Agenda — Ione City Council, February 20, 2024

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CITY OF IONE
IONE, CA 95640
REGULAR MEETING STARTS AT 6:00 PM
Mayor Alison LaFayne
Vice Mayor Diane Wratten
Councilmember Dominic Atlan
Councilmember Jack Mitchell
Councilmember Stacy Rhoades
AT 1 E. MAIN STREET, IONE, CA 95640

AND VIA ZOOM
The City of lone is inviting you to a scheduled Zoom meeting.

Join Zoom Meeting
https://zoom.us/j/2351961316?pwd=d31WTW0zbVJLblpQNXBDQWtpZkRyUT09 Meeting ID: 235 196 1316
Passcode: 95640
Tuesday, February 20, 2024

THE CITY OF IONE IS A GENERAL LAW CITY DEDICATED TO PROVIDING LEADERSHIP,

ACCOUNTABILITY, AND FISCAL INTEGRITY WHILE PROMOTING ECONOMIC OPPORTUNITIES AND MAINTAINING A HIGH QUALITY OF LIFE FOR OUR CITIZENS.

PLEASE LIMIT PUBLIC COMMENT/TESTIMONY TO FOUR MINUTES
Gov't. Code $54954.3
The lone City Council welcomes, appreciates, and encourages participation in the City Council Meeting. The City Council reserves the right to reasonably limit the total time for public comment on any particular noticed agenda item as it may deem necessary.

Full staff reports and associated documents are available for public review at the Office of the City Clerk, City Hall, 1 E. Main Street, lone, CA. Hard copies may be obtained for $3.60 for pages 1- 5 and $.45 for each additional page. Documents that are not available when the agenda is posted will be made available for public review at the meeting. 6:00 P.M. REGULAR MEETING AGENDA
A. ROLL CALL
B. CLOSED SESSION:

None.

If all matters are not completed prior to the regular meeting start time, the City Council will convene to Closed Session after the Regular Meeting ends.

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CITY OF IONE
IONE, CA 95640
C. PLEDGE OF ALLEGIANCE
D. REPORT OUT OF CLOSED SESSION
E. APPROVAL OF AGENDA
F. PRESENTATIONS/ANNOUNCEMENTS:

1. Proclamation for Kristi Roots
G. PUBLIC COMMENT: EACH SPEAKER IS LIMITED TO 4 MINUTES NOTE: This is the time for members of the public who wish to be heard on matters that do not appear on the Agenda. Persons may address the City Council at this time on any subject within the jurisdiction of the lone City Council.

Please be mindful of the 4 minute time limit per person. Pursuant to the Brown Act, the City Council may not take action or engage in a detailed discussion on an item that does not appear on the Agenda. However, matters that require Council action will be referred to staff for a report and/or recommendation for possible action at a future Council meeting. Is there anyone in the audience who wishes to address the Council at this time? H. INFORMATION ITEMS:

All matters listed under this category are for information only with no action to be taken by the City Council.

1. January 2024 Fire Department Report

2. January 2024 Police Department Report

3. January 2024 Administrative Report

4. January 2024 Building Department Report

5. January 2024 WWTP Report
I. CONSENT CALENDAR:

All matters listed under this category are considered to be routine and will be enacted by one motion. Any item may be removed for discussion and possible action and made a part of the regular agenda at the request of a Councilmember (s).

1. Minutes of January 16, 2024

2. Warrants

3. Ione 4H Agreement

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CITY OF IONE
IONE, CA 95640
J. REGULAR AGENDA:

1. Update regarding Housing grant funds.

Recommendation: For information.

2. Update regarding ACUSD DEIR and City's next steps.

Recommendation: For information only and staff direction.

K. REPORTS AND COMMUNICATIONS FROM CITY ATTORNEY
L. REPORTS AND COMMUNICATIONS FROM CITY MANAGER
M. COUNCIL COMMENTS/COMMITTEE REPORTS/FUTURE AGENDA ITEMS N. RESUME TO CLOSED SESSION IF NECESSARY
O. REPORT OUT OF CLOSED SESSION
P. ADJOURNMENT TO REGULAR MEETING ON MARCH 5, 2024

NOTICE REGARDING CHALLENGES TO DECISIONS
Pursuant to all applicable laws and regulations, including without limitation, California Government Code Section 65009 and or California Public Resources Code Section 21177, if you crish to mala deinons, any ofth babini deci rans rgard hose ansies yo or someone else raised at the public hearing(s) described in this notice/agenda, or in written correspondence delivered to the City at, or prior to, this public hearing.

ADA COMPLIANCE STATEMENT
In compliance with the American with Disabilities Act, if you need special assistance to participate in this meeting, please contact City Clerk Janice Traverso at (209) 274-2412, ext. 102.

Notification 24 hours prior to the meeting will enable the City to make reasonable arrangements to ensure accessibility to this meeting.

Agenda Item #F1
Proclamation

A PROCLAMATION OF THE CITY COUNCIL OF THE CITY OF IONE
WHEREAS, Kristi Roots was born in Southern California and raised in Sonora; and WHEREAS, Kristi fell in love with Mike Roots, a boy from lone; and WHEREAS, after college at CSU Stanislaus earning a Bachelor of Arts in Sociology, Mike and Kristi settled in lone to raise a family; and
WHEREAS, Kristi first worked at Mule Creek State Prison, but then decided to enter the family business with her mother in law; and
WHEREAS, after Dolores retired in 2000, the business became Kristi Roots Insurance and expanded to offer a range of insurance products; and WHEREAS, Kristi's business mantra is "We know our customers personally,"; and WHEREAS, Kristi has gotten involved with many community projects including organizing and operating the Ione Swim Team, served on the Board of Amador Youth Basketball; sponsoring youth sports, and has donated both her time and funding to a host of other projects through the years that have asked for her assistance; and WHEREAS, about twenty years ago, Kristi was asked to help set up a blood drive location for lone at Mule Creek and Preston Youth Correctional Facility; and WHEREAS, Kristi agreed to help and shortly after, the chair of the project retired and Kristi was "promoted" by default; and
WHEREAS, Kristi has been organizing blood drives in lone ever since which has served not only lone, but the entire Amador region.; and
WHEREAS, Kristi, her family, and her staff at Kristi Roots Insurance, work as a team to organize a blood draw event.; and
WHEREAS, Kristi organizes the operation, but everyone pitches in with social media posts, flyers, setting up chairs in Evalyn Bishop Hall, cleaning up, and buying the Nutter Butter cookies that blood donors "in the know" demand; and WHEREAS, Kristi has donated 116 pints of blood herself (19 pints ahead of Mike) and is pretty tireless in recruiting donors; and
WHEREAS, local blood donations benefit the local community by ensuring that blood will be available in the event of a major emergency or when disasters interrupt a community's ability to hold a blood drive locally; and
NOW THEREFORE BE IT RESOLVED, that the City Council of the City of lone hereby wishes to extend its sincere gratitude to Kristi Roots for giving of herself in so many ways that has benefitted lone and all of Amador.

BE IT FURTHER RESOLVED, by the City Council of the City of lone, the Council hereby takes great pleasure in congratulating Kristi Roots on receiving Golden Acorn Award.

The foregoing Proclamation was duly introduced and adopted by the City Council of the City of lone at their regular meeting held on February 20, 2024 by the following vote:

AYES:

NOES:

ABTAIN:

ABSENT:

Mayor Alison LaFayne
Attest:

Janice Traverso, City Clerk
CITY OF IONE Agenda Item #H1

FIRE DEPARTMENT
Monthly Status Report
January 2024
Type Number of Calls
Emergency Medical 43
Medical Alarms - False 1
Vehicle Accidents Jaws Used - 2 14
Animal Rescue 1
Lift Assist 21
Vehicle vs Building - Non injury 1
Natural Gas Leak/Investigation 1
Mutual Aid Fires 8
Water Rescue Lake Camanche 1
Support Services 2
Station cover assignments 27
Smoke alarm Activation Commercial 1
Residential 3
CO Alarm activation 2
Total fire loss in the city $ 0 Total Number of Incidents: 126 TRAINING: Total Hours 286 hrs of weekly department training 186 hrs of daily training
96 hrs of youth fire cadet training
In January the Department conducted the yearly CPR refresher for of our personnel Structural Fire standard operational procedures - Tactics - Fire protection systems Fire Fighter Survival and entrapment - Incident command for fire fighters down Hazardous Materials review and Decon for team and mass causality incidents Water Rescue Training and pre incident planing in the creek in town and rescue modes LARRO - Low Angle Rope Rescue training review
** RESCUES The department responded to two vehicle accidents that required the Jaws of life to be uses to extricate the trapped occupants, and also specialized rescue operations to get them to the medic unit.

The Personnel were also busy assisting with preparing and dealing with the heavy rains and wind Fire Prevention Inspections and Pre planning
** Through Donations to the Fire Fighters Association we were able to purchase and place into service a new CPR device call the "LUCAS DEVICE" that will assist us in CPR calls and assist us with OF
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CITY OF IONE
IONE, CA 95640
Agenda Item #H2
DATE: FEBRUARY 20, 2024
TO: THE HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL FROM: JOHN ALFRED, CHIEF OF POLICE
SUBJECT: RECEIVE AND FILE POLICE DEPARTMENT 2024 JANUARY REPORT RECOMMENDED ACTION:

Receive and file Police Department 2024 January Report
FISCAL IMPACT:

There is no fiscal impact associated with this item.

BACKGROUND:

This monthly report is for January 2024. This report is designed to give you an understanding of the day-to-day operations of the lone Police Department and staff for January 2024.

ATTACHMENTS:

Summary - 2024 January Report

IONE POLICE DEPARTMENT
January REPORT
Data is from January 15 to January 31st
POLICE
ICE

CITY OF IONE

POLICE DEPARTMENT
2024
January Report to City Council
Data is from January 1"' to January 315t

1. Calls for Service
2023 - January 465
2024 - January 532

2. Patrol Statistics
Type of Call 2023 - January 2024 - January
Officer Initiated 366 447
Incidents
Traffic Stops 95 134
Other OIA Incidents 271 313
Business Checks 187 239
Vehicle/Person Checks 14 15
Type of Report 2023 - January 2024 - January
Total Reports 43 34
Accident Reports :2 2
Corner's Case 0
Felony 7 2
Information Report 24 15
Infraction
Misdemeanor 15
Unclassified
Arrests 2023 - January 2024 - January
Total Arrests 9 6
Misdemeanor 8 6
Felony 1 0
Citations 2024 - January
2023- January
Total 21
Felony 0
Misdemeanor 3 5
Infraction 20 16

3. Staffing Levels
• 1 Chief
• 1 Sergeant
• 2 Corporals
• 3 Officers
1 Reserve
• 1 Part-time Administrative Analyst
• As of the date of this report, we are down one full-time sworn position. We have one reserve position open and are in the recruiting process to fill both positions. We have one new police officer who is currently in training. We hope she will be solo by mid- 2024.
• We currently run 12-hour shifts for patrol staff and corporals (Day Shift 6 AM - 6 PM, Graveyard 6 PM - 6 AM). Due to staffing levels, the Corporal overlap shift is not used. The Sergeant and Chief work a standard 8-hour shift Monday Through Friday.

4. Volunteer Unit
• This month, the volunteer unit was used for office duties, special events, and extra patrol.
• The Police Department could only function with the support of our volunteer unit. The volunteers assist with records, property and evidence, special events, vacation home checks, and other collateral duties as assigned.

5. Notable Cases
• On 1/2/24 and 1/3/24, officers responded to multiple locations in the City of lone on the report of vandalism. Multiple areas in the city were tagged with black spray paint. Victims included the City of lone, Kristi Roots Insurance, and the lone Hotel. Officers investigated and identified the suspect responsible for the tagging. The suspect was a juvenile, and the case was forwarded to probation.

On 1/12/24 at 0445 hours, Officers responded to a vehicle versus house accident in Wildflower. While en route, Dispatch advised the vehicle was leaving the scene. Officers found the vehicle on Foothill Blvd. and initiated a traffic enforcement stop. Officers interviewed the driver, who admitted to the accident and left the scene because he was scared. A report was sent to the DA for charges.
• During January, the lone Police Department Handled the following cases:
2 - hit and run accidents
3 - Sex offender registrations/updates
2 - Child abuse investigations
1 - Mental health detention
6 - Warrants cleared
2 - Domestic violence cases
4 - Violation of restraining/court orders
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CITY OF IONE
IONE, CA 95640
LIFO
Agenda Item #F3
DATE: FEBRUARY 20, 2024
TO: AMY GEDNEY, INTERIM CITY MANAGER
FROM: JODI STENECK, FINANCE MANAGER
SUBJECT: JANUARY 2024 FINANCE/ADMINISTRATIVE REPORT
To provide information regarding the activities of the Administration Department for the month of January 2023
Agendas & Meetings:
• Prepared and/or attended:
• One City Council meeting, one CFD Committee meeting, one Parks and Recreation Commission meeting and one Joint Workshop with City Council and Planning Commission.

Recreation Program:
• 2024 Recreation Event Calendar and Plan created.
• Ione 4-H Lease of Howard Park Barn.

Decorated the Park and Ride for Love lone event.

Human Resources:
• Hired a Public Works employee.
• Check out of two employees, one in Police, one in Administration.

Finance - Sewer Rate Study:
• Provided rates, fees, charges for customer class for sewer system. • Provided financial data as requested.
• Meeting with Willdan to discuss items provided and next steps.

Finance - Accounts Payables:
• Thirty-four (34) warrants for a total of $145,189.37
Grant Administrator:
• Updated loan balances for each recipient, identified loans paid or written off. • Updated grant fund balances
• Researched uses each specific grant
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CITY OF IONE
IONE, CA 95640
Agenda Item #H4
DATE: FEBRUARY 20, 2024
TO: AMY GEDNEY, INTERIM CITY MANAGER
FROM: JOSHUA TIRAPELLI, BUILDING OFFICIAL

JORDAN DOERKSEN, ADMINISTRATIVE ASSISTANT
SUBJECT: JANUARY 2024 BUILDING DEPARTMENT REPORT
To provide information regarding the activities of the Building Department for the month of January 2024.

Permits Issued:
• Solar: 5 $3,071.11
• HVAC: -
• Reroof: 1 $388.46
• Pool: 0
• Patio Cover: 0
• New SFD: 0
• Garage/Carport: 0
Water Heater: 4 $829.00
• Meter Panel: 0 $
• Misc. Electrical: $
• Misc. Building: $ -
Misc. Plumbing: 1 $166.00
TOTAL 11 $4,454.57
Inspections Completed:
• Code Enforcement: 0
Consultation: 1
• Drywall: 1
• Electrical:
• Electrical Panel: 4
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CITY OF IONE
IONE, CA 95640
Final Inspections: 4
Footings: 5
• Framing:

Garage/Carport: 0
• HVAC Final: 3
• Insulation:

Lath:

Patio Cover:
• Pool/Spa: 3
• Re-Roof: 1
• Roof Nail: 0
• Sewer Lateral: 1
Shear Nailing: 0
Solar P/V Final: 1
Structural Slab: 4
Water Heater: 1
Water Lateral: 4
TOTAL 40
Agenda Item #H5

MONTHLY

OPERATIONS
REPORT
forthe: City of lone
Castle Oaks and the Wastewater Treatment
Facilities
Wastewater Services
January 2024
Agenda Item #H5
RE: JANUARY 2024 MONTHLY OPERATIONS REPORT
Dear Mrs. Godney:

WaterStone Services is pleased to present our monthly operations report detailing our operations and maintenance activities at your wastewater treatment facilities during the previous month. Our report addresses the following key areas of concern:

1. Permit Compliance

2. Plant Flows

3. Plant Loads

4. Plant Process and Performances

5. Maintenance and Repair

6. Process Chemicals

7. Solids Disposal

8. Safety
Should you have any questions or concerns regarding this report or any aspect of our operation, please don't hesitate to contact me.

Thank you for your time,
Sincerely,
Kathy Stone- Operations Manager
Agenda Item #H5

1. PERMIT COMPLIANCE
Central Valley Regional Water Quality Control Board provides a Permit for the Operation of the Pond Treatment System. BOD excursions occurred in January. The State Water Resources Control Board was notified and an explanation letter was sent to the state regulator. All other regulatory water quality monitoring requirements were met. The WWTP Facilities achieved compliance with weekly parameters, as documented in TaBLe 1.1 below.

TABLE 1.1 - PERMIT COMPLIANCE

POND PARAMETER PERMIT LIMIT FREQUENCY AVERAGE MONTHLY HIGH MONTHLY LOW 1 Dissolved Oxygen >1.0 X 3 Weekly 2.9 3.2 2.2
2 Dissolved Oxygen >1.0X3 Weekly 3.5 4.2 2.5
3 Dissolved Oxygen 21.0X3 Weekly 4.7 3.5
4 21.0 X3 6.1 3.5
Dissolved Oxygen Weekly
*
5 Dissolved Oxygen >1.0X3 Weekly
6 Dissolved Oxygen >1.0X3 Weekly 3.9 5.7 2.6
>1.0X3 Weekly * * *
7 Dissolved Oxygen

POND PARAMETER PERMIT LIMIT FREQUENCY
1 pH 6.0-9.0 Weekly 7.1 72 6.9
2 pH 6.0-9.0 Weekly 7.0 7.2 6.8
pH 6.0-9.0 Weekly 6.6 72 6.4

6.0-9.0 Weekly 6.4 6.7 6.2
pH *
5 6.0.9.0 Weekly * *
pH
pH 6.0-9.0 Weekly 6.6 7.1 6.1

6.0-9.0 Weekly * * *
7 pH

POND PARAMETER PERMIT LIMIT FREQUENCY AVERAGE MONTHLY HIGH MONTHLY LOW 1 Freeboard 2.0 Weekly 2.0 2.0 2.0
2 Freeboard 2.0 Weekly 2.0 20 2.0
3 Freeboard 2.0 Weekly 2.0 2.0 2.0
4 Freeboard 2.0 Weekly 2.0 2.0 2.0
5 Freeboard 2.0 Weekly 9.9 10.0 9.8
6 Freeboard 2.0 Weekly 5.5 5.6 5.4
7 Freeboard 2.0 Weekly 9.6 9.6 9.6

POND PARAMETER PERMIT LIMIT FREQUENCY AVERAGE MONTHLY HIGH MONTHLY LOW 1 Berm Condition Visual Weekly OK
2 Berm Condition Visual Weekly
3 Berm Condition Visual Weekly
4 Berm Condition Visual Weekly
5 Berm Condition Visual Weekly OK
Berm Condition Visual Weekly OK
Berm Condition Visual Weekly OK

POND PARAMETER PERMIT LIMIT FREQUENCY AVERAGE MONTHLY HIGH MONTHLY LOW 1 Seepage/Odor Visual Weekly OK MILD ODOR OK
2 Seepage/Odor Visual Weekly OK
3 Seepage/Odor Visual Weekly
4 Seepage/Odor Visual Weekly
Seepage/Odor Visual Weekly 99999 \
5 6 Seepage/Odor Visual Weekly
Seepage/Odor Visual Weekly
* Pond level too low to safely sample
Agenda Item #H5

2. INFLUENT FLOW - Wastewater Treatment Pond Plant
The total Influent flow of 16.903 MGD of wastewater has been recorded for the month of January.

The average daily influent flow for January was 0.545 MGD. A maximum daily flow of 0.819 MGD was recorded on January 21ND. A minimum daily flow of 0.408 MGD on January 30TH.

Graph 1 below trends the Influent flow for the month.

INFLUENT FLOW

0.900

0.800

0.700

0.600

0.500

0.400

0.300

0.200

0.100

0.000
1/1/2024 1/15/2024 1/19/2024
_ influent Flow

3. PLANT PROCESSES AND PERFORMANCE
Solids - Tertiary Treatment Plant
Draining clarifier, solids sent to drying beds
Plant Loads
The plant loading consists of domestic wastewater.

Influent Headworks
Station is inspected daily. Filter screen cleaned as needed Aeration
All pond aerators working for the month of January,
Farmer's Irrigation - N/A FOR JANUARY
Agenda Item #H5

4. Collection System

DESCRIPTION
Hydro vac Oakview Dr. and Fairway Dr., Raymond Dr, Plymouth HWY, Castle Oaks Dr and Five Mile Dr. (in front of water treatment plant.)
Manholes
#3957 - #3955
#3959 - #3957
#3932 - #3959
#3926 - #3924
#3928 - #3926
#3930 - #3928
#3932 - #3930
#3934 - #3932
#3936 - #3934
#3939 - #3936
#3941 - #3939
#3943 - #3941
#5092 - #5094
#5094 - #3947
#3947 - #3949
#3949 - #3945
#3945 - #3943
#3784 - LH (Lamp hole)
#3782 - #3784
#3780 - #3782
#3787 - LH (lamp hole)
#3780 - #3787
#3778 - #3780
#3778 - LH (Lamp hole)
#3776 - #3778
#3774 - #3776
#3831 - #3774
#3840 - #3831
#6026 - #6024
#6028 - 6026
LIFT STATION #6028
TOTAL LENGTH CLEANED 8057'
Agenda Item #H5

5. MAINTENANCE AND REPAIR
Maintenance and repair is a critical component of the overall operations of the wastewater treatment cacials. sare steed and is worked i a tiny with the City of lone maintenance staff to assure that The following critical tasks completed this month:
• CHECKED AND INSPECTED EYE WASH STATIONS WEEKLY
• CHECKED AND INSPECTED LIFT STATIONS DAILY
• CHECK FIRE EXTINGUISHERS MONTHLY
• CL2 METER INSTALLED BY TELSTAR - 1/12/2024
• SEWER LINE CLEANING AS REQUIRED
• CREATED EXTRA POND STORAGE FOR WINTER SEASON
• TERTIARY PLANT SHUTDOWN ON 11/17/2024
• SAFETY SIGNAGE POSTED AT BOTH FACILITIES ONGOING
• ALL MONTHLY SAMPLES COMPLETED
• CALIBRATION OF METERS AND PROBES, AND OTHER QA/QC TASKS • CREATED IMPLEMENTED AND UPDATED SOP MANUALS
• RESPONDED TO ALL ALARMS /CALLOUTS

ITEMS REQUIRING CLIENT APPROVAL

ITEM CRITICALITY STATUS COMPLETION
DATE
CL 2 METER HIGH APPROVED 1/12/2024

CO LIFT SENSOR MEDIUM APPROVED N/A

CHEM SPEED DIAL POLY HIGH APPROVED N/A

CHLORINE TANK PLUMBED MEDIUM APPROVED N/A

PAINT FOR WWTP OPERATIONS MEDIUM APPROVED N/A

AND TOOL SHED BUILDINGS

CHEMICAL OXYGEN DEMAND MEDIUM APPROVED N/A

COLORIMETER AND TEST KIT

6.0 PROCESS CHEMICALS
The process chemical inventory (chlorine, polymer) are the bulk of chemicals used at the plant. Al chemicals used are being tracked on a daily basis.

7. SOLIDS DISPOSAL
Sludge is separated from water and deposited in the solids sludge drying bed. When enough is collectec it will be analyzed and sent to the disposal site.

Agenda Item #H5

8.0 SAFETY
Safety of the Waterstone Services staff, and the facility itself is a critical concern. Safety meetings topics for the month of January included: Personal Protective Equipment: Dress for Safety and Ergonomics. We are pleased to report that there were no workplace accidents or injuries in the past month Please be sure to send monitoring reports electronically using the following instructions:

To submit the electronic reports:

1. First, make a PDF copy of your report and include the signed transmittal form as the first page of

4. Attach the PDF file to the email.

Finally, send the email, PDF attachment, and the updated table to [email protected]
January 24, 2023 DMR Reporte
Title and Date of Report 01/18/2024
Contact Kenny Croyle (916) 464-4676
Regulatory Program Waste Discharge to Land (Non15)
Unit Compliance
City of lone, Jackson Rancheria
Regulated Party Name (Discharger) Development Corporation Facility Name lone Wastewater Treatment Facility
County Amador
CIWQS Place ID CW-214640
Monitoring Report Submittal Transmittal Form
Attn: Kenny Croyle (916) 464-4676
Discharger: City of lone, Jackson Rancheria Development Corporation Name of Facility: lone Wastewater Treatment Facility
WDRs Order Number: R5-2013-0022-001
CIWQS Place ID: CW-214640
County: Amador
I am hereby submitting to the Central Valley Water Board the following information:

Check all that apply:

Monthly Monitoring Report for the month of: Jaunuary 2024. 1st / 2nd / 3rd / 4th (circle one) Quarterly Monitoring Report for the year of 1st / 2nd (circle one) Semi-annual Monitoring Report for the year Annual Monitoring Report for the year _
Violation Notification
During the monitoring period, there were were not (circle one) any violations of the WDRs.

1. The violations were: Biochemical Oxygen Demand samples collected on in January exceeded the maximum daily limit of 60mg/L

2. Have the violations been corrected? Yes (No.)f no, what will be done to correct the violations:

We have purchased a COD colorimeter and will be closely monitoring COD in effluent pond 4. Plan has been implemented to remove duckweed for all ponds.

Certification Statement
"I certify under penalty of law that I have personally examined and am familiar with the information submitted in this document and all attachments and that, based on my inquiry of those individuals immediately responsible for obtaining the information, I believe that the information is true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment." Signature: Phone: 916 - 767-1767
Printed Name: Jesse Gaona Date: February 05, 2024
City of lone - Wastewater Treatment Plant
Monthly Discharger Self-Monitoring Report
Date: JANUARY 2024
Influent Monitoring Pond #4 Effluent Monitoring
Domestic ARSA Flow to Total Flow to
BOD;, Total
Influent PERC Water BODS, TDS,
Perc Ponds, EC, Monthly Nitrogen, pH,
Date Flow, Daily Monthly Monthly Monthiy
Ponds, Daily Daily Grab Monthly Monthly
Continuous Grab Grab Grab
Measurement Measurement (umhos/cm) Grab Grab
(mg/L) (mg/L) (mg/L)
(MGD) (MGD) (MGD) (mg/L)
1 0.452 0.452

0.671 0.671

0.503 200 0.503 >80 240 480 33 6.6
4 0.504 0.504

0.500 0.500

0.508 0.508

0.514 0.514

0.427 0.427
9 0.427 0.427
10 0.505 0.505
11 0.459 0,459
12 0.536 0.536
13 0.625 0.625
14 0.419 0.419
15 0.502 0.502
16 0.575 0.575 62
17 0.531 0.531
18 0.437 0.437
19 0.553 0.553
20 0.649 0.649
21 0.818 0.818
22 0.732 0.732
23 0.567 0.567 76
24 0.680 0.680 74
25 0.603 0.603 73
26 0.528 0.528
27 0.517 0.517
28 0.470 0.470
29 0.669 0.669
30 0,408 0.408
31 0.614 0.614
Ainimur 0.408 200 0.408 62 240 480 33 6.6
Чахітці 0.818 200 76 240 480 6.6

0.818 33
Average 0.545 200 0.545 71 240 480 33 6.6
Count 31 31 4 1 1
Month
ly 16.903 16.903
Total
5 Discharge Specifications
ADWF 0.52 Maximum 0.78 60 Daily
Minimum 6.0
Herinato 0.78 Total Annual 246
40 Avg Maximum 9.0
City of lone - Wastewater Treatment Plant
Monthly Discharger Self-Monitoring Report
Date: JANUARY 2024
Treatment Pond Monitoring
Pond #1
D.O., pH, Freeboard, Berm
Seepage,
Weekly Weekly Weekly Condition, Odor,
Date Weekly
Grab Grab Meas. Weekly Weekly
Visual
(mg/L) (SU) (0.1 ft) Visual
1 3.2 7.1 2.0 OK OK MILD
8 9
10 11 3.2 7.0 2.0 OK OK MILD
13 14
15 16
17 18 2.8 7.1 2.0 OK OK OK
19 21
25 2.2 6.9 2.0 OK PK OK
28 30
31 3.1 7.2 2.0 OK OK OK
Min 2. .2 6.9 2.0
Max 3.2 2.0
Average 2.9 7.1
Count 5 5
Monthly Total
Violations
Discharge Specifications
Minimum <1.0X3 6.0 2.0
Maximum 9.0
City of lone - Wastewater Treatment Plant
Monthly Discharger Self-Monitoring Report
Date: JANUARY 2024
Treatment Pond Monitoring
Pond #2
D.O., pH, Freeboard, Berm
Seepage,
Weekly Weekly Weekly Condition, Odor,
Date Weekly
Grab Grab Meas. Weekly Weekly
Visual
(mg/L) (SU) (0.1 ft) Visual
2 3
5 4.2 7.0 2.0 OK OK OK
vio
9 4.2 6.9 2.0 OK OK OK
15 16
17 18 2.5 7.2 2.0 OK OK OK
19 20
21 22
23 24
25 2.5 7.0 2.0 OK OK OK
26 27
28 29
30 31 6.8 2.0 OK OK OK
Minimum 6.8 2.0
Maximum 7.2 2.0
Average 3.5 7.0 2.0
Count 5 5 5
Monthly Total
Violations
Discharge Specifications
Minimum <1.0X3 6.0 2.0
Maximum 9.0
City of lone - Wastewater Treatment Plant
Monthly Discharger Self-Monitoring Report
Date: JANUARY 2024
Treatment Pond Monitoring
Pond #3
D.O., pH, Freeboard, Berm
Seepage,
Weekly Weekly Weekly Condition, Odor,
Date Weekly
Grab Grab Meas. Weekly Weekly
Visual
(mg/L) (SU) (0.1 ft) Visual
1 2
3 4
5 3.8 6.6 2.0 OK OK OK
8 3.5 6.6 2.0 OK OK OK
13 14
15 16
17 18 3.5 7.2 2.0 OK OK OK
19 20
21 22
23 24
25 3.8 6.4 2.0 OK OK OK
26 27
28 29
30 31 4.7 6.5 2.0 OK OK OK
Minimum 3.5 6.4 2.0
Maximum 4.7 2.0
Average 3.9 6.6 2.0
Count 5 5 5
Monthly Total
Violations
Discharge Specifications
Minimum < 1.0 X 3 6.0 2.0
Maximum 9.0
City of lone - Wastewater Treatment Plant
Monthly Discharger Self-Monitoring Report
Date: JANUARY 2024
Treatment Pond Monitoring
Pond #4
D.O., рн, Freeboard, Berm
Seepage,
Weekly Weekly Weekly Condition, Odor,
Date Weekly
Grab Grab Meas. Weekly Weekly
Visual
(mg/L) (SU) (0.1 ft) Visual
1 3
4 5 4.0 6.6 2.0 OK OK
OK
7 8

4.0 6.7 2.0 OK OK OK
12 13
14 15
16 17
18 3.5 6.5 2.0 OK OK OK
19 20
21 22
23 24
25 6.1 6.2 2.0 OK OK OK
26 27
28 29
30 31 6.1 2.0 OK OK OK
Minimum 6.1 2.0
Maximum 6.7 2.0
Average 4.6 2.0
Count 5 5
Monthly Total
Violations
Discharge Specifications
Minimum <1.0X3 6.0 2.0
Maximum 9.0
City of lone - Wastewater Treatment Plant
Monthly Discharger Self-Monitoring Report
Date: JANUARY 2024
Percolation Pond Monitoring
Pond #5
D.O., pH, Freeboard, Berm
Weekly Weekly Seepage,
Weekly Condition, Odor,
Date
Grab Grab Meas. Weekly
Weekly Weekly
Visual
(mg/L) (SU) (0.1 ft) Visual
2 3
4 5 EMPTY EMPTY EMPTY OK OK OK
9 10
11 EMPTY EMPTY EMPTY OK OK OK
12 13
14 15
16 17
18 EMPTY EMPTY EMPTY OK OK OK
19 20
21 22
23 24
25 * * 10.0 OK OK OK
26 27
28 29
30 31 * * 9.8 OK OK OK
Minimum 9.8
Maximum 10.0
Average 9.9
Count 2
Monthly Total
Violations
Discharge Specifications
Minimum < 1.0X3 6.0 20
Maximum 9.0
* Pond level too low to safely sample
City of lone - Wastewater Treatment Plant
Monthly Discharger Self-Monitoring Report
Date: JANUARY 2024
Percolation Pond Monitoring
Pond #6
D.O., pH, Freeboard, Berm
Seepage,
Weekly Weekly Weekly Condition, Odor,
Date Weekly
Grab Grab Meas. Weekly Weekly
Visual
(mg/L) (SU) (0.1 ft) Visual
2 4.0 7.1 5.5 OK OK OK
6 4.0 7.1 5.5 OK OK OK
13 14
16 17
18 2.6 6.2 5.6 OK OK OK
19 20
21 22
23 24
25 3.1 6.4 5.4 OK OK
26 27
28 29
30 31 5.7 6.1 5.6 OK OK OK
Minimum 2.6 6.1 5.4
Maximum 5.7 7.1 5.6
Average 3.9 6.6 5.5
Count 5 5 5
Monthly Total
Violations
Discharge Specifications
Minimum < 1.0 X 3 6.0 2.0
Maximum 9.0
City of lone - Wastewater Treatment Plant
Monthly Discharger Self-Monitoring Report
Date: JANUARY 2024
Percolation Pond Monitoring
Pond #7
D.O., pH, Freeboard, Berm
Seepage,
Weekly Weekly Weekly Condition, Odor,
Date Weekly
Grab Grab Meas. Weekly Weekly
Visual
(mg/L) (SU) (0.1 ft) Visual

EMPTY EMPTY EMPTY OK OK OK
9 10
11 EMPTY EMPTY OK OK
12 13
14 15
16 EMPTY EMPTY EMPTY OK OK
19 20
22 24
25 EMPTY EMPTY EMPTY OK OK OK
26 28
29 30
31 * * OK OK

9.6 OK
Minimum 9.6
Maximum 9.6
Average 9.6
Count 1
Monthly Total
Violations
Discharge Specifications
Minimum < 1.0X3 6.0 2.0
Maximum 9.0
City of lone - Wastewater Treatment Plant
Field Instrument Calibration Log
Date: JANUARY 2024
Horiba U-50 EUTECH
Date Multi Water Elite pH
Checker Tester
1/3/2024 N/A X
1/5/2024
1/11/2024
1/18/2024 x x
1/25/2024
1/31/2024
TxC

WATERSTONE
Date: 8 February 2024
To: Kenny Croyle, Waterboards
From: Kathy Stone, Waterstone Services
Re: Annual monitoring Report - 2023
Kenny -
Please find attached to this email a tabular and graphical summaries of the data collected during the 2023 year from the tertiary treatment system.

There were no violations since Waterstone took over Operations and Maintenance July 1, 2023. I have also attached pictures and narratives discussing all the improvements/maintenance we have implemented since July 1, 2023 for your review.

We are currently working with West Yost and Tel-Star on several capital improvements at the facility, which will enhance the process and operations.

Such as, telemetry, analyzers, NTU meters and chlorine and polymer feed pumps
No Biosolids were removed from the facility in 2023. We may have Synagro remove what is currently in the drying beds later this year when the solids have had a chance to dry.

Please let me know if you have any questions.

Thank you,
King Stone
Kathy Stone
Operations Manager
Cc: Amy Gedney - City of Ione
Jesse Gaona- Waterstone Services

MONTHLY

OPERATIONS
REPORT
forthe: City of lone
Castle Oaks and the Wastewater Treatment
Facilities
Wastewater Services
December 2023
RE: DeceMBEr 2023 MONTHLY OPERATIONS REPORT
Dear Mrs. Godney:

Permit Compliance

2. Plant Flows

3. Plant Process and Performances

4. Collection System

5. Maintenance and Repair

6. Process Chemicals

7. Solids Disposal

8. Safety
Should you have any questions or concerns regarding this report or any aspect of our operation, please don't hesitate to contact me.

Thank you for your time,
Sincerely,
Kathy Stone- Operations Manager
James Whitaker- Facility Manager

1.0 PERMIT CoMPLIANCE
Central Valley Regional Water Quality Control Board provides a Permit for the Operation of the Pond Treatment System. A BOD excursion occurred in December. The Pond 4 Effluent BOD result was 63 mg/l and the permit daily max is 60 mg/l. The State Water Resources Control Board was notified of the excursion and an explanation letter was sent to the State Regulator. All other regulatory water quality monitoring requirements were met. The WWTP Facilities achieved compliance with weekly parameters, as documented in TaBLe 1.1 below.

TABLE 1.1 - PERMIT COMPLIANCE

POND PARAMETER PERMIT LIMIT FREQUENCY AVERAGE MONTHLY HIGH MONTHLY LOW 1 3.7 4.5 3.2
Dissolved Oxygen >1.0 X 3 Weekly
2 Dissolved Oxygen >1.0X3 Weekly 3.8 5.6 2.1
3 >1.0 X3 5.1 6.5 3.4
Dissolved Oxygen Weekly
>1.0X3 3.3 5.5 22
Dissolved Oxygen Weekly
Dissolved Oxygen >1.0 X 3 Weekly 4.0 4.0 3.9
Dissolved Oxygen >1.0 X 3 Weekly 4.5 5.8 3.1
>1.0 X 3 Weekly 2.9 3.4 2.2
7 Dissolved Oxygen

POND PARAMETER PERMIT LIMIT FREQUENCY AVERAGE MONTHLY HIGH MONTHLY LOW 1 pH 6.0-9.0 Weekly 7.1 7.3 6.9
pH 6.0-9.0 Weekly 7.1 7.5 6.4
pH 6.0-9.0 Weekly 7.0 72 6.8

6.0-9.0 Weekly 6.7 7.0 6.4

6.0-9.0 Weekly 6.T 6.2 6.0
pH
pH 6.0-9.0 Weekly 6.8 7.5 6.2

6.0-9.0 Weekly 6.3 6.8 6.1
7 pH

POND PERMIT LIMIT FREQUENCY AVERAGE MONTHLY HIGH MONTHLY LOW

PARAMETER
1 Freeboard 2.0 Weekly 2.0 2.0 2.0
Freeboard 2.0 Weekly 2.0 2.0 2.0
Freeboard 2.0 Weekly 2.0 2.0 2.0
Freeboard 2.0 Weekly 2.0 2.0 2.0
Freeboard 2.0 Weekly 9.0 9.5 8.5
6 Freeboard 2.0 Weekly 7.1 8.0 6.1
7 2.0 Weekly 7.8 8.5 7.2
Freeboard

POND PARAMETER PERMIT LIMIT FREQUENCY AVERAGE MONTHLY HIGH MONTHLY LOW 1 Berm Condition Visual Weekly OK OK OK
2 Berm Condition Visual Weekly OK
3 Berm Condition Visual Weekly
4 Berm Condition Visual Weekly 79 7
Berm Condition Visual Weekly
5 6 Berm Condition Visual Weekly OK
Berm Condition Visual Weekly OK

POND PARAMETER PERMIT LIMIT FREQUENCY AVERAGE MONTHLY HIGH MONTHLY LOW 1 Seepage/Odor Weekly OK OK OK
2 Seepage/Odor Weekly OK
3 Seepage/Odor Weekly OK
4 Seepage/Odor Weekly
5 Seepage/Odor Weekly
6 Seepage/Odor Weekly
7 Seepage/Odor Weekly

2.0 INFLUENT FLOW - Wastewater Treatment Pond Plant
The total Influent flow of 13.354 MGD of wastewater has been recorded for the month of December. The average daily Influent flow for December was 0.431 MGD. A maximum daily flow December o was recorded on December 22™. A minimum daily flow of 0.289 MGD on Graph 2 below trends the Influent flow for the month.

INFLUENT FLOW

0.600

0.500

0.400

0.300

0.200

0.100

0.000
12/1/2024 12/5/2024 12/12/2024 12/19/2024 12/21/2024 12/23/2024 12/25/2024 12/27/2024 12/29/2024 12/31/2024 Influent Flow

3.0 PLANT PROCESSES AND PERFORMANCE
Solids - Tertiary Treatment Plant
Draining clarifier, solids sent to drying beds
Plant Loads
The plant loading consists of domestic wastewater.

Influent Headworks
Station is inspected daily. Filter screen cleaned as needed Aeration
All pond aerators working for the month of December,
Farmer's Irrigation - N/A FOR DECEMBER

4.0 Collection System
DESCRIPTION LENGTH IN FT.

OAKVIEW DRIVE 428
мн #3928 TO MH #3951 AND MH #3951 то мн #3953
BIRCHWOOD COURT 320
MH #4017 TO MH #4017
COTTONWOOD COURT 410
MH #4022 TO MH #4224
W. MARKET STREET & BUENA VISTA STREET 748
Mн#3679 TO MH #3681, MH #3679 TO MH #3687 AND MH #3687
TO MH #3716
W. MARLETTE STREET 1223
мн #3598 TO MH #3600, мн #3598 TO мн #3601, мн #3601 то 3603 AND MH #3603 TO MH #3605
EDGEBROOK #1 LIFT STATION, EDGEBROOK #2 LIFT STATION, N/A

SOUTHVALLEY LIFT STATION AND INFLUENT HEADWORKS
TOTAL LENGTH CLEANED 3183

5.0 MAINTENANCE ANd REPAIR
Maintenance and repair is a critical component of the overall operations of the wastewater treatment facilities. Waterstone Services is working closely with the City of lone maintenance staff to assure that critical tasks are identified and corrected in a timely manner.

The following critical tasks completed this month:
• CHECKED AND INSPECTED EYE WASH STATIONS WEEKLY
• CHECKED AND INSPECTED LIFT STATIONS DAILY
• CHECK FIRE EXTINGUISHERS MONTHLY
• SEWER LINE CLEANING AS REQUIRED
• CREATED EXTRA POND STORAGE FOR WINTER SEASON
• TERTIARY PLANT SHUTDOWN ON 11/17/2023, CLEANING REPAIRING EQUIPMENT • EMPTIED AND CLEANED CONTACT CHAMBERS AT TERTIARY PLANT • CREATED AND IMPLIMENTED JSA
• HOMETOWN GENERATORS SERVICED LIFT STATION GENERATORS
• GRIFF ELECTRIC SERVICED GFI AT EDGEBROOK #1 LIFT STATION • SAFETY SIGNAGE POSTED AT BOTH FACILITIES ONGOING
• ALL MONTHLY SAMPLES COMPLETED
• CALIBRATION OF METERS AND PROBES, AND OTHER QA/QC TASKS • CREATED IMPLEMENTED AND UPDATED SOP MANUALS
• RESPONDED TO ALL ALARMS /CALLOUTS

ITEMS REQUIRING CLIENT APPROVAL

ITEM CRITICALITY STATUS COMPLETION
DATE
CL 2 METER HIGH APPROVED N/A

CO LIFT SENSOR MEDIUM APPROVED N/A

CHEM SPEED DIAL POLY HIGH APPROVED N/A

CHLORINE TANK PLUMBED MEDIUM APPROVED N/A

PAINT FOR WWTP OPERATIONS MEDIUM APPROVED N/A

AND TOOL SHED BUILDINGS

6.0 PROCESS CHEMICALS
The process chemical inventory (chlorine, polymer) are the bulk of chemicals used at the plant. All chemicals used are being tracked on a daily basis.

7.0 SOLIDS DISPOSAL
Sludge is separated from water and deposited in the solids sludge drying bed. When enough is collected it will be analyzed and sent to the disposal site.

8.0 SAFETY
Safety of the Waterstone Services staff, and the facility itself is a critical concern. Safety meetings topics for the month of December included: Back Injury Prevention and Earthquake Preparedness. We are pleased to report that there were no workplace accidents or injuries in the past month Please be sure to send monitoring reports electronically using the following instructions:

To submit the electronic reports:

1. First, make a PDF copy of your report and include the signed transmittal form as the first page of the report.

2. Then, edit the table below to show the date and title of the report you are submitting

3. Copy and paste the updated table into the body of an email . Attach the PDF file to the email.

Check all that apply:

Monthly Monitoring Report for the month of: DECEMBER 2023. 1st / 2nd / 3rd / 4th (circle one) Quarterly Monitoring Report for the year of 1st / 2nd (circle one) Semi-annual Monitoring Report for the year Annual Monitoring Report for the year _
Violation Notification
During the monitoring period, there(were were not (circle one) any violations of the WDRS.

1. The violations were: Biochemical Oxygen Demand sample collected on 12/06/2023 exceeded the maximum daily limit of 60mg/L

2. Have the violations been corrected? (Yes No. If no, what will be done to correct the violations:

We had aerators with equipment failures in the month of December. These aerators are now back on-line, thus increasing the aeration in the basins. We also moved aerators around the ponds to facilitate better mixing and aeration.

Certification Statement
"/ certify under penalty of law that / have personally examined and am familiar with the information submitted in this document and all attachments and that, based on my inquiry of those individuals immediately responsible for obtaining the information, I believe that the nformation is true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment.' Signature: Phone: 530-902-4805
Printed Name: James M. Whitaker Date: January 18, 2024
Please be sure to send monitoring reports electronically using the following instructions:

To submit the electronic reports:

1. First, make a PDF copy of your report and include the signed transmittal form as the first page of

3. Topy ad pastable updato saw he date and the report you are submiting.

4. Attach the PDF file to the email.

Finally, send the email, PDF attachment, and the updated table to [email protected]
DECEMBER 2023 DMR Reports
Title and Date of Report 01/18/2024
Contact Kenny Croyle (916) 464-4676
Regulatory Program Waste Discharge to Land (Non15)
Unit Compliance
City of lone, Jackson Rancheria
Regulated Party Name (Discharger) Development Corporation Facility Name lone Wastewater Treatment Facility
County Amador
CIWQS Place ID CW-214640
000000City of lone - Wastewater Treatment Plant Monthly Discharger Self-Monitoring Report Date: December 2023
Influent Monitoring Pond #4 Effluent Monitoring
Domestic ARSA Flow to Total Flow to Total
BOD5, BODS, TDS,
Influent PERC Water Perc Ponds, EC, Monthly Nitrogen, pH, Monthly Monthly Monthly
Date Flow, Daily Ponds, Daily Daily Grab Monthly Monthly Grab Grab Grab
Continuous Measurement Measurement (umhos/cm) Grab Grab (mg/L) (mg/L) (mg/L)
(MGD) (MGD) (MGD) (mg/L)
1 0.368 0.368
2 0.352 0.352
3 0.371 0.371
4 0.462 0.462
5 0.502 0.502
6 0.474 290 0.474 63 240 470 22 6.5
7 0.449 0.449
8 0.442 0.442
9 0.329 0.329
10 0.444 0.444
11 0.432 0.432
12 0,428 0.428
13 0.392 0.392
14 0.441 0.441
15 0.289 0.289
16 0.422 0.422
17 0.440 0.440
18 0.473 0.473
19 0.442 0.442
20 0.461 0.461
21 0.428 0,428
22 0.529 0.529
23 0,479 0.479
24 0.364 0.364
25 0,390 0.390
26 0.406 0.406
27 0.442 0.442
28 0.455 0.455
29 0.487 0.487
30 0.505 0.505

0.456 0.456
Minimun 0.289 290 0.000 0.289 63 240 470 22 6.5
Maximur! 0.529 290 0.000 0.529 63 240 470 22 6.5
Average| 0.431 0.431 240
count 31 31
Month

13.354 13.354
ly Total
1 Discharge Specifications
ADWF 0.52 Maximum 0.78 60 Daily Minimum 6.0

0.78 Total Annual 246 40 Avg Maximum 9.0
000000City of lone - Wastewater Treatment Plant Monthly Discharger Self-Monitoring Report Date: December 2023
Treatment Pond Monitoring
Pond #1
D.O., pH, Freeboard, Berm
Weekly Weekly Weekly Condition, Seepage, Odor,
Date Weekly
Grab Grab Meas. Weekly Weekly
Visual
(mg/L) (SU) (0.1 ft) Visual
1 3.2 7.1 2.0 OK OK OK
2 3
4 5

4.5 6.7 2.0 OK OK OK
7 10/∞
10 11
12 13 3.2 6.9 2.0 OK
14 16
17 18
19 20
21 3.6 7.3 2.0 OK OK OK
22 23
24 25
26 27 3.8 7.3 2.0 OK OK OK
28 29
30 31
Min 3.2 6.7 2.0
Max 4.5 7.3 2.0
Average 3.7 7.1 2.0
Count 5 5
Monthly Total
Violations
Discharge Specifications
Minimum < 1.0X3 6.0 2.0
Maximum 9.0
000000City of lone - Wastewater Treatment Plant Monthly Discharger Self-Monitoring Report Date: December 2023
Treatment Pand Monitoring
Pond #2
D.O., pH, Berm
Weekly Freeboard, Condition, Seepage,
Date Weekly Weekly Meas. Weekly Odor,
Grab Grab Weekly Weekly
(mg/L) (0.1 ft) Visual
(SU) Visual
1 3.9 7.1 2.0 OK OK OK
5 6 5.6 6.4 2.0 OK OK OK
12 13 4.0 7.2 2.0 OK OK OK
14 15
16 17
18 3.3 7.4 2.0 OK OK OK
21 7.5 2.0 OK OK OK
Minimum 2.1 6.4 2.0
Maximum 5.6 7.5 2.0
Average 3.8 7.1 2.0
Count 5 5
Monthly Total
Violations
Discharge Specifications
Minimum < 1.0 X 3 6.0 2.0
Maximum 9.0
000000City of lone - Wastewater Treatment Plant Monthly Discharger Self-Monitoring Report Date: December 2023
Treatment Pond Monitoring
Pond #3
D.O., pH, Freeboard, Berm
Weekly Weekly Weekly Condition, Seepage,
Date Odor,
Weekly
Grab Grab Meas. Weekly Weekly
(mg/L) (SU) Visual Visual
(0.1 ft)
1 3.8 7.0 2.0 OK OK OK
2 3
4 5

3.4 6.8 2.0 OK OK OK
8 10
11 12
13 5.4 7.0 2.0 OK OK OK
14 15
16 17
18 19
20 21 6.4 7.2 2.0 OK OK OK
22 23
24 25
26 27 6.5 6.8 2.0 OK OK OK
28 29
30 31
Minimum 3.4 6.8 2.0
Maximum 6.5 7.2 2.0
Average 5.1 6.9 2.0
Count 5 5 5
Monthly Total
Violations
Discharge Specifications
Minimum < 1.0X3 6.0 2.0
Maximum 9.0
000000City of lone - Wastewater Treatment Plant Monthly Discharger Self-Monitoring Report Date: December 2023
Treatment Pond Monitoring
Pond #4
D.O., pH, Freeboard, Berm
Weekly Weekly Weekly Condition, Seepage,
Date Weekly Odor,
Grab Grab Meas. Weekly Visual Weekly
(mg/L) (SU) (0.1 ft) Visual
1 2.9 6.4 2.0 OK OK OK
2 3
4 5

2.9 6.5 2.0 OK OK OK
11 5 1.5 7.0 2.0 OK OK OK
14 15
16 17
18 19
20 21 3.0 7.0 2.0 OK OK OK
22 23
24 25
26 27 2.2 6.7 2.0 OK OK OK
28 29
30 31
Minimum 2.2 2.0
Maximum 5.5 7.0 2.0
Average 3.3 6.7
Count 5 5
Monthly Total
Violations
BANS Discharge Specifications
Minimum < 1.0 X 3 6.0 2.0
Maximum 9.0
000000City of lone - Wastewater Treatment Plant Monthly Discharger Self-Monitoring Report Date: December 2023
Percolation Pond Monitoring
Pond #5
D.O., pH, Freeboard, Berm
Weekly Weekly Weekly Condition, Seepage,
Date Weekly Odor,
Grab Grab Meas. Weekly Visual Weekly
(mg/L) (SU) (0.1 ft) Visual
1 3.9 6.2 8.5 OK OK OK
2 3
4 6 4.0 6.0 9.5 OK OK OK
7 10/00
10 11
12 13 EMPTY EMPTY EMPTY EMPTY EMPTY EMPTY
14 15
16 17
18 19
20 21 EMPTY EMPTY EMPTY EMPTY EMPTY EMPTY
22 23
24 25
26 27 EMPTY EMPTY EMPTY EMPTY EMPTY EMPTY
28 29
30 31
Minimum 3.9 6.0 8.5
Maximum 4.0 6.2
Average 4.0 6.1
Count 2
Monthly Total
Violations
Discharge Specifications
Minimum < 1.0X3 6.0 2.0
Maximum 9.0
000000City of lone - Wastewater Treatment Plant Monthly Discharger Self-Monitoring Report Date: December 2023
Percolation Pond Monitoring
Pond #6
D.O., pH, Freeboard, Berm
Weekly Weekly Weekly Condition, Seepage,
Date Odor,
Grab Grab Meas. Weekly Weekly Weekly
Visual
(mg/L) (SU) (0.1 ft) Visual
1 5.3 6.4 7.8 OK OK OK
2 4
5 3.1 6.2 8.0 OK OK OK
8 9
10 11
12 13 4.2 7.1 7.2 OK OK OK
14 15
16 17
18 19
20 21 3.9 7.0 6.5 OK OK OK
22 23
24 25
26 27 5.8 7.5 6.1 OK OK
28 29
30 31
Minimum 3.1 6.2 6.1
Maximum 5.8 7.5 8.0
Average 4.5
Count 5
Monthly Total
Violations
Discharge Specifications
Minimum <1.0X3 6.0 2.0
Maximum 9.0
00000City of one - Wastewater Treatment Plant Monthly Discharger Self-Monitoring Report Date: December 2023
: Percolation Pond Monitoring
Pond #7
D.O., pH, Freeboard, Berm
Weekly Weekly Weekly Condition, Seepage,
Date Weekly Odor,
Grab Grab Meas. Weekly Weekly
Visual
(mg/L) (SU) (0.1 ft) Visual
1 3.4 6.1 8.5 OK OK OK
2 3
4 5
6 2.2 6.1 7.6 OK OK OK
7 10/00
10 11
12 13 3.1 6.8 7.2 OK OK OK
14 15
16 17
18 19
20 21 EMPTY EMPTY EMPTY EMPTY EMPTY EMPTY
22 23
24 25
26 27 EMPTY EMPTY EMPTY EMPTY EMPTY EMPTY
28 29
30 31
Minimum 2.2 6.1 7.2
Maximum 3.4 6.8 8.5
Average 2.9 6.3 7.8
Count 3
Monthly Total
Violations
Discharge Specifications
Minimum < 1.0X3 6.0 2.0
Maximum 9.0
000000City of lone - Wastewater Treatment Plant Field Instrument Calibration Log Date: December 2023
Horiba U-50
EUTECH Elite
Date Multi Water
pH Tester
Checker
12/1/2023
12/6/2023
12/13/2023
12/21/2023 x
12/27/2023
email: [email protected]
Corporate: 208 Mason Street | Ukiah, CA 95482 | T: 707-468-0401 | F: 707-468-5267 | ELAP# 1551 18 December 2023
WaterStone Services for City of lone
Attn: James Whitaker
14063 Morning Glory Place
Chico, CA 95973
RE: INF Monthly Grab WWTP
Work Order: 23L1264
Enclosed are the results of analyses for samples received by the laboratory on 12/06/23 14:50. If you have any questions concerning this report, please feel free to contact me.

Sincerely,
Recal Kuna
Rachel J. Kaua
Project Manager
email: [email protected]
Corporate: 208 Mason Street | Ukiah, CA 95482 | T: 707-468-0401 | F: 707-468-5267 | ELAP# 1551 WaterStone Services for City of lone Project Manager: James Whitaker 14063 Morning Glory Place Project: INF Monthly Grab WWTP Re Chico, CA 95973 Project Number: [none] 12/18/2:

ANALYTICAL REPORT FOR SAMPLES
Sample ID Laboratory ID Matrix Date Sampled Date Receiv WWTP Influent Monthly Grab 23L1264-01 12/06/23 09:32 12/06/23 14:

Water
email: [email protected]
Corporate: 208 Mason Street | Ukiah, CA 95482 | T: 707-468-0401 | F: 707-468-5267 | ELAP# 1551 WaterStone Services for City of lone Project Manager: James Whitaker 14063 Morning Glory Place Project: INF Monthly Grab WWTP Re Chico, CA 95973 Project Number: [none] 12/18/2:

Result Units Reporting Limit Dilution Batch Prepared Analyzed ELAP# Method WWTP Influent Monthly Grab (23L1264-01) Sample Type: Water Sampled: 12/06/23 09:32 Conventional Chemistry Parameters by APHA/EPA Methods
Biochemical Oxygen Demand 290 mg/L 5.0 AL33950 12/07/23 07:05 12/12/23 09:26 2922 SMS210B haha..
email: [email protected]
Corporate: 208 Mason Street | Ukiah, CA 95482 | T: 707-468-0401 | F: 707-468-5267 | ELAP# 1551 WaterStone Services for City of lone Project Manager: James Whitaker 14063 Morning Glory Place Project: INF Monthly Grab WWTP Re Chico, CA 95973 Project Number: [none] 12/18/2.

Notes and Definitions
ND Analyte NOT DETECTED at or above the reporting limit dry Sample results reported on a dry weight basis
RPD Relative Percent Difference
* ELAP does not offer accreditation in this matrix for the requested analyte/method combination.

Corporate Laboratory Bay Area Laboratory
208 Mason Street, Ukiah CA 95482 6398 Dougherty Rd #35, Dublin CA 94568 Chain of Custody - Work Order 707-468-0401 F) 707-468-5267 925-828-6226 F) 925-828-6309 placal Laboratorie ine. smail: [email protected] Contral Valley Laboratory Reports and Invoices delivered by email in PDF format ww.alpha-labs.com ELAP Certifications 9090 Union Park Way #113, Elk Grove CA 95624 TERS, SEDIMENTS, SOLIDS Jkiah 1551 / Dublin 2728 / Elk Grove 2922 916-686-5190 F) 916-686-5192 2361264 Lab No Pg
Report to Project Information Signature below authorizes work under terms stated on reverse side.

Contact: ma cry of i dirent)
Project ID:
one Services, LLC for City of lone Jody Steneck City of lone WWTP Analysis Request TAT Temp upon Emall address: Influent Monthly Grab Receipt °C
one/James Whitaker Standard
[email protected] Project No: 10 days
Ukiah temp:
orning Glory Place
: 95973 PO Number: Standard
Phone/Fax:
6861 / 530-902-4805 5 days Dublin temp:

BEs:

Internal Lab Use: 48 hours
[email protected]/[email protected] 017 Total Number of Containers per Sample ID Container 668 Matrix Other:
nie Dennedy Elk Grove temp:
days
CV - BOD fL 190
Sampling 40ml Vial Na2S203 Wastwater
Poly Glass Sleeve Other HCI HNO3 H2S04 None Other Sample Notes or Date Time Soil
CDPH Source Numbers:

Influent Monthly Grab 12/4630932
Relinquished by Received by Yes No
CDPH Write On EDT Transmission?
ab Fridal 12/6/23|0959 State System Number:

Anda y
12-6.2313:58 if "y" please enter the Source Number(s) in the column above Mail Hardcopy to DDW- ? Yes No
alpha mean e
email: [email protected]
Corporate: 208 Mason Street | Ukiah, CA 95482 | T: 707-468-0401 | F: 707-468-5267 | ELAP# 1551 21 December 2023
WaterStone Services for City of lone
Attn: James Whitaker
14063 Morning Glory Place
Chico, CA 95973
RE: City of lone WWTP
Work Order: 23L0932
Enclosed are the results of analyses for samples received by the laboratory on 12/06/23 22:40. If you have any questions concerning this report, please feel free to contact me.

ANALYTICAL REPORT FOR SAMPLES
Sample ID Laboratory ID Matrix Date Sampled Date Receiv WWTP Eff Monthly Grab Pond 4 23L0932-01 12/06/23 09:15 12/06/23 22:

Water
Upha
pha Analytical Laboratories. In email: [email protected] Corporate: 208 Mason Street | Ukiah, CA 95482 | T: 707-468-0401 | F: 707-468-5267 | ELAP# 1551 WaterStone Services for City of lone Project Manager: James Whitaker 14063 Morning Glory Place Project: City of lone WITP Re Chico, CA 95973 Project Number: EFF Monthly Grab 12/21/2 Result Units Reporting Limit Dilution Batch Prepared Analyzed ELAP# Method WWTP Eff Monthly Grab Pond 4 (23L0932-01) Sample Type: Water Sampled: 12/06/23 09:15 Conventional Chemistry Parameters by APHA/EPA Methods
Biochemical Oxygen Demand 63 mg/L 5.0 1 AL33950 12/07/23 07:05 12/12/23 09:26 2922 SM5210B Specific Conductance (EC) 470 umhos/cm 20 1 AL34061 12/13/23 13:10 12/13/23 13:10 2922 SM2510B Total Dissolved Solids 240 mg/L 10 1 AL34006 12/10/23 12:09 12/12/23 11:58 2922 SM2540C Nitrate + Nitrite as N 3.5 mg/l. 1.0 5 AL33974 12/14/23 09:00 12/15/23 14:00 155| SM4500-N03 E Total Kjeldahl Nitrogen 18 mg/L 1.0 1 AL33641 12/08/23 09:30 12/08/23 15:17 1551 EPA 351.2 Total Nitrogen 22 mg/L 1.0 1 AL33571 12/07/23 12:59 12/19/23 15:14 1551* Calculation Ralpha.
email: [email protected]
Corporate: 208 Mason Street | Ukiah, CA 95482 | T: 707-468-0401 | F: 707-468-5267 | ELAP# 1551 WaterStone Services for City of lone Project Manager: James Whitaker 14063 Morning Glory Place Project: City of lone WWTP Re Chico, CA 95973 Project Number: EFF Monthly Grab 12/2112 Notes and Definitions
QM-01 The spike recovery for this QC sample is outside of established control limits possibly due to a sample matrix interference.

ND Analyte NOT DETECTED at or above the reporting limit dry Sample results reported on a dry weight basis
RPD Relative Percent Difference
* ELAP does not offer accreditation in this matrix for the requested analyte/method combination.

Corporate Laboratory Bay Area Laboratory
208 Mason Street, Ukiah CA 95482 6398 Dougherty Rd #35, Dublin CA 94568 Chain of Custody - Work Order 707-468-0401 F) 707-468-5287 925-828-6226 F) 925-828-6309 Epalacal Laboratories ime. - mail: [email protected] Central Valley Laboratory Reports and Invoices delivered by email in PDF format w.alpha-labs.com ELAP Certifications 9090 Union Park Way #113. Elk Grove CA 95624 IS, SEDIMENTS, SOLIDS Jkiah 1551 / Dublin 2728 / Elk Grave 2922 916-686-5190 F) 916-686-5192 2340932 Lab No Pg
Report to invoice to (it different) Project Information Signature below authorizes work under terms stated on reverse side.

Contact: City of lone Project ID:

City of lone WWTP Analysis Request TAT Temp upon
Services, LLC for City of lone Jody Steneck
Email address: Eft Monthly Grab Standard Receipt °C
/James Whitaker [email protected] Project No: 10 days Ukiah temp:

Address: Monthly
ng Glory Place 1•1
5973 PO Number: Standard
Phone/Fax: 5 days
Dublin temp:
:1 / 530-902-4805 x
Internal Lab Use: 48 hours preapproval required
[email protected]/[email protected] 018 Total Number of Containers per Sample ID Container Preservative Matrix Other: Elk Grove temp:
-days
CV - BOD CV - TDS Total Nitrogen 4500 19-
/Sampling CV - EC Sample Notes or
ple Identification HCI Soil
Date CDPH Source Numbers:
ff Monthly Grab Pond 4 12/6/23 0915
Received by Date Time CDPH Write On EDT Transmission? Yes No Lab Fridas 12/6/23 0959 State System Number:

Pre no 12:6-23 13-55
If "y" please enter the Source Numbers) in the column above 11a/413 |1450 Mail Hardcopy to DDW-? Yes No
Agenda Item #11

CITY OF IONE COUNCIL MEETING MINUTES
Meeting of January 16, 2024
Mayor Rhoades called meeting to order at 6:00 PM
A. ROLL CALL:

Present: Alison LaFayne, Mayor
Dominic Atlan, Councilmember
Jack Mitchell, Councilmember
Stacy Rhoades, Councilmember

Absent: Diane Wratten, Vice Mayor
Staff: Amy Gedney, Interim City Manager
Andy Pinasco, City Attorney
Janice Traverso, City Clerk
C. MAYOR LAFAYNE LED THE PLEDGE OF ALLEGIANCE
D. CLOSED SESSION: Council convened to Closed Session to discuss the following:

CONFERENCE WITH LEGAL COUNSEL-EXISTING LITIGATION:

Paragraph (1) of subdivision (d) of Section 54956.9)
Name of case: [Amador Court Case Number 22-CV-12824 - Amador Regional Sanitation Authority (ARSA) v City of lone and California Department of Corrections and Rehabilitation (CDCR)
E. REPORT OUT OF CLOSED SESSION: Mayor LaFayne reported that direction was given to staff on the following:

CONFERENCE WITH LEGAL COUNSEL-EXISTING LITIGATION:

It was moved by Councilmember Atlan, seconded by Councilmember Mitchell and carried to approve the agenda.

AYES: LaFayne, Atlan, Mitchell, Rhoades
NOES: None
ABSTAIN: None
ABSENT: Wratten
G. PUBLIC COMMENT:

Dave Anderson:

Asked for the extent of the problems at Wildflower Subdivision • Asked for an estimated time of completion of pending Public Records Requests
Dave Livingstone asked Council if senior citizens of lone are eligible for a discount on their garbage service from ACES Waste Management.

Greg Morris commented on a recent letter to the Editor in the Ledger Dispatch thanking the community for their help with caring for her father the last eight years.

This is an example of a great community we live in.

Oral Custer commented that on January 27, 2024 at King's View Church there will be a Demo Election for Fair and Transparent Elections.

G. INFORMATION ITEMS: Information item and no action taken.

1. December 2023 Fire Department Report

2. December 2023 Police Department Report

3. December 2023 Administrative Report

4. December 2023 Public Works Report

5. December 2023 Building Department Report

6. November 2023 WWTP Monthly Report

7. December 2023 Engineering Report
H. CONSENT CALENDAR:

It was moved by Councilmember Atlan, seconded by Councilmember Mitchell and carried to approve the following:

1. Minutes of December 5, 2023

2. Warrants of January 16, 2024

3. Councilmembers Committee Assignments
AYES: LaFayne, Atlan, Mitchell, Rhoades
NOES: None
ABSTAIN: None
ABSENT: Wratten
I. PUBLIC HEARING: None
DISCUSSION ITEMS:

For the record: Action minutes provide the necessary documentation of City Council action. Audio and visual recordings are available on the City's website at www.ione- ca.com for those desiring to hear the full discussions on each item. These recordings provide an accurate and comprehensive backup of City Council deliberations and citizen J. REGULAR AGENDA:

Mayor LaFayne recused herself from the dais for Item #1 - Cattle Charge at Ed Hughes Memorial Arena. Councilmember Atlan chaired the item.

1. Cattle Charge at Ed Hughes Memorial Arena - Stock dog trials are competitive events that showcase a herding dog's ability to work livestock, often cattle or sheep. The dog breeds used are often Border Collies or Australian Cattle Dogs and the trial demonstrates not only the dog's ability in ranching or farming operations, but the partnership between the handler and the dog. Amador County Stock Dog Trial Group (ACSD) is a group composed of local individuals. Event producers do not make any income. The group encourages out of town participants to visit downtown and support surrounding local businesses. It was moved by Councilmember Mitchell, seconded by Councilmember Rhoades and carried to adopt Resolution No. 2024-01 approving the recommendation from the Parks and Recreation Commission to waive the $250 cattle charge at Ed Hughes Memorial Arena for Amador County Stock Dog Trials.

AYES: Atlan, Mitchell, Rhoades
NOES: None
ABSTAIN: None
ABSENT: Wratten
RECUSED: LaFayne
Mayor LaFayne returned to the dais at this time.

2. Annual Regional Transportation Mitigation Fee Report - The purpose of this report is to documents Regional Traffic Mitigation Fee (RTMF) program history, describe project obligation, identify approved expenditures, account for new revenues, and describe new program modifications. It was moved by Councilmember Atlan, seconded by Councilmember Rhoades and carried to adopt Resolution No. 2024-02 approving the Fiscal Year 2022/2023 Amador County Regional Traffic Mitigation Fee Program Annual Report.

AYES: LaFayne, Atlan, Mitchell, Rhoades
NOES: None
ABSTAIN: None
ABSENT: Wratten

3. Road Capital Improvement Plan and Sanitary Sewer Master Plan - City Engineer, Jonathan Mitchell:
• Both the Sanitary Sewer Master Plan and a Capital Improvement Program are in draft development stages
• The two programs have projects identified on the same street segments • Sub-grade sewer repairs will impact roadway work requiring roadwa habilitation take place following sewer repairs
• This allows roadway rehabilitation funds to be shred in support of completion of sewer related roadway repairs

4. Mid-Year Budget Review - Jodi Steneck, Finance Manager reviewed the mid-year budget.

K. REPORT AND COMMUNICATION FROM CITY ATTORNEY: None
L. REPORT AND COMMUNICATION FROM CITY MANAGER:
• AWA passed a resolution that requires all building permits from lone will need to be approved by the AWA Board because of the moratorium on water. • Wastewater Meeting January 30, 3024.

M. COUNCIL COMMENTS/COMMITTEE REPORTS/FUTURE AGENDA:

Councilmember Atlan:
• Asked for an accounting of the funds sent to Amador Water Agency • Asked for an accounting of the funds sent the Amador County Unified School District
• Status of money given to Amador County Unified School District for the road into the Elementary School.

Councilmember Rhoades:
• Update on Wildflower Subdivision
N. ADJOURNMENT:

Mayor LaFayne adjourned the meeting at 7:22 p.m.

Respectfully submitted,
Janice Traverso
City Clerk

HALY OF TONT

CITY OF IONE
IONE, CA 95640
Agenda Item #12
DATE: FEBRUARY 20, 2024
TO: THE HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL FROM: JODI STENECK, FINANCE MANAGER
SUBJECT: FEBRUARY 20, 2024 WARRANTS
RECOMMENDED ACTION:

Staff recommends that the council review and approve the attached warrant list.

FISCAL IMPACT:
$234,331.50
ATTACHMENTS:

A. Warrant list dated 2-20-2024
City of lone Unpaid Invoice Report - UNPAID INV. REPORT Page: 1 Posting period: 02124 Feb 16, 2024 10:14AM
Invoice Seq.# Description Invoice GL Peri GL Account Activity# GL Account Description Net Invoice Number Date Number Check Amount
ACES
737351 2YD 1X WEEK FEB CHARGES 02/01/24 02/24 4311-92-6170 UTILITIES 321.00 Total 737351: 321.00

AMADOR COUNTY ENVIRONMENTAL HEALTH
IN0031992 3611 PUBLIC POOL 02/06/24 02/24 1111-92-6191 MAINT / OPERATIONS OF POOL0241 180.00 Total IN0031992: 180.00

AMADOR COUNTY SHERIFF'S DEPT
42027110 SECOND QUARTER 23/24 DISPATCH SERVICES 01/17/24 02/24 1111-70-6220 OTHER CONTRACTUAL SERVICES 50,208.60 42027110 SECOND QUARTER 23/24 DISPATCH SERVICES 01/17124 02/24 9670-70-6220 OTHER CONTRACTUAL SERVICES 41,079.76 Total 42027110: 91,288.36
42028110 DECEMBER 2023 RIMS ANNUAL SUPPORT SERVICES 01/18/24 02/24 1111-70-6220 OTHER CONTRACTUAL SERVICES 377.77 42028110 DECEMBER 2023 RiMS ANNUAL SUPPORT SERVICES 01/18/24 02/24 9670-70-6220 OTHER CONTRACTUAL SERVICES 309.08 Total 42028110: 686.85

AMADOR WATER AGENCY
005018-020X01202 HYDRANT METER 01/29/24 3111-92-6170 UTILITIES 151.50 Total 005018-020X012024: 151.50
005018-021X01202 HYDRANT METER 01/29/24 3111-92-6170 UTILITIES 151.50 Total 005018-021X012024: 151.50

ARCO BUSINESS SOLUTIONS
42022020 PD FUEL 02/02124 1111-70-6201 FUEL 877.53
42022020 PD FUEL 02/02124 02124 9670-70-6201 FUEL 717.98 42022020 SIP PHONE SYSTEM 02/02/24 02124 1111-65-6160 COMMUNICATIONS 397.90 42022020 SIP PHONE SYSTEM 02/02/24 2111-65-6160 COMMUNICATIONS 66.32 42022020 SIP PHONE SYSTEM 02/02/24 3111-65-6160 COMMUNICATIONS 132.63 42022020 SIP PHONE SYSTEM 02/02/24 02124 9670-65-6160 COMMUNICATIONS 33.16 42022020 SIP PHONE SYSTEM 02/02/24 02124 9675-65-6160 COMMUNICATiONS 33.16 42022020 ADOBE/ADMIN 02/02124 02/24 1111-65-6111 OFFICE EXPENSE 82.48 City of lone Unpaid Invoice Report - UNPAID INV. REPORT Page: 2 Posting period: 02/24 Feb 16, 2024 10:14AM
Invoice Seq.# Description Invoice GL Peri GL Account Activity # GL Account Description Net Invoice Number Date Number Check Amount
42022020 ADOBE/ADMIN 02/02/24 02/24 2111-65-6111 OFFICE EXPENSE - ADMIN GAS TAX 13.75 42022020 10 ADOBE/ADMIN 02/02/24 02124 3111-65-6111 OFFICE EXPENSE 27.49 42022020 ADOBEIADMIN 02/02/24 02124 9670-65-6111 OFFICE EXPENSE 6.87 42022020 ADOBE/ADMIN 02/02/24 02/24 9675-65-6111 OFFICE EXPENSE 6.87 42022020 CITY CLERK 02/02/24 02124 1111-62-6111 OFFICE EXPENSE 57.10 42022020 PROMOTIONS/HATS 02/02/24 02124 1111-65-6115 CLOTHING 1,414.67 42022020 SEWER BILLING 02/02/24 02/24 3111-65-6111 OFFICE EXPENSE 67.78 42022020 16 PW FACILITIES/MAINTENANCE 02/02124 02124 1111-92-6190 MAINT OF BLDGS, STRUCT, GROUND 596.36 42022020 PW - STREETS SPECIAL DEPT 02/02/24 02/24 2111-92-6120 SPECIAL DEPT 653.87 42022020 18 WWTP - OTHER 02/02/24 02124 3111-92-8813 CAPITAL OTHER 905.84 42022020 19 FD - SPECIAL DEPT 02/02/24 02/24 1111-75-6120 SPECIAL DEPARTMENTAL EXPENSE 409.54 42022020 20 FD - SPECIAL DEPT 02/02/24 02/24 9675-75-6120 SPECIAL DEPT 136.51 42022020 FD - SPECIAL DEPT 02/02/24 02124 9613-75-6120 SPEC DEPT - MEASURE M 136.51 42022020 FD - TRAINING 02102/24 02124 1111-75-6122 TRAINING & TRAVEL 223.97 42022020 FD - TRAINING 02/02/24 02124 9675-75-6122 TRAINING 74.66 42022020 FD - TRAINING 02/02/24 02/24 9613-75-6122 TRAINING - MEASUREM 74.66 42022020 FD - MAINT & REPAIR 02/02/24 02124 1111-75-6190 MAINT OF BLDGS, STRUCT, GROUND 1,121.23 42022020 FD - MAINT & REPAIR 02/02/24 02124 9675-75-6190 MAINT OF BLDGS 373.74 42022020 FD - MAINT & REPAIR 02/02/24 02124 9613-75-6190 MAINT OF BLDGS - MEAS M 373.74 42022020 FD - VEHICLE 02/02/24 02124 1111-75-6202 VEHICLE MAINT 56.68 42022020 FD - VEHICLE 02/02/24 02/24 9675-75-6202 VEHICLE MAINT. 18.89 42022020 FD - VEHICLE 02/02/24 02/24 9613-75-6202 VEHICLE MAINT - MEAS M 18.89 42022020 PD - MEMBERSHIP/DUES 02/02/24 1111-70-6240 MEMBERSHIPS AND DUES 104.50 42022020 PD - MEMBERSHIP DUES 02/02124 02/24 9670-70-6240 MEMBERSHIP 85.50 42022020 33 PD - VEHICLE 02/02/24 02124 1111-70-6202 VEHICLE MAINT 43.84 42022020 PD - VEHICLE 02/02/24 02/24 9670-70-6202 VEHICLE MAINT 35.84 Total 42022020: 9,380.46

BUCKMASTER OFFICE SOLUTIONS
466274 FOLDING MACHINE PAPER JAM REPAIR 01/31/24 02/24 1111-65-6203 M&O EQUIP 171.00 466274 FOLDING MACHINE PAPER JAM REPAIR 01/31/24 02124 3111-65-6203 MAO EQUIP - WWTP ADMIN 57.00 466274 FOLDING MACHINE PAPER JAM REPAIR 01/31/24 02124 9670-65-6203 M&O EQUIP 14.25 466274 FOLDING MACHINE PAPER JAM REPAIR 01/31/24 02124 9675-65-6203 M&O EQUIP 14.25 466274 FOLDING MACHINE PAPER JAM REPAIR 01/31/24 02/24 2111-65-6203 MAINT & OPERATIONS - EQUIPMENT 28.50 Total 466274: 285.00

CAMPBELL CONSTRUCTION GENERAL
1026 LABOR PER MAN HR. 02/06/24 02/24 3111-92-6203 REPAIR & MAINT 2,980.00

PARTS/MATERIAL/GLUE/PRIMER/TAPE/DOPE
City of lone Unpaid Invoice Report - UNPAID INV. REPORT Page: 3 Posting period: 02/24 Feb 16, 2024 10:14AM
Seq.# Description Invoice GL Peri GL Account Activity # GL. Account Description Net invoice Number Date Number Check Amount
Total 1026: 2,980.00
CARBON COPY INC.
626322 ADMIN 01/24/24 02/24 1111-65-6111 OFFICE EXPENSE 80.33 626322 ADMIN 01/24/24 02/24 2111-65-6111 OFFICE EXPENSE - ADMIN GAS TAX 13.39 626322 ADMIN 01/24/24 3111-65-6111 OFFICE EXPENSE 26.79 626322 ADMIN 01/24/24 02124 9670-65-6111 OFFICE EXPENSE 6.69 626322 ADMIN 01/24/24 02/24 9675-65-6111 OFFICE EXPENSE 6.69 Total 626322: 133.89
626323 PD COPIER 01/24/24 02/24 1111-70-6111 OFFICE 12.53 626323 PD COPIER 01/24/24 9670-70-6111 OFFICE 10.25
Total 626323: 22.78
CASELLE INC.
130953 ADMIN 02/01/24 02124 1111-65-6166 SOFTWARE 1,110.60 130953 ADMIN 02/01/24 02/24 2111-65-6166 SOFTWARE - GAS TX ADMIN 185.10 130953 ADMIN 02/01/24 02/24 3111-65-6166 SOFTWARE - WWTP ADMIN 370.20 130953 ADMIN 02/01/24 02/24 9670-65-6166 SOFTWARE 92.55 130953 ADMIN 02/01/24 02/24 9675-65-6166 SOFTWARE 92.55 Total 130953: 1,851.00
CODE 3 WEAR
1-201 NEW OFFICER UNIFORM 02/08/24 02124 1111-70-6140 CLOTHING / UNIFORM-NON-PAYROLL 481.71 1-201 NEW OFFICER UNIFORM 02/08/24 02/24 9670-70-6140 CLOTHING 394.12 Total 1-201: 875.83
CUB SCOUT PACK 477
240602 EB HALL DEPOSIT REFUND 1/26/24 EVENT 02/06/24 02124 1111-00-1119 DEPOSIT CLEARING ACCOUNT 700.00 Total 240602: 700.00
DAVID TAUSSIG & ASSOC. INC
2312375 ADMIN OF CFD #2009-3 FOR FISCAL YEAR 2023-2024 12/31/23 02/24 9111-50-6125 ADMINISTRATION COSTS 92.50 City of lone Unpaid Invoice Report - UNPAID INV. REPORT Page: 4 Posting period: 02/24 Feb 16, 2024 10:14AM
Invoice Seq.# Description Invoice GL Peri GL Account Activity# GL Account Description Net Invoice Number Date Number Check Amount
Total 2312375: 92.50
2312376 ADMIN OF CFD #2006-1 FOR FISCAL YEAR 2023-2024 12/31/23 02/24 9111-50-6125 ADMINISTRATION COSTS 47.50 Total 2312376: 47.50
2312377 ADMIN APPROVEMENT AREA #2 OF CFD #2005-2 12/31/23 02/24 9111-50-6125 ADMINISTRATION COSTS 190.00 FOR FISCAL YEAR 2023-2024
Total 2312377: 190.00
2312378 PREPARED PREPAYMENT MODEL 12/31/23 02/24 9111-50-6125 ADMINISTRATION COSTS 285.00 Total 2312378: 285.00
2312387 PROFESSIONAL SERVICES THROUGH DEC 2023 12/31/23 02/24 9111-50-6125 ADMINISTRATION COSTS 1,805.00 Total 2312387: 1,805.00
2312388 PROFESSIONAL SERVICES DECEMBER 2023 12/31/23 02/24 9111-50-6125 ADMINISTRATION COSTS 1,042.50 Total 2312388: 1,042.50
2312389 PROFESSIONAL SERVICES 12/31/23 02/24 9111-50-6125 ADMINISTRATION COSTS 377.50 Total 2312389: 377.50

ENVIRONMENTAL EXPRESS
1000771763 ENVIRONMENT EXPRESS MODEL 200 COD 01/30/24 02/24 3111-92-8813 CAPITAL OTHER 799.66

COLORIMETER
Total 1000771763: 799.66
FERGUSON ENT INC. #686
4863131 EB HALL REPAIR 01/31/24 02124 1111-92-6190 MAINT OF BLDGS, STRUCT, GROUND 134.68 Total 4863131: 134.68

GRIFF'S ELECTRIC
499 HOOKED UP AERATOR PUMP/REPLACED GFI

OUTLET IN OUT BUILDING/REPLACED FUSE ON
City of lone Unpaid Invoice Report - UNPAID INV. REPORT Page: 5 Posting period: 02/24 Feb 16, 2024 10:14AM
Invoice Seq.# Description Invoice GL Peri GL Account Activity# GL Account Description Net invoice Number Date Number Check Amount
AERATOR PUMP 10/23/23 02/24 3111-92-6203 REPAIR & MAINT 375.00 Total 499: 375.00
504 STOPPED BY SEWER PLANT TO GET AERATOR 11/28/23 02/24 3111-92-6203 REPAIR & MAINT 150.00

MOTOR GOING, WENT OVER TO EDGE BROOK

PUMPING STATION TO LOOK AT CONTROL MODULE

LOSING POWER
Total 504: 150.00
509 RAN CIRCUIT FROM ELECTRICAL PANEL TO POWER 01/09/24 02/24 3111-92-6203 REPAIR & MAINT 300.00

UP LOGIC CONTROLLER IN PUMP BOX
Total 509: 300.00
513 REPLACED FUSE ON CONTROL PANEL FOR 02/05/24 02/24 3111-92-6203 REPAIR & MAINT 150.00

AERATOR MOTO
Total 513: 150.00

IONE ACE HARDWARE
42025210 POLICE PURCHASING 01/25/24 02/24 1111-70-6202 VEHICLE MAINT 30.55 42025210 POLICE PURCHASING 01/25/24 02/24 9670-70-6202 VEHICLE MAINT 24.99 42025210 FIRE PURCHASING 01/25/24 02124 1111-75-6190 MAINT OF BLDGS, STRUCT, GROUND 76.55 42025210 FIRE PURCHASING 01/25124 02124 9675-75-6190 MAINT OF BLDGS 25.52 42025210 FIRE PURCHASING 01/25/24 02/24 9613-75-6190 MAINT OF BLDGS - MEAS M 25.52 42025210 PW VEHICLES 01/25124 02124 1111-92-6202 VEHICLE MAINT 37.20 42025210 WWTP - MAINTENANCE & REPAIRS 01/25/24 02124 3111-92-8813 CAPITAL OTHER 838.20 42025210 STREETS 01/25/24 02/24 2111-92-6190 MAINT OF BLDGS, STRUCT, GROUND 81.87 42025210 PARKS 01/25124 02124 1111-92-6190 MAINT OF BLDGS, STRUCT, GROUND 749.92 42025210 10 PW BUILDING AND GROUNDS 01/25/24 02124 1111-92-6190 MAINT OF BLDGS, STRUCT, GROUND 99.30 Total 42025210: 1,989.62

IONE ROTARY CLUB
240602 EB HALL DEPOSIT REFUND 02/03/24 EVENT 02/06/24 02/24 1111-00-1119 DEPOSIT CLEARING ACCOUNT 700.00 Total 240602: 700.00

IW SOLAR LLC
24302 SOLAR PRODUCED AT WATER TREATMENT FACILITY 02/29/24 02/24 3131-50-6170 UTILITIES 3,866.99 City of lone Unpaid Involce Report - UNPAID INV. REPORT Page: 6 Posting period: 02/24 Feb 16, 2024 10:14AM
Invoice Seq.# Description Invoice GL Peri GL Account Activity# GL Account Description Net Invoice Number Date Number Check Amount
Total 24302: 3,866.99
JAMES W MARSHALL CHAPTER 4A ECV
240602 EB HALL DEPOSIT REFUND 1/20/24 RENTAL 02/06/24 02/24 1111-00-1119 DEPOSIT CLEARING ACCOUNT 700.00 Total 240602: 700.00
JOHN M. MEYER, PH.D.
42021310 PRE EMPLOYMENT PSYCHOLOGICAL SCREENING 01/31/24 02124 1111-70-6120 SPECIAL DEPARTMENTAL 220.00 42021310 PRE EMPLOYMENT PSYCHOLOGICAL SCREENING 01/31/24 02/24 9670-70-6120 SPECIAL DEPARTMENTAL 180.00 Total 42021310: 400.00

LEAGUE OF CALIFORNIA CITIES
INV-11847-KOZ1F7 MEMBERSHIP DUES 01/10/24 02/24 1111-65-6240 MEMBERSHIPS AND DUES 3,351.00 INV-11847-KOZ1F7 MEMBERSHIP DUES 01/10/24 02/24 2111-65-6240 MEMBERSHIP & DUES -GAS ADMIN 558.50 INV-11847-KOZ1F7 MEMBERSHIP DUES 01/10/24 02124 3111-65-6240 MEMBERSHIP - WWTP ADMIN 1,117.00 INV-11847-KOZ1F7 MEMBERSHIP DUES 01/10124 02/24 9670-65-6240 MEMBERSHIP 279.25 INV-11847-KOZ1F7 MEMBERSHIP DUES 01/10/24 02/24 9675-65-6240 MEMBERSHIP 279.25 Total INV-11847-KOZ1F7: 5,585.00
MISSION IT SOLUTIONS INC.
2029 ADMIN 02/01/24 02124 1111-65-6167 IT SERVICES 49.13 2029 ADMIN 02/01/24 02/24 2111-65-6167 IT SERVICES - GAS TX ADMIN 8.19 2029 ADMIN 02/01/24 02124 3111-65-6163 IT SERVICES - ADMIN WWTP 16.38 2029 ADMIN 02/01/24 02124 9670-65-6167 IT SERVICES 4.09 2029 ADMIN 02/01/24 02/24 9675-65-6167 IT SERVICES 4.09 2029 POLICE 02/01/24 02/24 1111-70-6167 IT HARDWARE 45.03 2029 POLICE 02/01/24 02124 9670-70-6166 SOFTWARE 36.84
2029 FIRE 02/01/24 02124 1111-75-6167 IT HARDWARE 49.13 2029 FIRE 02/01/24 02/24 9675-75-6166 SOFTWARE 16.38
2029 FIRE 02/01/24 02/24 9613-75-6163 IT SERVICES 16.38 2029 BUILDING 02/01/24 02124 1111-85-6166 SOFTWARE PROGRAMS 32.75 2029 PUBLIC WORKS 02/01/24 02124 1111-92-6166 SOFTWARE PROGRAMS 16.70 PUBLIC WORKS 02/01/24 02124 2111-92-6166 SOFTWARE 16.21 2029 14 PUBLIC WORKS 02/01/24 02124 3111-92-6166 SOFTWARE - PW WWTP 16.20 City of lone Unpaid Invoice Report - UNPAID INV. REPORT Page: 7 Posting period: 02/24 Feb 16, 2024 10:14AM
Invoice Seq.# Description Invoice GL Peri GL Account Activity # GL Account Description Net Invoice Number Date Number Check Amount
Total 2029: 327.50

PARCELQUEST
9012-2-2024 ADMIN 02/06/24 02/24 1111-65-6166 SOFTWARE 359.85 9012-2-2024 ADMIN 02/06124 02124 2111-65-6166 SOFTWARE - GAS TX ADMIN 59.98 9012-2-2024 ADMIN 02/06/24 02/24 3111-65-6166 SOFTWARE - WWTP ADMIN 119.95 9012-2-2024 ADMIN 02/06/24 02124 9670-85-6166 SOFTWARE 29.99 9012-2-2024 ADMIN 02/06/24 02/24 9675-65-6166 SOFTWARE 29.99 9012-2-2024 POLICE 02/06/24 02124 1111-70-6166 SOFTWARE PROGRAMS 329.86 9012-2-2024 POLICE 02/06/24 02/24 9670-70-6166 SOFTWARE 269.89 9012-2-2024 FIRE 02/06/24 02/24 1111-75-6166 SOFTWARE PROGRAMS 359.85 9012-2-2024 FIRE 02/06/24 02/24 9675-75-6166 SOFTWARE 119.95 9012-2-2024 FIRE 02/06/24 02124 9613-75-6166 SOFTWARE - MEASURE M 119.95 9012-2-2024 BUILDING 02/06/24 02124 1111-85-6166 SOFTWARE PROGRAMS 239.90 9012-2-2024 PUBLIC WORKS 02/06/24 02/24 1111-92-6166 SOFTWARE PROGRAMS 122.34 9012-2-2024 PUBLIC WORKS 02/06/24 02124 2111-92-6166 SOFTWARE 118.75 9012-2-2024 PUBLIC WORKS 02/06/24 02124 3111-92-6166 SOFTWARE - PW WWTP 118.75 Total 9012-2-2024: 2,399.00

PECKHAM & MCKENNEY
240702 CITY MANAGER DIRECTOR SEARCH 02/07124 02/24 1111-65-6215 PROF & SPEC SERV. - OTHER 9,166.66 Total 240702: 9,166.66

PLYMOUTH ACE HARDWARE
42021310 FIRE PURCHASING 01/31/24 02124 1111-75-6202 VEHICLE MAINT 22.96 42021310 FIRE PURCHASING 01/31/24 02/24 9675-75-6202 VEHICLE MAINT. 7.65 42021310 FIRE PURCHASING 01/31/24 02/24 9613-75-6202 VEHICLE MAINT - MEAS M 7.65 Total 42021310: 38.26

PROCLEAN SUPPLY
590774 PAPER TOWELS, BATH TISSUE, FUEL SURCHARGE 02/09/24 02/24 1111-92-6190 MAINT OF BLDGS, STRUCT, GROUND 279.72 Total 590774 279.72

RADAR SHOP, THE
15342 RECERTIFIED RADAR UNITS 01/31/24 02/24 1111-70-6202 VEHICLE MAINT 688.60 City of lone Unpaid Invoice Report - UNPAID INV. REPORT Page: 8 Posting period: 02/24 Feb 16, 2024 10:14AM
Invoice Seq.# Description Invoice GL Peri GL Account Activity # GL Account Description Net Invoice Date Number Check Amount
15342 RECERTIFIED RADAR UNITS 01/31/24 02/24 9670-70-6202 • 0 VEHICLE MAINT 563.40 Total 15342: 1,252.00

SHRED CITY
23973013124 SHRED SERVICE 01/31/24 02/24 1111-65-6111 OFFICE EXPENSE • 120.00 23973013124 SHRED SERVICE 01/31/24 02/24 2111-65-6111 OFFICE EXPENSE - ADMIN GAS TAX 20.00 23973013124 SHRED SERVICE 01/31/24 02/24 3111-65-6111 OFFICE EXPENSE 40.00 23973013124 SHRED SERVICE 01/31/24 02/24 9670-65-6111 OFFICE EXPENSE 10.00 23973013124 SHRED SERVICE 01/31/24 02/24 9675-65-6111 OFFICE EXPENSE 10.00 Total 23973013124: 200.00
ST. KATHARINE DREXEL
240602 1400 W MARLETTE #44 HAD $1.63 BALANCE, SENT 02/06/24 02/24 3111-48-4805 SEWER SERVICE CHARGES 36.63 CHECK FOR S38.26 TO INCLUDE FEBRUARY $36.63
PAYMENT AND REMAINING BALANCE. CHECKS TO

GO TO PROPERTY MANAGER, COULD NOT
CONTACT HOMEOWNER AFTER MULTIPLE TRIES.

Total 240602: 36.63

STAPLES BUSINESS CREDIT
42025210 ADMIN 01/25/24 02/24 1111-65-6111 OFFICE EXPENSE 127.52 42025210 ADMIN 02/24 2111-65-6111 OFFICE EXPENSE - ADMIN GAS TAX 21.25 42025210 ADMIN 01/25/24 02/24 3111-65-6111 OFFICE EXPENSE 42.51 42025210 ADMIN 01/25/24 02/24 9670-65-6111 OFFICE EXPENSE 10.63 42025210 ADMIN 01/25/24 02/24 9675-65-6111 OFFICE EXPENSE 10.63 Total 42025210: 212.54

TELSTAR INSTRUMENTS
120174 LEVEL INSTRUMENTATION AND CONTROLS/RADAR 02/07/24 02/24 3111-92-6203 REPAIR & MAINT 17,760.00

LEVEL/FLOAT SWITCH
Total 120174: 17,760.00
120177 02/07/24 02/24 3111-92-6203 REPAIR & MAINT 11,025.00 (PARTS OMAN, SPIL PALLET-UP CHEMICALS
Total 120177: 11,025.00
City of lone Unpaid Invoice Report - UNPAID INV. REPORT Page: 9 Posting period: 02/24 Feb 16, 2024 10:14AM
Invoice Seq.# Description Invoice GL Peri GL Account Activity # GL Account Description Net Invoice Number Date Check Amount

TOMMY'S GARAGE
20045 LUBE OIL AND FILTER CHANGE 01/31/24 02124 1111-70-6202 VEHICLE MAINT 104.63 20045 LUBE OIL AND FILTER CHANGE 01/31/24 02/24 9670-70-6202 VEHICLE MAINT 85.61 Total 20045: 190.24

UNDERGROUND SERVICE ALERT
1180152024 BILLABLE TICKETS 01/30/24 02124 1111-92-6215 PROF & SPEC SERV. - OTHER 155.45 1180152024 BILLABLE TICKETS 01/30/24 02/24 2111-92-6215 PROF & SPEC SERV. - OTHER 116.59 1180152024 BILLABLE TICKETS 01/30/24 02/24 3111-92-6215 PROF SERVICES 116.58 Total 1180152024: 388.62

VECTOR SOLUTIONS
INV89564 MEMBERSHIP FOR TRAINING 02/01/24 1111-65-6122 TRAINING 912.00 INV89564 MEMBERSHIP FOR TRAINING 02/01/24 02124 2111-65-6122 TRAINING - ADMIN GAS 152.00 INV89564 MEMBERSHIP FOR TRAINING 02/01/24 02124 3111-65-6122 TRAINING - ADMIN WWTP 304.00 INV89564 MEMBERSHIP FOR TRAINING 02/01124 9670-65-6122 TRAINING 76.00 INV89564 MEMBERSHIP FOR TRAINING 02/01/24 02/24 9675-65-6122 TRAINING 76.00 Total INV89564: 1,520.00

VOLCANO TELEPHONE COMPANY
100054X20124 CITY HALL ADMIN 01/30/24 1111-65-6160 COMMUNICATIONS 37.77 100054X20124 CITY HALL ADMIN 01/30124 2111-65-6160 COMMUNICATIONS 6.30 100054X20124 CITY HALL ADMIN 01/30/24 3111-65-6160 COMMUNICATIONS 12.59 100054X20124 CITY HALL ADMIN 01/30/24 9670-65-6160 COMMUNICATIONS 3.15 100054X20124 CITY HALL ADMIN 01/30/24 9675-65-6160 COMMUNICATIONS 3.15 100054X20124 POLICE DEPT 01/30124 1111-70-6160 COMMUNICATIONS 34.63 100054X20124 POLICE DEPT 01/30/24 02124 9670-70-6160 COMMUNICATIONS 28.32 100054X20124 BUILDING DEPT 01/30/24 1111-85-6160 COMMUNICATIONS 13.99 Total 100054X20124: 139.90
42021020 VOLCANO VISIONVIEW/INTERNET 02/01/24 02/24 1111-75-6160 COMMUNICATIONS 141.25 42021020 VOLCANO VISIONVIEW/INTERNET 02/01/24 02/24 9675-75-6160 COMMUNICATIONS 47.08 42021020 VOLCANO VISION/VIEW/INTERNET 02/01/24 9613-75-6160 COMMUNICATIONS 47.08 Total 42021020: 235.41
City of lone Unpald Invoice Report - UNPAID INV. REPORT Page: 10 Posting period: 02/24 Feb 16, 2024 10:14AM
Invoice Seq.# Description Invoice GL Peri GL Account Activity# GL Account Description Net Invoice Number Date Number Check Amount
42022020 VOLCANO VISION 02/02/24 02/24 1111-75-6160 COMMUNICATIONS 44.94 42022020 VOLCANO VISION 02/02/24 02124 9675-75-6160 COMMUNICATIONS 14.98 42022020 VOLCANO VISION 02/02/24 02/24 9613-75-6160 COMMUNICATIONS 14.98 Total 42022020: 74.90

WATERSTONE SERVICES, LLC
1008 FEBRUARY 2024 OPERATIONS 02/01/24 02124 3111-92-6215 PROF SERVICES 28,050.00 1008 FEBRUARY 2024 OPERATIONS 02/01/24 02/24 3131-92-6215 PROF SERVICES - TERTIARY PW 18,700.00 Total 1008: 46,750.00

WEST YOST ASSOCIATES
2056919 COORDINATION WITH CITY. BEGAN DEVELOPING 12/31/23 02/24 3111-92-6215 PROF SERVICES 1,336.00 WATER BALANCE EVALUATION FOR 1/30
STAKEHOLDER MEETING.

Total 2056919: 1,336.00
2056920 ENG/SCIENTIST/GEOLOGIST MANAGER 1&2 12/31/23 02/24 3131-92-6215 PROF SERVICES - TERTIARY PW 1,465.50 Total 2056920: 1,465.50
2056949 PROFESSIONAL SERVICES DECEMBER 2023 TO 12/31/23 02/24 3131-92-6215 PROF SERVICES - TERTIARY PW 11,534.50 JANUARY 2024
Total 2056949: 11,534.50
Total: 234,331.50
Grand Totals: 234,331.50
Summary by General Ledger Account Number
GL Account Number Debit Credit
1111-00-1119 2,100.00 2,100.00
1111-62-6111 57.10 100 57.10
1111-65-6111 410.33 410.33
City of lone Unpaid Invoice Report - UNPAID INV. REPORT Page: 11 Posting period: 02/24 Feb 16. 2024 10:14AM
Summary by General Ledger Account Number
GL Account Number Debit Credit
1111-65-6115 1,414.67 .00 1,414.67
1111-65-6122 912.00 912.00
1111-65-6160 435.67 00 435.67
1111-65-6166 1,470.45 1,470.45
1111-65-6167 49.13 49.13
1111-65-6203 171.00 171.00
1111-65-6215 9,166.66 .00 9,166.66
1111-65-6240 3,351.00 3,351.00
1111-70-6111 12.53 .00 12.53
1111-70-6120 220.00 220.00
1111-70-6140 481.71 481.71
1111-70-6160 34.63 34.63
1111-70-6166 329.86 329.86
1111-70-6167 45.03 45.03
1111-70-6201 877.53 877.53
1111-70-6202 867.62 867.62
1111-70-6220 50,586.37 50,586.37
1111-70-6240 104,50 104.50
1111-75-6120 409.54 409.54
1111-75-6122 223.97 223.97
1111-75-6160 186.19 186.19
1111-75-6166 359.85 359.85
1111-75-6167 49.13 49.13
1111-75-6190 1,197.78 1,197.78
1111-75-6202 79.64 79.64
1111-85-6160 13.99 13.99
1111-85-6166 272.65 272.65
1111-92-6166 139.04 139.04
1111-92-6190 1,859.98 1,859.98
1111-92-6191 180.00 180.00
1111-92-6202 37.20 37.20
1111-92-6215 155.45 155.45
2111-65-6111 68.39 68.39
2111-65-6122 152.00 152.00
2111-65-6160 72.62 72.62
2111-65-6166 245.08 245.08
2111-65-6167 8.19 8.19
2111-65-6203 28.50 28.50
City of lone Unpaid Invoice Report - UNPAID INV. REPORT Page:

Posting period: 02/24 Feb 16,2024 10:14AM
Summary by General Ledger Account Number
GL Account Number Debit Credit Net
2111-65-6240 558.50 .00 558.50
2111-92-6120 653.87 .00 653.87
2111-92-6166 134.96 .00 134.96
2111-92-6190 81.87 .00 81.87
2111-92-6215 116.59 .00 116.59
3111-48-4805 36.63 .00 36.63
3111-65-6111 204.57 .00 204.57
3111-65-6122 304.00 .00 304.00
3111-65-6160 145.22 .00 145.22
3111-65-6163 16.38 .00 16.38
3111-65-6166 490.15 .00 490.15
3111-65-6203 57.00 .00 57.00
3111-65-6240 1,117.00 .00 1,117.00
3111-92-6166 134.95 .00 134.95
3111-92-6170 303.00 .00 303.00
3111-92-6203 32,740.00 .00 32,740.00
3111-92-6215 29,502.58 .00 29,502.58
3111-92-8813 2,543.70 .00 2,543.70
3131-50-6170 3,866.99 .00 3,866.99
3131-92-6215 31,700.00 .00 31,700.00
4311-92-6170 321.00 .00 321.00
9111-50-6125 3,840.00 .00 3,840.00
9613-75-6120 136.51 .00 136.51
9613-75-6122 74.66 00 74.66
9613-75-6160 62.06 62.06
9613-75-6163 16.38 .00 16.38
9613-75-6166 119.95 .00 119.95
9613-75-6190 399.26 .00 399.26
9613-75-6202 26.54 26.54
9670-65-6111 34.19 .00 34.19
9670-65-6122 76.00 .00 76.00
9670-65-6160 36.31 .00 36.31
9670-65-6166 122.54 .00 122.54
9670-65-6167 4.09 100 4.09
9670-65-6203 14.25 .00 14.25
9670-65-6240 279.25 00 279.25
9670-70-6111 10.25 .00 10.25
9670-70-6120 180.00 .00 180.00
City of lone Unpaid Invoice Report - UNPAID INV. REPORT Page: 13 Posting period: 02/24 Feb 16, 2024 10:14AM
Summary by General Ledger Account Number
GL Account Number Debit Credit
9670-70-6140 394.12 .00 394.12
9670-70-6160 28.32 .00 28.32
9670-70-6166 306.73 306.73
9670-70-6201 717.98 717.98
9670-70-6202 709.84 709.84
9670-70-6220 41,388.84 .00 41,388.84
9670-70-6240 85.50 85.50
9675-65-6111 34.19 .00 34.19
9675-65-6122 76.00 .00 76.00
9675-65-6160 36.31 .00 36.31
9675-65-6166 122.54 122.54
9675-65-6167 4.09 .00 4.09
9675-65-6203 14.25 .00 14.25
9675-65-6240 279.25 279.25
9675-75-6120 136.51 136.51
9675-75-6122 74.66 .00 74.66
9675-75-6160 62.06 62.06
9675-75-6166 136.33 .00 136.33
9675-75-6190 399.26 399.26
9675-75-6202 26.54 .00 26.54
Grand Totals: 234,331.50 .00 234,331.50
Summary by General Ledger Posting Period
GL Posting Period Debit Credit Net
01/24 303.00 303.00
02124 234,028.50 234,028.50
Grand Totals:
234,331.50 234,331.50

HALL OF TONE

CITY OF IONE
IONE, CA 95640
Agenda Item #13
DATE: FEBRUARY 20, 2024
TO: MAYOR LAFAYNE AND CITY COUNCIL
FROM: SALINA MITCHELL, RECREATION COORDINATOR
SUBJECT: IONE 4-H LEASE OF HOWARD PARK BARN
RECOMMENDED ACTION:

Approve Resolution 2024-* A Resolution of the City Council of the City of lone Authorizing an Agreement Between the City of Ione and the Regents of the University of California, Agriculture and Natural Resources Cooperative Extension (Ione 4H Club).

FISCAL IMPACT:

There are very minimal to no fiscal impacts as the lone 4-H Club will reimburse the City for water and power usage.

UPDATE:

At your last meeting, Council members noted there were some concerns with the lease relating to the Exhibits numbers being incorrect and the terms were inconsistent. Those items have been corrected. Additionally, it should also be noted, that it is not anticipated that this rental will interfere with potential barn rentals.

BACKGROUND:

The barn at Howard Park is located on the Southwestern portion of the park and currently holds five large stalls with paddocks and five large paddocks without stalls. There is also a large area of flat land surrounding the barn that can be utilized for other 4-H related projects. The barn is occasionally used by renters to keep their horses but is not rented out on a consistent basis.

The City met with lone 4-H Club in October 2023 to tour the barn and surrounding area. Ione 4- H thought is would be suitable to keep larger project animals such as steers, goats, sheep or pigs.

At the January 30, 2024 Parks and Recreation Commission, the Commission voted unanimously to recommend approval of the lease agreement between the City and the Regents of the University of California, Agriculture and Natural Resources Cooperative Extension.

DISCUSSION:

Ione 4-H Club is interested in leasing the barn to house fair animals for 4-H members that do not have the ability to care for them at their homes. Ione 4-H would keep larger animals at the barn such as sheep, swine, cattle etc. Ione 4-H will also be able to have meetings and store any needed supplies and equipment at the barn as well. With permission from the City, one 4-H will be responsible for any updates and improvements the barn may need in order to make it compatible for keeping animals.

Ione 4-H will also have first right of refusal with the barn. If prospective renters are interested in renting available stalls in the barn, they will need to contact the City. The City will determine availability with lone 4-H.

The Agreement will be valid through June 30, 2024, with the ability to extend the Agreement on an annual basis from July 1st - June 30th. Ione 4-H Club is only able to contract per fiscal year.

Central Sierra Cooperative Extension, the entity that the lone 4-H Club falls under, has already signed the attached agreement.

ATTACHMENTS:

A. Howard Park Barn Lease Agreement
B. Resolution 2024-**
Attachment #I3A
RESOLUTION 2024-*

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF IONE AUTHORIZING

AN AGREEMENT BETWEEN THE CITY OF IONE AND THE REGENTS OF THE

UNIVERSITY OF CALIFORNIA, AGRICULTURE AND NATURAL RESOURCES,

COOPERATIVE EXTENSTION
WHEREAS, at the January 30, 2024 Parks and Recreation Commission of the City of lone WHEREAS, the Ione Community 4-H Club has expressed interest in keeping project animals at the Howard Park Barn; and
WHEREAS, the City would like an organization to use the Howard Park Barn so that many people can enjoy it; and
WHEREAS, the Howard Park Barn sits at the southwestern portion of the barn and is occasionally used by renters but remains largely unoccupied; and WHEREAS, the lone Community 4-H Club would like to keep project animals, store equipment, and hold meetings at the Howard Park Barn; and WHEREAS, the lone Community 4-H Club would reimburse the City of lone for water and power usage at the Barn; and
WHEREAS, the lone Community 4-H Club would be responsible for any maintenance and improvements to the Barn and serviceable surrounding area with permission from the City; and WHEREAS, the lone Community 4-H Club is only permitted to enter into a lease agreement per fiscal year; and
WHEREAS, the Agreement for the Howard Park Barn between the City of lone and Ione Community 4-H Club will be valid through June 30, 2024 and then eligible for renegotiation on an annual basis.

NOW, THEREFORE BE IT RESOLVED, by the City Council of the City of lone The foregoing Resolution was duly passed introduced and adopted by the City Council of the City of lone at their regular meeting held on February 20, 2024, by the following vote:

AYES:

NOES:

ABSTAIN:

ABSENT:

Attachment #IA
Alyson LaFayne, Mayor
Attest:

Janice Traverso, City Clerk
Attachment #I3B

AGREEMENT BETWEEN THE CITY OF IONE AND THE
IONE COMMUNITY 4H CLUB FOR USE OF THE BARN

AT HOWARD PARK
This is a License Agreement ("Agreement") for the use of the Howard Park barn is entered into by and between the City of lone, a California municipal corporation, through its Parks & Recreation Department ("City"), and The Regents of the University of California, Agriculture and Natural Resources, Cooperative Extension ("lone Community 4H Club").

RECITALS
WHEREAS, the City owns and operates Howard Park located at 600 Church Street; and WHEREAS, the City of lone owns a barn in Howard Park; and WHEREAS, the barn has one single stall inside, four double stalls inside, and eight double outside pens; and
WHEREAS, the barn is furnished with power and water; and WHEREAS, surrounding the barn there is a grassy area, a wash rack and other serviceable areas such as paring, etc.; and
WHEREAS, lone Community 4H Club is a subsidiary of Central Sierra Cooperative Extension; and
WHEREAS, Ione Community 4H Club is a service club is the area whose mission is to engage youth in reaching their fullest potential while advancing the field of youth development; and
WHEREAS, Ione Community 4-H Club desires to use the barn at Howard Park to store club equipment, have meetings and keep market animals for the duration of this Agreement; and WHEREAS, the City wishes to grant lone Community 4-H Club permission to use the barn and immediately surrounding serviceable areas; and
WHEREAS, Ione Community 4H Club shall be responsible for the cost of utilities throughout the duration of the Agreement: and
WHEREAS, Ione Community 4-H Club will have first right of refusal of the barn at Howard Park for the duration of the Agreement; and
WHEREAS, should individuals not related to the Ione Community 4H Club occasionally want to rent available spaces in the barn those individuals shall contact the City directly: and WHEREAS, any outside rental shall be mutually discussed between the City and the lone Community 4H Club, with the City making the ultimate decision; and NOW, THEREFORE, in consideration of the above recitals, the mutual covenants herein contained and such other and further consideration as is hereby acknowledged, the parties agree as follows:

Attachment #I3B
Attachment #I3B

PARTICIPATING AGENCIES AND DESIGNATED CONTACT PERSONS
City of lone Representative: Ione Community 4H Club,
Central Sierra Cooperative Extension
Representative:

Amy Gedney, Interim City Manager JoLynn Miller, Central Sierra Director & 4-H City of lone Youth Development Advisor
#1 Main Street 52 North Washington
Ione, CA 95640 Sonora, CA 95370
Tel: (209) 274-2412, Ext. 116 Tel: (209) 256-6333

1. Term:

A. This Agreement will be valid from date of approval through end of the 2023/2024 fiscal year, dated June 30, 2024.

B. Upon expiration, the terms and conditions will be evaluated by both Parties and the Agreement may be extended for an additional fiscal year, dated July 1, 2024 through June 30, 2025.

C. Should both parties remain happy with the Agreement an extension may be granted on an annual basis.

D. If either party fails to perform any of its obligations under this Agreement when due and called for, that Party shall be in default. Should the defaulting Party fail to cure such default within thirty (30) days of receiving written notice from the non-defaulting Party; the Agreement may be terminated by the non-defaulting Party. Provided, however, that the nature of the default is a non-monetary default, and is the result of a force majeure occurrence, or is otherwise of a nature such that it cannot be fully cured within that thirty (30) day period, the Party in default shall have such additional time as is reasonably necessary to cure the default so long as the Party is proceeding diligently to complete the necessary cure after service of notice by the non-defaulting Party.

2. Mutual Covenants:

A. The City shall:

Monitor the Park and City facilities to ensure all commitments are being adhered to.

B. lone Community 4-H shall:

1. Reimbursement. Reimburse the City of lone for water and power costs on a monthly basis for the full term of the contract. The City will invoice for reimbursement of said costs. Invoices are based on a Net 20, to be paid within twenty (20) days.

2. Operations & Maintenance. Prior to expiration of the Agreement, on a bi-annual basis, both parties shall negotiate in good faith an appropriate reimbursement in a continuing effort to help the City offset rising operations and maintenance cost associated with the barn.

Attachment #I3B
a. lone Community 4-H Club Use. Functions of the Ione Community 4-H Club shall be conducted in accordance with applicable laws and City policies, including all OSHA regulations and standards. Ione Community 4-H Club shall not use the barn, nor permit others to use the barn in a way that will create a hazardous condition at the barn or surrounding areas. The Community 4-H Club Leader shall inspect the premises prior to any use to ensure no hazardous conditions are present.
b. Improvements. Permission shall be obtained from the City prior to the investment and/or development of the Howard Park barn and/or surrounding areas. Should the opportunity to raise funds through donations, grants and/or fund-raising efforts become available to Ione Community 4H Club, the City shall be notified and included in all decisions regarding capital improvements.
c. Equipment. Provide and maintain the necessary equipment for the barn at Howard Park for the use of lone Community 4-H Club. This includes, but is not limited to; hoses for watering, field rakes, shovels, weed eaters, animal waterers, etc.
d. Conservation. Assist Parks and Recreation Department staff to conserve both water and electrical power associated with the facilities.

3. Exclusivity & Scheduling:
a. This is an exclusive Agreement for the lone Community 4-H Club to use the Howard Park barn. However, lone Community 4-H Club shall maintain first right of refusal for the purpose of holding meetings, fair practices and storing equipment during the year, each year for duration of this Agreement. Ione Community 4-H shall request approval from the City for any events that are outside of meetings, fair practices, and storing equipment. b. The City will coordinate with lone 4H should any others be interested in renting the barn in conjunction with events at the Ed Hughes Memorial Arena.

4. Insurance:

The lone Community 4-H Club shall procure and maintain for the duration of this Agreement casualty and general liability insurance in commercially reasonable amounts, or as required by California Law, insuring against claims for injuries to persons or damages to property which may arise from or in connection with Ione Community 4-H Club'suse of the City Facilities or performance under this Agreement. The coverage shall in no event be less than $1,000,000 in primary coverage. a. The City, its officers, agents and employees are to be covered as additional insured. The policy shall not contain any special limitations on the scope of protection afforded to the City, its officers, agents and employees. b. For any claim related to this Agreement, Ione Community 4-H Club's insurance shall be the primary insurance as it relates to claims made against the City, its officers, officials and employees. Any insurance or self- Attachment #I3B
insurance maintained by the City, its officers, officials or employees shall be excess of the lone Community 4-H Club's insurance and shall not contribute to it.
c. lone Community 4-H Club's insurance shall apply separately to each insured against whom a claim is made, or suit is brought, except with respect to the limits of insurer's liability.
d. Each insurance policy required by this Section shall be endorsed to state that coverage shall not be suspended, voided or cancelled by either Party, reduced in coverage or in limits except after thirty (30) days prior (10 days for non- payment of premium) written notice by certified mail, return receipt requested, has been given to the City. Ione Community 4-H Club shall also provide the same notice to the City.
e. lone Community 4-H Club shall furnish the City with original endorsements effecting coverage required by this Section. The endorsements are to be signed by a person authorized by that insurer to bind coverage on its behalf.

All endorsements are to be received and approved by the City within thirty (30) days from execution of this Agreement.

1. Any failure to comply with reporting or other provisions of the parties, including breach of warranties, shall not affect coverage provided the City, its officers, agents and employees.

5. Indemnity:
lone 4-H shall indemnify and hold City, its officers, agents, volunteers and employees harmless from and against all claims, damages, losses and expenses, including attorneys fees and costs arising out of the use of other activities described in this Agreement by the Foundation, caused in whole or in part by any negligent act or omission of the Foundation, its agents, volunteers or employees or anyone directly or indirectly associated with the Foundation or anyone whose acts for which the Foundation may be liable, except where such liability is caused by the active negligence, sole negligence or willful misconduct of the City, its officers, agents or employees.

6. Assignment:

Ione Community 4-H Club agrees that it will not assign this Agreement, or any interest herein without first obtaining the prior written consent of City. Any assignment without the City's consent shall be voidable, and, at City's election, shall constitute a default.

7. Dispute Resolution:

If, during the performance of this Agreement, a dispute arises between lone Community 4-H Club and the City that cannot be settled by discussions, lone Community 4-H Club shall submit a written statement within ten [10] days of the incident giving rise to the dispute to the City. A decision by the City Administrator shall be made to the lone Community 4-H Club within seven [7] days, in writing. Ione Community 4-H Club reserves the right to appeal City Administrator's decision to the City Council. City Council's decision shall be binding and final. Ione 4-H Club and City shall continue to perform Agreement requirements without interruption during the dispute period.

Attachment #I3B

8. General Terms and Conditions.

The terms and conditions contained in this Agreement shall govern and shall take precedence over any different or additional terms and conditions that lone Community 4-H Club may have included in any documents attached to or accompanying this Agreement. Any handwritten changes on the face of this document shall be ignored and have no legal effect unless initialed by both parties. a. Choice of Law, Forum Selection, Entire Agreement and Modifications This Agreement shall be construed under California law (without regard for choice-of- law considerations) and the policies and procedures of the City, as amended from time to time. Any action arising out of this Agreement shall be heard by a state court in California. For this purpose, Ione Community 4-H Club specifically consents to jurisdiction in Amador County. This Agreement constitutes the entire agreement and understanding of the parties and replaces any prior or contemporaneous agreement, whether written or oral. b. Use of City Name or Logo.
lone Community 4-H Club agrees not to use the name, logo, or any other marks (including, but not limited to, colors and music) owned by or associated with the City or the name of any representative of the City in any sales promotion work or advertising, or any form of publicity, without the written permission of the City in each instance.
c. Terms of Payment.

Subject to the conditions below, payment shall be made by Ione Community 4- H Club within twenty (20) days upon City's presentation of an invoice for services rendered pursuant to this Agreement.
d. Termination.

The City may terminate this Agreement in whole or in part for Cause upon thirty (30) days written notice if lone Community 4-H Club fails to comply with any material term or condition of this Agreement, becomes insolvent or files for bankruptcy protection, or fails to comply in a material way with the requirements of this Agreement. Late delivery of services, or services that are defective or do not conform to the Agreement shall, without limitation, be causes allowing the City to terminate for cause.
e. Independent Ione Community 4-H Club.
lone community 4-H Club shall perform its duties hereunder as an independent Ione Community 4-H Club and not as an employee of the City. Neither Ione community 4-H Club nor any agent or employee of lone Community 4-H Club shall be or shall be deemed to be an agent or employee of the City. Ione community 4-h club shall pay when due all required employment taxes and income tax withholding, including all federal and state income tax on any monies paid pursuant to this agreement. Ione Community 4-H Club acknowledges that Ione Community 4-H Club and its employees are not entitled to tax withholding, worker's compensation, unemployment compensation, or any employee benefits, statutory or otherwise. Ione Community 4-H Club shall have no authorization, express or implied, to bind the City to any agreements, liability, or understanding except as expressly set forth herein. Ione Community 4-H club shall be solely Attachment #I3B
responsible for the acts of lone Community 4-H Club, its employees, and agents. f. Non-Waiver.

No waiver by any party of any default or nonperformance shall be deemed a waiver of any subsequent default or nonperformance.
g. Limitation on City Liability.

In No Event Shall the City Be Liable for Any Indirect, Consequential, Incidental, Lost Profits Or Like Expectancy Damages Arising Out Of The Agreement. The City's Maximum Obligation Under This Agreement Shall Not Exceed $7,500. h. Affirmative Action, Equal Employment Opportunity, and Targeted Group Business.

The City is committed to the policy that all persons shall have equal access to its programs, facilities, and employment without regard to race, color, creed, religion, sex, age, marital status, disability, public assistance status, veteran status, or sexual orientation and is committed to transacting business only with firms who follow these practices. Ione Community 4-H Club must apply every good faith effort to ensure implementation of this policy in their practices of employment, upgrade, demotion or transfer, recruitment, or recruitment advertising, layoff or termination, rates of pay or other forms of compensation, and selection for training, including apprenticeship. Ione 4-H Club will maintain non-segregated facilities for their employees and not allow their employees to perform services at any segregated facilities under its control. By accepting this Agreement, lone Community 4-H Club certifies that it complies with all applicable federal and state laws as well as City policies related to non- discrimination, equal employment opportunity, and affirmative action.

Compliance with Ordinances and Regulations.

Ione Community 4-H Club agrees to abide by all applicable laws and regulations and all rules, notices, prohibitions instructions, or directions posted on any park or trail sign by the City. This includes closures. The Ione Community 4-H Club is not authorized to alter, construct, erect, or remove any structure within a park or on a trail without permission from the City. This includes the physical alteration of structures. The Ione Community 4- H Club agrees to not assemble for the purpose of which, in fact, results in blocking or obstructing the lawful use by any other person of any portion of a park or trail or any structure in a park or on a trail or any position of access or exit to or from any park, trail, structure therein. This includes blocking off entrance drives and parking areas. Ione Community 4-H Club agrees not to charge admission, collect fees or payment for any activity, event, service or use of any land or facility in a park or on a trail without permission from the City. This includes charging a fee for the use of parking spaces.

Severability.

If any provision of this Agreement shall be invalid or unenforceable with respect to any party, the remainder of the Agreement, or the application of such provision to persons other than those as to which it is held invalid or unenforceable, shall not be affected and each provision of the remainder of the Agreement shall be valid and be enforceable to the fullest extent permitted by law.

Attachment #I3B
k. Survivability.

The terms, provisions, representations, and warranties contained in this Agreement that by their sense and context are intended to survive the performance thereof by any of the parties hereunder shall so survive the completion of performance and termination of this Agreement, including the making of any and

1. Notices.

All notices, requests, or other communications required hereunder shall be sufficient only if given in writing and shall be deemed given only when delivered personally or deposited in the United States mails by certified or registered mail, postage prepaid addressed as follows:

City of lone
Attn: City Manager
P.O. Box 398
lone, CA 95640
Ione Community 4H Club
Central Sierra Cooperative
Extension
Attn: Central Sierra Director & 4-H Youth
Development Advisor 311 Fair Lane
Placerville. , CA 95667
Such addresses may be changed by either party by written advice as to the new address delivered to the other party at the address provided above. m. Multiple Counterparts
This Agreement may be executed in multiple counterparts, each of which shall be an original, but all of which shall constitute one and the same document. Facsimile or electronic signatures shall have the same effect as original signatures.

IN WITNESS WHEREOF, the City of lone, a municipal corporation, has caused this Agreement to be executed in duplicate by its City Manager and attested to by its City Clerk: and lone Community 4-H Club has caused this Agreement to be executed by its CITY OF IONE IONE COMMUNITY 4-H CLUB
Digitally signed by JoLynn
Miller
By - 1631202180072
By .

Amy Gedney, Interim City Manager JoLynn Miller, Central Sierra Director & 4-H Youth Development Advisor
Attachment #I3B
APPROVED AS TO FORM:

By -
Andy Pinasco, City Attorney
By -
Janice Traverso, City Clerk
Attachment #13B

ATTACHMENT A
Standard Hold Harmless/Indemnification Clause Recognizing Property Owner's Interests
(While Not Placing Unacceptable Liability on the University of California) THE REGENTS OF THE UNIVERSITY OF CALIFORNIA shall defend, indemnity, and hold Name of other entity or person: CITY OF IONE, CA its officers, employees, and agents harmless from and against any and all liability, loss, expense (including reasonable attorney's fees), or claims for injury or damages arising out of the performance of this Agreement, but only in proportion to and to the extent such liability, loss, expense, attorneys' fees, or claims for injury or damages are caused by or result from the negligent or intentional acts or omissions of THE REGENTS OF THE UNIVERSITY OF CALIFORNIA, its officers, employees, or agents.

County Director's Name and Signature:

Digitally signed by JoLyrin
Miller
Date: 2024.01.17
-16.31.57.08:00
Date:

AMADOR
County Name:

University of California
Division of Agriculture & Natural Resources
Cooperative Extension
Authorized Name and Signature of the other entity:

Date:

CITY OF IONE, CA
USE THIS LANGUAGE TO MODIFY AN EXISTING CONTRACT/AGREEMENT.

CHA OF TONG

CITY OF IONE
IONE, C4 95640
Agenda Item #J1
DATE: FEBRUARY 20, 2024
TO: THE HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL FROM: DEBBIE MACKEY, GRANT ADMINISTRATOR
SUBJECT: COMMUNITY DEVELOPMENT BLOCK GRANT (CDBG) AND HOME

PROGRAM
RECOMMENDATION:

For information.

BACKGROUND:

This report is to provide an overview of the funding the City has received that supports housing needs within the community.

The Community Development Block Grant (CDBG) and HOME Program are initiatives that address various community development and affordable housing needs. Administered by the California Department of Housing and Community Development (HCD), these programs receive federal funding from the U.S. Department of Housing and Urban Development (HUD).

CDBG funding is primarily targeted towards low- to moderate-income areas and individuals. Its main objectives include:
• Stimulating economic development
• Providing affordable housing
• Improving community facilities and services
• Addressing urgent needs such as disaster recovery
The HOME program is a federal grant program aimed at expanding the supply of affordable housing for low-income households. Administered by the U.S. Department of Housing and Urban Development (HUD), it provides funding to states and localities to support a variety of affordable housing activities.

The primary goal of the HOME program is to increase the availability of safe, decent, and affordable housing for low-income individuals and families. It seeks to achieve this by:
• Funding the development, rehabilitation, and preservation of affordable housing • Assisting first-time homebuyers
• Supporting tenant-based rental assistance programs
Attachment #I3B

CERTIFICATE OF
Date: June 15, 2023

SELF-INSURANCE COVERAGE

PRODUCER/INSURED
The Regents of the University of California This Certificate is issued as a matter of information only to authorized viewers for Office of the President their internal use only and confers no rights upon any viewer of this Certificate Office of Risk Services The Certificate does not amend, extend or alter the coverage described below. 1111 Franklin St., 10th Floor This Certificate may only be copied, printed and distributed by an authorized Oakland, CA 94607-5200 viewer for its internal use. Any other use, duplication or distribution of the 510-987-9832 Certificate without the written consent of the Regents of the University of California is prohibited.

ENTITIES AFFORDING COVERAGE

PARTICIPATION
COMPANY LETTER A The ReQents of the University of California

THIS IS TO CERTIFY THAT THE REGENTS OF THE UNIVERSITY OF CALIFORNIA IS A GOVERNMENTAL ENTITY THAT HAS A SELF-FUNDED

RETENTION FOR LIABILITIES DESCRIBED BELOW, NOTWITHSTANDING ANY REQUIREMENT, TERM OR CONDITION OF ANY WRITTEN CONTRACT OR OTHER DOCUMENT WITH RESPECT TO WHICH THIS CERTIFICATE MAY PERTAIN. THIS SELF-FUNDED PROGRAM IS SUBJECT

TO ALL PROVISIONS OF THE BYLAWS AND STANDING ORDERS OF THE REGENTS OF THE UNIVERSITY OF CALIFORNIA, WHICH DOES NOT

PERMIT ANY ASSUMPTION OF LIABILITY WHICH DOES NOT RESULT FROM THE NEGLIGENT ACTS OR OMISSIONS OF ITS OFFICERS, AGENTS

TYPE OF INSURANCE POLICY NUMBER POLICY EFFECTIVE DATET POLICY EXPIRATION DATE LIMITS GENERAL AGGREGATE Is Not applicable
COMMERCIAL GENERAL LIABILITY PRODUCTS-COMP/OP AGG S5.000.000 J CLAIMS MADE OCCURRENCE Self-insured July 1, 2023 July 1, 2024 PERSONAL & ADV INJURY $ 5,000.000 CONTRACTUAL LIABILITY $ 5,000,000
EACH OCCURRENCE $ 5,000,000
TOMOBILE LIABILITY COMBINED SINGLE LIMIT 15 Not applicable A | ANY AUTO
ALL OWNED BODILY INJURI $ 2,500,000

AUTOS PER PERSON
SCHEDULED Self-Insured July 1, 2023 July 1, 2024
| AUTOS
X HIRED AUTOS BODILY INJURY $ 2,500,000
(PER ACCIDENT)
-X NON-OWNED
AUTOS
GARAGE LIABILITY PROPERTY DAMAGE $ 2,500.000

PROPERTY EACH OCCURRENCE
• 10.000,000
Self-Insured July 1, 2023 July 1, 2024 AGGREGATE
1 FIRE & EXTENDED PERILS 1 Notapicable

STATUTORY LIMITS
WORKERS' COMPENSATION AND Self-Insured July 1, 2023 July 1, 2024 EACH ACCIDENT

EMPLOYERS LIABILITY
DISEASE - POLICY LIMIT I Cateria Lay
DISEASE - EACH EMPLOYEES As requred by
Califomia Law

DESCRIPTION OF OPERATIONS/LOCATIONSNEHICLES/SPECIAL ITEMS

LADDITIONAL COVERED PARTY- AS REQUIRED BY WRITTEN CONTRACT OR AGREEMENT WITH RESPECT TO GENERAL LIABILITY

AND AUTOMOBILE LIABILITY
LOSS PAYEE• AS REQUIRED BY WRITTEN CONTRACT OR AGREEMENT WITH RESPECT TO PROPERTY COVERAGE

CERTIFICATE HOLDER CANCELLATION

PPLICABLE PARTY AS REQUIRED BY WRITTEN CONTRACT SHOULD THE REGENTS ELECT TO DISCONTINUE SELF-INSURING ITS

OR AGREEMENT LIABILITIES, THE REGENTS WILL UPDATE PROOF OF SELF-INSURANCE ON ITS WEBSITE. THE REGENTS SHALL NOT BE OBLIGATED TO PROVIDE INDIVIDUAL

NOTICE TO VENDORS OR OTHERS
By:
uy

KEVIN CONFETTI, AVP & CHIEF RISK OFFICER
The purpose of this report is to provide a comprehensive overview of the current status of the CDBG and HOME Programs.

DISCUSSION:

As loans are paid off back to the City, the City can then reissue those monies for purposes stated below:
• Housing Development: Funds can be used to construct, rehabilitate, or provide affordable housing units for low-income residents.
• Infrastructure Improvement: Supports projects like road repair, water and sewer systems, and community facilities.
• Public Services: Funds may be allocated to services such as childcare, senior services, and job training programs.
• Economic Development: Assists in fostering small business development and job creation initiatives.

HOME:

The program utilizes program income for first-time home buyers and housing rehabilitation.

The HOME Program promotes community development, economic prosperity, and affordable housing accessibility. The programs have shown significant impacts for our City.

To ensure continued success, strategic planning, advocacy, and collaboration will be essential.
• There are currently 15 active loans totaling $1,120,572.00. • Program income amounts to $1,193,625.81.

CDBG:
• Seeking funding through the 2023 CDBG for the wastewater treatment plant projects.

Staff anticipates advertising that funds are available in early spring.

Additionally, we are administering our current programs by:
• Choosing projects and partners.
• Setting up financial systems.
• Developing reporting and record keeping systems.
• Reviewing performance and compliance.

Additionally, we are requesting an extension for a $65,000.00 grant application that was approved in 2020 for a project located on Waterman Road. The amendment would allow us to analyze additional sites for review of the sewer collection system.

CALE OF TONE

CITY OF IONE
IONE, CA 95640
Agenda Item #J2
DATE: FEBRUARY 20, 2024
TO: THE HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL FROM: AMY GEDNEY, INTERIM CITY MANAGER
SUBJECT: ACUSD DEIR COMMENT LETTERS
RECOMMENDED ACTION:

For information and staff direction.

BACKGROUND:

The Amador County Unified School District has published a Draft Environmental Impact Report. Comments were due on February 13, 2024. Included in the staff report on responses from the Amador County Transportation Commission, Caltrans, Amador County, and the City of lone.

DISCUSSION:

Our City Planner, Susan Peters will be at our meeting to discuss next steps.

IKRONICK

KRONICK

MOSKOVITZ

TIEDEMANN
EDWARD A. GRUTZMACHER
[email protected] & GIRARD
February 13, 2024
VIA EMAIL AND U.S. MAIL
Jared Critchfield
Deputy Superintendent, Business Services
Amador County Unified School District
217 Rex Avenue
Jackson, California 95642
[email protected]
RE: School Closure/Consolidation Program Project Draft EIR Comments Dear Deputy Superintendent Critchfield:

I submit these comments on behalf of my client, the Amador County Transportation Commission ("ACT") regarding the Amador County School District's ("ACUSD" or "District") School Closure and Consolidation Program Project ("Project") and the Project Draft Environmental Impact Report ("DEIR") published on December 15, 2023. Despite our multitude of letters, communications, and meetings, ACTC remains seriously concerned that the District is moving forward with the Project without completing legally adequate CEQA' review. Specifically, the DEIR is lacking in information on and analysis of Project environmental impacts to traffic and traffic safety as well as lacking adequate identification, consideration, and adoption of mitigation measures.

ACT has communicated with the District regarding the Project multiple times, participated in meetings on the same, and appreciates this opportunity to further comment on the Project and Project DEIR.

Specifically, ACT has sent letters to the District on the Project since October 12, 2022, all of which are attached and incorporated by reference as if set forth in full here.

As you know, ACTC is the Regional Transportation Planning Agency and Local Transportation Commission to Amador County. ACT's mission includes the protection and advancement of local, regional, and state travel to the benefit of County citizens, visitors, and guests. In this vein, ACT has a direct interest in ensuring smart planning that is a catalyst for fluid, unimpeded transportation and traffic in the present and future. Since 1972, ACT Commissioners, staff, and consultants have researched analyzed, planned, and advocated for improving transportation networks throughout and surrounding Amador County. This five decades of local experience in such a highly-technical and specialized field make the Agency unequivocal experts in transportation and traffic in the Project area. If the Project fails 1 California Environmental Quality Act, Public Resources Code ("PRC") section 21000 et sea. ("CEQA"); see also regulations promulgated by the Governor's Office of Planning and Research pursuant to CEQA, California Code of Regulations, Title 14, Division 6, Chapter 3, section 15000 et seq. (Guidelines"). 1331 Garden Hwy, 2nd Floor | Sacramento, CA 95833 T. (916) 321-4500 | F. (916) 321-4555 www.kmtg.com 2460391.9
Jared Critchfield
Re: Consolidation DEIR
February 13, 2024

Page 2 ends

to account for impacts to transportation or traffic or mitigate such impacts, ACT's designated work in smart transportation planning will be much more difficult, or completely frustrated.

ACTC appreciates that the District extended the comment period. ACT asked that the comment period be extended both so that ACT could provide comments but also so that ACTC, the District, and other transportation experts could meet and attempt to come to a consensus on the analysis and mitigation of traffic impacts so that the Project could move forward in a timely manner. The meetings resulted in a sharing of concerns and some further information. Nonetheless, the meetings also made apparent that the District is some combination of: unaware of its CEQA obligations, unaware that the DEIR is legally deficient with regards to identifying Project environmental impacts, unaware of the significant project impacts that require mitigation, unaware of its obligations to identify mitigation measures to address the significant impacts, and unaware of the level of specificity required for mitigation measures.

ACTC is concerned that the District continues to disregard its obligations under CEQA and the CEQA Guidelines, particularly in regard to identification of Project impacts to traffic and transportation. As concisely explained by ACT's expert traffic engineer, Don Hubbard, 2 the District is not required to cure and correct every single traffic safety issue in the County. (See, Feb. 12, 2024 D. Hubbard Presentation, Slide 20 "Fair Share Fundamentals.") ACT's goal in submitting this comment letter is to ensure that all impacts to traffic and transportation from the Project are properly analyzed, identified, and mitigated to the extent feasible.

ACTC does not intend to stop the Project but only ensure that the District meets its obligations pursuant to CEQA. However, if the District refuses or fails to meet its CEQA obligations, ACT is reluctant but more than prepared to seek judicial resolution of the matters discussed herein.

A. CEQA Background
An agency is prohibited from approving a project prior to analyzing the reasonably foreseeable impacts of the project to the environment in the manner required by CEQA. (PRC, §§ 21002 and 21080; Guidelines, § 15004(a).) CEQA provides that "an agency must use its best efforts to find out and disclose all that it reasonably can" when forecasting environmental impacts and the feasibility of alternatives, including mitigation measures. (Guidelines, § 15144; see also id. at § 15151.) "'Feasible' means capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, social, and technological factors." (PRC, § 21061.1.) The lead agency is not only required to do "all that it reasonably can" to identify the environmental impacts of a proposed project, it must also disclose the nature and magnitude of impacts it finds significant. (Sierra Club v. County of Fresno (2018) 6 Cal.5th 502, 519; City of Long Beach v. City of Los Angeles (2018) 19 Cal.App.5th 465, 486.) After the lead agency identifies and evaluates those impacts, it must then analyze mitigation measures or alternatives that avoid or substantially lessen any significant effects. (PRC, §§ 21061, 21100(b)(1), (3) and 21002.1(a); Friends of Sierra Madre v. City of Sierra Madre (2001) 25 Cal.4th 163, 2 Mr. Hubbard is a licensed traffic engineer (CA License No. 2260) with engineering degrees from Northwestern University and a master's degree in city and regional planning from Harvard University's John F. Kennedy School of Government. He is a transportation planner and traffic engineer with over forty years' experience in travel demand forecasting and transportation policy. He specializes in transportation analyses of large-scale projects in conformance with state and federal law (e.g., CEQA, NEPA, Mitigation Fee Act, etc.). His clients have included, but are not limited to, a wide variety of California cities, counties, and other public agencies.
2460391.9
Jared Critchfield
Re: Consolidation DEIR
February 13, 2024

Page 3 ends

183.) The formulation of mitigation measures cannot be deferred; they must be identified by and incorporated into the environmental document. (Guidelines, § 15126.4.) Thus, to be informationally and legally adequate, an environmental impact report ("EIR") for a proposed project must set forth in detail: information about the impacts that the proposed project is likely to have on the environment, ways that the impacts might be minimized or mitigated, and alternatives to the project to reduce or avoid adverse impacts on the environment. (PRC, § 21061; Guidelines, §15126.) While mitigation is only required where the project is likely to have a significant impact on that aspect of the environment, meaning "a substantial, adverse change," all potential impacts must nonetheless be addressed in the EIR. (PRC, § 21068; Guidelines, § 151382.) B. Iraffic Safety Impact Analysis

1. The District is Required to Analyze Traffic Safety Impacts.

The District is required to identify and analyze impacts to traffic safety from the Project. (PRC, § 21099(b)(3).) During the meeting on February 12, 2024, the District's traffic consultant mistakenly stated that queueing that results in an unsafe condition is not a CEQA impact. This is consistent with the lack of safety analysis in the DEIR, which instead considered impacts to vehicle miles traveled ("VMT"). That is wrong and I immediately warned all meeting attendees of the legal defenselessness of that position.

Public Resources Code section 21099(b)(3), added to CEQA as part of Senate Bill 743 which established VMT, expressly provides:

This subdivision [establishing VMT as the metric to study traffic impacts] does not relieve a public agency of the requirement to analyze a project's potentially significant transportation impacts related to air quality, noise, safety, or any other impact associated with transportation. The methodology established by these guidelines shall not create a presumption that a project will not result in significant impacts related to air quality, noise, safety, or any other impact associated with transportation. Notwithstanding the foregoing, the adequacy of parking for a project shall not support a finding of significance pursuant to this section.
(Emphasis added.) In short, a public agency remains expressly required to continue to analyze safety impacts independent of VMT and a public agency is expressly prohibited from relying exclusively on VMT to side step analysis of, among other things, impacts to traffic safety. Indeed, the District's own CEQA consultant, Placeworks, agreed to this exact information when presented it on December 14, 2023 and January 31, 2024.

The DEIR does not include an analysis of the Project's impacts to traffic safety and fails to meet both these requirements. Why the District left out this critical analysis is unclear. Traffic safety is important in general but especially in this situation because the Project involves significant reorganization of school commute for the entire community. Instead, the DEIR limits its analysis to changes to VMT. This limited view of the District's CEQA responsibilities regarding traffic impacts is incorrect and insufficient. (PRC, § 21099(b)(3).) Please expand the DEIR to include analysis of impacts to traffic safety. 2460391.9
Jared Critchfield
Re: Consolidation DEIR
February 13, 2024

Page 4 ends

ACT's expert traffic engineer, Don Hubbard, presented this information to the District on at least two occasions. On January 31, 2024, Mr. Hubbard gave a presentation to District Trustees, staff, and consultants explaining why the District is required to study traffic safety, which ACT's legal counsel echoed. Placeworks responded "we agree with what's stated here." On February 12, 2024, Mr. Hubbard reiterated the same. Mr. Hubbard's slides from both presentations are combined and attached hereto to be made part of the record ("GHD Slides").

Mr. Hubbard also prepared a technical memorandum detailing the issues with the DEIR that he's identified and presented in his slides ("GHD Report"). That memorandum is attached hereto and incorporated herein as if set forth in full and, thereby, made part of the record. ACT expressly incorporates the GHD Report analysis and conclusions as its own.

The District has been made well aware of its responsibility to include analysis of the Project impacts to traffic safety. Substantial evidence has been presented by way of this letter as well as Mr. Hubbard's presentation, slides, and GHD Report. Please comply with CEQA and expand the DEIR to include analysis of Project impacts to traffic safety.

The District is Required to Analyze Traffic Queueing Impacts.

Queueing is an obvious facet of an adequate traffic safety analysis. As explained by ACT's traffic expert, Mr. Hubbard:
• If a project lengthens the queues at an intersection to the point where queues may extend past the existing turn pockets, the line of queued vehicles will spill over into the travel lanes. Having stationary, queued vehicles on a roadway where traffic typically moves at 45 MPH would greatly heighten the risk of rear-end collisions.
• Also, drivers get impatient when waiting in long queues, and are more likely to engage in risky behavior as a result. This includes turning into gaps in the opposing traffic that the driver might otherwise reject as insufficient, crossing the centerline (i.e., into the opposing direction of travel) to cut the queue to the left, or driving onto the shoulder to cut the queue to the right. The fact that many of the vehicles would be driven by inexperienced high school drivers would exacerbate the issue.
(GHD Report, p. 2.) Note that in the cases described above, a project can create or exacerbate a safety hazard simply by changing traffic patterns and volumes without making any physical change to the intersection. In addition to the queueing impacts to drivers waiting in car lines extending in an unsafe manner into streets, it is reasonably foreseeable that the unstudied, and unmitigated collection of vehicles attempting to perform drop-offs and pick-ups in crowded, undersized parking lots and travel lanes, coupled with student pedestrians and bicyclists, could result in hazardous interactions between vehicles and pedestrians/cyclists. The District itself suggested at the February 12 meeting that excessive queueing from the Project may lead to Project-related traffic routing through local neighborhoods. We agree that this is a likely possibility, which leads us to wonder if those impacts were not studied, either.

All of these impacts are exacerbated by the fact that a substantial portion of those drivers will be children with limited driving experience.

K
2460391.9
Jared Critchfield
Re: Consolidation DEIR
February 13, 2024

Page 5 ends

Caltrans also informed the District of the need for a queueing analysis to analyze traffic safety impacts.

Caltrans sent a letter to the District on July 12, 2023 in response to the District's Notice of Preparation of an EIR for the Project ("NOP"). A copy of the letter is attached hereto. That letter stated, in part:

In addition to the VMT analysis, the proposed project needs to conduct the queue analysis at the intersections of State Route (SR) 49/Hoffman St, SR 49/Sutter St., and SR 88/Argonaut Lane to analyze the potential safety impacts of the project as it may significantly change the traffic patterns. The queue analysis will determine, if any left- tum/right/turn storages at these intersections can accommodate additional traffic generated from the proposed project.

The queue analysis, at minimum, needs to provide the following:
• Existing turning movement traffic count, including pedestrians/students (AM & PM peaks) • Trip generation and trip distribution of the proposed project, including the estimation of the number of students who will use crosswalks at SR 49/Hoffman St, SR 49/Sutter St, and SR 88/Argonaut Lane
• Synchro/SimTraffic analysis.
(pg. 3, emphasis added.) Caltrans therefore informed the District, based on Caltrans modeling, knowledge, and unequivocal expertise in traffic safety analysis, that the Project had a potential to have traffic safety impacts and, in order to understand the magnitude of the impacts, a queueing analysis is required at least at SR 49/Hoffman St, SR 49/Sutter St., and SR 88/Argonaut Lane. Caltrans expressly instructed that the District (1) use Synchro/Sim Traffic software to do such analysis and (2) look at trip generation and trip distribution for the entire project, including the crosswalks at SR 49/Hoffman Street, SR 49/Sutter Street, and SR 88/Argonaut Lane. The District did not conduct the required analysis and the failure to do so in light of this expert evidence is a violation of CEQA.

Caltrans reiterated these concerns, and added additional traffic safety concerns, in its comment letter on the DEIR dated January 23, 2024. Specifically, Caltrans instructed the District's traffic impacts analysis be expanded to include not only a queueing analysis but also:

Existing Year
• Proposed Project Only (Trip Generation and Assignment) Existing Year Plus Proposed Project
• Cumulative Conditions without the proposed project
• Cumulative Conditions Plus Proposed Project
• Please provide analysis results for the 95th Percentile Queues. The 95th Percentile Queues and delays should be reported for each movement.

The peak-hour traffic counts need to include bicycle and pedestrian volumes.

The signal warrant analysis shows that the Sutter Street/Hoffman Street intersection meets the signal warrant. The Conclusions section states it does not. Please revise the conclusions based on the signal warrant analysis. Please also provide the raw traffic data (which appears to be a 24-hour count) in the attachment for this Traffic study. 2460391.9
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Re: Consolidation DEIR
February 13, 2024

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• The proposed project will increase a significant amount of traffic at the two intersections - SR 88/Argonaut Lane, and Sutter Street (SR 88)/Hoffman Street. The safety concems associated with the increased traffic from the proposed project, especially for the vehicles making a left turn out from the local roads experiencing a higher risk of broadside collisions with the mainline traffic due to longer wait at the stop sign, need to be addressed with the proposed project.

The traffic impact from the combined Junior High School at the current Amador High School should also be analyzed. Even though the total number of students remains the same, due to changes in traffic patterns from the combined school, the traffic would come from adjacent cities like lone and Jackson instead of locally from Sutter Hill only.

Please use the CA MUTCD worksheet for the traffic signal warrant study instead of Vistro.

Please use Synchro / SimTraffic software for the intersection analysis and provide the electronic files (Synchro Version 12) for Caltrans review.

ACTC concurs with Caltrans' July 12, 2023 and January 23, 2024 letters and the instructions therein - the District is required to complete a queueing analysis and further study in order to adequately analyze traffic safety impacts or else explain why such is not required. ACT is specifically concerned about the Project's traffic safety impacts at SR 49/Hoffman Street, SR 49/Sutter Street, and SR 88/Argonaut Lane as well as intersection of Spanish Street and Old State Route 49, near the current Amador High School, since there are already existing queueing issues and limited to no opportunity to queue.

ACT's expert traffic engineer, Don Hubbard, conducted a peer review of the DEIR's analysis and mitigation of identified traffic impacts from the Project. Mr. Hubbard concludes, "It appears that the project may trigger or exacerbate traffic safety issues at several locations. The [DEIR] did not examine these issues, perhaps in the mistaken belief that safety is not a CEQA issue. Until these are studied, the extent of the safety issues remain unknown and appropriate mitigation measures cannot be identified. " (GHD Report, p. 1.)
Given the substantial evidence from this letter, Mr. Hubbard's report, and Caltrans letters before the District regarding the potential for traffic safety impacts and need for, at least, a queueing analysis, the District is required to conduct the queueing analysis recommended by Caltrans at the intersections identified, as well as all other intersections likely to be impacted by the Project. Failure to do so is failure to comply with CEQA and subject to legal challenge.

3. The District's de minimis Traffic Safety Analysis is Inadequate.

To the extent the District claims that the limited data included in DEIR Appendix K satisfies CEQA's requirements, the District is incorrect. "The data in an EIR must not only be sufficient in quantity, it must be presented in a manner calculated to adequately inform the public and decision makers, who may not be previously familiar with the details of the project. [Information "scattered here and there in EIR appendices" or a report "buried in an appendix," is not a substitute for "a good faith reasoned analysis." ' " (Vineyard Area Citizens for Responsible Growth, Inc. v. City of Rancho Cordova (2007) 40 Cal.4th 412, 442.) Here, the District's limited analysis of traffic safety makes the exact error identified by the California Supreme Court, burying critical information for the public and the decision makers regarding the three intersections Caltrans identified - SR 49/Hoffman Street, SR 49/Sutter Street, and SR 2460391.9
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88/Argonaut Lane - in Appendix K. Moreover, the DEIR states that the analysis is expressly included "for informational purposes only" rather than being part of the DEIR analysis and conclusions. It is unclear why the District relegates such essential analysis of community safety to an appendix rather than fully addressing the matter in the body of the DEIR.

Further, even the limited analysis provided in Appendix K is inadequate. The analysis uses alternative traffic modeling technology, not the technology commonly used in the traffic engineering industry and expressly recommended by Caltrans, Synchro/SimTraffic. It is unclear, again, why the District used alternative technology, but whatever the reasoning, the results are that the DEIR information significantly differs from the conclusions Synchro/SimTraffic provides, functionally underplaying the traffic impacts. (GHD Report, p.4; GHD Slides, slide 7.) The District should use Synchro/SimTraffic modeling, explain why it did not, or explain the great discrepancy.

Even "for informational purposes only," Appendix K identifies that "operational deficiencies were identified" for at least three intersections - Argonaut Lane/State Route 88, Argonaut Lane/Stony Creek Road/Hoffman Street, and Sutter Street/Hoffman Lane." (Apx. K, p. 27.) Of specific concern, the signal warrant analysis "results showled] that the School PM peak hour volumes at Argonaut Lane/State Route 88 intersection meet the threshold to warrant signalization" and "an 8-hour signal warrant analysis is recommended at this intersection." (Ibid.) The District is required to complete the recommended analysis or else explain why the District declined to do so.

ACT's expert traffic engineer, Mr. Hubbard, raised these issues in the February 12, 2024 meeting, asked the District's traffic consultant why the study is only in an appendix "for informational purposes," and asked why the District's consultant did not use the methodology asked by Caltrans and most commonly used in their traffic engineering industry. The District's consultant admitted that the reason his team did not follow Caltrans's guidance is that, by the time they received the July 12, 2023 letter, they had already comments to the NOP, or else respond to why they are taking another direction. Guidelines section 15084 titled "Preparing the Draft EIR," subsection (c) reads "Any person, including the applicant, may submit information or comments to the Lead Agency to assist in the preparation of the draft EIR. The submittal may be presented in any format, including the form of a draft EIR. The Lead Agency must consider all information and comments received. The information or comments may be included in the draft EIR in whole or in part." (Emphasis added; see also Id. at § 15082.) This "it was too late" is legally inadequate.

Given Caltrans's expertise and the timeliness of their comment, the District was required to complete a traffic safety analysis in the way Caltrans directed and use Synchro/SimTraffic, or explain why not. This is also further example of how, as discussed in more detail below at Section (E), the District is reluctantly going through the hoops of the EIR process without allowing any meaningful input from the public or other public agencies.

To have a legally adequate CEQA analysis, the District is required to expand its traffic safety impacts analysis, include it in the body of the DEIR and acknowledge traffic impacts identified by such analysis, explain its choice of methodology, and mitigate for any significant impacts. 2460391.9
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Re: Consolidation DEIR
February 13, 2024

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The District's Traffic and Transportation Impacts Analysis is Inadequate.

The DEIR traffic and transportation analysis is also deficient in scope and content.

Traffic safety is not just an issue at full Project realization. The Project includes construction of improvements at three sites, or more. Construction includes large trucks, dust, dirt, and debris all of which are likely to disrupt regular traffic patterns. The DEIR fails to analyze traffic and traffic safety issues related to construction. Please add further information, discussion, and consideration of such in order to have an adequate traffic impact analysis. • The transportation analysis says, "Since all improvements would be made within existing school sites with the same number of students district-wide, the proposed project would not cause conflicts with proposed programs or plans to improve the circulation system for users including the vehicles, transit, bicycles, and pedestrians." (DEIR, pp. 5.15-18.) This assertion is without support or analysis and fails to consider that a change in route for students District-wide will cause impacts. Please add further analysis to this point and revise the DEIR in line with the results of such analysis.

CEQA Guidelines Appendix G requires the project applicant consider if the project will "substantially increase hazards due to geometric design feature (e.g. sharp curves or dangerous intersections)..." The diagrams in the Project description show parking traffic, parent pick- up/drop-off traffic, and bus traffic will be intermingled at Argonaut High School along one single- lane route. (DEIR, p. 3-27.) One lane of pick-up/drop-off is difficult to navigate, parking and reparking cars are difficult to navigate, and busses are difficult to navigate around. All of these together, in a single lane, at a school where adolescent pedestrians are mingling around, could result in obvious pedestrian, driver, and overall traffic safety issue that the DEIR does not disclose or adequately analyze. Please add further analysis and discussion on on-campus traffic safety.

Where traffic impacts are analyzed, the analysis heavily relies on the "campus supervisor" to be able to direct traffic flow and clear a way for emergency vehicles. From the DEIR, it appears the supervisor will only be directing traffic during peak hours in the morning and afternoon. It is also unclear what measures they can and will be trained to take to timely permit emergency vehicle access to the campuses. For instance, ACT has serious concerns about the single-lane roadway at the site improvements to Argonaut High School. How can emergency vehicles navigate that? Please add additional information and analysis on this issue and incorporate any possible mitigation measures.

Please make these corrections to have a legally adequate CEQA document.

C. Traffic Impact Mitigation Measures

1. The DEIR Traffic Impact Mitigation Measures are Improperly Deferred.

For identified significant impacts, CEQA requires a lead agency to adopt all feasible mitigation measures that could decrease or avoid the impact, or else provide an explanation for their rejection supported by K
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substantial evidence in the record and a statement of overriding considerations. (Guidelines, §§ 15126.4, 15041, 15091 and 15093.)
Mitigation measures may either be expressly identified in the EIR or else carefully deferred by including performance metrics and a list of mitigation measure options. (Guidelines, § 15126.4(a)(1)(B); Oakland Heritage Alliance v. City of Oakland (2011) 195 Cal.App. 4th 884, citing California Native Plant Society v City of Rancho Cordova (2010) 172 Cal.App.4th 603 ['"[W]hen a public agency has evaluated the potentially significant impacts of a project and has identified measures that will mitigate those impacts! and has committed to mitigating those impacts, the agency may defer precisely how mitigation will be achieved under the identified measures pending further study."].) Where an EIR improperly defers mitigation, the approving agency abuses its discretion by failing to proceed as required by law. (Golden Door Properties, LLC v. County of San Diego (2020) 50 Cal.App.5th 467, 519 citing Communities for a Better Environment v. City of Richmond (2010) 184 Cal.App.4th 70, 89-90.) The important thing is that the public agency commits itself, in the EIR, to a definitive plan.

The situations in which a lead agency may adopt a deferred mitigation measure are narrow, but not impossible. A lead agency may properly defer the specific details of mitigations "when it is impracticable or infeasible" to include those details during CEQA review, but only if the agency ' (1) commits itself to the mitigation, (2) adopts specific performance standards the mitigation will achieve, and (3) identifies the type(s) of potential action(s) that can feasibly achieve that performance standard and that will be considered, analyzed, and potentially incorporated in the mitigation measure.'" (Golden Door Properties, supra, 50 Cal.App.5th at 518-519 quoting Guidelines, § 15126.4(a)(1)(B); see also, Sacramento Old City Assoc. v. City Council of Sacramento (1991) 229 Cal.App.3d 1011.) This is all to say that a lead agency is not necessarily required to have an exact plan for mitigation or an overly technical one, that's only the first option. The second option is the agency can instead choose to state a performance standard it will meet and state a menu of legitimate options the agency will choose from to meet that standard, with evidence in the record supporting its standard and options.

The DEIR simply states that the District will develop a Transportation Demand Management Plan in order to manage transportation impacts and noise. (DEIR, § 5.15.4; see GHD Report, p. 5.) There is no performance standard that the District has committed to. There is no timeline for the District to develop such a plan. There is no party identified responsible for implementing it. There is no list of possible mitigation measures to choose from. When will this plan be created? What are the parameters that will ensure impacts will actually be mitigated? How will this be enforced? How much of the impact will be mitigated? This mitigation measure, as drafted, is illusionary and fails to reach the level of specificity required by CEQA and is improper deferral. (See Guidelines, § 15126.4(a)(1)(B).) Please revise and provide additional information in order to be legally adequate.

2. The DEIR Must Discuss the Feasibility of All Mitigation Measures Presented to the District.

As discussed above, even though the DEIR analysis of traffic safety impacts is inadequate, there are more than likely significant impacts to traffic safety. Where a significant impact is identified, the District is required to consider all mitigation measures to decrease the impact or else explain why it is infeasible. (Guidelines, §§ 15126.4, 15041, 15091 and 15093.)
K
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February 13, 2024

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In the course of letters, communications, and meetings on this matter, multiple mitigation measures have been presented to the District by various parties. By way of this letter, ACT expressly requests that the District consider at least the following mitigation measures to Project traffic impacts and either adopt the measure or explain why it is infeasible:

Designate a certain number of days each month as "study from home" days, which would reduce the VT impact of the Project.

Require students from some parts of the County to use school buses that would serve specific pickup locations.

Establish park-and-ride lots around the County to encourage carpooling. • Contribute the Project's fair share to the proposed southward extension of Wicklow Way, which would offer a new route to Argonaut High School that does not pass through the SR 88/Argonaut Lane intersection (See GHD Report, p. 6; GHD Slides, slides 22 and 28). Work with the County to design the extension in a mutually-beneficial manner.

Contribute the Project's fair share to improvements to the SR 49/Argonaut Lane intersection.

Contribute the Project's fair share to improvements to the SR 49/Hoffman Street Lane intersection.

Contribute the Project's fair share to improvements to the Sutter Street extension (See GHD Slides, slide 23.)
Review and discuss all ideas for mitigation measures to transportation impacts prepared by the California Air Pollution Control Officers Association "Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity" (See GHD Report, p. 5-6.)
Incorporate into Project designs an expanded and extended drop-off area at each campus, which separates individual drop-offs from busses.
• Discuss and confirm the mitigative effects of the District's acquisition and use of electric busses, mentioned by you, Mr. Critchfield, during our meeting February 12, 2024.

Discuss and confirm the mitigative effects of the, allegedly, more efficient bussing routes as a result of the Project mentioned by you, Mr. Critchfield, during our meeting February 12, 2024. • Discuss and confirm the mitigative effects of the District redrawing school lines, mentioned by you, Mr. Critchfield, during our meeting February 12, 2024. 3 Available at: https://www.airquality.org/ClimateChange/Documents/Handbook%20Public%20Draft_2021-Aug.pdf 2460391.9
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Re: Consolidation DEIR
February 13, 2024

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• Seek input from local public agencies on existing and anticipated projects for which they are lead agencies and the District may support with a resulting mitigation to traffic impacts.

Analyze and adopt, or else explain why infeasible, all mitigation measures to the significant traffic safety impacts of the Project presented to the District.

The VMT Threshold Is Unsupported
In order to identify an environmental impact and determine if the impact is "significant" or "substantial" requiring mitigation, the proper threshold must be identified and utilized. (Guidelines, §§ 15064(b) and 15064.7.) While the identification of the threshold of significance is generally at the discretion of the lead agency, it must be supported by explanation on "how compliance with the threshold means that the project's impacts are less than significant." (Id. at § 15064(b)(2).) As explained in the GHD Report, Section 5.15.3.1 of the DEIR states, "There are no established significance criteria for schools, so this analysis uses no increase in the VMT per student for the impact criteria." Nothing is said about the origin of this threshold, and no substantial evidence is presented to support it, as required under CEQA. (Guidelines, S§ 15064.7 and 15064(b)(2).) There are other issues with this threshold. For one thing, it completely omits consideration of the VMT associated with other travelers to the school. This includes parents, school employees, vendors, people who attend sporting and other events held at the school, etc., all of whom will be affected by the project.

According to the Big Data web service Replica, about 36% of the trips taken to school sites in Amador County are for purposes other than attending school. The most common other purpose is work trips, accounting for 22% of trips to a school.

The threshold is problematic even for the one thing it does cover - student travel. The State's greenhouse gas reduction goals require a decrease to 40% below 1990 levels by 2030. According to CARB's most recent Scoping Plan for achieving these goals, "Accordingly, VMT reductions will play an indispensable role in reducing overall transportation energy demand and achieving the state's climate, air quality, and equity goals." Merely maintaining the current levels of VMT production is no longer good enough for projects going forward. CARB suggests that we need to, "Achieve a per capita VMT reduction of at least 25 percent below 2019 levels by 2030 and 30 percent below 2019 levels by 2045." At a minimum, the DEIR must cite substantial evidence to support the chosen threshold. It should also explain why a reduction in VMT is not being pursued when CARB says that it is needed. Per Guidelines section 15064(b)(2) "Compliance with the [VMT] threshold does not relieve a lead agency of the obligation to consider substantial evidence indicating that the project's environmental effects may still be significant."
The District may believe that issues around the VMT threshold are moot because the impact was determined to be significant even with the limited threshold they applied, and they are planning to issue a Statement of Overriding Considerations in any case. The first problem with that is even when a project's benefits outweigh its unmitigated effects, agencies are still required to implement all mitigation measures unless those measures are truly infeasible. (King & Gardner Farms, LLC v. County of Kern (2020) 45 Cal.App.5th 814, 852.) The second problem with that approach is that an EIR is an informational document as well as a policy document. It must disclose to the public and to policy makers all of the likely 2460391.9
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Re: Consolidation DEIR
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impacts of the project, and only then describe what mitigation will or will not be done; otherwise, no one can assess what is being overridden. A lax or incomplete threshold can mislead the reader into underestimating the effects of a project, causing the DEIR to fail as an informational document. So, the issue of the threshold, which measures impacts against State goals, is far from moot.

E. Premature Project "Approval" and County Letter
We are aware that the County submitted a comment letter on the DEIR alleging, among other things, that the District made an illicit commitment to carry out the Project prior to completing CEQA review. (Letter from Deputy County Counsel Glenn Spitzer dated Feb. 9, 2024 "Comments on DEIR for School Closure/Consolidation Project", hereafter "County Letter".) ACT expressly incorporates the issues raised in the County Letter by reference as if set forth herein in full. Specifically, in the County Letter, the County alleges that the District's May 24, 2022 vote to approve school consolidation was approval of a "project" pursuant to CEQA and that was illegal pursuant to statute, the Guidelines, and caselaw. (See, PRC, § 21065; Guidelines, §§ 15352(a) and 15378(a); Save Tara v. City of West Hollywood (2008) 45 Cal.4th 116, 130.) ACT agrees and, notably, ACT raised the same concern in its October 12, 2022 letter - the District has been set on a course since before CEQA analysis even began and such pre- determination violates CEQA and violates the public's trust in the District. This is concerning because premature commitment to a project limits the lead agency's ability to incorporate mitigation measures or alternatives and completely frustrates the CEQA public review and comment process.

Guidelines section 15004 "Time of Preparation" reads:
(a) Before granting any approval of a project subject to CEQA, every Lead Agency ... shall consider a final EIR or Negative Declaration or another document authorized these Guidelines to be used in the place of an EIR or Negative Declaration. (See: The definition of "approval" in Section 15352)
(b) Choosing the precise time for CEQA compliance involves a balancing of competing factors.

EIRs and negative declarations should be prepared as early as feasible in the planning process to enable environmental considerations to influence project program and design and yet late enough to provide meaningful information for environmental assessment. (2) To implement the above principles, public agencies shall not undertake actions concerning the proposed public project that would have a significant adverse effect or limit the choice of alternatives or mitigation measures, before completion of CEQA compliance.
(Emphasis added.) For the purposes of CEQA, '''approval' means the decision by a public agency which commits the agency to a definite course of action in regard to a project intended to be carried out by any person... Legislative action in regard to a project often constitutes approval." Thus, the District was required to complete CEQA review, whatever course of action staff identified, on or before project approval.

At its May 24. 2022 meeting, the District Board of Trustees took formal action to approve the District consolidation plan. Included in the agenda packet was site master plans for multiple campuses, Project 2460391.9
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Re: Consolidation DEIR
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phasing data, and a Project anticipated timeline. This is clear evidence of an intended course of action and plainly absent is any CEQA analysis or consideration, or at the very least direction to staff to complete the CEQA review process. Absent CEQA review, the Board May 24, 2022 action violated CEQA.

During the February 12, 2024 meeting, District counsel asserted that the District was not required to conduct CEQA review prior to the May 24, 2022 meeting because staff needed sufficient information to determine if a categorical exemptions may apply. This is immaterial to the timing issue. The District is required "before granting any approval" to "consider a final EIR...or other document." (Guidelines, § 15004(a); see also Lozano Smith "CEQA for School Districts" (Jan. 2018).) If the District were to rely on an exemption, the proper time to make that determination was before committing the District to a definite course of action on May 24, 2022.

Premature commitment to a Project completely frustrates the CEQA public comment and review process - when the District is committed to a certain course, it is limited in the manners that it can reply to public comment or adopt mitigation measures. Please provide evidence in the DEIR that all reasonable alternatives to the Project were considered and the reason that they were each rejected.

The DEIR Must Be Recirculated Once the Requisite Analysis and Mitigation is Incorporated.

Considering the existing deficiencies in the DEIR described in this letter, recirculation of at least portions of the DEIR will be required. "A lead agency is required to recirculate an EIR when significant new information is added to the EIR after public notice is given... but before certification." (Guidelines, § 15088.5(a), emphasis added.) Significant new information is where the "EIR is changed in a way that deprives the public of a meaningful opportunity to comment upon a substantial adverse environmental effect of the project or a feasible way to mitigate or avoid such an effect.... 'Significant new information' requiring recirculation include, for example, a disclosure showing... a substantial increase in the severity of an environmental impact... [or] a feasible project alternative or mitigation measure considerably different from others previously analyzed would clearly lessen the environmental impacts of the project, but the project's proponents decline to adopt it." (Ibid.) Because there are entire impacts and mitigation measures, such as the traffic safety impacts discussed above, that the DEIR fails to discuss entirely, recirculation of this new analysis will be required.

G. Conclusion
ACTC is not asking that the District study every traffic issue in the entire County, or to pay more than their fair share for improvements. Instead, ACT is asking that the District properly study, analyze, and mitigate where possible how the Project will exacerbate existing traffic, transportation, and traffic safety issues. The District has been made aware through multiple mediums and experiences that this Project will have unanalyzed and unmitigated traffic impacts and is presented with further substantial evidence with this letter. ACT respectfully requests that the District analyze these impacts and mitigate them fully and recirculate the DEIR, or portions that are updated.

Please consider the issues raised in this comment letter and incorporate meaningful analysis and mitigation measures into the final EIR.

K
2460391.9
Jared Critchfield
Re: Consolidation DEIR
February 13, 2024

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Thank you for your consideration,

KRONICK, MOSKOVITZ, TIEDEMANN & GIRARD
A Professional Corporation
EDWARD A. GRUTZMACHER

ATTACHED
- Oct. 12, 2022 letter from ACTC counsel M. Ebrahimi to J. Critchfield - Dec. 7, 2022 letter from ACT counsel M. Ebrahimi to J. Critchfield - Jan. 23, 2023 letter from ACT counsel M. Ebrahimi to ACUSD Board - March 2, 2023 letter from ACT counsel C. Beecham to ACUSD counsel M. Cannon, A. Collins - July 12, 2023 letter from ACT counsel C. Beecham to J. Critchfield - July 12, 2023 letter from Caltrans Chief G. Ponce to Superintendent T. Gibson - Jan. 23, 2024 letter from Caltrans to J. Critchfield
- Feb. 13, 2024 GHD Technical Memo re Peer Review of Traffic Analysis in Project DEIR - Jan. 31 & Feb. 12, 2024 GHD Slides from ACUSD, et al. meeting

E-MAIL COPY TO
- Julia Burns, ACUS Board President ([email protected]) - Jim Whitaker, ACUSD Board Clerk ([email protected])
- James Marzano, ACUSD Board Trustee ([email protected]) - Kayla Parker, ACUSD Board Trustee ([email protected]) - Shane Crowe, ACUSD Board Trustee ([email protected]) - Dr. Torie F. Gibson, ACUSD Superintendent (torie. [email protected]) - Patrick Crew, ACTC Chairperson ([email protected])
- Steve McLean, ACTC Vice Chairperson ([email protected]) Susan Bragstad, ACTC Commissioner ([email protected]) Richard Forster, ACT Commissioner ([email protected]) - Dan Riordan, ACTC Commissioner ([email protected]) John Plasse, ACT Commissioner ([email protected])
John Gedney, ACT Executive Director ([email protected]) K
2460391 9

IKRONICK

KRONICK

MOSKOVITZ

TIEDEMANN
MONA G. EBRAHIMI
[email protected] & GIRARD
October 12, 2022
VIA E-MAIL AND U.S. MAIL
Jared Critchfield, Deputy Superintendent
Amador County Unified School District
Amador County Office of Education
217 Rex Avenue
Jackson, CA 95642
E-Mail: [email protected]
Re: Amador Consolidated High School Plan
Dear Mr. Critchfield:

As you are aware, we represent the Amador County Transportation Commission ("ACT) related to its interests in the Amador County School District's ("District") plan for Amador Consolidated High School ("Consolidation Plan" or "Project"). This follows ACT's Board meeting of October 6, 2022, wherein the Board was able to share some of ACT's concerns regarding the proposed Project as well as an approach moving forward, including the District's anticipated compliance with the California Environmental Quality Act ("CEQA").

ACTC is a State-designated regional transportation planning agency. Its mission includes the protection and advancement of local, regional, and intrastate travel for the benefit of Amador County residents, workers, business people, and visitors. In reviewing the District's Consolidation Plan, as set forth on the District's public website, it is clear the Consolidation Plan "has the potential for resulting in either a direct physical change in the environment or a reasonably foreseeable indirect physical change in the environment." (Pub. Resources Code, § 21065; CEQA Guidelines § 15378(a).) Hence, environmental review is required. ACT has identified numerous traffic impacts that will result from the Project, which will need to be analyzed and mitigated through the CEQA process.

As discussed, ACT is now informed the District took Board action in May of this year to advance the Consolidation Plan, which may be interpreted as approval of the Project without having first completed the CEQA process. (See Save Tara v. City of West Hollywood (2008) 45 Cal.4th 116, 130.) "The CEQA Guidelines define 'approval' as 'the decision by a public agency which commits the agency to a definite course of action in regard to a project.' " (Ibid. [citing Cal. Code Regs., tit. 14, § 15352, subd. (a).].) CEQA analysis informs the decision-making process, and should be completed before any Project commitments are made. At the October 6, 2022 ACT meeting, your representatives confirmed that the District was prepared to carry out the Project with or without the bond funding because it has sufficient money. While there are likely additional approvals required, the District should not have committed to the Consolidation Plan without first completing and certifying an Environmental Impact Report ("EIR").

Nevertheless, the District is required to comply with CEQA and complete appropriate and adequate environmental review, including, but not limited to, mitigating all traffic impacts, before advancing any further approval of the Project, and most certainly before the Project is operational. It is completely inappropriate to attempt mitigation after the Project is already operational. 1331 Garden Hwy, 2nd Floor | Sacramento, CA 95833 | T. 916.321.4500 | F. 916.321.4555 www.kmtg.com 2300223.1 14465-001
Jared Critchfield
October 12, 2022

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To assist in your review, and as a responsible agency for purposes of CEQA, ACT has identified the following impacts and potential mitigation measures. A necessary traffic study will likely identify additional impacts and new and different mitigation measures and this list is not exhaustive. • Impacts:
•
• Public safety impacts are likely to result from increasing the number of students in a single location.

Traffic impacts to numerous local, regional, and state highway intersections from increased student enrollment at consolidated schools. Students presently walking to schools will now be forced to travel by car.
• Potential Mitigation:

An expanded and extended drop-off area, which separates individual drop offs from busses.

Automated gates.
••. An internal circulation plan that contemplates emergency circumstances.

Fair-share contributions towards off-site roadway improvements.

ACT reiterates its request to receive notice of any Project action, including any notices of preparation r other CEOA documents
mitigation measures are implemented to reduce any impacts from the Project to less than significant.

Very truly yours,

KRONICK, MOSKOVITZ, TIEDEMANN & GIRARD
A Professional Corporation
Mona shi
MONA G. EBRAHIMI
MGE/dIc
cc: Torie F. Gibson, Ed.D., ACUSD Superintendent - [email protected] Amy Gedney, Sutter Creek City Manager - [email protected] Gregoria Ponce, Caltrans - District 10 Local Intergovernmental Review Senior Transportation Planner - [email protected]
Chuck lley, Amador County Administrative Officer - [email protected] 2300223.1 14465-001

IKRONICK

KRONICK

MOSKOVITZ

TIEDEMANN
MONA G. EBRAHIMI
[email protected] & GIRARD
December 7, 2022
VIA E-MAIL AND U.S. MAIL
Jared Critchfield, Deputy Superintendent
Amador County Unified School District
Amador County Office of Education
217 Rex Avenue
Jackson, CA 95642
E-Mail: [email protected]
Re: Amador Consolidated High School Plan-Brown Act Cure and Correct/Cease and Desist Letter and CEQA Notice
Dear Mr. Critchfield:

This is a follow up to our letter of October 12, 2022, sent on behalf of the Amador County Transportation Commission (ACT") regarding the Amador County School District's ("District) plan for Amador Consolidated High School ("Consolidation Plan" or "Project").

As an initial matter, we have not received any response to our prior correspondence. This includes any notice of preparation or other notice of commencement of environmental review under the California Environmental Quality Act ("CEQA") as requested at the ACT Board meeting of October 6, 2022, and reiterated in our letter. We repeat that ACT is not taking a position on the merits of the proposed Project, however, there are clear and significant impacts to traffic resulting from the proposed Project, which will need to be appropriately analyzed and mitigated. ACT remains ready to participate in the District's process to ensure reasonable and effective mitigation measures are implemented.

We further note there were multiple Brown Act deficiencies related to the District's purported approval of the proposed Project in May of 2022, including the failure to properly agendize the item for approval or provide any CEQA determination. Accordingly, ACT was only informed of the District's purported approval by your and Ms. Gibson's representations at the October 6, 2022 ACT meeting, which were paired with a promise that the District would undertake appropriate environmental review and mitigation.

The District's failure to properly and accurately agendize action items prevents ACT and the public from even knowing what will be discussed and/or acted upon at a board meeting. As such, this letter serves as a cease and desist notice and request to cure and correct your past Brown Act violation. Specifically, on May 24, 2022, the Board voted 5 to 2 in favor of a discussion/action item described only as "School Consolidation." Actually, this matter was first agendized for the May 11, 2022 meeting, but was voted down to be brought back on June 8, 2022 (not May 24). Then, at the May 24, 2022 meeting, the Board 1331 Garden Hwy, 2nd Floor | Sacramento, CA 95833 T. 916.321.4500 | F. 916.321.4555 www.kmtg.com 2325121.3 14465-007
Jared Critchfield
Re: Amador Consolidated High School Plan
December 7, 2022

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considered this matter, and it was agendized only as "School Consolidation". Nothing in this description includes a CEQA determination or possibility of action on the Project, as required by the Brown Act.

The recent court decision of G.I. Industries v. City of Thousand Oaks, 2d Civ. No. B317201 (October 26, Please provide us with notice of this meeting, along with notice of any Project action, including any notices of preparation or other CEQA documents, as well as notice of any Project meetings, discussions, reviews, or approvals. We look forward to receipt of appropriate notices (both CEQA and other approvals or developments) so that we may effectively participate in the required environmental review and analysis of the proposed Project.

Finally, as a result of the bond measure not passing this election, we were made aware that the District may be seeking to use traffic impact fees for projects unrelated to the purposes for which the impact fees were collected. Such use of impact fees is illegal under the Mitigation Fee Act. (Gov. Code, §§ 66001, 66006, 66008.) We urge the District to review the purposes for which any developer impact fees were collected and ensure that any expenditure of those fees comply with the Mitigation Fee Act and other applicable regulation. Traffic fees should be used for the purpose for which they were collected.

If you have any questions concerning the above-referenced matters, please contact me.

Very truly yours,

KRONICK, MOSKOVITZ, TIEDEMANN & GIRARD
A Professional Corporation
Mona
MONA G. EBRAHIMI
MGE/las
CC: Torie F. Gibson, Ed.D., ACUSD Superintendent - [email protected] Yvonne Kimball, Jackson City Manager - [email protected] Amy Gedney, Sutter Creek City Manager - [email protected] Michael Rock, lone City Manager - [email protected]
Gregoria Ponce, Caltrans - District 10 Local Intergovernmental Review Senior Transportation Planner - [email protected]
Chuck lley, Amador County Administrative Officer - [email protected] 2325121.3 14465-007

IKRONICK

KRONICK

MOSKOVITZ
MONA G. EBRAHIMI TIEDEMANN
[email protected] & GIRARD
January 23, 2023
VIA E-MAIL AND U.S. MAIL
Julia Burns, President ([email protected])
Jim Whitaker, Clerk ([email protected])
James Marzano, Trustee ([email protected])
Kayla Rae Parker, Trustee ([email protected])
Shane Crowe, Trustee ([email protected])
Amador County & Unified School District - District Office 217 Rex Avenue
Jackson, CA 95642
Re: Amador Consolidated High School Plan - CEQA Compliance, Brown Act Compliance Dear Board of Trustees:

I am contacting you on behalf of my client, the Amador County Transportation Commission ("ACT") regarding the Amador County School District's ("District") anticipated Amador Consolidated High School Plan ("Consolidation Plan" or "Plan").

By way of background, ACT is the Regional Transportation Planning Agency and Local Transportation commission to Amador County. ACTO's mission includes the protection and advancement of local, regional, and state travel to the benefit of County citizens, visitors, and guests. In this vein, it is ACT's responsibility to advocate for smart planning that is a catalyst for fluid, unimpeded traffic in the present and future.

ACTC is concerned about the Consolidation Plan's impacts to traffic and is eager to aid the District in identifying and mitigating any such impacts as required by the California Environmental Quality Act, Public Resources Code section 21000 et seq. ("CEQA"). Indeed, ACT sent letters to Deputy Superintendent Jared Critchfield on October 12, 2022 and on December 7, 2022 expressing the same concerns, among other things. Neither ACT commissioners, staff, nor I received a response to either letter. Copies of those letters are attached hereto for your further consideration.

I am reaching out again in hopes that you, the new District Board of Trustees ("Board"), are receptive to ACT's offer to collaborate and ensure all Consolidation Plan traffic impacts are identified and mitigated in compliance with CEQA. It has come to ACT's attention that the Board already took steps to advance the Consolidation Plan. As early as May of this past year, the Board approved the options for the Consolidation Plan. It is unclear what, if any, environmental analysis was done at that time. As you know, CEQA requires that a lead agency consider all impacts to the environment prior to taking any action that commits the agency to a definitive course of action. (14 CCR § 15352.) 1331 Garden Hwy, 2nd Floor | Sacramento, CA 95833 T. 916.321.4500 | F. 916.321.4555 www.kmtg.com 2333989.2 14465.007
Board of Trustees, Amador County & Unified School District Re: Amador Consolidated High School Plan
January 23, 2023

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On January 18, 2023, the Board passed a resolution apparently approving the Consolidation Plan. That Resolution expressly delayed CEQA environmental review until a later date. The District may not piece- meal aspects of the Consolidation Plan and evade CEQA and/or other laws. To the extent you have any CEQA analysis conducted, please provide all documentation related to the Board's May 2022 and January 2023 approvals related to the Consolidation Plan, including, but not limited to, any documentation of traffic impact analysis and mitigation of such impacts. 1 ACTC is legally obligated to and would like to work with you to ensure that all traffic impacts are identified, analyzed, and mitigated in order to preserve local and regional traffic flow. ACT has specialized knowledge and experience in such matters, as well as a responsibility to advocate for the same, and is eager to be a resource to the District. Please respond with information on how the District intends to comply with CEQA in approving the Consolidation Plan, especially as it relates to traffic impacts, as well as with information on how ACT can be part of that process. will repeat themselves. Specifically, the Consolidation Plan was agendized for the May 11, 2022 Board meeting. During that meeting, it was voted down to be brought back on June 8, 2022. Then, at the May 24, 2022 Board meeting, it was agendized, the Board considered the matter, and the Board voted 5 to 2 in favor of approval. Both times the Plan was agendized, it was only described as "School consolidation" with no mention of a CEQA determination or possibility of Board action on the Plan.

The Brown Act requires factually accurate and sufficient information be on an agenda to inform the public of what is going to be discussed. (Gov. Code, § 54954.2(a)(1) [each agenda item required to contain "brief general description"]; id. at (3) ['no action or discussion shall be undertaken on any item not appearing on the agenda"].) Here, the District failed - the agenda description was fragmentary, lacking in relevant detail, and did not mention any proposed action. Further, the Board failed to abide by its own instruction - saying it would discuss the matter in June but actually discussed and approved it sooner.

This is misleading to the public and contrary to the spirit of the Brown Act. As such, this letter is, first, a cease and desist notice for the Board to stop violating the Brown Act and, second, a request that you cure and correct the past violations by re-agendizing and reconsidering the Consolidation Plan in a manner that complies with the Brown Act.

Finally, please include ACT as well as me in all future public communications, meeting notices, and CEQA notices related to the Consolidation Plan. (Gov. Code, § 54954.1; Pub. Res. Code, § 21092.2.) | requested the same in the December 7, 2022 letter and failed to receive any notice related to the January 18, 2023 meeting. You may provide such notice electronically to [email protected] and [email protected].

Please respond to the matters raised in this letter no later than January 31, 2023. If I do not hear back from you before that date, ACT may resort to all remedies available to it in law and equity. 1 Please treat this as a request for records pursuant to the California Public Records Act, Government Code section 7920.000 et seq.
2333989.2 14465.007
Board of Trustees, Amador County & Unified School Distric le: Amador Consolidated High School Pla
January 23, 2023

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Very truly yours,

KRONICK, MOSKOVITZ, TIEDEMANN & GIRARD
A Professional Corporation
Mona sti
MONA G. EBRAHIMI
Attached:

October 12, 2022 Letter to Deputy Superintendent J. Critchfield December 7, 2022 Letter to Deputy Superintendent J. Critchfield Torie F. Gibson, Ed.D., ACUSD Superintendent - torie. [email protected] Yvonne Kimball, Jackson City Manager - [email protected] Amy Gedney, Sutter Creek City Manager - [email protected] Michael Rock, lone City Manager - [email protected]
Gregoria Ponce, Caltrans - District 10 Local Intergovernmental Review Senior Transportation Planner - [email protected]
Chuck lley, Amador County Administrative Officer - [email protected] 2333989.2 14465.007

IKRONICKI

KRONICK

MOSKOVITZ

TIEDEMANN

CARISSA BEECHAM
[email protected] & GIRARD
March 2, 2023

VIA ELECTRONIC MAIL ONLY
Michelle Cannon
Anne Collins
Counsel for ACUSD
[email protected]
[email protected]
Re: ACUSD Consolidated High School Plan
Dear Counselors:

As you are aware, this firm serves as counsel to Amador County Transportation Commission ("ACT").

On ACT's behalf, we have sent three letters to the Amador County Unified School District ("ACUSD" or "District") regarding the District's Amador Consolidated High School Plan ("Project"). We received a letter from ACUSD Superintendent Dr. Torie Gibson on January 26, 2023 that instructed we send further communications regarding the Project to you as ACUSD's counsel. For ease of reference, we are attaching each of our prior letters to ACUSD regarding the Project.

While we appreciate Dr. Gibson's letter and the information provided therein, ACT remains significantly concerned that the District is continuing to move the Project forward without completing the necessary environmental review required by the California Environmental Quality Act, Public Resources Code section 21000 et seq. ("CEQA"), despite repeated assurances otherwise.

Brown Act Violation
Dr. Gibson, on behalf of the District, provided an unconditional commitment to cease, desist from, and not repeat any violation of the Brown Act related to posting factually-accurate and sufficiently-detailed agenda items. ACT appreciates this, thank you.

Dr. Gibson noted that meeting information is available on the District's website. It is unreasonably difficult to find information on agenda items on the District's website. On the homepage, a user has to scroll down and click on the agendas link, which takes them to a general online board meeting agenda site. Then the user has to find and click a second link to actually get to the agendas page. Once they identify the past meeting, clicking the document icon only reveals the meeting minutes, no information on the agenda item except the title. To see the actual agenda information quoted, a user has to find and click agenda from the side bar, scroll to the item, click it to reveal documents in a drop-down, and click that drop down item. Only after navigating through four pages can a user find the information she quotes. As you know, the Brown Act requires a local agency either have the agenda posted on website 1331 Garden Hwy, 2nd Floor | Sacramento, CA 95833 T. 916.321.4500 | F. 916.321.4555 www.kmtg.com 2347618.2 14465-007
March 2, 2023

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homepage or else post a direct link to the integrated agenda management platform that, when clicked, takes the user directly to the platform. (Gov. Code, § 54954.25(a)(2)(C).) Further, the spirit of the Brown Act promotes transparency and accessibility for all members of the public to be appraised of public agency deliberations.

II. Renewed Request for Notice
ACTC requested notice of any Project action, including any notice of preparation or any other CEQA documents, as well as notice of any Project meetings, discussions, reviews, or approvals. ACTC requested notice in its October 12, 2022 letter and received no response or notice related to the Project. ACT renewed this request in its December 7, 2022 letter. ACT received no response ol notice of the January 18, 2023 meeting where the District Board resolved to approve the Project.

ACTC renewed the request again in its January 23, 2023 letter with specific citation to Government Code section 54954.1 and Public Resources Code section 21092.2. It appears that a handful of agenda items on the Board's February 8, 2023 meeting related to the Project. - e.g. "Review and Approval of Consolidated High School Campus Expansion Plan and Preliminary Cost Estimate at Argonaut High School", "Consolidated Administrative Staff". These items clearly fall within the parameters of ACT's request for notice. Still, the District did not provide the requested notice for this meeting.

While Dr. Gibson did not address ACT's request for notice in her January 26, 2023 letter, she noted that "all board meeting agendas are posted on the District's website...." Not only is the District' website unreasonably difficult to navigate, this is insufficient. As you know, when a party expressly requests notice pursuant to statute, it must be provided. ACT expressly requested direct notice of any meeting regarding the Project and any CEQA action regarding the Project. ACTC has made this request three times and reiterates it again now. Pursuant to Government Code section 54954.1 and Public Resources Code section 21092.2, the District has an obligation to provide direct notice of such Project matters to ACTC. Please acknowledge ACT's request and confirm that the District will provide such notice in the future.

III. CEQA Review of the Amador Consolidated High School Plan It appears that the District failed to comply with CEQA in approving the Project on January 18, 2023 without first conducting any environmental review. Indeed, Dr. Gibson admitted the same in her letter - the District has not done any CEQA analysis, does not plan to until later, and intends to do so in a piecemeal fashion. Specifically, Dr. Gibson stated "the Board specifically acknowledged that the particular scope of each phase of the Consolidation Plan is not yet known and that each may be a project subject to CEQA and the District will consider the effects of each to determine whether it will have a significant effect on the environment and such analysis will be brought back to the Board for discussion and appropriate action." The District's past and anticipated future actions violate CEQA.

An agency is prohibited from approving a project prior to analyzing project impacts to the environment in the manner required by CEQA. (PRC §§ 21002, 21080; 14 CCR § 15004(a); Save Tara v. City of W.

Hollywood (2008) 45 Cal.4th 116) The District appears to contend that the Board resolution is not a project under CEQA; it is. A "project" is defined as "an activity which may cause either a direct physical change in the environment, or a reasonably foreseeable indirect physical change in the environment..." (PRC § 21065; Van de Kamps Coalition v. Board of Trustees of Los Angeles Community College Dist. 2347618.2 14465-007
March 2, 2023

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(2012) 206 Cal.App.4th 1036 [resolution authorizing property be made available for rent and lease negotiations to begin a "project"].)
Here, the Amador Consolidated High School Plan subject of the January 18, 2023 resolution is a "project" because the consolidation will cause a direct physical change in the environment. Even if the consolidation is to take place at existing campuses, within the existing buildings' footprints, significantly more students and staff will be on the high school campus and will undeniably cause impacts to traffic, transportation, and overall circulation as they commute to and from the campus. For the same reason, students, staff, and resources are being completely reorganized and redirected. The Amador Consolidated High School Plan detailed in the Board's January 18, 2023 resolution is a "project" as defined by CEQA and must be analyzed in compliance with CEA's mandates.

The District also contends that it is not required to conduct EQA review at this time because the Project is not yet formulated and "that the particular scope of each phase of the Consolidation Plan is not yet known." "Approval" for the purposes of CEQA happens when a public agency makes a decision that "commits the agency to a definite course of action in regard to a project." (14 CCR § 15352(a); Save Tara v. City of W. Hollywood (2008) 45 Cal.4* 116; RiverWatch v. Olivenhain Mun. Water Dist., (2009) 170 Cal.App.4th 1186 [water delivery contract approval "project approval" for failure to reserve agency discretion to disapprove the agreement or require mitigation measures or alternatives after environmental analysis was completed].) Clearly, the District has committed itself to a definite course of action that will have direct impacts on the environment- consolidation. This should not have been done without first completing environmental review.

The Amador Consolidated High School Plan may have many phases, a project of this scale regularly does, however, the District's obligation to conduct CEQA review attached at the moment that the District committed to the Project. The January 18, 2023, resolution memorialized the District's intent to move forward with the Project by expressly directing "the Superintendent or her designee is authorized to move forward with any necessary work to implement the Consolidation Plan, including but not limited to retaining any necessary consultants" as well as authorizing and directing staff to complete environmental analysis. Thus, the District approved the Project on January 18, 2023 and violated CEQA by not conducting environmental analysis prior to taking that action.

Indeed, even if the January 18, 2023 resolution was not "approval," the Board's February 8, 2023 action "Review and Approval of Consolidated High School Campus Expansion Plan and Preliminary Cost Estimate at Argonaut High School" undeniably is project approval as the District is committing time, financial, and other resources to the Project.

Also of note, CEQA prohibits a public agency from dividing a project into small, individual subprojects to avoid the agency's responsibility for considering the environmental impact of the project as a whole. (Orinda Ass'n v. Board of Supervisors (1986) 182 Cal.App. 3d 1145, 1171.) Specifically, CEQA "cannot be avoided by chopping up proposed projects into bite-sized pieces which, individually considered, might be found to have no significant effect on the environment or to be only ministerial." (Tuolumne County Citizens for Responsible Growth, Inc. v. City of Sonora (2007) 155 Cal.App.4th 1214; Bozung v.

LAFCO (1975) 13 Cal.3d 263, 283; City of Carmel-by-the-Sea v. Board of Supervisors (1986) 183 2347618.2 14465-007
March 2, 2023

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Cal.App.3d 229, 251 [county violated CEQA by preparing negative declaration for rezoning and reserving preparation of EIR until later stage of approval]; Citizens Ass'n for Sensible Dev. v County of Inyo (1985) 172 Cal.App.3d 151, 167 [improper bifurcating in negative declaration for shopping center general plan amendment and rezoning followed by later negative declaration for subdivision map and road abandonment for same project, because, by bifurcating review, county failed to examine potential impacts of entire development].) The threshold question is if the activities will operate independently of brothere apor ages, he aniona row acompla
approval must evaluate the impacts of the ultimate development authorized by that approval.

Dr. Gibson indicated, and the same is reiterated in the January 18, 2023 resolution, that the District intends to conduct CEQA review for each phase of the project. Subsequent project-level approvals and the related environmental review will not obviate the District of its obligation to conduct the appropriate level of environmental review related to this initial project approval. CEQA requires the District to consider the effects to the whole action at the first approval, even if not meticulously known at this time. Indeed, this is the exact intent of programmatic EIRs - a lead agency may prepare a program EIR to consider broad programmatic issues for related actions at an early stage of the planning process and thereby facilitate more streamlined environmental review within the program at a project-level of detail later. (14 CCR § 15168(b).) The resolution anticipated the consolidation of all high school students, consolidation of all junior high school students, development of an elementary school site, and development of a preschool hub as well as closing of other District properties. The District was required to consider the environmental impacts of each of these actions pursuant to CEQA prior to adopting the resolution. The District's proposed approach may also result in improper piecemeal review, which is prohibited by CEQA.

Moreover, the District's February 8, 2023 approval does not demonstrate any attempt to complete the required environmental review prior to additional approvals.

IV. Meeting Request
As reiterated in each of ACT's communications to the District on the Project, ACTC is not interested in stopping the Project, only ensuring that all environmental impacts, and specifically those related to traffic, are appropriately analyzed and mitigated. To that end, we request that you agree to a meeting to discuss how the District can address ACT's concerns.

Please respond by Thursday, March 9, 2023 to schedule a meeting for this month.

We specifically ask that you be prepared to discuss at least how and when the District intends to complete a necessary traffic study to inform the required CEQA review.

Should the District continue to dismiss or otherwise fail to address ACT's concerns, ACTO will be required to pursue all available legal remedies.

K
2347618.2 14465-007
March 2, 2023

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Very truly yours,

KRONICK, MOSKOVITZ, TIEDEMANN & GIRARD
A Professional Corporation
Cante

CARISSA BEECHAM
Gregoria Ponce, Caltrans District 10, Sr. Transportation Planner - [email protected] Harlan Reymont, State Architect, Sacramento Regional Manager - [email protected] Yvonne Kimball, Jackson City Manager - [email protected] Amy Gedney, Sutter Creek City Manager - [email protected] Michael Rock, lone City Manager - [email protected]
Attached:

October 12, 2022 Letter to Jared Critchfield
December 17, 2022 Letter to Jared Critchfield
January 23, 2023 Letter to ACUSD Board of Trustees
2347618.2 14465-007

IKRONICK

KRONICK

MOSKOVITZ

TIEDEMANN

CARISSA BEECHAM
& GIRARD
[email protected]
July 12, 2023
ACUSD Office
Attn: Jared Critchfield
217 Rex Avenue
Jackson, CA 95642
[email protected]
Re: Response to Notice of Preparation- School Closure/Consolidation Program Project Dear Mr. Critchfield:

This is in response to the Notice of Preparation for the School Closure/Consolidation Program Project ("Project") issued by the District as Lead Agency under the California Environmental Quality Act ('CEQA"). As you are aware, the Amador County Transportation Commission (ACT") is the Regional Transportation Planning Agency and Local Transportation Commission to Amador County. ACT's mission includes the protection and advancement of local, regional, and state travel to the benefit of County citizens, visitors, and guests. In this vein, it is ACT's responsibility to advocate for smart planning that is a catalyst for fluid, unimpeded traffic in the present and future.

ACTC is pleased that the District will be preparing an environmental impact report ("EIR") for the Project.

ACTC has previously expressed the need for the District to fully study, identify, and mitigate the potential traffic impacts of the Project and repeats those concerns here.

To assist in your review, and as a responsible agency for purposes of CEQA, ACT has identified the following impacts and potential mitigation measures, which should be considered in the EIR. A necessary traffic study will likely identify additional impacts and new and different mitigation measures and this list is not exhaustive.

Impacts:
• Traffic impacts will include increased congestion during drop off and pick up, which increase air pollution from idling and reroute other traffic to longer, alternative routes, increasing vehicles miles traveled (VMT).
• Public safety impacts are likely to result from increasing the number of students in a single location.
• Traffic impacts to numerous local roads and intersections as well as regional and state highways and intersections from increased student enrollment, extracurricular activities, and related uses at consolidated schools. Students presently walking to schools will now be forced to travel by car. 1331 Garden Hwy, 2nd Floor | Sacramento, CA 95833 T. (916) 321-4500 | F. (916) 321-4555 www.kmtg.com 2390810.2 14465.007
ACUSD Office
July 12, 2023

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• Impacts to pedestrian routes for students in the interplay with safe streets.

Potential Mitigation:
• An expanded and extended drop-off area, which separates individual drop offs from busses. • Automated gates.
• An internal circulation plan that contemplates emergency circumstances. • Fair-share contributions towards off-site roadway improvements.

Please continue to keep us informed as the EIR is developed. ACT looks forward to working with the District to ensure that traffic impacts are adequately studied and reasonable and effective mitigatior neasures are implemented to reduce any impacts from the Project to less than significant Very truly yours,

KRONICK, MOSKOVITZ, TIEDEMANN & GIRARD
A Professional Corporation

CARISSA BEECHAM
CB
2390810.2 14465.007

Caltrans appreciates the opportunity to review and respond to the Amador County Unified School District (ACUSD) Notice of Preparation for the proposed School Consolidation project, affecting ACUSD's school campuses, including Amador High School, Sutter School, Jackson Junior High School, lone Elementary School, Jackson Elementary School, and the Sutter Creek Elementary School.

ACUSD provides preschool through 12th grade and adult education services to Amador County. The ACUSD is considering a program to consolidate eight schools onto six campuses. Sutter Creek Primary School and lone Elementary School will be closed for later disposition.

ACUSD proposes to combine Amador High School (HS) and Argonaut HS at Argonaut HS. This would change the enrollment capacity from 925 students to 1,325 students; the school would continue to serve grades 9 through 12. This campus would have site and building improvements to accommodate the increase in enrollment including adding a two-story 10-classroom building (with 4 science labs and 6 standard classrooms), relocate 5 portable classrooms from Jackson Junior HS and lone Elementary School to this campus, convert 2 preschool classrooms to regular classrooms, convert a classroom for counseling office, renovate and expand the kitchen, and renovate and expand gymnasium locker rooms. The campus would have a new parent drop-off, new access road connecting to Stony Creek Road, and accessibility compliance improvements throughout the campus.

Also proposed is to combine lone Junior HS and Jackson Junior HS at Amador HS. This change would not affect the enrollment capacity (875 students) of the campus nor the number of teaching stations (35 teaching stations). The campuses would serve grades 7 through 8 instead teaching stations (35 teaching stations). "Provide a safe and reliable transportation network that serves all people and respects the environment" Tore F. Gibson, Ed.D., Superintendent
July 12, 2023

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Also proposed is to relocate lone Elementary School to lone Junior HS and would add preschool and transitional kindergarten (K), and grades 1 through 5, to the campus.

This would change the enrollment capacity of the campus from 775 students serving grades 6 through 8 to 801 students serving preschool and grades TK through 6. This campus would also have site and building improvements to accommodate the increase in enrollment including adding 2 new classroom buildings and playground for preschool, TK, and Extending Learning; convert science labs to kindergarten classrooms; and convert restrooms to kindergarten restrooms. Also planned is expanding the parent drop-off/pick-up areas, the kindergarten drop-off area, the kitchen, and construct a new play structure and hardcourt areas.

Jackson Junior HS would be converted into the County Preschool Center. This would change the enrollment capacity and grade levels from 475 students in grades 6 through 8 to 195 preschool and transitional kindergarten students. The number of teaching stations would decrease from 19 to 15. Restrooms and fountains would be converted to age-appropriate fixtures.

ASUCD would add 6th grade to Jackson Elementary School. The enrollment capacity of 575 students and 23 teaching stations would remain the same.

Expansion is planned for Sutter Creek Elementary School to create a TK through 6th grade campus. This would increase the enrollment capacity from 325 students in grades TK through 2 to 625 students in grades TK through 6. To accommodate the increase in students, a new classroom building with 12 classrooms and a lunch shelter would be constructed.

The project areas include Amador City, lone, Jackson, Plymouth, Sutter Creek, and unincorporated regions within the County.

Caltrans at this time has the following comments:

Environmental
If any construction-related activities encroach into Caltrans Right of Way (ROW), the project proponent must apply for an Encroachment Permit to the Caltrans District 10 Encroachment Permit Office. All California Environmental Quality Act ICEQA) documentation, with supporting technical studies, must be submitted with the Encroachment Permit Application. These studies will analyze potential impacts to any cultural sites, historic properties, biological resources, hazardous waste locations, scenic highways, and/or other environmental resources within Caltrans ROW at the project site(s).
"Provide a safe and reliable transportation network that serves all people and respects the environment" Torie F. Gibson, Ed.D., Superintendent
July 12, 2023

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Hydrology
We request to review the pre- and post-construction runoff calculations and drainage plans to understand flow patterns. Once drainage plans and calculations are submitted for Argonaut High School, lone Jr. High School, and Sutter Creek Elementary School improvements, additional review will be done.

Traffic Operations
Senate Bill 743 is changing the California Environmental Quality Act (CEQA) analysis of transportation impacts. It requires local land use projects to provide a safe transportation system, reduce per capita Vehicle Miles Traveled (VMT), increase accessibility by mode share of bicycle, pedestrian, and transit travel, and reduce greenhouse gas (GHG) emissions. VMT reduction is necessary to meet the statewide GHG. Caltrans recommends VMT per capital thresholds are 15% below existing regional VMT per capita. A Traffic Impact Study (TIS) will need to include VMT analysis (including induced travel demand) to determine the significance of those impacts and identify potential mitigation measures. Caltrans also recommends the establishment of programs or methods to reduce VMT and support appropriate bicycle, pedestrian, and transit infrastructure.

This project may significantly change traffic patterns. Thus, a VMT study will be required for CEQA analysis. The VMT study should include VMT mitigation measures. Some possible VMT mitigation measures include school buses, shuttle buses, transit bus programs, and bike & pedestrian facility improvement that promotes walking & biking to school.
• In addition to the VMT analysis, the proposed project needs to conduct the queue analysis at the intersections of State Route (SR) 49/Hoffman St, SR 49/Sutter St, and SR 88/Argonaut Lane to analyze the potential safety impacts of the project, as it may significantly change the traffic patterns. The queue analysis will determine if any left-turn/right-turn storages at these intersections can accommodate • The queue analysis, at minimum, needs to provide the following:
•Existing turning movement traffic count, including pedestrians/students (AM & PM • Trip generation and trip distribution of the proposed project, including the estimation of the number of students who will use crosswalks at SR 49/Hoffman St, SR 49/Sutter St, and SR 88/Argonaut Lane
• Synchro/SimTraffic analysis
"Provide a safe and reliable transportation network that serves all people and respects the environment" Torie F. Gibson, Ed.D., Superintendent
July 12, 2023

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Caltrans suggest Amador County and ACUSD continue to coordinate and consult with occur from this project and other developments near this location. This will assist Caltrans public on existing and future state transportation facilities.

Encroachment Permits
If any future project activities encroach into Caltrans ROW, the project proponent must submit an application for an Encroachment Permit to the Caltrans District 10 Encroachment Permit Office. Appropriate environmental studies must be submitted with this application. These studies will include an analysis of potential impacts to any cultural sites, biological resources, hazardous waste locations, and/or other resources within Caltrans ROW at the project site(s). For more information, please visit the Caltrans Website at: https://dot.ca.gov/programs/traffic-operations/ep/applications.

If you have any question or would like to discuss these comments, please contact Paul Bauldry at (209) 670-9488 (email: [email protected]) or me at (209) 483-7234 (email: [email protected]).

Sincerely,
gregoria Poncé
Gregoria Ponce', Chief
Office of Rural Planning
c: Chuck Beatty, Director, Amador County Planning Department State Clearinghouse
"Provide a safe and reliable transportation network that serves all people and respects the environment"

CALIFORNIA STATE TRANSPORTATION AGENCY GAVIN NEWSOM, GOVERNOR California Department of Transportation
OFFICE OF THE DISTRICT 10 RURAL PLANNING
P.O. BOX 2048 | STOCKTON, CA 95201 Caltrans®
(209) 948-7325 | FAX (209) 948-7164 TTY 711
www.dot.ca.gov
January 23, 2024
Jared Critchfield, Deputy Superintendent Environmental Impact Report (EIR) Amador County Unified School District Amador County Unified School 217 Rex Avenue District (ACUSD)
Jackson, CA 95642 SCH 2023060568
Dear Mr. Critchfield,
The California Department of Transportation (Caltrans) appreciates the opportunity to review and respond to the Amador County Unified School District (ACUSD) Environmental Impact Report (EIR) for the proposed School Consolidation project, affecting ACUSD's school campuses, including Amador High School, Sutter School, Jackson Junior High School, lone Elementary School, Jackson Elementary School, and the Sutter Creek Elementary School.

ACUSD proposes to combine Amador High School (HS) and Argonaut HS at Argonaut HS. This would change the enrollment capacity from 925 students to 1,325 students; the school would continue to serve grades 9 through 12. This campus would have site and building improvements to accommodate the increase in enrollment. The ACUSD would add a 2-story, 10-classroom building (with 4 science labs and 6 standard classrooms), relocate 5 portable classrooms from Jackson Junior HS and lone Elementary School to this campus, convert 2 preschool classrooms to regular classrooms, convert a classroom for counseling office, renovate and expand the kitchen, and renovate and expand gymnasium locker rooms. The campus would have a new parent drop-off, new access road connecting to Stony Creek Road, and accessibility compliance improvements throughout the campus.
"Provide a safe and reliable transportation network that serves all people and respects the environment" Mr. Critchfield, Deputy Superintendent
January 23, 2024

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ACUSD proposes to combine lone Junior HS and Jackson Junior HS at Amador HS. This change would not affect the enrollment capacity (875 students) of the campus nor the number of teaching stations (35 teaching stations). The campuses would serve grades through 8 instead teaching stations 35 teaching stations).

ACUSD proposes to relocate lone Elementary School to lone Junior HS and would add preschool and transitional kindergarten (K), and grades 1 through 5, to the campus.

This would change the enrollment capacity of the campus from 775 students serving grades 6 through 8 to 801 students serving preschool and grades TK through 6. This campus would also have site and building improvements to accommodate the increase in enrollment. ACUSD would add 2 new classroom buildings and playground for preschool, TK, and Extending Learning; convert science labs to kindergarten classrooms; and convert restrooms to kindergarten restrooms. ACUSD would also expand the parent drop-off/pick-up areas, expand the kindergarten drop-off area, expand the kitchen, and construct a new play structure and hardcourt areas.

ACUSD would convert Jackson Junior HS into the County Preschool Center. This would change the enrollment capacity and grade levels from 475 students in grades 6 through 8 to 195 preschool and transitional kindergarten students. The number of teaching stations would decrease from 19 to 15. Restrooms and fountains would be converted to age-appropriate fixtures. ACUSD would add fth grade to Jackson Elementary School.

The enrollment capacity of 575 students and 23 teaching stations would remain the same.

ACUSD would expand Sutter Creek Elementary School to create a TK through 6th grade campus. This would increase the enrollment capacity from 325 students in grades TK through 2 to 625 students in grades TK through 6. To accommodate the increase in students, ACUSD would construct a new classroom building with 12 classrooms and a lunch shelter.

The project areas include Amador City, lone, Jackson, Plymouth, Sutter Creek, and unincorporated regions within the County.

Caltrans at this time has the following comments:

Environmental Impact Report
General Comments
If the consolidation results in a physical encroachment into Caltrans right-of-way (ROW), the project proponent must apply for an Encroachment Permit to the Caltrans District 10 Encroachment Permit Office. All California Environmental Quality Act (CEQA) documentation, with supporting technical studies, must be submitted with the "Provide a safe and reliable transportation network that serves all people and respects the environment" Mr. Critchfield, Deputy Superintendent
January 23, 2024

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Encroachment Permit Application. These studies will include an analysis of potential impacts on any cultural sites, historic properties, biological resources, hazardous waste locations, scenic highways, and/or other environmental resources within Caltrans ROW at the project site(s). In addition, CEQA compliance must include climate change analysis and evaluation regarding the change in commutes/traffic that may result from the school consolidation.

Section 5.9 Hydrology and Water Quality: Please provide pre- and post-construction runoff calculations and drainage plans to understand flow patterns. Additional review will be done once drainage plans and calculations are submitted for improvements at Argonaut High School, lone Jr. High School, and Sutter Creek Elementary school.

Appendix J - CEQA Transportation Memorandum

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coordinator to administer the Transportation Demand Management (TDM) program and encouraging the additional use of school buses. The Memo needs to explain how to increase the use of school buses. Since the schools are consolidated into single locations, the school bus service needs to extend to all the cities (lone, Sutter Creek, Jackson, etc.). The mitigation should include improving the school bus services.

Appendix K - Transportation Operations Memorandum
Please provide the following scenarios in the Traffic Operations memorandum:
• Existing Year
• Proposed Project Only (Trip Generation and Assignment) • Existing Year Plus Proposed Project
• Cumulative Conditions without the proposed project
• Cumulative Conditions Plus Proposed Project
• Please provide analysis results for the 95th Percentile Queues. The 95th Percentile Queues and delays should be reported for each movement. • The peak-hour traffic counts need to include bicycle and pedestrian volumes. • The signal warrant analysis shows that the Sutter Street/Hoffman Street intersection meets the signal warrant. The Conclusions section states it does not. Please revise the conclusions based on the signal warrant analysis. Please also provide the raw traffic data (which appears to be a 24-hour count) in the attachment for this Traffic study.
"Provide a safe and reliable transportation network that serves all people and respects the environment" Mr. Critchfield, Deputy Superintendent
January 23, 2024

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Appendix K - Transportation Operations Memorandum (continued) • The proposed project will increase a significant amount of traffic at the two intersections: SR 88/Argonaut Lane, and Sutter Street (SR 88)/Hoffman Street. The safety concerns associated with the increased traffic from the proposed project, especially for the vehicles making a left turn out from the local roads experiencing a higher risk of broadside collisions with the mainline traffic due to longer wait at the stop sign, need to be addressed with the proposed project.
• The traffic impact from the combined Junior High School at the current Amador High School should also be analyzed. Even though the total number of students remains the same, due to changes in traffic patterns from the combined school, the traffic would come from adjacent cities like lone and Jackson instead of locally from Sutter Hill only.
• Please use the CA MUTCD worksheet for the traffic signal warrant study instead of Vistro. Please use Synchro / SimTraffic software for the intersection analysis and provide the electronic files (Synchro Version 12) for Caltrans review.

Caltrans recommend scheduling a focus meeting to discuss the comments related to the Transportation Operations Memorandum.

Appendix L- Vehicle Miles Traveled Memo for Alternatives

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these values are calculated for columns "Existing VMT and Existing VMT + project".

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Caltrans suggest Amador County and ACUSD continue to coordinate and consult with Caltrans to identify and address potential cumulative transportation impacts that may occur from this project and other developments near this location. This will assist Caltrans in ensuring that traffic safety and quality standards are maintained for the traveling public on existing and future state transportation facilities.

If you have any question or would like to discuss these comments, please contact Paul Bauldry at 209) 670-9488 email: [email protected]) or me at (209) 483-7234 (email: [email protected]).

Sincerely,
gregoria Poncé
Gregoria Ponce', Chief
Office of Rural Planning
c: Mark Samuelson, Interim Planning Deputy, Caltrans D10 Duper Tong, Traffic Operations Deputy, Caltrans D10
State Clearinghouse
Chuck Beatty, Director, Amador County Planning Department "Provide a safe and reliable transportation network that serves all people and respects the environment" GHD
Technical Memorandum
February 12, 2024
To John Gedney, ACTC Executive Email [email protected] Director
From Don Hubbard, GHD Project No. 11219817
Project Name ACTC On-Call for Traffic
Subject Peer Review of Traffic Analysis in ACUSD School Consolidation Project EIR

1. Introduction
In accordance with your request we have reviewed to following documents pertaining to the Amador County Unified School District's (the District's) School Closure/Consolidation Program Project:
- Chapter 3 of the Draft Environmental Impact Report (DEIR), entitled "Project Description", - Chapter 5.15 of the DEIR, entitled "Transportation",
- Appendix J of the DEIR, entitled "CEQA Transportation Memorandum", - Appendix K of the DEIR, entitled "Transportation Operations Memorandum", and - Appendix L of the DEIR, entitled "VMT Memo for Alternatives".

Our review found that the transportation sections of the DEIR appear to be deficient in several respects:
• It appears that the project may trigger or exacerbate traffic safety issues at several locations. The report did not examine these issues, perhaps in the mistaken belief that safety is not a CEQA issue. Until these are studied, the extent of the safety issues remain unknown and appropriate mitigation measures cannot be identified
• The threshold used for the VMT analysis is not supported by substantial evidence, as required under CEQA.
• The identification of mitigation measures is deferred to a future date. This is not permissible under CEQA unless the lead agency commits itself to mitigation and adopts specific performance standards the mitigation will achieve. The DEIR does neither These issues are discussed in more detail in the sections below.

2. Traffic Safety Not Studied
The DEIR does not address the issue of traffic safety, perhaps in the mistaken belief that safety is no longer a CEQA issue post SB-743. In fact, when SB-743 replaced vehicular level of service (LOS) with vehicle miles of travel (VT) as an impact metric under CEQA, the change did not affect other transportation impact metrics. Per PRC § 21099(b)(3), "This subdivision does not relieve a public agency of the requirement to analyze a project's potentially significant transportation impacts related to air quality, noise, safety, or any other impact associated with transportation." (emphasis added) in eation ical Merica anaters asociated sin the prodi an undes out represent at approved pira on any in Commission is provided to foster discussion → The Power of Commitment
11219817 1
There is reason to believe that the project will have traffic safety impacts. In its comment letter on the NOP, Caltrans requested that a queuing analysis be performed the intersections of State Route (SR) 49 with Hoffman St, Sutter St, and Argonaut Lane, which are on the approaches to Argonaut High School. Queuing is a safety issue for several reasons:
•Ifa project lengthens the queues at an intersection to the point where queues may extend past the existing turn pockets, the line of queued vehicles will spill over into the travel lanes. Having stationary, queued vehicles on a roadway where traffic typically moves at 45 MPH would greatl heighten the risk of rear-end collisions.
• Also, drivers get impatient when waiting in long queues, and are more likely to engage in risky behavior as a result. This includes turning into gaps in the opposing traffic that the driver might otherwise reject as insufficient, crossing the centerline (i.e. into the opposing direction of travel) to cut the queue to the left, or driving onto the shoulder to cut the queue to the right!. The fact that many of the vehicles would be driven by inexperienced high school drivers would exacerbate the issue.

Note that in the cases described above a project can create or exacerbate a safety hazard simply by changing traffic patterns and volumes without making any physical change to the intersection.

To its credit, the District did have its traffic consultant perform an operations analysis of the three named intersections. However, this analysis was not incorporated into the body of the DEIR and is instead found in Appendix K, which is described in the DEIR as being "... for informational purposes only" rather than being part of the impact analysis. The wording on page 5.15-18 of the DEIR implies that the reason the operations analysis was for informational purposes (only) is because LOS is no longer considered under CEQA:
"LOS is no longer used as a measure of transportation impacts under CEQA. Transportation impacts, and the following analysis, will instead be evaluated based on a project's effect on VMT." However, it was not a LOS analysis that Caltrans requested from the operations analysis, it was a queuing analysis. And while the DEIR's subsequent VMT analysis may substitute for the LOS analysis that would have been done prior to SB-743, it does not substitute for the safety analysis that was requested.

Moreover, the project-related traffic that used for the LOS analysis appears to be incorrect. For the VMT analysis, the DEIR used data on the students' home locations relative to the school locations. But for the operational analysis, they factored up existing traffic volumes without regard to where the new students would be coming from:
"Vehicular traffic going to/from the schools were distributed at each intersection according to the turning movement proportions consistent with the existing counts for both the AM and School PM peak hours."
As a result, the DEIR's operational analysis appears to have underestimated the impact of the project on the turning movements most affected.

Another oddity of the operations analysis is that the consultant estimated project-related traffic using ITE's Trip Generation Handbook 11h Edition. While that would be appropriate for estimating traffic from a proposed new land use, it is poor practice when you are moving an existing use from one place to another.

Why not just do driveway counts at Amador High School and the junior high schools to find out how much traffic these particular schools are generating, rather than rely on old data from somewhere else? The Handbook describes its data for high schools as, "The sites were surveyed in the 1980s, the 1990s, the 2000s, and the 2010s in Alberta (CAN), Arizona, California, Connecticut, Delaware, Florida, Minnesota, New Jersey, North Carolina, Oregon, Texas, Vermont, Washington, and West Virginia." Surely data taken from the site in question would have been a better choice.

In addition, Caltrans NOP comment letter requested that the intersection analysis be done using Sychro/SimTraffic. This software package is Caltrans' standard software for this type of analysis and the most widely used nationwide. The DEIR consultant instead used Vistro, a different software package. When we spot checked one of the intersections to see if the results would be any different, we got queuing estimates that varied quite a bit different from what was found in the DEIR (see Table 1). While we cannot be sure why the results are different without seeing the settings used for their analysis, we can say that using the standard software package would eliminate at least one possible source of difference, which is one reason why Caltrans wants the analyses for every project done using the same software. ' Note that many roads in Amador County, including Argonaut Lane near SR 49, lack sidewalks, so any pedestrians would be on the shoulder.
11219817 2
Table 1: Queuing at SR 49/88 at Argonaut Lane
DEIR (ft) Synchro/Sim Traffic (ft)
Existing Existing Existing Existing
Lane Existing Existing Plus Plus Existing Existing Plus Plus AM PM Project Project AM PM Project Project

AM PM AM PM
EB Thru/Right 0 26 27
WB Left 3 7 40 64 71 75
WB Thru 0 0 0
NB Left 41 146 275 72 142 247 880
NB Right 41 87 146 275 64 64 71 72
One might ask why these three intersections were called out by Caltrans for consideration of safety issues? The reason is that they all have issues that might be worsened by the project:
• SR 49/Argonaut Lane: The area around this intersection has been the site of 38 accidents in the last ten years, including a fatality. Nine of these occurred on school days within an hour of the start and end of a school day at Argonaut High School. Figure 1 points out several safety issues at this intersection, including the fact that two of the queues that may be affected by the school consolidation project have curves on the approach.
• SR 49/Hoffman Street: The area around this intersection has been the site of 11 accidents in the last ten years, including a fatality. Five of these occurred on school days within an hour of the start and end of a school day. Figure 2 shows sight distance issues at this intersection. • SR 49/Sutter Street: The area around this intersection has been the site of 19 accidents in the last ten years, including a fatality. Figure 3 shows several safety issues at this intersection.

Our understanding is that there are other intersections in addition to these that may warrant a safety analysis and were not mentioned by Caltrans because they are under the jurisdiction of local agencies. It would be useful to see a map showing the traffic that would be re-routed as a result of the school consolidation project so that we could identify such intersections.

Please note that we are not saying that there definitely will be significant traffic safety impacts from the proposed project. We are simply pointing out that there is reason to believe that there may be significant impacts and that it is impossible to know for sure without a safety analysis.

3. Improper VMT Threshold
Section 5.15.3.1 of the DEIR states, "There are no established significance criteria for schools, so this analysis uses no increase in the VMT per student for the impact criteria." Nothing is said about the origin of this threshold, and no substantial evidence is presented to support it, as required under CEQA4.

There are other issues with this threshold. For one thing, it completely omits consideration of the VMT associated with other travelers to the school. This includes parents, school employees, vendors, people who attend sporting and other events held at the school, etc., all of whom will be affected by the project...

The threshold is problematic even for the one thing it does cover, student travel. The State's greenhouse gas reduction goals require a decrease to 40% below 1990 levels by 2030. According to CARB's most 2 My understanding is that if Caltrans had not already directed attention to these intersections, then other agencies would have raised this issue independently.
3 This data comes from the Statewide Integrated Traffic Records System (SWITRS), which is a database that collects and processes data gathered from a collision scene. The figure includes all recorded accidents for which the combination of SR 49 or Argonaut Lane were listed as the street and cross-street. The figure therefore includes accidents that may have occurred on the approaches to the intersection and were affected by the intersection, such as collisions occurring when one vehicle decelerates when approaching the intersection and is struck by another that does not. Not all accidents are reported. ^ See CEQA Guidelines § 15064.7, if the threshold is for general use, or § 15064(b)(2), if the threshold is for ad hoc use. 5 According to the Big Data web service Replica, more than a third of the trips taken to school sites in Amador County were for 11219817 3
recent Scoping Plan for achieving these goals, "Accordingly, VMT reductions will play an indispensable role in reducing overall transportation energy demand and achieving the state's climate, air quality, and equity goals." Merely maintaining the current levels of VMT production is no longer good enough for projects going forward. CARB suggests that we need to, "Achieve a per capita VMT reduction of at least 25 percent below - 2019 levels by 2030 and 30 percent below 2019 levels by 2045." At a minimum the EIR must cite substantial evidence to support the chosen threshold. It should also explain why a reduction in VMT is not being pursued when CARB says that it is needed. Per CEQA Guidelines §15064(b)(2) (new with SB-743), "Compliance with the threshold does not relieve a lead agency of the obligation to consider substantial evidence indicating that the project's environmental effects may still be significant."
The District may believe that issues around the VT threshold are moot because the impact was determined to be significant even with the limited threshold they applied, and they are planning to issue a Statement of Overriding Considerations in any case. The problem with that approach is that an EIR is an informational document as well as a policy document. It must disclose to the public and to policy makers all of the likely impacts of the project, and only then describe what mitigation will or will not be done; otherwise no one can assess what is being overridden. A lax or incomplete threshold can mislead the reader into underestimating the effects of a project, causing the EIR to fail as an informational document. So the issue of the threshold, which measures impacts against State goals, is far from moot.

4. Inadequate Mitigation
The single proposed mitigation measure (see Section 5.15.4 of the DEIR) simply states that, at some unspecified point in the future, the District will create a Transportation Demand Management (TDM) plan that would encourage carpooling among students or use of alternative modes (bicycle, pedestrian, and transit).

A plan is not in itself a mitigation measure since it has no effect on impacts in the field. The EIR defers identification of measures to actually mitigate the VMT impact to some (unnamed) future date. This violates § 15126.4, subd. (a) (1)(B) which says:
"Formulation of mitigation measures shall not be deferred until some future time. The specific details of a mitigation measure, however, may be developed after project approval when it is impractical or infeasible to include those details during the project's environmental review provided that the agency (1) commits itself to the mitigation, (2) adopts specific performance standards the mitigation will achieve, and (3) identifies the type(s) of potential action(s) that can feasibly achieve that performance standard and that will considered, analyzed, and potentially incorporated in the mitigation measure." (emphasis added) Although Section 5.15.4 of the DEIR mentions a few possible mitigation measures, no measurable (monitorable) performance standards are provided and in any case these are posed as mere suggestions, not firm commitments. How can anyone measure whether the District's future actions to "Encourage the additional use of school buses" or "Distribution of information concerning alternative transportation options" were sufficient? A measurable performance standard would read something like, "The District will provide additional school bus routes to serve 150 students per day" or "The District will include on its website information on alternative transportation options and will include a section on options in its monthly newsletter to parents."
There is no obvious reason why a TDM plan could not be developed and incorporated into the EIR. The California Air Pollution Control Officers Association offers a widely-cited handbook® with over a hundred pages of measures for mitigating transportation impacts. The handbook includes tips for quantifying the effect of mitigation measures, which was not done in the DEIR.

Besides the measures listed in the CAPCOA handbook, we would like to suggest several other measures for consideration by the District:
• The District could designate a certain number of days each month as "study from home" days, which would reduce the VMT impact of the project.
® Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity (https://www.airquality.org/ClimateChange/Documents/Handbook%20Public%20Draft 2021-Aug.pdf) 11219817 4
• They could also require students from some parts of the county to use school buses that would serve specific pickup locations.
• They could establish park-and-ride lots to encourage carpooling. • They could contribute a fair share to the proposed southward extension of Wicklow Way, which would offer a new route to Argonaut High School that does not pass through the SR 40/Argonaut Lane intersection (see Figure 4).
• They could contribute their fair share to improvements to the SR 49/Argonaut Lane intersection. • They could contribute their fair share to improvements to the SR 49/Hoffman Street Lane intersection.
11219817 5
[Choose document date]
Figure 1: SR 49 / Argonaut Lane
Curve leading into
possible end of queue
L
Double curve
leading into
possible end of
queue
Limited sight distance
to traffic from right
• The Power of Commitment
11219817
Figure 2: SR 49 / Hoffman Street
CP + Me
sulter so ins
Ralph Alley
Sulter St
Limited sight distance
to traffic from right
Hoffman St Hoffman St
offman St
Google
11219817
Figure 3: SR 49 / Sutter Street
H1T: HE 10E
Steep driveway
Limited sight distance to
traffic from right and left
11219817
GHD
Amador School
Consolidation
Traffic Issues
› Don Hubbard, TE, AICP
Technical Director
Traffic Engineering and
Transportation Planning
February 12, 2024
Topics For Today (e]
a) Traffic Safety Issues
b) Improper VMT Threshold
c) Inadequate Mitigation
d) ACTC's Requests
SPRTA Working Group Meeting | 2
MIS
offman S
Hoffman St Hoffman St
Issues
Suiter St Traffic Safety
Ralph Alley
Ralph Alley
NIMaInST sutter Se
Traffic Safety is Not Adequately Addressed GHD
• The DEIR does not address the issue of traffic safety, perhaps in the mistaken belief that safety is no longer a CEQA issue post SB-743. • SB-743 clarifies that when it replaced vehicle LOS with VMT as an impact metric under CEQA, the change did not affect other transportation impact metrics. Per PRC § 21099(b)(3):
"This subdivision does not relieve a public agency of the requirement to analyze a project's potentially significant transportation impacts related to air quality, noise, safety, or any other impact associated with transportation." (emphasis added) • The EIR must address traffic safety impacts. This has been pointed out to the District by multiple agencies on multiple occasions.

What Did the DEIR Study? GHD
• Caltrans sent a comment letter to the Notice of Preparation asking the District to study queuing issues at three specific intersections • The DEIR traffic consultant did perform an operations analysis at a number of intersections, including the three cited by Caltrans. • However, this analysis was not incorporated into the body of the DEIR and is instead found in Appendix K, which is described in the DEIR as being " ... for informational purposes only" rather than being part of the impact analysis • No safety impact analysis was done. The wording in the DEIR implies that only a VMT analysis is required: "LOS is no longer used as a measure of transportation impacts under CEQA. Transportation impacts, and the following analysis, will instead be evaluated based on a project's effect on VMT."
Why Are Caltrans and ACTC Concerned GHD
About Queuing?
• The issue is that if the project lengthens the queues at key intersections the queues may extend past the existing turn pockets and into the travel lanes • Having stationary, queued vehicles on a roadway where traffic typically moves at 45+ MPH would greatly heighten the risk of rear-end collisions.

So even if a project does not change the physical configuration of the intersection, adding traffic can create a new safety hazard • Also, drivers get impatient in long queues, and engage in risky behavior as a result (turn into gaps in the opposing traffic that may not be sufficient) • The fact that many of the vehicles would be driven by inexperienced high school drivers exacerbates the issue
DEIR's Queuing Analysis Seems Odd GHD
• Caltrans NOP comment letter requested that the intersection analysis be done using Sychro/Sim Traffic (Caltrans standard software and the most widely used). The DEIR used Vistro instead
• The results are very different:

Queuing at SR 49/88 at Argonaut Lane
DEIR (ft) Synchro/SimTraffic (ft)
Existing Existing Existing Existing
Lane Existing Existing Plus Plus Existing Existing Plus Plus AM PM Project Project AM Project Project

AM PM AM PM
EB Thru/Right 18 26 27
WB Left 40 64 71 75
WB Thru
NB Left 41 87 146 275 142 247 880
NB Right 41 87 146 275 64 64 71 72
SimTraffic Queuing Test GHD
An 880 ft queue
aORd would extend to
Argonaut Drive
nedy/Flat Ras
Argonaut Lan
No Project Condition Plus Project Condition
PM Peak Hr PM Peak He
I GHD
DEIR's Queuing Analysis Seems Odd GHD
• For the VMT analysis, the DEIR used data on the students' home locations relative to the school locations
• But for the queuing analysis, they factored up existing traffic volumes without regard to where the new students would be coming from:
"Vehicular traffic going to/from the schools were distributed at each intersection according to the turning movement proportions consistent with the existing counts for both the AM and School PM peak hours." • So the DEIR's queuing analysis underestimated the impact of the project on the turning movements most affected
Assumed Trip Generation Rate GHD
• For the operations analysis, the DEIR consultant estimated project-related traffic using ITE's Trip Generation Handbook
• While that would be appropriate for estimating traffic from a proposed new land use, it is poor practice for a project to move an existing use from one place to another
• It would have been much better to take counts at Amador High School and the junior high schools to find out how much traffic these particular schools are generating, rather than rely on old data from somewhere else • FYI: The Handbook describes its data for high schools as, "The sites were surveyed in the 1980s, the 1990s, the 2000s, and the 2010s in Alberta (CAN), Arizona, California, Connecticut, Delaware, Florida, Minnesota, New Jersey, North Carolina, Oregon, Texas, Vermont, Washington, and West Virginia." 10 Improper VMT
Threshold
g090g.

Google
Thresholds Matter GHD
• EIRs are informational documents as well as a policy documents. The first requirements is that impacts must be disclosed, even if a Statement of Overriding Considerations is later adopted
• Thresholds are used to help policy makers and the public gauge the extent of an impact. An improperly lax threshold misleads the reader by understating the severity of an impact.
• Also note that thresholds are not the end of the story. Per CEQA Guidelines §15064(b)(2) (new with SB-743):
"Compliance with the threshold does not relieve a lead agency of the obligation to consider substantial evidence indicating that the project's environmental effects may still be significant."
12 DEIR's VMT Threshold GHD
• Section 5.15.3.1 of the DEIR: "There are no established significance criteria for schools, so this analysis uses no increase in the VMT per student for the impact criteria."
• Nothing is said about the origin of this threshold, and no substantial evidence is presented to support it, as required by CEQA • Note that this threshold completely omits consideration of the VMT associated with other travelers to the school (parents, school employees, vendors, people who attend sporting and other events held at the school, etc.) who would also will be affected by the project
• Moreover, the State's GHG goals require a reduction in VMT for projects going forward; continuing at current levels is no longer good enough 13 Inadequate Mitigation
Proposed Mitigation is Inadequate GHD
• The proposed mitigation section simply states that, at some unknown point in the future, the District will create a Transportation Demand Management plan • A plan is not in itself a mitigation measure since it has no effect on impacts in the field. The DEIR defers identification of measures in violation of CEQA Guidelines § 15126.4, subd. (a)(1)(B) which says:
"Formulation of mitigation measures shall not be deferred until some future time."
• You are allowed to defer if the agency commits itself to the mitigation and adopts specific performance standards the mitigation will achieve. The DEIR does neither
15 Help is Available GHD
Handbook for Analyzing Greenhouse Gas Emission
• There are publications Reductions, Assessing Climate Vulnerabilities, and available to help agencies
Designed for Local Governments, Communities, and Project Developers identify suitable mitigation
measures
• The CAPCOA handbook has
over a hundred pages on
transportation mitigations,
including data to help quantify
their effect (not done in the 00 m 0% *
DEIR)
16 ACT's Requests
ACTC's Goals GHD
• Not trying to stop the District's project; just want this project to follow the same rules that every other project has to follow, namely:
• Do a proper safety analysis and include it in the EIR • Identify the District's mitigation measures, and quantify how much they reduce the project's impacts
• Contribute the District's fair share of the cost of intersection improvements • Work with ACTC and Caltrans to find solutions that will work well for all parties concerned
18 Potential
Issues &
Mitigations
6 RE OF
Google
Fair Share Fundamentals GHD
1,600
Project's Fair Share:
1,400
Scenario 1: Zero }Y
1,200
Scenario 2: YIX Capacity = 1,000
1,000 FY
Scenario 3: YIZ • Other Growth
Vehicles per Hour 800
• Project
600 •Existing
400
200
Case 1 Case 2 Case 3
20 Planned Improvements Signalize GHD
SR 48/Argonaut
TCIP Improvement Projects Map
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Wokow Way duena Vistaro
Wicklow Way Extension Signalize
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(Complete)
Legend
® New Roundabout Project Church
a New Traffic Signal Project
• Pedestrian & Bike Safety Enhancement E TE
• Pedestrian Undercrossing
- Complete Street Improvement (Marginal Widening Possible) Biue C - New Roadway
Roadway Rehabilitation Maintenance Sutter Street Extension Possibly Significant Widening
21 SR 49/Sutter Street GHD
battle
9089
19 collisions in last 10 years, including a fatality
22 Sutter Street Extension GHD
Prosect Ease work
Parceis
Argonaut Jackson
Mine Junior High
School
23 SR 49/Hoffman Street GHD
Sulter St
Hoffmanst
11 collisions in last
10 years, including a
fatality
5 during school
opening & closing
times
SR 49/Argonaut Lane GHD
• 38 collisions in last 10 years,
including a fatality
• 9 of these occurred on school
days around the start and end
of the school day at Argonaut
High School
SimTraffic Queuing Test
Arôje dition
Flat Ra
Argonau lane
An 880 ft queue
would extend to
Argonaut Drive
I GHD
Argonaut Lane GHD
Bike/Ped Potential
Unimproved Section
Improved Section
27 Wicklow Way GHD
Extension
Wicklow Way
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CALIFORNIA STATE TRANSPORTATION AGENCY GAVIN NEWSOM, GOVERNOR California Department of Transportation
5r
OFFICE OF THE DISTRICT 10 RURAL PLANNING
P.O. BOX 2048 | STOCKTON, CA 95201 Caltrans
(209) 948-7325 | FAX (209) 948-7164 TTY 711
www.dof.ca.gov
January 23, 2024
Jared Critchfield, Deputy Superintendent Environmental Impact Report (EIR) Amador County Unified School District Amador County Unified School 217 Rex Avenue District (ACUSD)
Jackson, CA 95642 SCH 2023060568
Dear Mr. Critchfield,
The California Department of Transportation (Caltrans) appreciates the opportunity to review and respond to the Amador County Unified School District (ACUSD) Environmental Impact Report (EIR) for the proposed School Consolidation project, affecting ACUSD's school campuses, including Amador High School, Sutter School, Jackson Junior High School, lone Elementary School, Jackson Elementary School, and the Sutter Creek Elementary School.

ACUSD proposes to combine Amador High School (HS) and Argonaut HS at Argonaut HS. This would change the enrollment capacity from 925 students to 1,325 students; the school would continue to serve grades 9 through 12. This campus would have site and building improvements to accommodate the increase in enrollment. The ACUSD would add a 2-story, 10-classroom building (with 4 science labs and 6 standard classrooms), relocate 5 portable classrooms from Jackson Junior HS and lone Elementary School to this campus, convert 2 preschool classrooms to regular classrooms, convert a classroom for counseling office, renovate and expand the kitchen, and renovate and expand gymnasium locker rooms. The campus would have a new parent drop-off, new access road connecting to Stony Creek Road, and accessibility compliance improvements throughout the campus.
"Provide a safe and reliable transportation network that serves all people and respects the environment" Mr. Critchfield, Deputy Superintendent
January 23, 2024

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ACUSD proposes to combine lone Junior HS and Jackson Junior HS at Amador HS. This change would not affect the enrollment capacity (875 students) of the campus nor the number of teaching stations (35 teaching stations). The campuses would serve grades 7 through 8 instead teaching stations 35 teaching stations).

ACUSD proposes to relocate lone Elementary School to lone Junior HS and would add preschool and transitional kindergarten (K), and grades 1 through 5, to the campus.

This would change the enrollment capacity of the campus from 775 students serving grades 6 through 8 to 801 students serving preschool and grades TK through 6. This campus would also have site and building improvements to accommodate the increase in enrollment. ACUSD would add 2 new classroom buildings and playground for preschool, TK, and Extending Learning; convert science labs to kindergarten classrooms; and convert restrooms to kindergarten restrooms. ACUSD would also expand the parent drop-off/pick-up areas, expand the kindergarten drop-off area, expand the kitchen, and construct a new play structure and hardcourt areas.

The enrollment capacity of 575 students and 23 teaching stations would remain the same.

The project areas include Amador City, lone, Jackson, Plymouth, Sutter Creek, and unincorporated regions within the County.

Caltrans at this time has the following comments:

Environmental Impact Report
General Comments
If the consolidation results in a physical encroachment into Caltrans right-of-way (ROW). the project proponent must apply for an Encroachment Permit to the Caltrans District 10 Encroachment Permit Office. All California Environmental Quality Act (CEQA) documentation, with supporting technical studies, must be submitted with the "Provide a safe and reliable transportation network that serves all people and respects the environment" Mr. Critchfield, Deputy Superintendent
January 23, 2024

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Appendix J - CEQA Transportation Memorandum

Page 27 ends

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Appendix K - Transportation Operations Memorandum (continued) • The proposed project will increase a significant amount of traffic at the two intersections: SR 88/Argonaut Lane, and Sutter Street (SR 88)/Hoffman Street. The satety concerns associated with the increased traffic from the proposed project, especially for the vehicles making a left turn out from the local roads experiencing a higher risk of broadside collisions with the mainline traffic due to longer wait at the stop sign, need to be addressed with the proposed project.
• The traffic impact from the combined Junior High School at the current Amador High School should also be analyzed. Even though the total number of students remains the same, due to changes in traffic patterns from the combined school, the traffic would come from adjacent cities like lone and Jackson instead of locally from Sutter Hill only.
• Please use the CA MUTCD worksheet for the traffic signal warrant study instead of Vistro. Please use Synchro / SimTraffic software for the intersection analysis and provide the electronic files (Synchro Version 12) for Caltrans review.

Caltrans recommend scheduling a focus meeting to discuss the comments related to the Transportation Operations Memorandum.

Appendix L- Vehicle Miles Traveled Memo for Alternatives • Page 2 and 3: Table 1, 2 and 3 - Additional information is needed to show how these values are calculated for columns "Existing VMT and Existing VMT+ project".

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If you have any question or would like to discuss these comments, please contact Paul Bauldry at (209) 670-9488 (email: [email protected]) or me at (209) 483-7234 (email: [email protected]).

Sincerely.

Gregoria Poncé
Gregoria Ponce', Chief
Office of Rural Planning
C: Mark Samuelson, Interim Planning Deputy, Caltrans D10 Duper Tong, Traffic Operations Deputy, Caltrans D10
State Clearinghouse
Chuck Beatty, Director, Amador County Planning Department "Provide a safe and reliable transportation network that serves all people and respects the environment cOu

AMADOR COUNTY COUNSEL
VIA U.S. MAIL AND EMAIL
Gregory G. Gillott, County Counsel
Lesley C. Barlow, Deputy
February 9, 2024 Glenn Spitzer, Deputy
Angela R. Creach, Paralegal
Amador County Unified School District
Att: Torie F. Gibson, Ed.D.
217 Rex Avenue
Jackson, CA 95642
[email protected]
RE: Comments on DEIR for School Closure/Consolidation Project Dear Dr. Gibson,
Amador County appreciates the opportunity to comment on the School Closure/Consolidation Project. Attached are comments from Richard Vela, Director of Transportation and Public Works, and from Chuck Beatty, Planning Director. These attached comments address issues within the expertise of these departments.

Additionally, this letter provides a general comment on the overall process. Informed decision making and public participation are fundamental goals of the California Environmental Quality Act (CEQA) process. (Union of Med. Marijuana Patients, Inc. v. City of San Diego (2019) 7 Cal.5th 1171, 1184.) An Environmental Impact Report's (EIR) informational function is considerod a preceduri enciremeny of nochis edwa 2007) O Cal 412, ard Area Cilizens This function fails when the information provided does not assist in the decision-making process.

Here, the obvious defect is that the Draft EIR (DEIR) speaks of the consolidation as a "proposed project" (See Section 1.4 of the DEIR) despite the fact that the Amador County Unified School District (ACUSD) has already officially decided the matter. At best, this conflict confuses the public and decision-makers. At worst, it creates the impression that the process is a sham.

ACUSD's website reads:

On May 24"h, 2022, the Amador County Unified School District Board of Trustees voted to approve school consolidation, which will combine our two high schools into one consolidated high school and our two junior high schools into one consolidated junior high school. As part of this plan, Ione Elementary School will move to the current lone Junior High campus once the junior high schools have consolidated.

February 9, 2024

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The webpage (https://amadorcoe.org/consolidated-high-school-infol) goes on to state: "The consolidated high school and consolidated junior high school are set to open in August 2026." It the decision has already been made, it begs the question: what is the purpose of this environmental information? A rational member of the public could conclude that the environmental information merely describes the effect of a past decision, or worse—-merely justifies that decision. Either way, this conflict clouds the process and discourages public participation.

It is a fundamental rule of CEQA that the environmental analysis must occur prior to the decision on the project. (Pub. Res. Code § 21100; Save Tara v. City of West Hollywood (2008) 45 Cal.4'h 116, i28.) ACUSD plainly violated this rule when it approved consolidation on May 24, 2022. Now ACUSD is compounding the problem by providing an analysis that appears to do no more than justify a prior decision.

In Laurel Heights Improvement Assn. v. Regents of U.C., the California Supreme Court addressed a similar situation as follows:
"CEQA requires that an agency determine whether a project may have a significant environmental impact, and thus whether an EIR is required, before it approves that project." (Citations.) This requirement is obvious in several sections of CEQA. For example, section 21081 refers to approval of a project for which an EIR "has been completed," and section 21151 requires an EIR for a project an agency "intend(s] to carry out or approve." (Italics added.) The Guidelines provide even more explicitly that "Before granting any approval of a project subject to CEQA, every lead agency ... shall consider a final EIR..." (Guidelines, § 15004(a), italics added.) A fundamental purpose of an EIR is to provide decision makers with information they can use in deciding whether to approve a proposed project, not to inform them of the environmental effects of projects that they have already approved. If post-approval environmental review were allowed, EIR's would likely become nothing more than post hoc rationalizations to support action already taken. We have expressly condemned this use of EIR's. (Citations.) The Regents' view that their approval of a project is the predicate for an EIR stands this principle on its head.
(Laurel Heights Improvement Assn. v. Regents of U.C. (1988) 47 Cal.3d 376, 394.) To address this glaring procedural defect, ACUS should acknowledge that its May 24, 2022 approval was defective and improper. ACUSD should officially void this approval and take any and all appropriate action to assure the public and decision-makers that a decision has not yet been made on the consolidation issue, and that all feasible mitigation and alternative measures (including the "no project" alternative) are viable options going forward. These actions, at a minimum, are necessary to assure the public that its participation in this process is meaningful.

February 9, 2024

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If you have any questions or seek to discuss this matter further, please do not hesitate to call me.

Sincerely,
Deputy County Counsel
Attachments: DEIR Comments (Public Works)
DEIR Comments (Planning Department)
Cc: Richard Vela
Chuck Beatty
Board of Supervisors
AMADOR COUNTY COMMUNITY DEVELOPMENT AGENCY PHONE: (209) 223-6429 TRANSPORTATION & PUBLIC WORKS FAX: (209) 223-6395
COUNTY ADMINISTRATION CENTER • 810 COURT STREET • JACKSON. CA 95642-2132

REVIEW OF DRAFT EIR (DEIR)

SCHOOL CLOSURE/CONSOLIDATION PROGRAM PROJECT

AMADOR COUNTY UNIFIED SCHOOL DISTRICT
Richard Vela, Director of Transportation and Public Works Preface
As the Director of Transportation and Public Works, the focus of my review is on portions of the DEIR that affect county road infrastructure, namely the high school consolidation at the existing Argonaut High School campus and its effects on the section of Argonaut Lane from the SR 49/88 intersection to Buena Vista Drive. In particular the intersection of SR 49/88 and Argonaut Lane. With that being said, I reviewed the following portions of the DEIR: Executive Summary, Chapter 5.15 Transportation, Appendix J CEQA Transportation Memorandum, Appendix K Transportation Operations Memorandum and Appendix L VMT Memo for Alternatives Executive Summary
Table 1-1, Impact 5.15-2. The proposed Mitigation Measure T-1 only applies to normal daily school activities and does not account for extra-curricular activity events.

Description of Existing Conditions
The DEIR describes the existing road infrastructure in the area. This information is found in Chapter 5.15 and is replicated in Appendix J and Appendix K. There are several inaccuracies in these descriptions.
• The limits of SR 49/88 concurrence through Jackson and Martell are not fully or accurately represented
• Under the description for SR 88, there is a reference to SR 41. This is in error as I believe the reference should be to SR 104.
• The descriptions of SR 49 and SR 88 in the concurrent section in Jackson are described differently. For SR 49, it is described as a 4-lane highway with a TWLTL (two way left turn lane) while for SR 88, it is described as a 5-lane highway. • For SR 88, there is mention of "limited sidewalks when passing east of Argonaut High School." While this is technically true, these sidewalks are nowhere near the Argonaut campus. The narrative suggests otherwise.
• Hoffman Street is described as extending from Sutter Street (SR 49/88) to Buena Vista Road. This is incorrect. Heading west, Hoffman Street ends at Argonaut Lane and the road becomes Stony Creek Road which extends to Buena Vista Road.

REVIEW OF DRAFT EIR (DEIR)

SCHOOL CLOSURE/CONSOLIDATION PROGRAM PROJECT

AMADOR COUNTY UNIFIED SCHOOL DISTRICT

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While these inaccuracies do not have a significant impact on the report or its findings, the fact that they exist calls into question the quality of the work by the consultant.

Chapter 5.15.3.1 Methodology
The VMT analysis is based on the project county-wide as a whole. Not on the impact at a site specific location. Since there is no increase in the student population county-wide, the overall VMT is marginally changed. This creates a significant oversight regarding the high school consolidation at the Argonaut campus where the student attendance is significantly increased Chapter 5.15.3.2 Impact Analysis
For the Argonaut campus, a valet program is being proposed "where campus personnel help load and unload students from vehicles and buses and control vehicles leaving the campus (metering) to allow for efficient circulation onto public streets, which would promote safety and efficient circulation." What happens for extra-curricular activities such as sporting events, concerts, graduation and community events held at the high school campus? The metering program does not address the extra-curricular activity events. The school district should provide examples where "metering" is effectively utilized at high school campuses.

Regarding the Argonaut High School site improvements construction, there is no mitigation proposed for the wear and tear of the construction equipment and vehicles on the local roads.

Perhaps the impact is minimal but the item is not addressed.

Chapter 5.15.4 Mitigation Measures and Chapter 5.15.5 Level of Significance After Mitigation
Mitigation Measure T-1 is the development and implementation of "a Transportation Demand Management (TDM) plan that would encourage carpooling among students or use alternative modes (bicycle, pedestrian and transit)." Given the location of the Argonaut campus at the edge of urbanization, alternative modes of transportation are not practical. Carpooling may have some effect. The TDM proposes to implement several passive measures, with likely minimal effectiveness. The TDM plan could encourage the additional use of school buses. How is this to be accomplished? Is the school district ready to purchase more buses to transport the same number of students? The Mitigation Measure T-1 is acknowledged to have unknown effectiveness. Mitigation Measure T-1 "may reduce the increase of VMT per student and potential impacts associated with transportation to a level that is less than significant. However, the impact would remain significant and unavoidable because the effectiveness of a TDM Plan in reducing the number of project trips cannot be quantified to ensure project impacts would be fully mitigated." Certainly not a ringing endorsement for the proposed Mitigation Measure T-1. In addition, it does not address extra-curricular activity events.

REVIEW OF DRAFT EIR (DEIR)

SCHOOL CLOSURE/CONSOLIDATION PROGRAM PROJECT

AMADOR COUNTY UNIFIED SCHOOL DISTRICT

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Appendix J CEQA Transportation Memorandum
See previous comments regarding the description of existing conditions.

On page 12, the Amador County Transportation Commission (ACTC) is described as being designated as the Regional Transportation Planning Agency (RPTA) for the Amador County region. The document states that ACT's responsibilities encompass three areas, while five areas are listed. While not a major item, it does bring into question the quality of the report.

On pages 25 and 26, the transportation analysis is made. The vehicle miles traveled (VT) is the primary performance metric. In satisfying the California Environmental Quality Act (CEQA) guidelines, VMT is calculated for the project as a whole, not for each individual campus site.

This whitewashes the effect of the increased traffic to the Argonaut High School campus.

Regarding the CEQA project impacts and proposed mitigations, Mitigation Measure TRAF-1 has an unknown effectiveness and therefore cannot be relied upon to be an effective mitigation measure. Will ACUSD work with Amador Transit to develop routes to support getting more students to/from campuses? The mitigation measure will encourage "the additional use of school buses." The document needs to explain how this to be accomplished. The mitigation should include how the school bus service will be improved.

Appendix K Transportation Operations Memorandum
See previous comments regarding the description of existing conditions.

To analyze existing traffic conditions, data was collected on Wednesday May 31, 2023. Is a single day of data collection sufficient to accurately represent existing traffic conditions and provide a basis for making a determination?
Existing level of service (LOS) for intersections 1 (Argonaut Lane @ SR 88 - D) and 4 (Hoffman Street @ Sutter Street - C) not great.

For existing plus project conditions:

LOS for intersection 1 goes from E to F for both AM and school peak PM.

LOS for Intersection 4 goes from C to E for both AM and school peak PM The signal warrant analysis shows that the Argonaut Lane /SR88 intersection and the Hoffman Street/Sutter Street intersections meet the signal warrant. The Conclusions on page 27 erroneously states the Hoffman Street/Sutter Street intersection does not meet the signal warrant. The Conclusions need to be revised to correctly identify both intersections as meeting the signal warrant.

A queuing analysis needs to be performed on each of the intersections to appropriately determine the queues and delays for each traffic movement.

REVIEW OF DRAFT EIR (DEIR)

SCHOOL CLOSURE/CONSOLIDATION PROGRAM PROJECT

AMADOR COUNTY UNIFIED SCHOOL DISTRICT

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Signalization is warranted for both the Argonaut Lane/SR 88 and Hoffman Street/Sutter Street intersections for the school peak PM. This cannot be ignored, even though it is not required by CEQA. This constitutes a safety issue which is compounded by the age/lack of experience of the high school student drivers that will use the intersections.

In relation to the Argonaut Lane/SR 88 intersection, the analysis needs to consider the potential impact of traffic on Kennedy Flat Road. Neither this road nor its intersection with SR 88 to the west is designed for an increased traffic volume that will most likely be realized with the high school consolidation at the Argonaut campus.

Other Observations/Comments
The Notice of Preparation (NOP) letter dated July 11, 2023 from the Amador County Department of Transportation and Public Works requested "the extension of Wicklow way to Stony Creek Road be strongly studied as both an impact mitigation as well as an opportunity to serve the Argonaut campus with a well-planned and designed access point for student drop off by bus as well as by parents at the west side of the campus." No mention of Wicklow Way was found in the transportation focus of the DEIR, even to dismiss it as a viable consideration. This is disappointing.

AMADOR COUNTY COMMUNITY DEVELOPMENT AGENCY PHONE: (209) 223-6380 PLANNING DEPARTMENT FAX: (209) 257-5002
COUNTY ADMINISTRATION CENTER • 810 COURT STREET • JACKSON, CA 95842-2132

REVIEW OF DRAFT EIR (DEIR)

SCHOOL CLOSURE/CONSOLIDATION PROGRAM PROJECT

AMADOR COUNTY UNIFIED SCHOOL DISTRICT
Chuck Beatty, Planning Director
The DEIR was prepared after the project decision had been approved, twice. On May 24, 2022, the ACUSD Board of Trustees voted to approve school consolidation plan before any environmental review had taken place. Following failure of the November 2022 bond measure to fund school consolidation, the ACUS Board of Trustees adopted Resolution #2022/2023-10 on January 18, 2023, approving the consolidation for a second time albeit with a different funding mechanism. The resolution ironically notes that the school consolidation "may be a project subject to CEQA," yet the project was approved anyway before any environmental review had taken place. This denied the public and the decision makers the opportunity to review the extent of any environmental impacts, the possible alternatives, and any necessary mitigations before the project decision was made.

The DEIR notes that the project will not interfere with the county and cities to implement their respective general plans, but does not indicate if any city or county projects were included in the cumulative impacts analysis. It would have been helpful to know if past, present, and reasonably foreseeable projects were considered. This is particularly concerning given that the County's request to study the extension of Wicklow Way to Stony Creek Road as a traffic mitigation measure was dismissed Any evaluation of Wicklow Way would have referenced the Draft Wicklow Way Specific Plan (DEIR in progress), which proposes approximately 700 residential units, the extension of Wicklow Way to Stony Creek Road, and an 8.8-acre future school site.

The DEIR uses the Vehicle Miles Traveled transportation analysis required by CEQA, which indicates a 5% increase in VMT for the project on a County-wide basis. The only proposed mitigation measure for this increase in VMT is to implement a Transportation Demand Management Plan that would "encourage carpooling among students or use of alternative modes (bicycle, pedestrian, transit)." The DEIR admits that a TDM Plan is not sufficient mitigation for the VMT increase, stating, "the effectiveness of a TDM Plan in reducing the number of project trips cannot be quantified to ensure project impacts would be fully mitigated."
The DEIR includes a Level of Service transportation analysis as an appendix. The analysis shows that traffic impacts would lower the LOS for the SR88/Argonaut Lane intersection from LOS D to LOS F during the A.M. peak hour and from LOS E to LOS F during the P.M. peak hour. Similarly, the LOS for the Argonaut Lane/Hoffman Street intersection would be reduced from LOS B to LOS C during the peak A.M. hour and from LOS B to LOSE during the P.M. peak hour. The impacts of these reductions in level of service are significant, yet they are ignored in the DEIR even though PRC 21099 "does not relieve a public agency of the requirement to analyze a project's potentially significant transportation impacts related to air quality, noise, safety, or any other impact associated with transportation" through the use of a VMT analysis or any other metric to measure transportation impacts.

Neither the DEIR, nor the LOS study, include an analysis of the safety impacts to any street, highway, or intersection required by PRC 21099.

The LOS analysis did not follow Caltrans' directive to use "Synchro" software for intersection analysis and used "Vistro" instead, resulting in significant underestimation of vehicle cueing at intersections, particularly Argonaut Lane/SR 88.

Emissions of greenhouse gases and other criteria air pollutants may be underestimated due to unknown impacts of vehicle cueing at intersections that were excluded from the LOS analysis, as well as from underestimation of vehicle cueing at intersections studies in the LOS analysis (see above comment).
• The DEIR did not study the traffic impacts of the combined Junior High School at the current Amador High School location. The DEIR notes that the number of students attending the combined campus will not exceed current enrollment at Amador High School. However, trip generation from the expanded attendance area will likely increase traffic impacts at the Sutter-lone Road/SR 49 intersection as well as at intersections within the City of Sutter Creek.

The combined Argonaut High School campus includes an unnamed tributary of Rock Creek which drains into adjacent County-owned property. The DEIR does not provide pre- and post- development runoff calculations to determine the change in flows that will discharge directly onto the County's property.

The DEIR's VMT and LOS analyses show that the project will ultimately cause significant and unavoidable impacts to transportation and noise without proposing any meaningful or effective mitigation measures.

CITY OF IONE
IONE: (1 95640
February 11, 2024
Amador County Unified School District
Attn: Jared Critchfield
217 Rex Avenue
Jackson, CA 95642
Re: Response to School Closure/Consolidation Program Project Draft Environmental Impact Report SCH 2023060568
Dear Mr. Critchfield,
Thank you for the opportunity to review and respond to the Amador County Unified School District (ACUSD) Draft Environmental Impact Report (EIR) for the proposed School Closure/Consolidation Project ("Project"). Relocation of lone Junior High School to Sutter Creek and relocation of the elementary to the Junior High facility will have significant impacts to the City of lone that have not been adequately addressed in the Draft EIR.

CEOA Process
Before addressing the deficiencies in the Draft EIR, we would like to express our concerns with the overall process that the ACUSD Board of Trustee followed that is in direct conflict with the California Environmental Quality Act, CEQA. CEQA Guidelines require an informed decisio naking process that includes public participation. While we understand that the School Boar vanted to move forward with plans for consolidation, they should have relied on the informatior rovided in the Draft EIR, including the alternatives analysis, to approve the actual project. The Draft EIR should demonstrate to the School Board which alternative is environmentally superior - meaning it has the least impacts. Drafting the EIR to accommodate the approved project is essentially painting the bullseye around the target.

The lone City Council and community strongly urges the School Board to rescind the consolidation project approval, re-draft the EIR to address the concerns of responsible agencies, re-circulate the Draft EIR and then make an informed decision.

Project Description:

Chapter 3 Project Description of the Draft EIR lacks the following information:
1 1. The project description for the improvements to the Junior High School to convert it to an elementary school does not address how some of the proposed improvements, which appear to be on Southern Pacific Railroad property, are allowed.

2. Safety features (i.e. fencing and road widening) to address concerns with emergency ingress and egress and interface with attractive nuisances (i.e. stock ponds and railroad facilities) are not included in the description;

3. The project description has no information regarding the disposition of the existing lone Elementary School. Will the existing facility be demolished? Will the site be rezoned and sold?
Assumptions Regarding Cumulative Impacts/Population & Housing:

The growth assumptions presented in Section 4.4 - Assumptions Regarding Cumulative Impacts utilizes wildly varying sources causing skewed growth percentages. The resulting analysis shows grossly overstated growth in the City of Sutter Creek (668% increase by 2040) compared to the City of lone (107% by 2030), which is where the County has seen and is projected to see the most growth. Additionally, these growth assumptions are not consistent with the numbers provided in Section 5.12 - Population and Housing.

To achieve greater accuracy for growth assumptions for the purposes of cumulative impacts analyses and determining future school needs, Section 4.4 should be rewritten utilizing the Amador Water Agency Connection Commitments Table from November, 2023 for the Tanner service area (Sutter Creek & Jackson) and from August 2023 for the Ione service area. These tables demonstrate that there are currently 180 residences with will-serve commitments in Sutter Creek and 3,657 commitments in lone. Furthermore, the cumulative projects listed in Section

4.4 does not include any of the approved housing developments under construction or approved in the City of lone. A complete list of approved housing developments should have been obtained from the lone Building Department and included in the cumulative impacts analysis.

More accurate growth assumptions should also be utilized in Section 5.12 - Population and Housing. While we understand this section is intended to address population inducing impacts, we believe that growth patterns in the County, specifically the anticipated increase in school aged population in the City of lone and surrounding areas, including Camanche, should have been presented. This information is vital in order for the School Board of Trustees to effectively evaluate the decision to close a school in the County's fastest growing city.

Transportation:

Section 5.15 Transportation of the Draft EIR is deficient for the following reasons:

1. Impact 5.15-1 - The proposed project would not conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities:
a. The Amador County Regional Transportation Plan (Goal IA), Amador Countywide Pedestrian and Bicycle Plan (Goal 2) and the lone General Plan Circulation Element (Goal CIR-1) all prioritize traffic and circulation safety. The 2 Draft EIR does not address the potential safety impacts resulting from increased traffic in a residential area with narrow streets and no sidewalks or increased queuing, specifically at the intersections of Sacramento/Main/Preston and Highways 104/88. Increased queuing at these intersections greatly increases the potential for traffic collisions. These impacts and potential mitigations must be addressed in the Transportation section of the Draft EIR (not in the Appendices).

Senate Bill 743 replacing Level of Service analysis with Vehicle Miles Traveled "does not relieve a public agency of the requirements to analyze a project's potentially significant transportation impacts related to air quality, noise, safety, or any other impact associated with transportation" (PRC Section 21099(b)(3)); b. The Draft EIR states that "The proposed project would hinder the City's goals to improve its transportation network, including roadway, bicycle, and pedestrian infrastructure," yet there is no explanation as to why and how this this impact is considered "Less than significant";
c. There is not enough information about the "valet" and busing programs to consider this adequate mitigation. Please provide more detailed information that clearly demonstrates how these programs reduce the number of trips and congestion and improves safety at the school site;
d. Additionally, the busing program must demonstrate adequate mitigation to the increased travel demands placed on state designated Disadvantaged Communities (i.e. Camanche). Increase travel distances are a constraint to economically disadvantaged students attending school and extracurricular activities. Impact analysis to these communities and potential mitigation should be included in the Draft EIR.

2. Impact 5.15-2 - The proposed project may conflict or be inconsistent with CEQA Guidelines Section 15064.3(b):
a. Again, Senate Bill 743 replacing Level of Service analysis with Vehicle Miles Traveled "does not relieve a public agency of the requirements to analyze a project's potentially significant transportation impacts related to air quality, noise, safety, or any other impact associated with transportation" (PRC Section 21099(b)(3)). The operations analysis that was performed was not included in the body of the Draft EIR, does not include analysis at key intersections (Sacramento/Main/Preston and Highway 104/88) and thus no mitigation measures are proposed. Safety impacts and proposed mitigation must be included in the Draft EIR for the document to be approved as adequate for decision making purposes;
The mitigation proposed in Section 5.15.4 to develop and implement a Transportation Demand Management Plan is not, according to CEQA Guidelines Section 15126.4(a)(1)(b), adequate. Future studies cannot be utilized as mitigation. The Traffic Demand Management Plan must be completed and incorporated into the Draft EIR.

3. Impact 5.15-4 - The proposed project would not result in inadequate emergency services:
a. The analysis provided in this section does not adequately describe the narrow roadways in the vicinity of the school site and lack of emergency access to the 3 south and east of the site. Additionally, there is no description of how the "valet and metering program" will operate during an emergency event; b. The Transportation section does not address the physical impacts to the residential streets accessing the site. These streets were not designed for the amount of traffic they are already receiving and are failing as a result. Increased traffic will exacerbate the problem potentially making them unsuitable for emergency response.

Utility and Service Systems:

Section 5.17 Utilities and Service System of the Draft EIR does not describe the wastewater collection capacity issues and concludes that closure of the existing elementary school will decrease the overall capacity requirements to the Wastewater Treatment Plant. This assumes no reuse of the existing elementary school. Wastewater credits from the existing elementary school should not be used unless there is no intent to reuse the site.

Substantial Changes to the Draft EIR:

The City of Ione, along with Caltrans, Amador County Transportation Commission, and the cities of Jackson and Sutter Creek are all requesting that the Transportation Operations analysis be undated to Caltrans standards and brought into the body of the Draft EIR so potential mitigation can be considered. This analysis, along with the Transportation Demand Management Plan inclusion into the document would be considered "significant new information" in accordance with CEQA Guidelines 15088.5(a) and requires re-circulation of the document. The ACUSD must allow public participation in the CEQA process. Adding the necessary analyses and allowing the public a chance to review and comment on that information is critical to the decision-making process.

We sincerely hope you, Mr. Critchfield, and the District's consultants address the deficiencies in the Draft Environmental Impact Report so the Amador County Unified School District Board of Trustees has accurate information to make an informed decision. Towards that objective, city staff encourages you and your staff and consultants to work collaboratively to ensure that potential impacts to the students and citizens are adequately analyzed and appropriate mitigation is detailed and implemented.

Sincerely,
Thin afaue
fison LaFayn
City of lone, Mayor
CC: Amador County Unified School District Board of Trustees Amador County Transportation Commission
4 California State Clearinghouse
Caltrans, District 10

Ione City CouncilFebruary 20, 2024

Ione City Council
February 20, 2024