Agenda — Escalon City Council, October 21, 2024 (part 2 of 4)

CITY OF ESCALON CONNECTION TO NICK DEGROOT WATER TREATMENT PLANT PROJECT FINAL INITIAL STUDY/ MITIGATED NEGATIVE DECLARATION SCH 2024090184 OCTOBER 2024 CITY OF ESCALON PAGE xlvi Impact Previously Approved MiAgaAon Measure from SSJID SCSWSP EIR (SCH# 98022018) DescripAon Of Changes and Applicability with proposed Project IS/MND
- Site specific erosion and sedimentaAon control measures including: soils stabilizaAon, revegetaAon, and runoff control to limit increases in sediment in stormwater runoff, such as detenAon basins, straw bales, silt fences, geofabrics, drainage swales, and sand bag dikes; - List of provisions to eliminate or reduce discharge of materials to stormwater including pracAces to minimize the contact of construcAon materials with stormwater; - Stockpiling of soils along the trench may be on the side of the trench farthest from the nearest creek or drainage where possible;
- BMPs for fuel and equipment storage, refueling acAviAes and equipment inspecAons to prevent chemicals from contacAng stormwater;
- DescripAon of waste management pracAces; and - Maintenance and training pracAces.

MM HYDRO-03: Erosion Control- SSJID shall incorporate into contract specificaAons requirements that the contractor(s) implement erosion control measures as well as RWQCB requirements for stormwater polluAon prevenAon for construcAon acAviAes. The contractor shall be required to exercise special care to prevent erosion in disturbed earth areas, and silt or eroded materials may not be introduced into any storm drain system or watercourse during and following construcAon. The contractor shall also apply erosion control measures where indicated on contract drawings and where the contractor has disturbed natural vegetaAon. For construcAon adjacent to, or crossing any waterways, SSJID shall obtain and comply with any necessary permits from state and local jurisdicAons.

Land Use and Planning
SSJID EIR SecAon 4.2.1:

SiAng and operaAon of project faciliAes could impact farmland or adjacent agricultural acAviAes.

MM LAND-01: Landowner ConsultaAon- SSJID shall consult with all potenAally affected landowners associated with the segments of the selected alignment that crosses farmland as part of the land acquisiAon process. As part of this acquisiAon process SSJID and the landowners shall negoAate an agreed-upon compensaAon for the loss of any exisAng orchard trees and/ or vines currently in producAon. During these consultaAons Escalon shall also, in conjuncAon with landowners’ input, access gates. Access gate locaAons shall be included in the final design plans for the proposed project. MiAgaAon Measure PREV MM TRAF-16: RouAng Traffic Adjacent to AcAve Agriculture OperaAons provides for controlled access for vehicle traffic associated with acAve agricultural operaAons in farmland areas.

DescripAon of Changes: Responsible party
and Aming.

Applicability: The proposed FCF will be
located on agricultural land acquired by the City of Escalon.

EIR SecAon 4.2.3:

ConstrucAon of proposed project faciliAes would result in short-term disturbance of sensiAve land uses, primarily MM LAND-02: Advance NoAce- SSJID shall provide minimum 2-week advance noAce of the construcAon acAviAes schedule to the affected community members adjacent to construcAon areas (e.g., residences, property owners, business owners, and public facility operators), including the posAng of signs.

DescripAon of Changes: Responsible party
and Aming.

Applicability: Project components will be
implemented along a major road, EscalonBellota Road. Short-term disturbances are

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MM LAND-03: ConstrucAon Contract Documents- SSJID shall incorporate miAgaAon measures in construcAon contract documents (e.g., terms of schedule or access condiAons or technical requirements). SSJID and its contractor(s) shall coordinate with local jurisdicAons and obtain all necessary permits (e.g., encroachment permit, uAlity excavaAon permit), shall comply with permit condiAons established to minimize construcAon impacts, and shall assign an inspector to the project to oversee construcAon acAviAes.

anAcipated along this road, ulAmately
impacAng adjacent residences and land uses. See SecAon 5.11.3. EIR SecAon 4.2.4: OperaAon of Water Treatment Plant and Tracy Pump StaAon would result in impacts to sensiAve adjacent land uses.

MM LAND-04: OperaAon of Project Components – SSJID shall implement miAgaAon measures described in the Air Quality and Noise SecAon.

DescripAon of Changes: Responsible party and Aming.

Applicability: See SecAon 5.3 Air Quality and

5.13 Noise.

Noise
EIR SecAon 4.8.1:

ConstrucAon of the proposed project would temporarily increase noise levels in nearby areas.

MM NOI-01: Noise in ResidenAal Areas- ConstrucAon acAviAes within residenAal areas shall be limited to the hours and days specified by each jurisdicAon as follows: - ConstrucAon acAvity is limited to hours and days when noise standard exempAons apply, per encroachment permit.
- If construcAon outside those exempt Ame periods is proposed, SSJID shall obtain a variance from the appropriate jurisdicAon.
- Where no construcAon exempAon is granted, construcAon shall be scheduled between 7:00 A.M. to 7:00 P.M. Monday to Sunday, or other hours and days as established by the appropriate local jurisdicAon on applicable encroachment permits.

MM NOI-02: Staging Areas- SSJID shall require in construcAon specificaAons that the contractor select staAng areas far as feasibility possible from exisAng residences. AcAviAes within these staging areas shall conform to the Ame limitaAons established in MM NOI-01: Noise in ResidenAal Areas. MM NOI-03: Noise Muffling Devices- SSJID shall require in construcAon specificaAon that the contractor maintain all construcAon equipment with manufacturers specified noise muffling devices.

MM NOI-04: StaAonary Noise Sources- SSJID shall require in construcAon specificaAons that the contractor place all staAonary noise generaAng construcAon equipment as far away as feasibly possible from sensiAve receptors or in an orientaAon minimizing noise impacts (i.e., behind exisAng barriers to storage piles, etc.) DescripAon of Changes: Responsible party
and Aming.

Applicability: Project construcAon at each
Project Component will temporarily and intermiLently increase noise levels in nearby areas.

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EIR SecAon 4.8.3: OperaAon
of the Tracy Pump StaAon would result in the generaAon of noise from pump machinery.

MM NOI-06: AcousAc Dampening Features- Based on a final site locaAon determinaAon, SSJID’s design engineer shall incorporate acousAcal dampening features capable of complying with the noise performance standards of San Joaquin County’s General Plan Noise Element and County Noise Control Ordinance (residenAal Ldn of 65 dBA). Design features may include, but not be limited to: - IncorporaAon of equipment enclosures fan silences, mufflers, acousAcal louvers, noise barriers, acousAcal panels, etc.
- OrientaAon of acousAcal exists (i.e., features allowing the escape of noise) toward less sensiAve land uses; and
- IncorporaAon of landscaping (hard and soV), where possible, to absorb and/or redirect noise.

DescripAon of Changes: Responsible party and Aming.

Applicability: The proposed BPS and FCF will
have emergency generators which will be operaAon at various points throughout the Project lifeAme. TransportaAon EIR SecAon 4.11.1:

ConstrucAon of the Water Transmission Lines would reduce the number of, or the available width of, travel lanes on public roads, resulAng in short-term traffic delays for vehicle traveling past the construcAon zone on the affected roadways.

MM TRAF-01: Traffic Control Plan- Once a final detailed pipeline alignment design is prepared, SSJID shall arrange for a Traffic Control Plan to be prepared by a licensed traffic engineer, for all project-affected roadways and intersecAons. The Traffic Control Plan shall comply with requirements in encroachment permits issued by San Joaquin County, Stanislaus County, the City of Manteca, and the City of Lathrop. The Traffic Control Plan to be prepared by the construcAon contractors shall include, but not be limited to, the following measures: - Maintain the maximum amount of travel lane capacity during non-construcAon periods, with all trenches covered with steel plates and provide flagger-control at all construcAon sites to manage traffic control. - Limit the construcAon work zone in each block to a width that, at a minimum maintenance alternate one-way traffic flow past the construcAon zone. AlternaAvely, use detour signing on alternate access streets when temporary full streets closure is required. - Restrict construcAon to non-peak traffic periods as required for specific work sites in encroachment permits. Weekend and night work shiVs may be considered in non-residenAal areas only. - Coordinate construcAon acAviAes (Ame of year and duraAon) to minimize traffic disturbances adjacent to commercial areas (e.g., avoid peak of Christmas, holiday shopping period), dairies, and the Atlanta Cemetery.

DescripAon of Changes: Responsible party
and Aming.

Applicability: The proposed 19,500 LF of
potable water pipeline will be constructed within the public right-of-way.

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MM TRAF-02: NighNme ConstrucAon- In consultaAon with the appropriate local agencies (i.e., San Joaquin County and City of Escalon), SSJID shall idenAfy areas where night construcAon may be appropriate. Candidate locaAons are non-residenAal zones where there are no or few sensiAve noise receptors.

MM TRAF-03: MulAple Work Crews- SSJID shall expedite construcAon by using mulAple work crews so that disturbances are kept as short in duraAon as possible.

MM TRAF-04: Telephone Hotline Resource- SSJID shall arrange for a 24-hour telephone hotline resources to address public quesAons and complaints during Project construcAon and to offer informaAon about detours, carpooling opportuniAes, etc.

MM TRAF-10: Off-Street ConstrucAon Parking- SSJID may require the contractor(s) to provide offstreet parking for construcAon worker’s vehicles in the vicinity of the work zone, or, workers may be shuLled to the work from an off-site locaAon.

EIR SecAon 4.11.2:

ConstrucAon of the proposed project would generate short-term increase in vehicle trips by construcAon workers and construcAon vehicles.

MM TRAF-05: ConsultaAon with Local Roadway Agencies- As part of the Traffic Control Plan for roadway segments and intersecAons, SSJID (and the construcAon contractor) shall specify designated haul routes from the Project aVer consultaAon with CalTrans and other agencies with local roadway jurisdicAon.

MM TRAF-06: Disperse Truck Trips- To the extent possible SSJD, shall schedule the daily work sites such that their relaAve locaAons shall disperse truck trips over a number of different trips on any one road. In addiAon, avoid construcAon workers and truck trips during peak traffic periods, to the extent possible.

DescripAon of Changes: Responsible party and Aming.

Applicability: The proposed 19,500 LF of
potable water pipeline will be constructed within the public right-of-way and require crew member to arrive to and from the Project. EIR SecAon 4.11.3:

ConstrucAon of the proposed project would affect access to adjacent land uses and streets for both general and emergency traffic, and for bicycle/pedestrian access.

MM TRAF-07: Traffic Control Plan Strategies- As part of the Traffic Control Plan for roadway segments and intersecAons, SSJID shall develop comprehensive strategies for maintaining emergency access for sensiAve land uses such as police and fire staAons, and schools in consultaAon with the facility owner or administer. Strategies shall include, but not limited to, maintaining steel trench plates at the construcAon sites to restore access across open trenches, parking of fire trucks outside the firehouse on the side of the street opposite the construcAon during affected work hours, and idenAficaAon of alternate rouAng around construcAon zones. Also, police, fire, and other emergency service providers shall be noAfied of the Aming locaAon, and duraAon of construcAon acAviAes throughout the Project, and the locaAon of detours and lane closures.

DescripAon of Changes: Responsible party and Aming.

Applicability: The proposed 19,500 LF of
potable water pipeline will be constructed within the public right-of-way.

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MM TRAF-09: Advanced NoAce- SSJID shall require a minimum 72-hour advance noAce of access restricAons for residents and businesses. Affected residents and businesses shall be advised of requirements for moving motor vehicles out of the area to be closed.

EIR SecAon 4.11.6:

ConstrucAon of the proposed project would increase potenAal traffic safety hazards for vehicles, bicyclists, and pedestrians on public roadways.

MM TRAF-11: Warning Signs- As part of the Traffic Control Plan(s) for roadway segments and intersecAons, SSJID shall ensure that such plans stress advance “Road Work Ahead” warning signs and speed control (including signs informing drivers of State-legislaAon double fines for speed infracAons in a construcAon zone) to achieve required speed reducAons for safe traffic flow through the work zone.

MM TRAF-12: Bicyclists and Pedestrians- SSJID shall incorporate into contract specificaAons for all Project components that requirement that traffic control plans include detours for bicyclists and pedestrians in all areas potenAally affected by Project construcAon.

EIR SecAon 4.11.7:

ConstrucAon of the proposed project would increase wear-and-tear on the designated haul routes used by construcAon vehicles to assess the project work site(s).

MM TRAF-13: Encroachment Permit- SSJID shall obtain encroachment permits from affected jurisdicAons prior to construcAon of the Project, and comply with haul route designaAons, and roadway wear monitoring and repairs condiAons.

MM TRAF-14: Video Tape of Road CondiAons- Prior to start-up of Project construcAon, SSJID shall prepare a videotape of road condiAons of all routes that shall be used by Project-related vehicles. SSJID shall prepare a similar videotape of road condiAons aVer Project construcAon is completed. The pre- and post-construcAon condiAons of the haul routes shall be reviewed by the staff of the County and local Public Works Departments. An agreement shall be entered into prior to construcAon that shall detail the pre-construcAon condiAons and post-construcAon requirements of the rehabilitaAon program.

DescripAon of Changes: Responsible party and Aming.

Applicability: The proposed 19,500 LF of
potable water pipeline will be constructed within the public right-of-way and require crew member to arrive to and from the Project. EIR SecAon 4.11.8:

ConstrucAon of the proposed project could disrupt newly repaved streets.

MM TRAF-15: RehabilitaAon of Roadways- SSJID shall comply with encroachment permit standards negoAated with by San Joaquin County, Stanislaus County, the City of Manteca, and the City of Escalon with respect to rehabilitaAon of roadways.

DescripAon of Changes: Responsible party
and Aming.

Applicability: The proposed 19,500 LF of
potable water pipeline will be constructed within the public right-of-way and require repaving of Escalon-Bellota Road. EIR SecAon 4.11.9:

ConstrucAon and operaAon of pipeline alignments could prohibit or limit use of MM TRAF-16: RouAng Traffic Adjacent to AcAve Agriculture OperaAons- SSJID shall establish a procedure for rouAng vehicle traffic associated with acAve agricultural operaAons in the pipeline easement area, including adequate access points and maintenance of controlled access.

DescripAon of Changes: Responsible party and Aming.

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Applicability: The proposed FCF will be
located on agricultural land acquired by the City of Escalon and along 3.4 miles of a public right-of-way. UAliAes and Services EIR SecAon 4.12.1: Pipeline
construcAon could result in temporary planned, or accidental disrupAon to uAlity services.

MM UTL-01- ExisAng UAliAes- A detailed study idenAfying uAliAes in the Project area shall be conducted during the pre-design stages of the Project. For Project components with adverse impacts, the following miAgaAons are idenAfied:
- UAlity excavaAon or encroachment permits shall be required from the appropriate agencies. These permits include measures to minimize uAlity disrupAon. SSJID and its contractors shall comply with permit condiAons, and such condiAons shall be included in construcAon contract specificaAons. - UAlity locaAons shall be verified through field survey (potholing) and use of the Underground Service Alert (USA) services.
- Detailed specificaAons shall be prepared as part of the design plans to include procedures for the excavaAon, support, and fill of areas around uAlity cables and pipes. All affected uAlity services shall be noAfied of SSJID construcAon plans and schedule. Arrangements may be made with these enAAes regarding protecAon, relocaAon, or temporary disconnecAon of services. - SSJID shall employ special construcAon techniques in areas where the water transmission pipeline is located parallel to wastewater pipelines. These special measures, which shall be included in the engineering specificaAons, may include trench wall-support measures to guard against trench wall failure and possible resulAng loss of structural support for the water pipeline. - Residents and businesses in the Project area shall be noAfied of planned uAlity service disrupAon two to four days in advance, in conformance with county and state standards.

DescripAon of Changes: Responsible party
and Aming.

Applicability: The proposed 19,500 LF of
potable water pipeline will be constructed within the public right-of-way with exisAng uAlity lines adjacent to the proposed locaAon.

EIR SecAon 4.12.2:

ConstrucAon in specific segments of the proposed Water Transmission Lines may result in uAlity conflicts.

MM UTL-02: UAlity Conflicts- In order to reduce potenAal impacts associated with uAlity conflicts, the following measures shall be implemented in conjuncAon with MM UTL-01- ExisAng UAliAes:
- Disconnected cables and lines shall be reconnected promptly.

DescripAon of Changes: Responsible party
and Aming.

Applicability: The proposed 19,500 LF of
potable water pipeline will be constructed within the public right-of-way with exisAng uAlity lines adjacent to the proposed locaAon.

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CITY OF ESCALON CONNECTION TO NICK DEGROOT WATER TREATMENT PLANT PROJECT FINAL INITIAL STUDY/ MITIGATED NEGATIVE DECLARATION SCH 2024090184 OCTOBER 2024 CITY OF ESCALON PAGE lii Impact Previously Approved MiAgaAon Measure from SSJID SCSWSP EIR (SCH# 98022018) DescripAon Of Changes and Applicability with proposed Project IS/MND
- Based on the uAliAes invesAgaAon to be conducted under Measure 4.12.1 a, SSJID shall consult with any enAAes having uAlity conflicts with the proposed project to negoAate relocaAon efforts or other plans to resolve the conflict. - SSJID shall observe DHS Waterworks Standards found in the Cal. Code Regs. chapter 16 et. seq. and are under the authority of the State Water Resources Control Board, Division of Drinking Water standards which require: 1) a 10-foot horizontal separaAon between parallel sewer and water pipelines (gravity or force pipelines); 2) 1-foot verAcal separaAon between perpendicular water and sewer line crossings (in the event that separaAon requirements may not be maintained, SSJID shall obtain DHS State Water Resources Control Board, Division of Drinking Water variance through provisions of sewer encasement, or other means deemed suitable by DHS State Water Resources Control Board, Division of Drinking Water); and 3) encasing water pipelines in protecAve sleeves where the pipeline crosses under or over an exisAng wastewater pipeline.

EIR SecAon 4.12.3: Pipeline
construcAon could temporarily block access routes from city police departments, San Joaquin and Stanislaus County Sheriff’s Department, fire departments, and emergency services.

MM UTL-03: Street Trench Plates- SSJID shall include, as part of construcAon contract specificaAon provisions, steel trench plates at the construcAon site to maintain emergency access. Steel trench plates shall be used to cover trenches at night.

DescripAon of Changes: Responsible party and Aming.

Applicability: The proposed 19,500 LF of
potable water pipeline will be constructed within the public right-of-way. Temporary disrupAon to emergency routes and service connecAons may occur.

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CITY OF ESCALON CONNECTION TO NICK DEGROOT WATER TREATMENT PLANT PROJECT FINAL INITIAL STUDY/ MITIGATED NEGATIVE DECLARATION SCH 2024090184 OCTOBER 2024 CITY OF ESCALON PAGE liii

3.4 ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED:

The environmental factors checked below would be potenAally affected by this project, involving at least one impact that is a "PotenAally Significant Impact" as indicated by the checklist on the following pages.

AestheAcs Agriculture & Forestry
Resources Air Quality
Biological Resources Cultural Resources Energy
Geology & Soils Greenhouse Gas Emissions Hazards & Hazardous Materials
Hydrology & Water Quality Land Use & Planning Mineral Resources Noise PopulaAon & Housing Public Services
RecreaAon TransportaAon Tribal Cultural Resources
UAliAes & Service Systems Wildfire Mandatory Findings of Significance

3.5 DETERMINATION (To be completed by the Lead Agency):

On the basis of this iniAal evaluaAon:

I find that the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared.

I find that although the proposed project could have a significant effect on the environment, there will not be a significant effect in this case because revisions in the project have been made by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared.

I find that the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required.

I find that the proposed project MAY have a "potenAally significant" or "potenAally significant unless miAgated" impact on the environment, but at least one effect 1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and 2) has been addressed by miAgaAon measures based on the earlier analysis as described on aLached sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed.

I find that although the proposed project could have a significant effect on the environment, because all potenAally significant effects (a) have been analyzed adequately in an earlier EIR or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or miAgated pursuant to that earlier EIR or NEGATIVE DECLARATION, including revisions or miAgaAon measures that are imposed upon the proposed project, nothing further is required.

Signature Date
Jaylen French
Printed Name
City of Escalon
For

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4.0 INITIAL STUDY

4.1 EVALUATION OF ENVIRONMENTAL IMPACTS:
1) A brief explanaAon is required for all answers except "No Impact" answers that are adequately supported by the informaAon sources a Lead Agency cites in the parentheses following each quesAon. A "No Impact" answer is adequately supported if the referenced informaAon sources show that the impact simply does not apply to projects like the one involved (e.g. the project falls outside a fault rupture zone). A "No Impact" answer should be explained where it is based on project-specific factors as well as general standards (e.g. the project will not expose sensiAve receptors to pollutants, based on a project-specific screening analysis). 2) All answers must take account of the whole acAon involved, including off-site as well as on-site, cumulaAve as well as project-level, indirect as well as direct, and construcAon as well as operaAonal impacts. 3) Once the Lead Agency has determined that a parAcular physical impact may occur, then the checklist answers must indicate whether the impact is potenAally significant, less than significant with miAgaAon, or less than significant. "PotenAally Significant Impact" is appropriate if there is substanAal evidence that an effect is significant. If there are one or more "PotenAally Significant Impact" entries when the determinaAon is made, an EIR is required.
4) Less Than Significant with MiAgaAon Incorporated" applies where the incorporaAon of miAgaAon measures has reduced an effect from a "PotenAally Significant Impact" to a "Less than Significant Impact." The Lead Agency must describe the miAgaAon measures, and briefly explain how they reduce the effect to a less than significant level (miAgaAon measures from SecAon XVII, "Earlier Analyses," may be cross-referenced). 5) Earlier analyses may be used where, pursuant to the Aering, program EIR, or another CEQA process, an effect has been adequately analyzed in an earlier EIR or negaAve declaraAon. SecAon 15063(c)(3)(D). In this case, a brief discussion should idenAfy the following:
a) Earlier Analyses Used. IdenAfy and state where they are available for review. b) Impacts Adequately Addressed. IdenAfy which effects from the above checklist were within the scope of and adequately analyzed in an earlier document pursuant to applicable legal standards, and state whether such effects were addressed by miAgaAon measures based on the earlier analysis.
c) MiAgaAon Measures. For effects that are "Less than Significant with MiAgaAon Measures Incorporated," describe the miAgaAon measures which were incorporated or refined from the earlier document and the extent to which they address site-specific condiAons for the project. 6) Lead agencies are encouraged to incorporate into the checklist references to informaAon sources for potenAal impacts (e.g. general plans, zoning ordinances). Reference to a previously prepared or outside document should, where appropriate, include a reference to the page or pages where the statement is substanAated.
7) SupporAng InformaAon Sources. A source list should be aLached, and other sources used, or individuals contacted should be cited in the discussion.
8) This is only a suggested form, and lead agencies are free to use different formats; however, lead agencies should normally address the quesAons from this checklist that are relevant to a project's environmental effects in whatever format is selected.
9) The explanaAon of each issue should idenAfy:
a) the significance criteria or threshold, if any, used to evaluate each quesAon; and b) the miAgaAon measure idenAfied, if any, to reduce the impact to less than significance.

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5.0 ISSUES AND SUPPORTING INFORMATION SOURCES

5.1 AESTHETICS
Issues
PotenAally
Significant
Impact
Less than
Significant
Impact with
MiAgaAon
Incorporated
Less than
Significant
Impact No Impact
I. AESTHETICS. Except as provided in Public Resources Code SecAon 21099, would the Project:
a) Have a substanAal adverse effect on a scenic
vista?
b) SubstanAally damage scenic resources,
including, but not limited to, trees, rock
outcroppings, and historic buildings within a
state scenic highway?
c) In nonurbanized areas, substanAally degrade the
exisAng visual character or quality of public
views of the site and its surroundings? (Public
views are those that are experienced from
publicly accessible vantage point). If the Project
is in an urbanized area, would the Project
conflict with applicable zoning and other
regulaAons governing scenic quality?
d) Create a new source of substanAal light or glare
which would adversely affect day or nighNme
views in the area?

5.1.1 Regulatory Compliance
California Scenic Highway Program
In 1963, the State Legislature passed California’s Scenic Highway Program to protect scenic highway corridors from changes that would impact the visual aestheAcs of lands surrounding highways. The program is managed by California’s Department of TransportaAon (CalTrans), which has taken “responsibility for the protecAon and enhancement of California's natural scenic beauty by idenAfying those porAons of the State highway system which, together with adjacent scenic corridors, require special conservaAon treatment” (CA DOT 2022). CalTrans coordinates with local government agencies, communiAes, and ciAzens to comply with the California Scenic Highway Program and preserve the State’s scenic resources.

San Joaquin County
San Joaquin County’s General Plan defines a Scenic Vista as open public views from regional roadways Interstate 5 (I5) and I-80 as well as views associated with the Stanislaus River, views at city gateways, rural roads toward agriculture, water features, and open space (San Joaquin County GP EIR). The County protects aestheAc resources through policies that address the preservaAon of open space and natural areas.

5.1.2 ExisAng CondiAons
According to the San Joaquin County 2035 General Plan EIR, Figure 4.L-1: Scenic Routes, the Project is not close to an officially designated scenic highway or scenic route. The closest Local Scenic Route to the Project is River Road, a twolane rural road running east to west from Ripon Road to Santa Fe Road, which is located approximately 2.8 miles south of the proposed BPS. River Road passes through local scenic resources including croplands, riparian vegetaAon, and the Stanislaus River. Stanislaus River is approximately 3 miles south of the planned locaAon for the BPS, storage tank, and wet well. This river is considered an important visual resource; however, there are no view corridors between the proposed Project and the Stanislaus River. Therefore, general views between the proposed Project and the river are substanAally obscured by exisAng land use and distance.

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5.1.3 Project Impacts
Guidelines provided in Public Resource Code (PRC) SecAon 21099 make aestheAc impacts from residenAal, mixed-use residenAal, or employment center projects on an infill site within a transit priority area less than significant pursuant to CEQA. SecAon 21099 refers to Transit-Oriented Infill Projects located within a Transit Priority Area (TPA). The proposed Project is a uAlity within a rural agricultural seNng and is not located in a TPA, the closest transportaAon center to the Project is an Amtrak StaAon located in Modesto, Stanislaus County, California, approximately 12 miles from the Project. Therefore, PRC SecAon 21099 does not apply to the proposed Project. a) Have a substanAal adverse effect on a scenic vista?
RESPONSE:

Less than Significant Impact. The Project is 2.8 miles north of an officially designated scenic highway or scenic route and consists of ground-mounted equipment, fencing, and below-grade components at the closest locaAons to designated scenic resources. The FCF and tank will be located at the southerly end of the Project on Cityowned parcels. and the potable water pipeline will be below ground surface (bgs), within the paved street rightof-way for Escalon Bellota Road. Low-profile enclosures and ground-mounted equipment are proposed at the FCF and the reservoir site and will not result in substanAve permanent changes above ground, resulAng in changes to scenic resources. Due to the proposed fencing that would be allowed by right under applicable codes and ordinances and exisAng low-profile development paLerns, views of above-ground Project improvements from public vantage points would remain localized and not highly visible from vantage points that are not immediately adjacent. Low-profile development adjacent to the south of the Project and proposed street setbacks shown on plans for the Project effecAvely block views from southerly vantage points. Temporary, and permanent changes expected with the Project would not be discernable from the closest scenic vista due to distance and the scale of above-ground equipment and structures. Below ground components of the Project would have no permanent visual impact upon compleAon, because plans indicate these areas will be restored to pre-project condiAons. The proposed above-ground components of the Project are described in the following paragraphs and would be visible from adjacent roadways and properAes within the surrounding agricultural areas. These components of the Project are anAcipated to blend in with the exisAng rural agriculture seNng, which consists of similar open setbacks, perimeter fences, and equipment interspersed with low-profile structures.

Proposed underground improvements include the reservoir, potable water transmission pipeline, underground drainage inlet systems, intake and oublow piping, equipment vaults, and wet well, which will involve temporary trenching and excavaAon up to approximately 6 feet bgs. These below-ground improvements will result in temporary disturbances from excavaAons and trenching, temporary staging and stockpiles, construcAon acAviAes, and equipment for foundaAon preparaAon and jack and bore construcAon beneath Lone Tree Creek.

ConstrucAon would be visible from adjacent streets and parcels over a period of approximately four months.

During this Ame, temporary construcAon trenches will be backfilled or covered at the end of each day. Once construcAon is complete, trenches and excavaAons will be permanently backfilled, and the surfaces returned to pre-Project condiAons except for permanent ground-mounted appurtenances. The potable water pipeline will have a minimum of 4 feet of permanent cover once construcAon is complete. No substanAve permanent visual impacts from below-grade structures would occur because these areas will be returned to pre-Project condiAons including replanAng perimeter vegetaAon and replacement trees pursuant to the applicable tree ordinance.

Permanent above-ground appurtenances of the Project at the FCF include perimeter fencing, which will block views of the ancillary ground-mounted appurtenances including enclosures for electrical, and site security systems from street views. The only above-ground components are the gate and perimeter fence, electrical enclosure, irrigaAon ditch, and a wall-mounted radio transmiLer.

The Project will recontour surface grades for drainage to direct surface runoff in a manner that is consistent with exisAng topography, resulAng in a less than significant impact. Permanent above-ground components of the Project at the BPS include a gate and security fence, culverts, overflow pipe and standpipe, pumps, and electrical building and would be visible from adjacent vantage points. Due to street setbacks, these are not anAcipated to result in significantly modified public views.

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Plans indicate perimeter fencing consisAng of chain link and barbed wire which will have a three-foot setback from Escalon- Ballota Road right-of-way at the FCF. The proposed electrical enclosure at this locaAon will be setback approximately 35 feet from Escalon-Ballota Road. The electrical enclosure at the BPS will be set back 8 feet from Escalon-Ballota Road with the pumps and generator mounted at finished grade on top of the subterranean reservoir. Upon the compleAon of construcAon along the Project alignment, disturbed areas will be backfilled, and surfaces will be returned to exisAng condiAons. Permanent visual changes from the implementaAon of the Project are associated with the installaAon of electrical enclosures, fences, pumps, and generators. Views of these components will be localized and will not substanAally change the rural character of the surrounding area or views from adjacent roadways due to the scale and setbacks from the streets. Above ground Project components are similar to what is currently found within the exisAng rural agricultural seNng.

Likewise, the Project will not significantly impact designated scenic highways or scenic resources associated with agricultural lands due to proposed street setbacks and the scale of the above-grade Project Components. See Figure 9: Flow Control Facility Site Plan, Figure 9A: Booster Pump StaAon Site Plan, and Figure 10: Project Component ElevaAons.

The locaAon for the subterranean reservoir is adjacent to an almond orchard; likewise, the locaAon of jack and bore construcAon; however, impacts to trees and vegetaAon currently found near Lone Tree Creek are not anAcipated to occur. In the unlikely event, that tree removal is necessary, anAcipated impacts from the installaAon of the potable water pipeline will result in localized impact to the edge of the orchard or creek. Tree removals are not expected to occur with the proposed Project.

As a result, the Project will not have substanAally adverse effects on a scenic vista; therefore, MiAgaAon Measures are not needed.

b) SubstanAally damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway?
RESPONSE:

Less than Significant Impact. See SecAon 5.1.3, Response a). The Project footprint does not contain rock outcroppings or historically significant structures and does not relate to a state scenic highway. The closest scenic resource is over 2 miles south of the locaAon for the proposed BPS (Figure 4.L-1: Scenic Routes, San Joaquin County 2035 GP EIR). Due to the Project’s proximity to designated scenic resources and no proposed substanAve land use changes above ground near applicable scenic highways, significant impacts from Project implementaAon are not anAcipated.

Trees line the Project along Escalon-Bellota Road and the almond orchard directly north of the exisAng parking lot where the BPS/reservoir site will be constructed. Tree removal will be limited along Escalon-Bellota Road to areas where bore and jack construcAon will be used at Lone Tree Creek. Tree removal along other porAons of Escalon-Bellota Road is not proposed because the conveyance pipeline will be installed within the paved street.

Tree removals at Lone Tree Creek and along the southerly edge of the exisAng orchard north of the reservoir, if necessary, would be implemented with landowner approval and would comply with the City of Escalon and San Joaquin County applicable tree removal permits before the start of construcAon. According to the permit’s condiAons of approval, the applicant must defray the cost of replacing a removed tree with an approved conformance with the street plan. Therefore, the Project will result in less than significant impacts on trees. c) In nonurbanized areas, substanAally degrade the exisAng visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the Project is in an urbanized area, would the Project conflict with applicable zoning and other regulaAons governing scenic quality?
RESPONSE:

Less than Significant with MiAgaAon Incorporated. See SecAon 5.1.3, Responses a) and b). The Project alignment is located within the developed County and City right-of-way adjacent to primarily agricultural land. Temporary impacts are anAcipated during Project construcAon due to earthwork and delivery/installaAon of equipment and construcAon materials. Upon compleAon of construcAon, materials and equipment will be removed, and trenches

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will be backfilled with a 4-foot cover; resulAng in the right-of-way being restored to its original state. Appurtenant ground-mounted equipment, enclosures, fences, and piping, which are permanent, may be visible from the adjacent public streets and properAes; however, these appurtenances will be set back from the streets and screened with privacy slats woven into the chain link fences. Due to the scale and types of these structures and the setbacks shown on plans for the Project, above-ground changes proposed with the Project would likely blend in with the exisAng agricultural seNng of the area and would not result in significant impacts or conflicts with the development code. Other areas that will be disturbed during construcAon will be returned to pre-project condiAons to the saAsfacAon of the landowner and the City of Escalon’s standards. Tree replacements, if needed, will be planted pursuant to landowner requirements for private property and city or county standards outlined in the agencies’ municipal codes for tree removal permits. The implementaAon of miAgaAon measures MM AES01: CoordinaAon with Private Landowners and Modified MM AES-04: Landscaping will guide the restoraAon of street-level views and maintain Project conAnuity with its surroundings. The City of Escalon shall verify landscaping replacement plans meet landowner and City requirements during the standard process of plan check and inspecAons and final cerAficaAons.

For the reasons above, the Project will result in less than significant impact on the exisAng visual character of public view from the Project and its surroundings with miAgaAon incorporated. d) Create a new source of substanAal light or glare which would adversely affect day or nighNme views in the area? RESPONSE:

Less than Significant with MiAgaAon Incorporated. See Response 5.1.3, a) through c). ConstrucAon will occur during dayAme hours (7:30 AM- 4:30 AM) on weekdays and may include weekend or night work to avoid traffic.

During Project construcAon, equipment and vehicles with reflecAve surfaces resulAng in new temporary sources of light and glare will be uAlized. These impacts are intermiLent and will cease once the Project is complete.

Project implementaAon within the public right-of-way is subject to an approved encroachment permit, which will be used to enforce the City of Escalon and County standards for safety within these areas related to light and glare, signage, detours, barriers, etc. Enforcement of these standards will result in less than significant impacts from light and glare during construcAon.

The Project may implement nighNme construcAon, requiring addiAonal sources of temporary lighAng.

Therefore, MiAgaAon Measure MM AES-02: ConstrucAon LighAng Plan and Modified MM AES-03: LighAng is proposed to require that the City Engineer verify that plans and specificaAons for the Project show temporary construcAon lighAng that is focused on acAve areas of construcAon and downlit/shielded to reduce spillover onto the acAve right-of-way and adjacent properAes. The contractor is responsible for the implementaAon and proper use of approved lighAng throughout construcAon. Project impacts from temporary lighAng are therefore less than significant with miAgaAon.

Based on conceptual Project plans, the installaAon of permanent exterior lighAng is proposed for the Project’s BPS structure. Exterior lighAng includes building illuminaAon, security lighAng, etc. However, all lighAng as a result of temporary Project construcAon and long-term operaAonal uses will comply with City Ordinance 17.41.065- Ligh
ng. The building will not require substanAal lighAng around the BPS exterior due to the proposed scale.

Reference Table 4: Temporary and Permanent Project Components for BPS scale.

Due to the long-term operaAonal use of the BPS, the Project design will remain consistent with CalTrans Appendix B-1 Ligh
ng Standards and County Policy NCR-7.7 below.

NCR-7.7: Reducing Glare and Light PolluAon. The County of San Joaquin and the City of Escalon shall encourage the Project designs, lighAng configuraAons, complementary land uses, and operaAonal pracAces that reduce the potenAal for glare during dayAme hours and reduce the nighNme light polluAon to protect the adjacent land uses from light glare and preserve views of the night sky.

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As a result of the Project’s scale, compliance with County Policies, CalTrans LighAng Standards, and implementaAon of MiAgaAon Measure MM AES-02: ConstrucAon LighAng Plan and Modified MM AES-03:

LighAng, the Project will not create a new source of substanAal light or glare which would adversely affect day or nighNme view in the area. Less than significant impacts with miAgaAon incorporated are anAcipated. See MM AES-02: ConstrucAon LighAng Plan and Modified MM AES-03: LighAng.

5.1.4 MiAgaAon Measures
MM AES-01: CoordinaAon with Private Landowners- Prior to the start of construcAon, the City and the contractor shall coordinate with private owners and obtain wriLen landowner approval for construcAon acAviAes on private property in the form of a signature on the plan sheet showing the proposed work. RestoraAon work on private property shall be agreed upon and approved by the landowner and the City in advance of construcAon. RestoraAon shall be cerAfied by the landowner and the City upon compleAon as adequately meeAng the City’s private landowner’s requirements.

MM AES-02: ConstrucAon LighAng Plan- If nighNme construcAon is planned to occur, the Project contractor must deploy the measures prior to and throughout nighNme construcAon acAviAes (dusk to dawn). Measures include direcAng light sources away from residenAal property or regularly occupied spaces. EliminaAon of uplighAng will occur by angling light sources down and fiNng light sources with covered bulbs, shields, and dimmers. Ensure that a 300- foot buffer from residenAal property lines is maintained throughout nighNme construcAon.

Modified MM AES-03: LighAng- LighAng at the FCF and BPS shall be posiAoned downward and shielded in order to prevent glare, and reduce offsite lighAng, and disrupAon of adjacent neighbors.

Modified MM AES-04: Landscaping- Natural landscaping, which blends with the surrounding aestheAc features, shall be placed along the perimeter of the FCF and BPS.

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5.2 AGRICULTURE AND FORESTRY RESOURCES
Issues
PotenAally
Significant
Impact
Less than
Significant
Impact with
MiAgaAon
Incorporated
Less than
Significant
Impact No Impact
II. AGRICULTURE AND FORESTRY RESOURCES. In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land EvaluaAon and Site Assessment Model (1997) prepared by the California Dept. of ConservaAon as an opAonal model to use in assessing impacts on agriculture and farmland.

In determining whether impacts to forest resources, including Amberland, are significant environmental effects, lead agencies may refer to informaAon compiled by the California Department of Forestry and Fire ProtecAon regarding the state’s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment Project; and forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board. Would the Project:
a) Convert Prime Farmland, Unique Farmland, or
Farmland of Statewide Importance (Farmland),
as shown on the maps prepared pursuant to the
Farmland Mapping and Monitoring Program of
the California Resources Agency, to nonagricultural use? b) Conflict with exisAng zoning for agricultural use,
or a Williamson Act contract?
c) Conflict with exisAng zoning for, or cause
rezoning of, forest land (as defined in Public
Resources Code SecAon 12220(g)), Amberland
(as defined by Public Resources Code
SecAon 4526), or Amberland zoned Timberland
ProducAon (as defined by Government Code
SecAon 51104(g))?
d) Result in the loss of forest land or conversion of
forest land to non-forest use?
e) Involve other changes in the exisAng
environment which, due to their locaAon or
nature, could result in conversion of Farmland,
to non-agricultural use or conversion of forest
land to non-forest use?

5.2.1 Regulatory Compliance
The City of Escalon’s approved General Plan (Escalon, 2005) along with the SSJID’s Water Master Plan (SSJID, 2022) establish a program and framework for the planned extension of infrastructure and services for managed growth and the planned conversion of land, from agricultural to urban uses, according to the City of Escalon’s approved land use map and General Plan Area. The Plan Area includes acreage within exisAng City Limits and “growth rings” illustraAng an approved program to annex property from county unincorporated into governance under the City’s Municipal Code. Accepted populaAon projecAons published by the San Joaquin Council of Governments (SJCOG), as referenced in the current SSJID Water Master Plan for the City of Escalon, indicate future growth within the City is expected to be 20 percent between 2015 and 2040. In support of this, the City’s General Plan and the Water Master Plan idenAfy infrastructure requirements, including the Project, and provide guidance for managed conversion of agricultural land to designated recreaAonal open space and residenAal land use within the Local Vicinity. These approved plans also address other types of urban land use within the City that will be served by the Project, as indicated in the City’s approved General Plan Land Use Map and Zoning Map.

The Project is currently located within unincorporated San Joaquin County, north of the Escalon City Limits. The proposed BPS site within the approved City of Escalon SOI, shown on the City of Escalon General Plan Boundaries Map as the 2035 General Plan Growth Boundary. According to these plans, the BPS site and adjacent parcels will be annexed into the City Limits by the year 2035. The Project and adjacent properAes are currently subject to state and county regulaAon regarding regulaAon of agriculture and forestry resources. Project conformance with approved city

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plans is also referenced in this secAon, and the goals and objecAves are outlined in the Eastern San Joaquin IRWMP (2020).

The California Land ConservaAon Act or Williamson Act
The California Land ConservaAon Act or Williamson Act was established aVer World War II in response to increasing conservaAon pressures on agricultural lands. The Act allows local agencies to contract with private landowners, allowing reduced property tax in exchange for restricAng the use of land for agriculture or open space only. In 1965, AB 1227 was enacted to establish a contract process to manage the rate of conservaAon of agricultural lands for urban uses. In determining whether impacts on agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land EvaluaAon and Site Assessment Model (1997) prepared by the California Department of ConservaAon (CA DOC) as an opAonal model to use in assessing the quality of agricultural land and level of impacts on agriculture and environmental effects, lead agencies may refer to informaAon compiled by the California Department of Forestry and Fire ProtecAon regarding the state’s inventory of forest land, including the Forest and Range Assessment Project; and the forest carbon measurement methodology providing in Forest Protocols adopted by the California Air Resources Board (CARB).

San Joaquin County General Plan
San Joaquin County’s 2035 General Plan has adopted policies and goals pertaining to agricultural resources, to achieve compact growth and limit the conversion of farmland to urban uses. When considering the conversion of farmland to non-agricultural uses, the County considers the following:
- PotenAal for the project to create development pressure on surrounding agricultural lands; - PotenAal for the premature conversion of prime farmland of statewide importance, unique farmland, farmland of local importance, and confined animal agriculture;
- PotenAal for impacts on surrounding farmland operaAons and pracAces; and - Provision of infrastructure and services to the new use and the potenAal impact of service demands or on the surrounding area (PSP) (Source: ExisAng GP, CODP, Growth AccommodaAon, ImplementaAon 13, ImplementaAon 14, modified)
(Source: San Joaquin County GP, LU-2.15: Agricultural Conversion)

City of Escalon Growth Management Ordinance
The City of Escalon’s Growth Management Ordinance was adopted to achieve the following objecAves:

1. To maintain and promote the distribuAon of residenAal densiAes as prescribed by the General Plan Land Use Map;

2. To maintain and promote economically, physically, and socially viable residenAal neighborhoods;

3. To preserve viable agricultural land to the maximum extent possible in the development and expansion of residenAal areas;

4. To promote the development of educaAonal, recreaAonal, and other necessary public faciliAes contribuAng to desirable residenAal areas.

The City’s General Plan Land Use Map depicts planned urbanizaAon that has been previously cerAfied for compliance with the CEQA regarding the conversion of agricultural land to nonagricultural use. The City achieves the previously listed growth management objecAves through the conAnued review and improvement of zoning and subdivision ordinances for residenAal purposes and site review via the building permit process for residenAal units and verificaAon of project consistency with approved plans (City of Escalon Growth Management Procedures Chapter 15.04). Future growth of residenAal buildings and the City’s public uAliAes shall conform to the Growth Management Ordinance which looks to protect prime agricultural lands from premature urbanizaAon.

5.2.2 ExisAng CondiAons
According to historic aerials of the Project and Local Vicinity, the earliest recorded aerial was shot in 1957, when the Local Vicinity was in use for Agricultural purposes (See hLps://www.historicaerials.com/viewer). Since 1957, this area has remained designated for agricultural uses. As menAoned in the Project DescripAon (SecAon 3.0), San Joaquin County is composed of primarily agricultural land (approximately 75 percent), due to its rich soil. Agriculture has

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become an essenAal part of local economies within the County. The County’s leading crops are almonds, walnuts, apples, and grapes (SJMSHCP 2000). The City of Escalon is a community dependent on the prosperity of these agricultural lands. For this reason, the City’s regulaAons and Growth Management Ordinance protect farmlands not typically found in other communiAes.

The proposed water main is located within the County’s right-of-way and paved public streets. The FCF will be located on undeveloped City right-of-way and the tank and BPS are proposed within the City right-of-way that is currently developed as a gravel top sports field over-flow parking lot and planned for future park expansion of Hogan-Ennis Park. The Project is proposed to improve the City’s water services to its consumer base reflected in exisAng connecAons within City Limits and planned growth idenAfied on the City’s General Plan Land Use and boundary maps.

The Project will reduce reliance on groundwater within the City of Escalon and is also proposed to fulfill regional objecAves for groundwater sustainability outlined in the Eastern San Joaquin IRWMP 2020 Addendum (Greater San Joaquin Regional Water CoordinaAon CommiLee, 2021).

5.2.3 Project Impacts
a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use?
RESPONSE:

Less than Significant Impact. Based on the CA DOC Farmland Mapping and Monitoring Program’s California Important Farmland Finder Website (See hLps://maps.conservaAon.ca.gov/DLRP/CIFF/), the Project will not directly convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to alternaAve uses. The Project will be implemented within the exisAng paved right-of-way, on a porAon of APN 207-190-06 designated as Farmland of Local Importance, and on a gravel parking lot designated as Unique Farmland (CA DOC Important Farmland Finder). The locaAon of the proposed FCF on APN 207-190-06, south of Dodds Road and Escalon- Bellota IntersecAon, is currently uAlized as an open grass field that is immediately adjacent to a paved street. The FCF site is proposed on exisAng agricultural land; however, this site is not Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland). The FCF will be posiAoned on approximately 900 sq. V. (0.02 acres) of Farmland of Local Importance. For the reasons above, no significant Project impacts related to direct conversion of Farmland to non -agricultural use would occur regarding the FCF or the water main.

Approximately 3.2 miles south of the proposed FCF, the Project will develop a porAon of an exisAng parking lot with the Project’s BPS, wet well, and subterranean storage tank facility. This parcel is designated as Unique Farmland and Prime Farmland by the County and City of Escalon in the DOC Farmland Mapping and Monitoring Program (CA DOC FMMP). The County has retained this parcel for future urban development under the land use designaAon agricultural reserve (AU Zone). AU Zones allow neighboring CiAes, like Escalon, to facilitate orderly and compact growth at appropriate Ames. This site is adjacent to exisAng urban uses and the City of Escalon has approved a plan to develop this site as part of the future expansion of Hogan-Ennis Community Park to serve the community pursuant to the approved Land Use Map and the General Plan. Due to the proposed size of the BPS on the exisAng overflow parking lot, the Project would not conflict with exisAng sports overflow parking or the intended future park use. The site is within the approved SOI and the City’s plans for development will supersede exisAng agricultural designaAons. Significant impacts are not anAcipated.

The Project will not result in direct or indirect impacts on Farmland; it is a planned extension of water services aligned with regional groundwater sustainability goals for the San Joaquin Valley that are intended to replace groundwater use with other sources of water to fulfill exisAng and future demand that has been considered with approved land use programs, such as the City of Escalon and County General Plan Land Use Maps. In this regard, the Project has been on the City’s CIP since 2019 and the implementaAon of the Project is an assumpAon considered in approved local and regional plans for urbanizaAon. Therefore, the Project would not result in addiAonal conversion of land. Historically, the City’s water supply has been provided from groundwater wells, however, Escalon’s planned future water supply will incorporate surface water from the SSJID SCSWSP supporAng regional groundwater sustainability and reduced groundwater extracAons in alignment with groundwater

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management objecAves of the Eastern San Joaquin IRWMP, 2020 Addendum (GSJRWCC, 2021). The Project is a planned infrastructure improvement that conjoins two water suppliers to promote groundwater sustainability as well as “provide system reliability and redundancy to the City’s long-term water supply” pursuant to the objecAves of the City’s Water Master Plan (Escalon Water Master Plan 2007). Growth-inducing impacts from the Project have been previously analyzed in the environmental documents and technical studies for the SCSWSP (SCH SCH#98022018) EIR. No addiAonal impacts beyond what have been previously idenAfied will result from Project implementaAon.

For these reasons, the Project will not result in Farmland conversion beyond what has already been approved in local plans for the City of Escalon’s General Plan and County and regional plans as well as regional plans regarding groundwater and water infrastructure in San Joaquin Valley. The Project will not conflict with the County and City’s General Plan goals and policies regarding the preservaAon of farmland and natural resources. Table 7:

Project Consistency with County and City Agriculture-Related General Plan Policies and Goals outlines Project consistency with policies and goals pertaining to agricultural land uses.

TABLE 7: PROJECT CONSISTENCY WITH COUNTY AND CITY AGRICULTURE-RELATED GENERAL PLAN

POLICIES AND GOALS
County General Plan (Land Use
Element)
City General Plan (Open
Space, ConservaAon, and
RecreaAon Element)
Project Consistency
Policy LU-1.1: Compact Growth and
Development. The County shall
discourage urban sprawl and
promote compact development
pa<erns, mixed-use development,
and higher development intensi
es
that conserve agricultural land
resources, protect habitat, support
transit, reduce vehicle trips, improve
air quality, make efficient use of
exis
ng infrastructure, encourage
healthful, ac
ve living, conserve
energy and water, and diversify San
Joaquin County's housing stock.

Policy LU-1.4: Encourage Infill
Development. The County shall
encourage infill development to
occur in Urban and Rural
Communi
es and City Fringe Areas
within or adjacent to exis
ng
development in order to maximize
the efficient use of land and use
exis
ng infrastructure with the
capacity to serve new development.

The County shall balance infill
development within outward
expansion of communi
es and new
development in other unincorporated
areas. (RDR) (Source: New Policy)
The Project proposes to install a BPS, wet well, and
subterranean storage tank within the southeastern
corner of an exisAng parking lot that is planned for
future park development. The proposed Project will be
on a shared parcel. Therefore, the Project will promote efficient and compact development by diversifying the
use of open spaces within the City’s SOI. In addiAon,
the FCF is located on parcels designated to agricultural use within unincorporated areas of San Joaquin County
that is currently in use for Agriculture and residenAal.

The FCF is anAcipated to have a footprint of
approximately 900 sq. V. (0.02 acres), which is
consistent with compact development paLerns
intended to be achieved by San Joaquin County’s
General Plan Land Use Policy LU-1.1.

Proposed Project Components will ulAmately conserve
the surrounding agricultural land resources the City
and County strive to preserve.

Policy 3.1.8 Maximize
farmland, open space, and
wildlife habitat preserva
on
on lands outside of the City by
See SecAon 5.2.3, Response a). The Project is not
intended to facilitate conversion of agriculture to
urban use and does not propose to convert farmland
outside of city limits. The Project will be located on

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establishing a greenbelt
including all lands not
designated for future
annexa
on on the General
Plan Land Use Diagram. The
City shall use natural or
manmade features to
transi
on from urban to nonurban uses.
land designated as public right-of-way. The BPS will be installed on a parcel that is currently developed and
planned for future development with urban uses. The
FCF will install infrastructure within a corner of a parcel that is in use for agriculture. The proposed footprint
of development for the FCF and BPS are small and
would not preclude planned expansion of the park use
or ongoing agricultural use at either locaAon.

The FCF will be placed on Farmland of Local
Importance; however, due to the scale and nature of
the FCF, land conversion is not anAcipated to be
significant. Therefore, with the installaAon of the FCF, adjacent agricultural uses to remain during the
facility’s long-term operaAon.

Policy LU-1.7: Farmland
Preserva
on. The County shall
consider informa
on from the State
Farmland Mapping and Monitoring
Program when designa
ng future
growth areas in order to preserve
prime farmland and limit the
premature conversion of
agricultural lands. (RDR) (Source:

New Policy)
See SecAon 5.2.3, Response a). The farmland finder
map indicates that the Project will install infrastructure on land that contains “lesser quality soils” typically
“used for the producAon of the state’s leading
agricultural crops” (Farmland Mapping Website). The
FCF is located on Farmland of Local Importance. This
designaAon is determined by each county’s board of
supervisors and a local advisory commiLee; however,
this designaAon is disAnctly different than Prime
Farmland, Unique Farmland, and Farmland of
Statewide Importance (Farmland Mapping Website).

The proposed locaAon for the FCF does not contain
crops and the installaAon and long-term operaAon of
the FCF will not limit the use of this parcel for on-going agricultural use; therefore, disrupAons to agricultural producAon are not anAcipated by the alternaAve in
land use for a public uAlity.

Project Components including the BPS, subterranean
storage tank, and wet well are within the AU Zone and
have been considered and approved for development,
the parcels designated land use is consistent with
County and City plans. The parcel designated as
Unique Farmland will not be converted to land uses
that have not already been uAlized for urban
development.

Policy LU-2.15: Agricultural
Conversions. When reviewing
proposed General Plan amendments
to change a land use diagram or
zoning reclassifica
on to change
from an agricultural use to nonagricultural use, the County shall consider the following:
- poten
al for the project to
create development pressure
on surrounding agricultural
lands;
- poten
al for the premature
conversion of prime farmland,
farmland of statewide
The proposed Project will improve water infrastructure
in a manner that is consistent with regional plans for
sustainable water use and groundwater management.

The proposed infrastructure is an allowed use
pursuant to local municipal codes and would not
require amendments to the General Plan or Zoning
Code.

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importance, unique farmland,
farmland of local importance,
and confined animal
agriculture;
- poten
al for impacts on
surrounding farming
opera
ons and prac
ces; and
- provision of infrastructure and
services to the new use and the
poten
al impact of service
demands or on the
surrounding area (PSP)
(Source: Exis
ng GP, CODP,
Growth Accommoda
on,
Implementa
on 13,
Implementa
on 14, modified)

Policy LU-7.9 Agricultural-Urban
Reserve The County shall preserve
areas designated Agricultural-Urban
Reserve (A/UR) for future urban
development by ensuring that the
opera
onal characteris
cs of the
exis
ng uses does not have a
detrimental impact on future urban
development or the management of
surrounding proper
es, and by
generally not allowing capitalintensive facility improvements or permanent structures that are not
compa
ble with future urban
development. (RDR/PSP)
The planned locaAon of the BPS, wet well, and
subterranean storage tank is within an AU Zone. The
proposed Project is consistent with development
standards set forth by the County and City within these parcels. The development standards allow
“compaAble public, quasi-public, and special uses”
including parks and proposed infrastructure to support
public water systems. The size and locaAon of the BPS
will not preclude the future park expansion or exisAng
use of the park.

The FCF is within agricultural land use designaAons.

The size and locaAon of the FCF will not preclude the
exisAng and future use of this parcel for agriculture or development due to size and locaAon within the
southwest corner of the parcel, adjacent to EscalonBellota Road.

Plans for the Project indicate the most of the
infrastructure that will be installed with the Project will be subterranean and would not affect exisAng or
future land use.

Policy 3.3.3: The City will
preserve and protect
agricultural use on lands in
and surrounding the Escalon
planning area for open space
purposes and for the
managed produc
on of
resources.

See SecAon 5.2.3, Response a). The Project design id
compact and will. install mostly subterranean features
that will not affect agricultural use on lands. Most of the Project is proposed on land that is developed and
in use for public right-of-way. Therefore, the Project is consistent with Policy 3.3.3.

Source: (1) City of Escalon General Plan Update, DEIR adopted February 2005; (2) San Joaquin County 2035 General Plan EIR, adopted October 2014 The Project would not significantly impact agricultural resources during construcAon or long-term operaAon due to the reasons stated above. Overall, the Project will funcAon in substanAal conformance with the assumpAons and conclusions associated with the approved project analyzed in the previously cerAfied SCSWSP EIR which incorporated the City of Escalon’s surface water connecAon. Less than Significant impacts are anAcipated.

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Less than Significant Impact. The Project is located on parcels within the County public right-of-way adjacent to land zoned under the Williamson Act as “Nonprime Agriculture Land”. The 19,500 LF of potable water pipeline proposes to stay within the bounds of the public right-of-way; the FCF will be located on land designated for Agricultural Urban Reserve and the BPS will be on land designated for General Agriculture. These parcels are not on land under a Williamson Act contract. The implementaAon of the FCF will be on land that is currently in agricultural use. However, due to the size, parcel corner locaAon, and mostly subterranean nature of the FCF design, this component of the Project will not conflict with the exisAng agricultural use. San Joaquin County anAcipates the conversion of farmland for infrastructure and services under County Policy LU-2.15: Agricultural Conversion. This parcel is not under a Williamson Act contract and the development of the FCF will not impact adjacent land uses east, north, and south of the proposed FCF locaAon, which are under the Williamson Act contract. The proposed infrastructure use on the FCF site is consistent and will allow uses idenAfied in the exisAng Zoning Code.

Staging areas are expected to be located along various points of the Project alignment and will not occur outside of the County and City right-of-way. Access to APN 207-190-06 will likely occur via Escalon-Bellota Road; therefore, disrupAons to adjacent agricultural producAon are not anAcipated to occur. The Project proposes a structure containing the BPS, subterranean storage tank, and wet well within the southeastern corner of an exisAng overflow sports parking lot. The footprint of the structure is approximately 40-feet-8-inch x 26-feet-8- inch (1,040 sq. V./0.024 acres) and does not propose to take up the enAre gravel-lined parking lot. Due to the proposed scale of the Project Component, the Project represents compact growth pursuant to County policy LU1.1: Compact Growth and Development and LU-2.15: Agricultural Conversions (see Table 7: Project Consistency with County and City Agriculture-Related General Plan Policies and Goals for more detail) and will not impact future park use or expansion.

As a result, the proposed Project will not conflict with exisAng zoning for agricultural use, or a Williamson Act contract beyond what has already been approved and considered by the County of San Joaquin, SSJID, and applicable landowners. Impacts are anAcipated to be less than significant; therefore, no MiAgaAon Measures are necessary.
c) Conflict with exisAng zoning for, or cause rezoning of, forest land (as defined in Public Resources Code SecAon 12220(g)), Amberland (as defined by Public Resources Code SecAon 4526), or Amberland zoned Timberland ProducAon (as defined by Government Code SecAon 51104(g))? RESPONSE:

No Impact. The Project will not result in any temporary, permanent direct or indirect change in areas labeled as Forest Land in the General Plan of both the County and City. Zones have not been labeled as forest land within the City or County and as such, no impact is foreseen due to the locaAon of the Project. Therefore, no MiAgaAon Measures are necessary.
d) Result in the loss of forest land or conversion of forest land to non-forest use? RESPONSE:

No Impact. See Response 5.2.3, c). The Project is not located near nor does the Project result in changes to areas labeled as Forest land within the County or City of Escalon General Plans. Therefore, no impact is foreseen. No MiAgaAon Measures are needed.
e) Involve other changes in the exisAng environment which, due to their locaAon or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use RESPONSE:

No Impact. The Project is located within a County and City right-of-way consisAng of an exisAng paved roadway, vacant agricultural land, and a gravel-surface parking lot for the purpose of replacing groundwater use with surface water allocaAons approved in exisAng agreements. The Project will implement City and regional plans that reflect approved local land use programs, General Plans, the SSJID Water Master Plan, the SCSWSP, and the

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Eastern San Joaquin IRWMP, 2020 Addendum. Changes associated with the Project would be derived from temporary construcAon acAviAes occurring enArely within the Project footprint and will not result in Farmland or forest land conversion to non-agricultural or non-forest use. Likewise, there will be no indirect impacts in this regard due to Project consistency with the applicable local and regional plans. ImplementaAon of the Project has been considered in regional plans and has been conceptually cerAfied for compliance with CEQA within the SCSWSP EIR; therefore, no impact is anAcipated, and no addiAonal MiAgaAon Measures are needed.

5.2.4 MiAgaAon Measures
No MiAgaAon Measures are needed.

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5.3 AIR QUALITY
Issues
PotenAally
Significant
Impact
Less than
Significant
Impact with
MiAgaAon
Incorporated
Less than
Significant
Impact No Impact
III. AIR QUALITY. Where available, the significance criteria established by the applicable air quality management district or air polluAon control district may be relied upon to make the following determinaAons. Would the Project:
a) Conflict with or obstruct implementaAon of the
applicable air quality plan?
b) Result in a cumulaAvely considerable net
increase of any criteria pollutant for which the
Project region is non-aLainment under an
applicable federal or state ambient air quality
standard?
c) Expose sensiAve receptors to substanAal
pollutant concentraAons?
d) Result in other emissions (such as those leading
to odors) adversely affecAng a substanAal
number of people?

5.3.1 Regulatory Compliance
Federal and State Ambient Air Quality Standards
The Federal Clean Air Act was first implemented by the U.S. Environmental ProtecAon Agency (U.S. EPA) in 1970 to enforce federal ambient air quality standards (NAAQS) for six criteria air pollutants, which include parAcular maLer of aerodynamic radius of 10 micrometers or less (PM 10), parAculate maLer of aerodynamic radius of 2.5 micrometers of less (PM 2.5), carbon monoxide (CO), nitrogen dioxide (NO2), ground-level ozone, and lead. Federal standards are designed to protect public health and the environment with a reasonable margin of safety (Reference Table 8: Federal and State Pollutant Standards).

TABLE 8: FEDERAL AND STATE POLLUTANT STANDARDS

Air Pollutant
ConcentraAon/ Averaging Time

Most Relevant Effect

California Standards
Federal Primary
Standards

Ozone (O3)

0.09 ppm/1-hour

0.07 ppm/8-hour

0.070 ppm/8-hour
(a) Decline in pulmonary funcAon and localized lung
edema in humans and animals; (b) Risk to public health
implied by alteraAons in pulmonary morphology and
host defense in animals;
(c) Increased mortality risk;
(d) Risk to public health implied by altered connecAve
Assue metabolism and altered pulmonary morphology
in animals aVer long-term exposures and pulmonary
funcAon decrements in chronically exposed humans;
(e) VegetaAon damage; and
(f) Property damage.

Carbon Monoxide
(CO)

20.0 ppm/1-hour

9.0 ppm/8-hour

35.0 ppm/1-hour

9.0 ppm/8-hour
(a) AggravaAon of angina pectoris and other aspects of
coronary heart disease;
(b) Decreased exercise tolerance in persons with
peripheral vascular disease and lung disease;
(c) Impairment of central nervous system funcAons;
and
(d) Possible increased risk to fetuses.

Nitrogen Dioxide
(NO2)

0.18 ppm/1-hour

0.03 ppm/annual
100 ppb/1-hour

0.053 ppm/annual
(a) PotenAal to aggravate chronic respiratory disease
and respiratory symptoms in sensiAve groups;
(b) Risk to public health implied by pulmonary and
extra-pulmonary biochemical and cellular changes and
pulmonary structural changes; and

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Sulfur
Dioxide
(SO2)

0.25 ppm/1-hour

0.04 ppm/24-hour
75 ppb/1-hour

0.14 ppm/annual
(a) BronchoconstricAon accompanied by symptoms
which may include wheezing, shortness of breath, and
chest Aghtness, during exercise or physical acAvity in
persons with asthma.

Suspended
ParAculate MaLer
(PM10)
50 µg/m3
/24-hour
20 µg/m3
/annual
150 µg/m3
/24-
hour
(a) ExacerbaAon of symptoms in sensiAve paAents with
respiratory or cardiovascular disease;
(b) Declines in pulmonary funcAon growth in children;
(c) Increased risk of premature death from heart or
Suspended lung diseases in elderly.

ParAculate MaLer
(PM2.5)
12 µg/m3 / annual 35 µg/m3
/24-hour
12 µg/m3
/annual
Sulfates 25 µg/m3
/24-hour
No Federal
Standards
(a) Decrease in venAlatory funcAon;
(b) AggravaAon of asthmaAc symptoms;
(c) AggravaAon of cardio-pulmonary disease;
(d) VegetaAon damage;
(e) DegradaAon of visibility;
(f) property damage.

Lead

1.5 µg/m3
/30-day 0.15 µg/m3/3-
month rolling
(a) Learning disabiliAes;
(b) Impairment of blood formaAon and nerve
conducAon.

Visibility Reducing
ParAcles
ExAncAon coefficient of

0.23 per kilometervisibility of 10 miles or
more due to parAcles
when humidity is less
than 70 percent.

No Federal
Standards
Visibility impairment on days when relaAve humidity is
less than 70 percent.

Source: hps://ww2.arb.ca.gov/sites/default/files/2020-07/aaqs2.pdf The CARB and the EPA designate air basin boundaries across the state to regulate air quality under the Clean Air Act through monitoring, permiNng, and establishing standards for criteria pollutants. Air basins exceeding established standards are designated as “nonaLainment” areas. If there is inadequate or inconclusive data to make a definiAve aLainment designaAon, they are considered “unclassified.” NaAonal nonaLainment areas are further designated as marginal, moderate, serious, severe, or extreme according to the extent of deviaAon from standards. Each standard has unique criteria for aLainment, based on specific air quality staAsAcs related to levels of probable health risk and potenAal environmental damage (CARB). Table 10: SJVAPCD A<ainment Status displays the current aLainment standards of San Joaquin Valley Air PolluAon Control District (SJVAPCD).

SJVAPCD
The Project is within the SJVAPCD’s District boundaries, which extend over eight counAes within California’s Central Valley region (approximately 250 miles long). SJVAPCD’s responsibiliAes as an Air PolluAon Control District are to protect public health while developing effecAve, acAve air polluAon controls for economic prosperity and growth opportuniAes. SJVAPCD regulates air quality in the basin by monitoring and reporAng levels of ten criteria air pollutants within its jurisdicAon and by seNng standards for achieving compliance with state and federal air quality regulaAons for each criteria pollutant in addiAon to their significance thresholds (See Table 9: SJVAPCD Air Quality Significance Thresholds and Table 8: Federal and State Pollutant Standards). SJVAPCD operates a total of 38 air monitoring staAons throughout San Joaquin Valley. Air monitoring sites are operated in collaboraAon with CARB, the NaAonal Park Services, and tribal naAons (Valley Air District 2022).

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TABLE 9 : SJVAPCD AIR QUALITY SIGNIFICANCE THRESHOLDS
Air Quality Thresholds of Significance
Pollutant/
Precursor
ConstrucAon
Emissions
OperaAonal Emissions
PermiLed Equipment and
AcAviAes
Non-PermiLed Equipment and
AcAviAes
Emissions (tons/ year) Emissions (tons/year) Emissions (tons/ year) CO 100 100 100
NOx 10 10 10
ROG 10 10 10
SOx 27 27 27
PM10 15 15 15
PM2.5 15 15 15
Air Quality Thresholds of Significance – Toxic Air Containments Carcinogens Maximally Exposed Individual risk equals or exceeds 20 in one million Non-Carcinogens Acute: Hazard index equals or exceeds 1 for the Maximally Exposed Individual Chronic: Hazard Index equals or exceeds 1 for the Maximally Exposed Individual Source: hLp://www.valleyair.org/transportaAon/ceqa_idx.htm SJVAPCD regulaAons target acAviAes known to contribute to high levels of criteria emissions. Source pollutants are grouped into two categories, either point source or non-point source, and are regulated through discreAonary review and approvals. The SJVAPCD process allows for review of proposed acAviAes and condiAonal approval incorporaAng emissions reducAon measures to achieve pollutant aLainment and maintenance of air quality standards adopted by CARB and U.S. EPA. Projects that propose to construct, modify, or operate a facility that may emit pollutants from a staAonary source into the atmosphere, must obtain an Authority to Construct, and thereaVer a Permit to Operate from the District, which may require implementaAon of BMPs or condiAons of approval with projects to target specific criteria pollutants and reduce emissions. Likewise, local agencies work cooperaAvely with SJVAPCD through the discreAonary enAtlement process to incorporate BMPs and condiAons of approval for construcAon acAviAes and longterm operaAons.

Pursuant to U.S EPA health-based NAAQS established by the Clean Air Act for criteria pollutants, the District has adopted 650 rules that have significantly reduced emission levels to comply with EPA’s NAAQS standards. The following rules apply to the proposed Project:

District Regula
on VIII (Fugi
ve PM10 Prohibi
ons) – Regula
on VIII (Rules 8011- 8081) is a series of rules designed to reduce PM10 emissions (predominantly dust/dirt) generated by human acAvity, including construcAon, road construcAon, bulk materials storage, landfill operaAons, etc. A Dust Control Plan must be submiLed for the District’s approval at least 30 days before construcAon acAviAes begin if the Project cumulaAvely encompasses 40 acres or more or will move more than 2,500 CY per day of material on at least three days of the Project.

District Rule 4641 (Cutback, Slow Cure, and Emulsified Asphalt, Paving and Maintenance Opera ons). If asphalt paving
will be used, then paving operaAons of the Project will be subject to Rule 4641. This rule applies to the manufacture and use of cutback asphalt, slow-cure asphalt, and emulsified asphalt for paving and maintenance operaAons.

District Rule 4102 (Nuisance) applies to any source operaAon that emits or may emit air contaminants or other materials. If the Project creates a public nuisance, it could be in violaAon and be subject to District enforcement acAon.

5.3.2 ExisAng CondiAons
The closest air monitoring staAons to the Project are the Modesto-14th Street staAon (Stanislaus County, California) and the Manteca (San Joaquin County, California) monitoring staAon. Modesto- 14th Street monitoring site is approximately 11.4 miles southwest of the proposed BPS, storage tank, and wet well site. The Manteca monitoring site is approximately 12.4 miles west of the proposed BPS, storage tank, and wet well site.

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Within the central valley, prevailing winds are from west to east up to 15 mph and annual rainfall averages 12.2 inches during the wet season (SSJID UWQMP 2020). Air quality data from these two monitoring staAons reflects areawide topography, meteorology, and climate, in addiAon to the quanAty of emissions released by exisAng air pollutant sources. As shown in Table 10: SJVAPCD A<ainment Status, the Project is within an area that is not in aLainment for ozone, PM10, and PM2.5 standards. The pollutants that are in aLainment status at this Ame include CO, NO, Sulfur Dioxide (SO2), Lead, Sulfates, and Vinyl Chloride. Carbon Monoxide tends to be higher and a greater cause for concern due to its primary source from automobile emissions; therefore, CO is regulated with specific standards and analysis methodology tailored to each specific locaAon.

TABLE 10 : SJVAPCD ATTAINMENT STATUS
Pollutant State Status Federal ALainment Status
Ozone- One hour No Federal Standard NonaLainment/ Sever Ozone- Eight-hour NonaLainment/ Extreme NonaLainment
PM10 ALainment NonaLainment
PM2.5 NonaLainment NonaLainment
Carbon Monoxide (CO) ALainment/ Unclassified ALainment/ Unclassified Nitrogen Monoxide (NO) ALainment/ Unclassified ALainment Sulfur Dioxide (SO2) ALainment/ Unclassified ALainment
Lead No DesignaAon/ ClassificaAon ALainment
Hydrogen Sulfide No Federal Standard Unclassified
Sulfates No Federal Standard ALainment
Visibility Reducing ParAcles No Federal Standard Unclassified Vinyl Chloride No Federal Standard ALainment
Source: SJVAPCD 2020.

In addiAon to source emissions like automobiles, the aLainment status of the pollutants listed within Table 10:

SJVAPCD A<ainment Status is heavily influenced by topographic features, climate, and weather paLerns that affect air moment. Due to San Joaquin Valley’s weather and unique terrain consisAng of elevated mountain ranges in the east and west in conjuncAon with temperature inversions, diluAon of air pollutants is restricted; therefore, air polluAon remains concentrated within the basin (Escalon GP DEIR, 2005). Table 11: San Joaquin County Ambient Air Quality outlines the number of days that air quality within the County exceeded Federal and State standards for PM 10 and Ozone. The following table is based on various monitoring sites throughout the County during a monitoring period between 1992 and 2002. State PM 10 exceeded Federal and State standards frequently at the Stockton Hazelton Street and Modesto 14th Street Monitoring Sites.

TABLE 11 : SAN JOAQUIN VALLEY COUNTY AMBIENT AIR QUALITY Days Exceeding Standards
Year
Stockton- E. Mariposa Stockton- Hazleton Street Modesto 14th Street State
Ozone
Federal
Ozone
State PM10 Federal
PM 10
State
Ozone
Federal
Ozone
State
PM10
Federal
PM10
1992 18 0 108 0 10 0 -- --
1993 11 1 77 0 13 0 -- --
1994 15 0 58 0 24 0 -- --
1995 13 2 18 0 19 2 -- --
1996 4 0 18 0 24 2 12 --
1997 3 0 26 0 5 0 -- --
1998 9 0 43 0 24 3 18 --
1999 4 1 60 0 13 0 12 0
2000 4 0 36 0 7 1 15 0
2001 5 0 60 0 12 0 57 3
2002 5 0 60 0 14 0 78 0
Source: (1) City of Escalon General Plan Update DEIR 2005 (2) Air Resources Board Aerometric Data Analysis and Management System (ADAM) (3) Measurements of PM 10 are made every sixth day. Data is the esAmated number of days that the standard would have been exceeded had measurements been collected every day.

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5.3.3 Project Impacts
The following responses are based on the Air Quality, Greenhouse Gas, and Energy Technical Memorandum (Appendix A) by the Ganddini Group dated July 25, 2023. The following analysis is focused on construcAon-related emissions and long-term operaAonal emissions.
a) Conflict with or obstruct implementaAon of the applicable air quality plan? RESPONSE:

Less than Significant Impact.

Short-term Impacts
The proposed Project is anAcipated to result in approximately 99,600 sq. V.2 of temporary disturbances during Project construcAon and will include approximately 3,348 CY of export and 4,680 CY of import3. Project construcAon is anAcipated to take approximately one year and four months to complete. Appendix A anAcipated one (1) more jack and bore locaAon than proposed for the Project; however, temporary disturbances from the addiAonal esAmate are negligible.

As shown within Table 12: Construc
on-Related Regional Pollutant Emissions, pollutant emissions modeled using CalEEMod based on these assumpAons, indicate construcAon-related criteria pollutant emissions for the construcAon of the proposed Project will not exceed the regional emission thresholds. As a result, impacts to applicable air quality plans are not anAcipated to occur. Less than significant impacts are anAcipated. No MiAgaAon Measures are needed.

TABLE 12 : CONSTRUCTION-RELATED REGIONAL POLLUTANT EMISSIONS AcAvity Pollutant Emissions (pounds/day)
ROG NOx CO SO2 PM10 PM2.5
Maximum Daily Emissions1 0.46 4.11 5.15 0.01 0.17 0.15
SCAQMD Thresholds 10 10 100 27 15 15
Exceeds Thresholds? No No No No No No
Source: CalEEMod Version 2022.1.1.13
Notes: See Appendix A (Air Quality, Greenhouse Gas Emissions, & Energy Technical Memorandum, Ganddini, 2023) (1) On-site PM 2.5 and PM 10 emissions show compliance with SJVAPCD RegulaAon VIII of fugiAve dust.

Long-term Impacts
OperaAonal emissions were analyzed using CalEEMod and based on the year 2026, the anAcipated opening year for the proposed Project, which has been delayed by two years; it is assumed that air quality condiAons in 2028 will be substanAally similar to 2026 condiAons. Long-term operaAon will not require addiAonal staffing needs for maintenance and operaAons, in addiAon, a minimal number of daily worker trips are anAcipated to conduct rouAne inspecAons and ensure proper long-term maintenance. Therefore, the addiAonal vehicle trips from the exisAng operaAons associated with the operaAon of the proposed Project are minimal.

The worst-case summer or winter VOC, NOx, CO, SO2, PM 10, and PM 2.5 emissions generated by the proposed Project’s long-term operaAons are shown in Table 13: Regional Opera onal Pollutant Emissions. As noted within
the table below, none of the analyzed criteria pollutants would exceed the SJVAPCD emissions thresholds.

Therefore, less than significant impacts are anAcipated. 2 Total disturbance area esAmated based on 19,500 LF of pipeline with trench 6 V deep x 4 V wide (19,500 x 4 V = ~78,000 sf disturbance area); 13 jacking pits at 20x35x13V = 700sf x 13 = ~9,100 sf and 13 receiving pits at 20x10x13V = 200sf x 13 = ~2,600 sf for jack and bore; FCF is ~50x70 V (~3,500 sf disturbance area); and BPS is ~64x100 V (~6,400 sf disturbance area). Therefore, total disturbance area of ~99,600 sf. 3 Assumed ~3,348 CY export and ~2,359 CY fill based on the calculated numbers provided in the 30% OPCC provided by the Ardurra Group Project Engineers (includes excavaAon, backfill, aggregate base, and subgrade numbers for pipeline, FCF, BPS, etc.).

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TABLE13 : REGIONAL OPERATIONAL POLLUTANT EMISSIONS
AcAvity
Pollutant Emissions (tons/year)
ROG NOx CO SO2 PM10 PM2.5
Maximum Daily Emissions 0.16 0.45 0.57 0.01 0.03 0.03
SJVAPCD Thresholds 10 10 100 27 15 15
Exceeds Threshold? No No No No No No
Source: Appendix A (Air Quality, Greenhouse Gas & Energy Technical Memorandum, Ganddini 2023).

Notes: (1) CalEEMod Version 2022.1.1.14; the higher of either summer or winter emissions.

Since short-term, construcAon-related emissions and long-term operaAonal emissions are not anAcipated to exceed SJVAPCD thresholds, Project impacts are considered less than significant. b) Result in a cumulaAvely considerable net increase of any criteria pollutant for which the Project region is nonaLainment under an applicable federal or state ambient air quality standard? RESPONSE:

Less than Significant Impact. See SecAon 5.3.3, Response a). As menAoned above, the Project does not anAcipate exceeding thresholds for criteria pollutants set by SJVAPCD for construcAon-related and operaAonal emissions.

See Table 12: Construc
on-Related Regional Pollutant Emissions and Table 13: Regional Opera onal Pollutant
Emissions above. In addiAon, due to the scale of the proposed Project and projected use, long-term pollutant emissions during operaAon are not anAcipated to exceed regional pollutant thresholds beyond what has been approved and considered by the City of Escalon’s General Plan, Water Master Plan, and SSJID’s SCSWSP EIR.

As a result of the following, impacts are anAcipated to be less than significant. Therefore, no MiAgaAon Measures are needed.
c) Expose sensiAve receptors to substanAal pollutant concentraAons? RESPONSE:

Less than Significant with MiAgaAon Incorporated. See SecAon 5.3.3 Response a) and b). The closest sensiAve receptors to the Project are exisAng residenAal uses located adjacent to Escalon-Bellota Road between Dodds Road to Miller Avenue. Approximately 150 feet south of the proposed locaAon of the FCF is a single-family residenAal development with agricultural support structures. In addiAon, Escalon High School is located approximately 887 feet (~270 meters) to the southeast of the proposed BPS site. Other air quality-sensitive land uses are located further from the Project area and would experience significantly lower impact. However, according to Table 12: Construc
on-Related Regional Pollutant Emissions and Table 13: Regional Opera onal
Pollutant Emissions, Project construcAon, and operaAons do not anAcipate exceeding the SJVAPD significance thresholds.

According to historic aerials, the Project and Local Vicinity have been in use as agricultural land since approximately 1957. As a result, the possibility that pesAcides and arsenic from these agricultural pracAces can be found in surface soils which may become airborne during excavaAon and earthwork for the Project could exceed levels of significance for environmental health. For this reason, the Project will implement SJVAPCD Rule 8081 regarding fugiAve dust emissions from agricultural sources (MM AQ-01: FugiAve Dust Control and MM AQ02: (Compliance with SJVAPCD) Verify SJVAPCD’s Control Measures) during construcAon acAviAes to reduce impacts to adjacent residenAal properAes under standard condiAon SC AQ-01: Regular Cleaning of Track-out Areas. These measures require implementaAon and recordkeeping on fugiAve dust emissions controls, tesAng, and temporary barriers between acAve construcAon and the closest sensiAve receptors and will result in less than significant impacts on emissions downwind to the Project and Local Vicinity. For these reasons, Project implementaAon would not expose sensiAve receptors to substanAal pollutant concentraAons and impacts are anAcipated to be less than significant with miAgaAon and standard condiAons incorporated.

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Less than Significant with MiAgaAon Incorporated. The Project proposed to install 19,500 LF of potable water pipeline; FCF; BPS, and a storage tank. Adhesives and other chemicals may be uAlized during Project construcAon, which any result in exposure to odors during construcAon with the closest receptors being construcAon crew members. However, this is not expected to result in significant impacts to the surrounding community because Cal-OSHA standards will be implemented for the crew during construcAon acAviAes to fully reduce emissions to acceptable levels and dispersion will occur with distance from construcAon.

Emissions relaAng to earthwork and equipment use will occur during construcAon, however, the Project contractor will deploy BMPs during construcAon acAviAes including compliance with California Code of RegulaAon Title 13, Motor Vehicles, secAon 2449(d)(3) Idling, which limits idling of construcAon vehicles and emission potenAally of odorous exhaust; and SJVAPCD Control Measures and FugiAve Dust Control under MM AQ-01:

FugiAve Dust Control and MM AQ-02: (Compliance with SJVAPCD) Verify SJVAPCD’s Control Measures.

As a result, Project impacts are anAcipated to be less than significant with the incorporaAon of miAgaAon.

5.3.4 MiAgaAon Measures
MM AQ-01: FugiAve Dust Control- For construcAon acAviAes associated with all project components: the City of Escalon shall require contractor(s) to implement the following measures throughout construcAon acAviAes. These measures shall be incorporated in bid documents prior to City approval. The implementaAon of these measures shall be verified on an ongoing basis through construcAon inspecAons:
- Water, chemical soil stabilizers/ suppressants, or vegetaAve ground cover shall be used to control fugiAve dust from all disturbed areas, including storage piles, which are not in acAve use at the construcAon site. - Water or chemical soil stabilizers shall be used to control fugiAve dust from all unpaved roads uAlized for construcAon access.
- ApplicaAons of water or presoaking shall be performed to control fugiAve dust from all land clearing, grubbing, scraping, excavaAon, land leveling, grading, cut and fill, and demoliAon acAviAes. - Cover and wet all materials transported off-site or require all trucks to maintain at least size feet of freeboard from the top of the container.
- Remove accumulated mud directly from adjacent public streets at least every 24 hours during construcAon periods. (The use of dry rotary brushes is expressly prohibited, except where preceded or accompanied by sufficient weNng to limit the visible dust emissions. The use of blower devices is also expressly forbidden.) - Water or chemical soil stabilizers/ suppressants shall be used to control fugiAve dust aVer each addiAon of materials to or removal of materials from all storage piles. - Limit the speed of all construcAon vehicles to 15 miles per hour on unpaved roads. - Re-plant vegetaAon in disturbed areas as quickly as possible.

MM AQ-02: (Compliance with SJVAPCD) Verify SJAPCD’s Control Measures. The contractor, City Engineer, and Inspectors shall verify that the SJVAPCD’s control measure is implemented as outlined below or equivalent to reduce fugiAve dust emissions throughout all phases of construcAon. These measures shall be incorporated in bid documents prior to City approval. The implementaAon of these measures shall be verified on an ongoing basis through construcAon inspecAons:

1. Require construcAon equipment used at the site to be equipped with catalysts/parAculate traps to reduce parAculate and NOx emissions. These catalysts/traps require the use of ultra-low sulfur diesel fuel (15 ppm).

At the Ame bids are made, contractors shall show that the construcAon equipment used is equipped with parAculate filters and/or catalysts or prove why it is infeasible.

2. Use alternaAve fuels and construcAon equipment.

3. Replace fossil-fueled equipment with electrically driven equivalents (provided they are not run via a portable generator set).

4. Install windbreaks on windward sides of construcAon areas.

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5. Curtail construcAon during periods of high ambient pollutant concentraAons. This may include ceasing construcAon acAvity during peak-hour vehicular traffic on adjacent roadways, and “Spare the Air Days” declared by the District.

5.3.5 Standard CondiAons
SC AQ-01: Regular Cleaning of Track-out Areas. Before Project approval, the City Engineer shall confirm that the plans and specificaAons for the Project include a note requiring regular cleaning of track-out areas throughout each workday and at the end of each workday to clean dirt deposited on any public highway or street (SJVAPCD Rule 8041: Carryout and Trackout).

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5.4 BIOLOGICAL RESOURCES
Issues
PotenAally
Significant
Impact
Less than
Significant
Impact with
MiAgaAon
Incorporated
Less than
Significant
Impact No Impact
IV. BIOLOGICAL RESOURCES – Would the project:
a) Have a substanAal adverse effect, either directly
or through habitat modificaAons, on any species
idenAfied as a candidate, sensiAve, or special
status species in local or regional plans, policies,
or regulaAons, or by the California Department
of Fish and Game or U.S. Fish and Wildlife
Service?
b) Have a substanAal adverse effect on any riparian
habitat or other sensiAve natural community
idenAfied in local or regional plans, policies,
regulaAons, or by the California Department of
Fish and Game or U.S. Fish and Wildlife Service?
c) Have a substanAal adverse effect on state or
federally protected wetlands (including, but not
limited to, marsh, vernal pool, coastal, etc.)
through direct removal, filling, hydrological
interrupAon, or other means?
d) Interfere substanAally with the movement of
any naAve resident or migratory fish or wildlife
species or with established naAve resident or
migratory wildlife corridors, or impede the use
of naAve wildlife nursery sites?
e) Conflict with any local policies or ordinances
protecAng biological resources, such as a tree
preservaAon policy or ordinance?
f) Conflict with the provisions of an adopted
Habitat ConservaAon Plan, Natural Community
ConservaAon Plan, or other approved local,
regional, or state habitat conservaAon plan
This secAon is based on the Biological Resources Assessment (BRA) for the City of Escalon’s ConnecAon to Nick DeGroot Water Treatment Plant Project in the City of Escalon, San Joaquin County California, dated August 30, 2024 (Appendix B). The BRA was performed by ELMT ConsulAng and is based on a field survey, conducted on March 1, 2023, by biologist Rachel A. Lyons, which evaluated the habitat within a 200-V buffer around the Project; and literature review and records search of special-status biological resources using a query of the CDFW’s QuickView Tool in the Biogeographic InformaAon and ObservaAon System (BIOS), CNDDB Rarefind 5, the California NaAve Plant Society’s (CNPS) Electronic Inventory of Rare and Endangered Vascular Plants of California, Calflora Database, compendia of special-status species published by CDFW, and the United States Fish and Wildlife Service (USFWS) species lisAngs. As well as the following resources:
• Google Earth Pro historic aerial imagery (1985-2024); • United States Department of Agriculture (USDA) Natural Resource ConservaAon Service (NRCS), Soil Survey4; • USFWS CriAcal Habitat designaAons for Threatened and Endangered Species; and • USFWS Endangered Species Profiles.
4 A soil series is defined as a group of soils with similar profiles developed from similar parent materials under comparable climaAc and vegetaAon condiAons. These profiles include major horizons with similar thickness, arrangement, and other important characterisAcs, which may promote favorable condiAons for certain biological resources.

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5.4.1 Regulatory Compliance
Federal Endangered Species Act (ESA)
The ESA was enacted in 1973 and establishes protecAons for fish, wildlife, and plants that are listed as threatened or endangered along with the ecosystems these species depend on (16 U.S.C. 1531-1544) (USFWS 2023). The U.S. Fish and Wildlife Service (USFWS) and NaAonal Marine Fisheries Services (NMFS) share the responsibility for implemenAng the ESA. Generally, the USFWS oversees terrestrial and freshwater species, while the NMFS manages marine and anadromous species.

Migratory Bird Treaty Act (MBTA)
The MBTA of 1918 established a conservaAon treaty intended to promote the sustainability of populaAons of protected migratory bird species. The MBTA prohibits the killing, capture, selling, trading, and transport of protected migratory bird species without prior authorizaAon by the USFW (USFWS 2023). In addiAon, the MBTA makes it unlawful to remove nests, eggs, and feathers from any of the species protected under the act.

Migratory bird species that are protected by law depend on the bird family and species included in the four internaAonal treaAes (Canada in 1916; Mexico in 1936; Japan in 1972; Russia in 1976). This list can be found under Title 50 Part 10.13 (10.13 list), which was last updated in 2020 to incorporate current scienAfic informaAon on taxonomy and natural distribuAon. The MBTA applies to almost all avian species that are naAve to California.

A migratory bird species is included on the list if it meets one or more of the following criteria:

1. It occurs in the United States or U.S. territories as the result of natural biological or ecological processes and is currently, or was previously listed as, a species or part of a family protected by one of the four internaAonal treaAes or their amendments.

2. Revised taxonomy results in it being newly split from a species that was previously on the list, and the new species occurs in the United States or U.S. territories as the result of natural biological or ecological processes.

3. New evidence exists for its natural occurrence in the United States or U.S. territories resulAng from natural distribuAonal changes and the species occurs in a protected family.

The Migratory Bird Treaty Reform Act amends the MBTA so that nonnaAve birds or birds that have been introduced by humans to the United States or its territories are excluded from protecAon under the MBTA.

California Fish and Game Code
The California Fish and Game Code is composed of various statutes that aid in the protecAon of biological resources, including the NaAve Plant ProtecAon Act (NPPA) of 1977 and the California Endangered Species Act (CESA) (California Fish and Game Code SecAons 2050-2098). The NPPA designated plants as rare or endangered and prohibits the take of any such plants unless authorized in limited circumstances by the Fish and Game Commission. CESA prohibits public agencies from approving projects that could jeopardize species listed under CESA as endangered or threatened.

In addiAon, the California Fish and Game Code protects naAve and migratory birds including nests and eggs in addiAon to protecAng various mammals (SecAon 4700), amphibians (SecAon 5050), and fish species (SecAon 5515). For this reason, the California Fish and Game Code requires that California Department of Fish and Wildlife be noAfied of lake or streambed alteraAon acAviAes. If acAviAes are determined to adversely affect exisAng fish and wildlife resources by CDFW, a streambed alteraAon agreement must be authorized to ensure the protecAon of biological resources and water quality.

San Joaquin County MulA-Species Habitat ConservaAon and Open Space Plan (SJMSCP) The SJMSCP was adopted on November 14th, 2000, to provide a framework for communiAes within the San Joaquin County to ensure development remains consistent with the following objecAves:

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• Balance the need to conserve Open Space and the need to Convert Open Space to non-Open Space uses while protecAng the region’s agricultural economy;
• Preserve landowner property rights;
• Provide for the long-term management of plant, fish, and wildlife species, especially those that are currently listed, or may be listed in the future, under the ESA or the CESA; • Provide and maintain mulAple-use Open Spaces that contribute to the quality of life of the residents of San Joaquin County and;
• Accommodate a growing populaAon while minimizing costs of Project proponents and society at large.

The MSHCP is a voluntary plan that provides a framework for compensaAon for the ConservaAon of Open Space to non-Open Space uses that will impact fish, plants, and other wildlife species and compensaAon for some impacts to recreaAonal, agricultural, scenic enjoyment, and other beneficial Open Space uses covered by the planning document (SJMSHCP 2000). The SJMSHCP covers all of San Joaquin County except federally owned lands. Overall, the SJMSCP intends to provide “100,841 acres of Preserves based on esAmated ConservaAon acreage of 109,302 acres” (SJMSHCP 2000).

5.4.2 ExisAng CondiAons
The Project is located within the SJMSCP Central Zone, composed primarily of agricultural habitat lands on the floor of the Central Valley including, primarily row and field crops both ditched and unditched. These croplands are bisected by riparian corridors and include, where vegetated, Great Valley riparian forest and Great Valley Oak riparian forest, with patches of Great Valley riparian scrub. AddiAonally, freshwater emergent wetlands and vernal or seasonal wetlands occur in associaAon with several creeks in the Central Zone. Other wetlands found within the Central Zone include numerous ditches and scaLered lakes and ponds. Isolated patches of valley grasslands are scaLered throughout the Central Zone, but the bulk of the SJMSCP Lands in the form of orchards and vineyards, are located within the Central Zone. The majority of exisAng urban development, and proposed new development in the County, exists or will exist within the Central Zone.

The proposed Project area is primarily used for agricultural purposes in unincorporated San Joaquin County. Adjacent developments include those associated with private residences, commercial businesses, and farming along EscalonBellota Road. This is a main thoroughfare connecAng to SR 120, south of the Project. The proposed Project will be limited to exisAng developed roads and thoroughfares in the public right-of-way.

VegetaAon
Due to historic anthropogenic acAviAes on-site and immediately adjacent to the Project, plant communiAes supported on land proposed for the Project Components vary in diversity. The Project supports three (3) land cover types that would be classified as disturbed, developed, and agricultural.

Disturbed
Disturbed areas of the proposed Project include stretches of land along Escalon-Bellota Road, consisAng of roadside shoulders and ditches. These areas range in vegetaAve density from barren to full coverage of monocultures, primarily fescue. Common plant species observed in the disturbed porAons of the proposed Project include those listed in the nonnaAve grassland community.

Developed
The Project supports developed land in the form of exisAng flood control infrastructure and paved driveways associated with adjacent residenAal and commercial development. These areas are maintained to be free of vegetaAon, except where perennial flows within channels coincide with an exisAng plant community. Within this report, areas, where developed land supports overlapping vegetation, are considered to be part of the adjacent plant community.

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Agricultural
An acAve agricultural area lies within and surrounding the FCF and BPS sites. This land cover type supports uniform vegetaAve coverage in the form of row crops of apple trees (Malus domes ca). RouAne disturbance occurs throughout
this area in associaAon with vehicular access on unpaved roads and areas adjacent to the apple orchard, as well as foot traffic throughout the orchard itself. Other plant species observed within the agricultural areas include some aforemenAoned species present within the disturbed porAons of the proposed Project.

Wildlife
The Project provides moderate habitat for wildlife species, especially those adapted to a high degree of anthropogenic disturbances and development.

Fish
No fish were observed at the Project or within the Local Vicinity during the field invesAgaAon. Lone Tree Creek, located centrally to the proposed scope of the Project, is known to support several fish species such as coastal rainbow trout (Oncorhynchus mykiss irideus), Owens speckled dace (Rhinichthys osculus), and Owens sucker (Catostomus fumeiventris). However, these species occur in areas that are less channelized and have not been manipulated or reinforced by dams or culverts, such as the porAon of Lone Tree Creek within the boundaries of the proposed Project.

Further, these species have not been observed in the Project’s Local Vicinity. Fish species that have the potenAal to occur within Local Vicinity include western mosquitofish (Gambusia affinis), and largemouth bass (Micropterus salmoides).

Amphibians
The roadside ditches, flood control channels, and Lone Tree Creek have the potenAal to support local amphibian species adapted to a high degree of human disturbance and condiAons within the Central Valley. These areas vary in water content from the perennial flow within Lone Tree Creek to ephemeral flooding following storm events within the roadside drainages. AddiAonally, most of these areas receive regular flows from urban runoff and irrigaAon from adjacent agricultural and residenAal development. No amphibian species were observed in or within the Local Vicinity.

However, common amphibian species that may occur adjacent to the Project include the American bullfrog (Lithobates catesbeianus) and Sierran tree frog (Pseudacris sierra).

Rep
les
No repAlian species were observed on-site during the field invesAgaAon. The Project provides suitable habitat for local repAle species adapted to rouAne disturbance and development. Common repAlian species that may occur on-site include western fence lizard (Sceloporus occidentalis), pond slider (Trachymys scripta), California king snake (Lampropel
s californiae), and southern alligator lizard (Elgaria mul carinata webbii).

Birds
The Project and Local Vicinity provide suitable foraging and nesAng habitat for resident and migratory bird species adapted to rouAne disturbance and development. Bird species detected during the field invesAgaAon include house finch (Haemorhous mexicanus), white-crowned sparrow (Zonotrichia leucophrys), northern mockingbird (Mimus polyglo<os), mourning dove (Zenaida macroura), great egret (Ardea alba), snowy egret (Egre<a thula), pine siskin (Spinus pinus), European starling (Sturnus vulgaris), house sparrow (Passer domes cus), and savannah sparrow
(Passerculus sandwichensis). Other common bird species that may occur within or adjacent to the Project include Canada goose (Branta canadensis), snow goose (Anser caerulescens), and ruby-crowned kinglet (Regulus calendula).

Mammals
The Project and Local Vicinity provide suitable foraging and cover habitat for mammalian species adapted to rouAne disturbance and development. Mammalian species detected during the field invesAgaAon include American badger (Taxidea taxus), domesAc cat (Felis catus), western gray squirrel (Sciurus griseus), and California ground squirrel (Otospermophilus beecheyi). AddiAonally, domesAc dogs (Canis familiarus) and livestock such as caLle (Bos taurus), horses (Equus caballus), and goats (Capra aegagrus hircus) occur commonly adjacent or in the Local Vicinity. Other common mammal species that may occur within or adjacent to the Project include coyote (Canis latrans), striped

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skunk (Mephi
s mephi
s), and desert coLontail (Sylvilagus audubonii). Further, local bat species adapted to rouAne disturbance have the potenAal to roost in the eucalyptus trees present adjacent to the Project.

The following table is a list of potenAally occurring sensiAve biological resources at the Project and within the Local Vicinity.

TABLE 14: SPECIAL-STATUS ANIMAL & PLANT SPECIES DOCUMENTED WITHIN THE LOCAL VICINITY Species Status DescripAon of Habitat Requirements Observed On-Site
PotenAal to Occur in
Study Area

WILDLIFE SPECIES
Acipenser
medirostris pop. 1
green sturgeonsouthern DPS
Fed: THR
CA: None
Generally found in the San Joaquin and Delta River systems. Spawn primarily in the upper mainstem of the Sacramento River but can also be found spawning in the Yuba and Feather Rivers. Remain in freshwater for a few years, then migrate to saltwater to feed, grow, and mature. Adults enter San Francisco Bay between midFebruary and early May and migrate upstream to spawn.

Congregate in bays and estuaries in Washington, Oregon, and California in the summer and fall, and northern Vancouver Island, B.C. in the winter and spring.

No Presumed Absent. There
is no suitable habitat
present within or
adjacent to the Project.

Ambystoma
californiense pop. 1
California Ager
salamander-central
California DPS
Fed: THR
CA: THR;
WL
Can be found in annual grasslands and oak woodlands with hot, dry summers and cool, rainy winters. Reside underground throughout most of the year in abandoned small mammal
burrows. Require ephemeral pools for breeding.

No Presumed Absent. There
is no suitable habitat
present within or
adjacent to the Project.

Anniella pulchra
northern California
legless lizard
Fed: None
CA: SSC
Occurs in moist, warm, loose soils with plant cover, or sparsely vegetated areas of beach dunes, chaparral, pine-oak woodlands, desert scrub, sandy washes, and stream terraces. Found in leaf liLer under trees and bushes, sunny areas, dunes with stabilized soil, under rocks and logs, and within suburban gardens.

No Low. Suitable foraging
and nesAng habitat
present within and
adjacent to the Project.

However, species have
not been observed in
the general area.

Ardea herodias
great blue heron
Fed: None
CA: None
Fairly common all year throughout most of California, in shallow estuaries and fresh and saline emergent wetlands. Less common along riverine and rocky marine shores, in croplands, pastures, and in mountains about foothills.

No High. Suitable foraging
and nesAng habitat is
present within and
surrounding the Project.

Athene cunicularia
burrowing owl
Fed: None
CA: SSC
Occurs in open, annual, or perennial grasslands, deserts, and scrublands characterized by low-growing vegetaAon. Dependent upon fossorial mammals for burrows, most notably ground squirrels.

No Presumed Absent. There
is no suitable habitat
present within or
adjacent to the Project.

Bombus occidentalis
western bumble bee
Fed: None
CA: CE
Occurs along the Pacific coast and western interior of North America. Dependent on habitat with rich, floral resources throughout nesAng season. Require above and below-ground microsites for overwintering and nesAng including logs, stumps, and abandoned rodent and ground nests and dens.

No Presumed Absent. There
is no suitable habitat
present within or
adjacent to the Project.

Buteo swainsoni
Swainson’s hawk
Fed: None
CA: THR
Typical habitat is open desert, grassland, or cropland containing scaLered, large trees or small groves. Breeds in stands with few trees in juniper-sage flats, riparian areas, and in oak savannah in the Central Valley. Forages in adjacent grassland or suitable grain or alfalfa fields or livestock pastures.

No Presumed Absent. There
is no suitable habitat
present within or
adjacent to the Project.

Desmocerus
californicus
dimorphus
valley elderberry
longhorn beetle
Fed: THR
CA: None
Found only within the valley floor and lower foothill region within riparian and foothill oak communiAes in the Central Valley, of California. Dependent on elderberry as a host plant.

No Presumed Absent. There
is no suitable habitat
present within or
adjacent to the Project.

Elanus leucurus
White-tailed Kite
Fed: None
CA: FP
Locally common yearlong resident of southern California. Occurs in coastal and valley lowlands including open grasslands, agricultural areas, wetlands, and oak woodlands. Nest is placed No Low. There is no suitable
nesAng habitat within

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Entosphenus
tridentatus
pacific lamprey
Fed: None
CA: SSC
Spend most of their lives in freshwater streams before entering the ocean as adults. Young lamprey burrow in muddy boLoms of backwater pools and eddies. Spawn in medium and large-sized, low-gradient rivers and streams.

No Presumed Absent. There
is no suitable habitat
present within or
adjacent to the Project.

Eumops pero
s
californicus
western masAff bat
Fed: None
CA: SSC
Found in a variety of habitats from dry desert washes, flood plains, chaparral, oak woodland, open ponderosa pine forest, grassland, montane meadow, and agricultural areas. Requires rock
outcroppings, cliff faces, tunnels, or tall buildings for roosAng.

No Presumed Absent. There
is no suitable habitat
present within or
adjacent to the Project.

Hysterocarpus
traskii traskii
Sacramento-San
Joaquin tule perch
Fed: None
CA: None
Found in deep waters of low-elevaAon lakes, streams, and estuarine environments. Require cool, well-oxygenated water.

Occupy deep pools with complex vegetaAve cover.

No Presumed Absent. There
is no suitable habitat
present within or
adjacent to the Project.

Lavinia exilicauda
exilicauda
Sacramento hitch
Fed: None
CA: SSC
Inhabits warm, lowland waters, including clear streams, turbid sloughs, lakes, and reservoirs. Generally found in pools or runs among aquaAc vegetaAon associated with streams.

No Presumed Absent. There
is no suitable habitat
present within or
adjacent to the Project.

Mustela frenata
xanthogenys
San Joaquin longtailed weasel
Fed: None
CA: None
Occurs in woodlands, thickets, and open areas such as farmland, usually near a water source. Uses abandoned mammal burrows to den, preferably under stumps or beneath rock piles.

No Presumed Absent. There
is no suitable habitat
present within or
adjacent to the Project.

Mylopharodon
conocephalus
hardhead
Fed: None
CA: SSC
stream habitat with high water clarity. Limited to well-oxygenated streams and reservoir surface waters. Common in small
aggregaAons in pools and runs during the day. Primarily boLomfeed but can feed on driVing material and insects at the water’s surface.

No Presumed Absent. There
is no suitable habitat
present within or
adjacent to the Project.

Oncorhynchus
mykiss irideus pop.
11 steelhead – central
valley DPS
Fed: THR
CA: None
Occurs primarily in tailwaters of dammed rivers, undammed creeks, and four hatchery-supported systems of BaLle Creek, and the Feather, American, and Mokelumne Rivers.

No Presumed Absent. There
is no suitable habitat
present within or
adjacent to the Project.

Oncorhynchus
tshawtyscha pop. 13
Chinook salmoncentral valley
fall/late fall-run ESU
Fed: None
CA: SSC
Spend early life growing and feeding in freshwater streams, estuaries, and associated wetlands. Adults live in coastal oceanic areas. This populaAon includes naturally spawned spring-run individuals, originaAng from the Sacramento River and its tributaries, as well as the Feather River Hatchery program.

No Presumed Absent. There
is no suitable habitat
present within or
adjacent to the Project.

PLANT SPECIES
Legenere limosa
legenere
Fed: None
CA: None
CNPS:
1B.1
Found mainly in vernal pools in Sacramento and Solano counAes but has also been recorded in several other north-central, and baydelta areas. Restricted to seasonal wetland environments below 2,000 feet. Blooms from May to June.

No Presumed Absent. There
is no suitable habitat
present within or
adjacent to the Project.

Tuctoria greenei
Greene’s tuctoria
Fed: END
CA: Rare
CNPS:
1B.1
Grows in vernal pools or grasslands with vernal swale complex land cover. Occurs in open grassland communiAes, on the eastern side of the Sacramento and San Joaquin Valleys.

No Presumed Absent. There
is no suitable habitat
present within or
adjacent to the Project.

Source: ELMT ConsulAng, 2024
Notes:

USFWS
(Fed) - Federal
END- Federal Endangered
THR- Federal Threatened
CE- Candidate for lisAng under
the Federal ESA
California Department of Fish and
Wildlife
END- California Endangered
THR- California Threatened
CE- Candidate for lisAng under the
California ESA
FP- California Fully Protected
SSC- Species of Special Concern
WL- Watch List
CNPS
California Rare Plant Rank
1B Plants Rare, Threatened, or Endangered
in California and Elsewhere
2B Plants Rare, Threatened, or Endangered
in California, But More Common Elsewhere
3 Plants About Which More InformaAon is
Needed – A Review List
4 Plants of Limited DistribuAon – A Watch
List

CNPS Threat Ranks

0.1- Seriously threatened in California

0.2- Moderately threatened in California

0.3- Not very threatened in California

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5.4.3 Project Impacts
a) Have a substanAal adverse effect, either directly or through habitat modificaAons, on any species idenAfied as a candidate, sensiAve, or special status species in local or regional plans, policies, or regulaAons, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service? RESPONSE:

Less than Significant with MiAgaAon Incorporated. According to the CNDDB and CNPS, two (2) special-status plant species; and sixteen (16) special-status wildlife species have been recorded in the Escalon and Avena quadrangles.

No special-status plant or animal species were observed on-site during the habitat assessment. The Project and Local Vicinity have been subject to anthropogenic disturbances, including grading, and vegetaAon removal in recent decades in associaAon with flood control measures, and on-site and adjacent development. These disturbances have reduced the suitability of the habitat to support special-status plants and reduced potenAal foraging and nesAng/denning opportuniAes for wildlife species known to occur in the Project’s Local Vicinity.

Based on habitat requirements for specific special-status plant species and the availability and quality of habitats needed by each species, it was determined that the Project does not provide suitable habitat for any of the special-status plant species known to occur in the area and all are presumed to be absent from the Project. No focused surveys are recommended.

However, natural revegetaAon and the installaAon of ornamental landscaping conAnue to provide suitable habitats for some local wildlife species. Based on habitat requirements for specific species and the availability and quality of on-site habitats, it was determined that the proposed Project and Local Vicinity has a high potenAal to support great blue heron (Ardea alba) and a low potenAal to support northern California legless lizard (Anniela pulchra). The Project does not provide suitable habitat for the remaining special-status species known to occur in the Local Vicinity and all are presumed to be absent. Of these species, the California Ager salamander is both federally and state-listed as threatened, and Swainson’s hawk is state-listed as threatened. None of the other aforemenAoned species are federally or state-listed.

No acAve nests or birds displaying nesAng behavior were observed during the field survey. However, on-site plant communiAes have the potenAal to provide suitable nesAng habitat for year-round and seasonal avian residents, as well as migraAng songbirds that could occur in the area that are adapted to rouAne disturbance. In addiAon, suitable nesAng opportuniAes for raptors are present in the eucalyptus trees that occur throughout adjacent site areas and the disturbed porAons of the Project have the potenAal to provide suitable nesAng opportuniAes for birds that nest on the open ground (e.g., killdeer [Charadrius vociferus]). As a result of potenAal nests at the Project and within the Local Vicinity, a pre-construcAon nesAng bird clearance survey, and ground nesAng raptors pre-construcAon survey shall be conducted prior to Project construcAon pursuant to MiAgaAon Measures MM BIO-01: Pre-construcAon NesAng Bird Clearance Survey, Modified MM BIO-02: Ground NesAng Raptors PreconstrucAon Survey, Modified MM BIO-03: Raptor Nests, and Modified MM BIO-04: AcAve Nests.

As a result, less than significant impacts are anAcipated with the incorporaAon of MiAgaAon Measures. b) Have a substanAal adverse effect on any riparian habitat or other sensiAve natural community idenAfied in local or regional plans, policies, regulaAons, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service?
RESPONSE:

Less than Significant with MiAgaAon Incorporated. The USFWS NWI and the USGS NaAonal Hydrography Dataset were reviewed to determine if any blueline streams or riverine resources have been documented within or immediately surrounding the Project. Based on this review, several riverine resources were idenAfied in the area of the Project by the NWI. The main water feature in the area is Lone Tree Creek, which passes below EscalonBellota Road between Magnolia Avenue to the south and Buerer Road to the north. Several agricultural water conveyance features and water storage basins that occur adjacent to the Project alignment were constructed in the uplands for agricultural purposes and are not considered jurisdicAonal by the Corps, Regional Board, or CDFW.

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Lone Tree Creek supports a riparian plant community. Plant species observed within the riparian community include caLail (Typha sp.), black poplar (Populus nigra), Gooding’s willow (Salix gooddingii), California black oak (Quercus kelloggii), blackberry (Rubus occidentalis), rosewood (Vaquelinia sp.), red gum eucalyptus (Eucalyptus camaldulensis), and AsiaAc jasmine (Trachelospermum asia cum). However, no impacts on this plant community
will occur. Based on the proposed Project plans and limits of disturbance, Project acAviAes will not result in impacts to Corps, Regional Board, or CDFW jurisdicAonal areas and regulatory approvals will not be required.

However, since jack and bore construcAon is proposed underneath Lone Tree Creek, impacts may occur.

Therefore, the Project will implement MiAgaAon Measure Modified MM BIO-05: Jack and Bore ConstrucAon to ensure that a Project biologist is onsite during jack and bore construcAon and that stream crossings are fenced with snake-proof fencing prior to construcAon acAviAes.

As a result, impacts are anAcipated to be less than significant with miAgaAon incorporated.

c) Have a substanAal adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interrupAon, or other means? RESPONSE:

No Impact. As menAoned in Response b) above, several riverine resources were idenAfied in the area of the Project by the NWI. However, no wetland features were idenAfied. No impacts to state or federally-protected wetlands are anAcipated as a result of the Project. No MiAgaAon Measures are needed. d) Interfere substanAally with the movement of any naAve resident or migratory fish or wildlife species or with established naAve resident or migratory wildlife corridors, or impede the use of naAve wildlife nursery sites? RESPONSE:

No Impact. The proposed Project has not been mapped as occurring within any recognized wildlife corridor or linkage. Mokelumne Vernal Wildlife Corridor occurs approximately 6.7 miles to the east and Stanislaus Vernal Wildlife Corridor occurs approximately 3.9 miles to the southeast. AddiAonally, the site occurs in proximity to several open spaces including golf courses, parks, and inacAve agricultural areas which provide movement opportuniAes for local wildlife, especially for avian species.

Due to the nature and scope of the proposed Project and construcAon acAviAes, which will be confined to exisAng paved road right-of-way or heavily disturbed areas, short-term impacts to suitable movement habitat within Lone Tree Creek may occur unAl phase compleAon of each relevant area. As a result, no long-term impacts are expected to occur as a result of Project implementaAon. No impacts are anAcipated; no MiAgaAon Measures are needed.
e) Conflict with any local policies or ordinances protecAng biological resources, such as a tree preservaAon policy or ordinance?
RESPONSE:

No Impact. The Project does not propose to remove trees as a result of Project implementaAon. Therefore, conflicts with any local policies or ordinances protecAng biological resources including tree preservaAon policies or ordinances are not anAcipated as a result of the Project. No impacts are anAcipated; no MiAgaAon Measures are needed.
f) Conflict with the provisions of an adopted Habitat ConservaAon Plan, Natural Community ConservaAon Plan, or other approved local, regional, or state habitat conservaAon plan? RESPONSE:

No Impact. The proposed Project occurs within an area primarily allocated to agricultural pracAces and associated development. Natural vegetaAon supported on-site is limited to narrow strips of primarily invasive and ruderal species which were re-established following the complete removal of vegetaAon in recent decades to accommodate surrounding development and associated flood control infrastructure. NaAve vegetaAon in Local Vicinity occurs in very limited areas, mostly along the banks of Lone Tree Creek, which passes under EscalonBellota Road central to the proposed scope of the Project.

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Due to the scope of the Project and the proposed construc/on ac/vi/es, impacts to na/ve vegeta/on within the Project are expected to be limited to exis/ng disturbed areas, and Project ac/vi/es are not expected to result in long-term or significant impacts to na/ve plant communi/es. As a result, implementa/on of the proposed Project will not result in any impacts to any areas protected by the SJMSCP. No impacts are an/cipated; therefore, no Mi/ga/on Measures are needed.

5.4.4 Mi/ga/on Measures
MM BIO-01: Pre-construc/on Nes/ng Bird Clearance Surveys. If construc/on occurs between February 1st and August 31st, a p Pre-construc/on clearance surveys for nes/ng and protected birds and raptors should be conducted by a qualified biologist, pursuant to CDFW protocol and as delineated below, within fiAeen (15) days and three (3) days in advance of the start of any vegeta/on removal or ground disturbing ac/vi/es and mobiliza/on for the Project. Preconstruc/on surveys are intended to iden/fy ac/ve nests and other evidence of protected species so that construc/on can completely avoid species that are protected under the MBTA and Fish, Game Code and that applicable agency protocol can be implemented so ensure that no nes/ng migratory birds, protected birds or raptors will be disturbed during construc/on.

Survey Report: The biologist conduc/ng the clearance surveys should document a nega/ve survey with a brief leEer report for each survey indica/ng that no impacts to ac/ve avian nests or protected species will occur or sta/ng whether addi/onal protocol surveys or protec/ons are warranted.

No Disturbance Buffer: A no-disturbance buffer or alterna/ve method approved by CDFW will be established by the City’s biologist to protect any species and ac/ve nests. The size of the no-disturbance buffer will be determined by the wildlife biologist and will depend on the level of noise and/or surrounding anthropogenic disturbances, line of sight between the nest and the construc/on ac/vity, type and dura/on of construc/on ac/vity, ambient noise, species habitua/on, and topographical barriers. These factors will be evaluated on a case-by-case basis when developing buffers and distances. Limits of construc/on to avoid an ac/ve nest or species take will be established in the field with flagging, fencing, or other appropriate barriers; and construc/on personnel will be instructed on the sensi/vity of nest areas and species loca/ons so that disturbance, take, possession, and destruc/on of any protected birds or raptors is completely avoided.

Biological Monitor: A biological monitor should be present to delineate the boundaries of the buffer areas and to monitor the ac/ve nest, protec/on in place, or reloca/ons to ensure that protected species and nes/ng behavior is not adversely affected by the construc/on ac/vity. Once the young have fledged and leA the nest, or the nest otherwise becomes inac/ve under natural condi/ons or if the biologist deems that there is no poten/al for impacts on protected species, construc/on ac/vi/es within the buffer area can occur. • The contractor shall inspect construc/on and staging/stockpiles daily at the start and end of each day for wildlife and verify that storage areas are covered and secured. If wildlife is encountered within these areas, the contractor shall immediately contact the city’s biologist to determine and implement appropriate handling and next steps.

Swainson’s Hawk: A qualified biologist shall conduct a SWHA survey within a minimum 1/2-mile radius around the project. Surveys should be conducted according to the following the five-period schedule in accordance with the “Recommended Timing and Methodology for Swainson's Hawk Nes/ng Surveys in California's Central Valley (Swainson's Hawk Tech. Advis. Comm., 5/2000)”:
• January to March 20- One (1) Survey, All Day
• March 20 to April 5- Three (3) Surveys, Sunrise to 1000 / 1600 to Sunset • April 5 to April 20- Three (3) Surveys, Sunrise to 1200 / 1630 to Sunset • April 21 to June 10- Monitoring

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• June 10 to July 30- Three (3) Surveys, Sunrise to 1200 / 1600 to Sunset If an occupied nest is found and may be impacted by project ac:vi:es, the project proponent should consult with CDFW and demonstrate compliance with CESA. CDFW is responsible for ensuring appropriate conserva:on of fish and wildlife resources including threatened, endangered, and/or candidate plant and animal species, pursuant to CESA.

CDFW recommends that a CESA Incidental Take Permit (ITP) be obtained if the project has the poten:al to result in “take” (Fish & G. Code § 86 defines “take” as “hunt, pursue, catch, capture, or kill, or aDempt to hunt, pursue, catch, capture, or kill”) of CESA-listed species, either through construc:on or over the life of the project.

Modified MM BIO-02: Ground Nes:ng Raptors Pre-construc:on Survey- Prior to Project construc:on, the City of Escalon shall retain a qualified biologist to conduct a survey for ground and other nes:ng raptors (in March or April) 30 days and repeated 3 days prior to construc:on ac:vi:es (i.e., grading) in areas containing suitable nes:ng habitat.

Ac:ve raptor nests located within 500 feet of construc:on ac:vity shall be mapped.

Modified MM BIO-03: Raptor Nests- If ac:ve raptor nests are located on or within 500 feet of a construc:on site, a minimum of a 500 feet buffer area shall be established by a qualified biologist and construc:on ac:vi:es shall be prohibited within this buffer zone un:l the end of the nes:ng season (April through August) or un:l the young have fledged. A qualified wildlife biologist shall monitor the nest to determine when the young have fledged and submit weekly reports to CDFW throughout the nes:ng season.

Modified MM BIO-04: Ac:ve Nests- Prior to construc:on ac:vi:es, the City of Escalon in coordina:on with the Project contractor and qualified biologist shall iden:fy trees with ac:ve nests. Ac:ve nests shall only be removed prior to the onset of the nes:ng season (March) or aKer the young have fledged (late August).

Modified MM BIO-05: Jack and Bore Construc:on- At jack and bore loca:ons, bore pits shall be excavated at least 50 feet outside the edge of riparian vegeta:on to avoid impacts. A biological monitor shall be present during staking for jack and bore and during jack and bore construc:on to alert the construc:on crew to the possible presence of any special-status amphibian or rep:le at risk during the crossing. The following measures shall be implemented:
- Construc:on at stream crossings with riparian and/or emergent vegeta:on shall be limited to facilitate detec:on and reduce the poten:al of direct mortality for snakes. The USFWS Sacramento Field office shall be contacted in the event that construc:on needs to occur between October 2 and April 30 to determine if addi:onal measures are necessary to minimize and avoid take.
- Two weeks prior to any ground-disturbing ac:vity at stream crossings with riparian and/or emergent vegeta:on, the bore pit, staging area, and access routes shall be fenced with snake-proof fencing that will be installed under supervision of the city’s biologist. Two days prior to construc:on, a biological monitor with appropriate state and federal permits shall survey the fenced-in areas and determine the presence of snakes. If present, the monitor shall relocate snakes a minimum of 500 feet from construc:on ac:vi:es. During construc:on, the monitor shall be present on-site to ensure that no snakes are in the disturbance area, that all excavated areas are backfilled or covered, and to educate the construc:on personnel as appropriate.

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5.5 CULTURAL RESOURCES
Issues
PotenAally
Significant
Impact
Less than
Significant
Impact with
MiAgaAon
Incorporated
Less than
Significant
Impact No Impact
V. CULTURAL RESOURCES. Would the Project:
a) Cause a substanAal adverse change in the
significance of a historical resource pursuant to
§ 15064.5?
b) Cause a substanAal adverse change in the
significance of an archaeological resource
pursuant to § 15064.5?
c) Disturb any human remains, including those
interred outside of dedicated cemeteries?
The following responses are based on a Cultural Resources Assessment conducted by BCR ConsulAng LLC, dated May 12th, 2023 (See Appendix C). Conclusions and recommendaAons are based on research, a cultural resources records search, a SLF search, and intensive-level pedestrian cultural resources field survey performed on April 28th, 2023.

David Brunzell M.A., R.P.A, acted as Principal InvesAgator, provided project oversight, and authorized the technical report with contribuAons from BCR ConsulAng Staff Archeologist Doug Kazmier, B.A., and BCR ConsulAng Archeological Crew Chief Nicholas Sheptuk, B.A. Central InformaAon Center (CCIC) staff completed the cultural resources records search through its archive at California State University, Stanislaus. Mr. Kazimer completed the field survey.

5.5.1 Regulatory Compliance
California Public Resource Code 15064.5
The following regulaAons are applicable to cultural resources that could be found during construcAon of the Project:

California Code of RegulaAons Title 14 SubsecAon 15064.5 generally defines historically significant cultural resources as any object, building, structure, site, area, place, record, or manuscript which is:
• A resource listed or eligible for lisAng by the State Historical Resources Commission, for lisAng in the California Register of Historical Resources (CRHR)
• A resource included in a local register of historical resources, as defined in secAon 5020.1(k) of the PRC, or idenAfied as significant in a historical resource survey meeAng the requirements secAon 5024.1(g), (listed as historical by local ordinance)
• A resource a Lead Agency determines to be historically significant.

California Code of RegulaAons §15064.5 relaAng to historical resources pertains to environmental changes impacAng any object, building, structure, site, area, place, record, or manuscript associated with:
• Events that have made a significant contribuAon to the broad paLerns of California's history and cultural heritage.
• The lives of persons important in our past.
• The disAncAve characterisAcs of a type, period, region, or method of construcAon, or represents the work of an important creaAve individual, or possesses high arAsAc values. • Resources which have yielded, or may be likely yield, informaAon important in prehistory or history.

ProperAes that are listed in or eligible for lisAng in the NaAonal Register of Historic Places pursuant to SecAon 106 of the NaAonal Historic PreservaAon Act are considered eligible for lisAng in the CRHR and thus are significant historical resources for the purpose of CEQA (PRC SecAon 5024.1(d)(1)).

CEQA SecAon 21083.2
CEQA SecAon 21083.2 requires that the CEQA Lead Agency determine whether a project may have a significant effect on unique archaeological resources. A unique archaeological resource is defined in as an archaeological

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arAfact, object, or site about which it can be clearly demonstrated that there is a high probability that it:
• Contains informaAon needed to answer important scienAfic research quesAons, and there is demonstrable public interest in that informaAon;
• Has a special or parAcular quality, such as being the oldest of its type or the best available example of its type; or
• Is directly associated with a scienAfically recognized important prehistoric or historic event or person.

California Health and Safety Code SecAon 8100
SecAon 8100 of the California Health and Safety Code defines a cemetery as six or more human burials at one locaAon.

Disturbance of NaAve American cemeteries is a felony (Health and Safety Code SecAon 7052). SecAon 7050.5 of the Health and Safety Code requires that if human remains are found during construcAon or excavaAon, the acAviAes be stopped unAl the county coroner can determine if the remains are NaAve American. If the remains are determined to be NaAve American, the coroner must then contact the NAHC, which has jurisdicAon pursuant to PRC SecAon 5097.

5.5.2 ExisAng CondiAons
Natural SeNng
The elevaAon of the Project alignment ranges from approximately 110 to 120 feet AMSL and is located within Township 1 South, Range 9 East on the Escalon, CA USGS 7.5-minute quadrangle. Local geologic units include Late Pleistocene to Early Holocene riverbank formaAon (Wagner et. al 1991). The Project will be constructed in areas that have been subject to previous disturbances for road construcAon and maintenance, canal construcAon and maintenance, and agricultural acAviAes to depths not exceeding approximately 10 feet bgs.

Cultural SeNng
The Project is located within the tradiAonal boundaries of the Northern Valley Yokuts, whose regional seLlement began between 9,000- 11,500 years before the present. This prehistoric populaAon depended heavily on the San Joaquin River and its connecAng sloughs and rivers for sustenance and transportaAon. Due to numerous perennial water sources, the Northern Valley Yokuts were able to pursue a sedentary lifestyle in an otherwise arid climate. The first Europeans to establish contact with the Yokuts were Spanish troops. Prehistorically, such sedenAsm oVen coincides with a village-style residenAal model in which residenAal bases remain the same or seasonal, while specialized procurement parAes are deployed to more remote areas to collect specialized resources (Binford 1980, Thomas 1983). This village model has been locally supported by early ethnographers, who considered Yokuts unique in California for forming "true tribes" and for developing an unparalleled array of dialects (Kroeber 1925:474).

The Mexican era (1821-1848) saw liLle notable cultural exchange between Mexicans and Yokuts, although an 1833 malaria epidemic devastated the local naAve populaAon (Wallace 1978:460). The American era, punctuated by California’s annexaAon into the United States in 1848, resulted in overwhelming Anglo seLlement which disrupted local Yokut influence. Mining and ranching represented the early historical focus of the San Joaquin Valley, although abundant natural water, a mild climate, and arable land soon led to the successful development of agriculture.

5.5.3 Project Impacts
a) Cause a substanAal adverse change in the significance of a historical resource pursuant to § 15064.5? RESPONSE:

Less than Significant with MiAgaAon Incorporated. During the Project’s field survey, notable past disturbances related to the construcAon and maintenance of roads, canals, and infrastructure, as well as agricultural acAviAes were documented. Surface condiAons observed included sediments, sandy silt, and vegetaAon which was dominated by seasonal grasses affording approximately 30 percent surface visibility within exisAng unpaved areas where the Project will be implemented. The field survey conducted by Mr. Kazmier, BCR Staff Archaeologist, on May 12th, 2023, consisted of an inspecAon of the enAre Project using 15-meter transect intervals on either side of the proposed water main alignment and the BPS, and FCF sites, for both prehistoric and historic-period cultural resources. There were no cultural resources (including pre-historic or historic archeological or historic architectural resources) idenAfied during the field survey.

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During preliminary research, results from the CCIC revealed 16 cultural resources studies have taken place resulAng in 16 cultural resources recorded within a one-half-mile radius of the Project, see Table 15: Cultural Resources Within One-Half Mile of the Project below.

TABLE 15: CULTURAL RESOURCES WITHIN ONE-HALF MILE OF THE PROJECT USGS 7.5 Min
Quad
Primary No. Resource DescripAon Within Project Studies Within OneHalf Mile Escalon and
Avena,
California
(1968)
P-39-0015 Tidewater Southern Railway 0.5-mile SJ-1543, 2544, 3358, 3366, 3367, 3380,
3654, 4193*, 4203,
4204, 4565, 5170,
6625, 6975, 9021,
9023
P-39-0112 Burlington Northern Santa Fe Railroad 0.35-mile P-39-0439 Historic-Period Electrical DistribuAon Lines 0.2-mile P-39-0441 Calizo’s Deli, Escalon Auto Parts 0.5-mile
P-39-0442 Bud’s Frosty 0.5-mile
P-39-0443 Historic-period Building 0.5-mile
P-39-0444 Escalon RecreaAonal Vehicle Sales 0.5-mile
P-39-0445 Santa Fe Railroad 0.35-mile
P-39-0447 No InformaAon Available --
P-39-0452 Farmer Bill’s 0.4-mile
P-39-4172 Axel Larson Residence 0.4-mile
P-39-4173 Escalon Motel 0.4-mile
P-39-4174 Historic-period Single-family Residence 0.4-mile P-39-4245 Structure, Other 0.35-mile
P-39-5061 Dent School 0.4-mile
P-39-5062 Escalon Union High School 0.1-mile
Source: BCR ConsulAng, 2023
Notes: * Occurred Within the Project.

Since no cultural resources including historic or prehistoric archaeological sites and historic architectural resources were found during research and the field survey for the Project, no addiAonal cultural resources work, or monitoring is recommended pursuant to CEQA Guidelines § 15064.5. The possibility for substanAal adverse changes in the significance of a historical resource pursuant to SecAon 15064.5 is considered low; however, impacts are not considered less than significant due to proposed depths of excavaAon and trenching for the water main, and subterranean porAons of the BPS, tank and FCF that may disturb naAve soils below exisAng levels of disturbance associated with exisAng development paLerns. This was documented as a potenAally significant impact of the SCSWSP and in the Cultural Resources Assessment for this Project. Therefore, crew training for Prehistoric or historic cultural materials that may be encountered during ground-disturbing acAviAes is recommended, and miAgaAon measures Modified MM CUL-01: (Ground InspecAon) Pre-ConstrucAon Crew Training and Modified MM CUL-02: Discovery of Buried Cultural Resources have been included to require that a qualified cultural resources professional be hired by the City to conduct crew training prior to start of construcAon. ImplementaAon of Modified MM CUL-01: (Ground InspecAon) Pre-ConstrucAon Crew Training and Modified MM CUL-02: Discovery of Buried Cultural Resources will result in less than significant impacts with miAgaAon for buried cultural resources.
b) Cause a substanAal adverse change in the significance of an archaeological resource pursuant to § 15064.5? RESPONSE:

Less than Significant with MiAgaAon Incorporated. See SecAon 5.5.3, Response a). According to the Cultural Resources Assessment, the Project Components are underlain with Pleistocene and Pliocene loosely consolidated deposits. While the records search and field survey did not idenAfy cultural resources within the locaAon of each Project Component, ground-disturbing acAviAes proposed by the Project have the potenAal to discover buried deposits not observed on the surface.

Project construcAon will require ground disturbance below the depths of previous disturbance. Therefore, MiAgaAon Measures Modified MM CUL-01: (Ground InspecAon) Pre-ConstrucAon Crew Training, Modified MM CUL-02: Discovery of Buried Cultural Resources, MM CUL-03: Cultural Resources Treatment and DisposiAon, will

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be implemented during construcAon acAviAes. The MiAgaAon Measures listed in SecAon 5.5.4 below will ensure that construcAon crew members are informed of standard procedures expected from the City of Escalon in the event construcAon results in the discovery of prehistoric or historic cultural deposits.

As a result, the proposed Project will have less than significant direct impacts on archeological resources pursuant to Public Resources SecAon 15064.5.

c) Disturb any human remains, including those interred outside of dedicated cemeteries? RESPONSE:

Less than Significant with MiAgaAon Incorporated. See SecAon 5.5.3, Response a) and b). According to the records search and review of aerial photos, the previous land uses for the Project area were for agriculture, not a cemetery. Therefore, the discovery of human remains during Project construcAon is unlikely, but not impossible.

ConstrucAon acAviAes will require ground disturbances beyond depths of previous disturbances. Therefore, the implementaAon of Project Components including the FCF, BPS, and subterranean storage tank has the potenAal to unearth human remains that were unknown to occur within the Project and Local Vicinity.

As a result of the potenAal for discovery, MiAgaAon Measure MM CUL-04: Discovery of Human Remains and Modified MM CUL-02: Discovery of Buried Cultural Resources ensures appropriate procedures are taken in the unlikely event that human remains are discovered. The following MiAgaAon Measure results in Project impacts being less than significant.

5.5.4 MiAgaAon Measures
Modified MM CUL-01: (Ground InspecAon) Pre-ConstrucAon Crew Training: Prior to start of construcAon, the City of Escalon shall hire a qualified archaeologist and tribal monitor to conduct pre-construcAon tailgate training for the construcAon crew. The training can be videotaped for crew added later during construcAon. Training shall be documented with a sign-in sheet and wriLen materials including photos of cultural materials as follows:
• historic arAfacts such as glass boLles and fragments, cans, nails, ceramic and poLery fragments, and other metal objects;
• historic structural or building foundaAons, walkways, cisterns, pipes, privies, and other structural elements; • prehistoric flaked-stone arAfacts and debitage (waste material), consisAng of obsidian, basalt, and or cryptocrystalline silicates;
• groundstone arAfacts, including mortars, pestles, and grinding slabs; • dark, greasy soil that may be associated with charcoal, ash, bone, shell, flaked stone, groundstone, and fireaffected rocks.

Modified MM CUL-02: Discovery of Buried Cultural Resources: Throughout Project construcAon, the contractor shall maintain records of field crew training per Modified MM CUL-01: (Ground InspecAon) Pre-ConstrucAon Crew Training and a cultural resources monitor shall be present at the site to document any cultural resources encountered during construcAon with photos, georeferencing, and maps. If field personnel encounter buried cultural materials, work in the immediate vicinity of the find should cease within 50 feet of the resources and the City and a qualified archaeologist should be contacted immediately to assess the significance of the find. The qualified archaeologist shall have the authority to stop or divert construcAon and excavaAon as necessary. If the qualified archaeologist finds that any cultural resources present meet eligibility requirements for lisAng on the California Register or the NaAonal Register, plans for the treatment, evaluaAon, and miAgaAon of impacts to the find will need to be developed.

MM CUL-03: Cultural Resources Treatment and DisposiAon: Immediately upon discovery of buried resources encountered during construcAon, the contractor shall cease work in the immediate vicinity of the find pursuant to Modified MM CUL-02: Discovery of Buried Cultural Resources and allow the qualified archaeologist to determine: a) if any cultural resources are significant or meet eligibility requirements for lisAng on the California Register or the NaAonal Register; b) to idenAfy appropriate disposiAon measures for proper treatment through protecAon in place

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MM CUL-04: Discovery of Human Remains: If human remains are encountered during construcAon, the contractor shall noAfy the County Coroner of the find immediately. If the remains are determined to be prehistoric, the coroner will noAfy the NAHC, which will determine and noAfy a Most Likely Descendant (MLD). With the permission of the landowner or his/her authorized representaAve, the MLD may inspect the site of the discovery. The MLD shall complete the inspecAon within 48 hours of noAficaAon by the NAHC.

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5.6 ENERGY
Issues
PotenAally
Significant Impact
Less than
Significant Impact
with MiAgaAon
Incorporated
Less than
Significant Impact No Impact
VI. ENERGY. Would the Project:
a) Result in potenAally significant
environmental impact due to
wasteful, inefficient, or
unnecessary consumpAon of
energy resources, during Project
construcAon or operaAon?
b) Conflict with or obstruct a state or
local plan for renewable energy or
energy efficiency?

5.6.1 Regulatory Compliance
California Energy Commission (CEC)
The CEC is a planning and policy agency responsible for forecasAng future energy needs, promoAng energy efficiency, maintaining energy data, developing energy technology, promoAng renewable energies, and planning for energy emergencies throughout California. The Title 24 Building Energy Efficiency Standards were developed by the CEC and are updated periodically (SJ 2035 GP DEIR).

Green Building Standards Code (CalGreen)
CalGreen was first adopted in 2009 and has been updated every three years since. CalGreen pertains to sustainable pracAces for residenAal and commercial construcAon projects in California. Pursuant to CalGreen, construcAon projects must meet a mandatory set of minimum requirements and extensive voluntary measures. The Code covers planning and design, energy efficiency, water efficiency and conservaAon, materials conservaAon and resource efficiency, and indoor environmental quality.

5.6.2 ExisAng CondiAons
Electricity within San Joaquin County is provided by PG&E, Modesto IrrigaAon District (MID), Lodi Electric UAlity, and Port of Stockton. The City of Escalon receives electrical services primarily from PG&E. Annually, PG&E provides approximately 86,000 GWh of electricity to over 25 million consumers within Northern and Central California (SJ 2035 GP DEIR). Electricity is provided to residenAal, commercial, and industrial accounts across the County.

SSJID used a total of 4,178,374 kilowaL hours (kWh) of energy during 2020 operaAons. Efforts have been made to reduce energy consumpAon within the District’s systems, including a solar farm at the Nick C. DeGroot Wastewater Treatment Plant. The solar farm consists of 7,000 photovoltaic panels installed on 14 acres of land to offset operaAonal energy uses and costs.

5.6.3 Project Impacts
a) Result in potenAally significant environmental impact due to wasteful, inefficient, or unnecessary consumpAon of energy resources, during Project construcAon or operaAon? RESPONSE:

Less than Significant Impact. The Project is a 19,500 LF water pipeline that will connect to an FCF, BPS, and storage tank with a wet well. The Project anAcipates connecAng to nearby power poles for energy use at the BPS and proposed FCF, throughout the lifeAme of the Project via coordinaAon with PG&E. At the BPS, PG&E will provide service to the proposed pump staAon site with the implementaAon of a new meter that will feed into a new 480V distribuAon panelboard via an automaAc transfer switch.

The Project will install infrastructure that will implement regional groundwater sustainability by reducing well water use. The Project does not anAcipate significant long-term use of energy or wasteful, inefficient, or unnecessary consumpAon of energy resources, since the BPS will not be uAlized to its full capacity during longPage 240 of 440

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term operaAon, pumps were assumed to uAlize approximately 1,006,031 kWh per year5. In addiAon, SSJID has proposed to incorporate solar into overall operaAons; therefore, energy consumpAon from the proposed Project will be offset with solar power provided by SSJID’s system. The Project’s proposed scale and nature prevent the Project from substanAal energy consumpAon beyond what has already been approved and considered by the City’s General Plan and Water Master Plan.

A diesel backup power generator will be provided to power the pumps at the BPS in the event of power loss from the uAlity provider. The modeling has been performed to assume the 125-kW generator will provide power to two of the 50 HP pumps, and HVAC system, in addiAon to instrumentaAon and lighAng loads. The San Joaquin Valley Air PolluAon Control District requires that any diesel-fired generator with break horsepower exceeding

37.3 kW (50 HP) be provided to comply with EPA Tier 4 RegulaAons. Since the generator is capable of providing power for up to 72 hours and will provide diesel-powered electricity exceeding 37.3 kW (50 HP), the 125kW generator will comply with EPA Tier 4 regulaAons.

Similarly at the FCF, a new 120/ 240V panelboard will be installed in an enclosed electrical building, which will be powered by PG&E throughout the lifeAme of the Project. A 10kW propane backup generator will be provided to power the flow control equipment and the PLC. The generator is significantly larger than the load associated with the Project, which is not anAcipated to exceed 1 kW (1.34 HP).

During Project construcAon, substanAal uses of energy are not anAcipated beyond what was previously idenAfied in the EIR for the SCSWSP. A generator might be uAlized intermiLently during construcAon acAviAes; however, Project equipment will primarily be diesel-powered. In addiAon, Project Components are not located near electrical infrastructure or hookups. As a result, energy resources will not be heavily uAlized during Project construcAon due to the lack of availability.

The Project is included in the planned buildout of the City of Escalon’s Water Master Plan and General Plan EIR and will not result in changes to land use or addiAonal GHG emissions. The Project is not anAcipated to result in significant energy consumpAon beyond what has already been idenAfied in the General Plan EIR and less than significant impacts are anAcipated. The Project is part of a planned phased construcAon from the City’s Water Master Plan, which is intended to efficiently accommodate approved future growth for the City of Escalon while maintaining consistent and reliable services to their consumer base.

For the reasons above, the proposed Project is anAcipated to have less than significant impacts on energy resources during Project construcAon or operaAon. No MiAgaAon Measures are needed. b) Conflict with or obstruct a state or local plan for renewable energy or energy efficiency? RESPONSE:

Less than Significant Impact. See SecAon 5.6.3, Response a). Long-term operaAonal energy use is required for the proposed Project and is anAcipated to total approximately 1,006,031 kWh per year. Project plans indicate electricity, diesel, and propane will be used for the conAnuous operaAon of the Project for water delivery via pumps and emergency generators. The Project is part of a planned buildout of the General Plan within the City of Escalon and is required for annexaAons, future water system extensions, and buildout of future land use shown in the City of Escalon’s approved General Plan Land Use Map. The Project has been approved in concept within the SCSWSP to enhance the City’s water delivery system to serve growth which has already been approved. The Project will replace groundwater extracAon and will promote sustainability plans for water resources. The Project 5 During the first year of operaAon, it is assumed that the 25-HP pump will operate 24/7 or ~8,760 hours per year and the 50-HP pumps would not be in operaAon. During final buildout, it is assumed that the 25-HP pump will operate ¼ of the Ame or ~1,095 hours per year and each of the 50- HP pumps will operate 1/3 of the Ame or approximately 2,920 hours per year for each 50-HP pump. Therefore, the operaAonal hours at final buildout are anAcipated to be worst-case and were uAlized in the analysis. Energy use calculaAons for the pumps include: 1-HP=0.75 kW. 25-HP pump = 18.75 kW x 1,095 hours/year = 20,531 kWh/year. 3x50-HP pumps = 150-HP = 112.5 kW x (3x2,920 hours/year) = 985,500 kWh/yr. Total of ~1,006,031 kWh/year of electricity used by the proposed pumps. OperaAon of project is that of the electric pumps and generators only, no natural gas anAcipated to be used (Ganddini, 2023).

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will facilitate the implementaAon of the City’s water systems pursuant to previously approved plans with increased capabiliAes to beLer serve water customers.

For these reasons, implementaAon of the Project is not anAcipated to conflict with or obstruct a state or local plan for renewable energy or energy efficiency. No MiAgaAon Measures are necessary.

5.6.4 MiAgaAon Measures
No MiAgaAon Measures are needed.

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5.7 GEOLOGY AND SOILS
Issues
PotenAally Significant
Impact
Less than
Significant Impact
with MiAgaAon
Incorporated
Less than
Significant Impact No Impact
VII. GEOLOGY AND SOILS. Would the Project:
a) Directly or indirectly cause
potenAal substanAal adverse
effects, including the risk of
loss, injury, or death involving:
i) Rupture of a known
earthquake fault, as
delineated on the most recent
Alquist-Priolo Earthquake
Fault Zoning Map, issued by
the State Geologist for the
area or based on other
substanAal evidence of a
known fault? Refer to Division
of Mines and Geology Special
PublicaAon 42.
ii) Strong seismic ground
shaking?
iii) Seismic-related ground
failure, including
liquefacAon?
iv) Landslides?
b) Result in substanAal soil
erosion or the loss of topsoil?
c) Be located on a geologic unit
or soil that is unstable, or that
would become unstable as a
result of the Project, and
potenAally result in on- or offsite landslide, lateral spreading, subsidence,
liquefacAon or collapse?
d) Be located on expansive soil,
as defined in Table 18-1-B of
the Uniform Building Code
(1994), creaAng substanAal
direct or indirect risks to life or
property?
e) Have soils incapable of
adequately supporAng the use
of sepAc tanks or alternaAve
wastewater disposal systems
where sewers are not available
for the disposal of
wastewater?
f) Directly or indirectly destroy a
unique paleontological
resource or site or unique
geologic feature?

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5.7.1 Regulatory Compliance
Alquist-Priolo Earthquake Fault Zoning Act
California’s Alquist-Priolo Earthquake Fault Zoning Act (Alquist-Priolo Act) (PRC SecAon 2621 et seq.), originally enacted in 1972 as the Alquist-Priolo Special Studies Zones Act and renamed in 1994, is intended to reduce the risk to life and property from surface fault rupture during earthquakes. The Alquist-Priolo Act prohibits the locaAon of most types of structures intended for human occupancy across the traces of acAve faults and strictly regulates construcAon in the corridors along acAve faults (earthquake fault zones). It also defines criteria for idenAfying acAve faults and establishes a process for reviewing building proposals in and adjacent to earthquake fault zones.

Under the Alquist-Priolo Earthquake Fault Zoning Act, special safety requirements apply to faults that are considered acAve by the State Geologist, because of repeated acAvity. Faults are mapped according to fault surface trace locaAons with a surrounding buffer delineaAng the Earthquake Fault Zone where there is elevated potenAal for ground rupture and structural damage. Surface traces of acAve faults could pose a risk to structures and are in regulated areas if they are acAve. “A fault is considered well defined if its trace can be clearly idenAfied by a trained geologist at the ground surface or in the shallow subsurface, using standard professional techniques, criteria, and judgment.

California Building Code (CBC)
The CBC establishes regulaAons for building design and safety related to seismicity, materials, and foundaAons which are implemented through the standard applicaAon of plan check and inspecAons for grading and construcAon.

California is seismically acAve, and it is likely that the site would experience earthquake ground shaking within the life of the Project. Strong earthquake shaking is a hazard shared throughout the region and the direct risks posed to structures by ground shaking are miAgated through the structural design provisions of the CBC. The seismic design provisions of the 2010 CBC include a methodology by which sites are classified as A through F in order to quanAfy site-specific ground-shaking effects.

City of Escalon Standard SpecificaAons
The City of Escalon has published Standard SpecificaAons that are compliant with the City’s standard review and approval process for various Projects. These specificaAons outline the City’s procedures applicable to the proposed Project including inspecAons, dust and dirt control, erosion and sedimentaAon control, trench excavaAon, stability of pipeline beds, etc.

CEQA: Paleontological Resources
CEQA provides guidance relaAve to significant impacts on paleontological resources, indicaAng that a project will have a significant impact on paleontological resources if it disturbs or destroys a unique paleontological resource or site or unique geologic feature. SecAon 5097.5 of the California Public Resources Code specifies that any unauthorized removal of paleontological remains is a misdemeanor. Further, California Penal Code SecAon 622.5 sets penalAes for damage or removal of paleontological resources. CEQA documentaAon prepared for projects would be required to analyze paleontological resources as a condiAon of the CEQA process to disclose potenAally significant impacts and miAgaAon measures. Please note that as of January 2018, paleontological resources are considered a geological rather than cultural category in the CEQA checklist.

5.7.2 ExisAng CondiAons
The Project is within the southeastern corner of San Joaquin County, which extends across the Central Valley. The County is generally flat and since the Project is on the valley floor, elevaAons at the Project range from 100 to 200 feet ASML. Land within the County is underlain with alluvial deposits that originate from “eroded silica-based volcanic and graniAc materials from the Sierra Nevada” and “shale/clay and quartzite marine deposits” from Coastal Ranges (SJ 2035 GP DEIR).

The Project Local Vicinity are not over or adjacent to a mapped fault line; the closest fault lines are east and west of the Project. Approximately 21 miles to the west from the Ae-in with SSJID transmission main is the Vernals Fault, which traverses through Stockton City Limits to the base of the San Joaquin River NaAonal Wildlife Refuge.

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5.7.3 Project Impacts
The responses within this secAon were based on a previously published IS/MND within the City of Escalon with technical reports outlining the baseline condiAons of the soil composiAon. Specifically, the IS/MND uAlized during the preparaAon of these responses was drawn from the following sources:
• AdministraAve Review DraV IS/MND for the Irwin Village Senior ResidenAal Project, Escalon, CA, prepared by BaseCamp Environmental Inc., November 2021. LocaAon: approximately 1.0 mile southwest of the proposed BPS site.
• Cultural Resources Assessment, City of Escalon ConnecAon to Nick DeGroot Water Treatment Plant, Escalon, San Joaquin County, California, prepared by BCR ConsulAng LLC, (May 12th, 2023), Project No. ARD2301 a) Directly or indirectly cause potenAal substanAal adverse effects, including the risk of loss, injury, or death involving:
i. Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map, issued by the State Geologist for the area or based on other substanAal evidence of a known fault? Refer to Division of Mines and Geology Special PublicaAon 42.

RESPONSE:

No Impact. As menAoned above, the Project is not in close proximity to known fault lines and therefore, is not within the boundaries of an Earthquake Fault Zone for fault rupture hazard as defined by the AlquistPriolo Earthquake Zoning Act of 1972. This conclusion was verified uAlizing the CA DOC’s Geological Survey Website (Reference CGS Earthquake Zones (ca.gov)). The CA DOC defines Alquist-Priolo earthquake fault zones as “regulatory zones surrounding the surface traces of acAve faults in California” with an increased potenAal for surface rupture. Since the Act has come into effect, laws prohibit structures meant for human occupancy to be built across traces of acAve faults. Structures built within these areas should maintain a minimum of 50 feet from the fault line.

Since the Project is not within mapped fault zones or within the confines of acAve fault traces or their associated Alquist- Priolo Fault Zones, it is unlikely for ground displacement to occur outside of these areas.

For these reasons, no impact is anAcipated in associaAon with fault rupture. This includes the risk of loss, injury, or death, which is not anAcipated to occur at the Project or other properAes in the Local Vicinity.

Therefore, no MiAgaAon Measures are needed.
ii. Strong seismic ground shaking?
RESPONSE:

Less than Significant with MiAgaAon Incorporated. All of California is subject to potenAal seismic acAvity, and areas within proximity of fault zones are subject to regulaAons minimizing the risk associated with ground shaking. The Project is subject to ground shaking due to its geographic locaAon and the state’s overall suscepAbility to earthquakes and there is nothing unique about the locaAon of the Project that would make it more suscepAble to strong seismic ground shaking. The severity of shaking is dependent on proximity to acAve faults and the esAmated maximum ground acceleraAon of the fault. The City of Escalon General Plan EIR states that “according to the California Division of Mines and Geology BulleAn 198, “Urban Geology Master Plan for California,” the Escalon area is shown to be in a low severity zone with a probable maximum intensity of VI or VII on the Modified Mercalli Scale of 1931” (City of Escalon GP EIR 2035).

While the potenAal for seismic ground shaking is low due to the Project proximity to the nearest fault zone being more than 21 miles away, the proposed Project will sAll implement BMPs during Project construcAon pursuant to the City’s Standard SpecificaAons 3.02 U
li
es, CBC and Cal-OSHA standards for workers safety,
which will reduce risks associated with seismic ground shaking at the various Project Components. In addiAon, the Project will implement previously approved MiAgaAon Measures from the SCSWSP EIR (Modified MM GEO-01: Seismic Design Criteria and Modified MM GEO-02: Geotechnical Design Criteria) to ensure that recommendaAons from the geotechnical engineer as well as City and San Joaquin County’s engineering design policies are incorporated for minimal impact associated with strong seismic ground shaking.

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The standard applicaAon of the local agency plan check and inspecAon processes will result in, less than significant impacts as a result of strong seismic ground shaking with the implementaAon of MiAgaAon Measures.
iii. Seismic-related ground failure, including liquefacAon? RESPONSE:

Less than Significant Impact. Reference Response 5.7.3, a) i) and ii). LiquefacAon, as defined by the CA DOC, is “the transformaAon of granular materials from a solid state into a liquefied state as a consequence of increased pore-water pressure” (CA DOC 2023). AddiAonally, liquefacAon is anAcipated in areas where the groundwater is less than 30 feet from the surface. Subsurface informaAon within the City’s General Plan Update Background Report published in 2004, indicated that subsurface soil types at the Project or in the Local Vicinity are not conducive to liquefacAon (Escalon DraV GPU 2004).

The soils idenAfied within this region consist of Honcut sandy loam and VeriAs fine sandy loam with 0 to 2 percent slopes (BaseCamp Environmental 2021). AddiAonally, according to the CA DOC CompilaAon of Quaternary Surficial Deposits, the Project is underlain with primarily Alluvial Fan Deposits (Qf) (See hLps://maps.conservaAon.ca.gov/cgs/QSD/). These deposits consist of gravel, sand, and small pieces of sediment like silt, which result as a product of flowing water interacAng with hills or mountains daAng back to the Pleistocene-age (NaAonal Geographic 2022).

According to the CA Geologic Survey, the City of Escalon is not within areas idenAfied as having high suscepAbility to liquefacAon or landslide potenAal (City of Escalon General Plan 2035) and can be verified using the Earthquake Zones of Required InvesAgaAon, provided by the CA DOC (See hLps://maps.conservaAon.ca.gov/cgs/EQZApp/app/).

For these reasons, the proposed Project is not highly suscepAble to seismic-related ground failure, including liquefacAon. Impacts are anAcipated to be less than significant, and no MiAgaAon Measures are needed.

iv. Landslides?
RESPONSE:

Less than Significant Impact. See Response 5.7.3, a) iii). The Project is on relaAvely flat land with surrounding land uses primarily designated for agricultural uses. Mountain ranges or hills are not close to the Project. The closest point of elevaAon to the Project is located east near the Goodwin Dam RecreaAon Area, approximately 27 miles east from the Ae-in pit with the SSJID transmission line.

According to the CA DOC, the City of Escalon, including the Local Vicinity surrounding and including the Project, does not have a high suscepAbility for landslides (DOC, CGS InformaAon Warehouse: Landslide Map).

During construcAon, excavaAon may involve steep trench slopes and deeper excavaAons for the reservoir, FCF, tank, and water main as well as jack and bore pits. These slopes will be 6 feet or deeper and are required to be temporarily reinforced through means such as shoring pursuant to Cal-OSHA standards and the California Division of Industrial Safety and City of Escalon’s Standard Specifica ons for 3.04- Trench
Excava
ons, 3.03- Protec
on, and 1.04 Quality Assurance. Upon compleAon of construcAon, excavated areas will be backfilled, and surfaces will be stabilized pursuant to City of Escalon’s Engineering Standards with the standard applicaAon of plan check and inspecAons. Therefore, there will be no long-term impacts related to unstable soils.

ImplementaAon of the City of Escalon Standard SpecificaAons will miAgate construcAon impacts to less than significant levels. There will be no long-term impacts. No MiAgaAon Measures are needed.

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Less than Significant with MiAgaAon Incorporated. See Response 5.7.3, a) i) through iii). Project construcAon will require the disturbance of stable ground surfaces for open-cut trenching, jack, and bore, and deeper excavaAons for the proposed subterranean components of the tank, BPS, and FCF. Therefore, construcAon will temporarily disturb stable ground surface leaving soils suscepAble to erosion during acAve construcAon. Jack and bore, will be implemented beneath the Lone Tree Creek crossing, along the Project alignment, which is located approximately 250 feet south of Lone Tree Road, and will also require deeper and more extensive excavaAon for entry and exit pits making the soils in this area temporarily suscepAble to erosion. AddiAonally, during construcAon, other processes such as truck traffic, equipment access, and materials hauling may also temporarily disrupt topsoil resulAng in dust and erosion. Therefore, soil erosion and potenAal loss of some topsoil may occur during construcAon, especially during high winds and rains. The City’s Standard SpecificaAons within Sec on
01500: Construc
on Facili
es and Temporary Controls, which will ensure erosion and sedimentaAon control via storm runoff containment, temporary drainage structures, and prevent windblown dust or dirt; and previously approved MiAgaAon Measures Modified MM HYDRO-01: Stream Crossings and Modified MM HYDRO-03: Erosion Control will prevent destabilizaAon of the streambed at Lone Tree Creek Crossing and ensure erosion control measures are in place at excavated, graded, and other disturbed areas to prevent soil erosion.

Therefore, substanAal erosion or the loss of topsoil will be miAgated to less than significant levels with the incorporaAon of the City’s standard specificaAons. As a result, less than significant impacts are anAcipated with the implementaAon of MiAgaAon Measures.
c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the Project, and potenAally result in on- or off-site landslide, lateral spreading, subsidence, liquefacAon or collapse? RESPONSE:

Less Than Significant Impact. See Response 5.7.3, a) through b). At the Project, the geologic composiAon is comprised of alluvial fan deposits daAng back to the Pleistocene-Holocene age, between 2,580,000 to 11,700 years ago. The Project and surrounding areas are flat and level and will be subject to disturbance during earthwork that is consistent with engineering standards for safety. The City Engineer and inspectors will verify, pursuant to City’s Standard Specifica
ons Sec
on 01500: Construc
on Facili
es and Temporary Controls will be implemented
by the Project contractor to the saAsfacAon of the City Engineer and verified during plan check and field inspecAons. The City’s Engineer has the right to monitor and inspect Project construcAon regularly throughout the duraAon of construcAon to ensure erosion control measures and temporary drainage structures are implemented pursuant to the City’s Standard SpecificaAons Sec on 01500: Construc
on Facili
es and Temporary
Controls.

For these reasons, less than significant impact is anAcipated from geologic units or soils that are unstable resulAng in potenAal on- or off-site landslide, lateral spreading, subsidence, liquefacAon or collapse. Therefore, no MiAgaAon Measures are needed.

d) Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creaAng substanAal direct or indirect risks to life or property?
RESPONSE:

Less Than Significant Impact. See Responses 5.7.3, a) through c). Expansive soils undergo shrinking and swelling with changes in moisture. These characterisAcs are aLributed to higher clay content within the soil. As expansive soils dry, the clay causes soils to shrink; when the moisture is reintroduced, the soils swell up. Developing infrastructure on low expansive potenAal is preferred since the soil will not change its volume depending on the moisture and will therefore provide a stable foundaAon that is more staAc. The Project is underlain with Pleistoncene-aged alluvial deposits from the Modesto FormaAon and Riverbank FormaAon (BCR ConsulAng 2023). However, alluvial soils tend to not be expansive soils and contain granular and less clayey characterisAcs.

To maintain low expansive potenAal, the City of Escalon will implement Standard Specifica on Sec
on 01400:

Quality Control and Tes
ng during plan check, construcAon and inspecAons. This will ensure that the appropriate

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methods of trenching, pipe bedding and recommended backfill material with low shrink-swell properAes are implemented with the Project. In addiAon, the plan check and review process with the City of Escalon will result in the proposed Project-related infrastructure being designed and built to comply with the applicable soil expansion index found within the Uniform Building Code.

For these reasons above, the Project will not increase the potenAal for direct and indirect risks to life and property due to expansive soils, nor will the Project increase exposure to expansive soil hazards. Therefore, less than significant impacts are anAcipated, and no MiAgaAon Measures are needed.

e) Have soils incapable of adequately supporAng the use of sepAc tanks or alternaAve wastewater disposal systems where sewers are not available for the disposal of wastewater? RESPONSE:

No Impact. SepAc tanks or alternaAve wastewater disposal systems are not proposed with the Project. There are no exisAng sepAc tanks or alternaAve wastewater disposal systems within the public right-of-way where the Project is proposed. The Project proposes to develop underground structures that will store and convey potable water planned to be distributed to Escalon’s residents.

Therefore, no impacts are anAcipated, and no MiAgaAon Measures are needed. f) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature? RESPONSE:

Less than Significant with MiAgaAon Incorporated. On March 3rd, 2023, a records search was conducted for the proposed Project by the Western Science Center (WSC). The Project and Local Vicinity were evaluated along Escalon-Bellota Road on SecAon 32 and between SecAon 29/28, 20/21/ 17/16 of Township 1 South, Range 9 East on the Escalon, CA USGS 7.5-minute quadrangle. There are no previously documented resources at the WSC located within the Local Vicinity or within a 3-mile radius. However, results from the records indicate high paleontological sensiAvity due to underlying alluvial deposits.

ExisAng condiAons indicate the Project is underlain with Pleistocene-aged alluvial deposits from the Modesto FormaAon and the Riverbank FormaAon (Wagner, Bortungo, McJunkin 1991). Pleistocene geologic units are considered to be highly paleontologically sensiAve. Therefore, any fossil specimen from the SSJID Surface Water ConnecAon Project would be scienAfically significant. Since Project construcAon requires ground disturbances beyond depths of previous disturbance, the Project has the potenAal to result in significant impacts on paleontological resources found within paleontologically sensiAve Pleistocene-aged alluvial units.

As a result, it is recommended by the WSC that a paleontological resources miAgaAon program pursuant to MM PALEO-01: Paleontological Resource MiAgaAon Program be put in place to monitor, salvage, and curate any recovered fossils associated with Project construcAon. The following MiAgaAon Measure will ensure the Project does not directly or indirectly destroy a unique paleontological resource or site or unique geological feature.

Therefore, Project impacts will be less than significant with miAgaAon incorporated.

5.7.4 MiAgaAon Measures
MM PALEO-01- Paleontological Resource MiAgaAon Program: Prior to the start of Project construcAon, the City of Escalon shall hire a qualified paleontologist to conduct pre-construcAon tailgate trailing for the construcAon crew and monitoring during ground disturbance. The training can be videotaped for crew added later during construcAon.

Training shall be documented with a sign-in sheet and wriLen materials including photos of potenAally significant paleontological resources.

In addiAon, the City’s paleontologist shall prepare and implement a Paleontological Resource MiAgaAon Program to monitor, salvage, and curate any recovered fossils which will be funded by the City. Throughout Project construcAon, the Project contractor shall maintain records of field crew training and monitoring and shall document any paleontological resources encountered during construcAon with photos, georeferencing, and maps. If field personnel

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encounter buried paleontological resources, work in the immediate vicinity of the find should cease within 50 feet of the resource and the City and a qualified paleontologist should be contacted immediately to assess the significance of the find. A qualified paleontologist shall have the authority to stop or divert construcAon and excavaAon as necessary.

Modified MM GEO-01: Seismic Design Criteria- Facility design shall comply with the site-specific seismic design criteria recommendaAons of a geotechnical engineer. Facility design shall also comply with the seismic design requirements of the UBC and with applicable provisions and policies of the San Joaquin County General Plan.

Modified MM GEO-02: Geotechnical Design Criteria- Facility design shall comply with the site-specific geotechnical design criteria recommendaAons of a geotechnical engineer, applicable requirements of the UBC, and applicable provisions and policies of the San Joaquin County General Plan.

See MiAgaAon Measure Modified MM HYDRO-01: Stream Crossings in SecAon 5.10 Hydrology.

See MiAgaAon Measure Modified MM HYDRO-03: Erosion Control in SecAon 5.10 Hydrology.

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5.8 GREENHOUSE GAS EMISSIONS
Issues
PotenAally
Significant Impact
Less than
Significant Impact
with MiAgaAon
Incorporated
Less than
Significant Impact No Impact
VIII. GREENHOUSE GAS EMISSIONS. Would the Project:
a) Generate greenhouse gas
emissions, either directly or
indirectly, that may have a
significant impact on the
environment?
b) Conflict with an applicable plan,
policy or regulaAon adopted for
the purpose of reducing the
emissions of greenhouse gases?

5.8.1 Regulatory Compliance
Greenhouse Gases (GHGs) trap heat in the atmosphere and can occur both naturally and from human acAviAes.

Sources of naturally occurring GHG include volcanic acAvity, respiraAon, and decomposiAon of plants. Climate data indicates a relaAonship between increased industrializaAon and conAnuously elevated atmospheric temperatures aLributed to GHG. Human acAviAes that are considered as a conAnuous source of GHG emissions include electricity producAon, transportaAon, manufacturing, and agriculture. GHGs are formed via the mixing of chemicals emiLed into the atmosphere. Specific chemicals that are known to result in GHG include water vapor, (CO2), methane (CH4), (NOx), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF6) (State Guidelines, SecAon (State CEQA Guidelines, SecAon 15364.5 and Health and Safety Code, SecAon 38505(g)). Levels of GHGs in the atmosphere enhance the GHG Effect, resulAng in trapped heat within the Earth’s atmosphere leading to the conAnual warming of the Earth’s climate. According to the 2007 Intergovernmental Panel on Climate Change (IPCC) Report, global temperatures are anAcipated to increase by approximately 0.2 degrees Celsius per decade (IPCC 2007). Due to the impacts GHG emissions have on the planet, SB97 was signed into legislaAon in 2007. SB97 required CEQA documents to prepare feasible miAgaAon of GHG emissions and evaluate potenAal effects.

U.S. EPA
The federal government administers a range of public-private partnerships to reduce the GHG intensity generated in the United States. The U.S. EPA is responsible for implemenAng federal policies and programs to address GHGs, which primarily focus on energy efficiency, renewable energy, methane and other non-CO2 gases, agricultural pracAces, and implementaAon of technologies to achieve GHG reducAons.

San Joaquin County
Since the 2035 San Joaquin General Plan integrates CCAP-related policies and implementaAon programs, the General Plan is recognized as a “Plan for the ReducAon of GHG Emissions.” The County plans to achieve reducAon targets through “modified County operaAons, reduced auto trips, emphasis on infill development in urban communiAes and ciAes, and reduced energy and water consumpAon” (San Joaquin GP DEIR 2035).

The County of San Joaquin General Plan Public FaciliAes and Service Element includes the following goals and policies relaAng to GHGs that apply to the proposed Project.
- Goal PHS-6. To reduce GHG emissions as part of the Statewide effort to combat climate change.

PHS-6.2 The County shall reduce community GHG emissions by 15 percent below 2005 levels by 2020 and shall strive to reduce GHG emissions by 40 percent and 80 percent below reduced 2020 levels by 2035 and 2050, respecAvely.

PHS-6.7 The County shall require new development to incorporate all feasible miAgaAon measures to reduce construcAon and operaAonal GHG emissions.

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City of Escalon
The City of Escalon’s General Plan Air Quality Element includes goals and policies related to GHG emissions that promote development pracAces and are compaAble with air quality standards and regional effects to improve air quality and encourage energy- efficiency while promoAng GHG reducAon. See Table 17: Project Consistency with County and City General Plan Energy and Climate Change Policies and Goals.

5.8.2 ExisAng CondiAons
Since GHG emissions are aLributed to industrial/manufacturing, agriculture, uAliAes, transportaAon, and residenAal land use, city and county plans focus on reducing emissions from these sources. The largest percentage of the State’s GHG emissions come from transportaAon, approximately 41 percent, followed by energy generaAon. Water and wastewater services only account for 4% of all electricity consumpAon naAonally and 6.9% of all electricity in California (SJVAPCD CCAP 2008).

ConstrucAon-phase GHG emissions can be quanAfied via rouAne air quality emissions modeling using CalEEMod for CEQA compliance. Pursuant to SJVAPCD protocol, the significance of GHG emissions for a project is determined by adding GHG emissions quanAAes, which have been amorAzed over 30 years, to long-term GHG emissions for a project.

Since the SJVAPCD has not adopted a metric for the threshold of significance for GHG emissions, analysis of the significance for direct and indirect Project-related GHG emissions is discussed qualitaAvely in this secAon.

5.8.3 Project Impacts
a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
RESPONSE:

Less than Significant Impact. Based on the size of the Project and the percentage of regional GHG emissions aLributed to water and wastewater services, long-term GHG emissions for the Project are considered negligible from the power needed to maintain the pumps. Likewise, the Project implementaAon has been considered conceptually in approved city and regional plans. The Project would be implemented in response to approved growth considered in the City’s General Plan and will not result in appreciable long-term GHG emissions.

AssumpAons made within the Project DescripAon were used as input to CalEEMod to quanAfy construcAon phase GHG emissions for the Project. Examples include numbers and types of construcAon equipment, construcAon acAviAes, duraAon of construcAon (16 months), earthworks quanAAes (approximately 3,348 CY) of export and 4,680 CY of import), and area of temporary disturbance (99,600 sq. V.; approximately 2.04 acres). The results from modeling temporary Project emissions are shown below in Table 16: Construc on-Related GHG Emissions,
which indicate that Project construcAon will result in temporary GHG emissions. The extent of these emissions is proporAonate to construcAon acAvity levels.

TABLE 16: PROJECT-RELATED GHG EMISSIONS
Category
GHG Emissions (Metric Tons/Year)
Bio-CO2 NonBio-CO2 CO2 CH4 N2O CO2e
Maximum Annual OperaAons 0.06 219 219 0.02 0.005 220
ConstrucAon 1 0.00 25.70 25.70 0.00 0.00 25.80
Total Emissions 0.06 244.70 244.70 0.02 0.01 245.80
Source: Appendix A- Air Quality, Greenhouse Gas, Energy Technical Memorandum, Ganddini 2023.

Notes: CalEEMod Version 2022.1.1.14 for Opening year 2026. (1) ConstrucAon GHG emissions CO2e based on a 30-year amorAzaAon rate.

As shown within Table 16: Construc
on-Related GHG Emissions, the proposed Project (without credit for any reducAon from sustainable design, and/or regulatory requirements) would result in 25.8 MTCO2e (amorAzed over 30 years) for Project construcAon and 220 MTCO2e per year for project operaAon resulAng in a total of 245.8 MTCO2e per year. Since the Project will generate GHG during construcAon from acAviAes, equipment, and the use of electricity, Project-generated GHG emissions would result in both direct impacts from Project acAviAes and indirect impacts from the use of electricity. Project construcAon is temporary, based on the anAcipated

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ConstrucAon will not result in substanAal earthwork; materials import and export or use of electricity. This is based on the overall Project footprint of 2.4 acres and approximately 3,348 CY of export and 4,680 CY of import requiring approximately 64,310 vehicle miles traveled (VMT) (50,486 VMT from construcAon workers; and 13,824 VMT from construcAon vendor/ hauling trips) during the 16-month construcAon period.

Based on the size of the Project, GHG emissions related to Project construcAon are not considered significant.

Long-term Project operaAons are anAcipated to exceed what has been considered within the City’s approved Water Master Plan and CIP. For the reasons above, the Project would result in a less than significant impact on the environment related to GHG, and no miAgaAon measures are needed. b) Conflict with an applicable plan, policy or regulaAon adopted for the purpose of reducing the emissions of greenhouse gases?
RESPONSE:

Less than Significant Impact. See SecAon 5.8.3, Response a) above. The Project will be required to comply with all applicable construcAon-related SJVAPCD regulaAons, including SJVAPCD RegulaAon VIII, and Title 24 energy standards. RegulaAon VIII will ensure ambient concentraAons of PM 10 are reduced during Project construcAon and Title 24 energy standards will ensure long-term operaAons are energy efficient and sustainable. As a result of the Project’s compliance with applicable construcAon-related SJVAPCD regulaAons, the Project would comply with the goals of the City of Escalon and County of San Joaquin General Plans and the Project would not conflict with any applicable plan, policy, or regulaAon of an agency adopted for the purpose of reducing GHG emissions.

See Table 17 Project Consistency with County and City General Plan Energy and Climate Change Policies and Goals.

TABLE 17: PROJECT CONSISTENCY WITH COUNTY AND CITY GENERAL PLAN ENERGY AND CLIMATE

CHANGE POLICIES AND GOALS
San Joaquin County General Plan
Energy and Climate Change
Policies
City of Escalon General Plan Air Quality Element Policies Project Consistency Policy 5.1-3: Review development and land use projects to ensure that measures are incorporated to reduce air
pollutants, including par
culate ma<er emissions, and
greenhouse gases associated with project design, site
prepara
on, grading, and construc
on as condi
ons of
approval for all development projects, subdivision maps, site plans, and grading permits. These measures may include, but are not limited to:

1. All applicable par
culate ma<er control requirements
of SJVAPCD Regula
on VIII;
ReducAon measures outlined within Escalon’s
General Plan will be implemented upon the City’s
plan check and review process. The following
reducAon measures consist of:
- Encouraging new buildings and development to
be energy efficient through passive design
concepts through the installaAon of “cool” roof
(e.g., roof materials with a high albedo) and
pavement materials.

Therefore, alignment with these policies and
procedures set forth by the City will result in less than significant impact. Agency coordinaAon will be
implemented through the CEQA process.

Goal: To protect the health and welfare of Escalon residence by promo
ng development and planning prac
ces that are
compa
ble with air quality standards and regional efforts to
improve air quality.

Policies and Standards1. Coordinate with other local and regional jurisdic ons,
including the SJVAPCD, San Joaquin Council of
Governments (SJCOG), and the California Air Resources
Board (ARB), in the development and implementa
on
of regional and county plans, programs, and mi
ga
on
measures that address cross-jurisdic
onal and
regional air quality impacts, including transporta
on
and climate change impacts, and incorporate the
relevant provisions of those plans into City planning
and project review procedures. Also cooperate with the
SJVAPCD, SJCOG, and ARB in:

Iden
fying baseline air pollutant and greenhouse gas
emission
Developing consistent procedures for evalua
ng and
mi
ga
ng project-specific and cumula
ve air quality
impacts of projects

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8. Encourage new buildings and development designed to
be energy efficient. Reduce energy consump
on and
greenhouse gas emissions through:

Requiring new development to be energy-efficient through passive design concepts (e.g., si
ng and loca
on) and
construc
on methods.

Encouraging and accommoda
ng projects that incorporate
alterna
ve energy, enhanced energy conversion measures,
and other voluntary methods of reducing energy usage and greenhouse gas emissions.

Implementa
on Strategy 1-6 Review new development and
rehabilita
on projects for consistency with policies related to
reducing energy consump
on and greenhouse gas
emissions. Acceptable energy reduc
on measures include,
but are not limited to:
- Construc
on methods (LEED Cer
fica
on, exceedance
of Title 24 Energy standards, and green building
methods)
PFS-1.6: Efficient Infrastructure
and Facili
es. When performing
maintenance, upgrading, or
expanding infrastructure and
facili
es, the County shall use
technologies that improve energy
efficiency and conserve water,
when feasible. (RDR/PSP)
(Source: New Policy)
The Project proposes a planned improvement to a
public uAlity. As a result, the planned improvement
will allow for the public works facility to be uAlized
more efficiently with current technology
incorporated. Therefore, the Project is aligned with
the proposed policy within the County’s General
Plan.

PFS-3.2: Sustainable Plans and
Opera
ons. The County shall
integrate sustainability concepts,
greenhouse gas reduc
on
strategies, and climate change
resiliency planning into County
facility and service plans and
opera
ons. (PSP/SO) (Source:

New Policy)
Upon the implementaAon of the Project Components
(BPS, Storage Tank, Wet Well, and FCF, etc.), the
Project will incorporate new sustainability concepts
(e.g., energy efficiency, water conservaAon, waste
reducAon/ recycling, purchasing preferences, etc.)
that have been reviewed prior by the City’s Planning
Department through the standard applicaAon and
plan check and inspecAon processes. Therefore,
resulAng in less than significant impacts.

Goal PSH-6: To reduce
Greenhouse Gas Emissions at
part of the Statewide effort to
combat climate change.

PSH-6.2: The County shall reduce
community greenhouse gas
emissions by 15 percent below
2005 levels by 2020 and shall
strive to reduce GHG emissions by
40 percent and 80 percent below
reduced 2020 levels by 2035 and
2050, respec
vely.

PSH-6.7 The County shall require
new development to incorporate
all feasible mi
ga
on measures
to reduce construc
on and
opera
onal GHG emissions.

ReducAon measures outlined within Escalon’s
General Plan will be implemented upon the City’s
plan check and review process. The following
reducAon measures consist of:
- Encouraging new buildings and development to
be energy efficient through passive design
concepts including the installaAon of “cool”
roof (e.g., roof materials with a high albedo)
and pavement materials.

Therefore, compliance with these policies and
procedures set forth by the County’s Planning
Department will result in less than significant impact.

Source: (1) City of Escalon GP Update, DEIR, adopted February 2005; (2) San Joaquin County 2035 GP EIR, adopted October 2014

5.8.4 MiAgaAon Measures
No MiAgaAon Measures are needed.

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5.9 HAZARDS AND HAZARDOUS MATERIALS
Issues
PotenAally
Significant Impact
Less than Significant
Impact with
MiAgaAon
Incorporated
Less than Significant
Impact No Impact
IX. HAZARDS AND HAZARDOUS MATERIALS. Would the Project:
a) Create a significant hazard
to the public or the
environment through the
rouAne transport, use, or
disposal of hazardous
materials?
b) Create a significant hazard
to the public or the
environment through
reasonably foreseeable
upset and accident
condiAons involving the
release of hazardous
materials into the
environment?
c) Emit hazardous emissions or
handle hazardous or acutely
hazardous materials,
substances, or waste within
one-quarter mile of an
exisAng or proposed school?
d) Be located on a site which is
included on a list of
hazardous materials sites
compiled pursuant to
Government Code
§ 65962.5 and, as a result,
would it create a significant
hazard to the public or the
environment?
e) For a Project located within
an airport land use plan or,
where such a plan has not
been adopted, within two
miles of a public airport or
public use airport, would the
Project result in a safety
hazard or excessive noise for
people residing or working
in the Project area?
f) Impair implementaAon of or
physically interfere with an
adopted emergency
response plan or emergency
evacuaAon plan?
g) Expose people or structures,
either directly or indirectly,
to a significant risk of loss,
injury, or death involving
wildland fires?

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5.9.1 Regulatory Compliance
Materials are considered hazardous if they are corrosive, ignitable, reacAve, or toxic and are on a list maintained by federal, state, or local agencies, for hazardous materials. RegulaAons are established to reduce exposure to hazardous materials because exposure can result in damage to health, property, and the environment depending on the extent of exposure and individual suscepAbility.

Hazardous materials are uAlized frequently throughout the County and City of Escalon for residenAal, commercial, industrial, and agricultural purposes. Examples include ferAlizers, pesAcides, cleaners, solvents, paints, and automoAve products. RegulaAons that are established and enforced by agencies such as the EPA, California Department of Toxic Substances Control (CA DTSC), and local fire departments promote proper handling, storage, and transport of hazardous materials to protect the public and the environment. These agencies also oversee the remediaAon of polluted air, water, and soils and have jurisdicAon to issue permits for the producAon and uAlizaAon of hazardous materials under the authority of environmental protecAon laws including the Clean Air Act, Clean Water Act (CWA), Porter-Cologne Water Quality Act, Resource ConservaAon and Recovery Act (RCRA), Title 22 of the California Code of RegulaAons, Health and Safety Code, and California OccupaAonal Safety and Health (Cal-OSHA) Act of 1973.

U.S. EPA
The U.S. EPA provides federal regulaAons regarding adequate hazardous waste management. The EPA was given authority by Congress to develop the RCRA program through the RCRA Act. The Act created the framework for the proper management of hazardous and non-hazardous solid waste. Under RCRA, the EPA regulates hazardous waste from generaAon to disposal, referred to as “cradle to grave.” Over the years, the EPA has led several hazardous waste iniAaAves to meet the growing challenges that come with hazardous waste management. The EPA has created standards, exclusions, and exempAons for certain types of waste including Universal Waste, Household Hazardous Waste, PharmaceuAcal hazardous waste, etc.

CA DTSC
CA DTSC has primary responsibility for regulaAng hazardous materials in California under the authority of RCRA and the California Health and Safety Code and California Hazardous Waste Control Law. Other enAAes with responsibility for hazardous materials regulaAon include:
− Regional Water Quality Control Board (RWQCB) – under authority of the Porter-Cologne Water Quality Control Act of 1969
− California Department of PesAcide RegulaAons, Department of Food and Agriculture, and the Department of Public Health – under authority of California Code of RegulaAons Title 3 and Title 22 − California Department of Industrial RelaAons, Division of OSHA – under authority of California Code of RegulaAons Title 8
− California Air Toxic “Hot Spots” (AB 2588) Program – under the authority of the California Safety Code In addiAon to various regulaAons, the DTSC also provides an Emergency Response Unit (ERU). The ERU is in place to issue a “statewide response to actual and potenAal release of hazardous substances that pose an acute threat to public health and/ or the environment” (DTSC 2022).

Cal-OSHA
Cal-OSHA enforces worker safety requirements, which contain standards specifically for hazardous waste operaAons, emergency response, safety, and preparedness. Cal-OSHA standards must be implemented during general industry and construcAon acAviAes

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Central Valley RWQCB (Region# 5)
The Central Valley RWQCB implements programs to meet and exceed water quality standards. This agency establishes regulaAons to ensure public and environmental health. The RWQCB enforces water quality plans to comply with Water Quality laws and sustain long-term water supplies within the state.

The RWQCB has created a tool called “GeoTracker” to idenAfy sites that impact or have the potenAal to impact, water quality within California. GeoTracker contains records for unregulated and regulated faciliAes that include: “Irrigated Lands, Oil and Gas ProducAon, operaAng PermiLed Underground Storage Tanks (USTs) and Land Disposal Sites” (CA Water Boards 2023).

NaAonal Pollutant Discharge EliminaAon System (NPDES)
The NPDES is a permit program led and managed by the U.S. EPA Office of Wastewater Management in coordinaAon with EPA regional offices. The NPDES permit program ensures water quality is not degraded by the discharge of stormwater from construcAon projects. The NPDES General ConstrucAon Permit applies to projects that plan to disturb more than one acre or more of land during construcAon. Compliance with permiNng requirements called for a Storm Water PolluAon PrevenAon Plan (SWPPP).

CerAfied Unified Program Agency (CUPA)
The CUPA is a program that consolidates the administraAve requirements, permits, inspecAons, and enforcement acAviAes of mulAple environmental and emergency response programs. California EPA and other state agencies set the standards for the Program, while local governments enforce their standards via CUPAs. San Joaquin County’s CUPA is part of the Environmental Health Department, which was an acAon approved by the State for San Joaquin in January 1997. This department administers/ oversees the Hazardous Material Business Plan, California Accidental Release PrevenAon (Cal-ARP), Aboveground Petroleum Storage Act, Hazardous Waste Generator, Hazardous Waste Onsite Treatment (Tiered PermiNng) and Underground Storage Tank program.

San Joaquin
Local-Hazard Mi
ga
on Plan (LHMP)
The San Joaquin LHMP provides strategies and miAgaAon for reducing potenAal impacts due to natural or humaninduced hazards. LHMP became a State and Federal requirement when the Disaster MiAgaAon Act was passed in 2000 (SC LHMP 2023). San Joaquin County’s LHMP incorporates plans, studies, reports, and technical informaAon from the State Hazard MiAgaAon Plan, General Plan December 2016, Emergency OperaAons Plan (EOP), Emergency Preparedness Plan, Threat and Hazard IdenAficaAon and Risk Assessment (THIRA), Flood Plan, and Emergency AcAon Plan.

The following documents were uAlized to curate six separate elements of San Joaquin County’s LHMP that address local hazards from the planning phase to remediaAon. The six separate elements include:
1) Element A: Planning Process - Documents formal governing body planning process for this plan by all parAcipaAng jurisdicAons as well as the County.
2) Element B: Hazard IdenAficaAon and Risk Assessment - IdenAfies hazards affecAng the OperaAonal Area and profiles each hazard with a list of past occurrences, threat analysis, and map or geographic descripAon of the risk area.
3) Element C: MiAgaAon Strategy - Documents County miAgaAon goals, miAgaAon strategies by hazard type, and a list of projects that would miAgate sites of past damages or potenAal future damages. 4) Element D: Plan Update, EvaluaAon, and ImplementaAon - Procedures to maintain this plan on an ongoing basis.

This element ensures the County will monitor the miAgaAon projects for modificaAon, new projects to be added, and compleAon of miAgaAon acAons.
5) Element E: Plan AdopAon: - DocumentaAon of plan adopAon including the County and other jurisdicAons, level of parAcipaAon, risk assessment, and miAgaAon acAons.
6) Element F: AddiAonal State Requirements

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San Joaquin County
EOP
The County’s EOP was published on February 17th, 2022. The EOP is wriLen in accordance with federal and state guidelines to provide a response to potenAal emergencies throughout San Joaquin County. The plan was wriLen in coordinaAon with various fire departments throughout the County to appropriately define acAons and roles necessary for efficient emergency response with San Joaquin County and neighboring communiAes.

The County’s EOP is compliant with “the Standardized Emergency Management System (SEMS), the NaAonal Incident Management System (NIMS), the Incident Command System (ICS), the NaAonal Response Framework (NRF), and the NaAonal Preparedness Guidelines to include Developing and Maintaining Emergency OperaAon Plans, Comprehensive Preparedness Guide (CPG) 101, version 3.0” (San Joaquin County EOP 2022).

The EOP consists of individualized planning scenarios and response protocols for hazards, incidents, events, and emergencies believed to be important to the operaAonal area. Planning and preparedness efforts within the County’s EOP breaks the core capabiliAes of responsiveness to potenAal hazards or threats into five categories: (1) prevenAon, (2) protecAon, (3) miAgaAon, (4) response, and (5) recovery (San Joaquin County EOP 2022). The County will uAlize these categories to prevent and prepare for potenAal risks to San Joaquin County communiAes, including the Project.

5.9.2 ExisAng CondiAons
Response to human-induced and natural hazards within City Limits is the City’s primary duty. The City’s municipal code is intended to protect the health, safety, and welfare of its populaAon. For these reasons, the City’s Safety Element within the General Plan proposes policies and goals specific to hazard-prone areas. PotenAal natural hazards within City Limits include soil instability, flooding, wildland and urban fires, and evacuaAon routes. Geologic and soil hazards are discussed in SecAon 5.7- Geology and Soils. Human-induced hazards including hazardous materials and waste associated with potenAally toxic substances are addressed in this secAon. The presence of all hazards within the City is miAgated by uAlizing the procedures detailed in San Joaquin County’s EOP; the City’s Standard SpecificaAons and Municipal Code including City planning documents such as the General Plan and Escalon’s Water Master Plan.

According to GeoTracker, a website maintained by the State Water Quality Control Board (SWRCB) and EnviroStor website, maintained by the DTSC, there are no acAve or past significant environmental hazards at the Project and Local Vicinity. The closest acAve Clean Up Site is 5.6 miles south, downgradient, of the Project’s proposed BPS Site, and is a LUST Cleanup Site approximately located at 23659 S. Santa Fe Rd Riverbank, CA 95367. The site is former Barrera’s Market but contaminates are unknown.

5.9.3 Project Impacts
a) Create a significant hazard to the public or the environment through the rouAne transport, use, or disposal of hazardous materials?
RESPONSE:

Less than Significant Impact. As referenced in SecAon 5.9.2- ExisAng condiAons, the closest acAve LUST Cleanup Site is located over 5 miles downgradient from the Project; therefore, no impact is anAcipated as a result.

Project construcAon will involve the use of heavy equipment and chemicals including the transport of diesel fuel for construcAon equipment to and from the Project. Due to these anAcipated pracAces, the Project will conform to programs and regulaAons for temporary hazardous materials storage, handling, and transport during construcAon. The contractor will coordinate construcAon acAviAes with City and County Fire Departments; this includes the development of a manifest of potenAally hazardous materials and an approved plan under San Joaquin County’s EOP and LHMP for proper containment of the materials during Project construcAon. The Project contractor will also implement Cal-OSHA requirements for workers' safety and conduct regular site inspecAons.

The use of hazardous materials such as diesel fuel and propane for Project equipment including the 125kW diesel generator and the 10kW propane generator are anAcipated to be uAlized throughout the lifeAme of the Project.

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However, the proposed equipment is not anAcipated to be rouAnely used, since generators are for backup/ emergency purposes. The generators will be rouAnely inspected and will be designed with containment to prevent the release of hazardous materials within internal equipment components. The proposed 125kW diesel generator will provide power for two of the 50 HP pumps, exceeding 50 HP. Therefore, the proposed generator will comply with the EPA’s Tier 4 RegulaAons and Guidelines, which require that any diesel-fired generator with break horsepower exceeding 50 HP be provided to comply with EPA Tier 4 RegulaAons. Compliance with EPA Tier 4 RegulaAons requires the generator's exhaust to meet emissions standards set for nonroad engines (see Table 18: Final Emission Standards in grams per horsepower-hour (g/hp-hr)) and generators must decrease sulfur levels to reduce parAculate maLer associated with nonroad equipment (EPA 2004). The Project design incorporates addiAonal equipment to adequately treat air exhaust to meet the requirements of EPA Tier 4 RegulaAons.

TABLE 18: FINAL EMISSION STANDARDS IN GRAMS PER HORSEPOWER-HOUR (G/HP-HR) Rated Power First Year that Standards
Apply
PM NOx
hp<25 2008 0.30 --
25 ≤ hp < 75 2013 0.02 3.5*
75 ≤ hp < 175 2012-2013 0.01 0.30
175 ≤ hp < 750 2011-2013 0.01 0.30
hp ≥ 750 2011-2014
2015

0.075

0.02/0.03**

2.6/0.50

0.50 Source: EPA Office of TransportaAon and Air Quality, 2004 As a result of the reasons above, less than significant impacts are related to a significant hazard to the public or the environment through the rouAne transport, use, or disposal of hazardous materials. No MiAgaAon Measures are needed.

b) Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident condiAons involving the release of hazardous materials into the environment? RESPONSE:

Less than Significant Impact. See SecAon 5.9.3, Response a). The handling, use, and disposal of hazardous materials during Project construcAon is regulated through the standard applicaAon and compliance with the City’s Municipal Code via plan check and inspecAon process. As a result, impacts during construcAon of the Project are considered to be less than significant.

According to San Joaquin County’s LHMP 2017, the Project is not located within a high-risk area for wildland fire, flooding, or earthquakes (Reference San Joaquin County Local Hazard MiAgaAon Plan pgs. 20-28). As shown within the LHMP, higher-risk areas are located outside of City Limits, primarily west of the City of Escalon. The Project is not within a special study area for Alquist-Priolo Earthquake Fault Zones, FEMA Flood Zones, or Highrisk Fire Zones. However, the Project is within a Dam InundaAon Zone for New Melones Dam. However, this zone is not isolated to the Project since the enAre City of Escalon is within the inundaAon zone as well. Due to the exisAng urban land use within City Limits and surrounding the Project Site, implementaAon of the Project proposes changes that have already been anAcipated and considered by the City of Escalon. In addiAon, the City’s plan check and review process will ensure that requirements for minimizaAon of damage to public faciliAes and uAliAes within the inundaAon zone are implemented pursuant to Escalon’s Municipal Code Chapter 17.32 Floodplain Management Overlay District. Therefore, the threat of the Project being in a dam inundaAon zone for New Melones is considered to be less than significant.

ExisAng vegetaAon within the construcAon area for the Project will be removed as an iniAal step of site preparaAon for construcAon at the FCF. Therefore, Project construcAon will primarily occur within non-flammable areas, either pavement, dirt, or gravel top within the City right-of-way, and the potenAal for fire due to construcAon equipment’s internal combusAon is not likely to occur but is sAll a possibility due to adjacent agricultural lands. Over the long-term, the infrastructure installed with the Project will be subject to regular inspecAon and maintenance to ensure proper funcAoning. In addiAon, Project construcAon will incorporate local

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agency emergency response planning (Reference SecAon 5.9.1- Regulatory SeNng) via the plan check and inspecAon processes. Emergency response planning will be provided by the San Joaquin County EOP and together with regular maintenance and inspecAons, will reduce long-term risk of significant hazard.

According to the County’s EOP, 311 spills/ incidents of hazardous materials occurred within the County between 2017- 18 and have been steadily increasing in past years (San Joaquin EOP 2022). For this reason, San Joaquin County has developed a Joint Hazardous Materials Response Team, which is an extension of the Environmental Health Department that responds to events throughout the City. Project construcAon may involve use of hazardous materials as well as acAviAes such as welding that may result in accidents. The Project is designed for automated and remote operaAon and does not involve use or storage of large quanAAes of hazardous materials; the internal components of the pumps and generators contain small quanAAes of petroleum materials that are considered hazardous and potenAally flammable; however the Project design provides secondary containment and safety features to reduce risk. Therefore, the risk of release of hazardous materials involving significant risk to the public is low. In the unlikely event that emergency response is needed at the Project, the Joint Hazardous Materials Response Team will be the primary responders to incidents involving potenAal hazardous materials releases and will work in coordinaAon with local Fire Departments throughout the County during short-term construcAon and long-term maintenance and operaAons. The County’s Emergency OperaAon Center (EOC) noAfies local responders of potenAally hazardous events and determines the scope of the emergency and the type of resources needed to effecAvely support the event.

The closest fire staAons to the Project are Escalon Fire StaAon 1 and Oakdale Rural Fire Department StaAon 30.

StaAon 1 is located within downtown Escalon approximately 1.0 mile south of the proposed site for the BPS site directly north of City Limits (1749 Coley Avenue, Escalon, CA 95320). StaAon 30 is located within Oakdale, CA, west of Woodward Reservoir, and approximately 5.5 miles southeast of the Dodds Road and Escalon Bellota intersecAon, which is the northerly end of the Project alignment. Both fire staAons respond to medical emergencies, motor vehicle accidents, rescue calls, and incidents involving hazardous materials. Since the proposed BPS is just north of City Limits, within the SOI, the locaAon is accessible within the exisAng City layout.

Therefore, long-term maintenance and operaAons of the proposed faciliAes are consistent with approved plans and programs for future build-out of the City and County. The closest fire staAons are equipped with adequate equipment and personnel to respond to emergencies and perform necessary inspecAons with City and County approval.

For the reasons above, impacts related to a significant hazard to the public or the environment through reasonably foreseeable upset and accident condiAons involving the release of hazardous materials into the environment are anAcipated to be less than significant. No MiAgaAon Measures are needed. c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within onequarter mile of an exisAng or proposed school? RESPONSE:

Less than Significant Impact. The closest exisAng school to the Project is Escalon High School (1520 Yosemite Avenue, Escalon, CA 95320) located approximately 887 feet from the proposed site for the BPS, tank, and wet well. Escalon High School has approximately 814 students enrolled (9-12 grade) and 39 full-Ame teaching staff (CA Department of EducaAon, 2023-24 Enrollment by Grade). Daily commutes to Escalon High School occur via Escalon-Bellota Road, a designated route for hazardous materials transport to and from City Limits. However, since construcAon acAviAes will occur more than a quarter mile from an exisAng or proposed school and the proposed Project will comply with Federal, State, and Local regulaAons concerning hazardous materials, impacts are anAcipated to be less than significant, ensuring the health and safety of students within Escalon will be protected.

As menAoned in SecAon 5.9.3, Response a) and b) above, Project implementaAon is not likely to emit hazardous emissions or involve the handling of acutely hazardous waste in a manner resulAng in significant risk to the public or release. Long-term operaAons will involve Chlorine sampling at the BPS. Since surface water from SSJID is treated with Chlorine; however, the use of Chlorine for addiAonal treatment will not occur at the BPS. In addiAon,

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the applicaAon of federal, state, and local regulaAons outlined within SecAon 5.9.1- Regulatory SeNng, will provide worker safety for the closest receptors and ensure hazardous materials, substances, or waste are being handled appropriately through regular inspecAons by the City during construcAon and long-term For these reasons, the proposed Project does not anAcipate significant impacts related to the emissions or handling of hazardous or acutely hazardous materials, substances, or waste within one-quarter miles of an exisAng or proposed school. Less than Significant impacts are anAcipated; therefore, no MiAgaAon Measures are needed.

d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code § 65962.5 and, as a result, would it create a significant hazard to the public or the environment? RESPONSE:

No Impact. Government Code secAon 65962.5 is an updated list of Hazardous Waste Substances, also referred to as the Cortese List. The CA DTSC Publishes the list on the EnviroStor Website (DTSC Cortese List 2022).

Based on a preliminary search on the EnviroStor Website, uAlizing the City name, Zip Code, and County, no results were found at the Project or Local Vicinity. None of the results were located at the Project or adjacent land use addresses. Since the Project is not included on the Cortese List of sites that have known or potenAal contaminaAon and are not located where faciliAes are permiLed to treat, store, or dispose of hazardous waste, no impacts are anAcipated with the Project regarding Government Code secAon 65962.5. For this reason, miAgaAon measures are not required.
e) For a Project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the Project result in a safety hazard or excessive noise for people residing or working in the Project area?
RESPONSE:

No Impact. See SecAon 5.9.3, Response a) through d). The nearest airports to the Project are Modesto City-County Airport, located approximately 14.2 miles south of the Project’s proposed BPS Site, and Oakdale Airport, approximately 13.2 miles east of the Project’s proposed BPS Site. Since the closest airport to the Project is over two miles away from a public airport or public-use airport, the Project will not result in impacts to a safety hazard or excessive noise for people residing or working in the Project area. No MiAgaAon Measures are needed.

f) Impair implementaAon of or physically interfere with an adopted emergency response plan or emergency evacuaAon plan?
RESPONSE:

Less than Significant Impact. In order for the City to manage disasters such as earthquakes, floods, and other emergencies affecAng the City, Escalon follows the County’s Local Hazard MiAgaAon Plan and Emergency Response Plan. The City’s General Plan Chapter 2- Safety Element outlines policies and goals that will assist the local community and emergency response departments during disasters. As a result, the Project will abide by applicable policies and goals within these secAons of the General Plan as shown in Table 19: City of Escalon General Plan Safety Element Applicable Policies and Goals below.

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TABLE 19: CITY OF ESCALON GENERAL PLAN SAFETY ELEMENT APPLICABLE POLICIES AND GOALS Safety Element
City of Escalon General Plan Project Consistency
Policy 2.1.1 The City will maintain its emergency preparedness, including evacua
on procedures, to address poten
al natural
and man-made hazards. These procedures shall be developed in coordina
on with San Joaquin County’s emergency
opera
ons plans.

The Project is consistent with such plans that involve the County’s EOPs. Reference Responses within SecAon 5.9.3, Response f).

Policy 2.1.5 The City shall establish a network of streets that permits emergency vehicle access to any individual property that is no more than one minute from designated Arterial, Collector, or Minor Collector roadways.

With the coordinaAon from the City, the traffic control plan will allow for conAnuous vehicular access to the
Project and surrounding properAes. The traffic control
plan and Project construcAon will ensure that emergency routes are undisturbed in the event of an accident or
disaster.

Source: City of Escalon General Plan Safety and CirculaAon Element According to Escalon’s EvacuaAon Map provided by San Joaquin County’s Office of Emergency Services, EscalonBellota Road is a major evacuaAon route traveling away from downtown Escalon and north towards Farmington.

AddiAonal emergency services are provided at Hogan-Ennis Community Park, in the event evacuaAon is not possible for City residents. The proposed Project does not anAcipate impairing or physically interfering with the emergency evacuaAon routes, since the Project will implement traffic control measures and applicable BMPs including detours, signage, flagmen, and maintaining conAnuous access throughout Project construcAon.

There are no criAcal emergency faciliAes (hospitals, fire departments, police staAons, etc.) adjacent to the Project that could be directly impacted during construcAon. ConstrucAon would not change access such that emergency response acAviAes would be disrupted. The long-term operaAon of the Project will not differ substanAvely from exisAng condiAons.

Therefore, the impact related to interference with an adopted emergency response plan or emergency evacuaAon plan during Project construcAon would be less than significant. No MiAgaAon Measures are necessary.

g) Expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires?
RESPONSE:

Less than Significant Impact. See Responses 5.9.3 a) through f). According to CalFire’s Fire Hazard Severity Zones (FHSZ) Viewer, the Project and City Limits are not located within a zone with high to moderate fire risk. The closest zones for moderate fire risk are to the east and west, surrounding the Central Valley Region. These zones are approximately 13 miles and 22.9 miles from the Project and outside of City Limits. Due to the proximity of fireprone areas to the Project, exisAng condiAons do not pose a risk to the Project or Local Vicinity.

As a result, direct exposure to wildland fires is not anAcipated to significantly impact people or structures and result in loss, injury, or death. Accidental fire as a result of heavy machinery uAlized during construcAon is possible due to the surrounding land uses containing orchards and agricultural land uses. However, potenAal impacts will be reduced to less than significant levels with the implementaAon of the City’s Standard SpecificaAons. No MiAgaAon Measures are needed.

5.9.4 MiAgaAon Measures
No MiAgaAon Measures are needed.

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5.10 HYDROLOGY AND WATER QUALITY
Issues
PotenAally
Significant Impact
Less than Significant
Impact with
MiAgaAon
Incorporated
Less than Significant
Impact No Impact
X. HYDROLOGY AND WATER QUALITY. Would the Project:
a) Violate any water quality
standards or waste
discharge requirements or
otherwise substanAally
degrade surface or ground
water quality?
b) SubstanAally decrease
groundwater supplies or
interfere substanAally with
groundwater recharge such
that the Project may impede
sustainable groundwater
management of the basin?
c) SubstanAally alter the
exisAng drainage paLern of
the site or area, including
through the alteraAon of the
course of a stream or river or
through the addiAon of
impervious surfaces, in a
manner which would:
i. result in a substanAal erosion or
siltaAon on- or off-site;
ii. substanAally increase the rate
or amount of surface runoff in a
manner which would result in
flooding on- or offsite;
iii. create or contribute runoff
water which would exceed the
capacity of exisAng or planned
stormwater drainage systems or
provide substanAal addiAonal
sources of polluted runoff; or
iv. impede or redirect flood
flows?
d) In flood hazard, tsunami, or
seiche zones, risk release of
pollutants due to Project
inundaAon?
e) Conflict with or obstruct
implementaAon of a water
quality control plan or
sustainable groundwater
management plan?

5.10.1 Regulatory Compliance
The Clean Water Act (CWA)
CWA implementaAon is overseen by the U.S. EPA with the intent to “restore and maintain the chemical, physical, and biological integrity of the naAon’s waters” (SJ County DEIR 2014). EPA has assigned implementaAon authority for the CWA to other trustees and responsible agencies, such as the United States Army Corps of Engineers, as well as state

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and local agencies including the SWQCB, RWQCB, County of San Joaquin, and the City of Escalon. The CWA is an important instrument for Waterboards across California in the management of water quality and is the foundaAon of various regulatory and non-regulatory programs (educaAon, outreach, voluntary efforts, partnerships with stakeholders, etc.) to monitor water quality and reduce pollutant discharges into waterways. Regulated waterways under the CWA include lakes, streams, creeks, rivers as well as groundwater and recharge basins. The CWA contains several provisions protecAng water quality, including SecAons 303(c)(2)(B), 303(d), 305(b), 401, 402(p), and 404, and the Toxics Rule:

SecAon 303(c)(2)(B) establishes water quality standards and designated beneficial uses within various water bodies (e.g., drinking water, recreaAon, biological preservaAon, etc.). This SecAon of the CWA requires the State to review and update standards for designated uses.

SecAon 303(d) pertains to impaired waters. The State is required to submit a list of waters that do not meet water quality standards and are impaired due to pollutants. The State must develop Total Maximum Daily Loads (TMDLs) for these water bodies, which establishes a maximum threshold of a pollutant allowed within a water body.

SecAon 401 gives the State the authority to issue water quality cerAficaAons to conduct acAviAes including, but not limited to, construcAon or operaAon of large faciliAes by an individual permiLee, which may result in any discharge into surface waters. Individual permits can be issued for projects that exceed the approved threshold of the NPDES Permit issued to the local agency. As a result, before the issuance of a permit that might result in a discharge to navigable waters, the State must cerAfy that the acAvity will comply with State water quality standards, either through an individual permit issued for a specific project or verificaAon by the local agency that a project conforms with the general permit issued to the local agency (city or county) for a specific acAvity idenAfied via plan check and discreAonary approval.

SecAon 402(p) pertains to the NPDES program. This secAon focuses on regulaAng point source stormwater discharges associated with industrial acAvity, requiring industrial faciliAes to obtain permits for their stormwater discharges.

SecAon 404 regulates the discharge of fill materials into “Waters of the United States”, including wetlands. The Corps is responsible for the issuance of the SecAon 404 permit if any project proposes to fill wetlands or “waters of the United States.”
Toxic Rulesinclude various regulaAons related to toxic substances within water bodies. The EPA establishes thresholds for toxic pollutants discharges into navigable waters.

NPDES
The NPDES is a permit program led and managed by the U.S. EPA Office of Wastewater Management in coordinaAon with EPA regional offices. However, while the EPA retains oversight authority, responsibility for implementaAon is delegated to the State via SWQCB and RWQCB. The State agencies require local agencies (e.g., CiAes and CounAes) to develop an NPDES for local level by the local agencies via the discreAonary permit process. The NPDES stormwater permiNng program regulates the discharge of any pollutant into surface waters (San Joaquin County GP EIR 2014).

The SWQCB established the NPDES permit program and issued discreAonary permits (individual and municipal) to private enAAes and local agencies under the authority of the CWA. AddiAonally, approved Municipal permit programs are implemented by local agencies (e.g., counAes, ciAes, and special districts); local agencies may also be required to apply for individual permits under certain circumstances. The NPDES General ConstrucAon Permit applies to projects that plan to disturb more than one acre of land during Project construcAon. This permit requires Project applicants to prepare and implement a Storm Water PolluAon PrevenAon Plan (SWPPP). The City of Escalon requires that the SWPPP include erosion control, spill prevenAon, response procedures, nature and locaAon of chemicals uAlized and stored during project construcAon, and methods to prevent adverse impacts of any discharge of chemicals, substances, or materials (Ord. 542, 2014). The implementaAon of the SWPPP starts prior to construcAon with the installaAon of temporary BMPs for erosion and polluAon source control. According to the City of Escalon’s Municipal Code Sec
on 13.15.100 Construc
on Ac
vi
es, a SWPPP developed pursuant to the ConstrucAon General Permit may

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subsAtute for the erosion and sediment control plan for projects where a SWPPP has been developed since the SWPPP is implemented throughout construcAon. (San Joaquin County GP EIR 2014).

Federal Emergency Management Agency (FEMA)
FEMA is a Federal agency that oversees floodplains and the NaAonal Flood Insurance Program (NFIP), adopted under the NaAonal Flood Insurance Act of 1968. FEMA provides flood management protecAons set forth by their adopted standards. In addiAon, FEMA has developed the NaAonal Flood Hazard Layer (NFHL) to assist local jurisdicAons with flood potenAal on the idenAficaAon of land uses at risk. According to the FEMA flood map, various locaAons along the Project are idenAfied as regulatory floodways and Zone AE, high-risk flood zones.

Porter-Cologne Water Quality Control Act
The Porter-Cologne Water Quality Act protects the waters of the state for the use and enjoyment of the people. The Act regulates acAviAes that foreseeably degrade water quality within the state, to aLain the highest reasonable water quality and to protect beneficial uses of surface water bodies, wetlands and groundwater. The Porter-Cologne Water Quality Act is administered at a regional level, within the framework of the SWQCB and nine RQWCB across the state of California. Under the Act, each RWQCB must formulate and adopt its own water quality control plan that establishes water quality objecAves to ensure the reasonable protecAon of beneficial uses and prevenAon of nuisance either from point source or non-point source discharges (CA.gov 2023).

Delta ProtecAon Act
The Delta ProtecAon Act was enacted in 1992, “declaring the Delta a natural resource of statewide, naAonal, and internaAonal significance, containing irreplaceable resources” (California Delta ProtecAon Commission). The Act recognizes the preservaAon and protecAon of this resource for cultural, recreaAonal, and agricultural uses for California residents. RegulaAons under the California Code of RegulaAons, Title XIV, Division 9, are enforced by the State of California Delta ProtecAon Commission and ensure potenAal threats from urban encroachment do not impact agriculture, wildlife habitat, and recreaAon uses.

Central Valley RWQCB
The Central Valley RWQCB regulates water quality within San Joaquin County and is given water permiNng authority by the U.S. EPA. The primary responsibility of the RWQCB is to protect the quality of the waters within the Region for all beneficial uses through the formulaAon and adopAon of water quality plans that are tailored for specific groundwater or surface water basins. In addiAon, the RWQCB enforces regulaAons for industrial, domesAc, and agricultural water discharges contained within the Porter-Cologne Water Quality Control Act.

The Central Valley RWQCB is the largest and most diverse region in California. The Region spans from northern Los Angeles to the Oregon Border, approximately 60,000 sq. mi., and composes nearly 40 percent of the state.

SSJID
As a result of the San Joaquin Valley region’s focus on agricultural producAon, irrigaAon districts are common throughout San Joaquin County and adjacent counAes. IrrigaAon districts including SSJID and OID are primarily focused on agricultural water management; however, irrigaAon districts have expanded their services to provide water to urban and municipal areas as a result of diversified iniAaAves and goals (e.g. SCSWSP). The use of “irrigaAon district” terminology reflects the enAty’s prioriAzaAon of providing water for agricultural purposes and disAnguishes these enAAes from water agencies that only focus on water needs within urban and municipal areas.

SSJID has adopted goals and policies including the SCSWSP to supply water to various municipaliAes. As menAoned within SecAon 3.0 Project DescripAon, this was a collaboraAve effort that sought to "make full beneficial use of SSJID’s water rights, bolster groundwater sustainability within the local groundwater basin, and supplement fisheries pulse flows for the benefit of the environment and water users” (SSJID 2022 Water Master Plan).

Standard Specifica
ons
SSJID’s Standard SpecificaAons were adopted on July 28th, 1992, and deployed “to protect the District’s interests in the operaAon, maintenance, construcAon, and reconstrucAon of its works and faciliAes” (SSJID Special Provisions

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1992). The Standards SpecificaAons provide a framework for Project contractors, planners, and engineers to conduct work to SSJID faciliAes according to the District’s saAsfacAon.

Eastern San Joaquin Groundwater Authority (ESJGWA)
ESJGWA is a joint power authority formed by the 16 groundwater sustainability agencies (GSAs) within the Eastern San Joaquin Subbasin. Currently, the Eastern San Joaquin Groundwater Subbasin is criAcally over-draVed; as a result, the ESJGWA adopted a Groundwater Sustainability Plan (GSP) in 2019 to manage and use groundwater in a manner that does not cause undesirable results during the planning and implementaAon of future projects (CA DWR, 2018; Eastern San Joaquin GSP, 2019). The GSP seeks to promote long-term sustainability efforts that locally manage groundwater resources. Through ESJGWA's collaboraAon with GSAs, projects have been idenAfied throughout the Subbasin that help achieve sustainability goals. (Eastern San Joaquin GSP, 2019). The proposed Project is within the South San Joaquin (SSJ) GSA, comprised of 64,000 acres with parAcipaAng enAAes including SSJID and the City of Escalon, and has been idenAfied as a project that will reduce Escalon's groundwater demand.

SSJ GSA
Groundwater Sustainability Plan
In September 2014, the Sustainable Groundwater Management Act (SMGA) was enacted into California’s regulatory framework for groundwater management. The SMGA requires that local jurisdicAons achieve sustainability in groundwater subbasins through the implementaAon of GSAs. The Eastern San Joquin Groundwater Authority (ESJGWA) is a joint power authority formed by the 16 groundwater sustainability agencies (GSAs) within the Eastern San Joaquin Subbasin. the ESJGWA adopted a Groundwater Sustainability Plan (GSP) in 2019 to manage and use groundwater in a manner that does not cause undesirable results during the planning and implementaAon of future projects (CA DWR, 2018; Eastern San Joaquin GSP, 2019). The GSP provides a framework for local jurisdicAons to reach the subbasin’s sustainability goal of recharging the groundwater basin with 78,000 acre-feet of surface water per year (SSJID 2023).

SSJID in conjuncAon with San Joaquin County communiAes and ciAes formed the SSJ GSA and has idenAfied projects throughout the Subbasin that help achieve sustainability goals. The proposed Project is within the SSJ GSA, comprised of 64,000 acres with parAcipaAng enAAes including SSJID and the City of Escalon, and has been idenAfied as a project that will reduce Escalon's groundwater demand. According to their measurable objecAves on pages 3-10 (Table 3-3:

Interim Milestones for Chronic Lowering of Groundwater Levels), the SSJ GSA's groundwater levels, on average, are

22.2 feet AMSL (2013-2016). The GSP established an interim milestone, that states groundwater levels should be 23.1 feet AMSL by 2030; and eventually return to 24 feet AMSL, to "allow a reasonable margin of operaAonal flexibility between minimum thresholds to allow for acAve management of the Subbasin during dry periods without reaching the minimum threshold" (Eastern San Joaquin GSP, 2019).

City of Escalon
The City of Escalon’s General Plan Open Space, ConservaAon, and RecreaAon Element, outlines policies and goals intended to protect water resources within City Limits and the City’s Sphere of Influence. The following policies serve as a guide for the City of Escalon for “planning and maintaining recreaAonal faciliAes, enhancing the natural ameniAes of Escalon and minimizing environmental effects of planned development”:
- Protect natural resources including groundwater, soils, and air quality, to meet the needs of present and future generaAons.
- Expand programs that enhance groundwater recharge in order to maintain the groundwater supply, including the installaAon of retenAon ponds in new growth areas

5.10.2 ExisAng CondiAons
San Joaquin County’s water resources include surface water and groundwater. The Project is located within the San Joaquin Valley Groundwater Basin. Specifically, the Project is within the Eastern San Joaquin County Groundwater Subbasin. According to the San Joaquin County Flood Control and Water ConservaAon District (FCWCD), groundwater is located approximately 80-90 feet bgs (San Joaquin FCWCD 2018). However, data collected within the Eastern San Joaquin County Groundwater Subbasin indicates, groundwater levels have dropped approximately 100 feet over the

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last 40 years approximately 1.5 feet per year (San Joaquin County General Plan EIR 2014). As a result, groundwater overdraV has been a reoccurring issue within San Joaquin County throughout the County’s groundwater basins.

However, “there have been acAve aLempts by the County irrigaAon districts to conserve and uAlize the recharge basins to facilitate groundwater recharge have been recognized as effecAve management alternaAves” (GBA, 2007).

Surface waters throughout the County consist of numerous creeks, sloughs, and manmade channels, comprising an intricate network of waterways uAlized for agricultural irrigaAon, as well as urban and industrial uses. During the growing season, these surface waters are heavily monitored and maintained for conAnuous availability, in order to serve adjacent agricultural land uses year-round. However, various factors impact the quality of surface waters within San Joaquin County. Factors include “seasonal hydrologic paLerns, mineral composiAon of watershed soils, topography, land use, and sources of contaminaAon (e.g. agriculture, mining, industrial faciliAes, etc.)” (San Joaquin County General Plan EIR 2014). Table 20: Water Resources and Their Beneficial Uses, outlines the surface waters and groundwaters within the Central Valley perAnent to the Project. The following table illustrates the various uses of water resources adjacent to the Project and Local Vicinity.

TABLE 20: WATER RESOURCES AND THEIR BENEFICIAL USES
Water Resources Beneficial Uses Other OperaAng Agency Source of Supply Users San Joaquin River X X X X X -- -- Riparian farmers,
Shipping industry,
IrrigaAon Districts
Mokelumne River X X X X Flood
control
-- -- IrrigaAon Districts
Camanche
Reservoir (1963)
X X EBMUD1 Mokelumne River Local Residents
Calaveras River X X X -- -- Water Districts
Stanislaus River X X X -- -- IrrigaAon Districts
Delta X X X X Scenic -- MulAple Sources RecreaAonists,
Wildlife, USBR2,
DWR3
, shipping
industry
Delta-Mendota
Canal
X X X X U.S Bureau of
ReclamaAon
Sacramento River City of Tracy,
IrrigaAon
Districts,
Commercial,
Businesses
California
Aqueduct
X X X X California
Department of
Water Resources
Sacramento River Commercial,
Businesses,
IrrigaAon Districts
Lodi Lake X -- Mokelumne River Local Residents
Groundwater X X -- San Joaquin Valley
Groundwater Basin
Private
individuals, ciAes,
towns
Source: 1) RWQCB, 2011; 2) San Joaquin County General Plan EIR, 2014.

Notes: A= IrrigaAon; B= Municipal/ Industrial; C= RecreaAon; D= TransportaAon; E= Estuary/ Wildlife Area 1) East Bay Municipal UAlity District
2) U.S. Bureau of ReclamaAon
3) California Department of Water Resources
Waterways within the Central Valley are impaired due to various sources of polluAon. Table 21: CWA 303(D) Water Quality Limited Segments within San Joaquin County outlines a list of water bodies with pollutant levels in excess of the standards established to protect the beneficial uses of water in accordance with SecAon 303 (d) of the Federal Clean Water Act. A variety of ongoing point and non-point industrial, urban, and agricultural acAviAes contribute to the degradaAon of groundwater and surface waters throughout the Central Valley region.

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TABLE 21: CWA 303(D) WATER QUALITY LIMITED SEGMENTS WITHIN SAN JOAQUIN COUNTY Water Body Pollutants Likely Sources of PolluAon Proposed TMDL CompleAon Calaveras River, Lower (Stockton
DiverAng Canal to the San Joaquin
River, includes porAons of Delta)
Diazinon Urban runoff/ storm sewers 2021
Mercury Resource ExtracAon 2021
Organic Enrichment/
Low dissolved oxygen
Urban Runoff/ Storm sewers 2012
Pathogens Urban runoff/ storm sewers,
recreaAonal and tourism
acAviAes (non-boaAng)
2008a
Delta Waterways (eastern porAon)
Chlorpyrifos Agriculture, urban runoff/
storm sewers
2007a
DDT Agriculture 2011
Diazinon Agriculture, urban
runoff/storm sewers
2007a
Invasive Speciesb Unknown 2019
Group A PesAcides Agriculture 2011
Mercury Resource extracAon
(abandoned mines)
2009
Unknown Toxicity Unknown 2019
Delta Waterways (southern porAon)
Chlorpyrifos Agriculture, urban runoff/
storm sewers
2007a
DDT Agriculture 2011
Diazinon Agriculture, urban
runoff/storm
sewers
2007a
Electrical conducAvity Agriculture 2019
Invasive Species Unknown 2019
Group A PesAcides Agriculture 2011
Mercury Resource extracAon (mining) 2009
Unknown Toxicity Unknown 2019
Delta Waterways (Stockton Ship
Channel)
Chlorpyrifos Agriculture, urban runoff/
storm sewers
2006
DDT Agriculture 2011
Diazinon Agriculture, urban
runoff/storm sewers
2006
Dioxinc Point source 2019
ExoAc Species Unknown 2019
Furan compounds Contaminated sediments 2019
Group A pesAcides Agriculture 2011
Mercury Resource extracAon (mining) 2006
Organic Enrichment/
Low Dissolved
Oxygen
Municipal Point Sources,
Urban Runoff/ storm sewers
2007a
Pathogens Urban Runoff/ storm sewers 2008
Polychlorinated
biphenyls
Point source 2019
Unknown toxicity Unknown 2019
Middle River
Low dissolved oxygen HydromodificaAon/ Source
Unknown
2019
Chlorpyrifos Agriculture 2021
Copper Resource ExtracAon 2020
Mercury Resource ExtracAon 2021
Oxygen, Dissolved Unknown 2021
Unknown Toxicity Unknown 2021
Zinc Resource extracAon 2020
Chlorpyrifos Urban runoff/ storm sewers 2007a

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San Joaquin River (Stanislaus River
to Delta boundary)
DDE (PesAcides) Agriculture 2011
DDT (PesAcide) Agriculture 2011
Diuron Agriculture 2021
Electrical
ConducAvity
Agriculture 2007a
Group A pesAcides Agriculture 2011
Mercury Resource extracAon 2012
Temperature Unknown 2021
Toxaphene Source Unknown 2019
Unknown toxicity Agriculture 2019
Source: 1) San Joaquin County General Plan EIR, 2014; Table 4.J-2; 2) CVRWQCB, 2010 Notes: a= Date of USEPA approved compleAon; b= Invasive Species- refers to an organism (considered a pollutant) that is not naAve to California waters as a result of human acAviAes
Natural stormwater flows generally flow from north to south and are directed towards County and City drainage faciliAes (e.g. storm drains) within the public right-of-way as well as canals managed by irrigaAon districts. At the Ae-in with the SSJID transmission line along Dodds Road, stormwater flows south into an exisAng parkway adjacent to grass fields uAlized as a grazing field for livestock. Along Escalon-Bellota Road, where the water main will be installed for the 19,500 LF of potable water pipeline, there are irrigaAon ditches parallel and adjacent to the eastern edge of Escalon-Bellota Road. Since natural stormwater flows generally flow north to south, elevaAon gradually decreases along Escalon-Bellota Road as it approaches City Limits.

Along Escalon Bellota Road, surface flows drain into Lone Tree Creek, irrigaAon ditches, and adjacent drainage culverts, adjacent to northbound and southbound travel lanes. ProperAes adjacent on either side of Escalon Bellota Road drain toward the street. The closest City storm drains are located along EscalonBellota Road within City Limits, approximately 100 feet south of the proposed BPS; the closest County storm drains are located along various locaAons of the Project alignment. The closest water retenAon basins to the proposed BPS site are Hogan Basin, approximately 650 feet southwest, and Sunrise Basin, approximately 0.3 miles west.

A porAon of the Project alignment is bordered by FEMA-designated flood zones, Zone A and Zone AE, and a regulatory floodway (FEMA NFHL Viewer). Reference Figure 11: Riverine Flood Zones. According to FEMA, Zone A and Zone AE are areas that present a 1% annual chance of flooding and a 26% chance over 30 years, in addiAon, no depths or base flood elevaAons are shown within these zones (FEMA n.d.).

The flood zones are adjacent to Lone Tree Creek and are a result of potenAal inundaAon at Lone Tree Creek relate to the riverine floodway. Flood zones are approximately 1.16 miles north from the proposed BPS; and according to Project plans, approximately 2,300 LF of potable water pipeline will be within the FEMAdesignated Zone A. Project acAviAes anAcipated to be within the flood zone include jack and bore construcAon, trenching, and installaAon of the water main.

5.10.3 Project Impacts
a) Violate any water quality standards or waste discharge requirements or otherwise substanAally degrade surface or ground water quality?
RESPONSE:

Less than Significant Impact. The majority of receiving waters are manmade, irrigaAon canals or sloughs, relied upon for agricultural uses. Non-point sources of polluAon due to agriculture and urban runoff contribute heavily to the accumulaAon of polluAon within these receiving waters that degrade water quality. Trace amounts of contaminants including coliform bacteria, lead, copper, sodium, arsenic, barium, etc. have been known to be found in water sources within San Joaquin County as shown in Table 21: CWA 303(D) Water Quality Limited Segments within San Joaquin County (San Joaquin County GP EIR 2005).

Project construcAon will result in a total of approximately 2.4 acres of temporary disturbance. Since Project construcAon anAcipates more than one acre of disturbance, the Project Applicant is required to apply for coverage under the City’s NDPES General ConstrucAon Permit from the Central Valley RWQCB prior to the start

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of construcAon. Under the NPDES Permit, a SWPPP will be established and implemented during construcAon to reduce the potenAal for polluAon from construcAon entering surface flows and discharging into receiving waters.

The Project will remain compliant with the NPDES permit program, by idenAfying and implemenAng Projectspecific BMPs at the proposed Project (Ae-in pit with SSJID transmission main, FCF, BSP, storage tank, wet well, and along 19,500 LF of the proposed potable water pipeline). Erosion control and polluAon prevenAon BMPs will be implemented via plan check, and inspecAons by the contractor. Examples of these BMPs include the installaAon of temporary filters and containment surrounding acAve construcAon zones, regular sweeping of impervious surfaces and trackout areas, and covering stockpiles and haul trucks. According to Escalon’s Municipal Code Ar
cle III. Reduc
on of Pollutants in Stormwater, 13.15.080- Best Management Prac ces, recognizes BMPs
as an essenAal tool in regulaAng the discharge of pollutants to the City and County’s storm drain system, surface waters, and receiving waters. Proposed BMPs are intended to result in no substanAal degradaAon to surface, or groundwater quality during construcAon acAviAes so that Project construcAon remains compliant with the CWA and other water quality regulaAons. The City of Escalon has established General ConstrucAon & Site Supervision BMPs, which consist of keeping pollutants off exposed surfaces, limited use of water at the Project Site, immediate cleanup of leaks or other spills, erosion control via planAng vegetaAon, etc. RegulaAon of discharges into the municipal stormwater system at the Project will be under the jurisdicAon of the EPA and RWQCB as enforced by the City through plan checks and inspecAons.

Impervious surfaces due to the proposed Project are anAcipated to increase by 4,900 sq. V. and will trigger requirements for permanent structural and non-structural BMPs such as filtered storm drain structures that require ongoing maintenance. While impervious surfaces will be increased due to Project implementaAon and ulAmately increase the rate of runoff, surface drainage in addiAon to structural BMPs are planned to prevent pollutants from entering storm drains. Structural BMPs include the extension of the irrigaAon ditch and storm water drainage adjacent to the FCF; and guLers along either side of the BPS for surface water drainage into the City’s inlets located along Escalon-Bellota Road. Project plans indicate minimal changes to the natural topography and quality of imported soil needed for proposed improvements.

For reasons above, Project impacts related to the violaAons of any water quality standards or waste discharge requirements or otherwise degraded surface, or groundwater quality are considered to be less than significant.

Therefore, no MiAgaAon Measures are needed.
b) SubstanAally decrease groundwater supplies or interfere substanAally with groundwater recharge such that the Project may impede sustainable groundwater management of the basin? RESPONSE:

Less than Significant Impact. See SecAon 5.10.3, Response a). Project plans indicate improvements within the City and County right-of-way with exisAng impervious surfaces, will be removed and replaced to pre-Project condiAons for approximately 3.4 miles of the proposed Project alignment along Escalon-Bellota Road. However, due to the addiAon of the following Project Components: FCF, BPS, storage tank, and wet well, impervious surfaces are anAcipated to increase by 4,900 sq. V. This increase does not anAcipate substanAal changes to the rate at which infiltrates into the ground; nor will these proposed improvements significantly change the volume of groundwater recharge currently experienced under exisAng condiAons.

AddiAonally, the Project Components assist the City of Escalon in receiving surface water supplies that will replace losses from groundwater recharge due to the proposed conversion of land uses within the City’s General Plan.

The Project plans to extend into exisAng enAtled land uses consistent with the General Plan; therefore, the Project does not propose improvements that have not already been considered and approved by the City of Escalon and the County of San Joaquin and is not considered grow-inducing.

As a result, the proposed Project will not substanAally decrease supplies or interfering substanAally with groundwater recharge such the Project may impede sustainable groundwater management of the basin. The Project is intended to support regional groundwater sustainability.

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c) SubstanAally alter the exisAng drainage paLern of the site or area, including through the alteraAon of the course of a stream or river or through the addiAon of impervious surfaces, in a manner which would:
i. result in a substanAal erosion or siltaAon on- or off-site; RESPONSE:

Less than Significant with MiAgaAon Incorporated. See Response 5.10.3, a). The Project alignment generally slopes from north to south and drainage flows in the same southerly direcAon. During construcAon, the contractor will remove exisAng surfaces and perform earthwork. The proposed earthwork will temporarily disturb stable surfaces, resulAng in loosened soils, and increased potenAal for erosion and dust; likewise, deeper cuts proposed for the reservoir, pipes, valves, and temporary bore and jack pits will result in temporary stockpiles of the excavated materials. Temporary stockpiling from earthwork, imported materials, and export soils has the potenAal to increase construcAon-phase dust emissions that may impact surface waters and beneficial uses in receiving waters. This is a potenAally significant temporary impact.

Likewise, Project implementaAon is anAcipated to require the full discharge of any residual water within exisAng pipes and components prior to equipment removal and replacement and is expected to impact water quality. For these reasons, project construcAon may result in a temporary increase in erosion and siltaAon in surface waters and downstream receiving waters, which is a potenAally significant temporary impact that will be reduced to less than significance with the implementaAon of BMPs and miAgaAon measures idenAfied in the EIR for the SCSWSP (SCH #98022018).

Previously idenAfied miAgaAon required implementaAon of temporary erosion control around acAve areas of construcAon as well as dust emissions BMPs to prevent debris, polluAon, and dust from entering surface waters, downstream receiving waters, and jurisdicAonal waters such as Lone Tree Creek.

Temporary filters, inlet covers, and surface containment will be placed around acAve construcAon to prevent dust and debris from entering surface waters. ConstrucAon equipment, temporary structures, or materials that may temporarily modify localized drainage on parcels and in public right-of-way would be placed around acAve construcAon areas and removed upon compleAon of construcAon. Project plans indicate construcAon areas will either be restored to pre-Project condiAons or will be constructed with onsite drainage features which are designed to retain and control discharge entering the exisAng municipal storm drain system without significant impacts or requirements for upsizing or other modificaAons. Post-construcAon drainage paLerns will follow exisAng drainage paLerns to minimize impacts on the current topography and for minimal permanent changes to drainage paLerns and volumes, resulAng in less than significant impacts. Therefore, the Project would not substanAvely modify drainage or require addiAonal miAgaAon for drainage.

The exisAng paved streets contain impervious surfaces with high runoff potenAal and the Project does not propose addiAonal impervious surfaces in these areas. Project trenches and jack and bore pits will be backfilled, and the surface of the pavement will be restored to pre-Project condiAons pursuant to the San Joaquin County Public Works Standard R-29 and the City’s Encroachment Permit Standards, Trench Patch Structural SecAon Requirements. ConstrucAon acAviAes including trenching, excavaAon, installaAon of equipment and structures, as well as temporary jack and bore construcAon adjacent to the creek will remain compliant with the NPDES ConstrucAon General Permit issued by the City and County for CWA Compliance pursuant to the city’s standard processes for plan check and inspecAon and the implementaAon of the municipal code.

The Project contractor will deploy pre-established structural and nonstructural BMPs pursuant to the NPDES MS4 Permit during Project construcAon, to ensure polluAon is reduced and runoff is filtered prior to discharge into the municipal storm drain system. Upon compleAon of construcAon, disturbed surfaces from Project construcAon will be backfilled and stabilized. ConstrucAon areas will be restored to prProject condiAons for each segment of pipeline.

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Due to potenAally significant temporary impacts related to erosion, it is recommended that previously approved miAgaAon measures from EIR for the SCSWSP (SCH #98022018) will be tailored to the Project and implemented to protect water quality, REV MM HYDRO-01: Stream Crossings, MM REV HYDRO-02:

SWPPP SpecificaAons, and REV MM HYDRO-03: Erosion Control, and MM HYDRO-04: Lead Agency Approval shall be implemented in conjuncAon with SSJID Special Provisions for water quality to reduce potenAally significant impacts to a less than significant levels.

Project construcAon has the potenAal to increase erosion or siltaAon during construcAon acAviAes including jack and bore construcAon, excavaAon, and trenching. As a result, the Project will implement the proposed MiAgaAon Measures, restore drainage paLerns to pre-Project condiAons where possible, and install addiAonal storm drainage faciliAes consistent with applicable engineering standards for storm drainage within the Zone AE of Lone Tree Creek. Approximately 2,300 LF of the Project alignment is located within Zone AE, adjacent to Lone Tree Creek, and will require temporary jack and bore construcAon to avoid direct impacts on exisAng underground infrastructure owned and operated by SSJID.

For the above reasons, the Project will result in less than significant impact with MiAgaAon Measures. ii. substanAally increase the rate or amount of surface runoff in a manner which would result in flooding on- or offsite;
RESPONSE:

Less than Significant Impact. See SecAon 5.10.3, Response a) through c) i) above. The Project will not substanAally change the direcAon or volume of surface flows discharging into the municipal storm drain system or involve direct modificaAon of the Lone Tree Creek channel. According to Project plans, the Project will follow exisAng condiAons of surface runoff. Since impervious surfaces are anAcipated to increase by approximately 4,900 sq. V., the construcAon of these Project Components will include drainage plans meeAng the City’s standards so that a substanAal increase in the rate of surface runoff from the proposed Project is not anAcipated to occur.

As a result, less than significant impacts to substanAal increases in the rate or amount of surface runoff in a manner that would result in flooding on- or off-site are anAcipated. iii. Create or contribute runoff water which would exceed the capacity of exisAng or planned stormwater drainage systems or provide substanAal addiAonal sources of polluted runoff; or RESPONSE:

Less than Significant Impact. See SecAon 5.10.3, Response a) through c) ii. The Project has the potenAal to increase the volume and rate of runoff due to addiAonal impervious surfaces that are proposed at the FCF, reservoir, and pump staAon. However, the Project will include on-site and off-site drainage faciliAes to collect, convey, and discharge runoff from the proposed FCF, BPS, and storage tank to the exisAng municipal storm drain system. The FCF will be constructed to discharge surface water into an exisAng irrigaAon ditch along the northern and western perimeter of the facility, which carries flows to a new 12-inch storm drain within Escalon-Bellota Road that will be constructed with the Project (See Figure 9.

FCF Site Plan). The proposed reservoir will be designed with an overflow pipe to convey excess stored water as the surface flows toward the street and into an exisAng storm drain. Drainage from the FCF will Ae into the County’s exisAng drainage system and will be designed to discharge according to established engineering standards. Drainage that will be constructed with the Project at the BPS site includes two 4-foot-wide concrete valley guLers located on the northern and southern side of the pump staAon flowing east towards Escalon-Bellota Road at 1 percent grade (See Figure 9A. BPS Site Plan). The guLers at the BPS site will flow to an exisAng storm drain system along Escalon-Bellota Road.

The design of the proposed BPS includes design for addiAonal runoff due to increases in impervious surfaces. As a result, run-off is not anAcipated to exceed the exisAng capaciAes of exisAng storm drainage systems or provide substanAal addiAonal sources of polluted runoff.

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AddiAonally, the Project will abide by the City of Escalon’s Post-ConstrucAon Standards Plan to minimize impacts from increases in impervious surfaces that may be detrimental to adjacent bodies of water (rivers, lakes, reservoirs, estuaries, etc.) within the County. As a result, less than significant impacts are anAcipated, and no MiAgaAon Measures are needed.
iv. impede or redirect flood flows?
RESPONSE:

Less than Significant with MiAgaAon Incorporated. See SecAon 5.10.3, Response a) through c) iii above.

Project plans indicate consistency with exisAng drainage paLerns surrounding the Project. During earthwork, trenching, and jack and bore construcAon, the exisAng topography of the site will temporarily be modified from localized earthwork and construcAon acAviAes. Likewise, equipment and materials will be temporarily placed within acAve construcAon areas and within the floodplain; however, due to the scale of the Project and proposed miAgaAon measures, significant impacts are not anAcipated. Lone Tree Creek is within a FEMA-designated A Flood Zone and bore and jack construcAon for the Project will occur in the A Flood Zone. However, the Project will comply with BMPs from the San Joaquin County Flood Management Division BMP HYDRO-05: ConstrucAon within Riverine Floodway and MiAgaAon Measures Modified MM HYDRO-02: SWPPP SpecificaAons and Modified MM HYDRO-03: Erosion Control will be in place during Project construcAon according to the NPDES ConstrucAon General Permit to reduce potenAal impacts to the floodplain during construcAon.

The Project will not install permanent structures within the floodway and will facilitate long-term use of the BPS site, storage tank, wet well, and FCF for delivery of potable water with no substanAve changes to surface topography that would impede or redirect flows. Although the Project will result in permanent increases in impervious surfaces and would modify the topography and drainage paLern at the FCF and BPS/tank site, changes are not expected to be substanAve since a majority of the surfaces impacted by the Project will return to pre-Project condiAons and plans for the project indicate adequately sized drainage faciliAes will be constructed with the Project, both on-site and downstream to reduce potenAal impacts from flooding to less than significance.

For the reasons above, the Project is not anAcipated to impede or redirect flood flows with the implementaAon of MiAgaAon Measures.
d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to Project inundaAon? RESPONSE:

No Impact. See SecAon 5.10.3, Response a) through c) iv above. The Project will perform jack and bore construcAon underneath Lone Tree Creek, which is located approximately halfway along the proposed Project alignment. Lone Tree Creek is considered jurisdicAonal, Waters of the United States, under the U.S. Army Corps jurisdicAon, and is within a FEMA-designated AE Flood Zone (FEMA NFHL Viewer) at this locaAon. Use of jack and bore will avoid direct impacts on Waters of the U.S. ConstrucAon near Lone Tree Creek will involve earthwork that could result in the release of pollutants during construcAon. ConstrucAon will implement containment and erosion control miAgaAon measures that will reduce potenAally significant impacts related to the release of pollutants in surface waters to less than significant. ConstrucAon is not proposed during rain events. Upon compleAon of construcAon, surfaces near Lone Tree Creek will be restored to pre-project condiAons. The Project does not propose new permanent structures within the floodway or floodplain. There will be no permanent impacts from the Project from release of pollutants due to inundaAon from flooding.

The CA DOC does not place the Project within a zone at risk for a tsunami (See hLps://www.conservaAon.ca.gov/cgs/tsunami/maps). The Project Area is located within southeastern San Joaquin Valley, which is not geographically close to the ocean or large bodies of water. This area is not suscepAble to a tsunami or within seiche zones that have the potenAal to release pollutants due to Project inundaAon, as indicated by the FEMA flood maps. The Project does not propose work during rain events or permanent structures that would dam or divert flowing water from Lone Tree Creek onto other properAes or increase flood flows

Page 272 of 440 ends

Escalon City CouncilOctober 21, 2024

Escalon City Council
October 21, 2024