`� E mUw°ii x a) Q.� o O� y N as0 ua� C Y p CD CLCL aa) O O N "6 O .L L M �O E �� i '> O N 3 N N O a3 U a) N %r �cc �3 O�>W UL��I—E`asri o 0 0 o tLc°>>�WomE rimE %W O_c 00 E E o 0 0 • •u -7 L a N m E o� o=moo N m3 (s m O C O = ,UaRRW, •- m1. ,a m. m 0 o m m Qco' aU o_ m N m ads c� E o-o a rna� a'o n mma (n m o o'm0 mm N a) QN p a> � m >•�.•Q-0 N NDw N O_0 m.CD m .N (n = �' m a "' C a) C o— c m O L O .Q : (D m w > a) m m E c O U 0 0 �� > v o o 0 mw o m= E RRMM,� 3 c� o aa) a`� cL n o c (� �o��a,,m o �m�VNU 32 a>roEU � v)ocn m(miQ�Q mCL ��V mN> oa�rnm �(Dmm cn ro N> a 0 c c fn cn '0 N o cs E mQ >> w m N m p 3 N .J N E a m N O a �� c >O C O 5 o >.oy a c a� c U ca-a C m U c0 o o E o� a) >� a) c n a) O .O N O c c m N a) c m U E '3 Fn O a) m 75o� �.a) co E 2 N> rno L) En 0mo c aa) p C >oaU aoi m o > aL� as O o 3 c a� > Qv,c > co�'cc-ua cai 0 0CL w uo2 oaooi � nU E- m "Mv a? aci c0� o m o c m U ocm ou> > N y,.OJQ Ua c'a)vai O CL U) — O c ' N — c- �E aM coax >' Q. p N U " a) O !� o a m c N a U m0 N w L_ w O a)� N.� O a)_O N N O U N (n N> N a N o ca c a��cag`�ca a c Eo `M (L) a"6 ca) > m n ��Qw�°a�om N U — c N O a = c cRRRRRR O O p > N O O N r C 0 4 3 w > N E v� oQ ui m c Q L 0 ai m a) :� .o o � a �ca�=c.>>-E� coi 44) � .0 m .. (oi O O a O z p w O a W z Q Z t O F Z O E Z O Q c� F a O w L () i w Q N C O U d -a c t O c rnOEM �w 3 X c 0 a O p .= U 0 c 0 U � r X N N m � 0 U y .Q O C � U CL N ° O U •c c � � O .0 .0 En,O 0 N O 0 O Q m � in a) °� O N m U C N m d) O CO O� O L p m 0 a) O C -0 C 0 .— E @ Q V C m• w 0 -0 ME: `m O'O O oc -CPU U w E (ODU a) ai c o 0) c � Q° o w O .�.p 0'Od:_ m U c U f0 U Q U m a) C C .0 a) L c N T w O) N C a)C m> Env E I' U c 0 ? 7 m i N 0 U m in a) a) p c U N C '0 m 2 O L .- ... C. Q (n L_ M T C O-0 (`� O_ N O Q. O C1. C N � Q "O U m O a) T (6 O O N m 3 N i 0 N N Q M4IIIA a2) 0 0 0.0 o aci °-c mI. m o c 0 o-° n � o 0) o�'� MMMMM-0 � � Q a) fn U 00 0 N 3 L 0) 3 T m >> O m y U N p L Q N 4 c y Q LL a) O 0)'U U L M0 m 01 0 0) m 2i N m .0:- OIMMM, N N p U 0 0° —_ C o N L > c � co a) 3. t4 �O o in o CU T .0 L 0 0) m .0 L c a) a) i m C/ W a) ,� O to i '3 m O N N c N m p` O� p ..O •C .�N. m a) N C m 0)N ..L... N O > I.O. c U) m a) p c pMIMI, �''0.0 m C O U E -O U C Q c -O O O Nc C C N f- C O O m '0 0) 0 0 O •- m L p !�- ."' p U O- C 0) C IPW, i p 0 '01. a) N .Q U °' 01 a) C C m C L 3 m _ U a) N -O N c C C E 0 -0 m a) N .N N r0-. O O 6'> MMI, U N O_ O V.. U U L N a) U U) c Q C.... N .� 0 C .m OPC: Q M L Q m y 0 m• m m O c Q O U C 70 E '0MOIIIF N - U °- U 0) �'>,� cw� ° a) o>CL ° m o N U n� �15 c °,c 0) a) 3Y o N c. m -O . O m a) E cu 'O Cca O Q E1. O_ a) a "" MrIIII0 N N a) '0 () a) N O 0 > O 3 Mc .N N •� .3 E U 3 N O UI. w C m o .Lm.. Cn w-0� 3 a) N c O m L L a) .Q m o 3-01" w co m L) o (A =3 =3 v �'c� V._ ° E aa)) N o � o w c mY `0 3 0 o 2 3 o m �-0 N m ami'c m� �.� c> o -0 3•0 y o m `m3 Um0 a) .L ONN>i�OTU E33• Z c c 0)Qc a`) m� ° ° oa c - � m E. a) ai 0 m o c p N L -O _� -O N Y N a) m 0 E@ �° O a) s E 7 N a a) 0) o .0 'p L Q -0 '0 M N '0 N c C CY m C a) U '6 N r m a) p N m _O O m C L m I N O a) ca m m m O N m N N C m L U 0) N a) a7 0 -0 m O U E a) -0 m m m to N (N L O_ 3 Y a) et a) O N 0) T 7 Ccc; w Q U — m Q �_ ME� m _ m Q.> o v o c La m���Q� °0C.m���mm • • O O L 0 Z H w O a w ❑ Z Q Z R O F Z O E Z O Q cF G C O L) Q N C O U m 3 MID (D = o U W C L) •L L X C N •L ❑ O O •� U O C O •V d 0 y x O m N C O U Y - m s `O N w i U Q C u) O y U O U _ co C O f6 C O N N a) 'O C)a N O if 'C O C' V C O Q N C N 0) _ � o N .N. '— C T o Q E E O C C m 'O N -Q _ N .� En O O C C L E p 0 ^L f6 U �= O N O E N E O C 0 C O '� Z 0= N C N o W ° a'��° o 0 0 E ' cu N _a_ ca) C C O 7 f6 C N 3 m co0 a) iUCn —a CU C 'O O CE% CUn Nm >T � U W O O_ a O CL a) T = > >. C = 3 a) > ch a) a3 a) C �N.• U a O 0 () �O a) -O C N T MC U O O N > a a) a3 a) ;Q 'O N L G •0 O L E T> p in � a) N >' U C 3 (nZ u) -6N �— Q a a) � �'p c o_m o� 3> L U_ 0 T a) i• ""� a) a) C N_ (a w C 'O T O M. C N O1 N a) L co .a N U Ma N C O. w N o c c m o m H a) m `O O C O> a) a) O o' m a3 Q. U as a) c a) s c Q- v M c a) U 3 '�'' a) C a) O_ "" c-) (6 C L E• 4 N rn N �` N O a O� p O � . E .(A >' Q1 � ca m CL 3 U w Ma OO Mo 'O f9 � O a) j Q "' "O > X Q,.>—„ i N N ;O a) -Q E O N N_ N c a O U .� � Cc� :E V C N C> C N@ O E C O U w a a) C E U C ) a0. "" = a caca cn "O O_ U U N N 0) p) " N ,Q m '� > m N O O -a m a) a) N �.o CU N o 3a as Ui o ._ N o x— a) C o— L) �.0� °�.a) m a� m coN. aC a) N a) >O a) �,a) N O a) N 0 Q O — t O . O) N a) -a N U r co N U C O ��) Q �, — N°yNCaa)��o--oaa) a�°oaimC F� wo 3�-a 70� o MMMMMi 3 = m o °' a) �Y o E� n n �� me rn� (D u y as O �•2 �� a�a �L >t as Lid EZ N U a) = o aEi �3E 3 mvC y =NUo�'=� �Q��3 � ��� mmo>�cu w C a) O O a) Mo_ 'a N N 4MMMa) >i N l7u 'O ccn N C a) Cb6hbii a) y O N N O co N 'O T M a) a) 'O _N O N � C >_ o a) a) N N 0) a) a) > O U m a) N > 0 c6 C a) a) 3 0) a) a V v c6 Z a .j to O O •o '6 •�>—,, � U a3 j N C .0 U? a) '6 V N c V N Q N 3 C p '> N ca ca U c6 ' U a) a) x L a3 a) x N N a) "' O U L N Q CD a3 O_ N Q a1 U N a) i- C 3 E 'O a) iri U N T Q O) Q �" U Z ca — +� 0 (D m E E NF • a 0 L V � L Q N C O U d a c t o V � V � C _ � N O p U r 0 c 0 d U 0 r X O N m C O U a — N o Lo CO U Q C N o m ° C V) U O O C 4T- '� C C)N O O O N a) m N m o ca c w U O a Cl) > a) N N (L) U O O N C O 7 3 o_ N fn i N — — Q N (o C Q N N (M O ".' N i L C U N C 'L (U a) (6 a) 0 C O (n U 0 aj O C ._ E C E O N N N U .2 L S° N OC o O i a) 0 U N CD C: U ° 0 0 o o a) a) V- C O N �0 O Lr. N O oo-� oo .Q C c U is'� mo _ = .a) w NN C O Lzo rn O .rn c E .N-� 'V y C a) C 0 0 U o «� N o s Q 0_.0 -z U Cl) .0 m •� •� ,o U U O oQ a) (n L m c °C co a) E N 0 _ o = o (D aNi n n. o _ U ea CD • • 6 ! • • C) a a) m cu 'a 0 C O ma :tf a N O a) CN +�-' U N "p p U a U p -o ._ C p a) N@ a O N E N , f9 C a3 a) (D N N N O N -0 �6 c O— 0 O a) onQ. 2 .O O U °i d (o Q C C En N N O- C N Y O 0. N_ N O ° C LL a) C .= mo O C v= U o) N 7 t (o _C O O N FF- y .0 a) �, n (a C O' Ccn °- o a) 4 '6 °° O M wM. 0 — a) N U p) ".' w �O ;� O a) (o O N .3 N '~ N 0) N U a) N OL :9 .(n U : C >, — (n () N o 0+ � i N .O (> a) m� - Q 0 Q a) o m cu o ° U cam t n o o c m oa. a o m �•n O ma o m•E aci °=� a CU �s 0 m c�U.a) a) m a) m 0,6 o.o'o N m N °� ° o N E E a) c�i >� a s �n �Q ai N o c' o Qaa)LCL �'3 viu).>.0aL0oo.> ° oQ °o0m3c�� 0 ND1o0=NO0a)0 o Zm y°)mN a)t6cof=cb a)m �_ ��o as3oa�yas am -:oco0�o.S rn N Q 3 ` m U N O N m Q W (6 O N o_ = 3" f6 m a) c (nn C C a) N S U O... OD E (6 3 Z'N .— a) coU O.Nw i,Nw a) ccrn — a a Ems°� Via) mof63°�rn�c�3m�mm> c ° (n 0>>� co os N° .� C 0 N 70 m a) cn o N p a) .O Q a) fo a) C d' D O m v a) t0 N N Q= O N C LL O O a O .� (6 U a) M (6 a 0_ N w a U U N 'O (6 .0 N .�., .�-+ > a) O_ (6 M (O NN3' C N cu U a) Y EO O 'O m3 Ec 5 U O a) !" O Q- 0 Q O. U E m o_ o_ _ C m 4 0_ N° 0 0 E no .0 C =c (o (a (o N N N 7 O Y U CD L W Q N C O U _m v s g = O N O p :E U O C O � U 0 0 � X O m N C O U Y — m v! s 00 `O N C i y i a in0U 0 a1 U = C N U N M O Ui .o N O -C N 0 0= 0 o: 0 CL a0 U -O a)ai - O_ m OO) (D UE OU a) U N U (D (D UN (D o N ' a O O a) CL T •O N N O U m N L O N 2 0 N � C 0) CZ O cu m cNm wa)Q No• Coo (n0.0 n�Q ga Co =No mL) CNp (D E �� 0CC C �m 0cC . oC 01.a)0 0 �m0. 0 U' a)0 �mn C o C °0 m o.S 0'en p0 2E6w u 00 �= � 2Ero � C U m U O Q N ;n >, C N O) (0 U � O_ jn A C 2 to > O a) O) C- m E N a) N C C C a) N O O) C O E N C C a) N a) a) N C 0. E m E =O ""' O 0 fn a)maeffid E s U C O O mz�O O O C E O s U C O U O d U N U U N O .0 O U U U U .� m O U EU U— 2 O N (D c C O) U C U C .cu :� E C a L S m U p N E _ O Fa Cn CD Colobld 7 fn Fa O m N U .0 C. O W .� O 0) a) C. m c6 .aa) O =O U N N ca Q U t N Q E 'L a) U a) '" 0 a) 0. a) `m a) N U N '=' a) N N N d 0. c E n. � E d2 w p o_ rn .� U n m .S m ,r. as N N O m .0 m m Y d C C O) - U N N O (D Y m o rnL a) m 0. Q 3 Qm �-00 2 m 0 0 C m O) N U U m _ C _ O m a) a) MV E Q E a) m U 3 7 LL C E .� Q1 m O E M a) O a) .- C 3 t6 N N U 'C N 'O N N O fl. O .m 'C @ O M "-' _7 N a) _ Q N _• in _ 3 0 a� 3= O �. E -a O 0� m vi m coi = m N 0 O a) a) N N m m = 0) a) N .p (n PC Co Oi m0 L-' >` C N p Q N U O) N E a) C 0) O w X N 0 cL N L F- m O O '= a) j w C "� iMMMM) (L N N N C O Q C N E C C C `) m �� �;° m mm o m m E.. O N� O m vi N.0 U m o 2i 0 CL f G -O � Co E N 2 N ,t- N ._ O .� O N@ -O CIL U Q w 3 E ` �O V C N O N _ N fn M w N m E E _ O� U a) = O N Q E Q NN Cu` U -C E c o x— O N 0 m ai 3 o c:�' o m U aC C a) m (D N0 p m N a) Cu %U m Q � (D c� a) N N c N m U a --00 N in O_ N C 'O N 0 N f6 .= CU m N. d V 2 (6 "m' w.6 U aL+ 'p O C m� in N U U U C '� U C 0MAC O_ N C N c m L N C M N 0 -O N m 2 C E N O C a .: N FINE 0) C: N._ N 0� N'- - N Ammodo a ma 0 m i�p's�mc0 00m ) aNmmc) 3 F-coimaw CU'oW- mN3m a C N Cu m.0 Q m m C _rn OMENSO a).2 Q=o o00 E 0DLL E U mm N A O w L U � L Q N C O N N a) � C ul c Mo o c' m 0 m ca �-( m m � O Q U t O �Ao Q (UU ��.� 0 O A. U O O N O"m i Q O N m_ N O N O a) = C N C a) C U C U E N A. m' aMAMMMM a@�(' c on. � D m c m mCIA N O a) 01 c U N U E= O O c a) m._ p .N N U 3 N O p m .O ,N m d Lu n.? Q � O N U Q 0 N O N a) m= 0 0 o c �'nrn3•N 0 N c a) os N c m w a) N C C C 7 a) C.m ML E U T 3 3 N O m = N 0 O 0 N 0 cn cn c-4 A. AU .O C a) as rn O O c D O s rn N °-0) ' c 0 N N a3 U N a) p n O O N U O O Y N a) Q C c) � '� 'O O ° 0 c O U N O a3 N N C w ca f6 t >' U of N U a3 N m `) t6 0 > 3 a) O c U 3 a) OL p> !n E. V a) p c E Q. N N O N O_ > N L P FAA, A. O_ •= ) a) c p p U () a) Q. O- E .0 O p N N> 3 f- N 'O O N M N N E N O) c c 0� '6 p 0)A. c' s c ,� a) N N p c .� c c OAMC cn ca C E N _m 0 0 'OMAMMA, Ca O_ a) a) N 7 7 C m al .a 3 T N .� C O `p d aS '� o AD N L a) V O •(6 o ca 0) m ma c N �.�$ E m� m c m 0 �a 0a 3� E csi E m rn m o c N N E U Q E N E = w C N o— N a) C 3 O a D 0 N O> O C N yN, 7 U �' m O N 0 C 6 t a) + O f/) 3 N .-� � c0 N N O) p 'O a) m O) U N N N U cu a) N 'O N� 0 a) Q 1 'Q a) L co N�- -O 'O N 3 3 =) E O a) .> a3 .> N> O O c tp C N c 0 a) ;C 3 as ca 0 N c m a) aa)-0� o COY a0m o.E Ev m 0 0)ca a) c0oc @ N: cm .0 N o 0 Em•N •� �m 0 p Mmm as 0 m E 0 3 a) a) m m c 0) O .0 a) N N o cn N a) _ .ca O N > 'Cu .— N co a) w, CU N ..+ N .0 m Qas� om 0 E a. Qo o n w E� m �m A N ca w 00 N C C O-0 EO :N O_a O' N.Q N N.3 N O,� Q 0 QN3300. amQmA.co A cno Q0mom� A� 0 Y L (� i w Q N C O U m L O •� „ X C •L 0 O •E U O 5 c O d c) X d aL+ Lit N C O U T N IMMM 4 O N � i CL U N O N U , .0 CO N -o c .U3m O ,6 t') O N N C U C C= d Q U O N N U N N C an - d C LA CL N O (D - O_ 3 O E O i mUL6 O C N O0. N O LL U E N O m N m U O N C O 0)c A c c cnN Nw C U5 O v •E U N N U Q OQ U•C U O� U N N i c TE_O M. a) m c o _U E 'i p N N s Q N O d0 cv �0_ L1��m LYw Q. O• £ Q' • • • • w f6 N G U o n o a c� ° o 0c O 3 — Cc m> 0 0 o o� rn ai a NM c O N O N > C O O_ Q N T >G O (6 2 i T m O 0 C 'C N O p 7 C ,O 0 `° O p an d (6 E E a� m N 7 C N N O � C 3 s om E L m N N C' N O O o_N O oLo 3 a) o) > m"> m N m a) 0�`m somma O O N m U m I— N m C E E fa C O a c m 7 p �«`-. N O N N a� w i C O_ N 0. 'O m O 1. 7 O, Nm -0 N N N= O E �' fa L m '6 0 N is O p •� O N 'O ' N 3 m N c aN .0 3 U n C m a 0 m.� t� (Dw m w` 0 o 3 mw 0 c m o Mcc a o E C N C .O N N to — O_ ++ O O t N� i_ N O U N C v- O N m N T — fA — N C d C (D m� E 0)(D c-m`o m o--0 ro o a)ia ° c>� o= o= D u m m m E' n �Cm Lm' Hom a) c `o m m � a cu 0 (n3 0 �� c 0 �� a� > o � mLL c� p iq 'm N O E N -O C N C ..-� Q C m CO O N 7 N U 9 i N O C O +J m =1 N N O U N N' Ic:N C m O. O O 0. Uc-• � U N Ca C 'O m N Q 7 U O_ m U� CO O =1 i O O O N N N C L U -6 E> _O N U O N OQ Q O .� N '06 O C f6 Q N U@ N C N 7 :� C O) m ��N NN cN�Qcmo oaoiE3wE o�'mc's �oo.c�a, a) m •O N U N O Y O7 •- -O N C Q O- U= N .Q C •- .� N N N N O) N -O C N N N O Q U d Q •7 > N U C y1 p N O 0 0. O E .E C' ++ O m m 0 M C L— O m N O" N co N j N 0 C C N O O E o C f 3U 3 mw n m n�LL� a) �s d d o Q w m N °� 0 E aEi ++ O LL P N O_C I� M O) m Q E 'O ... E N M § /{ § 0 2 \ § A f\ ~ / kk \ L) k . E \/ . x . . inc 0 f y\ Of E ( $ � - = 0 f \ 3: §/ƒ kG § �� § \ `at @% 2 /\ M kf§\\ $ G� 0 m ! a , `� % E EQ c0\ %) a 2 % \\\\\do* M0 c \� \ o°oc m/__ \/ \\_ \\ \�o E / \ M � 0. E - 5 cu M°®° 3/7}}\}/ D Ma _� _S E/ \2e} $ _t CCD 0\/ \ ( jj/} MCA r 0 {\ j00 ƒ §[Jk 00 /\�j kC: EEL )E73 s \]/«/§ �f tG_ 2e ik 0m0 /> JE/502 kk }/G )\\k 0E Ja0Ca 2 $, _ _ 2\E / {\ U) 0\22§0 (\ \c $/#\ § \a\)&fk _sue ; n /&\ k(D 0 f\f»§/\ $ a3¢Q Lg64o©n %$ %§0 ■ !e ®�°2% J�\tƒ)) @y® in $ �� (n ®ƒ�/a ®]=)E02 ..m&oa=o %$ `E\9\ Qyy[c:o ` / \�� \\ja) §}/j3 / /\ /\ �S § \\( (D 2k) {\0 oK(D Jm) \a% / / _ 0 e 27f\§0 j a (D > _ o=2~=mom c �//\\§f/k \k\\2�0 <ze�c/=Ab 7\\k§%/2cu ) >_ $&±'a \\§22�>)n oE=(u6Ecu ®®>`:W, %±Mr.-0Ca ® c°¥Eem°Om § �±�;e2>oE 8 t«]&/®®a- " D0 =®&d# ��� 0 ice .. > \ @ o k55§�\jo §fa)o (DD G unm==o_5< a 0 :a L V L W Q N C 0 U m a O = L O U � 'L 3 L 0 p :E U O C 0 w d V X �L3 m N G O U T Q .N _T o U a tl) (D T V) O 0 t3 0 CL C cO a) a am 0) c o wy a O3 O v (Da) Q() Oo- CO 0 E L O Q 0) oD a)o 'c -o ` a w o. w (D'� ° Osmond Om C a) a).� U MPPMR°� (n 0E R Q (O N Cu ° " c rn c<too. aEnoi.c�0 me ca Ea) o y0 Q E Cu fl. 0 a1 (n c fn a) N L N • O _ NLO Cu oo,000m a) _ >,3 U 3 N%O �� .TE O � � ac)w o ro° a m �.0 a) U� 0 O o 3 O O 7 O Q 0 W to N tF, 0 ° 0 0 ° O. a) `� O .O m Ca rncc � °ico•�� CO o N o�� � m a�i ami a)� m.� a) .. c i O O Q) O CO oMMMM 0 L +'�' N 0 z 0 `' N m ° 0 > 0 m L '6 7M0000i 7 a) Cl. 0) Cn Ca 3 T S Cu '0)U CO U N °� >1 a) Cu (n N G N 0 T.N a) f° C t a) �' Cu . }>,` C CA Imoo, O U U Cn 0 0 U a) c O3 O L L U � ul D w 3 0) G d1 Cu L U c 0 c� 'EC •� 0 0 a) V a) LO a d "'.' LO Ca U O L m[- w-� CO O .0. '� Cu O C O loom,aoi CO a) U �- .� .mC _O Cri(D o-� a a) o m� L^o �w oQ ° Nome m L m,0 oc c U� m� � w No CuME 0( C: U o c 00 E �w=Q= � � ro (D Ca 0 Q a) -C 0 0 Q -O L� N — L N W V o U N a o N U L E 7� w N E a) N N N (6 0)wo...�c�63 Cu Ca f° waZ-0(n O°��amijQ(n �o ami ° COi? c ' ° o400s + m� c N T� °'cam—� a) � 0 Z m a) a) m c°i E aa))X. a) a) ca cM w� 0)>'° o (D m > �_ o600mo c� �� ._ a) C1' a o ��$�UUU m O N (O m a)ofoom O 3 j O O ° CU NLO. a) N N> 0. w�., L N m U to •N Cu a) U N N 0 ° C LO c fl_ U@ a) U U U U 5 U U 0 d) .'�.. Q :1 >+ztf I— N U 0 fU ,,rn U a) +• N —�. d C x 7 N >. Ca CT O) N _ a N YO N L O nc mrnrn° m �a �` a) °— ° a� Ana a`) :3 Ua D_ 0 mo d� u�cc. 0 m 00 �c00a)0 rno s E(D000a) ��F o sabho •O M — �a c R 0 '� N N a Q p CO O 0 'T a) m V) N i '� a) N a) O_ N `� fO Cu c�c O 0. O O a) , E J 3 L O _ 0. L L C O0 O 0 0 O COc 0= 0 E U U CO = a) U T 4_ L 0 w Q N m U ".' 0 m a) O; O m CO a) L O `mw iV.. O) �c c E UUL—=° o-> rn.c -C 0W o- t— ac`aQ mQ¢�� m Cu o m a 3a N U� A 0 s. U i w a N C O U m 3 'O = .0C O N C U LOOM X c •% Q = 0 0 :L U 0 c 0 Y �O i X y m C 0 U w - m Q o y T U C cu O U CL o (D U o: U) o` 'j ° M tj o c 0 0 O a N U E 0) WOOM A 'c O) C c 05 o c 3 c 0 (D IMMOM, U '� '6 c O O w i U .0 LU 3 p •L 0 O U N co L ° O 0 0 o c m E +' F L6 U� 0 Co c = C ' E 0 U N 'i = = .0O U :� O O_i Cl. c 0) c 0 E U) 0 i a)coMM� o 3 U -� ornc"= O c O c ty6 a 0 'O '.,0- 0 ME U 0 G O) � i c c (6 ... U ca �_ c O 0 C 3 C ca U •� O a C 0 COMM c o O 0 0 N p — 0 E Q a". E� c Q. Q e • • • ME L6 a N c U 'O '0 w O c 0 n Q — 0 "O N U (0 C .0 O O c O. . _ >. _ h 0 Q c 3 U O 01 (E tU c U `� 'p m c L 0 0 .� 0 ° 'O c0 O N c6 O 'O E Q 0 N U)i N 3co c m c U OM.^ w N c- 'L' 'c � v 0 0 I @ p o O N p c N (A N° a U N .0 0 (Q6 0 U N U '. U O) o Q Q. 3 7 0 N= �L,,, U V 0 U L o) U o 0 U 0 .LO,. m m -06_ Nsa c ° 0 0 •� Q O_ w Z Q 0 '6 3 'C 2 3 °- O U 3MMO O N ° .-: �' c C 0 0 0 0-0 .c •gip (n � � Co 0) MMOMMOM� C E 0 0 0MOMMOM 0 'L'' Q (6 3� U� C T 3 Q a) 0 c N C 0 N c O c 0 O 0 W N. 0 O O 3 -O FD C E O O 3 N ,O d1 4MOM '._. U ZMMMM U O O° O" (6 Q N N O_ w __ 0 (h 0 .� 0 CO `) CO f0 -O N U 0 c(D 0 N 0 0) L" U° 0 T .LO-� C c) o L N 0 D a) O 0) 0 y 4a) � y 'O 2� N�° 1. O 0 G O_ f/1 N 0 N O 0 c V.6N L9 N~ V L�>.p-p QO � > c > 0 ° OQ U) QN N?_'�(�. .Q N w f6 C N 3� O) 0 3 0 V a. 0 0 a 0 co C d N p d` 0 >' 3 L6 O O 0 0 L6 O FU O 0 -O N •� N N a c L '� �«-. c m L O_ L N MOC m N LO U O N°> c a 0 S 0 U i 0) 0 L O_ i L L N N 3 � N O . m 0 N .L..• p Y •� N m N c6 :O = N C o O 'O >' U 0 .N co m 0 0 �' 0 0 c y CD 0 O U ° LO j 0@ y O 0 0 O U 0 0 0 'p O_ U� 0 0 s 0 3 0° D 0 0 (� w� cu 0 to m U MOO .s = O_ U Co y 3 +-' NO c U U V N O.. U p- 3° `) N N �) N O _0 IL R N (04 N L N O 'Q MOr .LO. 0 3-0 .0 Q 0 4 � 0 0 0 ' � d .O a U Q N �- U Q a' N N 'O .0Q �.Ul c 0 N -O — C°' O- m -O 0° 3 O_ a 0 to o c c f6 > o O c '= f6 0 O p. 0 O. 3 0 c a) C N M N 0 y -° .O U ._ O ._ Q ;J C O1. N NL-' O) w 0 cO a "� c N U 0 C _ a) 0 C y 0 w U 0 0 U O .O U p 0 N 0 S L Z c i<'�. Q p O) m a M O U co f0 o) 'c 0 3 0 0 NOM to 3. 3 0 O N ._'MOMMM 0 0 N .O 0 0 Q._ U J" C J 1+ N U Ul N c 0 0' 'r. U U N N c 3 0 a) M C "o a) U U Q) f0A ..L. _� •� cn -O f°/) �o w w'ra>)� m0 N .0w oQ o m E m �a aEU� o_N o_Ea c°) a0i R C9 O L a Z F x O (L w 0 Z Q Z of O F z O E z... O H Q cH G C O .0 L L W a� 0 U d s O U p) V cn _ •L L _ � N C _ O p := U 0 c 0 U d 0 i X CO N _ O U w .N = _T O U a tl) N d' o 0 in N a) c oCt3ro E OS p N � C C ca ca ,O O Q rn E o 9 ca C O N T O �co U w O d C Co Q. 7 d _ O � Q QC. Q E• w a) U >, 0 O t U U c Y -s a) C p 4 ..�. —_ 0 0 w co O sFIIM O3 0 "0 U IID COr N CO 0)m 3Z-0 �3 0 cC. o � (D0 S s � a=) Oo m 0 > N a) m. o w'� m o aQ w o a co n L �IIPII;� �.rn•o Z aa) � o a iiIII MIIIIIO McIIIII Uver E c a) U) `� mo a) u u c ia� Z o > m Q.E ° LIIII O0 aOiw Y a) °'°'a = � E m > = a � o 0 sa�NiMo � 0 M 0-tf.� c.� a, O U C Q O U E U @ (6 U Y C Of .�.+ O) I- O > a3 N O f6 00. W. iU N N O3 O w O O" C m '= ) N 'O a) > .N R i •� O CO o mmwasa)� N U3 m N�ui 1. U-_L) �o sF-as�Epa)Nasm . w N '8 F- O N N 3 i N -O N COU Q N E .N a) C) � ?i 't N O U O) ) U C 0 Ln a= O_ .n 3 N :> -O ' O N X 0- 7 N 7 N O a� J C= U Q = '� f6 O N a) U) O L N — N O C N U N a) O= N N m �� m � o a) 3 m 0-0 0 D =o =3 CU �° a)wQ L 0 c.2 aNi 0 cOa Ov m O U 't- N M O a) O• N N>� — O N vo) > N i6 c 0) N U F- U N cl N '6 O_ U N O U N 0 p >O w OS O a) ,O Q V (O N r (6 = N .� (NO a) O a) C o N �' O3 a) N 'O U "- C d N L N O_ o IIIM " i U "" O a) L f6 O m Rf o M v O3 .� E N JOIN, U a) L O_ � N O� C C1. U N Q U O L U y i 0Irt cn C:Q G a) N f6 OS a3 00 O N N O N m N 00 N w O C a) O) m V _ O C _ Mz m .LO-: C ci a) C o = a`)) U >� EO o m E c 3 OF m m U a) (mi ��a) E� �•o aa))� = 0 a) 3 ma 00 ° U m= m 3 rn a) a)� �.g aa)) c O 3 N w ti 0 C a) is o i� U C 0) a) a�i� N o_ N U N N O3 U O_ MMMMMO O .O 0 O3 a) N E cu 16 U E N r!' 3 •� O U N '> a) I Q 'O i a) N E Q m N '00 N '00 2' '00 '06 p U U) m O "= O O a s rn m U7 N O o ." N ' - .a) �d=�m0 Co (D MINORQwaaaw� � C\j0 U� CL U O M O W N Q 2 U V N 0 0 .... ..�-. m i A a� mmN ov � N � u�m boo a cm @mow °N >' J z N m 0 O U O -O C a3 O_ a) o '= O co O c m��'m�U 'i ��M'L) o m rnrnm �� a=i m S 0 �� m as 0 G N U 7.N a) Q-� @ a3 O U N 0 0 O C E m � -0 E N cn O N 'c 0 Q L O E Ci N H N� Q U � -Q C N C (D 0 2.i N o O o N N Q) = O 0 0 o (n a a) 0 cn i fl cm ° � �'�' E oO o m c 0 o'm. w as o o cu _ - -L• Z m as c o ass = �� m Edo.>_ c 0�o c o c m mQ �mmN oN N a> �' 70 has - cu a3Ea) p U(D� cdaci Q aci � N N o� c m � 4) c a) (v 0 0� m� 3 a� � N 3�� �N 0 aEi=o mm"= LLl o mQc a� � ° Qm 0 m o0 0 -Ncn Q o o-a m asp as O a°i m 340 _ 0 E co r: Q. a°'i m `�-0 aoi m °� �� m a=i'm—a°�. �� N E �� a Nw To Qom o om mom �� N @ �� m `o-0 c�Z �'3 0 > o o 'o aNi N O m h U '- N a) O v N O N E m O N U a) Q 0~ N N N N 0) c -O �� �Z Oovm °i �\Z a) EU N Edo 0mt NCU ti�m'� o Co E� ���-0 (D 0a��Y`o N m E aa).0 ° F-o o m w N N rna) o'�� co o �N �� o c `° �a 3 c.E ° 3 �c� m-- 2 �' a� c o E aNi ro o _Y o m.m ° °' o m EN a� `° c a�� o ° vim �m m °' L E mQ L E a°i o ° a_co 0 a�Q moo-Q (D co (D a=i v C: � N m Q E m c 3 cj o Cl 'fJ1 CD (6 N U Q Q. U a) "O f°q N U N C°70 J U ° CO m m o )0 FD-0 -mU� � �.S ain- CA o o m EF-Qz E a m mLr. CLQY u i A O w L 0 z F w O a w 0 z Q z 2 O F Z O 5 z O_ V F.. C O L 70 ate:: a) — 0- L a)cu o-� ° a=i > a)t o 0 o aci °) E Co N 0 ion c o N a) 'a03a)U=a)3�. Na)a)oQUccav-a)m•)�E 3 'p U N p Oa) 0a O a) U N ca N ca) a'0 a3 NLN¢ 3p c N p N .0 o oC3T aYJ'C�NUa) U T � � oM� ,�0m�� cC)o�0wt�o0QE0. Uaai (D�.UTn ? Q Op �si�a) (.0N� O)U en 1� .0 aO=) ��orn�c � a�� mm�o aT ��Zo=°D aoE> E uU)oos(D a) 6a)o�ma)a)�m) ) a)CO O u@ ow E �o3asp Q�oQ) � o OUUm aiNo a) O iUOV� a7NNOt p cm:z N Q6 aQ�U N ° o m o Q�E �t N 'o N aa) U O ca O E aa) '6 cm: (D Lp C O a) O N a) U_000-a)oa)mNa)Mrn-CCa)tfa) i cu aoic' a) 0�a)nm»�c�m�E` Ema)u)-Nm�°EaE2 Qa �c�QQ�Qo N cU a) � �N D .c o-a� A c O w m � 4- L Q M C O U m a c t ° U +c N c 7 �L L X � 3 N O O •� U O C O � U X 4D m N c O U - N Q o N m 0 U c N o a) U 0 O IMPIMP ro U c MID' c w — N CY) a) a.O c 2 mZMA O N -° c cG i N O) N N to O- > CO ° E U`�AWWdWWW a) U aUa5 1W R n 0c 0 C N-O Woo) a O N0 °U (6 (a w )o Ua �0o L a O •� ._ o- o a) a o :u U N a) c O U a) c Q N c U C O C 0 c 7 N (6 N Q (6 a) t6 c 0 N 0 0 0 a) O E tf C U K Q U E Q E a) ° Q O- a) � o o • s a0 O N 0� 3 JC: 6 N E N .. "" a) O N — ca (6ioya j gU oU 1. Q N o C ° ° -a U CIS Ent al co Co N Q c Co r_° U a) n ° 0' FQ. d O MOMMA a) Lco O a)Y 7MIMMIMM'^2-O O wL•�a (6— m.�-+ N CL NU. N c Oa N c j O U a5 U c 0 O I a) I> 0 N E E N E U L 7 0 "" a) E 0 N (� 0) X Q 0> N NQ U as c° U.� Eta o c E a) 3 m� m �._ E N'c (D ate) c o o" �_ m N �-° U_ a) a) m C M N a) O U U a U a E p '> ° a) O) 0 0_ 7 .S E �' fN >, C M >� N U .c O) t O� Q O) w f6 Q O _c a) O— N f0 U = U O .0) a) O C .MIMM,IMPIMPU '06 w�0.. N -0 w L L 0 0 0 a5 c O) " O a) E 7 I N 0 0 a O C.0 N U c NWIMMIM 0 �. D U U a) N O) y C CL (6 C a) c ..>'. — a) O 0 V O) LL U 7> C 'C U U Q U c0 N L a) Q O a) E N > N •� Ucn Q (a 0O O O> Q c V N O O 'O N �' N a m r .L.+ O) MIMMIMO m ❑_ N O O) ODONNE MICIMPIMP N a) U f6 CU. w a) Yam„ r E C Z C @ OE U 3 -° "O O1. WlWMMoN O O > L .—.. O I. m N '_�� O +N' .VMIMM, N N Q a) N- NO Co m 0-Q co L Q O N O Nca OL w'O c C c6 L'(6IWOMMIR Z to I.O U 7 �- >' U Q- N fl- U N N> Q 0 E N 2 O 0 > 0 (D U a) o a 'O'' M m 00 N 0 w b' asp fac4 to m �= E Q m rn° 0a� cM -0 N as c o mQ as a) Ua O ma �� O c 0 O ~ a) O Z ° c E to L c a L c� 0 c N O) o a) � w O( O p N 0 U al y a3 C. m o c 3 O o �•� �w a c a ci c Ch 0 0 oc�� c O �: UU)•�� 3 rn� > c O .c N U c o M= Q N ❑ ° O � d. Q ai aa)) CoWIMMIM wC:L •� 0 'O 0 O) toil r. CU Q a) 6 Q O� O J•MMIMM, UN O y 0 O N O O N N O N U�cfl O a.a o, 'vUVa • a N N a) O Co N p c U LL1. Q N (a c N p) O N (6 a) N y N Q,N O N 3 aai m a) f°a�L c sm: C7 a) •>Wr, N Oj O y0 E O Co 7 N �O a) N N cN co CY) = C Cw O.Qd C m a) a) o c o` 3 n� �� a � > ��2E-.Q0com ccn 0u) 3 C � R c o N N 0 Q c ° c w 0 O— C:_ a) c + O ' O j 3Ep)uL) a`))�ncn" ap)0E-off coC: a) cuooMoa) mcWcU O L 'O—j to U 0 ..c O O O O U Q E (6 E tNVn d W Q. t a) OO L ca m m E Q 0'3F o 0,0 act).0 p w E � NO a) c t� 0) a) O d U O O� C O O N a) 'N U ,c L U U L i t 7 p L X c O L p L p" W IC—a'�L)) 3-oo cca m a)wa � M 0)CU y a) — a) �` O •�-U N D O.. N 'p .c N p p a3 a3 L pO O N N U a) aS a) O w �' O- O N I. N M oaci Q c U c N� N p V o E L �'0 E o o �a N .c O (n O co UI. O� � J cn w -O O (a 0 0 0 N E O �o O N V U ;� N N(D p -o O Q o Q m N 0 w O c c m m m s a) m W m N'mm L m E o.�caa ro o_a) U aa))� m e c o a'L ca c C O co a) E Mo.) m fop m a) M m,0 L O L U c ._ .L.. (a °a Caa)�o0>CU >m a`) U N a) a) E a) O Q O -6 Locuc(D caZmoNQ0LC a o-a oa Q� L E ca �' Q (Oj O C C a U 0 ..N- O N 'ca m c m O O N N a) t L OCL.C a a) Wo a) Q (a fn Cl. N N .�-. O a) I... . p N 0 U Ua).N� o c a3 uoi U N w O N N N � (a 7 U -- o) merino c C: O U N E (D ca E-LL oa3a) �u)aa))� � � c in U 7 O � O O O p 6 p O m O C N O m� � o m N W� a a m N N O U O O) — � - N N p c6 m N a N o 0 a) C m� 14 O 1 3 0 U = a) 'p)0_ c m 0 3 0 G a '� 'U Y a m O' 2i 0 c O a) Q— a m ' m N N O C p N C .-• .i V) N O O m N— N m •i 0) 3 N L U N �w� c m E o~ `—' a) c `� � °'� o m C: I ocnrn n. C a� m � c� N 3 o os U o E"_ E �U Na o 0 o�rn Q)a E o m o 0 0�� QN mMMO a) N Em M > m m °' @a cn Qm� o o c E"c m� .mm �ai.�>aF-m�a �m E��N0(Dc c ca NNo orn m a� U co -0 a) a) Boa U :3 m e o m o U T� a))-o E— U cU o w a) (DCoE�' c Ensw L �m m"� m N a c o@ U a) CD o U ai �.1 m'c o E c c U= m �w n m c E 0 o a) 3 a) L �` O- Z' a .0 m a) O- a) 0_ w m co ~ •� U fn O a) N .0 L co oc� U) � >.EU a) > m a�i a c c m o cU E o m �'� �.� o-0 E N _ o'C 0a c m � a U) m oU m m a) c oa ai Taos rnE 3 > > E �_ aia ca)i �D ca)i+L m ro CUa Q-aZ � m ti m �) 3 � a) � ma EY m rna U m c� Q Qsm aa)) ° m a) Q'N m >Y om (� u3)s m aoi E� 3 a) m.`s . E E" c >mm m 3 o_m m p o o OF ns. �n p.3Q - as u3i� as o mm o MOP� a��i uoir w o� ha �mn o E aa))� o•o m m mm =m m E a�'3 c 0 � � �� > > ��^ c)C m (CL DMo � (D o wa� �.m-maL�m�3�a�umiLa)�� �'�a)°)mii�cac C M a)>�ENm0n E 0 aNi� coa)�� o o Qvo) C m o ° hmL o 0 o (D o� m� N E E 0. CD rnL D o m Qm � (n o_U a)�o U CL.Q o cmU QF- cn o=o N 3 Qo N T c� O w a a z p of O a w z a c� z Q' O F z O E Z O F Q O o � cNiwF- o o.Naa) > En.3J =m aso`° 3 o EU a) c o o m > m m c= 0 c 0 ocn ai > ovo w �� 0 c� o c �o E as 0Z N oU `" o as �0 0� m_c 0 _ oNN O a) Ea) f a) oNm� ma) (nn-0ma�t�a�iE3COmm U o N 0 0 o E� � m E o ? m (D c 0 v (D.o.0 00 Z E��` c o as-c 0 �� o� o� rn oU > os 3 ar. 0 N m a`)w� o =w a) c o-0 a) oEm` -'o oo �a)m0 �N���o�� m nQa��>rnrimo�E .� a��a °'E m= a`) _ o E c('1 Q Z E. o E- a) 0� �6 c c n N' -, :1 o �w m m c0i m aD o o aL).o 0 o m.5 �o� E o E o� o,o c a3 m Eom>0No-5 c=' o-iaa a) a) o>iac=N.c= -- Mo c N9L 0 n� N C as N m a 0 E 0 vi~ cp0 ��y"= a: o as . o m 0m N oa E� N �.o E m = 0U� o > � c a) (n o" `o ° E o m o-�MW � F5 M 0 cu �.> E" aci of °w a3 m1. cc PC: � a0i� o o N �w c� 0 E O�.0 E 0 0 0 0 ca a> E o 0)ci� p 0 MO 0 0 �� 0�' N cSn o Qcoi m = a) Q� m� = coi- > m %Z m o m (n o oQ m2ELL m M (D am to Q 0 0s 0 Ns m c m N O.c as a 0 w o�� 0 0 c o. H >+Lcw00)m>,� a0E-ow m� 00 0(00a)=coic0i0 oQ ATE ��� C oU m c�� o N � as oZ o,ca Q� Co MID o cy a�icn m �.c o $Mo asp o o cqMMMM"= m m E Lo cU .o E l m EUIMP. t c� o Qm aa)'Th `m N m o� oL o ow = (D E o'm.L� aOi � E m E E E (D a' c �' `4 N 0 o c � Q. N �a MrMPPM o N E� 3UaU �-0U 3� UQ-000 �7 a M mQ o M c E c o 0 U T "m 0 0 N m U Q m _T C'1 U v- N o N 3 •c C N > a o > o O 6 U m U O -O O a) m = O o E Q E m a) F C a) ow@oa)m C C a) p o_ a) -a -ow U 00 Q U CO N C N > '- ML, E Q� J m C U a Z N O _ O — o N Z N N o sU L .0 > C o U _ m N 7 _ A N ov ~ a cn a) U m O Z Q p aLp. 0 Q N Q O— " n 0 N m me N m Q C m U 7 .� p a) N Co a� Q E a 0) a a -0 N N U a) ^ = a) c > 0 co m s> p c J cl- (u rna) o� N � c aa) a) Cc a) O •= E N t -o a)) C O.— N N a) N C C C = U a) N U •� .� C LO.o C N O E m N Q m o a V C —_ 0) O C m a)o m m >_EDn (6 a pp O -0 a) a) Z a) Q 0) N o > m U a m (U a) Z a c 3 m-> m U O (� y�.GEm-0Z X = rn a o - cm w o n - o E � 0) o n maw E m N N 7 m — m p i •- 6 `� N C E o a m O T C Z U '� o (a C O N O O y C U :� > C Q E O (3 p m N 0 U U R) m C 0 U a) C S m L) c 0 Fa U U U m c 0 N m Q f6 O U m U m a) m E Ew o � L'a N _ > N C O D C U N c 0 V N rn E � -o a) @ � N w3L, T a) i m L 'O U O N O) 3 O w' N a) C L — m W o- coi QC m 0 a m O 0 N U m_0 . m `o L C a) �0 0 0) N m U 0 Q O r o�Zi) o "a M.0 0 O L U O m -a U N (J ?mod _Q c a=i U) _= 3 3 c m a O 0) , 0) Q a� m 0 0 U C Y= N L fa o N m (6 C U ym .> �l 0 m O o) N '� U .Q L. — mE> a) T N O 0� U N L .Fa a) � C a) C y C N O L N U O) J N p L 0� Q fA a) '� C C _ 0) m N .0 p_ C a) • d .N N UN-o a> 0)� `o m a) a) w a) a) N E°)aa))m 3r°) p L) — m 0 0 N U m m�a)m>am.,Ca > m' m —�� i. "o t N m a) o� m N a) N '0 C i o c o m a a oo E ca C N a a) U O N N 0 0� V U C Q U O- -0 m Q p N N g o a� (D >,Q) a) Q Lm O "C C f6 m C m Q a) m N 3 O O U aim. a � U m L C U i m U m� sin O N C 0�. C a)NmmNME: C Q C O U> 0) N t0/L) U O U N a) (CD: C> N N 0 C Qa)a)2Mo3a) N w v C co a m i U x a a z F- 0 a w z Q z_ 2 0 F Z 0 5 Z 0 Q p E _ 0 Y L � a� O U m 3 ,= O fn C X C O Y O p :E U 0 _ O CJ d X m N C O U A N O N T U > � a) O_ c N O (DU C g o p m N O o_L� C w 0 4)° (D_ 0 (D 0 0) o rn rn E W1.� C C c as a) Q O (Dp CD7 O U O n N O N O E 0 0 U O C O = N O) C O- O N U O N .L .0 O a) U N � c O y= = Q. a) E om m O@ O a) E U 'O N E o rnm E E C a) a) �U C C O_O � C U. 2O E NWC C O O O O a) 0 ca :a E U Q O �= mU o�.�Q of Ec U) -O m CL 0 `cam Co C O , O a) i 0 N U M N a) '6 _ O :w .E .0 C w E N Q C O WE > E :✓ U 'O U. O U U O 0 0 %WWWN m a)a3 i N U._'— N � @ C fp (n 00' 0 'O a) C O C yacu � O C m C CL �. a) O O O N *.' C O 0 0 U E O U C (a N w-0 a) C OO) G Q- a) aT+ T N O) — N C N C N cu a) .>'- U Co a) ."..O .o i Z, �, L O U E U _ c -0 3 C a) o' m Y N N m a) o(n m (6 O- a) L=. _> U O O Y O', > m C C a) O 'C a) a3 a3 .0 CO U wp P O N w C a) U> N a) (6 O .UL T 3= U O = -' a) C N' E rnm m o �� �' m .o .O O U C� N.N W-w3 N a)U A U r. a) N=a) N 01 U C W' A •C U 'O � C O E Z U a) N E. 0 t E O =- C N N tl) L (6 .a E t E 0 -° m w N O O) C .0 E N .� o 0 a)a) p O ca �_ Q Ec Q) 7 a) C p 16 C Q (O// o p C V a) m L C O w U C 7 m� rn O mat O m O C� N > _ 6.0 O N C N 'O U () a) O) O L YO w O a Z N C a) U 0 0 0 O N C 'O C D '- T p -O N m a3 E U 7 ..0 Q N C-0 m O L > 0 '0 C w C UImWW, O w O w Q �" o O) N ) -c: Q. C O O O ��.� c w y 0 cam' x ono 3.cQ-o�`> a)L 0W= FL- >j 3 CO a) c p) p fO/) = 7 3 X 7 r o�'a�� 7 <- (D •' 0) C a) N `~ a) Co C N �_ o' 0 U N' ty O -O c C N_ Oj d a) N 4@ (6 .L.+ > N �' a) C C 0 '6 WO CO a3 a) a) ' U a3 C (p Q a) " E U p a) U �' a) U .> N (FLU u o as o a) w .L-+ N c c U C O C O .O w a1 a) T O > O),� U a) .N a) N a) O 0 U`1 > f6 N U O� 3 7 � 4 o M a) 7 +� N U w c T a) m N o O Q) �a C ..L.. N a E O 'O m L OC) m= c L ._ O Q N 0)> C C 0 C N C my as OWWW c o a) c a) m a14i rn� EQ a)w a)a (D rn-o m aa))� 3: o (2 i m E >, T C U) O a) N O C L a) (6 a) Q O C> O Ca cu 3 Ei n w '� o co O a c w '� m a a) = o a) o J J a.� a�i aa)) a`) m o .m m =aim o�L L m a=� � °o o ° C Q. E c � m � N� a°)is � aoi o° a U U aa� 3 o E, Na N a) 3 o as mY o f rn�._ U Q a) U § § 4 kf 3 2 ) E $ E � E j) ME . k % k/ (D0 0 \ co m Mo § \ \ \ _ cu k f 8 8 ; � o \)§ 0 % ?\ } 0 \ (D 0 7 / ��§ \ / )§/ \/ \\/ 0 ( =ma® �j§ aE'D 0 e o=c a2� m= �»= E) ){\$ ®/§/ KM G k0 k[{ k C 0 §� \ ° %= f a` #cu §] k �� 0� E \0 \ a) Q\ . a=eL 5 0a) 7— CU {E a~0 }\0 CL t\ 0 0- cy) /S /L) // \] ��\ /� /D j/\)\/C\ > , �7 ± \7c0c0):3 0tt7mE S\#g\C 0\ ��b\ ��66© >-4\ L)> -omE]G�7-22�»+@/\JJ f±,)==o=«®0en -Q$D E_L� & o, o\ o� `=E0 o®>o, \=\\°7�000 o0 D D)o005�Q--amoa�Q9«o7 � §7<%=.E0w00<0\3MCL 00\a� l(nEsza /\#2\a)== ;E=-e e m y2=<§/�cM >02¥m[6)m�mmg _ _ -c>m3C) eEc`°o¥� mL)®>=>m�mA0 k0(y83°mmg=� ƒa > 0-0caMCa =p2&a===�� .. -»£ao &\&£@2. „zc==a�f5 g /[/%] o @@77=_,m— CO otU a) ewe >aze�\9«9�@Szf7o°a >e=m0== {oo= &m#�o�>==,ee2ol�«5/,m E)®&\['mt��#E]§mtf/7\£/G k�/§\)kk\kk§ c., oeEm�§6<ScE,Qo&a—moo 0 m=owW-53- o�e—�//�y®� o�-- � -+oc,— oe=mo=oo$E3#\{§a cu = oar`Ia� _m e�oc2 2 %-=20§Q]Q {G�no.o, E?—m-Ear°5g§kG/(D —&o- .g(D CD(n(D .0C:@ff (Dc(D <o3yf;°$>ma a 0)L)\$E\3±�22 �f//}jfm° q% ° > C:E�&/®`mc(D00) gg7 oo:3 >0o%�o,®�&om 2 . a� a) a) _ =oo .!&_-0a) �,==gf2 ova oa ,=o_mm(na)0) m�C) _ ,cuE&= ��_��� {a§,G/%S/2QeE=8»o/\mo%_b oo_�besco% �%0 # ecaec > ±o�°�¥xoa) �cu 0 0 C:Co 0 : , f j=®ma�So= cr a2J=%E�m2228�7£m/Sa°Ea) 0,En °Gae±�oe&2\ o0 :3 = 72�o®eEa@ ` ■ $=moo �=E%ME<�e o%o>�oe£<2 �o,Ig==S_a(n'a c 0 L U vy- L Q N C O U d 75 L O cn C 3 a•) OEM L L _ = N O 0 PE U 0 c 0 u m X X to N C 0 U y N N Q O O cu o U U a N o 0U () U c = o o a) O N 'C O C) a3 o a > 15 w �_ N a) 7 � 'N •O "U 0 .U� "U 0 N _ C C •- a) O O N C a) O () N N N NL-. O � N C N— D N O a) E N N 0) O E V N D1 p U ai .0 O U La E U a .0 a 0) O O a) (6 p (a DO •WNS = @ C CO00 mCO N C O _a) ^LO O CCO a) a3 U V O ' aU 'O CU y U3@ 0 E d@ O '� C a3 i� N a3 � N (6 N C Ot =UN U N = UUin0)a ba a d 0)a) O a) C O C « (0 N o 'O a3 N > ,0 0 cb N N U 0 ._ O t O a) "L' N N a) C N— .0 N 0 E> 'a N a N a) �.. -00 t0A -0 > N L a3 ) a) :�' O) L a) C C a) Eca N _ N a3 a3 a) -O U M Q O Oouds 0= x L O L Z N N -O 0- O O).a) N r a=_~ CU O �' C U 'O) N = D > a) 0 -o Q O � C co f6 N a) a) a) 0 .0 CA a3 OL O "> M = M Ca O O E Y C a) +� C ._ 0 a) N a) O E N> -0 :� m O) E O O a O O a > r.a) co w m a) N �E a)o 0 3 o m Oa CM "�Ca m aa) aa)) a�)�L° m N) 0 �•c c0i a 0> rns m caw v rn=w— a�w > c a) rnrn L m�� o m m a) E O N= C C N Q' O C O) "-' a) L O ,O . N� C N N a) � a) O N 0 aS a) f6 O � a3 0 � N E 'O o Q '0 � w. m a) C � E � O � L .N .a) � 0 •� -0 O o MAINE � � ..L.. H 70 (6 U L N w -0 N E E a) fn — O O C `= 0 V a3 L N a u ,� a3 N .? N 0 E a) 0 0 N '_ a.0 a) > > N j i > E 0 C O U 0 a) 0 a). o N-0 ca � o m C% a) m 0)Com— a w oL m m o a) Mai 16 coi aa)a)(Dp a,Z�== Ci�� map ma)m�0Ca o0)aoo a3 \CL' U � w a) 0 a) o N •� j :p N U a) N B a3 y L- L >' a3 O O N _N 'O d = � G 'C.- N +' ._ N L.. w 6 a3 O O L= 70 0 0 O N a3 O) •-• >, a3 a) E C o'oa p 0 C7— `o� 3� 0 0 3 0U(D o 3 o m N c N o =� p a=i m V c4) U J N p C N 66c Q. o o C� V N o 3 w .� m (n 4? m o CD r.uai a'm�omO��Nm �oc��=p�Na—pioa�iamc �aaOiU`)0=�33 p rn� v �� 0—, "0 CL aF' N o o N 3 o" c N @ a� aim o a) m c C a) . J 3 aNi a O NC13 N m c c m o (D" Q) N m N Y of 0 01 U N U n. m �O „LO„ ip R U E N O N U O 's `- c) �vj .0 co E C .a>'+ p c rn o O i/1 C o Cl) O N O a) m a) o E NW Co ;> E u� o m =w.0 mw N m ?'ip'N = QUn c a) a=i c� a)F-U o�QU �� aU U� m as Q,� a Ea UE-� aw o� @w m 0 cps mOD 0 k) kf 3 2. } �/E X / kf . \ 3 . k 0 j{ . 3 / m 0 // / ) ° \ ®/ y Mn \ \ \ )a /§ 2� \ ( \ } ) 7 § ) 0\ ucau \> \ ® E k / 0 > & E/ 7§ \\ \S($/ k) W �� -%\0� .{E 7� /\»�/5/\ f\ j o ± E i \{§ 2[ // . . . . . \ - b ) _ { 0 e / § -7 . _ » ME2`-®-G\a�=%of° o U) W 65.0L (DrE=W'00'= `Z_==2_m= 2=7m > �e=-eo=�±®=�=�-�mo���--�* (Djs_#f�G/ 0Mc 0oo°°°r°°m¥3:En ;\- oGa==t[`-\eo0) /Q=b°ameB,Ea= .� e-�co= o- §QE/=G®o eQm=02&t77c %5 of~o=`%G®ao oyI®=2, o ■47=e%a=f±ow10c '0 0. am )_ e �7$@aQ±=o `2>se2°®°;aa0 C:\ °222 co cu «p �a&aM0 G2�§\/��§§/»f0.a)co 77 0co \a ,<&§2f�»&a®_io >a/�_===>�,$e]E G®M(D ) 00cu 0 ƒm0=3(n,±,Q9\=® G �n/o])Eo a7c®=o$%��=m&=o \/ t1G(D gym_-0 E77��-0® �-0®®,7-°0 §c m-- ¥ .2�aa2;/&&2£r°,7f%0)0 we ® %@ 00�:: a)0 o/00 wo E00.0 >=�8a k` a/&`R[\=D =¥*2Afze2�,ac@e2lEf\ . a§ o. �&_�noi%,a)0-0 0ccc33mmmmmmm-= CMCU0==-0C: 0)Mo -0 , 2 oa46-�®E°=5CL��==M o0 8 �c>©»]�=afo222°°o±a/§\$®�)£� 0 o2m#��CUa {5£-.Efow®c=/2/\o §0 ±\/0 $ ® ■ 2§Ma.—(n 22,ao®=== 2®®I,Q£n% z0 ,_=,c=f0®Go==@t7-5o4af IL(n0 5`7� -` c 2e oaEo o -®�»,G®m{ g o;oo -Eoo2y= oa%e�»=m�8/0 r. �§yc��-=$00®=002� o�=��=_�oo \_ / �cE#/§\»§{0 cn(D/§� )/g%o§G2{GG7 _® =oe7G5f&'=E§G„ oo>EQ3£&+3Fu(D0W W G\ § o o0)ems=�=l02ch «f4f/y&&e&Ga�Emaa0 a 0 L (� Q N C O U 0 L O U ++ � = U O p :E U 0 c 0 my U 0 N m C O U w - N N m `0 0 Wy �, U j; U cu oam U U IZ En N 0 0 a) U U N Cp N 'o U C 'a O 0 '0) O 0 U U U N _O O U a) a5 (1) m a) N N m m m m O C O N O_ N L .i p .O p d)C13 U C m O a)U C m O 0 E Sam) Coo- c m O , E >O p 0 0 .� 0 N N a3 U N N O U 0 0 E E Q o c 0 'a= N as a) L i 0:3 0)i .0 c o c o.� ac m 0 3 N = m m WE 0 o c o N _ O C .� N N C U .� N N Q Q E4) o • • • N O -O C a)N m Ca O m 0 N L C N al w ... C a C cu U 0 a) _ .a3 O ..- 0 O C a)cn i'U O a) @ a) y N N C U L 0 g .o a3 � •- .0 .0 .o E � O a) mo o1.N msma�i o EEn>aa0i .N i� QC1 a a o'>o.0)oCcn C.0 a) E U L N .N :'= N N N 7 a) Y_ .N C V O C N N .� N p 4 a) OL E N y .N N N:tf 3-0 O N m �? — 3 E W —� 0 N o 00 a) 0 cU� �U� 0' — i o to a)0 m 0_ 0 in p 0 D. � UO >' O O N N a) O E •� E� O D U 3 E N 3: C >., N E C O_ C to o) •— C aNi .0 m- N o U 70 C '� O .L.-� a3 >` f— C C f` a3 -0 O LL U U o O C. •� a) U O ..0.. o N O^ U m 4,00 a) o) `) '� O U w a) N O > a) 00 N a) (6 •� 0 O O O E ` o" N .L-1 (0 Z CL f (D � m 00 � � m� 0 Ua-00-,c o �-oa) m-Um u)rn � c0i Q0w�� t:!° 0� = 0�L N c 0 c N o 3 > a)o 0 WE c0)� Qa) Oen "' a�i O = O_ c c070 = a3 .N .m V� w _C U m m U O 3 C m ate) `- N 0 C 0 O C w-� C: w 0 0 m C 0 2:L C ° �� U) Z m 0 �� o m NoL o.� m p co)�_ ° aa) a`)).0 o cu o "moo 3U�-' Co � �:� °' L o E mU'� c c m o E a`�i c 3 L D Q CL m U a) a3 m V V U L C m E N a) p m U C N m .� C O a) Q. C _ :tT y C C > O.. w 7 'U 0) U a) L cn C N m_ L U a) O N C) > C o 'O U a) _ a) 7 a3 •> U N O ._ a3 > Q C > O U Y 3 .N o) a) N C p C a) m� o C) E 0 w Z a) m a) rnmw 0)c Z _ _`�N>>-0o-C: N —a'w 0 o�0mc 'E3 m a) -o m0 0m *MMINM 0 0 0 m d C .> .0 a) Q Y 00 Y CU N C O (— O N 'C l4 'a to 0 U C C U �O (9 'a V7 J O J 'o 'o a) O N >. > mo cn _ ._ ca O co>_ Ul N 0) J U m v 'c U J 'V Z in N m U C a) y E � •� w U WC .a) U� 70 Cc U c0) 0� w m °'cn Us 3 0 u0i� a)U m�Z���.Ev m cum< rn a) A O O L U Z F- O IL w Z a c� z x O F Z O E z O 0 F c 0 w L (� MOW X a= O U c o_ Ld C U 3 y 0 c O U c O dy X X X m a) C O U T m m m s Lo 0 .-� 0 .N .- co �-. co L 0 U U U a o 0 0 a) L)U U N w a) c V) 0 N o c O C c .m O- O O C 0 O .O V) a) _O o M n cD E o o �' E 0 o m 0 0 a c m c w cm i) rn � cm' 0- o0 c o o oomE c c ocoa a)E ai m N cu r.O L m N N Q U' O to O 4J Q U' N c o w N V) m o U a `�= 7 N i O .0 O C 3 0) E a) o o a) y U c m c 0 m i) n C � U o m o ) 0- 3 U E a) o N 0) O N 'm O U c c U E O U O c N N "= 3 -O .0 E v o n ° E m c0i N.N c E m 0' a) o �> o m n c ow U > Qc c�acEff o c� -0cE'-�oaUna) 0 a c o a, o.� oo a) a) oo a) cL c cc 0 m u.o— > �0 00 2 mo wo,o MMMMMMMa) 'coc c o �'N - 0 oIMOMM, o'a cu o ME 0_rnc m E 0 y, _rnIMMOWM,c m NrwYQ- DOMrnE Elmo. U m co,cUm d C 3 m m O Fu N o .0 N' a 00 O_ N .O '067 N N 00 N aa)i C O' C fmn Q E c 0 0 a) a) (D fl 5 o a) 0 ME 0 a) n 0 o a) 0 0 Ca ca o o d 0 - O� U�- m c o �,.. E 0 �.5 c 0 �,.. C: DO, .� c 0 QQ - - Q' o o e • e • • • • • o-O = O a) -O N a) 0 cM.ZE m .N O).0 a)a) ca 0 m a) o a)i-O Z 3 0s o)c a) �z•o 3 o E c �c0 O'0Ocn a?a)>m QW.m c m U)c.@0U a) O3a) Uc.0 a,c°0 a)�oa).S moC m c EE 0�o I-- m oink a) a)oz. o Q m MMMM 3 M L) 0 QE- 0 co m� a) ma � i 0 c 0 0Q �.� Q a) (n �'0 m m Lo o n o 3 c C N'c w 3Oo E E 0):L- 'O (nn 'O N m OMPOMMM C U 00 N O) a O. O c o m 3 C N Q — Q(D w aocWOMMOMMa)E-cn r�cmmaa)) vOo��E¢0<m 0 3 m E axi m�� (n aa)cn aa) N��.- c c•m m a) N 0)� a 0 E-c U >c ui cMOO o m o E o MOMMOMM3° � �Ia a) m m y o E m o cMOMMOMM, m.n o 0 () +T+ :✓ a) 0 3 a � 0 C C m C O L O_ N U) 3 O) •c o- C a) c E > aN 0. -0cm:L m.Q� o p.Q.o.3 >.� z� o ME �a) c'0 10 0 0 d cn � a� ', a 0- O� .+_T' U� 0 O_ m N O E MOM 0 0_ � a N U N N O N aNi N m a) 0) U 0 niu a) fro' o b a) o m� oy 0 1. m�a'ur� m U 30�Umn m Em on aN30) 0 O N ) U •_L a) N 3 o E aC)dMME OUfn L) Na O O-O 3 = c 0 ZL) T UU) c _Z w O O y a 0cu c a) IMMOMM, a �OO E .. ! ' 0 O r Cmoa 0) C LLI)COC 6 ) m � O)_� U a) Z;a U c E mE o M )iN 0 =MOO m .a'x0a)mO0W>�-0 E0 7 .� (6 a) N cn Q. aaU Ci U)��U 'O N (9 0 .0 _ > O- Z Z F- W 0 .a, � O � c � O O U w U C L .> 3 () a) C N U Q. O ) O 0 0 t— a N CU 4 Q m T� O a) 'L Q N 0o m m c 3 m om- a N o 0 ocaao��' N D p C L O > '3 : (h CU .0 c mim�3oa�o c0L+s��o o am— rn o O V a fa C ) U O N 0 U �?m'0 CLW O = C t C m e '0 3 L) y 3 � La a n a) N O o O O o 0 U c U C a) N N C C (6 N w U O (O 1. �= M _N (a N U N U a) C N M i 0� m 'P a) N O N N C C N O N C N N N N •� 0 C c 0 0 c 0 N 'yam—, L(n O f6 N 0 to m � c m a) c O m T 0 0) aa) oo m Q c a) OL E m L U0'�p�NcO -Cna) Co o aDa LL—u U) o x QQcoi mom a)� E N 0 3 0 o o a) M. a) N O T f6 L -O a) N O to .=3 O ff.+ O. (ca C ca M U O C = E — a) — U Co 0( N 0) N O C a) N N Q >% 3 .0 aQ � ) aciEo cn o> c � 0m00•NN Y a) '� N in 41111 c ._ N �c O N r. o c o m mM a a) NJ o m (n ami vi aa) 0 o-0 Qa QN a) o a`) c a) c m E o o �° nm o 3 �°� co ow v i m m� �° E O m N >•`O E o o�v0,C: �E�� EQ�cocw. o�v��cc C O C N N f6 O = N N a) C i= a Y Q O N 3 N "O O_ N C U� O 3 0 N 0 IIPIIdP V Q N Q E Y (6 O 3 0 a) O O UO 0 Co '-00 cL.) U x a) 'E m m o' (D o- o � � >, 0 x vOi � vOi U U. — C Y m N Q a) E_ Q a) Cn a) U 66,,6 9 .c Y N 3 E 3 A C7 O w a a z p Of O EL W Z Q Z ie O t- Z CO C Z O Q C7 F E Books O w W L X Q N O U m 3 � C .0 O U � v � � 7 (j) •L L _ = N •L ❑ O O .E U O c O :F.k 42 X CD 0] N C O U r N T o U a N a) ro o N c O aaPIIIP ° a) 'o 0 N 7 C U Z O a) 'o c a O i O C a) p cu o N N c ,— C 7 C 0° U ns a) a) C m n c U N O .a) C O N U° N a) O_ N O_ a) = C C O "' c6 C O p m C o C N o-aNi� o �C:= a) u°)i r. OlE U mUC UE 0 0 a)U a) U U 'Q N C 3 0 '(6 Q c 'O a) 'p 'F N �uu))Xo.�Cjo.0 a) N a3 C .� O N yo — E Q Q m O N N = a) c fa O f6 N o c N N �° rn i O m° N O a) N� c N C > C .= a) N a) O- 7 NN aaPIIIP O N N�� -= 0 O 0 LO' N En 0(DN� E a) N O O •C Q. a) O N N 0 ° U N N U O N 0 0 70 m � U O N Ci O -6 .2 N N N E U L 'co i+ C N 0 FL- U c 0 O '0 a) a) 3 O 0 O a) N O O a) = 0� i c Z o co z EL � -0 a) .Q d y •4 ' n� .� 3 L a) ❑• U O' O (a 'o U T N O N O 0 0 0 Q O •O N 0 a) y 0 O N yQiafl CO, O° E° a)uiEu) c ->Na)mcz —CL (D .O .�- N O p Z N N"" = 41111111 m O N Y t:' .O fa C f6woman cmaoN3a. m� Oa°iC FBI °0 QNN N C— O co a3w N a) N U+-'_Ta) m 75 Co E-0000EO m'g)�� �a) Q�°a)°wa) aaaa p•0 m c mcc ac>N—o a-0arnaa))L) oc�md) Co N c N, a3 •_ -0 N N C O' Q. C O _ O _c � w O C C a) >� Y L a) f6IISBIIJP 7 u) �% a) oj Co W ZD C C a3 O W O a) O N U E N .� '� (6 a_) _❑ N NImmImlI ' � O o 3 a) a) a) c a) -O le E • Z a U 'O N C c c 0 C 0 0 0 ,.. ._ X X 0 O O N 'N6L U Q O O° O O C aS U ECL 0 UO La) w C 7 0 c 0 CO y0 � � -6 � U O.— a) E U N C 0 L E O O uu)) E N a) O) a) _ C O_ C > C r. O C Q. N p) O) a) :3 C 0 Q C o _ a) (D a) •«• -O d1 c O E O O C O .".' �_ O O °- c -° O O U 3 U E aS E U a) a) N U C C O— a) c E °) 7 i '� •a) O Q O in .O > -° U) Q C O- U C N 0.:� C C E •a) a) 0 C O C C a) a c c:g� c >0 U ca.ci 0 V.� aa�O 0 67=3 i �� m° O' C N >, O N U fA fl. �oa)o cO�a)=ca)o a) O (6 _U N c O �' a) � c N a) w L ,� C CU 0)M U w 0 N m -0 �-+ � �- N CO C N a- C) N OL `o_ NU mia c c o a) o Q. aca)�3Mvmoy000 C� Q� Q O) Co t 0� of O >. N N O a°° U 'm N womplopo 3 = rn p C C N 7 U 0 ° °)-O -0 U O .0 0 o c rn0 c cuwa. °IIIIIIII F- O O Uaw 0 0� •N >L C (� ° L OL ` aacfn BIIIII a3 N a3 CO N 0 3 0 o 0.3 � M�� :3 C a3 C 'O C U U C O 'O .RL.. FMO 00 O O 'O .� O C C 'a cn • U U� a) N U p a3 (h O r O` O N L .0 D O c N LL +- C +•• FaabIIIff - QccoSaaPIIIP >pCV(D'.>U F- F- U 3 U F-' "Oo 'No E U 6 C) m a) cq i a w @ 5 tLn p >1 o o N C L 1 7 a) O U_ U _� C N 3@ CO C a� �_ N cu U a 0 O_ U f6 > '6 N p c-O c Co Q) a)- c.0 N N U -° @ E U O O) C Q C O C@ Qc� O)o'3 o u)me Q •- .3 a) p 'O C � U 7 a) @=c_ N a) F- N O O p c C 3 N �Ni6� Ua.U).� 3 m� � cnc N �� o aU) U_ D- U C O 'O N~ U w tt=U O_ OL N O tf �° U C@ N y O U a)ocn @E°mCA o- >. -O N 0. @ a) N �a)a)r50a)CL N� ''�@� i- `@a a) m rna@i� c rn 3 F-.�Q.-tfs�mom0.�tim�m N C C T a) O u @ca) w Uoo i6 'O E@ N N ,� ,� N o @ -O = u! O c p O N U°@ N U En U)@ a) N .� O N T@ @ O .-. @ 0 r. U° i Q C a)� TNO O_ 3 c o f6 0 3 0 `o 3-° >. '6 U N 0 U) w Q U 0 •> M m mo O C Ca X ca a)p O N U) °- �i a) p N@@ Up Ycn T w @ 0)@ i cncu EO Q.o C O N 3 .- U"c3v�a)CL mo��om U O .O-a) (D @ O p o U o @��, o N O O N 3a) °Em°—m a n - Lo @ p C c C a) @ N' > N f6 > 0 C 3 0 0 0 ca .�....0.. � 2 U (nn 'O 0 @ U O O� C � N � @ LO rn � m U O C) CC) a) H o m � & § L 2 0 LU ■ 2 « ) 0 0 E 0 � 2 S � 2 fj ka 0 § 2\ )0 0 \ ( / }o /\00 \7/a /�777teao aFE§2=0 � ��.c, ofaCaoc�eo §5/E%f®G\ 222==c[0 0 a) Ca c © % 0 Co0a), o»&2�e `(D L) o %2 2>ooc--s9 =�(on 888@o0cn {\\\\\\//\ , 7<e7/2w000 ; ®7/»`mom&+© /\oeR/,cnoG »>-- c ®-/»f�o`»G @ B �cnacu)7'§% )C[/(Da \¥i §\\\/[ EXHIBIT C to Resolution No. 61-18 Statement of Overriding Considerations CEQA requires a public agency balances the benefits of a project against its unavoidable environmental effects in determining whether to approve the project, and authorizes a public agency to approve a project with significant and unavoidable environmental impacts if it concludes that such impacts are acceptable because they are outweighed by the benefits of the project. In making this determination, the City of Morro Bay is guided by CEQA Guidelines Section 15093 which provides as follows: (a) CEQA requires the decision -making agency to balance, as applicable, the economic, legal, social, technological, or other benefits, including region -wide or statewide environmental benefits, of a Project against its unavoidable environmental risks when detennining whether to approve the project. If the specific economic, legal, social, technological, or other benefits, including region -wide or statewide environmental benefits, of a Project outweigh the unavoidable adverse environmental effects, the adverse environmental effects may be considered "acceptable." (b) When the lead agency approves a project which will result in the occurrence of significant effects which are identified in the final EIR but are not avoided or substantially lessened, the agency shall state in writing the specific reasons to support its action based on the Final EIR and/or other information in the record. The statement of overriding considerations shall be supported by substantial evidence in the record. (c) If an agency makes a statement of overriding considerations, then the statement should be included in the record of the project approval and should be mentioned in the notice of determination. This statement does not substitute for, and shall be in addition to, findings required pursuant to Section 15091. Impacts of the Project Consistent with the CEQA Guidelines and the California Public Resources Code subdivision 21081(b), the City has made agood-faith effort to eliminate, minimize, and render less than significant all potentially significant adverse impacts that may result from implementation of the Project through the adoption of feasible mitigation measures. Despite that effort, the City concludes the Project is likely to result in significant and unavoidable impacts to historic and archaeological resources and human remains during construction. However, after considering the Project and the entire administrative record and weighing the Project's benefits against its potential environmental impacts, the City concludes the benefits of the Project outweigh its potential significant and unavoidable adverse environmental impacts. Benefits of the Project CEQA requires the lead agency to balance the benefits of a project against its unavoidable environmental risks in determining whether to approve a project. The City finds each of the following benefits of the WRF Project supports the overriding of the significant impacts identified above. 01181.0001/495767.1 Page 1 of 3 ® Flood Hazard Areas — Decommissioning of the WWTP would remove treatment facilities from the 100-year flood hazard area, which is beneficial because it would remove a substantial impediment within the flood plain, which is a net beneficial impact. ® Water Supply Entitlements —Operation of the Project would allow for the development of 650 to 825 AFY of advanced treated recycled water for indirect potable reuse, thereby enhancing water supplies in the project area and providing water supply reliability with a new local renewable water supply. ® Wastewater Treatment Capacity —The WRF will be designed to accommodate the City's projected wastewater treatment capacity needs in the future based on limited buildout projections allowed pursuant to the General Plan. ® Improved Reliability and Public Safety — By relocating the WWTP farther from the coast, the WRF would be less subject to coastal hazards that could impair the operations of the facility, thus minimizing the potential for a shutdown in service that could adversely impact public health and safety. In addition, the WRF infrastructure would be more reliable than the existing WWTP, thereby reducing potential service interruptions. ® Improved Opportunity for Appropriate Coastal Uses —relocation of the existing WWTP would free up valuable coastal lands, which could ultimately be used more beneficially and be more consistent with the intent of the Coastal Act. Depending on the nature of the future use, the land could also result in improved economic benefits for the City and, thus, improve its ability to provide public services. • Beneficial Funding —The City has no option but to replace the existing WWTP and must provide a system to handle the community's wastewater. Replacing the WWTP with a facility that includes water recycling operations will provide opportunities for low interest loans or grants to fund this needed project at a lower cost. ® Compliance with effluent water quality criteria and with SWRCB/CCRWQCB order. Conclusion The City acknowledges, despite all feasible mitigation measures, approval of the Project may result in significant adverse and unavoidable impacts to historic and archaeological resources and human remains. However, for the foregoing reasons and based on the FEIR and the entire administrative record, the City hereby determines when the impacts are balanced against the Project's specific benefits, on the whole the benefits of the Project outweigh the limited impacts and warrant approval of the Project. The City recognizes the importance of providing wastewater treatment services that meet State water quality requirements and augmenting potable water supply reliability with advanced treated recycled water. The Project would make the best use of recycled water by recharging it and storing it in the Morro Valley Groundwater Bain for subsequent extraction by the City. The Project would involve a suite of mitigation measures to reduce impacts during construction to historic and archaeological resources and human remains, including, first and foremost, measures to avoid those impacts to the extent feasible. While the Project impacts may not be reduced to a 01181.0001 /495767.1 exHieiT c Page 2 of 3 level of less than significant, the Project specifically balances the needs for the City to meet the State's requirements to meet wastewater treatment standards, remove essential wastewater infrastructure away from coastal flood hazard zones, and provide water supply to meet consumptive water demands of its ratepayers with the need to protect the environment of California to the greatest extent feasible. The City further finds each of the overriding considerations set forth above constitutes a separate and independent basis for finding that the benefits of the Project outweigh the unavoidable adverse environmental effects, and warrants approval of the Project. 01181.0001 /495767.1 EXHIBIT C Page 3 of 3