Escalon City Council
October 21, 2024

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 70
downstream. In addiAon, since the Project alignment is only parAally located within the flood zone and permanent structures are proposed outside of the flood zone, the Project may be exempt from flood zone construcAon requirements with the submission of a site plan, showing all Federal and State flood zones and floodways, property lines, and the footprint of all exisAng and proposed structures pursuant to San Joaquin County FCWCD (SJ Flood Management Division SFHA). MiAgaAon Measures and BMPs including Modified MM HYDRO-01:

Stream Crossings, Modified MM SWPPP SpecificaAons, and BMP HYDRO-05: ConstrucAon within Riverine Floodway are proposed to protect water quality in receiving waters including the creek. Erosion control pracAces will be implemented pursuant to the City’s Standard SpecificaAons and County policies and goals, to miAgate the release of pollutants in surface waters such as Lone Tree Creek.

For the reasons above, the proposed Project is anAcipated to have less than significant impacts. Therefore, no MiAgaAon Measures are needed.
e) Conflict with or obstruct implementaAon of a water quality control plan or sustainable groundwater management plan?
RESPONSE:

Less than Significant with MiAgaAon Incorporated. See SecAon 5.10.3, Responses a) through d) above. The Project will follow current requirements for polluAon source control and flood control or a sustainable groundwater management plan. A Storm Water PolluAon PrevenAon Plan (SWPPP) pursuant to the NPDES will be incorporated into Project specificaAons. As menAoned within this secAon in Response c) i, the Project contractor will implement stormwater polluAon prevenAon measures and erosion control pursuant to Modified MM HYDRO-02: SWPPP SpecificaAons.

For the reasons above, Project impacts are less than significant with miAgaAon incorporated during construcAon acAviAes.

5.10.4 MiAgaAon Measures
Modified MM HYDRO-01: Stream Crossings- Prior to final approval of the Project Plans and specificaAons and the start of Project construcAon, the City of Escalon Engineering staff shall verify that standard design criteria for pipeline installaAon at stream crossings using the jack and bore method prevents destabilizaAon of the streambed and banks.

The Project design shall locate the pipe far enough below streambeds and site the boring entry locaAon and boring slope at a significant distance from the streambank to avoid a future encounter between the pipeline and surface water due to stream downcuNng or lateral migraAon.

Modified MM HYDRO-02: SWPPP SpecificaAons- Prior to the cerAficaAon and approval of Project Plans and the start of Project construcAon, the City of Escalon Engineering staff shall verify that the Project contractor develops and implements a SWPPP, as required by the SWRCB and enforced by the CVRWQCB, for areas to be disturbed by construcAon acAviAes. SSJID and the City of Escalon shall incorporate into contract specificaAon the requirement that the contractor comply with, and implement the provisions of, the SWPPP and the RWQCB requirements for the NPDES General Permit for Discharges of Storm Water Associated with ConstrucAon AcAvity. The SWPPP should be kept on site during construcAon and implementaAon shall be recorded with the SWPPP. The objecAves of the SWPPP are to idenAfy pollutant sources that may affect the quality of stormwater discharge, to implement control pracAces to reduce pollutants in stormwater discharges, and to protect receiving water quality. The SWPPP may include, but is not limited to, the following elements:
- PreparaAon of a site map;
- DescripAon of construcAon materials, pracAces, and equipment storage and maintenance; - List of pollutants likely to contact stormwater;
- EsAmate of the construcAon site area and percentage impervious area; - Site-specific erosion and sedimentaAon control measures including soil stabilizaAon, revegetaAon, and runoff control to limit increases in sediment in stormwater runoff, such as detenAon basins, straw bales, silt fences, geo-fabrics, drainage swales, and sandbag dikes;

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 71
- 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.

Modified MM HYDRO-03: Erosion Control- Prior to the issuance of permits and Project construcAon acAviAes, the City of Escalon 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 as outlined within Modified MM HYDRO-02: SWPPP SpecificaAons (revegetaAon, soil stabilizaAon, stray bales, silt fences, etc.) where indicated on contract drawings and where the contractor has disturbed natural vegetaAon. For construcAon adjacent to, or crossing any waterways, the City of Escalon shall obtain and comply with any necessary permits from state and local jurisdicAons.

MM HYDRO-04: Lead Agency Approval of Project Plans- Prior to final approval of the Project Plans and start of construcAon, City of Escalon Engineering staff shall verify that Project Plans implement the following measures to ensure water quality BMPs are maintained:
a) The generator, fuel tank, containment areas, controls, and transfer switches should be mounted and anchored securely above the expected flood level on a concrete plaborm inside or next to the building in a protecAve structure and shielded from wind or windborne debris. At a minimum, the generator should be placed above the main electrical service equipment and above the uAlity company pad mount transformer with containment.
b) The locaAon of the emergency generator’s transfer switch(es), and all electrical distribuAon equipment so that the generator switches are at elevaAons that are at least as high as the generator. c) Provide adequate access to the new generator so that related operaAng measures, chemicals, and processes are above the floodplain and accessible during storms and emergencies. d) If a fuel tank is provided on-site, provide containment and anchor tank to resist floataAon. e) Flood-proof any chemicals, process, or operaAons for the generator within the floodplain f) Provide an approved operaAonal plan for the Project to relocate chemicals above the floodplain in advance of a flood event.
g) Verify that the local code requirements and standards and appropriate regulaAons of the uAlity companies are incorporated in Project plans
h) Verify that ConstrucAon Plans incorporate all local and naAonal building codes, as well as applicable electrical codes for the safety of site personnel.
i) All fuel supply and electrical lines must be protected from potenAal flooding and high wind. j) A consistent and regularly planned maintenance program should be developed, adopted, and enforced.

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 72
k) The City Engineer shall verify that construcAon within the floodway and flood zone will occur outside of the rainy season (October 15 through April 15). AcAve construcAon within the floodway and flood zone will not occur during rain events.

5.10.5 Best Management PracAces
BMP HYDRO-05: ConstrucAon within Riverine Floodway- Prior to Project construcAon and final approval of Project plans, the City of Escalon’s Engineering staff and San Joaquin County Flood Management Division shall verify that Project Plans and SpecificaAons contain the following measures to minimize impacts within FEMA-designated flood Zone A and AE:

1. A minimum of two (2) surveys are required; one before and one aVer construcAon. The first survey establishes the elevaAon of the project site, and is compared to the BFE to determine the height above grade that flood damage reducAon measures must be taken. Based on this iniAal survey, the “Preliminary ElevaAon CerAficate” an FM form series must be completed by a surveyor or engineer and is required prior to clearance from Public Works. If your plans/ applicaAon package does not include a completed FM-1 you cannot proceed to the Community Development Building for a plan check (SJ SFHA Construc on Requirements);

2. All uAliAes, machinery, equipment, tanks, and wells are required to be elevated above the BFE or be designed, constructed, and installed to prevent floodwaters from entering or accumulaAng within its components. For addiAonal informaAon, see ASCE 24-05 Chapter 7(SJ SFHA Construc on Requirements);

3. Upon the compeAAon of daily Project acAviAes within the flood zones, the Project contractor shall ensure that debris, trash, loose branches, and vegetaAon have been removed from Lone Tree Creek or riverbanks.

VegetaAon that is acAvely growing in the stream bank should not be removed without permission. Prior to any removal of streamside vegetaAon or to report any observaAons of the clearing of vegetaAon or trees on stream banks, contact San Joaquin County Channel Maintenance Division at 209.468.9698 (SJ Hazards in San Joaquin County);

4. UAlize methods and pracAces that minimize flood damage, throughout Project construcAon (Escalon Municipal Code Sec
on 17.32.130 Standards of Construc
on);

5. Electrical, heaAng, venAlaAon, plumbing, and air condiAoning equipment and other service faciliAes that are designated and/or located so as to prevent water from entering or accumulaAng within the components during condiAons of flooding (Escalon Municipal Code Sec on 17.32.130 Standards of Construc
on);

6. All new and replacement water supply and sanitary systems shall be designated to minimize or eliminate infiltraAon of flood waters into the systems; and discharge from the systems into flood waters (Escalon Municipal Code Sec
on 17.32.150 Standards of U
li
es).

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 74

5.11 LAND USE AND PLANNING
Issues
PotenAally
Significant Impact
Less than Significant
Impact with
MiAgaAon
Incorporated
Less than Significant
Impact No Impact
XI. LAND USE AND PLANNING. Would the Project:
a) Physically divide an
established community?
b) Cause a significant
environmental impact due
to a conflict with any land
use plan, policy, or
regulaAon adopted for the
purpose of avoiding or
miAgaAng an environmental
effect?

5.11.1 Regulatory Compliance
City of Escalon
The City of Escalon’s General Plan consists of 11 elements that provide a framework for achieving long-range goals for the future. The City of Escalon has adopted a Land Use Element as part of the General Plan, which is a required element pursuant to state law, California Gov. Code § 65300, and a tool to achieve managed growth and development.

The Land Use Element and the General Plan also establish standards that implement programs for achieving broad legislated goals and stated objecAves in regional plans; one example of this is water quality. The Land Use Element consists of text and a Land Use Map describing the general distribuAon, locaAon, and extent of land uses within city limits. It also defines the locaAon of city limits and the City’s SOI. The Land Use Element describes present and planned land uses in the City and incorporates regional and state program goals for resource management, such as water quality and sustainable groundwater use. The Land Use Element is the foundaAon for many citywide plans and programs as well as other General Plan Elements. Examples of this include the City’s CIP and Water Master Plan, for managing adequate provision of uAliAes and services, to support exisAng and future land use. The Land Use Element is the foundaAon for zoning and master plan development. The City’s approved plan for Hogan-Ennis Community Park expansion, at the southern end of the Project, is an example of a master plan.

The City’s Open Space, ConservaAon and RecreaAon Element was developed to implement policies to conserve natural resources as well as regulate open space and provide recreaAonal opportuniAes to the community over the long term. The City’s natural resource objecAves and policies that are stated in this Element and related to the Project include the following:

ObjecAves:
• Protect natural resources including groundwater, soils, and air quality, to meet the needs of present and future generaAons.
• Ensure that environmental hazards including potenAal flooding and impacts from agricultural pracAces are adequately addressed in the development process within the City and the Escalon Planning Area.

Policies And Standards:
• Expand programs that enhance groundwater recharge in order to maintain the groundwater supply, including the installaAon of retenAon ponds in new growth areas.

San Joaquin County
The County of San Joaquin General Plan Element stated purpose is to focus on encouraging employment generaAng development while preserving prime farmland. The County works with the City of Escalon and other local ciAes on annexaAons to expand local city SOI. The County is also responsible for coordinaAng with the San Joaquin Council of Governments regarding State regional housing needs allocaAons for adequate housing supplies throughout the County. The County’s General Plan provides a framework for orderly development, provision of community services,

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 75
and regional management of resources. The County is commiLed to preserving agriculture and the land use element emphasizes the importance of farming in San Joaquin County and encourages protecAve fencing between farm and urban uses.

ESJGWA IRWMP
As menAoned within SecAon 3.0 Project DescripAon, the ESJGWA IRWMP is designed to protect and improve water quality and supplies by idenAfying feasible agricultural and urban water use efficiency strategies, considering the drinking water quality of communiAes within the plan area, and recognizing significant threats to groundwater resources from over-draVing. These objecAves align with the mission of the GSJCRWCC and ESJGWA which aim to achieve long-term sustainability of water resources in the San Joaquin Region.

The Project is consistent with the regional long-term plans since it will provide the City of Escalon surface water to address potenAal imbalances caused by groundwater extracAon for drinking water.

5.11.2 ExisAng CondiAons
Unincorporated San Joaquin County contains approximately 681,21 acres (74.6%) of agricultural land, making agriculture the most abundant land use designaAon within County Limits. Since the adopAon of San Joaquin County’s General Plan in 1992, ciAes have annexed approximately 3 percent of the County’s total land (San Joaquin County 2035 EIR With populaAon anAcipated to increase within ciAes over the next few years, annexaAons are expected to conAnue pursuant to approved land use paLerns from each City’s General Plan and the need for regional housing established by the State. PorAons of the Project and Local Vicinity are within the approved SOI for the City of Escalon, with pre-annexaAon land use designaAons reflecAng the approved conversion of land use from agricultural to urban use accommodaAng anAcipated populaAon growth.

All project components will be constructed within the City right-of-way, either within exisAng paved streets or on parcels that are planned for public use and have been selected for the proposed FCF and the BPS, storage tank, and wet well, due to locaAons adjacent to the developed Escalon-Bellota Road. The City’s established land use designaAons allow for the development of public uAliAes on parcels owned by the City of Escalon that will not conflict with exisAng or proposed land use.

5.11.3 Project Impacts
a) Physically divide an established community?
RESPONSE:

Less than Significant with MiAgaAon Incorporated. The Project involves subsurface installaAon of a potable water main within the public right-of-way that is not anAcipated to permanently divide an established community. In addiAon, the proposed Project is part of the City’s and SSJID’s Water Master Plan; therefore, the Project does not propose to develop infrastructure or public uAlity improvements that have not already been conceptually considered and approved for the region by SSJID, City of Escalon, and County of San Joaquin. Proposed belowgrade improvements along Escalon-Bellota Road will connect to exisAng water infrastructure owned and operated by the SSJID and the City of Escalon. Upon the compleAon of construcAon, the public right-of-way will return to pre-construcAon condiAons which involves backfilling trenches and repaving the roadway.

Due to temporary Project construcAon, the contractor will implement a traffic control plan for work within the paved right-of-way pursuant to the City of Escalon’s Standard SpecificaAons. The traffic control plan will ensure that safe and consistent through access is maintained during construcAon along Escalon-Bellota Road and within surrounding areas. In addiAon, adjacent land uses will receive a minimum of 2-weeks’ noAce prior to construcAon acAviAes and construcAon acAviAes will be subject to frequent inspecAons in accordance with SSJID SCSWSP previously approved MiAgaAon Measures Modified MM LAND-02: Advance NoAce and Modified MM LAND-03:

ConstrucAon Contract Documents.

Both site plans for the FCF and the Project’s BPS, storage tank, and wet well are consistent with County and City land use policies and goals and Local Zoning Codes on adjacent parcels. The proposed tank/wet well will be

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located on a parcel that is currently a pervious parking lot uAlized for overflow parking that is a porAon of the planned expansion of Hogan-Ennis Community Park. This parcel is designated as Agricultural- Urban reserve.

Land designated for Agricultural-Urban Reserve is compaAble with “public, quasi-public, and special uses” including parks and proposed infrastructure to support public water systems (San Joaquin County GP EIR). Plans indicate compact layout for Project improvements, which are adjacent to the Escalon-Bellota paved street in a manner that will not substanAally conflict with the future park use proposed within this area. Other Project Components will be constructed as underground uAliAes within the County and City right-of-way; therefore, the BPS, tank and wet well components of the Project will not conflict with an established community or designated zoning requirements.

The location of the FCF is proposed on land that will be converted to public right-of-way. This parcel is designated for General Agriculture (AG-40). The FCF has a proposed footprint of approximately 3,500 sq. ft. (0.08 acres) and is currently a vegetated open space, void of crops. The FCF will be located adjacent to Escalon-Bellota Road. Due to the compact nature of the Project improvements at this location and adjacent siting to the existing paved rightof-way, no conflicts with existing or future land use would occur.

Due to the scale, Project impacts are not anAcipated to be significant. However, to minimize potenAal conflicts during construcAon, the proposed Project will incorporate SSJID SCSWSP previously approved MiAgaAon Measures Modified MM LAND-01: Landowner ConsultaAon and Modified MM LAND-04: OperaAon of Project Components. The following measures will ensure that adequate compensaAon is provided during landowner consultaAon and that long-term operaAon does not significantly impact noise and air quality.

In addiAon, the proposed Project will comply with San Joaquin Valley and the City of Escalon General Plan Policies and Goals. Reference Table 22: County and City Consistency with Applicable Land Use Policies and Goals.

TABLE 22: COUNTY AND CITY CONSISTENCY WITH APPLICABLE LAND USE POLICIES AND GOALS County General Plan Update Land Use
Policies and Goals
City General Plan Update Land Use
Policies and Goals
Project Consistency
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 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. (Source: New
Policy)

Policy 7.6.1: Provide for orderly outward
expansion of new urban development
that is con
guous with exis
ng
development, allows for the incremental
expansion of infrastructure and public
services, and minimizes impacts on the
environment.

The Project indirectly supports LU-1.4 by
building infrastructure that reduces
reliance on groundwater north of the
city limits. The development of the BPS
will occur on an underuAlized parcel
directly north of City Limits within
Escalon’s SOI, adjacent to the exisAng
Escalon-Bellota Road. Currently, the
parcel is a City-owned overflow parking
lot that serves commercial land uses to
the south.

The BPS site will maximize the efficient
use of County land by implemenAng
compact, mostly subterranean water
infrastructure essenAal to the City of
Escalon.

Similarly, the FCF is proposed on land
designated for agricultural use is
currently an open space grass field. The
FCF will be connected the SSJID
transmission main in Dodd Road to the
City of Escalon’s potable water system.

The Project has been approved and
considered by the County through the
SCSWSP.

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 77
Therefore, the Project is consistent with
County Policy LU- 1.4.

LU- 1.13 Regional Growth
Considera
ons. The County shall
consider the San Joaquin Council of
Governments’ Regional Transporta
on
Plan, including the Sustainable
Communi
es Strategy or Alterna
ve
Planning Strategy, and adopted city
general plans and those of surrounding
coun
es each
me it considers an
update to the General Plan or any
master plan, strategy, or zoning.
(Source: Exis
ng GP, CODP, Growth
Accommoda
on Implementa
on 1,
modified)

Since Project improvements do not
propose to increase exisAng density or
populaAon within the surrounding area.

Significant impacts to the following plan
outlined within the SJCOG RTP/SCS are
not anAcipated. As a result, the
proposed Project is consistent with
County Land Use policy LU- 1.7.

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

See SecAon 5.2.3, Response a), Table 7:

Project Consistency with County and City
Agriculture-Related General Plan Policies
and Goals.

LU-1-14: Review of New Infrastructure.

The County shall comment on any plan
that would result in new infrastructure
(e.g., freeways/roads, transmission
lines, rail lines, surface water
conveyance facili
es) that would
physically divide an established
community and shall require that any
rou
ng be revised to protect exis
ng
communi
es. The County shall work with
special districts, community service
districts, public u
lity districts, mutual
water companies, private water
purveyors, sanitary districts, and sewer
maintenance districts to provide
adequate public facili
es and to
plan/coordinate, as appropriate, future
aboveground u
lity corridors in an effort
to minimize future land use conflicts.

The Project will undergo a plan check
and review process by the City of
Escalon. In addiAon, the CEQA process
requires a 30-day public review period
for Public Comment. During that Ame.
the County will have the opportunity to
review the ISMND. The City of Escalon is
open to recommendaAons and
comments from the County.

The City, County, Oakdale Water
District, and SSJID are working together
to implement Phase 2 of the SCSWSP
(proposed Project), which connects
Escalon to the SSJID’s treated surface
water system. Their conAnued
coordinaAon is necessary for the
implementaAon of the proposed
Project, which will provide adequate
public faciliAes for regional groundwater
sustainability and future growth within
urbanized areas of the County.

Goal 7.5.4: Con
nue to plan and provide
efficient public safety and
leisure/cultural facili
es and services for
the community
The Project will provide water services
for the community more efficiently,
since this is a part of a planned buildout
of the water distribuAon network, as
outlined in the City’s Water Master plan.

The community overall will benefit from
the proposed Project because it will

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allow for an enhanced level of service
meeAng the City’s established level of
service standards for exisAng and future
land use shown in the approved Land
Use Map of the General Plan
Policy 7.6.1-5: Ensure that land uses
proposed in general plan updates and
amendments are supported by adequate
exis
ng or planned infrastructure and
u
li
es, including water, wastewater,
and a mul
-modal transporta
on
system.

The Project supports a full buildout of
the City’s current General Plan Land Use
Map. The BPS site is proposed on
underuAlized land, currently designated
for overflow parking. Other Project
Components are within the County and
City right-of-way; therefore, the
installaAon of a 19,500 LF potable water
pipeline and tee connecAon with an
SSJID 48-inch transmission line is
compaAble with the County and City’s
General Plan. The proposed Project
improvements will reduce the City’s
reliance on groundwater and provide
the City with enhanced levels of service
to the water system’s consumer base.

While the FCF is proposed on a porAon
of land designated for agricultural use,
the Project Component will support the
planned buildout of Escalon’s General
Plan. The FCF along with other Project
Components will achieve reliable water
services.

In addiAon, the Project is part of the
City’s Water Master Plan; therefore, the
Project does not propose land uses that
have not already been approved or
considered by the City.

For the reasons above, the proposed
Project is consistent with City General
Plan Policy 7.6.1-5.

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 will allow the City of Escalon to receive its surface water allotment and to implement approved policies for the region for balanced groundwater management, sustainable groundwater use, and reduced groundwater extracAons. Most of the proposed components of the Project, the proposed water main, wet well and the tank and the FCF will be underground. Proposed above-ground improvements will be a fenced uAlity consisAng of perimeter fence, gate and ground-mounted appurtenances. The Project will be located within the approved SOI of the City's General Plan, adjacent to developed public right-of-way and will not conflict with exisAng and planned land use in the Local Vicinity. The Project has been approved in concept in the SSJID Water Master Plan and EIR (SCH#98022018). Therefore, implementaAon of the Project is not expected to indirectly or directly change land use, induce growth, or physically divide an established community. ImplementaAon of the Project has been approved conceptually and is included as assumpAon in regional plans for this area.

The Project will implement water infrastructure that is consistent with the City’s Water Master Plan, the SSJID Water Master Plan, and the Eastern San Joaquin IRWMP. The Project will be installed within and adjacent to the

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exisAng paved public right-of-way for Dodds Road and Escalon-Bellota Road and will not physically divide an established community. Therefore, no miAgaAon measures are needed. b) Cause a significant environmental impact due to a conflict with any land use plan, policy, or regulaAon adopted for the purpose of avoiding or miAgaAng an environmental effect? RESPONSE:

Less than Significant with MiAgaAon Incorporated. See SecAon 5.11, Response a). ImplementaAon of the approved General Plan for the City of Escalon and the City’s Water Master Plan have accounted for the infrastructure improvements that are being proposed with the Project. Project implementaAon will convert approximately 9,900 square feet of land that is currently in use for overflow parking and open space to public right-of-way; however, these proposed modificaAons are adjacent to and are a logical extension of exisAng public right-of-way for Dodd’s Road and Escalon Bellota Road, where the Ae in and the transmission pipeline will be constructed bgs within the adjacent to the exisAng streets. InstallaAon of infrastructure is an allowed use under the City and County General Plan and zoning designaAons for agricultural and commercial land use associated with the FCF and BPS/tank site. Plans for the Project indicate compact project layouts at the FCF and BPS that are intended to reduce conflicts with exisAng and planned adjacent land use.

Project improvements are proposed to reduce the City’s reliance on groundwater wells for its potable water service, improve system reliability and water quality within the City’s potable water system, and to facilitate the City of Escalon’s use of its surface water allotment that was approved in 1999 to support goals and policies of the City’s General Plan for regionally sustainable groundwater use within the City as well as groundwater management within the San Joaquin Valley region. Therefore, the Project is aligned with goals and policies for water quality, groundwater management, capital improvements, land use, and emergency response that have been incorporated into the County’s and the City’s General Plans as well as approved regional plans supporAng reduced use of groundwater by the City of Escalon, through the proposed Project’s connecAon to the SSJID surface water transmission line. The proposed Project is aligned with established land use policies and regulaAons pertaining to future buildout of the City and the City’s potable water system. Since the proposed Project will not exceed what has been anAcipated under the City’s approved allotment of surface water, the City’s Water Master Plan, County and City General Plans, Project implementaAon is not expected to cause significant environmental impact due to conflicts with a land use plan or policy adopted for the purpose of avoiding or miAgaAng an environmental effect. The Project is intended to enhance the reliability of the water distribuAon network to accommodate the City’s receipt of surface water for potable use up to the approved allotment.

Project construcAon may result in temporary and intermiLent localized neighborhood impacts to traffic, air quality and noise from construcAon vehicles, equipment and acAviAes. MiAgaAon measures are proposed to reduce conflicts with adjacent landowners and nuisance during construcAon. The Project will install new equipment, such as permanent pumps, generators, and valves that may result in exceedances in municipal standards for noise, which is a potenAally significant impact. The Project will implement standard condiAons from the City’s municipal code, Project- specific miAgaAon measures, and modified miAgaAon measures from SCH#98022018 to reduce impacts on traffic, air quality, land use, and noise to less than significant levels.

Therefore, less than significant impacts related to County and City regulaAons are anAcipated.

As a result, of required implementaAon of standard condiAons and miAgaAon measures proposed with the Project, no addiAonal impacts beyond what has already been considered for the City of Escalon and County of San Joaquin within the environmental analysis of the cerAfied General Plan EIRs and SSJID’s SCSWSP and cerAfied EIR (SCH#98022018) will occur. Modified miAgaAon measures from SCH#98022018 including Modified MM LAND-01: Landowner ConsultaAon, Modified MM LAND-02: Advance NoAce, Modified MM LAND-03:

ConstrucAon Contract Documents, and Modified MM LAND-04: OperaAon of Project Components will be implemented with the Project to reduce land use conflicts from construcAon and long-term operaAon to less than significant levels.

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5.11.4 MiAgaAon Measures
Modified MM LAND-01: Landowner ConsultaAon- The City of Escalon 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 Escalon 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. Modified 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.

Modified MM LAND-02: Advance NoAce- The City of Escalon shall provide a 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.

Modified MM LAND-03: ConstrucAon Contract Documents- The City of Escalon shall incorporate miAgaAon measures in construcAon contract documents (e.g., terms of schedule or access condiAons or technical requirements). The City 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.

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

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5.12 MINERAL RESOURCES
Issues
PotenAally
Significant Impact
Less than Significant
Impact with
MiAgaAon
Incorporated
Less than Significant
Impact No Impact
XII. MINERAL RESOURCES. Would the Project:
a) Result in the loss of
availability of a known
mineral resource that would
be a value to the region and
the residents of the state?
b) Result in the loss of
availability of a locally
important mineral resource
recovery site delineated on
a local general plan, specific
plan, or other land use plan?

5.12.1 Regulatory Compliance
The California Surface Mining and ReclamaAon Act of 1975 The County of San Joaquin and the City of Escalon idenAfy potenAal mineral resources within their General Plan documents under the California Surface Mining and ReclamaAon Act of 1975 (SMARA). The Act sets requirements for mining and reclamaAon policy to ensure the following:
• ProducAon and conservaAon of minerals is encouraged;
• Environmental effects are prevented or minimized;
• ConsideraAon is given to recreaAonal acAviAes, watersheds, wildlife, range and forage, and aestheAc enjoyment; • Mined lands are reclaimed to a useable condiAon once mining is completed; and • Hazards to public safety both now and in the future are eliminated In addiAon, the Act requires local jurisdicAons, within the State of California, to classify land that has the potenAal for the discovery of mineral resources called Mineral Resource Zones (MRZs). According to the California State Board’s Guidelines for ClassificaAon and DesignaAon of Mineral Lands, the following MRZ designaAons are below:
• MRZ-1: Areas where available geologic informaAon indicates that there is minimal likelihood of significant resources.
• MRZ-2: Areas underlain by mineral deposits where geologic data indicate that significant mineral deposits are located or likely to be located.
• MRZ-3: Areas where mineral deposits are found but the significance of the deposits cannot be evaluated without further exploraAon.
• MRZ-4: Areas where there is not enough informaAon to assess the zone. These are areas that have unknown mineral resource significance.
• SZ: Areas containing unique or rare occurrences of rocks, minerals, or fossils that are of outstanding scienAfic significance shall be classified in this zone.

Due to the ongoing discovery of mineral resources on County lands, policies and goals are enacted by both San Joaquin County and the City of Escalon to conserve the natural resources within the region. The State Office of Mining ReclamaAon (OMR) and the County Public Works Department monitor all mining acAviAes within San Joaquin County to ensure operaAons are compliant with applicable laws.

5.12.2 ExisAng CondiAons
San Joaquin County’s mineral resources consist of primarily sand and gravel aggregate with limited mining of peat, gold, and silver. A total of 41 mining sites are located within San Joaquin County (13 acAve mines and 4 newly permiLed mines); however, none of the mining sites are within Local Vicinity (San Joaquin GP EIR 2014); therefore, mineral resources will not be impacted by the Project As shown in San Joaquin County’s General Plan EIR, Figure 4.OPage 284 of 440

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1: Aggregate Resources, MRZs containing known and potenAal resources are located in the northeastern and southwestern corners of the County. The Project is not within an MRZ or close to an acAve mining facility.

5.12.3 Project Impacts
a) Result in the loss of availability of a known mineral resource that would be a value to the region and the residents of the state?
RESPONSE:

No Impact. The Project is being implemented to support sustainable groundwater use by replacing potable groundwater extracAon with surface water from SSJID up to the approved City allotment from 1999. The Project will improve water quality and water system reliability within the City of Escalon to serve exisAng and approved land use in the City’s General Plan and would not induce addiAonal growth and development; therefore, indirect Project impacts on mineral resources would not occur as a result of the Project. Since the areas with known mineral resources of significance are outside the bounds of the Project and Local Vicinity, no direct impacts from the implementaAon of the Project on mineral resources are anAcipated. b) Result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan?
RESPONSE:

No Impact. See Response 5.12.3 a). There are no locally important mineral resource recovery sites delineated in the County’s General Plan. The Project would not induce addiAonal growth beyond what is approved with the exisAng zoning and general plan. Therefore, Project implementaAon will not result in direct or indirect impacts on mineral resources or the loss of availability of a locally important mineral resources recovery site delineated on a local general plan or other land use plan. No impacts are anAcipated.

5.12.4 MiAgaAon Measures
No MiAgaAon Measures are needed.

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5.13 NOISE
Issues
PotenAally
Significant Impact
Less than Significant
Impact with
MiAgaAon
Incorporated
Less than Significant
Impact No Impact
XIII. NOISE. Would the Project result in:
a) GeneraAon of a substanAal
temporary or permanent
increase in ambient noise
levels in the vicinity of the
Project in excess of standards
established in the local
general plan or noise
ordinance, or applicable
standards of other agencies?
b) GeneraAon of excessive
groundborne vibraAon or
groundborne noise levels?
c) For a Project located within
the vicinity of a private
airstrip or 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 expose people
residing or working in the
Project area to excessive
noise levels?
The responses within this SecAon are based on the Noise Impact Analysis for the Project (Appendix D) conducted by Ganddini Group, published on July 27th, 2023. The purpose of the Noise Impact Analysis study is to provide an assessment of the noise impacts associated with the construcAon and long-term operaAon of the proposed Project and to idenAfy miAgaAon measures that may be necessary to reduce associated impacts.

5.13.1 Regulatory Compliance
Federal Noise Control Act of 1972
In 1972, the U.S. EPA Office of Noise Ambient and Control issued the Federal Noise Control Act, which established programs and guidelines to idenAfy and address the effects of noise on public health, welfare, and the environment.

The EPA established Levels of Environmental Noise and recommended that Ldn should not exceed 55 dBA outdoors or 45 dBA indoors to prevent significant acAvity interference and annoyance in noise-sensiAve areas (e.g. residences, schools, hospitals, etc.). 55 dBA was idenAfied as an “adequate margin of safety” for noise level increase relaAve to a baseline noise exposure level of 55 dBA Ldn. The standards set by the EPA’s Federal Noise Control Act are advisory exposure levels below which there would be no risk to a community from any health or welfare effect of noise.

In 1981, EPA administrators determined that subjecAve issues such as noise would be beLer addressed at lower levels of government. Consequently, in 1982 responsibiliAes for regulaAng noise control policies were transferred to State and local governments. However, noise control guidelines and regulaAons contained in EPA rulings in prior years remain in place by designated Federal agencies, allowing more individualized control for specific issues by designated Federal, State, and local government agencies.

San Joaquin County Code
The San Joaquin County Municipal Code establishes noise standards for transportaAon and staAonary noise sources through the implementaAon of its General Plan Public Health and Safety Element (San Joaquin County GP). The following standards are shown below in Table 23: Maximum Noise Exposure Criteria for Sta onary Noise Sources.

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Noise-sensiAve land uses proposed by exisAng or planned staAonary noise sources will require noise exposure miAgaAon if noise levels exceed County thresholds, to ensure staAonary noise sources do not create a constant or periodic noise nuisance in a fixed locaAon.

TABLE 23: MAXIMUM NOISE EXPOSURE CRITERIA FOR STATIONARY NOISE SOURCES Noise Descriptor DayAme (7 AM- 10 PM) NighNme (10 PM- 7 AM.) Hourly Leq 50 45
Lmax 70 65
Notes: Standards are applied at the outdoor acAvity area of the receiving land use. If no outdoor acAvity area is known, the standard shall be applied at the property line of the receiving land use. Each of the criteria shall be reduced by 5 dBA for impulsive noise, tonal noise, or noise consisAng primarily of speech and/or music.

Source: San Joaquin County DEIR 2014, Table 4.H-9.

City of Escalon
The City of Escalon regulates noise impacts within City Limits through its General Plan Noise Element and the City of Escalon Municipal Code.

General Plan Noise Element
The City’s Noise Element outlines policies and standards that will accomplish the City’s main objecAves which include:

A. To protect the ciAzens of the City from the harmful and annoying effects of exposure to excessive noise.

B. To protect the economic base of the City by prevenAng incompaAble land uses from encroaching upon exisAng or planned noise-producing uses.

C. To preserve the tranquility of residenAal areas by prevenAng noise-producing uses from encroaching upon exisAng or planned noise-sensiAve uses.

D. To educate the ciAzens of the City concerning the effects of exposure to excessive noise and the methods available for minimizing such exposure.

E. To emphasize the reducAon of noise impacts through careful site planning and project design, giving second preference to the use of noise barriers and/or structural features to buildings containing noise-sensiAve land uses.

The City of Escalon’s Noise standards indicate that noise levels must be maintained at 55 dBA, CNEL in exisAng residenAal areas. Allowable exterior noise levels of 65 dBA, CNEL if interior levels can be maintained at 45 dBA, CNEL.

Municipal Code
The City of Escalon Municipal Code addresses noise regulaAons and standards in Chapter 8.16 Noise Control. The standards applicable to the proposed Project include the following:
- Sec
on 8.16.020 Prohibited Generally: It shall be unlawful for any person to willfully or knowingly make, conAnue, or cause to be made any loud and raucous noise.
- Sec
on 8.16.030 Enumera
on of public nuisances: The following specific acts, subject to the exempAons provided in EMC 8.16.020, Noises Prohibited Generally, are declared to be public nuisances in violaAon of EMC 8.16.020, namely:

A. The loud and raucous discharge into the open air of the steam of any steam equipment or exhaust from any staAonary internal-combusAon engine;
B. The loud and raucous operaAon or use of any of the following before 7:00 a.m. or aVer 9:00 p.m. daily (except Saturday and Sunday and state or federal holidays, when the prohibited Ame shall be before 8:00 a.m. and aVer 9:00 p.m.). Any construcAon, demoliAon, excavaAon, erecAon, alteraAon, or repair acAvity C. Unless permiLed by an approved condiAonal use permit by the planning commission or otherwise approved by the city planner, outdoor acAviAes that involve the operaAon of commercial vehicles and diesel-operated equipment, other than for the purposes specifically stated in subsecAon F of this secAon, shall be limited to the hours of 7:00 a.m. to 6:00 p.m., Monday through Friday and from 8:00 a.m. to 5:00 p.m. on Saturdays,

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Sundays, or holidays. Warm-up and maintenance acAviAes of said vehicles and equipment are specifically prohibited before or aVer these hours. When considering modificaAon of these hours, the approving body shall consider the factors enumerated in EMC 8.16.020.

Per EMC 8.16.040.E. AcAviAes on or in publicly owned property and faciliAes, or by public employees while in the authorized discharge of their responsibiliAes, are exempt; provided, that such acAviAes have been authorized by the owner of such property or faciliAes or its agent or by the employing authority;

5.13.2 ExisAng CondiAons
ExisAng sensiAve land uses near the Project include single-family residenAal homes along and near Escalon-Bellota Road as close as 40 feet. Other single-family residences close to the Project Components are approximately 105 feet south and southwest of the FCF and approximately 200 feet from the BPS. In addiAon, Escalon High School is located approximately 887 feet southeast of the southernmost porAon of the Project and proposed BPS; Hogan-Ennis Community Park is located as close as approximately 145 feet southwest of the southernmost porAon of the water main and BPS.

ExisAng ambient noise measurements were taken using the American NaAonal Standards InsAtute (ANSI SecAon S1.4 2014 Class 1) Larson Davis model LxT sound meter. Noise measurements consisted of five (5) 15-minute dayAme noise measurements between 1:10 PM and 4:15 PM on June 14th, 2023; one (1) long-term 24-hour noise measurement taken from June 14th, 2023, to June 15th, 2023. See Figure 12: Noise Measurement Overview LocaAon Map for locaAons of each short-term and long-term noise measurement locaAon. Noise measurements indicate exisAng shortterm ambient noise levels are between 54.4 to 77.2 dBA Leq; long-term hourly noise measurement ambient noise levels range from 58.9 to 72.1 dBA Leq. Prominent noise sources in the Local Vicinity derived from train acAvity and vehicular traffic along Escalon-Bellota Road, Dodds Road, and Mariposa Road.

5.13.3 Project Impacts
a) GeneraAon of a substanAal temporary or permanent increase in ambient noise levels in the vicinity of the Project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies?
RESPONSE:

Less than Significant with MiAgaAon Incorporated.

Construc
on Noise
ConstrucAon Noise sources are regulated within SecAon 8.16.030(F)(7) of the City of Escalon’s Municipal Code, which prohibits the loud and raucous operaAon or use of construcAon equipment outside of the hours between 7:00 AM and 9:00 PM daily except on Saturday, Sunday, and state or federal holidays in which the hours are between 8:00 AM and 9:00 PM. Therefore, the Project impacts will be significant if construcAon noise sources do not comply with SecAon 8.16.030(F)(7). However, the Project will comply with City Ordinance 8.16.030(F)(7); therefore, construcAon impacts are anAcipated to be consistent with applicable plans and policies and impacts would technically be less than significant under CEQA.

Noise levels during Project construcAon were calculated using the Federal Transit AdministraAon (FTA) Transit Noise and VibraAon Impact Assessment Manual (2018) in addiAon to key construcAon parameters including distance to each sensiAve receptor, equipment usage, percent usage factor, and baseline parameters for the locaAon of each Project component. The FTA considers Project impacts to be significant if construcAon noise levels exceed 80 dBA Leq for an 8-hour period at residenAal and noise-sensiAve outdoor areas. For each construcAon phase, noise levels were modeled uAlizing typical construcAon equipment and typical usage factors from the Federal Highway AdministraAon (FHWA) Roadway ConstrucAon Noise Model User’s Guide (2006) based on anAcipated construcAon equipment (see Sec
on 3.0 Project Descrip
on, Project Elements- Construc
on
Equipment). Modeling results are shown within Table 24: Construc on Noise Levels by Loca
on (dBA Leq) and
indicate various construcAon phases including excavaAon, pipeline installaAon, backfill and resurfacing, striping,

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and resurfacing, fencing/restoraAon, tank construcAon, and equipped/ pumps/ piping/ values are anAcipated to exceed 80 dBA at the nearest sensiAve receptor.

TABLE 24: CONSTRUCTION NOISE LEVELS BY LOCATION (dBA Leq) LocaAon ConstrucAon Phase Noise Level at 50
feet (Dba Leq)
Distance to Nearest
SensiAve Receptor
Total Noise Level at Nearest
SensiAve Receptor
Tie-In at Dodds
Road
Site PreparaAon 85.2 284 79.5
ExcavaAon 86.1 284 80.4
ExisAng Pipe Cut-in 83.5 284 77.8
Backfill and Resurfacing 87.0 284 81.3
Striping/ Restriping 83.4 284 77.7
Pipeline
InstallaAon
DemoliAon 86.3 30 85.8
Pipeline InstallaAon 87.4 30 86.9
Backfill and Resurfacing 87.0 30 86.5
Striping/ Restriping 83.4 30 82.9
FCF
Clear and Grub 85.5 20 83.9
ExcavaAon 86.1 20 84.5
Piping and Valves 86.3 20 84.7
Backfill and Resurfacing 87.0 20 85.4
Fencing/ RestoraAon 85.1 20 83.5
BPS
DemoliAon 86.3 70 86.1
ExcavaAon 86.1 70 85.9
Tank ConstrucAon 88.11 70 87.9
Equipping Pumps/ Pipes/
Valves

86.6 70 86.4
Backfill 87.0 70 86.8
Fencing/ RestoraAon 85.1 70 84.9
Source: Noise Impact Analysis, Ganddini 2023 (Appendix D)

Due to anAcipated noise levels during Project construcAon, MiAgaAon Measure MM NOI-01: ConstrucAon Noise ALenuaAon shall be implemented. MiAgaAon Measure MM NOI-01: ConstrucAon Noise ALenuaAon will require construcAon equipment to be equipped with mufflers, and noise shields, and directed away from sensiAve receptors to limit noise levels during construcAon acAviAes.

AddiAonally, noise associated with construcAon-related vehicle trips is anAcipated. The Air Quality, Greenhouse Gas, and Energy Technical Memorandum (Appendix A) indicated the greatest number of construcAon-related vehicle trips per day would be a maximum of up to 102 vehicle trips per day (98 worker trips, and 14 hauling trips). Traffic counts along Escalon-Bellota Road, where the water main will be installed, range between 2,769 and 8,457 average daily trips (ADT)6. The lower end of the exisAng counts was used for modeling purposes in order to show the greatest possible increase in noise levels due to Project-generated vehicle traffic. Roadway noise levels were calculated for the following scenarios:
- ExisAng (without Project): This scenario refers to the exisAng year traffic noise condiAons. - ExisAng Plus Project ConstrucAon: This scenario refers to the exisAng year plus Project construcAon traffic noise condiAons.

Modeling results show that exisAng noise levels along Escalon-Bellota Road are 65.5 dBA CNEL and exisAng plus Project noise levels would be 65.7 dBA CNEL. The proposed Project would result in a noise increase of less than one decibel, which is equivalent to typical rapid transit; according to San Joaquin County a “substanAal increase” in noise would be an increase in Leq of 12 dB during peak hours of traffic noise (SJ RTP/SCS DraV EIR 2014).

Therefore, impacts would be less than significant. No miAgaAon measures are required.

6 San Joaquin County GIS, hLps://sjc-gis.maps.arcgis.com/apps/webappviewer/index.html?id=b031e6e5a21b4c039643eddcb8a13fc3

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Sta
onary Source Noise
As menAoned above, the City of Escalon’s General Plan indicates that operaAonal noise from staAonary noise sources is considered significant if exterior noise exceeds 65 dB Ldn (or CNEL) and interior noise exceeds 45 dB Ldn (or CNEL) within the interior living spaces of sensiAve receptors. Several noise sources are proposed as a result of the Project; at the FCF, the 10-12 kW propane generator, which was modeled assuming the generator would operate 24 hours a day, and at the BPS, noise sources include a diesel generator, a 25Hp pump, three 50 Hp pumps, and an HVAC condenser7.

FCF
At the FCF, the 10-12 kW propane generator is anAcipated to be located approximately 55 feet from the southern property line shared with the exisAng residenAal land use. Therefore, noise levels from the southern property line as a result of the propane generator are anAcipated to reach up to 64 CNEL, assuming the generator will be operaAonal 24/7. Noise associated with the propane generator will not exceed the City’s established exterior noise standard of 65 dBA CNEL. In addiAon, the residenAal property is located approximately 50 feet further south from the shared property line, the residenAal property is 105 feet from the proposed locaAon of the propane generator. As a result, interior noise levels are anAcipated to be approximately 38 CNEL; exterior noise levels at the house would be 58 CNEL, but residenAal construcAon provides 20 dB of exterior-to-interior sound reducAon with windows closed. Since the Project’s operaAonal interior noise levels are below the City’s interior goal of 45 CNEL for sensiAve receptors, impacts are considered to be less than significant. No MiAgaAon Measures are anAcipated as a result of the FCF operaAonal noise levels.

BPS
Two operaAonal noise scenarios were calculated 1) normal demand and 2) high demand. Normal demand assumes that only one 25 HP pump is uAlized, and high demand assumes all four pumps (one 25-HP pump and three 50 HP pumps) are uAlized. Modeling indicated exterior noise levels would range from 56 and 74 CNEL at sensiAve receptor property lines under normal demand and between 58 and 76 CNEL at sensiAve receptor property lines during high demand, see Table 25: Opera
onal Exterior Noise Levels at Sensi
ve Receptor Property
Lines. Since the City’s exterior noise level criteria of 65 CNEL under both scenarios will be exceeded, miAgaAon is required. For this reason, the Project design shall incorporate MiAgaAon Measure MM NOI-02: StaAonary Source Noise, which provides opAons for achieving 65 CNEL via equipment with specific sound pressure levels, noise aLenuaAon structures, etc. Impacts on exterior noise levels will be less than significant with the implementaAon of MiAgaAon OpAon 1 (for both normal and high demand) OR with the implementaAon of either MiAgaAon OpAon 2 or 3.

TABLE 25: OPERATIONAL EXTERIOR NOISE LEVELS AT SENSITIVE RECEPTOR PROPERTY LINES Receptor Equipment QuanAty
Noise
Reference
Level Dba,
Leq1
CNEL
Normal Demand2 High Demand4
Total
Equipment
Sound
Levels
MiAgated
Total
Equipment
Sound
Levels3
Total
Equipment
Sound
Levels
MiAgaAon
OpAon 1
Total
Equipment
Sound
Levels
MiAgaAon
OpAon 2
Total
Equipment
Sound
Levels
MiAgaAon
OpAon 3
Total
Equipment
Sound
Levels
FCF
Receptor 1 12-kW Kohler Propane
Generator (Model
#RESV(L))
1 65 at 23 V 64 n/a 64 n/a n/a n/a
BPS
Receptor 1 Diesel Generator 1 73 at 21 V 74 65 76 65 65 65 25 Hp Pump 1 80 at 3 V 7 Combined noise levels were modeled using SoundPLAN Noise Model. The SoundPLAN soVware allows the user to input specific noise sources spectral content, sound barriers, building placement, topography, and sensiAve receptor locaAons.

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50 Hp Pump 3 85 at 3 V
HeaAng and VenAlaAon
Unit Condenser 1 62 at 3 V
Receptor 2
Diesel Generator 1 73 at 21 V
61 51 62 52 57 62
25 Hp Pump 1 80 at 3 V
50 Hp Pump 3 85 at 3 V
HeaAng and VenAlaAon
Unit Condenser 1 62 at 3 V
Receptor 3
Diesel Generator 1 73 at 21 V
67 56 68 56 65 65
25 Hp Pump 1 80 at 3 V
50 Hp Pump 3 85 at 3 V
HeaAng and VenAlaAon
Unit Condenser 1 62 at 3 V
Receptor 4
Diesel Generator 1 73 at 21 V
56 47 58 47 58 58
25 Hp Pump 1 80 at 3 V
50 Hp Pump 3 85 at 3 V
HeaAng and VenAlaAon
Unit Condenser 1 62 at 3 V
Source: Noise Impact Analysis, Ganddini 2023 (Appendix D) Notes: 1) Provided by equipment manufacturers.
2) Normal Demand includes the 25 HP pump only
3) Diesel generator shall not exceed 90 Lw. 25 Hp pump shall not exceed 88 Lw. The HVAC condenser shall not exceed 70 Lw. 50Hp pumps shall not exceed 72 Lw.
4) High demand includes operaAons of all the pumps at the same Ame.

The exisAng house located on an adjacent residenAal parcel that would be affected by noise associated with the pump staAon is located 180 feet northwest of the proposed pumps. The exterior noise level at the house would be 61 CNEL without miAgaAon during normal demand, and up to 62 CNEL during high demand. However, typical residenAal construcAon provides 20 dB of the exterior to interior sound reducAon with the windows closed (assuming HVAC is provided). Therefore, interior noise levels would be approximately 42 CNEL, and pump staAon operaAonal noise would not exceed the City’s interior noise standard of 45 dBA CNEL. This impact would be less than significant, and no miAgaAon is required.
b) GeneraAon of excessive groundborne vibraAon or groundborne noise levels? RESPONSE:

Less than Significant Impact. The City of Escalon does not have a City-established numerical threshold of significance for groundborne vibraAon. Therefore, groundborne vibraAon impacts are based on guidance from the Federal Transit AdministraAon (FTA) Transit Noise and VibraAon Impact Assessment Manual (FTA 2018). The FTA threshold indicates potenAal to cause architectural damage at the nearby buildings will occur if the Project exceeds the following PPV:
- 0.10 in-sec at buildings extremely suscepAble to vibraAon damage - 0.20 in/sec at non-engineered Amber and masonry buildings - 0.30 in/sec at engineered concrete and masonry (no plaster) buildings - 0.50 in/sec at reinforced concrete, steel, or Amber (no plaster) buildings The closest structure to the proposed construcAon is a single-family residenAal home located approximately 40 feet from the proposed water main, northeast of the Escalon-Bellota Road and Lone Tree Road intersecAon.

ConstrucAon equipment with the highest vibratory potenAal are plate compactors. The peak parAcle velocity (PPV) per square foot associated with these vibratory plates is 0.21 at a distance of 25 feet (See Table 26:

Construc
on Equipment Vibra
on Sources Levels). Vibratory plates are expected to be uAlized within 25 feet of an exisAng structure. Other equipment anAcipated to be used during construcAon generates lower PPV.

Therefore, groundborne vibraAon generated by Project construcAon would not exceed the levels necessary to cause architectural damage.

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TABLE 26: CONSTRUCTION EQUIPMENT VIBRATION SOURCE LEVELS Equipment PPV at 25 V, in/sec Approximate Lv* at 25 V
Pile Driver (impact) Upper range 1.518 112
typical 0.644 104
Pile Driver (sonic) Upper range 0.734 105
typical 0.170 93
Clam shovel drop (slurry well) 0.202 94
Hydromill (slurry wall) In soil 0.008 66
In rock 0.017 75
Vibratory Roller 0.210 94
Hoe Ram 0.089 87
Large Bulldozer 0.089 87
Cassion Drilling 0.089 87
Loaded Trucks 0.076 86
Jackhammer 0.035 79
Small Bulldozer 0.003 58
Source: Noise Impact Analysis, Ganddini 2023 (Appendix D) Notes: Based on Federal Transit AdministraAon Transit Noise and VibraAon Impact Assessment Manual, 2018. *RMS velocity in decibels, VbB re 1 micro-in/sec
The potenAal for construcAon equipment to exceed the threshold of annoyance due to vibraAon is possible. As a result, the closest sensiAve receptors to the proposed Project Components may experience temporary annoyances; however, construcAon vibraAon is anAcipated to be temporary and intermiLent throughout construcAon acAviAes. In addiAon, annoyances will only occur if equipment is uAlized within 21 feet of a structure.

Since the closest structures are 40 feet from construcAon acAviAes, impacts are less than significant. No MiAgaAon Measures are needed.

Sources of groundborne vibraAon during long-term Project operaAons will occur from passenger vehicles and trucks along the paved Escalon-Bellota Road. Loaded trucks have a PPV of 0.076 at a distance of 25 feet (CalTrans 2020), which is substanAally lower than most construcAon equipment including the vibratory roller (0.210 in/sec PPV at 25 feet). As a result, groundborne vibraAon levels generated by Project operaAons will not exceed those modeled for Project construcAon. Impacts are anAcipated to be less than significant, and no MiAgaAon Measures are proposed.
c) For a Project located within the vicinity of a private airstrip or 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 expose people residing or working in the Project area to excessive noise levels? RESPONSE:

No Impact. There are no airports within two miles of the project site. Therefore, the proposed Project would not expose people residing or working in the area to excessive noise levels. There is no impact, and no miAgaAon is required.

5.13.4 MiAgaAon Measures
MM NOI-01: ConstrucAon Noise ALenuaAon1. During all Project Site excavaAon and grading, construcAon contractors shall equip all construcAon equipment, fixed or mobile, with properly operaAng and maintained mufflers, consistent with manufacturer standards.

2. The contractor shall place all staAonary construcAon equipment so that emiLed noise is directed away from the noise-sensiAve receptors nearest the project site. One-inch plywood or acousAc blankets capable of achieving a reducAon level of at least 10 dB shall be used to keep equipment noise from exceeding the 80 dBA noise level standard.

3. Equipment shall be shut off and not leV to idle when not in use.

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4. Whenever possible, electric power will be used instead of internal combusAon engine power.

5. The contractor shall locate equipment staging in areas that will create the greatest distance between construcAon-related noise/vibraAon sources and sensiAve receptors nearest the Project Site during all project construcAon.

6. Jackhammers, pneumaAc equipment, and all other portable staAonary noise sources shall be shielded, and noise shall be directed away from sensiAve receptors.

7. The Project proponent shall mandate that the construcAon contractor prohibit the use of music or sound amplificaAon on the Project Site during construcAon.

8. The construcAon contractor shall limit haul truck deliveries to the same hours specified for construcAon equipment.

MM NOI-02: StaAonary Source NoiseOpAon 1
Prior to Project construcAon, the Project contractor and the City of Escalon shall verify with sound measurements that the 125-kW diesel generator does not exceed 82 dB at 3 feet or a sound power level of 90; along with the proposed 25 Hp with a sound pressure level of 80 dB at 3 feet (sound power level of 88) and the proposed HVAC condenser with a sound pressure level of 62 dB at 3 feet (power level of 70). See Figure 13: BPS OperaAonal Noise Levels.

In addiAon, to ensure that operaAonal noise levels do not exceed 65 CNEL during high demand, the Project contractor and City engineers shall require (measure, confirm, and monitor during site inspecAons) on an ongoing basis each 50 Hp pump does not have a noise level that exceeds 64 dB at a distance of 3 feet (sound power level of 72). See Figure 13: BPS OperaAonal Noise Levels.

OR
OpAon 2
Prior to the issuance of building and grading permits, the City of Escalon engineering department shall verify Project plans including the construcAon of a 10-foot-high concrete barrier along the northern edge of the pad proposed for the pumps and a 7-foot-high barrier along the eastern boundary of the BPS. See Figure 13: BPS OperaAonal Noise Levels.

OR
OpAon 3
Prior to the issuance of building and grading permits, the City of Escalon engineering department shall verify Project plans including the construcAon of an 8-foot-high concrete barrier along the northern boundary of the exisAng parking lot and a 6-foot barrier along the eastern edge of the pump area pad, parallel to Escalon-Bellota Road. Figure 13: BPS OperaAonal Noise Levels.

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5.14 POPULATION AND HOUSING
Issues
PotenAally
Significant Impact
Less than Significant
Impact with
MiAgaAon
Incorporated
Less than Significant
Impact No Impact
XIV. POPULATION AND HOUSING. Would the Project:
a) Induce substanAal unplanned
populaAon growth in an area,
either directly (for example,
by proposing new homes and
businesses) or indirectly (for
example, through extension
of roads or other
infrastructure)?
b) Displace substanAal numbers
of exisAng people or housing,
necessitaAng the
construcAon of replacement
housing elsewhere?

5.14.1 Regulatory Compliance
Regional Housing Needs Plan (RHNP)
The 2023-2031 RHNP was adopted by SJCOG and approved by the California Department of Housing and Community Department pursuant to the Housing Element Law of Government Code SecAon 65580. The RHNP establishes the number of housing units for various income levels that a city or county in California must plan for. The RHNP applies to housing within ciAes and counAes throughout the State. CiAes and unincorporated San Joaquin County must plan for housing needs at various income levels idenAfied within the RHNP during the specified planning period. The RHNP establishes methodology and objecAves to assist local jurisdicAons in meeAng regional housing needs.

San Joaquin County
Housing Element
Pursuant to the State Housing Element Law, San Joaquin County created a Housing Element that adequately addresses ways to meet projected housing needs for all socioeconomic segments of the community based on the SJCOG RHNP.

San Joaquin County’s Housing Element also evaluates the progress made since the housing element was last adopted in 2010.

5.14.2 ExisAng CondiAons
Since the year 1920, San Joaquin County’s populaAon has increased by approximately 159% (79,905 residents in 1970; 710,731 residents in 2014). From 2010 to 2014, San Joaquin County’s populaAon increased by 0.9%, which is above the State average of 0.7% (SJ Housing Element 2015). PopulaAon growth is expected to conAnue into 2035, with projecAons showing a 1.5% increase in total populaAon every 5 years (See Table 7-9 SJCOG Popula on Projec
ons, SJ
Housing Element 2015). The City of Escalon is amongst the few ciAes within the County that receive moderate growth (approximately 1.8%) but conAnues to maintain a populaAon under 50,000 residents.

According to Escalon’s Water Master Plan, the esAmated populaAon for 2005 through 2025 is anAcipated to be approximately 11,950 residents, which will require an addiAonal 382 acres for future built-out (Escalon Water Master Plan 2007). As of 2020, the City of Escalon has a total populaAon of 7,523 residents. Therefore, falling behind on anAcipated growth projecAons.

As menAoned within SJCOG’s 2023-2031 RHNP, San Joaquin County needs a total of 52,719 units (21,637 units designated to lower income; 31,082 designated to higher income) to meet future demands. Within Escalon 367 units need to be allocated (146 units designated to lower income; 221 units designated to higher income).

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5.14.3 Project Impacts
a) Induce substanAal unplanned populaAon growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)? RESPONSE:

No Impact. PopulaAon within the City of Escalon and County of San Joaquin are indicated to increase consistently pursuant to each jurisdicAon’s approved General Plan. Increases within these local jurisdicAons mirror similar growth paLerns that are also expected throughout the state into the future. The rate of populaAon growth within the City is less that what was anAcipated in the City’s General Plan and is less than the rate of growth in the County. The City’s populaAon was expected to reach 11,950 residents by 2025; however, the current populaAon of the City of Escalon is 7,523.

The proposed Project will complete the City of Escalon’s surface water turnout to deliver treated surface water from the SSJID transmission line on Dodds Road; the Project will supply treated surface water to the City via this new connecAon between the City of Escalon’s water system within City Limits and SSJID’s regional water distribuAon system that is intended to deliver water from the Stanislaus River to local ciAes within the SSJID service area. The Project is a proposed improvement within the City’s Water Master Plan and will be completed pursuant to the SSJID SCSWSP Water Supply Development Agreement of 1999. The Agreement was made with SSJID amongst the CiAes of Escalon, Manteca, Lathrop, and Tracy acknowledging the “delivery of treated surface water is needed to supplement the municipal and industrial water supplies of these communiAes” which rely on groundwater (Escalon Water Master Plan 2007). The Agreement intends to increase the reliability of the water distribuAon network for the City of Escalon as well as support sustainably managed groundwater resources within the San Joaquin Valley.

As a result of the Project’s consistency with the SSJID SCSWSP Water Supply Development Agreement and the City of Escalon’s Water Master Plan, the proposed Project is not anAcipated to result in unplanned populaAon growth by either implemenAng new homes or businesses or indirectly extending infrastructure. Therefore, impacts are not anAcipated, and no MiAgaAon Measures are needed. b) Displace substanAal numbers of exisAng people or housing, necessitaAng the construcAon of replacement housing elsewhere?
RESPONSE:

No Impact. The Project will install a connecAon, turnout, FCF, BPS, storage tank and 19,500 LF of water main within public t right-of-way along Escalon-Bellota Road. The FCF, storage tank, wet well, and BPS will be located on land that does not require the removal of exisAng buildings. In addiAon, the Project alignment and Project Components will be located on the City’s public right-of-way; therefore, Project implementaAon does not anAcipate displacement of substanAal numbers of exisAng people or housing developments.

The Project will increase the reliability of the water distribuAon networks and reduce reliance on groundwater in order to accommodate water quality standards and service requirements as well as eventually achieve planned growth projected within the Escalon City Limits that is indicated in the City’s approved General Plan. For these reasons, no impacts related to the displacement of substanAal numbers of exisAng people or housing, necessitaAng the construcAon of replacement housing elsewhere is not anAcipated to occur. MiAgaAon Measures are not needed.

5.14.4 MiAgaAon Measures
No MiAgaAon Measures are required.

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5.15 PUBLIC SERVICES
Issues

PotenAally
Significant Impact
Less than Significant
Impact with
MiAgaAon
Incorporated
Less than Significant
Impact No Impact
XV. PUBLIC SERVICES. Would the Project:
a) Result in substanAal adverse
physical impacts associated
with the provision of new or
physically altered
governmental faciliAes, need
for new or physically altered
governmental faciliAes, the
construcAon of which could
cause significant
environmental impacts, to
maintain acceptable service
raAos, response Ames, or
other performance
objecAves for any of the
public services:
i. Fire ProtecAon?
ii. Police ProtecAon?
iii. Schools?
iv. Parks?
v. Other public faciliAes?

5.15.1 Regulatory Compliance
Fire Services
Fire protecAon and emergency services are provided by The Escalon Consolidated Fire ProtecAon District (ECFPD), a combined iniAaAve from both the City of Escalon and the County of San Joaquin to ensure maximum fire protecAon.

The District was founded in 1912 and serves the southeast porAon of San Joaquin County, approximately 65 square miles of primarily agricultural land. Escalon Fire provides emergency response services including Emergency Medical Services (EMS), vehicle fires, vegetaAon fires, motor vehicle accidents, structure fires, fire alarms, and public safety assistance (Escalon Fire 2023).

Police Services
Law enforcement services are provided within the City of Escalon. The Escalon Police Department strives to communicate with community members and visitors through their working partnerships and quality service. The goal of the Department is to preserve and improve the quality of life for the community members that they serve (Escalon Police Department Website 2023).

SSJID
SSJID was established in 1909 to provide a “reliable and economical source of irrigaAon water for agricultural areas in and around Escalon, Manteca, and Ripon” (SSJID Website 2023). By extending water service within these areas, SSJID gave life to the region, assisAng in the delivery of water services to 70,000 acres of producAve farmland (SSJID 2023).

Today, the District provides water services to approximately 1,943 parcels. The District shares “pre-1914 water rights on the Stanislaus River” with the neighboring District, OID; water is diverted via canals, ditches, and pipelines (SSJID Water Master Plan 2022).

City of Escalon
The City of Escalon evaluates the environmental impact of Public Services and FaciliAes within their General Plan EIR.

The evaluaAon provided within the EIR ensures that the City has sufficient levels of public services as Escalon anAcipates growth. The City is required to provide sufficient public services including parkland pursuant to the Quimby

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Act; and school/ school districts pursuant to the California EducaAon Code. The City regularly evaluates the adequacy of services by establishing a land use plan that incorporates insAtuAonal public services and faciliAes through in-lieu fees paid at the Ame of discreAonary permit issuance for implementaAon and maintenance of public services.

5.15.2 ExisAng CondiAons
Fire Services
The Project is within the bounds of the ECFPD. The ECFPD provides fire protecAon, emergency medical, hazardous materials, and other services to residents and businesses within its area of service. Within the City of Escalon, there are two staAons. StaAon 1 is located on 1749 Coley Avenue, Escalon, CA 95320, approximately 1 mile from the proposed BPS, storage tank, and wet well and adjacent to the heart of Escalon’s downtown. Currently, there are seven full-Ame acAve firefighters working in this staAon with an addiAonal four volunteer firefighters and eight reserve personnel. StaAon 62 is located northwest of the Project Site, approximately 3.3 miles southwest of the proposed BPS, storage tank, and wet well at 17950 South Van Allen Road. The closest fire hydrant is along the eastern perimeter of Escalon-Bellota Road, approximately 500 feet from the proposed BPS, storage tank, and wet well.

Police Protec
on
The City of Escalon Police Department will provide police protecAon to the Project. The closest police staAon to the Project is located on McHenry Avenue, approximately 1.1 miles from the proposed BPS, storage tank, and wet well facility. Response Ames to calls within City Limits are on average two minutes for emergency calls and 5 to 10 minutes for non-emergency calls (Escalon General Plan EIR 2005).

Schools
The Project is within the Escalon Unified School District (EUSD). The closest school to the Project is located near Escalon’s downtown area, approximately 887 feet north of the Project Site. Escalon High School is located south of the proposed BPS, storage tank, and wet well, along Escalon-Bellota Road. As menAoned within SecAon 5.9.3, Response c), 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).

Parks
Parks near the Project include Escalon Dinosaur Park (approximately 250 feet west) and Hogan-Ennis Community Park (100 feet east) of the proposed BPS, storage tank, and wet well.

SSJID Facili
es
The closest exisAng faciliAes owned and operated by SSJID to the Project Alignment are the 48-inch transmission main along Dodds Road that connects from the WTP in the east.

5.15.3 Project Impacts
a) Result in substanAal adverse physical impacts associated with the provision of new or physically altered governmental faciliAes, need for new or physically altered governmental faciliAes, the construcAon of which could cause significant environmental impacts, in order to maintain acceptable service raAos, response Ames, or other performance objecAves for any of the public services:
i. Fire ProtecAon?
RESPONSE:

Less than Significant with MiAgaAon Incorporated. During construcAon an approved traffic control plan will be followed pursuant to the City’s Standard SpecificaAons and Modified MM TRAF-01: Traffic Control Plan. This will allow services to funcAon as usual and would reduce conflicts and delays from construcAon within the public right-of-way to the Fire and Police Department response during construcAon. As a result, less than significant impacts are expected during construcAon on fire and police services. The closest Fire StaAon is StaAon 1, which is approximately 1 mile south of the proposed BPS site. The Project will be constructed and tested prior to the permanent connecAon at the Ae-in at Dodds Road so that

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adequate water pressure for potable deliveries and emergency response within the surrounding area will be achieved.

The Project does not propose or indirectly contribute to increased populaAon or density that would require an addiAonal fire staAon, equipment, or staff over the long term. Likewise, the Project would not to change land use resulAng in an increased need for fire response beyond what has already been idenAfied in the City’s approved Water Master Plan and General Plan. The standard applicaAon of the City’s plan check, inspecAon, and design criteria will verify the implementaAon of fire protecAon performance objecAves for the Project and facilitate fire protecAon within the Local Vicinity.

For these reasons, impacts are considered less than significant with MiAgaAon incorporated. ii. Police ProtecAon?
RESPONSE:

Less than Significant with MiAgaAon Incorporated. See SecAon 5.15.3, Response a) i. Since the Project is a part of the Water Master Plan, intended to benefit the City’s public works faciliAes, the Project will not impact the level of police protecAon at the Project. The Project does not propose to increase populaAon or change land use.

During construcAon, an approved traffic control plan will be followed pursuant to the City’s Standard SpecificaAons and Modified MM TRAF-01: Traffic Control Plan. This will allow services to funcAon as usual, and access will remain open throughout the areas of disturbance and along the Project Alignment.

ImplementaAon of the approved traffic control plan by the contractor is intended to provide adequate and safe access pursuant to city standards, which is expected to be adequate for law enforcement. Upon compleAon of construcAon, road and sidewalk surfaces will be returned to pre-Project condiAons. Areas where permanent above-ground structures will be implemented will be fenced and gated; onsite security will be installed. The proposed Project will not permanently increase populaAon or change land use resulAng in an increased need for police services either directly or indirectly.

Less than significant long-term impacts on police protecAon are expected. Short-term impacts will be miAgated by a traffic control plan; therefore, impacts are anAcipated to be less than significant with MiAgaAon incorporated.
iii. Schools?
RESPONSE:

Less than Significant with MiAgaAon Incorporated. Within the downtown region, El Portal Middle School, Dent Elementary School, and Escalon High School are located within blocks of one another. As menAoned in SecAon 5.15.2 ExisAng CondiAons, the Project is closest to Escalon High School, approximately 887 feet south of the proposed BPS site. Walking and biking during Project construcAon may be temporarily impacted along Escalon-Bellota Road, therefore the traffic control plan contains provisions for pedestrians and bicyclists to gain access during construcAon. In addiAon, MiAgaAon Measure Modified MM TRAF-02: Coordinate Traffic Plan with EUSD shall be implemented throughout Project construcAon to ensure that the traffic control plan has been reviewed by the District to avoid construcAon conflicts along local roadways during pick-ups and drop-offs.

AddiAonally, the Project will not increase populaAon or density either directly or indirectly within the planning area; therefore, the project will not result in changes to school enrollment. Due to the Project’s proximity to the closest educaAonal faciliAes and the implementaAon of a traffic control plan under Modified MM TRAF-01: Traffic Control Plan and Modified MM TRAF-02: Coordinate Traffic Plan with EUSD. As a result of the proposed MiAgaAon Measures, Project construcAon will not conflict with or directly impact these schools during peak hours for drop-off and pickup.

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As a result, less than significant impacts are anAcipated with the incorporaAon of MiAgaAon Measures Modified MM TRAF-01: Traffic Control Plan and MM PUB-01: CoordinaAon with Local School District for Traffic Control.
iv. Parks?
RESPONSE:

Less than Significant with MiAgaAon Incorporated. See SecAon 5.15, Responses a) i through iii. The Project does not propose to change land use resulAng, either directly or indirectly, in an increase in density or populaAon that would affect park use. However, the BPS site is proposed within the southeastern corner in a 0.15 (6,400 square feet) acre area that was planned within Phase Two of the Hogan-Ennis Community Park expansion. Project implementaAon will convert approximately 0.15 acres of parkland to public right-of-way for a uAlity. However, according to the City’s Final GP EIR, the City’s suggested raAo of 5 acres per 1,00 populaAon is exceeded and saAsfies future growth needs (City of Escalon GP FEIR, 2005). Therefore, the allocaAon of 0.15 acres of parkland for a public uAlity is anAcipated to have negligible impacts on the City’s parkland.

The Project is planned to be constructed within the County and City right-of-way; therefore, an approved traffic control plan will be implemented in compliance with City Standard SpecificaAons pursuant to Modified MM TRAF-01: Traffic Control Plan. As a result, access to exisAng parkland adjacent to Project Components is not anAcipated to be impacted by Project construcAon. Upon compleAon of construcAon, the project will be fenced and gated; therefore, the long-term use of recreaAonal faciliAes will not be changed as a result of Project implementaAon.

Therefore, less than significant impacts are anAcipated with the incorporaAon of MiAgaAon Measures. v. Other public faciliAes?
RESPONSE:

No Impact. Proposed Project Components are located directly north of Escalon City Limits, adjacent to agricultural land uses and away from other public faciliAes. Therefore, construcAon is not anAcipated to result in the closure of public faciliAes in the City of Escalon.

Proposed improvements are consistent with the County Water Management Plan and City Water Master Plan as part of the SCSWSP. As a result, no impacts are anAcipated to other public faciliAes within the County or City of Escalon due to Project implementaAon. MiAgaAon Measures are not required.

5.15.4 MiAgaAon Measures
See applicable MiAgaAon Measures modified from SCSWSP, Modified MM TRAF-01: Traffic Control Plan and Modified MM TRAF-02: Coordinate Traffic Plan with EUSD within SecAon 5.17.4- TransportaAon MiAgaAon Measures.

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5.16 RECREATION
Issues

PotenAally
Significant Impact
Less than Significant
Impact with
MiAgaAon
Incorporated
Less than Significant
Impact No Impact
XVI. RECREATION.
a) Would the Project increase
the use of exisAng
neighborhood and regional
parks or other recreaAonal
faciliAes such that substanAal
physical deterioraAon of the
facility would occur or be
accelerated?
b) Does the Project include
recreaAonal faciliAes or
require the construcAon or
expansion of recreaAonal
faciliAes which might have an
adverse physical effect on the
environment?

5.16.1 Regulatory Compliance
The Quimby Act
The Quimby Act of 1965, SecAon 66477 of the California Government Code, enables local governments, ciAes, or counAes to require the dedicaAon of land or impose a requirement of the payment of the in-lieu fees during the subdivision process to miAgate increased demand for parks and use of parks due to populaAon growth associated urbanizaAon. Park-in-lieu fees are collected based on development size and the fees are used to purchase land for recreaAonal use and develop or rehabilitate parks within the community. Quimby Act requirements establish minimum acreage requirements for parks per capita, 3 acres of park area per 1,000 persons unless the park acreage of a municipality exceeds that standard, in which case the maximum dedicaAon is five acres per 1,000 residents (San Joaquin County GP EIR, 2014).

City of Escalon Ordinances
The proposed Project is subject to compliance with the City of Escalon’s Municipal Code. Since the Project is an infrastructure improvement that was considered in the City’s Water Master Plan and General Plan, the Project would not directly generate increased populaAon or demand for recreaAon or parks. Current City standards require five acres of parkland per 1,000 residents; one acre per thousand to be developed for mini-parks, 3 acres per 1,000 for neighborhood parks, and 1 acre per thousand for regional parks (Escalon General Plan EIR 2005). There are no deficiencies in parkland per capita within the City.

Plans within the City Limits include the expansion of Hogan-Ennis Community Park. The site of the proposed BPS, subterranean storage tank, and wet well is on land owned by the City of Escalon that has been planned and approved for future development of a porAon of the Hogan-Ennis Community Park expansion, Phase Two. Hogan-Ennis Community Park Project is part of the City’s CIP. The City of Escalon plans to expand the park into parcels that were previously uAlized for agriculture and are currently vacant and located northeast and north of the exisAng park within unincorporated San Joaquin County. These parcels are designated under the County’s General Plan for AgriculturalUrban Reserve (AU).

Future Improvements are planned to be implemented in three phases of park development are listed in Table 3:

Hogan-Ennis Community Park CIP Phases. The Project is part of Phase Two, located in an area planned for a skatepark.

The phases and park improvements are summarized in Table 3: Hogan-Ennis Community Park CIP Phases & Figure 6:

Master Plan of Hogan-Ennis Community Park.

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5.16.2 ExisAng CondiAons
San Joaquin County contains over 2,800 acres of regional and local parkland (San Joaquin County GP EIR 2014). Within Escalon’s City Limits and SOI, park/ open space accounts for approximately 82 acres. According to the City’s Final GP EIR, the City’s suggested raAo of 5 acres per 1,000 populaAon is exceeded and saAsfies future growth needs (City of Escalon GP FEIR, 2005). The closest parks to the Project within the Escalon City Limits, consist of Escalon Dinosaur Park, approximately 250 feet northwest, and Hogan-Ennis Community Park, approximately 100 feet southeast of the proposed BPS, storage tank, and wet well.

5.16.3 Project Impacts
a) Would the Project increase the use of exisAng neighborhood and regional parks or other recreaAonal faciliAes such that substanAal physical deterioraAon of the facility would occur or be accelerated? RESPONSE:

Less than Significant Impact. Project implementaAon is considered in the approved General Plan and Water Master Plan for the City of Escalon, as well as regional water plans and programs for groundwater sustainability.

The Project would not generate long-term employment, new housing units, or increase the local populaAon.

Therefore, Project implementaAon will not increase the use of exisAng parks or the demand for new parks.

The Project proposes to implement a compact design for a tank, wet well and BPS within approximately 9,600 square feet; this infrastructure will be installed within the northeastern corner of the planned Hogan-Ennis Community Park expansion, at the northeast corner of the master plan area. Due to the proposed locaAon and size of the Project faciliAes at this locaAon it is not expected to conflict with the overall use of the exisAng or future park. The Project will be adjacent to the west of the paved right-of-way for Escalon-Bellota Road. The Hogan-Ennis Park expansion is an approved CIP project within the City of Escalon that was iniAally planned for 2019-20; however, the CIP project is sAll part of future planning projects within the CIP. The CIP project will extend exisAng Hogan Park to the north and east of the developed park boundaries, within the City’s SOI to include passive and acAve park spaces including a baseball field and skate park.

The BPS, tank and wet well that are proposed with Project would not result in a substanAal conversion of parkland resulAng in noncompliance of the City’s park requirements per capita. Likewise, Project implementaAon will not preclude the park uses that are proposed with the CIP park expansion. The BPS, tank and wet well are essenAal components of the Project that are needed to achieve the groundwater sustainability goals and policies of approved city and regional plans including the City’s General Plan, Safety Element, and Water Master Plan and regional groundwater sustainability plans. The Project will provide reliable potable water deliveries for Escalon’s exisAng and future populaAon. The Project will enable reliable delivery of water services and fire response that will be distributed for required land uses across the City (residenAal, commercial, park, etc.) and will support ongoing park operaAons and maintenance within city limits as well as the planned buildout of the General Plan.

As a result, the Project impacts are considered less than significant impacts on exisAng neighborhood and regional parks or other recreaAonal faciliAes. Likewise, implementaAon of the Project would not result in substanAal physical deterioraAon or accelerated deterioraAon of park faciliAes. No MiAgaAon Measures are needed. b) Does the Project include recreaAonal faciliAes or require the construcAon or expansion of recreaAonal faciliAes which might have an adverse physical effect on the environment? RESPONSE:

No Impact. See SecAon 5.16, Response a). The Project is proposed to support the buildout of the City’s approved land use map and will not cause substanAal changes to approved land use paLerns, recreaAonal faciliAes, or the use of these faciliAes, as menAoned above. The Project will have no impacts related to the construcAon or expansion of recreaAonal faciliAes or an adverse physical effect on the environment related to recreaAon faciliAes. Therefore, no miAgaAon is required.

5.16.4 MiAgaAon Measures
No MiAgaAon Measures are required.

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5.17 TRANSPORTATION
Issues

PotenAally
Significant Impact
Less than Significant
Impact with
MiAgaAon
Incorporated
Less than Significant
Impact No Impact
XVII. TRANSPORTATION. Would the Project:
a) Conflict with a program, plan,
ordinance, or policy
addressing the circulaAon
system, including transit,
roadway, bicycle, and
pedestrian faciliAes?
b) Conflict or be inconsistent
with CEQA Guidelines §
15064.3, subdivision (b)?
c) SubstanAally increase
hazards due to a geometric
design feature (e.g., sharp
curves or dangerous
intersecAons) or
incompaAble uses (e.g., farm
equipment)?
d) Result in inadequate
emergency access?

5.17.1 Regulatory Compliance
CEQA Guidelines
In December 2018, CEQA Guidelines SecAon 15064.3, subdivision (b) was proposed by the Office of Planning and Research and adopted by the California Natural Resources Agency. The updated guidelines outline the specific consideraAons for evaluaAng a project’s transportaAon impacts; idenAfying “vehicle miles traveled” (VMT) as the most appropriate measure for determining impact levels. The updated guidelines focus primarily on transit priority areas, shiVing the focus from driver delay to GHG reducAons, the uAlizaAon of mulAmodal networks, and mixed-use land use paLerns that may improve walkability and reduce reliance on automobile use.

SecAon 15064.3 subdivision (b) considers all the following acceptable criteria for analyzing transportaAon impacts:
(1) Land Use Projects. Project-related VMT exceeding an applicable threshold of significance may indicate a significant impact. Generally, projects within one-half mile of either an exisAng major transit stop or a stop along an exisAng high-quality transit corridor should be presumed to cause a less than significant transportaAon impact based on proximity with mass transit or goods and services. Projects that decrease VMT should be presumed to have a less than significant transportaAon impact.
(2) TransportaAon Projects. TransportaAon projects that reduce, or have no impact on, VMT should be presumed to cause a less than significant transportaAon impact. For roadway capacity projects, agencies have the discreAon to determine the appropriate measure of transportaAon impact consistent with CEQA and other applicable requirements. To the extent that such impacts have already been adequately addressed at a programmaAc level, such as in a regional transportaAon plan EIR, a lead agency may Aer from that analysis as provided in SecAon 15152.
(3) QualitaAve Analysis. If exisAng models or methods are not available to esAmate VMT for the parAcular project being considered, a lead agency may analyze the project's VMT qualitaAvely. Such a qualitaAve analysis would evaluate factors such as the availability of transit, proximity to other desAnaAons, etc. For many projects, a qualitaAve analysis of construcAon traffic may be appropriate. (4) Methodology. A lead agency has the discreAon to choose the most appropriate methodology to evaluate a project's VMT, including whether to express the change in absolute terms, per capita, per household, or in any other measure. A lead agency may use models to esAmate a project's VMT and may revise those esAmates to

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reflect professional judgment based on substanAal evidence. Any assumpAons used to esAmate VMT and any revisions to model outputs should be documented and explained in the environmental document prepared for the project. The standard of adequacy in SecAon 15151 shall apply to the analysis described in this secAon.

Source: CEQA Guidelines SecAon 15064.3- Determining the Significance of TransportaAon Impacts.

5.17.2 ExisAng CondiAons
According to the San Joaquin County General Plan, Figure TM-1 Circula on Diagram, Escalon-Bellota Road is a major
arterial street within unincorporated San Joaquin County, that transiAons to a minor arterial within Escalon’s City Limits. Escalon-Bellota Road right-of-way is where the Project will be implemented and current traffic counts from San Joaquin County indicate Escalon-Bellota operates at acceptable traffic levels. For a two-lane major collector street similar to Escalon-Bellota Road, San Joaquin County’s threshold capacity volume to maintain Level of Service C is 12,500 vehicles (San Joaquin County EIR, 2014). According to the San Joaquin County Department of Public Works, recent traffic counts along Escalon-Bellota Road, the Project Alignment, are between 2,769 and 7,777 average daily trips (ADT) (San Joaquin County Dept. Public Works GIS), less than the roads design capacity.

State Route (SR) 120 is approximately 0.5 miles north of the proposed BPS and provides regional access to the Project.

State Route 120 traverses east to west across Escalon’s Downtown, connecAng Escalon to neighboring ciAes including Oakdale and Manteca, approximately 9 miles east and 10 miles west of the proposed BPS.

5.17.3 Project Impacts
a) Conflict with a program, plan, ordinance, or policy addressing the circulaAon system, including transit, roadway, bicycle, and pedestrian faciliAes?
RESPONSE:

Less than Significant Impact. The Project plans to install 19,500 LF of potable water pipeline bgs within the paved public right-of-way of Escalon-Bellota Road. Upon compleAon of construcAon, the street surface will be returned to pre-project condiAons. No permanent impacts on the City of Escalon’s or County’s circulaAon system are proposed with the Project. Likewise, the Project will not cause direct changes to exisAng or planned land use resulAng in increased VMT. Project construcAon is anAcipated to cause temporary and intermiLent increased traffic during construcAon and will increase acAvity within construcAon zones from the arrivals and departures of the crew, inspectors, contractor trips, truck trips, and equipment use. As anAcipated within the Project’s Air Quality, Greenhouse Gas, & Energy Technical Memorandum (Appendix A), construcAon worker trips will generate 50,486 vehicle miles traveled (VMT) related to construcAon worker trips8; and 13,824 VMT for vendor and hauling trips9
during Project construcAon, totaling 64,310 VMT over 16 months (Ganddini 2023). As a result, modeling in Appendix A, shows daily truck trips from construcAon works and vendor hauling are not anAcipated to exceed approximately 112 trips per day (Appendix A, Ganddini, Table 7: Construc on Worker Fuel Consump
ons
Es
mate; Table 9: Construc
on Hauling Fuel Consump
on Es
mates (HHD Trucks)) throughout the various phases
of Project construcAon.

Due to the temporary and intermiLent acAviAes from Project construcAon along Escalon-Bellota Road and in the temporary increase of approximately 112 daily trips per day during construcAon, the increase in daily trip trips from Project construcAon is not anAcipated to have significant impacts on traffic. ADT along Escalon Bellota road is well below the County’s capacity threshold of 12,500 vehicles and the temporary increase in trips per day as a result of Project construcAon does not anAcipate resulAng in significant transportaAon deficiencies.

As a result, Project construcAon will not result in daily trips exceeding County-established capacity thresholds or significantly increased VMT. For the reasons above, the proposed Project is not anAcipated to conflict with a 8 ConstrucAon worker trips are based on CalEEMod User's Guide Appendix C (April 2022) states that construcAon work trips are made by a fleet consisAng of 25 percent light-duty auto (or passenger car), 50 percent light-duty truck type 1 (LDT1), and 25 percent light duty truck type 2 (LDT2). 9 Vendor and hauling trips are based on the following assumpAons contained within CalEEMod User's Guide Appendix C (April 2022) states that vendor trips are made by a fleet consisAng of 50 percent medium trucks (MHDT) and 50 percent heavy trucks (HHDT) and that hauling and onsite truck trips are made by a fleet consisAng of 100 percent HHDT.

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program, plan ordinance, or policy addressing the circulaAon system including transit, roadway, bicycles, and pedestrian faciliAes. Less than significant impacts are anAcipated. No MiAgaAon Measures are needed. b) Conflict or be inconsistent with CEQA Guidelines § 15064.3, subdivision (b)? RESPONSE:

Less than Significant with MiAgaAon Incorporated. CEQA Guidelines SecAon 15064.3, subdivision (b) pertains to VMT that are expected from a Project. The Project does not propose changes to exisAng or approved land use and will not facilitate permanently increased traffic trips or permanently increased VMT. As menAoned above, Appendix A, Air Quality, Greenhouse, & Energy Technical Memorandum anAcipates temporary Project construcAon will generate 50,486 VMT related to construcAon worker trips; and 13,824 VMT for vendor and hauling trips, totaling 64,310 VMT over 16 months. Throughout the various phases of Project construcAon, approximately 112 daily trips are not anAcipated to be exceeded. As a result of temporary increases in construcAon trips along local roadways, the Project will implement previously approved MiAgaAon Measures from SSJID’s SCSWP, which have been modified for the proposed Project. MiAgaAon Measures Modified MM TRAF-01: Traffic Control Plan will ensure a licensed traffic engineer maintains the maximum amount of travel lane capacity and emergency access during Project construcAon.

Since impacts to VMT are anAcipated to be temporary and intermiLent during Project construcAon, the County’s ADT thresholds will not be permanently impacted; therefore, less than significant impacts are anAcipated with the implementaAon of proposed MiAgaAon Measures.
c) SubstanAally increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersecAons) or incompaAble uses (e.g., farm equipment)?
RESPONSE:

No Impact. The Project will be constructed below the ground surface and will not implement above-ground features that could result in permanent hazards from a geometric design feature. During construcAon, the Project will require transport of heavy equipment to the Project and Local Vicinity and the use of heavy equipment. Work within the public right-of-way requires review and approval of an encroachment permit by the City, which will require an approved traffic control plan with BMPS such as temporary barriers and detours, signage, and flagging. Therefore, no impacts are anAcipated. d) Result in inadequate emergency access?
RESPONSE:

Less than Significant with MiAgaAon Incorporated. Refer to Responses 5.17.3 a) through c). PotenAal for delay within the Local Vicinity during Project construcAon is likely since slower-moving equipment and trucks used during construcAon could create temporary delays. ConAnuous access will be maintained by the contractor by implemenAng the approved traffic control plan. The Project will implement the City’s Standard SpecificaAons and will comply with City requirements for plan check review and approval and construcAon inspecAons. During construcAon, an approved traffic control plan under modified MiAgaAon Measures Modified MM TRAF-01: Traffic Control Plan through Modified MM TRAF-07: Encroachment Permit will be followed to allow services to funcAon as usual, and any required road or driveway access will be available for emergency access by the Fire and Police department through the Project site. As a result of the proposed MiAgaAon Measures, impacts will be less than significant. In the long term, The Project will return to pre-project condiAons and there will be no impact on vehicular access near the Project Alignment or in the Local Vicinity.

5.17.4 MiAgaAon Measures
Modified MM TRAF-01: Traffic Control Plan- Upon the finalizaAon of a detailed pipeline alignment design, the City of Escalon 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. The Traffic Control Plan to be prepared by the construcAon contractors shall include, but not be limited to, the following measures:

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- 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 alternates 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 the peak of Christmas, and holiday shopping period), dairies, and the Atlanta Cemetery.
- Post advanced warnings of construcAon acAviAes (e.g., signs, arAcles in newspapers, noAces on radio/TV, etc.) to allow motorists to select alternaAve routes in advance.

Modified MM TRAF-02: Coordinate Traffic Plan with EUSD - Prior to Project construcAon, the City of Escalon shall develop comprehensive strategies for maintaining emergency access for sensiAve land uses such as Escalon police and fire staAons, and Escalon Unified School District in consultaAon with the facility owner or administer, as part of the Traffic Control Plan for roadway segments and intersecAons. Strategies shall include but are 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. In addiAon, the Project contractor must share the traffic control plan with the Escalon Unified School District to coordinate best management pracAces during peak operaAonal hours (pickup and drop-offs) at Escalon High School.

Modified MM TRAF-03: Advanced NoAce- Prior to construcAon acAviAes along the Project alignment and at the site of the FCF, and BPS, the City of Escalon shall require a minimum 72-hour advance noAce of access restricAons for residents and businesses. Affected residents and businesses shall be advised of the requirements for moving motor vehicles out of the area to be closed.

Modified MM TRAF-04: Off-Street ConstrucAon Parking- During construcAon acAviAes, the City of Escalon may require the contractor(s) to provide off-street 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.

Modified MM TRAF-05: Warning Signs- As part of the Traffic Control Plan(s) for roadway segments and intersecAons, the City of Escalon 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.

Modified MM TRAF-06: Bicyclists and Pedestrians- Prior to construcAon acAviAes, the City of Escalon shall incorporate into contract specificaAons for all project components that require that traffic control plans include detours for bicyclists and pedestrians in all areas potenAally affected by project construcAon.

Modified MM TRAF-07: Encroachment Permit- Before the approval of Project plans, the City of Escalon shall obtain encroachment permits from affected jurisdicAons before construcAon of the project, and comply with haul route designaAons, and roadway wear monitoring and repairs condiAons.

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5.18 TRIBAL CULTURAL RESOURCES
Issues

PotenAally
Significant Impact
Less than Significant
Impact with
MiAgaAon
Incorporated
Less than Significant
Impact No Impact
XVIII. TRIBAL CULTURAL RESOURCES.
a) Would the Project cause a
substanAal adverse change in
the significance of a tribal
cultural resource, defined in
Public Resources Code §
21074 as either a site,
feature, place, cultural
landscape that is
geographically defined in
terms of the size and scope of
the landscape, sacred place,
or object with cultural value
to a California NaAve
American tribe, and that is:
i. Listed or eligible for
lisAng in the California
Register of Historical
Resources, or in a local
register of historical
resources as defined in
Public Resources Code
secAon 5020.1(k), or
ii. A resource determined
by the lead agency, in its
discreAon and
supported by
substanAal evidence, to
be significant pursuant
to criteria set forth in
subdivision (c) of Public
Resources Code §
5024.1. In applying the
criteria set forth in
subdivision (c) of Public
Resource Code §
5024.1, the lead agency
shall consider the
significance of the
resource to a California
NaAve American tribe.

5.18.1 Regulatory Compliance
Assembly Bill (AB) 52
AB 52 became effecAve on July 1st, 2015, and requires lead agencies to provide noAce to any California NaAve American tribes that have requested noAce of projects. Upon the receipt of the noAce, the tribe has 30 days to request consultaAon with the lead agency. AB 52 created a new category of resources formally known as “Tribal Cultural Resources” (TCRs).

Public Resources Code 21074 defines “Tribal cultural resources as any of the following “Sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California NaAve American tribe that are either: (A) Included or determined to be eligible for inclusion in the California Register of Historical Resources and/or (B) Included

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in a local register of historical resources as defined in subdivision (k) of SecAon 5020.1. This may include a resource determined by the Lead Agency, in its discreAon and supported by substanAal evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code SecAon 5024.1. In applying the criteria set forth in subdivision (c) of SecAon 5024.1 for the purposes of this paragraph, the lead agency shall consider the significance of the resource to a California NaAve American tribe.”

5.18.2 ExisAng CondiAons
As menAoned within SecAon 5.5.2 ExisAng CondiAons, the Project area is within the tradiAonal boundaries of the Northern Valley Yokuts. The tribe adopted a sedentary lifestyle due to the benefits of the perennial water sources in an otherwise arid climate. A sedentary lifestyle allows the tribe to have a village-style residenAal model in which residenAal-based remained the same or seasonal and sancAoned mobility to more remote areas for the collecAon of specialized resources (Binford 1980, Thomas 1983). The village-style residenAal 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 (Krober 1925:474).

5.18.3 Project Impacts
a) Would the Project cause a substanAal adverse change in the significance of a tribal cultural resource, defined in Public Resources Code § 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California NaAve American tribe, and that is:
i. Listed or eligible for lisAng in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code secAon 5020.1(k), or RESPONSE:

Less than Significant with MiAgaAon Incorporated. On March 13th, 2023, a records search of the NAHC SLF was completed for the proposed Project. The results from the SLF were negaAve and no resources have been previously idenAfied in the immediate area of the Project. However, the SLF search does not indicate the absence of cultural resources during construcAon. Therefore, addiAonal sources, including informaAon from NaAve American Tribes, who have knowledge of cultural resources within the Project area is needed (see SecAon 5.18.3, Response i) below). The City of Escalon has iniAated AB 52 ConsultaAon with tribes listed on the NAHC SLF Search pursuant to Standard CondiAon SC TRI-01: AB 52 and proposes MiAgaAon Measures MM TRI-01: Agreements, ConsulAng, and Monitoring with Affiliated Tribes and MM TRI-02: Diversity of Buried Tribal Cultural Resources requiring tribal monitoring and coordinaAon during construcAon.

Based on the results of the SLF, impacts on cultural resources pursuant to Public Resources Code SecAon 21074 and 5020.1(k) are considered less than significant with miAgaAon. ii. A resource determined by the lead agency, in its discreAon and supported by substanAal evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code § 5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code § 5024.1, the lead agency shall consider the significance of the resource to a California NaAve American tribe.

RESPONSE:

Less than Significant with MiAgaAon Incorporated. As menAoned within SecAon 5.18.3, Response i) above, the SLF search results indicate the Project is not located within an area where tribal cultural resources have been previously found. Therefore, The City of Escalon has contacted tribes affiliated with the Local Vicinity to beLer understand the potenAal for discovery of tribal cultural resources and Project impacts.

The NAHC provided a list of NaAve American tribes that may have informaAon on tribal cultural resources that may be present near the Project. The list includes seven tribes (ConsulAng Tribes) listed as follows: Buena Vista Rancheria of Me-Wuk Indians, California Valley Miwok Tribe, Ione Band of Miwok Indians, North Valley Yokuts Tribe, Tule River Indian Tribe, Wilton Rancheria, and Wuksache Indian Tribe/

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Eshom Valley Band. These tribes along with many others are affiliated with the Local Vicinity and were historically present within the region. Therefore, the City of Escalon, the lead agency, has contacted the following tribes inquiring whether or not they will require formal consultaAon pursuant to Standard CondiAon SC TRI-01- Assembly Bill 52: Buena Vista Rancheria of Me-Wuk Indians, California Valley Miwok Tribe, Chicken Rancho Rancheria of Me-Wuk Indians, Ione Band of Miwok Indians, Nashville Enterprise Miwok-Maidu-Nishinam Tribe, North Valley Yokuts Tribe, The Confederated Villages of Lisjan, Tule River Indian Tribe, Wilton Rancheria, Wuksache Indian Tribe/ Eshom Valley Band, and the United Auburn Indian Community of the Auburn Rancheria. On September 5, 2024, the City received a response from the California Valley Miwok Tribe. The tribe indicated that they understood the nature and purpose of the proposed Project and the tribe did not have any further comments or concerns.

In addiAon, tribal monitoring will be implemented during earthwork pursuant to TRI-01, MM TRI-01:

Agreements, ConsulAng, and Monitoring with Affiliated Tribes. This miAgaAon measure and standard condiAon will ensure claims of tribal cultural significance of the areas where earthwork is anAcipated for Project implementaAon are appropriately assessed and that finds during earthwork are not significantly impacted. Less than significant impacts with miAgaAon measures would result.

Based on preliminary review of the SLF, significant impacts are not likely. However, the proposed depths of excavaAon have the potenAal to impact naAve soils and could uncover previously unknown tribal resources. Therefore, therefore, tribal coordinaAon and monitoring is proposed. Therefore, MiAgaAon Measures MM TRI-01: Agreements, ConsulAng, and Monitoring with Affiliated Tribes and MM TRI-02:

Diversity of Buried Tribal Cultural Resources are proposed to ensure that prior to Project construcAon agreements with consulAng tribes are established; field training is conducted on the appropriate procedures in the event a TCR is discovered; and procedures were established for reburial.

As a result, the Project anAcipates less than significant impact with miAgaAon incorporated.

5.18.4 MiAgaAon Measures
MM TRI-01: Agreements, ConsulAng, and Monitoring with Affiliated Tribes. Prior to the issuance of grading or building permits, the City of Escalon shall secure agreements with ConsulAng Tribes for monitoring. The City will be required to provide 30 days’ advanced noAce to the tribes of all ground-disturbing acAviAes. The NaAve American Tribal RepresentaAves shall have the authority to temporarily halt and redirect earth moving acAviAes in the affected area if suspected tribal resources are unearthed. The NaAve American Monitor(s) shall aLend the pre-construcAon crew training with the Project Archaeologist, City, the construcAon manager and any contractors pursuant to Modified MM CUL-01: (Ground InspecAon) Pre-ConstrucAon Crew Training. The training will include a Tribal PerspecAve of the mandatory Cultural Resources Worker SensiAvity Training to those in aLendance.

MM TRI-02: Diversity of Buried Tribal Cultural Resources. If sub surface cultural resources are discovered during ground disturbing acAviAes (inadvertent discoveries), the following shall be carried out for final disposiAon of the discoveries:

1. PreservaAon-in-Place: The cultural resource shall be preserved in place by the Project contractor if possible.

PreservaAon-in-Place means avoiding the resources and leaving them in place where they were found with no development affecAng the integrity of the resources. All work around the inadvertent discoveries shall be halted unAl the Project archeologist or representaAve from a ConsulAng Tribe is noAfied and onsite for retrieval.

2. NoAfy ConsulAng Tribes: Prior to the reburial or resuming construcAon acAviAes, tribes must be noAfied immediately by the District regarding treatment and disposiAon of arAfacts.

3. Reburial: Onsite reburial of the discovered items shall be reburied; and the reburial area shall be protected from any future impacts in perpetuity. Reburial shall not occur unAl all legally required cataloging and basic recordaAon have been completed. No recordaAon of sacred items is permiLed without the wriLen consent of all ConsulAng Tribes. The locaAon for the future reburial area shall be idenAfied on a confidenAal exhibit

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on file with the City and concurred to by the ConsulAng Tribes prior to cerAficaAon of the environmental document.

5.18.5 Standard CondiAons
SC TRI-01: AB 52: Prior to Project construcAon, the City of Escalon shall complete coordinaAon with the local tribes pursuant to AB 52. If a response has not been received within two weeks of noAficaAon, the City of Escalon might follow-up with a telephone call or email to ensure that the Project informaAon has been received and reviewed by each respecAve tribe.

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5.19 UTILITIES AND SERVICES
Issues

PotenAally
Significant Impact
Less than Significant
Impact with
MiAgaAon
Incorporated
Less than Significant
Impact No Impact
XIX. UTILITIES AND SERVICE SYSTEMS. Would the Project:
a) Require or result in the
relocaAon or construcAon of
new or expanded water,
wastewater treatment or
storm water drainage,
electric power, natural gas, or
telecommunicaAons
faciliAes, the construcAon or
relocaAon of which could
cause significant
environmental effects?
b) Have sufficient water
supplies available to serve
the Project and reasonably
foreseeable future
development during normal,
dry and mulAple dry years?
c) Result in a determinaAon by
the wastewater treatment
provider, which serves or
may serve the Project that it
has adequate capacity to
serve the Project’s Projected
demand in addiAon to the
provider’s exisAng
commitments?
d) Generate solid waste in
excess of state or local
standards, or in excess of the
capacity of local
infrastructure, or otherwise
impair the aLainment of solid
waste reducAon goals?
e) Comply with federal, state,
and local management and
reducAon statutes and
regulaAons related to solid
waste?

5.19.1 Regulatory Compliance
City of Escalon
The City of Escalon Public Works Department provides water and wastewater services within City Limits. Escalon’s primary water source is from groundwater wells located throughout City Limits. Wastewater is directed to Escalon’s Wastewater Treatment Plant south of City Limits off East River Road.

The City of Escalon provides consumers with a “Consumer Confidence Report” every year evaluaAng the groundwater contaminants within the City wells (Wells 3A- South, 9-Northeast, 10-East). The reports provided by the City of Escalon ensure that the City’s drinking water is safe to drink according to the U.S. EPA and State Board.

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Water Master Plan
The City of Escalon’s Water Master Plan is a comprehensive water infrastructure strategy for adequate delivery of service to the exisAng consumer base and planned future growth. The City’s Water Master Plan sets service objecAves that account for water needed to serve land uses, populaAon projecAons, and planning horizons that are described in the approved General Plan. This document is used to idenAfy, organize, and phased implementaAon of CIP projects to achieve master plan objecAves (Escalon Water Master Plan 2007). The objecAves of the Water Master Plan include the following:

1. Development of a logical expansion plan that can be phased according to growth projecAons and land use idenAfied in the General Plan as well as the City’s Growth Ordinance which limits residenAal development to a maximum of 75 residenAal units per year. Revenue generated by connecAon charges for improvements will be limited accordingly.

2. ProjecAon of future water demands based on historical water use data and approved land use as defined in the General Plan.

3. IdenAficaAon of water infrastructure needs to meet the goals and objecAves of the General Plan including supply, storage, pumping and distribuAon faciliAes.

4. DescripAon of improvements including capital costs which will be used to develop the appropriate water connecAon charge.

5. Development of an implementaAon plan and recommended water connecAon charge.

5.19.2 ExisAng CondiAons
Within City Limits, electrical services are provided by both PG&E and MID. Solid waste collecAon is provided by Gilton Solid Waste Management and is taken to McClure Transfer StaAon in Modesto, where it is processed and sent to the Fink Landfill in Stanislaus County.

Near City Limits, along Escalon-Bellota Road, a water main and sewer line runs parallel to the City’s right-of-way. Water services being provided by the City are distributed from the exisAng water main to adjacent land uses including residenAal, commercial, agricultural, and parkland. Pipeline diameters range from three to 16 inches. In addiAon, the water distribuAon system is operated by SCADA, which allows Escalon to regulate the system’s desired pressure and configure the wells uAlizing a lead/lag pumping configuraAon (Escalon Water Master Plan 2007), with a conAnuous lead pump assisted by a lag pump to meet flow requirements when the system demands exceed the capability of the lead pump.

According to the Water Master Plan, the distribuAon system is in excellent condiAon; however, to meet further demand requirements and provide redundancy and reliability to the City’s long-term water supply, the City needs to supplement well water with “surface” water provided by SSJID (Escalon Water Master Plan 2007). As a result, the City is a parAcipant in the SSJID SCSWSP, which agrees to deliver treated surface water to supplement municipal and industrial water supplies to communiAes’ part of the agreement (Escalon, Tracy, Lathrop, Manteca). As proposed in the Water Master Plan, the primary faciliAes associated with the SSJID project include the conveyance of water from the exisAng 48-inch SSJID transmission main and turnout faciliAes (storage tank and BPS).

5.19.3 Project Impacts
a) Require or result in the relocaAon or construcAon of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunicaAons faciliAes, the construcAon or relocaAon of which could cause significant environmental effects?
RESPONSE:

Less than Significant with MiAgaAon Incorporated. RelocaAon of exisAng uAliAes will not be required for Project construcAon. The Project will be implemented using open trench and jack and bore methods for the proposed improvements to the City’s water distribuAon network. Jack and bore will be used to avoid impacts on exisAng uAliAes. Project implementaAon requires the installaAon of 19,500 LF of potable water from the SSJID transmission line, an FCF, BPS, a storage tank, and wet well. The extension of the potable water line from the

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SSJID Ae-in, will expand the City’s water infrastructure and assist with providing potable water to the City’s consumer base. The improvements will help achieve regional groundwater sustainability goals and to meet the demands that are forecasted due to populaAon growth.

Project construcAon of Project Components is meant to increase water supply and improve performance and reliability. Since the BPS will connect to the City’s water distribuAon network along Escalon-Bellota Road, water services may be temporarily impacted to allow for the connecAon to the exisAng water line. Electrical services will be extended to the BPS from nearby power poles owned and operated by PG&E. Electricity demand anAcipated at the BPS over the lifeAme of the Project and is not anAcipated to be significant due to the anAcipated scale.

The Project is included in the City’s Water Master Plan; therefore, the Project does not propose to develop infrastructure or public uAlity improvements that have not already been considered and approved by the City of Escalon. As outlined below in Table 27: Project Consistency with County General Plan Services and Recrea on
Policies and Goals, the Project is consistent with the policies and goals outlined in San Joaquin County’s General Plan.

For the reasons above, the Project will result in the construcAon of new expanded wastewater uAliAes; however, new construcAon will not result in significant impacts that involve the relocaAon of new or expanded water, wastewater treatment, stormwater drainage, electric power, natural gas, or telecommunicaAons faciliAes.

TABLE 27: PROJECT CONSISTENCY WITH COUNTY GENERAL PLAN SERVICES County General Plan Policies and Goals (Public
Services and RecreaAon)
Project Consistency
IS-1.3: Facili
es and Services Deficiencies. The County
shall coordinate with other public facility districts and agencies (e.g., special districts, community service
districts) to iden
fy and find solu
ons to key
infrastructure deficiencies in the County. (IGC)
(Source: New Policy)
The proposed Project will be implemented in coordinaAon with SSJID, OID, the City of Escalon, and San Joaquin County. The proposed Project will be owned and operated by the City of Escalon; however, SSJID and San Joaquin County are involved to ensure that acAviAes proposed within the SCSWSP EIR are carried out to reduce significant impacts.

IS-1.4: Infrastructure Maintenance. The County shall
work with agencies to maintain, improve, and replace
public facili
es as necessary to maintain adequate
levels of service for exis
ng and future development
and reduce the need for new facili
es. Where public
facili
es and services are provided by other agencies,
the County shall encourage similar service-level goals. (PSP/IGC) (Source: Exis
ng GP, CODP, Growth
Accommoda
on, Policy 25, modified)

The Project will carry out Policy IS-1.4 by improving the water distribuAon network to maintain adequate levels of service for exisAng and future development. The improvement will allow water services to run as usual and will reduce impacts on groundwater.

IS-1.5: Infrastructure and Service Expansions. The
County shall base the expansion of public facili
es and
services on current needs and planned or projected
development pa<erns. (PSP) (Source: Exis
ng GP,
CODP, Growth Accommoda
on, Policy 26, modified)

The Project is proposed to reduce the City’s use of groundwater and will also serve to support projected populaAon growth within City Limits pursuant to the approved General Plan. Project Components will accommodate the increase in growth anAcipated within the coming years by connecAng Escalon’s water infrastructure to SSJID’s transmission main that will supply surface waters. The Project will improve and modify water service in the City.

Source: San Joaquin County 2035 General Plan
Since the proposed Project is anAcipated to connect to exisAng water infrastructure including the SSJID 48-inch transmission line and a water main along Escalon-Bellota Road with City Limits, conflicts with exisAng uAliAes have the potenAal to occur. As a result, the Project will implement SSJID’s previously approved MiAgaAon

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Measure Modified MM UTL-01: ExisAng UAliAes and Modified MM UTL-02: UAlity Conflicts from the SCSWSP DEIR; therefore, less than significant impacts are anAcipated with miAgaAon incorporated. b) Have sufficient water supplies available to serve the Project and reasonably foreseeable future development during normal, dry and mulAple dry years?
RESPONSE:

No Impact. The proposed Project will connect to SSJID’s transmission line currently located on Dodds Road in unincorporated San Joaquin County and bring surface water to the City of Escalon for long-term use and ensure system reliability and redundancy as well as fulfill groundwater sustainability goals. The Project does not propose to increase populaAon or density. Proposed Improvements will improve the City’s water infrastructure and supply addiAonal sources of water (via SSJID transmission main). The Project is part of the SSJID SCSWSP and has been approved and considered within the City’s Water Master Plan and SSJID.

As a result, no impacts are foreseen, as the Project is not anAcipated to substanAally impact water supplies that serve the Project and reasonably foreseeable future development during normal and mulAple dry years. No MiAgaAon Measures are needed.
c) Result in a determinaAon by the wastewater treatment provider, which serves or may serve the Project that it has adequate capacity to serve the Project’s Projected demand in addiAon to the provider’s exisAng commitments?
RESPONSE:

No Impact. Wastewater flows are treated by the Escalon Wastewater Treatment Plan (WWTP) located at 25100 East River Road, Escalon, CA 95320, approximately 3.5 miles south of the proposed BPS site. At the Escalon WWTP, influents from domesAc and industrial are received at this plant, then processed separately in different secAons of the facility (Escalon WWTP Master Plan Report 2019).

Since the proposed Project does not anAcipate the generaAon of wastewater over the long-term, Escalon WWTP does not need to account for increased capacity due to Project acAviAes. Therefore, changes to the faciliAes exisAng commitments are not anAcipated. No impacts are anAcipated, and MiAgaAon Measures are not required for the Project.
d) Generate solid waste in excess of state or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the aLainment of solid waste reducAon goals? RESPONSE:

Less than Significant Impact. According to Escalon’s Sewer System Map, a sewer main runs north-south along the western perimeter of Escalon-Bellota Road. An exisAng manhole lid is directly west of the proposed BPS site, on the border of City Limits. Since Project improvements are planned to expand the City’s water distribuAon network for redundancy and reliability, the Project does not propose to increase populaAon density at the locaAon of any Project Components. Therefore, waste management services or submiLal of an approved Waste Management and Recycling Plan for the Project is not necessary. Long-term operaAon of the proposed components including the FCF, BPS, storage tank, and wet well, will be maintained by the City of Escalon’s Public Works Department.

OperaAon of the faciliAes do not anAcipate regular disposal of debris or waste, since faciliAes will be operated on an automaAc pump system uAlizing lead/lag configuraAon.

However, Project construcAon will result in debris from excavaAon, trenching, and jack and bore construcAon. As a result, the Project contractor will implement a waste management plan for the Project, which will include temporary lidded bins at on-site staging areas. Lidded bins will be uAlized for collecAon, disposal, recycling, and transport of construcAon-related waste.

e) Comply with federal, state, and local management and reducAon statutes and regulaAons related to solid waste RESPONSE:

No Impact. The Project will not increase solid waste producAon over the long-term, since the Project does not propose to increase populaAon or density at the Project or within the Local Vicinity. The Project improvements

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to the City’s water distribuAon network to increase the reliability of water services for the City’s consumer base.

Therefore, no impacts are anAcipated, and no MiAgaAon Measures are required.

5.19.4 MiAgaAon Measures
Modified MM UTL-01- ExisAng UAliAes- A detailed study idenAfying uAliAes within areas subject to earthwork with the Project construcAon shall be conducted during the pre-design stages of the Project. For project components with uAlity conflicts, 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. The City 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 the City’s construcAon plans and schedule. Arrangements may be made with these enAAes regarding protecAon, relocaAon, or temporary disconnecAon of services.
- The City 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.

Modified MM UTL-02: UAlity Conflicts- In order to reduce potenAal impacts associated with uAlity conflicts, the following measures shall be implemented in conjuncAon with Modified MM UTL-01- ExisAng UAliAes:

- Disconnected cables and lines shall be reconnected promptly - Based on the uAliAes invesAgaAon to be conducted by the City of Escalon shall consult with any enAAes having uAlity conflicts with the proposed project to negoAate relocaAon efforts or other plans to resolve the conflict.
- The City of Escalon shall observe DHS standards 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 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, the City 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.

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5.20 WILDFIRE
Issues

PotenAally
Significant Impact
Less than Significant
Impact with
MiAgaAon
Incorporated
Less than Significant
Impact No Impact
XX. WILDFIRE. If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the Project:
a) SubstanAally impair an
adopted emergency
response plan or emergency
evacuaAon plan?
b) Due to slope, prevailing
winds, and other factors,
exacerbate wildfire risks, and
thereby expose Project
occupants to pollutant
concentraAons from a
wildfire or the uncontrolled
spread of a wildfire?
c) Require the installaAon or
maintenance of associated
infrastructure (such as roads,
fuel breaks, emergency water
sources, power lines or other
uAliAes) that may exacerbate
fire risk or that may result in
temporary or ongoing
impacts to the environment?
d) Expose people or structures
to significant risks, including
downslope or downstream
flooding or landslides, as a
result of runoff, post-fire
slope instability, or drainage
changes?

5.20.1 Regulatory Compliance
2019 CEQA Guidelines
In 2019, CEQA Guidelines were amended to address the need to evaluate wildfire impacts since it has worsened in recent history.

While wildfires have been prevalent throughout California’s history and more acres of California have burned in the past decade than in the previous 90 years (CALFIRE, Top 20 Largest California Wildfires 2022). Wildfires are typically caused from human acAviAes such as downed powerlines, electrical sources associated with residenAal development and industrial faciliAes” (CA ALorney General 2022). As development expands, residenAal development has the potenAal to expand into wildland-urban interfaces. Approximately one-third of California’s housing units are currently located within these areas (CA ALorney General 2022). As a result, wildfire risks have increased within the state of California. For this reason, each local jurisdicAon within the state of California is now required to adopt a Safety Element to incorporate fire safety and response into city plans as well as plan for other types of natural safety concerns. The Safety Element is a required element of each local general plan pursuant to California Government Code §65302(g).

California Fire Code
The County has adopted the 2010 California Fire Code published by the California Building Standards Commission, which is based on the adopted 2009 InternaAonal Fire Code of the InternaAonal Code Council. County Fire Code regulaAons applicable to the proposed Project will be followed. Applicable regulaAons include the following:

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• SecAon 4-1006. Access Roadways for Fire Apparatus
• SecAon 4-1009. Fees
• SecAon 4-1017. OperaAonal Fees
• SecAon 4-1018. ConstrucAon Fee

San Joaquin County
San Joaquin County Safety Element
The County of San Joaquin is in the process of updaAng its Safety Element. The stated purpose of the County’s Safety Element is to create a framework for the protecAon of people and property from natural and man-made hazards.

General Plan
The proposed Project will remain consistent with the following policies and goals outlined within San Joaquin County’s General Plan EIR.

Goal PHS-1: To maintain a level of disaster preparedness necessary for the protecAon of public and private property, and the health, safety, and welfare of people living and working in San Joaquin County. • Policy PHS-1.1 Effec
ve Emergency Response. The County shall maintain adequate faciliAes equipment and staffing to respond effecAvely to emergencies. (PSP/SO) • Policy PHS-1.3 Emergency Opera
ons Plan. The County shall maintain and implement the following emergency and hazard miAgaAon plans to provide emergency planning, miAgaAon, response, and recovery acAviAes to the community
o Emergency OperaAons Plan,
o Mountain House Community Emergency OperaAons Plan,
o MulA-Hazard FuncAonal Plan,
o Local Hazard MiAgaAon Plan, and
o Flood Safety Plan and ConAngency Mapping (PSP/SO)
Goal PHS-4: To minimize the risk of wildland and urban fire hazards. • Policy PHS-4.1 Community Wildfire Protec
on Plan. The County shall maintain and implement the Community Wildfire ProtecAon Plan as a mechanism for community input and idenAficaAon of areas with high fire hazard risk. (PSP)
• Policy PHS-4.2 Residen
al Densi
es in High Hazard Areas. The County shall restrict development to rural residenAal densiAes or lower and require on-site fire suppression measures in areas with high or extreme wildfire hazards. (RDR/PSP)
• Policy PHS-4.3 Fire Preven
on Measures. The County shall implement State recommendaAons for fire prevenAon in Fire Hazard Severity Zones and require new and/or exisAng development to provide clearance around structures, use fire-resistant ground cover, build with fire-resistant roofing materials, parAcipate in fuel load reducAon, and take other appropriate measures. (RDR/PSP) • Policy PHS-4.6 Fire ProtecAon CoordinaAon. The County shall encourage well-organized and efficient coordinaAon among fire agencies, CalFire, and the County. (IGC) City of Escalon
Safety Element
The City of Escalon’s Safety Element is dated June 6, 2005, and outlines policies and standards to achieve the stated fire protecAon objecAve of maintaining an effecAve and well-trained Fire Department. Stated policies for fire protecAon in the City are as follows:

1. The City’s fire service response goal shall be five minutes from “tone-out” to arrival on the scene.

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2. The City shall maintain a reliable water supply system that meets the fire protecAon needs of the community.

3. The City shall enforce the municipal code as it pertains to the abatement of fire hazards related to exisAng buildings, structures, and weed control.

4. The City shall support local, state, and federal programs designed to inform and educate the public concerning fire prevenAon and suppression.

5. The City will coordinate with San Joaquin County in the provision of fire protecAon services to ensure the maximum level of protecAon for all residences, commercial establishments, and industries within the planning area.

6. The City will encourage the installaAon of fire safety devices in all residences and require such installaAon at the Ame of original construcAon, remodeling, or expansion.

7. The City will establish five minutes, or two miles travel distance as the maximum response Ame or travel distance from the nearest fire staAon. Outside of this response range, built-in fire protecAon systems (i.e. sprinklers) shall be required in all new buildings.

8. The City will encourage the community to become involved in promoAng state and federal fire protecAon programs in school and civic funcAons.

CALFIRE Fire Hazard Severity Zones
The CALFIRE Fire Hazard Severity Zone (FHSZ) is “a mapped area that designated zones (based on factors such as fuel, slope, and fire weather) with varying degrees of fire hazard” (CALFIRE 2022). CALFIRE released a FHSZ Viewer that idenAfies areas where wildfires are prone to occur (See hps://egis.fire.ca.gov/FHSZ/). The uAlizaAon of this tool is meant to limit wildfire damage in preliminary phases of planning to miAgate and prevent acAviAes or land uses that would cause greater risk for a wildfire.

5.20.2 ExisAng CondiAons
Land use surrounding the Project consists of agricultural use and urban development within a rural context. According to CALFIRE’s FHSZ Viewer, the Project is not within designated Fire Hazard Severity Zones (CALFIRE FHSZ Viewer). The closest lands that are categorized as such are east and west of the Project, approximately 7.2 and 33.9 miles from the Dodds Road/Escalon-Bellota intersecAon, on the north end of the Project. However, in the event of a fire, the Project and adjacent areas will be served by Escalon Fire StaAon (StaAon 1) and Oakdale Rural Fire Department (StaAon 30).

StaAon 1 is located within downtown Escalon approximately 1.0 miles from the proposed BPS. 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, at the north end where the Project Aes into the SSJID water distribuAon system (See Figure 2: Local Vicinity Map). Reference Sec
on 5.9- Hazards and Hazardous Materials: Exis
ng Condi
ons for
addiAonal informaAon regarding emergency response and StaAon personnel/ equipment.

5.20.3 Project Impacts
a) SubstanAally impair an adopted emergency response plan or emergency evacuaAon plan? RESPONSE:

Less than Significant with MiAgaAon Incorporated. According to Escalon’s EvacuaAon Map, provided by San Joaquin County’s Office of Emergency Services, Escalon-Bellota Road is an evacuaAon route that will not be permanently affected by the Project. Improvements that are proposed with the Project will be installed bgs and the paved surface of Escalon-Bellota Road will be returned to pre-Project condiAons aVer Project construcAon is complete.

Project implementaAon is not anAcipated to involve significant impacts to evacuaAon routes and emergency response plans for vulnerable, fire-prone areas, because the Project is not near a Fire Hazard Severity Zone.

Likewise, the Project is not anAcipated to require elevated or unique emergency response services, because the scope and nature of the Project will not require handling, storage, and use of materials involving elevated risk; areas of acAve construcAon will be monitored during the day and secured at night and the Project is subject to plan check and inspecAons by the City of Escalon and the Fire Department.

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The Project will implement a Traffic Control Plan to facilitate conAnuous access within and through construcAon areas. As a result of the Traffic Control Plan, the Project will not significantly affect emergency response. During construcAon, there may be traffic delays during acAve construcAon. To miAgate potenAal impairments to the local roadways and evacuaAon routes, the Project will implement a traffic control plan under MiAgaAon Measure Modified MM TRAF-01: Traffic Control Plan and Modified MM TRAF-02: Coordinate Traffic Plan with EUSD. The proposed traffic control plan will be reviewed by the City’s Fire Department, school district, and addiAonal emergency response personnel.

In the event of an emergency, fire staAons closest to the Project will assist in providing access to evacuaAon routes. See SecAon 5.20.2-ExisAng CondiAons for more informaAon. As a result of the reasons above, the Project will implement Project MiAgaAon Measure Modified MM TRAF-01: Traffic Control Plan and Modified MM TRAF02: Coordinate Traffic Plan with EUSD during Project construcAon to reduce impacts to a less than significant level.
b) Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose Project occupants to pollutant concentraAons from a wildfire or the uncontrolled spread of a wildfire? RESPONSE:

Less than Significant Impact. See Response 5.20.3, a). Since the Project is not within a CALFIRE Fire Hazard Severity Zone or a zone of higher severity Locally or Regionally, the Project will not be prone to fires and is relaAvely flat.

According to the City’s General Plan, “no historic wildfire acAvity has been idenAfied in or around the [City’s planning area]” (Escalon GP, 2005).

However, during Project construcAon almond orchards and other agricultural land uses surround the Project northern porAons of the Project and may be suscepAble to fire. For this reason, BMPs for handling machinery should be uAlized during Project construcAon and include the following: ensuring equipment is properly stored in staging areas and regular inspecAons of the equipment are performed to ensure flammable gasoline is not leaking.

As a result, the impacts due to slope, prevailing winds, and other factors related to wildfires are less than significant.
c) Require the installaAon or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines, or other uAliAes) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?
RESPONSE:

Less than Significant Impact. The Project will not require installaAon or maintenance of infrastructure that would exacerbate fire risk. Project plans indicate the installaAon of approximately 19,500 LF of potable water main within the exisAng developed County and City right-of-way along Escalon-Bellota Road between a proposed Aein at the northern end, within the intersecAon of Escalon-Bellota Road at Dodd Road, and the southerly terminus of the Project that will be located on a developed parcel north of Hogan- Ennis Park that is currently developed with an overflow sports parking lot. The Project will provide long-term reliable water services to the City of Escalon as well as fulfill regional goals for sustainable groundwater use. Prior to trenching and jack and bore construcAon, exisAng infrastructure within the County and City right-of-way will be mapped and marked on-site uAlizing plans obtained by the City and other uAlity operators, to avoid potenAal temporary disrupAons.

AddiAonally, Project plans will be consistent with the long-term goals and objecAves of the City’s General Plan and Water Master Plan, which have already been considered and approved by the City’s decision-makers and reviewed by City Engineers to ensure compliance with the Municipal Code and Standard SpecificaAons pertaining to potable water services and fire flow. The Project will not obstruct above-ground infrastructure or exacerbate fire risk because the potable water line will be underground.

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For the reasons above, the implementaAon of the Project will not exceed what has already been considered and approved by the Water Master Plan and other approved City and regional plans regarding water distribuAon.

Therefore, the Project will not result in addiAonal impacts due to Project implementaAon. d) Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes? RESPONSE:

No Impact. See Response 5.20.3, a) through c). According to CALFIRE’s Fire Hazard Safety Zone Map, the area is designated as Local Responsibility exhibiAng no high-moderate fire hazards. Therefore, based on this assessment, the Project is not in an area with unique features or elevated risk from wildfire, slope, flooding, runoff, landslides, and drainage. Project compliance with the City’s Municipal Code will be verified during the standard applicaAon of the City’s plan check and inspecAon processes and will reduce risk to people and structures from flooding and soil instability.

For these reasons, impacts are less than significant. No MiAgaAon Measures are needed.

5.20.4 MiAgaAon Measures
See applicable MiAgaAon Measures modified from SCSWSP, Modified MM TRAF-01: Traffic Control Plan and Modified MM TRAF-02: Coordinate Traffic Plan with EUSD within SecAon 5.17.4- TransportaAon MiAgaAon Measures.

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5.21 MANDATORY FINDINGS OF SIGNIFICANCE
Issues

PotenAally
Significant Impact
Less than Significant
Impact with
MiAgaAon
Incorporated
Less than Significant
Impact No Impact
XXI. MANDATORY FINDINGS OF SIGNIFICANCE. Would the Project:
a) Does the Project have the
potenAal to substanAally
degrade the quality of the
environment, substanAally
reduce the habitat of a fish or
wildlife species, cause a fish
or wildlife populaAon to drop
below self-sustaining levels,
threaten to eliminate a plant
or animal community,
substanAally reduce the
number or restrict the range
of a rare or endangered plant
or animal or eliminate
important examples of the
major periods of California
history or prehistory?
b) Does the Project have
impacts that are individually
limited, but cumulaAvely
considerable? (“CumulaAvely
considerable” means that the
incremental effects of a
Project are considerable
when viewed in connecAon
with the effects of past
Projects, the effects of other
current Projects, and the
effects of probable future
Projects.)
c) Does the Project have
environmental effects which
will cause substanAal adverse
effects on human beings,
either directly or indirectly?

5.21.1 Project Impacts
a) Does the Project have the potenAal to substanAally degrade the quality of the environment, substanAally reduce the habitat of a fish or wildlife species, cause a fish or wildlife populaAon to drop below self-sustaining levels, threaten to eliminate a plant or animal community, substanAally reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory?
RESPONSE:

Less than Significant with MiAgaAon Incorporated. The discussion for Environmental Checklist indicates only short-term, temporary impacts during construcAon will occur with Project implementaAon. MiAgaAon measures to reduce all potenAally significant impacts to less than significance are provided in the IS/MND. Due to its locaAon within the street right-of-way and proposed improvements on developed land and/or disturbed land use for agricultural producAon, the Project has limited potenAal to result in direct significant impacts on wildlife or habitat. The Project will uAlize jack and bore construcAon to avoid direct impacts on Lone Jack Creek. MiAgaAon Measures will be implemented for biological resources which include MM BIO-01: Pre-construcAon NesAng Bird

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Clearance Survey, Modified MM BIO-02: Ground NesAng Raptors Pre-construcAon Surveys, Modified MM BIO03: Raptor Nests, Modified MM BIO-04: AcAve Nests, Modified MM BIO-05: Jack and Bore ConstrucAon). These MiAgaAon Measures will ensure bird species protected under the MBTA are protected through required preconstrucAon surveys and nest protecAon if needed, and impacts do not occur to Lone Tree Creek during jack and bore construcAon. Less than significant impacts with miAgaAon would occur.

The Project will be implemented within the public right-of-way and adjacent parcels for the installaAon of the FCF and BPS. Requirements to conduct preconstrucAon training for cultural resources and treatment protocols for buried resources, should they be encountered; consultaAon with NaAve American tribes; requirements for an archeological monitor and tribal monitor throughout construcAon acAviAes are included within the prescribed MiAgaAon Measures. The following MiAgaAon Measures and Standard CondiAons will avoid impacts on cultural and tribal cultural resources: 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, MM CUL-04: Discovery of Human Remains, MM TRI-01: Agreements, ConsulAng, and Monitoring with Affiliated Tribes, MM TRI-02: Diversity of Buried Tribal Cultural Resources, SC TRI-01: AB 52).

As a result, impacts are anAcipated to be less than significant with miAgaAon incorporated. b) Does the Project have impacts that are individually limited, but cumulaAvely considerable? (“CumulaAvely considerable” means that the incremental effects of a Project are considerable when viewed in connecAon with the effects of past Projects, the effects of other current Projects, and the effects of probable future Projects.) RESPONSE:

Less than Significant with MiAgaAon Incorporated. The Project intends to carry out long-term regional plans consistent with ESGWJA, SSJID, and the City of Escalon. The Project will reduce the potenAal for groundwater overdraV since the City of Escalon is solely reliant on groundwater for its drinking water needs; and provide a more reliable source of drinking water to Escalon’s residents. The Project proposes to implement permanent structures; however, the maintenance of the proposed structures is not anAcipated to change based on the proposed Project components. Therefore, the level of acAvity at the Project and within the Local Vicinity is not anAcipated to change in the long term.

However, during short-term, temporary Project construcAon potenAally significant impacts were idenAfied for the following resources: aestheAcs (light and glare), air quality emissions, biological resources (avian), buried cultural and tribal cultural, buried paleontological resources, hydrology and water quality, land use and planning (temporary neighborhood impacts), noise (permanent equipment installaAons), public services, uAliAes and services, transportaAon (encroachment and traffic control). As a result, Project impacts will be reduced to less than significance with the implementaAon of recommended MiAgaAon Measures, Standard CondiAons, and BMPs idenAfied herein: aestheAcs, (Modified MM AES-01: CoordinaAon with Private Landowners, Modified MM AES-02: ConstrucAon LighAng, Modified MM AES-03: LighAng, Modified MM AES-04: Landscaping), air quality (MM AQ-01: FugiAve Dust Control, MM AQ-02: (Compliance with SJVAPCD) Verify SJAPCD’s Control Measures, and SC AQ-01: Regular Cleaning of Track-out Areas), biological resources MM BIO-01: Pre-construcAon NesAng Bird Clearance Survey, Modified MM BIO-02: Ground NesAng Raptors Pre-construcAon Survey, Modified MM BIO-03: Raptor Nests, Modified MM BIO-04: AcAve Nests, Modified MM BIO-05: Jack and Bore ConstrucAon), cultural and tribal resources (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, MM CUL-04: Discovery of Human Remains, MM TRI-01: Agreements, ConsulAng, and Monitoring with Affiliated Tribes, MM TRI-02: Diversity of Buried Tribal Cultural Resources, SC TRI-01: AB 52), geology and soils (Modified MM GEO-01: Seismic Design Criteria, Modified MM GEO-02: Geotechnical Design Criteria, Modified MM HYDRO-01: Stream Crossings, Modified MM HYDRO-03: Erosion Control, MM PALEO-01- Paleontological Resource MiAgaAon Program), hydrology and water quality (Modified MM HYDRO-01: Stream Crossings, Modified MM HYDRO-02: SWPPP SpecificaAons, Modified MM HYDRO-03: Erosion Control, MM HYDRO-04: Lead Agency Approval of Project Plans, BMP HYDRO-05: ConstrucAon within Riverine Floodway), noise (MM NOI-01: ConstrucAon Noise ALenuaAon and MM NOI-02: StaAonary Source Noise), land use planning

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(Modified MM LAND-01: Landowner ConsultaAon, Modified MM LAND-02: Advance NoAce, Modified MM LAND03: ConstrucAon Contract Documents, and Modified MM LAND-04: OperaAon of Project Components), public services and transportaAon (Modified MM TRAF-01: Traffic Control Plan, Modified MM TRAF-02: Coordinate Traffic Plan with EUSD, Modified MM TRAF-03: Advanced NoAce, Modified MM TRAF-04: Off-Street ConstrucAon Parking, Modified MM TRAF-05: Warning Signs, Modified MM TRAF-06: Bicyclists and Pedestrians, Modified MM TRAF-07: Encroachment Permit), uAliAes and services (Modified MM UTL-01- ExisAng UAliAes, Modified MM UTL02: UAlity Conflicts), and wildfire (Modified MM TRAF-01: Traffic Control Plan, Modified MM TRAF-02: Coordinate Traffic Plan with EUSD).

As a result, impacts are anAcipated to be less than significant with miAgaAon incorporated. c) Does the Project have environmental effects which will cause substanAal adverse effects on human beings, either directly or indirectly?
RESPONSE:

Less Than Significant with MiAgaAon Incorporated. The analysis in this report indicates that Project implementaAon, with the incorporaAon of MiAgaAon Measures, will not cause substanAal adverse effects on human beings either directly or indirectly. As menAoned above, the Project will implement MiAgaAon Measures and Standard CondiAons for air quality (MM AQ-01: FugiAve Dust Control, MM AQ-02: (Compliance with SJVAPCD) Verify SJAPCD’s Control Measures, and SC AQ-01: Regular Cleaning of Track-out Areas), noise (MM NOI-01:

ConstrucAon Noise ALenuaAon and MM NOI-02: StaAonary Source Noise) throughout Project construcAon. The Project is proposed to improve water quality and reliability within the City of Escalon’s potable water system.

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

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6.0 REPORT PREPARATION
This secAon lists those individuals who contributed to the preparaAon of this IS/MND.

6.1 CITY OF ESCALON
Jaylen French Interim City Manager

6.2 AGENCIES OF PERSONS CONTACTED
The following agencies or persons were contacted during the preparaAon of this document.

Contact AffiliaAon
Lori TroNer, AICP CEP Ardurra Group
Riley ChrisAe, ENV SP, LEED AP ND Ardurra Group
Bradley Waldrop, PE Ardurra Group
Amy Czajkowski, PE Ardurra Group
Rick Kennedy, PE Ardurra Group
Dolores Salgado, PE Ardurra Group
ChrisAan Minerman Ardurra Group
Travis McGill ELMT
David Brunzell BCR ConsulAng
Cate Howe Ganddini
Giancarlo Ganddini Ganddini
Kate Wilson Ganddini
Roma Stromberg Ganddini

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7.0 REFERENCES

PROJECT DESCRIPTION

1. San Joaquin County 2035 General Plan Environmental Impact Report (EIR), adopted October 2014 a. Table 4.A-1: Summary of Assessed Land By Generalized Use of Category Unincorporated San Joaquin County, 2008

2. California Climate AdapAon Strategy, San Joaquin Valley Region, hLps://climateresilience.ca.gov/regions/sanjoaquin-valley.html

3. South San Joaquin IrrigaAon District, Urban Water Quality Management Plan, adopted 2020, hLps://www.ssjid.com/wp-content/uploads/2020_UWMP_SSJID.pdf

4. South San Joaquin IrrigaAon District, South San Joaquin County Surface Water Supply Project EIR, adopted 1999.

5. City of Escalon Capital Improvement Program 2018-2019 through 2020-2021

6. Eastern San Joaquin Groundwater Authority, Subbasin Groundwater Sustainability Plan, 2019, GSP (esjgroundwater.org)

7. Eastern San Joaquin Integrated Regional Water Management Plan 2020 Addendum, Greater San Joaquin Regional Water Coordination Committee, adopted 2021, Integrated Regional Water Management Plan (IRWMP) > IRWMP > Eastern San Joaquin ICU Program (esjirwm.org)

AESTHETICS

8. California Department of TransportaAon (CalTrans). (n.d.). California scenic highways. hLps://dot.ca.gov/programs/design/lap-landscape-architecture-and-community-livability/lap-liv-i-scenichighways

9. San Joaquin County. (2014). San Joaquin County 2035 General Plan Environmental Impact Report (EIR).

Adopted October 2014. Table 4.L-1: Local Scenic Routes, Figure 4.L-1: Scenic Routes.

AGRICULTURE AND FORESTRY RESOURCES

10. California Department of Conservation. (n.d.). California agricultural land evaluation and site assessment model, California important farmland finder. https://dlrp.ca.gov/FarmlandFinder

11. City of Escalon. (2005). City of Escalon General Plan Update, Draft Environmental Impact Report. Adopted February 2005. Chapter 3.2.- Agriculture and Forestry Resources.

12. City of Escalon. (n.d.). City of Escalon ordinances, Growth management procedures, Chapter 15.04. https://www.codepublishing.com/CA/Escalon/html/Escalon15/Escalon1504.html

13. City of Escalon. (2007). City of Escalon Water Master Plan. Adopted January 2007. https://cdn5- hosted.civiclive.com/UserFiles/Servers/Server_10745808/File/Government/Departments/Development%20S ervices/Engineering/Water_Master_Plan_.pdf

14. NETRONLINE (NETRO). (n.d.). Historic aerials. https://www.historicaerials.com/

15. San Joaquin County. (2014). San Joaquin County 2035 General Plan Environmental Impact Report (EIR).

Adopted October 2014. Agriculture and Forestry Resources.

16. Southern California Association of Governments. (2020). 2020-2045 Regional Transportation Plan/ Sustainable Communities Strategy. Adopted September 3, 2020. https://scag.ca.gov/connectsocal

AIR QUALITY

17. California Air Resources Board. (2016). Ambient air quality standards. Adopted May 4, 2016. https://ww2.arb.ca.gov/sites/default/files/2020-07/aaqs2.pdf

18. CALGREEN. (2019). Green Building Code part 11, title 24, California code of Regulations. https://up.codes/viewer/california/ca-green-code-2019

19. City of Escalon. (2005). City of Escalon General Plan Update, Draft Environmental Impact Report. Adopted February 2005. Chapter 3.3.- Air Quality.

20. (Appendix A) Ganddini Group. (2023). Appendix A- Air quality, greenhouse gas, & energy technical memorandum. July 25, 2023.

21. San Joaquin Valley Air Pollution Control District (SJVAPCD). (n.d.). Ambient air monitoring network. https://ww2.valleyair.org/air-quality-information/air-monitoring/

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BIOLOGICAL RESOURCES

22. (Appendix B) ELMT ConsulAng. (2024). Appendix B- Biological Resources Assessment. August 2024.

23. California LegislaAve InformaAon. (n.d.). California fish and game code. hLps://leginfo.legislature.ca.gov/faces/codesTOCSelected.xhtml?tocCode=FGC&tocTitle=+Fish+and+Game+C ode+-+FGC

24. San Joaquin County. (2000). San Joaquin County mul
-species habitat conserva
on and open space plan
(SJMSCP). Adopted November 14, 2000. hLps://ca-sjcog2.civicplus.com/DocumentCenter/View/5/HabitatPlanpdf?bidId=

25. U.S. Fish and Wildlife Service. (1918). Migratory Bird Treaty Act of 1918. hLps://www.fws.gov/law/migratorybird-treaty-act-1918

CULTURAL RESOURCES

26. (Appendix C) BCR ConsulAng LLC. (2023). Appendix C- Cultural resources assessment City of Escalon connec
on to Nick DeGroot water treatment plant project, Escalon, San Joaquin County, CA. May 12, 2023.

ENERGY

27. CALGREEN. (2019). Green Building Code part 11,
tle 24, California Code of Regula
ons.
hLps://up.codes/viewer/california/ca-green-code-2019

28. San Joaquin County. (2014). San Joaquin County 2035 General Plan Environmental Impact Report (EIR).

Adopted October 2014. SecAon P: Energy and Climate Change.

29. South San Joaquin IrrigaAon District. (2020). Urban water quality management plan. Adopted 2020. hLps://www.ssjid.com/wp-content/uploads/2020_UWMP_SSJID.pdf

GEOLOGY AND SOILS

30. BaseCamp Environmental Inc.. (2021). Administrative review draft initial study: Geology and soils.

31. California Department of Conservation. (n.d.). Geologic hazards data and maps. https://maps.conservation.ca.gov/geologichazards/

32. California Department of Conservation. (n.d.). Seismic Hazards Mapping Act. https://www.conservation.ca.gov/cgs/hazards/seismic-hazards-mappingact#:~:text=Liquefaction%20is%20defined%20as%20the,information%20and%20subsurface%20geotechnical %20data

33. Southern California Earthquake Data Center (SCDEC). (n.d.). CalTech/ USGS Southern California Seismic Network (SCSN). https://scedc.caltech.edu/index.html

34. City of Escalon Chapter 1- Standard SpecificaAons hLps://cdn5- hosted.civiclive.com/UserFiles/Servers/Server_10745808/File/Government/Departments/Development%20S ervices/Engineering/Improvement%20Standards/escalon%20standard%20specificaAons.pdf

35. Local Hazard MiAgaAon Plan, San Joaquin County, revised 2017, hLps://www.sjgov.org/docs/defaultsource/office-of-emergency-services-documents/lhmp/documents/local-hazard-migraAonplan.pdf?sfvrsn=b92c072_11

36. Emergency OperaAon Plan (EOP), County of San Joaquin Office of Emergency Services, February 17th, 2022, hLps://www.sjgov.org/docs/default-source/office-of-emergency-services-documents/emergencyplans/2022-sjc-emergency-operaAons-plan.pdf?sfvrsn=6fdd3c17_3

GREENHOUSE GAS EMISSIONS

37. California Air Resources Board. (2016). Assembly Bill 32: Global Warming Solu ons Act of 2006.
hLps://ww2.arb.ca.gov/resources/fact-sheets/ab-32-global-warming-soluAons-act-2006

38. California Air Resources Board. (n.d.). California greenhouse gas emission inventory program. hLps://ww2.arb.ca.gov/ghg-inventory-data

39. California Air Resources Board. (2022). California’s 2022 climate change scoping plan. hLps://ww2.arb.ca.gov/sites/default/files/2022-12/2022-sp.pdf

40. California Environmental ProtecAon Agency (CalEPA). (2020). California climate investments report 2020:

PuOng cap-and-trade dollars to work for California. hLps://calepa.ca.gov/climate/climate-investments/

41. (Appendix A) Ganddini Group. (2023). Appendix A- Air quality, greenhouse gas, & energy technical memorandum. July 25, 2023.

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 125

42. San Joaquin County. (2014). San Joaquin County 2035 General Plan Environmental Impact Report (EIR). Adopted October 2014. SecAon P: Energy and Climate Change.

HAZARDS AND HAZARDOUS MATERIALS

43. California Department of Toxic Substances Control (DTSC). (n.d.). EnviroStor database. https://www.envirostor.dtsc.ca.gov/public/

44. San Joaquin County. (2014). San Joaquin County 2035 General Plan Environmental Impact Report (EIR).

Adopted October 2014. Section R: Hazards and Hazardous Materials.

45. U.S. Environmental Protection Agency (EPA). (n.d.). Comprehensive environmental response, compensation, and liability information system (CERCLIS) database. https://www.epa.gov/superfund/superfund-sites-whereyou-live

46. Escalon High School Enrollment Rate. U.S. News & World Report. (2023). Escalon High School enrollment rate. https://www.usnews.com/education/best-high-schools/california/districts/escalon-unified-schooldistrict/escalon-high-school-2143

47. California Unified Program Agency (CUPA), San Joaquin County Environmental Health Department (EHD) San Joaquin County Environmental Health Department. (n.d.). California Unified Program Agency (CUPA). https://www.sjgov.org/department/envhealth/programs/certified-unified-program-agency-(cupa)

48. State Water Resources Control Board GeoTracker State Water Resources Control Board. (n.d.). GeoTracker. https://geotracker.waterboards.ca.gov/

49. Department of Toxic Substances Control. (n.d.). EnviroStor - Hazardous waste and substances site list (CORTESE).
https://www.envirostor.dtsc.ca.gov/public/search?cmd=search&reporttype=CORTESE&site_type=CSITES,FUD S&status=ACT,BKLG,COM&reporttitle=HAZARDOUS+WASTE+AND+SUBSTANCES+SITE+LIST+%28CORTESE%29

50. Local Hazard Mitigation Plan, San Joaquin County. (2017). Local hazard mitigation plan (revised 2017). https://www.sjgov.org/docs/default-source/office-of-emergency-servicesdocuments/lhmp/documents/local-hazard-migration-plan.pdf?sfvrsn=b92c072_11

51. Emergency Operation Plan (EOP), County of San Joaquin Office of Emergency Service San Joaquin County Office of Emergency Services. (2022, February 17). Emergency operations plan. https://www.sjgov.org/docs/default-source/office-of-emergency-services-documents/emergencyplans/2022-sjc-emergency-operations-plan.pdf?sfvrsn=6fdd3c17_3

52. City of Escalon General Plan. City of Escalon. (n.d.). General plan: Safety element.

53. Regulatory Announcement, Office of Transportation and Air Quality, Environmental Protection Agency Office of Transportation and Air Quality, Environmental Protection Agency. (2004, May). Clean air nonroad diesel rule https://nepis.epa.gov/Exe/ZyPDF.cgi/P10001RN.PDF?Dockey=P10001RN.PDF

HYDROLOGY AND WATER QUALITY

54. California Department of Water Resources. (n.d.). California Water Plan Update 2018. https://water.ca.gov/Programs/California-Water-Plan

55. California State Water Resources Control Board (SWRCB). (n.d.). GeoTracker database. https://geotracker.waterboards.ca.gov/

56. San Joaquin County. (2014). San Joaquin County 2035 General Plan Environmental Impact Report (EIR).

Adopted October 2014. Section Q: Hydrology and Water Quality.

57. U.S. Geological Survey (USGS). (n.d.). National Water Information System (NWIS). https://waterdata.usgs.gov/nwis

58. South San Joaquin Irrigation District. (n.d.). Groundwater sustainability plan adopted. https://www.ssjid.com/groundwater-sustainability-plan-adopted/

59. Eastern San Joaquin Groundwater Authority. (2019). Subbasin groundwater sustainability plan. https://esjgroundwater.org/gsp/

60. Greater San Joaquin Regional Water Coordination Committee. (2021). Eastern San Joaquin integrated regional water management plan 2020 addendum. https://esjirwm.org/integrated-regional-watermanagement-plan-irwmp/eastern-san-joaquin-icu-program/

61. California Department of Conservation. (n.d.). Geologic hazards data and maps (tsunami). https://cadoc.maps.arcgis.com/home/webmap/viewer.html?useExisting=1&layers=2769c700c0694548b5435 a60ff52b807

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 126

62. San Joaquin County Department of Public Works, Flood Management Division. (n.d.). Building in a special flood hazard area. https://sjwater.org/SFHA-Construction-Booklet.pdf

63. San Joaquin County Department of Public Works, Flood Management Division. (n.d.). Flood hazards in San Joaquin County. https://www.sjgov.org/docs/default-source/public-works-documents/water-resources/floodpage-brochures/information-on-flood-plains.pdf?sfvrsn=ce61c1af_3

LAND USE AND PLANNING

64. San Joaquin Council of Governments Board Regional TransportaAon Plan and Sustainable CommuniAes Strategy (RTP/SCS), adopted June 28th, 2018, hLps://www.sjcog.org/278/Adopted-2018-RTPSCS

MINERAL RESOURCES

65. San Joaquin County. (2014). San Joaquin County 2035 General Plan Environmental Impact Report (EIR).

Adopted October 2014. Section O Mineral Resources
i. Figure 4.O-1: Aggregate Resources
ii. Table 4.0-1: Status of Aggregate Mines in San Joaquin County NOISE

66. California Department of Transportation (CalTrans). (n.d.). Transportation and construction-induced vibration guidance manual. https://dot.ca.gov/programs/environmental-analysis/noise-vibration/guidance-manuals

67. Federal Highway Administration (FHWA). (2017). Highway traffic noise: Analysis and abatement guidance. https://www.fhwa.dot.gov/environment/noise/regulations_and_guidance/analysis_and_abatement_guidanc e/

68. San Joaquin County. (2014). San Joaquin County 2035 General Plan Environmental Impact Report (EIR).

Adopted October 2014. Section T: Noise.
i. Table 4.H-9: Maximum Nose Exposure Criteria from StaAonary Noise Sources

POPULATION AND HOUSING

69. SJCOG, 6th Cycle Regional Housing Needs 2023-2031 Regional Housing Needs Plan (RHNP), adopted September 22, 2022, hLps://www.sjcog.org/DocumentCenter/View/7407/2022-SJCOG-RHNP_Adopted-Sep-2022_Oct22

70. San Joaquin County California, 2015-2023 Housing Element, adopted December 15, 2015, cerAfied October 13th, 2016, hLps://www.sjgov.org/commdev/cgi-bin/cdyn.exe/file/Planning/Documents/2015- 2023%20HOUSING%20ELEMENT.pdf
a. Table 7-9: San Joaquin Council of Governments PopulaAon ProjecAons

71. Southern California AssociaAon of Government, Regional TransportaAon Plan/ Sustainable CommuniAes Strategy, adopted 2016, hLps://scag.ca.gov/sites/main/files/file-aLachments/f2016rtpscs.pdf?1606005557

72. City of Escalon Water Master Plan, adopted January 2007, hLps://cdn5- hosted.civiclive.com/UserFiles/Servers/Server_10745808/File/Government/Departments/Development%20S ervices/Engineering/Water_Master_Plan_.pdf
a. Table 2-2: Community Development Needs, 2005- 2025

PUBLIC SERVICES

73. Escalon Fire Department, hLps://www.escalonfire.com/about-2

74. City of Escalon Police Department, Department Policies, hLps://escalon.hosted.civiclive.com/government/departments/police/policiesprocedures

75. South San Joaquin IrrigaAon District (SSJID) Water Master Plan, adopted 2022, hLps://www.ssjid.com/watermaster-plan/

76. San Joaquin County Flood Control and Water ConservaAon District, Water Management Plan, Phase 1- Planning Analysis and Strategy- Volume 1, adopted October 2001, hLps://www.sjgov.org/docs/defaultsource/public-works-documents/water-resources/san-joaquin-water-management-plan-vol1.pdf?sfvrsn=7e2a528b_3

RECREATION

77. San Joaquin County. (2014). San Joaquin County 2035 General Plan Environmental Impact Report (EIR).

Adopted October 2014. SecAon W: RecreaAon.
a. Table 4.M-4: ExisAng Park and Open Space Areas in San Joaquin County

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 127

TRANSPORTATION

78. California Department of Transportation (CalTrans). (n.d.). Transportation impact studies guidance. https://dot.ca.gov/programs/transportation-planning/office-of-smart-mobility-climate-change/land-usedevelopment/transportation-impact-study

79. San Joaquin County. (2014). San Joaquin County 2035 General Plan Environmental Impact Report (EIR).

Adopted October 2014. Section X: Transportation.

TRIBAL CULTURAL RESOURCES

80. BCR Consulting LLC. (2023). Appendix C- Cultural resources assessment City of Escalon connection to Nick DeGroot water treatment plant project, Escalon, San Joaquin County, CA. May 12, 2023.

81. San Joaquin County. (2014). San Joaquin County 2035 General Plan Environmental Impact Report (EIR).

Adopted October 2014. Section Y: Tribal Cultural Resources.

WILDFIRE

82. CAL FIRE, Top 20 Largest California Wildfires (Jan. 13, 2022), hLps://www.fire.ca.gov/media/4jandlhh/top20_acres.pdf

83. Best PracAces for Analyzing and MiAgaAng Wildfire Impacts of Development Projects Under the California Environmental Quality Act, State of California Office of the ALorney General- Rob Bonta

84. California Department of Forestry and Fire Protection (Cal Fire). (n.d.). Fire hazard severity zone maps. https://www.fire.ca.gov/fire-prevention/fire-prevention-wildland-maps/

85. San Joaquin County. (2014). San Joaquin County 2035 General Plan Environmental Impact Report (EIR).

Adopted October 2014. Section AA: Wildfire.

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 128

8.0 APPENDICES
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OCTOBER 16, 2024

CITY OF ESCALON CONNECTION TO NICK DEGROOT WATER TREATMENT PLANT

FINAL INITIAL STUDY/ MITIGATED NEGATIVE DECLARATION

ESCALON, SAN JOAQUIN COUNTY, CALIFORNIA
STATE CLEARINGHOUSE NO. SCH 2024090184
LEAD AGENCY:

CITY OF ESCALON
2060 MCHENRY AVENUE, ESCALON, CA 95320
PREPARED BY:

(Intentionally Blank Page)

FINAL INITIAL STUDY/

MITIGATED NEGATIVE DECLARATION
FOR

CITY OF ESCALON CONNECTION TO NICK DEGROOT

WATER TREATMENT

ESCALON, SAN JOAQUIN COUNTY, CALIFORNIA
State Clearinghouse No. 2024090184

PREPARED FOR:

CITY OF ESCALON
2060 McHenry Avenue
Escalon, CA 95320
209-691-7430
OCTOBER 16, 2024
PREPARED BY:

ARDURRA GROUP
3737 Birch Street, Suite 250
Newport Beach, CA 96220

City of Escalon Connection to Nick DeGroot Water Treatment Plant Final Initial Study/ Mitigated Negative Declaration
State Clearinghouse No. 2024090184
October 2024 Page i City of Escalon
Table of Contents

1.0 INTRODUCTION .......................................................................................................................................... 1

2.0 RESPONSE TO PUBLIC COMMENTS ........................................................................................................... 2

3.0 ERRATA ..................................................................................................................................................... 36

4.0 FINAL MITIGATION MONITORING AND REPORTING PROGRAM ............................................................. 42

5.0 FINAL ISMND ............................................................................................................................................ 67

City of Escalon Connection to Nick DeGroot Water Treatment Plant Final Initial Study/ Mitigated Negative Declaration
State Clearinghouse No. 2024090184
October 2024 Page 1 City of Escalon

1.0 INTRODUCTION
Pursuant to California Environmental Quality Act (CEQA) Section 15073, the City of Escalon has prepared responses to comments received during the 30-day public review period on the Draft IS/MND for the City of Escalon Connection to Nick DeGroot Water Treatment Plant. The Response to Comments and Errata, which are included in this document, together with the revised Draft IS/MND and revised Appendices, and the Final Mitigation Monitoring and Reporting Program (MMRP), comprise the Final IS/MND for use by the City of Escalon in its review and consideration of the environmental impacts of implementing the City of Escalon Connection to Nick DeGroot Water Treatment Plant.

This Final Initial Study Mitigated Negative Declaration (IS/MND) document is organized into five sections:

Section 1—Introduction.

Section 2—Response to Comments: Provides a list of the agencies, organizations, and individuals who commented on the Draft IS/MND during the 30-day public review period, which began on September 6, 2024, and ended on October 7, 2024. Copies of all letters received on the Draft IS/MND and written responses to these comments are included in this section.

Section 3—Errata: During the public review period, comments from California Department of Fish and Wildlife (CDFW) resulted in changes to the document and modified mitigation measures.

Section 4—Final Mitigation Monitoring and Reporting Program: Provides a list of Mitigation Measures with changes made as summarized in the Errata.

Section 5—Final IS/MND and Appendices (Separate Cover).

The Draft IS/MND that was circulated for public review has been revised to incorporate revisions shown as Errata in underline/strikeout. As summarized in Section 3, text additions are underlined, and deletions are shown in strikeout. The Final IS/MND includes the following contents:
• Draft IS/MND Project Description and CEQA Environmental Checklist • Draft IS/MND Appendices
o APPENDIX A: Air Quality and Greenhouse Gas Impact Study/Energy (Ganddini 2023) o APPENDIX B: Biological Resources (ELMT 2024) - Updated o APPENDIX C: Cultural/Archaeological/Tribal/ Paleontological Resources Report (BCR Consulting 2023)
o APPENDIX D: Noise Study (Ganddini 2023)
Considering reasonably anticipated environmental consequences that can be expected from Project implementation, based on the location and proposed scope of the Project, the City of Escalon has determined that this Final IS/MND has been written with a sufficient degree of analysis to make an informed decision on whether the Project will have a significant impact on the environment as a basis for approving the Project. Therefore, this Final IS/MND has been completed in compliance with CEQA.

Based on the revisions found within Section 3- Errata, the Draft IS/MND will not require recirculation since “substantial changes” did not occur.

City of Escalon Connection to Nick DeGroot Water Treatment Plant Final Initial Study/ Mitigated Negative Declaration
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October 2024 Page 2 City of Escalon

2.0 RESPONSE TO PUBLIC COMMENTS
A Public Review Period for the Project started on September 6, 2024, and concluded on October 7, 2024.

During the public review period, an email was received from California Department of Fish and Wildlife.

TABLE 1: SUMMARY OF COMMENTERS
Comment Letter No. Person, Firm, or Agency Letter Dated 1 California Department of Fish and Wildlife 10/04/24 Email 2 Central Valley Regional Water Quality Control
Board 10/07/24
3 State Water Resources Control Board 10/07/24
For each comment, a written response was given to ensure that comments from each agency were evaluated and incorporated into the final document for a comprehensive and meaningful review of the proposed Project. The Comment Numbers are correlated with the bracketed and identified portions of each comment letter.

Comments from CDFW, have resulted in revisions to the proposed mitigation measures for biological resources. Revisions to the Draft IS/MND are noted as follows: an addition is indicated in double-underline to the text; strikethrough indicates deletions to the text.

City of Escalon Connection to Nick DeGroot Water Treatment Plant Final Initial Study/ Mitigated Negative Declaration
State Clearinghouse No. 2024090184
October 2024 Page 3 City of Escalon
RESPONSE TO COMMENTS MATRIX – California Department of Fish and Wildlife Commenter Comment
Number
Comment Response Revision(s) to
ISMND
Zachary Kearns,
Senior Environmental Scientist (Specialist) CDFW
1-1 The California Department of Fish and
Wildlife (CDFW) appreciates the opportunity to comment on the Draft Initial Study/Mitigated Negative Declaration (IS/MND) for the City of Escalon Connection to Nick Degroot Water Treatment Plant (project). CDFW is responding to the IS/MND as a Trustee Agency for fish and wildlife resources (Fish & G. Code, §§ 711.7 & 1802, and CEQA Guidelines, §§ 15386), and as a Responsible Agency regarding any discretionary actions (CEQA Guidelines Section 15381), such as the issuance of a Lake or Streambed Alteration Agreement (California Fish and Game Code Sections 1600 et seq.) and/or a California Endangered Species Act (CESA) Permit for incidental take of endangered, threatened, and/or candidate species (California Fish and Game Code Sections 2080 and 2080.1). The project spans from approximately Latitude: 37.804888, Longitude: -120.997823 to approximately Latitude: 37.856665, Longitude: -120.999258 along Escalon-Bellota Road, in San Joaquin County. The project consists of coordination between the City of Escalon (Lead Agency), South San Joaquin Irrigation District (SSJID), the County of San Joaquin, and Oakdale Irrigation District (OID). The proposed project would install CDFW provided an email with comments to the City of Escalon in response to the circulation of the ISMND and MMRP for public review by state agencies. CDFW’s comments were received on October 4, 2024. Comment 1-1 is the introduction to CDFW comments and describes CDFW’s project understanding. CDFW is providing comments as a Trustee Agency for fish and wildlife resources pursuant to Fish & G. Code, §§ 711.7 & 1802, and CEQA Guidelines, §§ 15386.

No revisions
are required.

City of Escalon Connection to Nick DeGroot Water Treatment Plant Final Initial Study/ Mitigated Negative Declaration
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October 2024 Page 4 City of Escalon
Commenter Comment
Number
Comment Response Revision(s) to
ISMND
Zachary Kearns,
Senior Environmental Scientist (Specialist) CDFW
1-1
Continued
approximately 19,500 linear feet of 18-inch
PVC potable water line using along existing Escalon-Bellota asphalt roadway and County easement, construction of a new flow control facility (FCF) on existing agricultural land, and construction of a new booster pump station (BPS).

Zachary Kearns,
Senior Environmental Scientist (Specialist) CDFW
1-2

CDFW recommends the following items be addressed in the future planning of the project: 1. Fully Protected Species. A Fully Protected Species (Fish & G. Code § 4700) has the potential to occur within or adjacent to the project area, including, but not limited to: White-Tailed Kite (Elanus leucurus). Fully protected species may not be taken or possessed at any time. Project activities should be designed to completely avoid any fully protected species that have the potential to be present within or adjacent to the project area. Appendix B of the ISMND identifies the White-Tailed Kite as a fully protected species on page 154 of the report. The White-Tailed Kite is a raptor. On page 30 of the circulated Draft ISMND and pages 4 and 5 of the circulated MMRP, the environmental analysis for the Project recommends mitigation measures MM BIO-01 through MM BIO-04, which are intended to implement CDFW protocol for protecting birds and raptors under supervision of the City’s qualified biologist to avoid potentially significant impacts to raptors and nesting raptors, such as the White-Tailed Kite, and nesting migratory birds, of which there are many species; Therefore, the circulated Draft ISMND indicates construction impacts on raptors and their nests and active bird nests of all kinds are a potentially significant impact during construction that will be reduced to less than significant levels by requiring preconstruction surveys for nesting birds and raptors within all vegetation and trees that may be directly or indirectly affected by the Project, as well as implementing appropriate protocol within these areas, prior to the start of construction. The pre-construction surveys will be conducted by the City’s qualified biologist, in cooperation with the City and the contractor, within an appropriate buffer surrounding the Project; the buffer indicated in MM BIO-03 is up to a 500-foot radius for raptors. Mitigation measures for the Project require preconstruction surveys for migratory birds and raptors to be conducted by the City’s qualified biologist and buffers or other appropriate protocols must be implemented by the City’s biologist to protect species pursuant to the Fish and Game Code and MBTA.

Appendix B,
Table 14, MM
BIO-01 through MM BIO-04
modified as
stated in the response to comment.

City of Escalon Connection to Nick DeGroot Water Treatment Plant Final Initial Study/ Mitigated Negative Declaration
State Clearinghouse No. 2024090184
October 2024 Page 5 City of Escalon
Commenter Comment
Number
Comment Response Revision(s) to
ISMND
Zachary Kearns,
Senior Environmental Scientist (Specialist) CDFW
1-2
Continued The CCDNB query for the Project that was circulated for public review did not show potential for White-Tailed Kite at the Project Site and the report has been updated with a new and revised database query indicating White-Tailed Kite could potentially occur within proximity of the Project. This is not a new impact, as the circulated Draft ISMND indicates potential impacts to raptors, which includes but is not limited to White-Tailed Kite, Burrowing Owl, and Swainson’s Hawk, and requires mitigation measures for the Project during construction to fully protect raptors and migratory birds, which may consist of distance buffers, barriers, or other agency-required protocol. For clarification, Mitigation Measures MM BIO-01 and BIO-02 have been modified to require preconstruction nesting surveys conducted fifteen (15) days and three (3) days prior to construction, regardless of the season. Subheadings have been added to the mitigation measures to clarify actions required by the City and contractor for specific species. MM BIO-01 also requires crew training shall be provided by the City’s biologist based on the results of the preconstruction surveys provided by the City’s biologist.

Zachary Kearns,
Senior Environmental Scientist (Specialist) CDFW
1-3

2. Nesting Birds. Sections 3503, 3503.5, and 3513 of the Fish and Game Code protect nesting and migratory birds and birds of prey. Section 3503 states that it is unlawful to take, possess, or needlessly destroy the nest or eggs of any bird, except as otherwise provided by the Fish and Game Code or any regulation made pursuant thereto. Section 3503.5 states that it is unlawful to take, possess, or destroy any birds in the orders Falconiformes or Strigiformes (birds of prey) or to take, possess, or destroy the nest or eggs of any such bird except as otherwise provided by the Fish and Game The Project will implement Mitigation Measures MM BIO-01 through BIO-04 as indicated in the circulated Draft ISMND, MMRP and Errata updating these mitigation measures for clarity. Pursuant to revised Mitigation Measures MM BIO-01 through BIO-04, preconstruction nesting surveys will be conducted fifteen (15) days and three (3) days prior to construction, regardless of the season. MM BIO-03 of the circulated Draft ISMND specifically requires a minimum 500-foot buffer for raptors. Therefore, significant impacts on nesting birds will be avoided. MM BIO-01 through MM BIO-04 modified as stated in the response to comment.

City of Escalon Connection to Nick DeGroot Water Treatment Plant Final Initial Study/ Mitigated Negative Declaration
State Clearinghouse No. 2024090184
October 2024 Page 6 City of Escalon
Commenter Comment
Number
Comment Response Revision(s) to
ISMND
Zachary Kearns,
Senior Environmental Scientist (Specialist) CDFW
1-3
Continued
Code or any regulation adopted pursuant
thereto. Section 3513 states that it is unlawful to take or possess any migratory nongame bird as designated in the federal Migratory Bird Treaty Act. MMBIO-04 on Page xliii of the IS/MND describes the nesting season from March to late August. CDFW recommends that nesting bird surveys be conducted if project activities are scheduled to occur between February 1 and August 31, to fully encapsulate the potential nesting season. The survey should take place no more than 15 calendar days prior to ground disturbing activities. CDFW typically recommends a minimum of a 500-foot survey radius for migrating birds, and a ½ mile survey radius for nesting raptors.

Zachary Kearns,
Senior Environmental Scientist (Specialist) CDFW
1-4

3. Swainson’s Hawk. Swainson’s hawk (Buteo swainsoni) (SWHA) is a species listed as threatened under CESA and has the potential to occur on the project area. California Natural Diversity Database (CNDDB) has records of at least three (3) previous SWHA occurrences within five (5) miles of the project area. Review of aerial imagery also suggests that there may be suitable nesting trees and foraging habitat on open farmland. CDFW recommends a qualified biologist conduct a SWHA survey within a minimum 1/2-mile radius around the project area. Page 26 of the circulated Draft ISMND identifies Swainson’s Hawk as a species listed under CESA with potential to occur in the area. Mitigation Measures have been modified to include specific recommendations for Swainson’s Hawk that are outlined in CDFW Comment 1-4, which reflect current protocol for this species. MM BIO-01 Modified

City of Escalon Connection to Nick DeGroot Water Treatment Plant Final Initial Study/ Mitigated Negative Declaration
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October 2024 Page 7 City of Escalon
Commenter Comment
Number
Comment Response Revision(s) to
ISMND
Zachary Kearns,
Senior Environmental Scientist (Specialist) CDFW
1-4
Continued
Surveys should be conducted according to the following the five-period schedule in accordance with the “Recommended Timing and Methodology for Swainson's Hawk Nesting 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 • 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 activities, the project proponent should consult with CDFW and demonstrate compliance with CESA. CDFW is responsible for ensuring appropriate conservation 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 potential to result in “take” (Fish & G. Code § 86 defines “take” as “hunt, pursue, catch, capture, or

City of Escalon Connection to Nick DeGroot Water Treatment Plant Final Initial Study/ Mitigated Negative Declaration
State Clearinghouse No. 2024090184
October 2024 Page 8 City of Escalon
Commenter Comment
Number
Comment Response Revision(s) to
ISMND
1-4
Continued
kill, or attempt to hunt, pursue, catch,
capture, or kill”) of CESA-listed species, either through construction or over the life of the project.

Zachary Kearns,
Senior Environmental Scientist (Specialist) CDFW
1-5

4. Passive Relocation and Entrapment Prevention: At the end of each workday, any structures where wildlife may become trapped (e.g. open pipes, pits, trenches, etc.) should be tightly covered with hard material to prevent wildlife from entering, or an escape ramp should be placed at each end of any open excavation to allow wildlife that may become trapped to climb out overnight. The ramp may be constructed of either dirt fill or wood planking or other suitable material that is placed at an angle no greater than thirty (30) degrees. A qualified biologist or construction monitor should survey the project area prior to work each day to ensure wildlife incidentally trapped due to project activities are allowed to escape prior to project commencement.

The Project will be constructed within public right-of-way where covering and backfilling trenches and pits overnight is required through the typical application of the City of Escalon’s Standard Engineering Specifications. In the Project Description, on page xxiii of the circulated ISMND, the ISMND states that “Temporary fencing will be constructed around each work area to control access and for safety and security overnight and will be closed, concluding daily construction activities. Active construction within the paved right-ofway will either be backfilled or covered with trench plates by the end of each workday.” Modified MM TRAF-02 of the circulated MMRP and ISMND specifically requires trench plates or backfill placed at the end of each workday as part of the traffic control plan. Mitigation Measure MM BIO-01 in the circulated Draft MMRP and ISMND states that “Limits of construction to avoid an active nest will be established in the field with flagging, fencing, or other appropriate barriers; and construction personnel will be instructed on the sensitivity of nest areas.” MM BIO-01 has been modified to clarify construction requirements and daily inspections so that disturbance, take, possession, and destruction of any protected birds or raptors is completely avoided.

No Further
Revisions Needed.

Zachary Kearns,
Senior Environmental Scientist (Specialist) CDFW
1-6

5. Lake and Streambed Alteration: Section 1602 of the Fish and Game Code requires an entity to notify CDFW prior to commencing any activity that may do one or more of the following: a. Substantially divert or obstruct the natural flow of any river, stream, or lake; Mitigation measures MM BIO-05 and MM HYDRO-01 through MM HYDRO-04 have been incorporated into the Project to avoid significant impacts on surface waters and surface water quality. MM BIO-05 from the circulated Draft ISMND and MMRP requires 50-foot setbacks and monitoring by the City’s, to avoid and prevent construction debris, waste, or other materials from entering into surface waters. Page 29 of the circulated Draft ISMND states that “…jack and bore construction is proposed underneath Lone Tree Creek, [and] impacts may occur. Therefore, the Project will implement Mitigation Measure Modified MM BIO-05: Jack and Bore Construction No Further
Revisions Needed.

City of Escalon Connection to Nick DeGroot Water Treatment Plant Final Initial Study/ Mitigated Negative Declaration
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October 2024 Page 9 City of Escalon
Commenter Comment
Number
Comment Response Revision(s) to
ISMND

Zachary Kearns, Senior Environmental Scientist (Specialist) CDFW

1-6
Continued
b. Substantially change or use any material from the bed, channel or bank of any river, stream, or lake; or c. Deposit debris, waste or other materials where it may pass into any river, stream or lake. Please note that "any river, stream or lake" includes those that are episodic (i.e., those that are dry for periods of time) as well as those that are perennial (i.e., those that flow year-round). This includes ephemeral streams and watercourses with a subsurface flow. It may also apply to work undertaken within the flood plain of a body of water. Page 29 of the IS/MND states that proposed construction includes jack and bore construction underneath Lone Tree Creek and that “…CDFW jurisdictional areas and regulatory approvals will not be required.” This activity may trigger Notification with CDFW due to the description in comment 5 (c) above. If upon review of an entity’s notification, CDFW determines that the project activities may substantially adversely affect an existing fish or wildlife resource, a Lake and Streambed Alteration (LSA) Agreement will be issued which will include reasonable measures necessary to protect the to ensure that a Project biologist is onsite during jack and bore construction. As a result, impacts are anticipated to be less than significant with mitigation incorporated.” Mitigation Measure BIO- Modified MM BIO-05 requires that bore pits shall be excavated at least 50 feet outside the edge of riparian vegetation to avoid impacts that will trigger an LSA permit. MM HYDRO-01 specifically requires the City Engineer to verify that plans for the Project show no direct impacts to surface water. The City’s standard process for plan review, approval and CIP implementation will provide verification during plan check and inspections that there will be no significant direct or indirect impacts on surface waters regulated by CDFW. The standard application of the City’s Engineering Specifications, Section 01400, requires sampling and testing by the contractor and verification by the city for quality control for environmental and safety compliance during construction. The City may initiate early communication with CDFW regarding necessary permits during final design for the Project. A biological monitor shall also be present during staking for jack and bore and during jack and bore construction to verify no direct impacts to surface waters occur and that the setbacks from regulated resources are maintained. Furthermore, implementation of hydrology and water quality mitigation measures MM HYDRO – 01 through HYDRO-04 from the circulated Draft ISMND will be implemented throughout construction to prevent deposit, debris, waste or other materials entering into any river or stream or lake. Due to the standard application of the City’s Engineering Specifications, construction setbacks from Lone Tree Creek, as well as erosion control and water quality measures implemented during construction, less than significant impacts on Lone Tree Creek are anticipated. The first two paragraphs of page 69 of the circulated Draft ISMND state that the project will implement mitigation measures so that construction does not result in water quality No Further Revisions Needed.

City of Escalon Connection to Nick DeGroot Water Treatment Plant Final Initial Study/ Mitigated Negative Declaration
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October 2024 Page 10 City of Escalon
Commenter Comment
Number
Comment Response Revision(s) to
ISMND

Zachary Kearns, Senior Environmental Scientist (Specialist) CDFW

1-6
Continued
resource. CDFW’s issuance of an LSA Agreement is a “project” subject to CEQA (see Pub. Resources Code 21065). To facilitate issuance of an LSA Agreement, if one is necessary, the environmental document should fully identify the potential impacts to the lake, stream, or riparian resources, and provide adequate avoidance, mitigation, and monitoring and reporting commitments. Early consultation with CDFW is recommended, since modification of the project may avoid or reduce impacts to fish and wildlife resources. LSA Notification types must be submitted online through CDFW’s Environmental Permit Information Management System (EPIMS). For more information about EPIMS, please visit https://wildlife.ca.gov/Conservation/Environmental-Review/EPIMS. More information about LSA Notifications, paper forms and fees may be found at https://www.wildlife.ca.gov/Conservation/Environmental-Review/LSA. degradation. Implementation of MM HYDRO-01 through HYRDO-04 will reduce potentially significant impacts to less than significant levels. No Revisions Needed.

Zachary Kearns,
Senior Environmental Scientist (Specialist) CDFW
1-7 Pursuant to Public Resources Code sections
21092 and 21092.2, CDFW requests written notification of proposed actions and pending decisions regarding the project. Written notifications may be directed to: California Department of Fish and Wildlife North Central Region, 1701 Nimbus Road, Rancho Cordova, CA 95670.

The Escalon City Council will hold a public hearing in the Council Chambers, City Hall, 2060 McHenry Ave, Escalon, California, on October 21, 2024, at 7:00 PM to consider adoption of the IS/MND and MMRP.

No Revisions
Needed.

City of Escalon Connection to Nick DeGroot Water Treatment Plant Final Initial Study/ Mitigated Negative Declaration
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Commenter Comment
Number
Comment Response Revision(s) to
ISMND
Zachary Kearns,
Senior Environmental Scientist (Specialist) CDFW
1-8
CDFW appreciates the opportunity to comment on the project and recommends that the City of Escalon address CDFW’s comments and concerns in the forthcoming CEQA document. CDFW personnel are available for consultation regarding biological resources and strategies to minimize impacts. If you have any questions regarding the comments provided in this letter or wish to schedule a meeting and/or site visit, please contact Zach Kearns, Senior Environmental Scientist (Specialist) at (916) 358-1134 or [email protected].

This is a closing statement from the CDFW. Thank you. We appreciate your input on the ISMND.

No Revisions
Needed.

Haggerty, Nicole@Wildlife
From: Kearns, Zachary@Wildlife
Sent: Friday, October 4, 2024 7:45 AM
To: [email protected]
Cc: Wildlife R2 CEQA; Kilgour, Morgan@Wildlife; Sheya, Tanya@Wildlife; Wilson, Billie@Wildlife
Subject: CDFW Comments - City of Escalon Connection to Nick DeGroot Water Treatment Plant Hello Jaylen French,
The California Department of Fish and Wildlife (CDFW) appreciates the opportunity to comment on the Draft Initial Study/Mitigated Negative Declaration (IS/MND) for the City of Escalon Connection to Nick Degroot Water Treatment Plant (project). CDFW is responding to the IS/MND as a Trustee Agency for fish and wildlife resources (Fish & G. Code, §§ 711.7 & 1802, and CEQA Guidelines, §§ 15386), and as a Responsible Agency regarding any discretionary actions (CEQA Guidelines Section 15381), such as the issuance of a Lake or Streambed Alteration Agreement (California Fish and Game Code Sections 1600 et seq.) and/or a California Endangered Species Act (CESA) Permit for incidental take of endangered, threatened, and/or candidate species (California Fish and Game Code Sections 2080 and 2080.1).

The project spans from approximately Latitude: 37.804888, Longitude: -120.997823 to approximately Latitude: 37.856665, Longitude: -120.999258 along Escalon-Bellota Road, in San Joaquin County. The project consists of coordination between the City of Escalon (Lead Agency), South San Joaquin Irrigation District (SSJID), the County of San Joaquin, and Oakdale Irrigation District (OID). The proposed project would install approximately 19,500 linear feet of 18-inch PVC potable water line using along existing Escalon-Bellota asphalt roadway and County easement, construction of a new flow control facility (FCF) on existing agricultural land, and construction of a new booster pump station (BPS).

CDFW recommends the following items be addressed in the future planning of the project:

1. Fully Protected Species. A Fully Protected Species (Fish & G. Code § 4700) has the potential to occur within or adjacent to the project area, including, but not limited to: White-Tailed Kite (Elanus leucurus). Fully protected species may not be taken or possessed at any time. Project activities should be designed to completely avoid any fully protected species that have the potential to be present within or adjacent to the project area.

2. Nesting Birds. Sections 3503, 3503.5, and 3513 of the Fish and Game Code protect nesting and migratory birds and birds of prey. Section 3503 states that it is unlawful to take, possess, or needlessly destroy the nest or eggs of any bird, except as otherwise provided by the Fish and Game Code or any regulation made pursuant thereto. Section 3503.5 states that it is unlawful to take, possess, or destroy any birds in the orders Falconiformes or Strigiformes (birds of prey) or to take, possess, or destroy the nest or eggs of any such bird except as otherwise provided by the Fish and Game Code or any regulation adopted pursuant thereto. Section 3513 states that it is unlawful to take or possess any migratory nongame bird as designated in the federal Migratory Bird Treaty Act.

MMBIO-04 on Page xliii of the IS/MND describes the nesting season from March to late August. CDFW recommends that nesting bird surveys be conducted if project activities are scheduled to occur between February 1 and August 31, to fully encapsulate the potential nesting season. The survey should take place no more than 15 calendar days prior to ground disturbing activities. CDFW typically recommends a minimum of a 500-foot survey radius for migrating birds, and a ½ mile survey radius for nesting raptors.

3. Swainson’s Hawk. Swainson’s hawk (Buteo swainsoni) (SWHA) is a species listed as threatened under CESA and has the potential to occur on the project area. California Natural Diversity Database (CNDDB) has records of at least three (3) previous SWHA occurrences within five (5) miles of the project area. Review of aerial imagery also suggests that there may be suitable nesting trees and foraging habitat on open farmland.

CDFW recommends a qualified biologist conduct a SWHA survey within a minimum 1/2-mile radius around the project area. Surveys should be conducted according to the following the fiveperiod schedule in accordance with the “Recommended Timing and Methodology for Swainson's Hawk Nesting 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
 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 activities, the project proponent should consult with CDFW and demonstrate compliance with CESA. CDFW is responsible for ensuring appropriate conservation 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 potential to result in “take” (Fish & G. Code § 86 defines “take” as “hunt, pursue, catch, capture, or kill, or attempt to hunt, pursue, catch, capture, or kill”) of CESA-listed species, either through construction or over the life of the project.

4. Passive Relocation and Entrapment Prevention: At the end of each workday, any structures where wildlife may become trapped (e.g. open pipes, pits, trenches, etc.) should be tightly covered with hard material to prevent wildlife from entering, or an escape ramp should be placed at each end of any open excavation to allow wildlife that may become trapped to climb out overnight. The ramp may be constructed of either dirt fill or wood planking or other suitable material that is placed at an angle no greater than thirty (30) degrees. A qualified biologist or construction monitor should survey the project area prior to work each day to ensure wildlife incidentally trapped due to project activities are allowed to escape prior to project commencement.

5. Lake and Streambed Alteration: Section 1602 of the Fish and Game Code requires an entity to notify CDFW prior to commencing any activity that may do one or more of the following:

a. Substantially divert or obstruct the natural flow of any river, stream, or lake; b. Substantially change or use any material from the bed, channel or bank of any river, stream, or lake; or
c. Deposit debris, waste or other materials where it may pass into any river, stream or lake.

Please note that "any river, stream or lake" includes those that are episodic (i.e., those that are dry for periods of time) as well as those that are perennial (i.e., those that flow year-round). This includes ephemeral streams and watercourses with a subsurface flow. It may also apply to work undertaken within the flood plain of a body of water.

underneath Lone Tree Creek and that “…CDFW jurisdictional areas and regulatory approvals will not be required.” This activity may trigger Notification with CDFW due to the description in comment 5 (c) above.

If upon review of an entity’s notification, CDFW determines that the project activities may substantially adversely affect an existing fish or wildlife resource, a Lake and Streambed Alteration (LSA) Agreement will be issued which will include reasonable measures necessary to protect the resource. CDFW’s issuance of an LSA Agreement is a “project” subject to CEQA (see Pub. Resources Code 21065). To facilitate issuance of an LSA Agreement, if one is necessary, the environmental document should fully identify the potential impacts to the lake, stream, or riparian resources, and provide adequate avoidance, mitigation, and monitoring and reporting commitments. Early consultation with CDFW is recommended, since modification of the project may avoid or reduce impacts to fish and wildlife resources. LSA Notification types must be submitted online through CDFW’s Environmental Permit Information Management System (EPIMS). For more information about EPIMS, please visit https://wildlife.ca.gov/Conservation/Environmental-Review/EPIMS. More information about LSA Notifications, paper forms and fees may be found at
https://www.wildlife.ca.gov/Conservation/Environmental-Review/LSA.

6. Burrowing Owl (BUOW). The IS/MND states that BUOW is presumed absent from the site, however satellite and street imagery demonstrate potential nesting habitat adjacent to the project area on cleared agricultural land, or near disturbed areas with exposed soil and limited vegetation.

If construction activities are planned in suitable BUOW habitat, a qualified biologist should conduct a survey for burrowing owl following the methodology described in the Staff Report on Burrowing Owl Mitigation, within 1-2 weeks prior to the start of construction. If BUOW, or signs of BUOW presence such as whitewash, feathers, animal dung, etc. are detected or observed within 500 feet of the project area, the project proponent should develop an Impact Assessment consistent with the Staff Report on Burrowing Owl Mitigation and submit the Impact Assessment to CDFW prior to construction work. The final avoidance and mitigation measures should be determined in coordination with CDFW.

Pursuant to Public Resources Code sections 21092 and 21092.2, CDFW requests written notification of proposed actions and pending decisions regarding the project. Written notifications may be directed to:

California Department of Fish and Wildlife North Central Region, 1701 Nimbus Road, Rancho Cordova, CA 95670.

CDFW appreciates the opportunity to comment on the project and recommends that the City of Escalon address CDFW’s comments and concerns in the forthcoming CEQA document. CDFW personnel are available for consultation regarding biological resources and strategies to minimize impacts.

If you have any questions regarding the comments provided in this letter or wish to schedule a meeting and/or site visit, please contact Zach Kearns, Senior Environmental Scientist (Specialist) at (916) 358- 1134 or [email protected].

Sincerely,
Zach Kearns
Senior Environmental Scientist (Specialist)
(916) 358-1134
1701 Nimbus Rd.

Rancho Cordova, CA 95670

City of Escalon Connection to Nick DeGroot Water Treatment Plant Final Initial Study/ Mitigated Negative Declaration
State Clearinghouse No. 2024090184
October 2024 Page 16 City of Escalon
RESPONSE TO COMMENTS MATRIX – Central Valley Regional Water Quality Control Board Commenter Comment
Number
Comment Response Revision(s) to
ISMND
Peter G. Minkel, Engineering Geologist
(CVRWQCB)
2-1
October 7, 2024 Jaylen French City of Escalon 2060 McHenry Avenue Escalon, CA 95320 COMMENTS TO REQUEST FOR REVIEW FOR THE MITIGATED NEGATIVE DECLARATION, CITY OF ESCALON CONNECTION TO NICK DEGROOT WATER TREATMENT PLANT PROJECT, SCH#2024090184, SAN JOAQUIN COUNTY Pursuant to the State Clearinghouse’s 6 September 2024 request, the Central Valley Regional Water Quality Control Board (Central Valley Water Board) has reviewed the Request for Review for the Mitigated Negative Declaration for the City of Escalon Connection to Nick DeGroot Water Treatment Plant Project, located in San Joaquin County. Our agency is delegated with the responsibility of protecting the quality of surface and groundwaters of the state; therefore our comments will address concerns surrounding those issues.

CVRWQCB provided comments with an official letter to the City of Escalon and Office of Planning and Research (OPR) in response to the circulation of the ISMND and MMRP for public review by state agencies. CDFW’s comments were received on October 7, 2024. Comment 2-1 is the introduction and describes CVRWQCB’s review and responsibilities as a state agency and Trustee Agency to protect the quality of surface and groundwaters of the State.

No Revisions
Needed.
2-2
I. Regulatory Setting Basin Plan The Central Valley Water Board is required to formulate and adopt Basin Plans for all areas within the Central Valley region under Comment 2-2 reiterates that the Regional Water Board is reliant on water quality objectives outlined within their adopted Basin Plan to maintain compliance with Section 13240 of the Porter-Cologne Water Quality Control Act; and federal regulations. Due to the importance of the Basin plan, which provides water quality objectives to ensure No Revisions Needed.

City of Escalon Connection to Nick DeGroot Water Treatment Plant Final Initial Study/ Mitigated Negative Declaration
State Clearinghouse No. 2024090184
October 2024 Page 17 City of Escalon
Commenter Comment
Number
Comment Response Revision(s) to
ISMND
Peter G. Minkel, Engineering Geologist
(CVRWQCB)
2-2 Continued
Section 13240 of the Porter-Cologne Water Quality Control Act. Each Basin Plan must contain water quality objectives to ensure the reasonable protection of beneficial uses, as well as a program of implementation for achieving water quality objectives with the Basin Plans. Federal regulations require each state to adopt water quality standards to protect the public health or welfare, enhance the quality of water and serve the purposes of the Clean Water Act. In California, the beneficial uses, water quality objectives, and the Antidegradation Policy are the State’s water quality standards. Water quality standards are also contained in the National Toxics Rule, 40 CFR Section 131.36, and the California Toxics Rule, 40 CFR Section 131.38. The Basin Plan is subject to modification as necessary, considering applicable laws, policies, technologies, water quality conditions and priorities. The original Basin Plans were adopted in 1975, and have been updated and revised periodically as required, using Basin Plan amendments. Once the Central Valley Water Board has adopted a Basin Plan amendment in noticed public hearings, it must be approved by the State Water Resources Control Board (State Water Board), Office of Administrative Law (OAL) and in some cases, the United States Environmental reasonable protection of beneficial uses, the plan is reviewed every 3 years. The review of the plan assesses the appropriateness of existing standards and evaluates and priorities Basin Planning issues. The City of Escalon acknowledges the importance of the Basin plan and has incorporated water quality mitigation measures and BMPs to ensure water quality in receiving waters including the creek is protected throughout Project construction.

City of Escalon Connection to Nick DeGroot Water Treatment Plant Final Initial Study/ Mitigated Negative Declaration
State Clearinghouse No. 2024090184
October 2024 Page 18 City of Escalon
Commenter Comment
Number
Comment Response Revision(s) to
ISMND
Peter G. Minkel, Engineering Geologist
(CVRWQCB)
2-2 Continued Protection Agency (USEPA). Basin Plan amendments only become effective after they have been approved by the OAL and in some cases, the USEPA. Every three (3) years, a review of the Basin Plan is completed that assesses the appropriateness of existing standards and evaluates and priorities Basin Planning issues. For more information on the Water Quality Control Plan for the Sacramento and San Joaquin River Basins, please visit our website: https://waterboards.ca.gov/centralvalley/water_issues/basin_plans/ 2-3
Antidegradation Considerations All wastewater discharges must comply with the Antidegradation Policy (State Water Board Resolution 68-16) and Antidegradation Implementation Policy contained in the Basin Plan. The Antidegradation Implementation Policy is available on page 74 at: https://waterboards.ca.gov/centralvalley/ water_issues/basin_plans/sacsjr_201805.p df In part it states: Any discharge of waste to high quality waters must apply best practicable treatment or control not only to prevent a condition of pollution or nuisance from occurring, but also to maintain the highest Comment 2-3 indicates the proposed Project must be compliant with the Antidegradation Policy outlined within CVRWCB’s Basin Plan. The policy is in place to ensure that disposal of waste does not result in pollution or nuisance; and water quality is maintained at a high level. Since this is a standard part of the RWQCB’s NPDES and discharge waste requirements, the proposed Project will remain compliant with this policy through the contractor’s implementation of Mitigation Measure Modified MM HYDRO-02: SWPPP Specifications.

The proposed Mitigation Measure will ensure that the contractor comply with, and implement the provisions of, the SWPPP and the RWQCB requirements for the NPDES General Permit for Discharges of Storm Water Associated with Construction Activity. The SWPPP should be kept on site during construction and implementation shall be recorded with the SWPPP. The objectives of the SWPPP are to identify pollutant sources that may affect the quality of stormwater discharge, to implement control practices to reduce pollutants in stormwater discharges, and to protect receiving water quality. Compliance with Modified MM HYDRO-02: SWPPP Specifications will No Revisions
Needed.

City of Escalon Connection to Nick DeGroot Water Treatment Plant Final Initial Study/ Mitigated Negative Declaration
State Clearinghouse No. 2024090184
October 2024 Page 19 City of Escalon
Commenter Comment
Number
Comment Response Revision(s) to
ISMND
Peter G. Minkel, Engineering Geologist
(CVRWQCB)
2-3 Continued
water quality possible consistent with the maximum benefit to the people of the State.

This information must be presented as an analysis of the impacts and potential impacts of the discharge on water quality, as measured by background concentrations and applicable water quality objectives. The antidegradation analysis is a mandatory element in the National Pollutant Discharge Elimination System and land discharge Waste Discharge Requirements (WDRs) permitting processes. The environmental review document should evaluate potential impacts to both surface and groundwater quality. be verified through the standard application of the City’s plan check and inspection process.
2-4
II. Permitting Requirements Construction Storm Water General Permit Dischargers whose project disturb one or more acres of soil or where projects disturb less than one acre but are part of a larger common plan of development that in total disturbs one or more acres, are required to obtain coverage under the General Permit for Storm Water Discharges Associated with Construction and Land Disturbance Activities (Construction General Permit), Construction General Permit Order No. 2009-0009-DWQ. Construction activity subject to this permit includes clearing, grading, grubbing, disturbances to the ground, such as stockpiling, or excavation, but does not include regular maintenance As mentioned above in Comment 2-3, the Project will implement a Storm Water Pollution Prevention Plan (SWPPP) pursuant to Modified MM HYDRO-02: SWPPP Specifications since the Project is part of a larger common plan of development that will disturb one or more acres. The SWPPP will be required to be implemented by the Project contractor and verified by the City throughout Project construction. No Revisions Needed.

City of Escalon Connection to Nick DeGroot Water Treatment Plant Final Initial Study/ Mitigated Negative Declaration
State Clearinghouse No. 2024090184
October 2024 Page 20 City of Escalon
Commenter Comment
Number
Comment Response Revision(s) to
ISMND
Peter G. Minkel, Engineering Geologist
(CVRWQCB)
2-4 Continued activities performed to restore the original line, grade, or capacity of the facility. The Construction General Permit requires the development and implementation of a Storm Water Pollution Prevention Plan (SWPPP). For more information on the Construction General Permit, visit the State Water Resources Control Board website at: http://www.waterboards.ca.gov/water_issues/programs/stormwater/constpermits.shtml 2-5 Clean Water Act Section 404 Permit If the project will involve the discharge of dredged or fill material in navigable waters or wetlands, a permit pursuant to Section 404 of the Clean Water Act may be needed from the United States Army Corps of Engineers (USACE). If a Section 404 permit is required by the USACE, the Central Valley Water Board will review the permit application to ensure that discharge will not violate water quality standards. If the project requires surface water drainage realignment, the applicant is advised to contact the Department of Fish and Game for information on Streambed Alteration Permit requirements. If you have any questions regarding the Clean Water Act Section 404 permits, please contact the Regulatory Division of the Sacramento District of USACE at (916) 557-5250.

According to Page 29 of the ISMND, there are no wetland features identified by the Biological Resources report. Jack and bore construction will be used to avoid impacts on jurisdictional waters. Therefore, no impacts to state or federally protected wetlands are anticipated as a result of the Project. The Project does not anticipate performing work within a streambed and the contract is required to implement erosion control and water quality protection throughout construction. Throughout Project construction, temporary filters, inlet covers, and surface containment will be placed around active construction to prevent dust and debris from entering surface waters pursuant to the Project’s Mitigation Measures and BMPs. For the reasons above, the Project does not require a Section 404 permit or Streambed Alteration Permit.

No Revisions
Needed.
2-6
Clean Water Act Section 401 Permit
– Water Quality Certification See Response to Comment 2-5 above. The Project does not anticipate performing work within a streambed or within jurisdictional waters. No Revisions Needed.

City of Escalon Connection to Nick DeGroot Water Treatment Plant Final Initial Study/ Mitigated Negative Declaration
State Clearinghouse No. 2024090184
October 2024 Page 21 City of Escalon
Commenter Comment
Number
Comment Response Revision(s) to
ISMND
Peter G. Minkel, Engineering Geologist
(CVRWQCB)
2-6 Continued If an USACE permit (e.g., Non-Reporting Nationwide Permit, Nationwide Permit, Letter of Permission, Individual Permit, Regional General Permit, Programmatic General Permit), or any other federal permit (e.g., Section 10 of the Rivers and Harbors Act or Section 9 from the United States Coast Guard), is required for this project due to the disturbance of waters of the United States (such as streams and wetlands), then a Water Quality Certification must be obtained from the Central Valley Water Board prior to initiation of project activities. There are no waivers for 401 Water Quality Certifications. For more information on the Water Quality Certification, visit the Central Valley Water Board website at: https://www.waterboards.ca.gov/centralvalley/water_issues/water_quality_certificatio n/ However, BMPs and Mitigation Measures pursuant to Modified MM HYDRO-01: Stream Crossings through BMP HYDRO-05: Construction within Riverine Floodway (pg 69 to 71) shall be implemented throughout construction to protect water quality adjacent to receiving water bodies. As a result, the Project does not require a Section 401 permit. 2-7
Waste Discharge Requirements
– Discharges to Waters of the State
If USACE determines that only nonjurisdictional waters of the State (i.e., “nonfederal” waters of the State) are present in the proposed project area, the proposed project may require a Waste Discharge Requirement (WDR) permit to be issued by Central Valley Water Board. Under the California Porter-Cologne Water Quality Control Act, discharges to all waters of the State, including all wetlands and other waters of the State including, but not According to Page 28 of the ISMND, the main water feature in the Project area is Lone Tree Creek, which passes below Escalon-Bellota Road between Magnolia Avenue to the south and Buerer Road to the north. In addition, there are several agricultural conveyance features (sloughs, canals, etc.) that occur adjacent to the Project alignment and were constructed in the upland for agricultural purposes. These water features were determined by the Biological Resources report as non-jurisdictional by the Corps, Regional Board, and CDFW. Therefore, Project activities will not result in impacts to jurisdictional areas and regulatory approvals.

No Revisions
Needed.

City of Escalon Connection to Nick DeGroot Water Treatment Plant Final Initial Study/ Mitigated Negative Declaration
State Clearinghouse No. 2024090184
October 2024 Page 22 City of Escalon
Commenter Comment
Number
Comment Response Revision(s) to
ISMND
Peter G. Minkel, Engineering Geologist
(CVRWQCB)
2-7 Continued limited to, isolated wetlands, are subject to State regulation. For more information on the Waste Discharges to Surface Water NPDES Program and WDR processes, visit the Central Valley Water Board website at: https://www.waterboards.ca.gov/centralvalley/water_issues/waste_to_surface_water/Projects involving excavation or fill activities impacting less than 0.2 acre or 400 linear feet of non-jurisdictional waters of the state and projects involving dredging activities impacting less than 50 cubic yards of nonjurisdictional waters of the state may be eligible for coverage under the State Water Resources Control Board Water Quality Order No. 2004-0004-DWQ (General Order 2004-0004). For more information on the General Order 2004-0004, visit the State Water Resources Control Board website at: https://www.waterboards.ca.gov/board_decisions/adopted_orders/water_quality/200 4/wqo/wqo2004-0004.pdf A portion of the pipeline will be installed under Lone Tree Creek using jack and bore construction, which will require a 20-foot by 45-foot area of disturbance. 2-8
Dewatering Permit If the proposed project includes construction or groundwater dewatering to be discharged to land, the proponent may apply for coverage under State Water Board General Water Quality Order (Low Threat General Order) 2003-0003 or the Central Valley Water Board’s Waiver of Report of Waste Discharge and Waste Discharge Requirements (Low Threat On page 64 of the ISMND, it is noted that the Lead Agency (City of Escalon) will require Project coverage under the City’s NDPES General Construction Permit from the Central Valley RWQCB prior to the start of construction. The General Construction Permit will ensure that potential pollution from construction does not enter surface flows and discharge into receiving waters. Through the General Permit, erosion control and pollution prevention BMPs including temporary filters and containment of active construction zones will be in place throughout construction activities to protect water quality. No Revisions Needed.

City of Escalon Connection to Nick DeGroot Water Treatment Plant Final Initial Study/ Mitigated Negative Declaration
State Clearinghouse No. 2024090184
October 2024 Page 23 City of Escalon
Commenter Comment
Number
Comment Response Revision(s) to
ISMND
Peter G. Minkel, Engineering Geologist
(CVRWQCB)
2-8 Continued Waiver) R5-2018-0085. Small temporary construction dewatering projects are projects that discharge groundwater to land from excavation activities or dewatering of underground utility vaults. Dischargers seeking coverage under the General Order or Waiver must file a Notice of Intent with the Central Valley Water Board prior to beginning discharge. For more information regarding the Low Threat General Order and the application process, visit the Central Valley Water Board website at: http://www.waterboards.ca.gov/board_decisions/adopted_orders/water_quality/2003/wqo/wqo2003-0003.pdfFor more information regarding the Low Threat Waiver and the application process, visit the Central Valley Water Board website at: https://www.waterboards.ca.gov/centralvalley/board_decisions/adopted_orders/waiv ers/r5-2018-0085.pdf Enforcement of the proposed BMPs via the General Permit will occur through the City’s standard review and plan checks and inspections. 2-9
Limited Threat General NPDES Permit If the proposed project includes construction dewatering and it is necessary to discharge the groundwater to waters of the United States, the proposed project will require coverage under a National Pollutant Discharge Elimination System (NPDES) permit. Dewatering discharges are typically considered a low or limited threat to water quality and may be covered under the See Response to Comment 2-8 above. The Project will require coverage under a NPDES permit and will be enforced via the City’s standard review and plan check and inspections. The permit will be submitted to the Central Valley Water Board prior to Project construction and a report shall be submitted upon the competition of Project construction. No Revisions Needed.

City of Escalon Connection to Nick DeGroot Water Treatment Plant Final Initial Study/ Mitigated Negative Declaration
State Clearinghouse No. 2024090184
October 2024 Page 24 City of Escalon
Commenter Comment
Number
Comment Response Revision(s) to
ISMND
Peter G. Minkel, Engineering Geologist
(CVRWQCB)
2-9 Continued General Order for Limited Threat Discharges to Surface Water (Limited Threat General Order). A complete Notice of Intent must be submitted to the Central Valley Water Board to obtain coverage under the Limited Threat General Order. For more information regarding the Limited Threat General Order and the application process, visit the Central Valley Water Board website at: https://www.waterboards.ca.gov/centralvalley/board_decisions/adopted_orders/gene ral_orders/r5-2016-0076-01.pdf NPDES Permit
If the proposed project discharges waste that could affect the quality of surface waters of the State, other than into a community sewer system, the proposed project will require coverage under a National Pollutant Discharge Elimination System (NPDES) permit. A complete Report of Waste Discharge must be submitted with the Central Valley Water Board to obtain a NPDES Permit. For more information regarding the NPDES Permit and the application process, visit the Central Valley Water Board website at: https://www.waterboards.ca.gov/centralvalley/help/permit/ 2-10
If you have questions regarding these comments, please contact me at (916) 464- 4684 or [email protected]. This is a closing statement from the Regional Water Board. Thank you. We appreciate your input on the ISMND. No Revisions Needed.

City of Escalon Connection to Nick DeGroot Water Treatment Plant Final Initial Study/ Mitigated Negative Declaration
State Clearinghouse No. 2024090184
October 2024 Page 25 City of Escalon
Commenter Comment
Number
Comment Response Revision(s) to
ISMND
Peter G. Minkel, Engineering Geologist
(CVRWQCB)
2-10 Continued Peter G. Minkel Engineering Geologist
cc: State Clearinghouse unit, Governor’s Office of Planning and Research Sacramento

Central Valley Regional Water Quality Control Board
7 October 2024
Jaylen French
City of Escalon
2060 McHenry Avenue
Escalon, CA 95320
[email protected]

COMMENTS TO REQUEST FOR REVIEW FOR THE MITIGATED NEGATIVE

DECLARATION, CITY OF ESCALON CONNECTION TO NICK DEGROOT WATER TREATMENT PLANT PROJECT, SCH#2024090184, SAN JOAQUIN COUNTY Pursuant to the State Clearinghouse’s 6 September 2024 request, the Central Valley Regional Water Quality Control Board (Central Valley Water Board) has reviewed the Request for Review for the Mitigated Negative Declaration for the City of Escalon Connection to Nick DeGroot Water Treatment Plant Project, located in San Joaquin County.

Our agency is delegated with the responsibility of protecting the quality of surface and groundwaters of the state; therefore our comments will address concerns surrounding those issues.

I. Regulatory Setting
Basin Plan
The Central Valley Water Board is required to formulate and adopt Basin Plans for all areas within the Central Valley region under Section 13240 of the Porter-Cologne Water Quality Control Act. Each Basin Plan must contain water quality objectives to ensure the reasonable protection of beneficial uses, as well as a program of implementation for achieving water quality objectives with the Basin Plans. Federal regulations require each state to adopt water quality standards to protect the public health or welfare, enhance the quality of water and serve the purposes of the Clean Water Act. In California, the beneficial uses, water quality objectives, and the Antidegradation Policy are the State’s water quality standards. Water quality standards are also contained in the National Toxics Rule, 40 CFR Section 131.36, and the California Toxics Rule, 40 CFR Section 131.38.

The Basin Plan is subject to modification as necessary, considering applicable laws, policies, technologies, water quality conditions and priorities. The original Basin Plans were adopted in 1975, and have been updated and revised periodically as required, using Basin Plan amendments. Once the Central Valley Water Board has

adopted a Basin Plan amendment in noticed public hearings, it must be approved by the State Water Resources Control Board (State Water Board), Office of Administrative Law (OAL) and in some cases, the United States Environmental Protection Agency (USEPA). Basin Plan amendments only become effective after they have been approved by the OAL and in some cases, the USEPA. Every three (3) years, a review of the Basin Plan is completed that assesses the appropriateness of existing standards and evaluates and prioritizes Basin Planning issues. For more information on the Water Quality Control Plan for the Sacramento and San Joaquin River Basins, please visit our website:
http://www.waterboards.ca.gov/centralvalley/water_issues/basin_plans/ Antidegradation Considerations
All wastewater discharges must comply with the Antidegradation Policy (State Water Board Resolution 68-16) and the Antidegradation Implementation Policy contained in the Basin Plan. The Antidegradation Implementation Policy is available on page 74 at:
https://www.waterboards.ca.gov/centralvalley/water_issues/basin_plans/sacsjr_2018

05.pdf
In part it states:

Any discharge of waste to high quality waters must apply best practicable treatment or control not only to prevent a condition of pollution or nuisance from occurring, but also to maintain the highest water quality possible consistent with the maximum benefit to the people of the State.

This information must be presented as an analysis of the impacts and potential impacts of the discharge on water quality, as measured by background concentrations and applicable water quality objectives.

The antidegradation analysis is a mandatory element in the National Pollutant Discharge Elimination System and land discharge Waste Discharge Requirements (WDRs) permitting processes. The environmental review document should evaluate potential impacts to both surface and groundwater quality.

II. Permitting Requirements
Construction Storm Water General Permit
Dischargers whose project disturb one or more acres of soil or where projects disturb less than one acre but are part of a larger common plan of development that in total disturbs one or more acres, are required to obtain coverage under the General Permit for Storm Water Discharges Associated with Construction and Land Disturbance Activities (Construction General Permit), Construction General Permit Order No. 2009-0009-DWQ. Construction activity subject to this permit includes clearing, grading, grubbing, disturbances to the ground, such as stockpiling, or excavation, but does not include regular maintenance activities performed to restore the original line, grade, or capacity of the facility. The Construction General Permit requires the development and implementation of a Storm Water Pollution Prevention Plan (SWPPP). For more information on the Construction General Permit, visit the

State Water Resources Control Board website at:
http://www.waterboards.ca.gov/water_issues/programs/stormwater/constpermits.sht ml
Clean Water Act Section 404 Permit
If the project will involve the discharge of dredged or fill material in navigable waters or wetlands, a permit pursuant to Section 404 of the Clean Water Act may be needed from the United States Army Corps of Engineers (USACE). If a Section 404 permit is required by the USACE, the Central Valley Water Board will review the permit application to ensure that discharge will not violate water quality standards. If the project requires surface water drainage realignment, the applicant is advised to contact the Department of Fish and Game for information on Streambed Alteration Permit requirements. If you have any questions regarding the Clean Water Act Section 404 permits, please contact the Regulatory Division of the Sacramento District of USACE at (916) 557-5250.

Clean Water Act Section 401 Permit – Water Quality Certification If an USACE permit (e.g., Non-Reporting Nationwide Permit, Nationwide Permit, Letter of Permission, Individual Permit, Regional General Permit, Programmatic General Permit), or any other federal permit (e.g., Section 10 of the Rivers and Harbors Act or Section 9 from the United States Coast Guard), is required for this project due to the disturbance of waters of the United States (such as streams and wetlands), then a Water Quality Certification must be obtained from the Central Valley Water Board prior to initiation of project activities. There are no waivers for 401 Water Quality Certifications. For more information on the Water Quality Certification, visit the Central Valley Water Board website at:
https://www.waterboards.ca.gov/centralvalley/water_issues/water_quality_certificatio n/
Waste Discharge Requirements – Discharges to Waters of the State If USACE determines that only non-jurisdictional waters of the State (i.e., “nonfederal” waters of the State) are present in the proposed project area, the proposed project may require a Waste Discharge Requirement (WDR) permit to be issued by Central Valley Water Board. Under the California Porter-Cologne Water Quality Control Act, discharges to all waters of the State, including all wetlands and other waters of the State including, but not limited to, isolated wetlands, are subject to State regulation. For more information on the Waste Discharges to Surface Water NPDES Program and WDR processes, visit the Central Valley Water Board website at:https://www.waterboards.ca.gov/centralvalley/water_issues/waste_to_surface_wat er/
Projects involving excavation or fill activities impacting less than 0.2 acre or 400 linear feet of non-jurisdictional waters of the state and projects involving dredging activities impacting less than 50 cubic yards of non-jurisdictional waters of the state may be eligible for coverage under the State Water Resources Control Board Water Quality Order No. 2004-0004-DWQ (General Order 2004-0004). For more information on the General Order 2004-0004, visit the State Water Resources

Control Board website at:
https://www.waterboards.ca.gov/board_decisions/adopted_orders/water_quality/200 4/wqo/wqo2004-0004.pdf
Dewatering Permit
If the proposed project includes construction or groundwater dewatering to be discharged to land, the proponent may apply for coverage under State Water Board General Water Quality Order (Low Threat General Order) 2003-0003 or the Central Valley Water Board’s Waiver of Report of Waste Discharge and Waste Discharge Requirements (Low Threat Waiver) R5-2018-0085. Small temporary construction dewatering projects are projects that discharge groundwater to land from excavation activities or dewatering of underground utility vaults. Dischargers seeking coverage under the General Order or Waiver must file a Notice of Intent with the Central Valley Water Board prior to beginning discharge.

For more information regarding the Low Threat General Order and the application process, visit the Central Valley Water Board website at:
http://www.waterboards.ca.gov/board_decisions/adopted_orders/water_quality/2003/ wqo/wqo2003-0003.pdf
For more information regarding the Low Threat Waiver and the application process, visit the Central Valley Water Board website at:
https://www.waterboards.ca.gov/centralvalley/board_decisions/adopted_orders/waiv ers/r5-2018-0085.pdf
Limited Threat General NPDES Permit
If the proposed project includes construction dewatering and it is necessary to discharge the groundwater to waters of the United States, the proposed project will require coverage under a National Pollutant Discharge Elimination System (NPDES) permit. Dewatering discharges are typically considered a low or limited threat to water quality and may be covered under the General Order for Limited Threat Discharges to Surface Water (Limited Threat General Order). A complete Notice of Intent must be submitted to the Central Valley Water Board to obtain coverage under the Limited Threat General Order. For more information regarding the Limited Threat General Order and the application process, visit the Central Valley Water Board website at:
https://www.waterboards.ca.gov/centralvalley/board_decisions/adopted_orders/gene ral_orders/r5-2016-0076-01.pdf
NPDES Permit
If the proposed project discharges waste that could affect the quality of surface waters of the State, other than into a community sewer system, the proposed project will require coverage under a National Pollutant Discharge Elimination System (NPDES) permit. A complete Report of Waste Discharge must be submitted with the Central Valley Water Board to obtain a NPDES Permit. For more information regarding the NPDES Permit and the application process, visit the Central Valley Water Board website at: https://www.waterboards.ca.gov/centralvalley/help/permit/

If you have questions regarding these comments, please contact me at (916) 464-4684 or [email protected].

Peter G. Minkel
Engineering Geologist
cc: State Clearinghouse unit, Governor’s Office of Planning and Research, Sacramento

City of Escalon Connection to Nick DeGroot Water Treatment Plant Final Initial Study/ Mitigated Negative Declaration
State Clearinghouse No. 2024090184
October 2024 Page 31 City of Escalon
RESPONSE TO COMMENTS MATRIX – State Water Resources Control Board Commenter Comment
Number
Comment Response Revision(s) to
ISMND
Lori Schmitz Environmental
Scientist (SWRCB) Division of Financial Assistance
3-1 October 7, 2024
Jaylen French City of Escalon 2060 McHenry Avenue Escalon, CA 95320 CITY OF ESCALON (CITY), INITIAL STUDY/MITIGATED NEGATIVE DECLARATION (IS/MND) FOR THE CITY OF ESCALON CONNECTION TO NICK DEGROOT WATER TREATMENT PLANT PROJECT (PROJECT); STATE CLEARINGHOUSE #2024090184 Dear Jaylen French: Thank you for the opportunity to review the IS/MND for the proposed Project. The State Water Resources Control Board, Division of Drinking Water (State Water Board, DDW) is responsible for issuing water supply permits pursuant to the Safe Drinking Water Act. This Project is within the jurisdiction of the State Water Board,
DDW’s Stockton District. DDW Stockton District issues domestic water supply permit amendments to public water systems pursuant to Waterworks Standards (Title 22 California Code of Regulations [Cal Code Regs.] chapter 16 et. seq.). A public water system requires a water supply permit amendment when changes are SWRCB provided comments with an official letter to the City of Escalon and Office of Planning and Research (OPR) in response to the circulation of the ISMND and MMRP for public review by state agencies. SWRCB’s comments were received on October 7, 2024. Comment 3-1 is the introduction and indicates that a domestic water supply permit is applicable for this Project pursuant to Waterworks Standards (Title 22 California Code of Regulations [Cal Code Regs.] chapter 16 et. seq.). The City of Escalon will ensure compliance with the Waterworks Standards by applying for a water supply permit amendment for approval of the new source and new storage reservoir prior to Project construction. This permit will be obtained as part of the standard plan check process for the Project.

No revisions
are required.

City of Escalon Connection to Nick DeGroot Water Treatment Plant Final Initial Study/ Mitigated Negative Declaration
State Clearinghouse No. 2024090184
October 2024 Page 32 City of Escalon
Commenter Comment
Number
Comment Response Revision(s) to
ISMND
Lori Schmitz Environmental
Scientist (SWRCB) Division of Financial Assistance
3-1
Continued
made to a domestic water supply source,
storage, or treatment and for the operation of new water system components- as specified in the Cal. Code Regs. § 64556. The City will need to apply for a water supply permit amendment for approval of the new source and new storage reservoir. 3-2
The State Water Board, DDW has the following technical recommendations regarding the Project planning:
- The City should initiate early
communication with the DDW Stockton District during the project design phase to ensure compliance with all necessary permit requirements for the new facilities. - The City needs to be prepared to
meet the increased regulatory requirements associated with water quality monitoring, including disinfection byproducts, lead and copper, corrosion control water quality parameters, and applicable surface water monitoring requirements. - The City should anticipate potential
water quality challenges, such as taste, odor, color, corrosivity, bacteriological, and chemical changes, that may arise from the introduction of a new surface water source into its groundwater-based system.

The City of Escalon will involve the DDW Stockton District in the design phase to ensure the Project is compliant with necessary permitting. The City of Escalon anticipates the state to be involved throughout the planning process. The purpose of the proposed Project is to provide residents within the City of Escalon with potable water that meets state and federal drinking water requirements. Therefore, the City will implement longterm maintenance and operations to ensure that potable water conveyance and storage through the proposed Project is consistent with regulatory framework and the City’s standards. According to the City of Escalon’s Water Master Plan, the City’s water system meets “Domestic Water Quality and Monitoring Regulations” adopted by the State of California which includes bacteriological; general physical; and inorganic, organic, and general chemical monitoring and testing; as well as water quality standards set by the State of California. The proposed Project will comply with applicable monitoring and testing requirements placed on drinking water throughout the lifetime of the Project pursuant to Title 22 requirements and remain consistent with the City’s monitoring and testing procedures.

No revisions
are required.

City of Escalon Connection to Nick DeGroot Water Treatment Plant Final Initial Study/ Mitigated Negative Declaration
State Clearinghouse No. 2024090184
October 2024 Page 33 City of Escalon
Commenter Comment
Number
Comment Response Revision(s) to
ISMND
Lori Schmitz Environmental
Scientist (SWRCB) Division of Financial Assistance
3-2 Continued And the City should conduct preliminary studies to evaluate the potential effects of changes in the source water and any issues related to the integration of groundwater and surface water sources within the City's system. 3-3
The State Water Board, DDW, as a responsible agency under the California Environmental Quality Act (CEQA), also has the following comments on the City’s IS/MND:
- The Modified Mitigation Measure
UT0-02 Utility Conflicts (UT0-02) needs to be updated to correct inaccuracies (PDF page 167). The first line of the UT0-02 states the City “will observe DHS standards.” The California Department of Health Services no longer exists. The referenced standards are the 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. UT0-02 also states, “the City shall obtain DHS variance through provisions of sewer encasement, or other means deemed suitable by DHS.” Please replace “DHS” with “State Water Resources Control Board, Division of Drinking Water”, as this statement refers to a variance to Waterworks Standards which State Water Board, DDW would Based on this comment Mitigation Measure Modified MM UTL-02:

Utility Conflict was revised to redact references to the California Department of Health Services on page 167 and on page lii (Table 6) to reflect the Division of Drinking Water’s (DDW) oversight on installation standards contained within the Waterworks Standards found in the Cal. Code Regs. chapter 16 et. seq.

Revisions
were made to Mitigation Measure
Modified MM UTL-02: Utility Conflicts.

City of Escalon Connection to Nick DeGroot Water Treatment Plant Final Initial Study/ Mitigated Negative Declaration
State Clearinghouse No. 2024090184
October 2024 Page 34 City of Escalon
Commenter Comment
Number
Comment Response Revision(s) to
ISMND
Lori Schmitz Environmental
Scientist (SWRCB) Division of Financial Assistance
3-3 Continued need to approve. Please update Table 6, the Mitigation Monitoring and Reporting Plan, and any other reference to DHS to reflect these corrections. 3-4
When the CEQA review process is completed, please forward the following items with the permit application to the State Water Board, DDW Stockton District Office at [email protected]:
- Copy of the IS/MND and Mitigation
Monitoring and Reporting Plan;
- Copy of all comment letters received
and the lead agency responses as appropriate;
- Copy of the Resolution or Board
Minutes adopting the IS/MND and Mitigation Monitoring and Reporting Plan; and - Copy of the date stamped Notice of
Determination filed at the San Joaquin County Clerk’s Office and the Governor’s Office of Planning and Research, State Clearinghouse.

Please contact Lori Schmitz of the State Water Board at (916) 449-5285 or [email protected], for questions regarding this comment letter. Sincerely, Lori Schmitz This is a closing statement from the State Water Board. Per the State Water Board’s request, the City of Escalon will provide the following to the DDW Stockton District Office upon the completion of the CEQA review process:
- Copy of the IS/MND and Mitigation Monitoring and Reporting Plan;
- Copy of all comment letters received and the lead agency responses as appropriate;
- Copy of the Resolution or Board Minutes adopting the IS/MND and Mitigation Monitoring and Reporting Plan; and
- Copy of the date stamped Notice of Determination filed at the San Joaquin County Clerk’s Office and the Governor’s Office of Planning and Research, State Clearinghouse.

We appreciate your input on the ISMND and thank you for taking the time to review the proposed Project.

No revisions
are required.

City of Escalon Connection to Nick DeGroot Water Treatment Plant Final Initial Study/ Mitigated Negative Declaration
State Clearinghouse No. 2024090184
October 2024 Page 35 City of Escalon
Commenter Comment
Number
Comment Response Revision(s) to
ISMND
Lori Schmitz Environmental
Scientist (SWRCB) Division of Financial Assistance
3-4 Continued Environmental Scientist Division of Financial Assistance Special Project Review Unit 1001 I Street, 16th floor Sacramento, CA 95814 Cc: Office of Planning and Research, State Clearinghouse Mostafa Khademi Water Resources Control Engineer Stockton District Bhupinder Sahota District Engineer Stockton District

State Water Resources Control Board
October 7, 2024
Jaylen French
City of Escalon
2060 McHenry Avenue
Escalon, CA 95320

CITY OF ESCALON (CITY), INITIAL STUDY/MITIGATED NEGATIVE DECLARATION (IS/MND) FOR THE CITY OF ESCALON CONNECTION TO NICK DEGROOT WATER TREATMENT PLANT PROJECT (PROJECT); STATE CLEARINGHOUSE
#2024090184
Dear Jaylen French:

Thank you for the opportunity to review the IS/MND for the proposed Project. The State Water Resources Control Board, Division of Drinking Water (State Water Board, DDW) is responsible for issuing water supply permits pursuant to the Safe Drinking Water Act.

This Project is within the jurisdiction of the State Water Board, DDW’s Stockton District.

DDW Stockton District issues domestic water supply permit amendments to public water systems pursuant to Waterworks Standards (Title 22 California Code of Regulations [Cal Code Regs.] chapter 16 et. seq.). A public water system requires a water supply permit amendment when changes are made to a domestic water supply source, storage, or treatment and for the operation of new water system componentsas specified in the Cal. Code Regs. § 64556. The City will need to apply for a water supply permit amendment for approval of the new source and new storage reservoir.

The State Water Board, DDW has the following technical recommendations regarding the Project planning:
· The City should initiate early communication with the DDW Stockton District during the project design phase to ensure compliance with all necessary permit requirements for the new facilities.
· The City needs to be prepared to meet the increased regulatory requirements associated with water quality monitoring, including disinfection byproducts, lead and copper, corrosion control water quality parameters, and applicable surface water monitoring requirements.
· The City should anticipate potential water quality challenges, such as taste, odor, color, corrosivity, bacteriological, and chemical changes, that may arise from the introduction of a new surface water source into its groundwater-based system.

And the City should conduct preliminary studies to evaluate the potential effects of changes in the source water and any issues related to the integration of groundwater and surface water sources within the City's system.

The State Water Board, DDW, as a responsible agency under the California Environmental Quality Act (CEQA), also has the following comments on the City’s IS/MND:
· The Modified Mitigation Measure UT0-02 Utility Conflicts (UT0-02) needs to be updated to correct inaccuracies (PDF page 167). The first line of the UT0-02 states the City “will observe DHS standards.” The California Department of Health Services no longer exists. The referenced standards are the 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. UT0-02 also states, “the City shall obtain DHS variance through provisions of sewer encasement, or other means deemed suitable by DHS.” Please replace “DHS” with “State Water Resources Control Board, Division of Drinking Water”, as this statement refers to a variance to Waterworks Standards which State Water Board, DDW would need to approve. Please update Table 6, the Mitigation Monitoring and Reporting Plan, and any other reference to DHS to reflect these corrections.

When the CEQA review process is completed, please forward the following items with the permit application to the State Water Board, DDW Stockton District Office at [email protected]:
· Copy of the IS/MND and Mitigation Monitoring and Reporting Plan; · Copy of all comment letters received and the lead agency responses as appropriate;
· Copy of the Resolution or Board Minutes adopting the IS/MND and Mitigation Monitoring and Reporting Plan; and
· Copy of the date stamped Notice of Determination filed at the San Joaquin County Clerk’s Office and the Governor’s Office of Planning and Research, State Clearinghouse.

Please contact Lori Schmitz of the State Water Board at (916) 449-5285 or [email protected], for questions regarding this comment letter.

Sincerely,
Lori Schmitz
Environmental Scientist
Division of Financial Assistance
Special Project Review Unit
1001 I Street, 16th floor

Sacramento, CA 95814
Cc:

Office of Planning and Research, State Clearinghouse
Mostafa Khademi
Water Resources Control Engineer
Stockton District
Bhupinder Sahota
District Engineer
Stockton District

City of Escalon Connection to Nick DeGroot Water Treatment Plant Final Initial Study/ Mitigated Negative Declaration
State Clearinghouse No. 2024090184
October 2024 Page 39 City of Escalon

3.0 ERRATA
As mentioned in Section 2.0 Response to Comments, of this Final IS/MND, changes are noted as follows:
an addition is indicated in double-underline to the text; strikethrough indicates deletions to the text.

These errata address technical responses received from Comment Letters 1,2,3 on the Draft IS/MND. The Draft IS/MND was circulated for public review beginning on September 6, 2024, and concluded on October 7, 2024. The changes made to the Draft IS/MND do not influence the overall conclusion of the environmental impacts outlined within the document. The revisions and modifications are not considered to result in any new or substantially greater significant impacts than those identified in the Draft IS/MND.

3.0 PROJECT DESCRIPTION, 3.2 SCSWSP EIR MITIGATION MEASURES, TABLE 6, PAGE lii MM UTL-02: Utility Conflicts- In order to reduce potential impacts associated with utility conflicts, the following measures shall be implemented in conjunction with MM UTL-01- Existing Utilities:
- Disconnected cables and lines shall be reconnected promptly. - Based on the utilities investigation to be conducted under Measure 4.12.1 a, SSJID shall consult with any entities having utility conflicts with the proposed project to negotiate relocation 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 separation between parallel sewer and water pipelines (gravity or force pipelines); 2) 1-foot vertical separation between perpendicular water and sewer line crossings (in the event that separation 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 protective sleeves where the pipeline crosses under or over an existing wastewater pipeline.

SECTION 5.4 BIOLOGICAL RESOURCES, 5.4.4 MITIGATION MEASURES, PAGE 30-31 MM BIO-01: Pre-construction Nesting Bird Clearance Surveys. If construction occurs between February 1st and August 31st, a p Pre-construction clearance surveys for nesting and protected birds and raptors should be conducted by a qualified biologist, pursuant to CDFW protocol and as delineated below within fifteen (15) days and three (3) days in advance of the start of any vegetation removal or ground disturbing activities and mobilization for the Project. Pre-construction surveys are intended to identify active nests and other evidence of protected species so that construction can completely avoids species that are protected under the MBTA and Fish, Game Code and that applicable agency protocol can be implemented so ensure that no nesting migratory birds, protected birds or raptors will be disturbed during construction.

Survey Report: The biologist conducting the clearance surveys should document a negative survey with a brief letter report for each survey indicating that no impacts to active avian nests or protected species will occur or stating whether protocol surveys are warranted. If an active avian nest is discovered during the pre-construction clearance survey, construction activities should stay outside of a No Disturbance Buffer: A no-disturbance buffer or alternative method approved by CDFW that will be established by the City’s biologist to protect any species and active nests. The size of the no-disturbance

City of Escalon Connection to Nick DeGroot Water Treatment Plant Final Initial Study/ Mitigated Negative Declaration
State Clearinghouse No. 2024090184
October 2024 Page 40 City of Escalon
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 construction activity, type and duration of construction activity, ambient noise, species habituation, and topographical barriers. These factors will be evaluated on a case-by-case basis when developing buffers and distances. Limits of construction to avoid an active nest or species take will be established in the field with flagging, fencing, or other appropriate barriers; and construction personnel will be instructed on the sensitivity of nest areas and species locations so that disturbance, take, possession, and destruction 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 active nest, protection in place, or relocations to ensure that protected species and nesting behavior is not adversely affected by the construction activity. Once the young have fledged and left the nest, or the nest otherwise becomes inactive under natural conditions or if the biologist deems that there is no potential for impacts on protected species, construction activities within the buffer area can occur.

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 Nesting 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
• 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 activities, the project proponent should consult with CDFW and demonstrate compliance with CESA. CDFW is responsible for ensuring appropriate conservation 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 potential to result in “take” (Fish & G. Code § 86 defines “take” as “hunt, pursue, catch, capture, or kill, or attempt to hunt, pursue, catch, capture, or kill”) of CESA-listed species, either through construction or over the life of the Project.

Modified MM BIO-02: Ground Nesting Raptors Pre-construction Survey- Prior to Project construction, the City of Escalon shall retain a qualified biologist to conduct a survey for ground and other nesting raptors (in March or April) 30 fifteen (15) days and repeated 3 days prior to construction activities (i.e., grading) in areas containing suitable nesting habitat. Active raptor nests located within 500 feet of construction activity shall be mapped.

Modified MM BIO-04: Active Nests- Prior to construction activities, the City of Escalon in coordination with the Project contractor and qualified biologist shall identify trees with active nests. Active nests shall only be removed prior to the onset of the nesting season (March) or after the young have fledged (late August).

SECTION 5.19 UTILITIES AND SERVICES, 5.19.4 MITIGATION MEASURES, PAGE 113

City of Escalon Connection to Nick DeGroot Water Treatment Plant Final Initial Study/ Mitigated Negative Declaration
State Clearinghouse No. 2024090184
October 2024 Page 41 City of Escalon
Modified MM UTL-02: Utility Conflicts- In order to reduce potential impacts associated with utility conflicts, the following measures shall be implemented in conjunction with Modified MM UTL-01- Existing Utilities:

- Disconnected cables and lines shall be reconnected promptly - Based on the utilities investigation to be conducted by the City of Escalon shall consult with any entities having utility conflicts with the proposed project to negotiate relocation efforts or other plans to resolve the conflict.
- The City of Escalon shall observe DHS standards 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 which require: 1) a 10-foot horizontal separation between parallel sewer and water pipelines (gravity or force pipelines); 2) 1-foot vertical separation between perpendicular water and sewer line crossings (in the event that separation requirements may not be maintained, the City 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 protective sleeves where the pipeline crosses under or over an existing wastewater pipeline.

City of Escalon Connection to Nick DeGroot Water Treatment Plant Final Initial Study/ Mitigated Negative Declaration
State Clearinghouse No. 2024090184
October 2024 Page 42 City of Escalon

4.0 FINAL MITIGATION MONITORING AND REPORTING PROGRAM
This page is left intentionally blank.

FINAL MITIGATION MONITORING AND REPORTING PROGRAM

CITY OF ESCALON CONNECTION TO NICK DEGROOT WATER TREATMENT PLANT PROJECT

ESCALON, SAN JOAQUIN COUNTY, CA
SEPTEMBER OCTOBER 2024
October 2024 Page 43 City of Escalon

FINAL MITIGATION MONITORING AND REPORTING PROGRAM
The following is a Mitigation Monitoring and Reporting Program (MMRP) for the City of Escalon Connection to Nick Groot Water Treatment Plant (Project) located in the southeastern corner of San Joaquin County, California. This MMRP has been prepared pursuant to Section 15097 of the CEQA Guidelines and Section 21081 of the Public Resources Code. This MMRP lists all applicable Project Mitigation Measures (MM), applicable Mitigation Measures previously approved by San Joaquin County via the South County Surface Water Supply Project EIR (SCH#98022018) (Modified MM), and environmental commitments for executing Standard Conditions (SC) that are required to be implemented with the Project under existing Plans, Programs, and Policies for environmental resource protection. This MMRP includes implementation timing and responsible party to ensure proper enforcement of all MM and SC to reduce Project impacts. The City of Escalon, the Lead Agency, will utilize the MMRP to document the implementation of Project mitigation and SC environmental commitments, which ensure all project impacts are reduced to less than significance pursuant to The California Environmental Quality Act (CEQA).

Issue Potentially Significant Impact reduced
to Less than Significant Impact
Recommended Mitigation Measure Timing Responsible Party Date Completed and Initials
Aesthetics c) In nonurbanized areas, substantially degrade the existing 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 regulations governing scenic quality? MM AES-01: Coordination with Private Landowners- Prior to the start of construction, the City and the contractor shall coordinate with private owners and obtain written landowner approval for construction activities on private property in the form of a signature on the plan sheet showing the proposed work. Restoration work on private property shall be agreed upon and approved by the landowner and the City in advance of construction. Restoration shall be certified by the landowner and the City upon completion as adequately meeting the City’s private landowner’s requirements. Prior to the start of construction. City of Escalon, Project contractor Date: ________ Initials: _______ Modified MM AES-04: Landscaping- Natural landscaping, which blends with the surrounding aesthetic features, shall be placed along the perimeter of the FCF and BPS. Upon implementation of the proposed Project components. City of Escalon, Project contractor Date: ________ Initials: _______ d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area? MM AES-02: Construction Lighting Plan- If nighttime construction is planned to occur, the Project contractor must deploy the measures prior to and throughout nighttime construction activities (dusk to dawn). Measures include directing light sources away from residential property or regularly occupied spaces. Elimination of uplighting will occur by angling light sources down and fitting light sources with covered bulbs, shields, and dimmers. Ensure that a 300-foot buffer from residential property lines is maintained throughout nighttime construction. Throughout nighttime construction. Project contractor Date: ________ Initials: _______

FINAL MITIGATION MONITORING AND REPORTING PROGRAM

CITY OF ESCALON CONNECTION TO NICK DEGROOT WATER TREATMENT PLANT PROJECT

ESCALON, SAN JOAQUIN COUNTY, CA
SEPTEMBER OCTOBER 2024
October 2024 Page 44 City of Escalon
Issue Potentially Significant Impact reduced
to Less than Significant Impact
Recommended Mitigation Measure Timing Responsible Party Date Completed and Initials
Aesthetics d) Continued… Modified MM AES-03: Lighting- Lighting at the FCF and BPS shall be positioned downward and shielded in order to prevent glare, and reduce offsite lighting, and disruption of adjacent neighbors. Throughout Project implementation and design. Project contractor Date: ________ Initials: _______ Air Quality c) Expose sensitive receptors to substantial pollutant concentrations? MM AQ-01: Fugitive Dust Control- For construction activities associated with all Project components: the City of Escalon shall require contractor(s) to implement the following measures throughout construction activities. These measures shall be incorporated in bid documents prior to City approval. The implementation of these measures shall be verified on an ongoing basis through construction inspections: - Water, chemical soil stabilizers/ suppressants, or vegetative ground cover shall be used to control fugitive dust from all disturbed areas, including storage piles, which are not in active use at the construction site. - Water or chemical soil stabilizers shall be used to control fugitive dust from all unpaved roads utilized for construction access. - Applications of water or presoaking shall be performed to control fugitive dust from all land clearing, grubbing, scraping, excavation, land leveling, grading, cut and fill, and demolition activities. - 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 construction periods. (The use of dry rotary brushes is expressly prohibited, except where preceded or accompanied by sufficient wetting 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 fugitive dust after each addition of materials to or removal of materials from all storage piles. - Limit the speed of all construction vehicles to 15 miles per hour on unpaved roads. - Re-plant vegetation in disturbed areas as quickly as possible. Throughout Project construction. City of Escalon; Project contractor(s) Date: ________ Initials: _______