City of Sacramento
City Council - 5PM Report
915 I Street Sacramento, CA 95814
www.cityofsacramento.org
File ID: 2024-01776 10/22/2024 Consent Item 5.
Accepting Sacramento Area Flood Control Agency’s 2024 Urban Level of Flood Protection (ULOP) Adequate Progress Annual Report
File ID: 2024-01776
Location: Citywide
Recommendation: Adopt a Resolution accepting Sacramento Area Flood Control Agency’s 2024 Urban Level of Flood Protection Adequate Progress Annual Report.
Contact: Remi Mendoza, Acting Long Range Planning Manager, (916) 808-5003, [email protected], Community Development Department; Rosa Millino, Senior Engineer, (916) 808-1451, [email protected]; Neal Joyce, Supervising Engineer, (916) 808-1461, [email protected]; Department of Utilities.
Presenter: None
Attachments:
1-Description/Analysis
2-Resolution
3-Exhibit A-SAFCA 2024 ULOP Adequate Progress Annual Report 4-Transmittal Cover Letter from SAFCA’s Board
Description/Analysis
Issue Detail: On June 21, 2016, the City Council passed a resolution accepting the Sacramento Area Flood Control Agency’s (SAFCA) Urban Level of Flood Protection (ULOP) Plan, prepared pursuant to Senate Bill 5 (SB 5) and related legislation. The ULOP Plan identifies flood improvement projects, cost estimates, anticipated funding sources, and a schedule to complete them by 2025, which would result in 200-year flood protection for the city.
When considering development within a flood hazard zone, the City has relied on the 2016 ULOP Plan and the subsequent 2017 through 2023 ULOP annual reports as substantial pieces of evidence that SAFCA has made adequate progress on the construction of a 200-year flood protection system.
The purpose of the ULOP annual report is to provide an additional piece of the substantial evidence
File ID: 2024-01776 10/22/2024 Consent Item 5.
necessary to support the “adequate progress finding” in the approval of new development within a flood hazard zone. Attached is SAFCA’s eighth annual report, the 2024 ULOP Adequate Progress Annual Report intended to serve that purpose (Attachment 3). The annual report concludes that SAFCA is meeting State standards for adequate progress on achieving a 200-year urban level of flood protection. Staff recommends that Council adopt a resolution accepting the SAFCA 2024 ULOP Adequate Progress Annual Report.
Policy Considerations: The 2040 General Plan includes the following goals and policies related to flood protection:
GOAL Environmental Resources and Constraints (ERC-6) Protection of life and property from flooding hazards.
ERC-6.6 Flood Regulations. The City shall continue to regulate new development in accordance with State requirements for 200-year level of flood protection and federal requirements for 100-year level of flood protection.
ERC-6.8 Interagency Levee Management. The City shall coordinate with local, regional, State, and federal agencies to ensure new and existing levees are adequate in providing flood protection and coordinate to achieve local certification of levees for 200-year flood protection by 2025.
Economic Impacts: Not applicable.
Environmental Considerations: Policies to achieve a 200-year level of flood protection were included in the 2040 General Plan and evaluated in the certified Master Environmental Impact Report. Acceptance of the SAFCA 2024 ULOP Adequate Progress Annual Report will enable the City to use this document for future flood-related findings in compliance with state law. Acceptance of this document constitutes an administrative action that will not result in direct or indirect physical changes in the environment, and the action is not a project that requires environmental review under the California Environmental Quality Act (CEQA). See CEQA Guidelines section 15378(b)(5); 15060 (c)(3).
Sustainability: The proposed resolution will reduce flood risk by strengthening the linkage between local land use planning decisions and flood management practices. This resolution would also support the City’s efforts to promote urban infill and redevelopment.
Commission/Committee Action: None.
Rationale for Recommendation: Approval of this resolution will achieve compliance with state law (SB 5 and subsequent amendments) thereby allowing the City to make the required findings related
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to flood protection for approval of developments projects.
Financial Considerations: Not applicable.
Local Business Enterprise (LBE): Not applicable.
Background: In 2007, the California Legislature enacted SB 5 and other interrelated bills in effort to strengthen the link between flood management and local land use planning decisions. Per the new state law, effective on July 1, 2016, cities and counties within the Central Valley have been required to make one of the following findings before approving development agreements, tentative maps, discretionary permits, and ministerial permits for new residences:
1. The existing flood management facilities protect the property to an urban level of flood prote ction, or
2. The city has imposed conditions that will protect the property to an urban level of flood protection, or
3. The local flood management agency has made adequate progress on the construction of a flood protection system to provide an urban level of flood protection by 2025, or
4. The property is in an undetermined risk area.
In most cases the ULOP is defined as protection against a 200-year flood. In the Sacramento region, major improvements to levee systems are ongoing which will provide 200-year flood protection by 2025. In 2016 the City’s Local Flood Management Agency - SAFCA - prepared an ULOP Plan which has aided the City in making the “adequate progress finding” (No. 3 above). SAFCA’s ULOP plan highlights key planned improvements that will provide Sacramento with a 200-year level of flood protection, their costs, revenues to fund them, and a schedule to complete them by 2025. On June 27, 2016, the City Council accepted SAFCA’s ULOP plan (Resolution No. 2016-0226).
In order for the City to continue to rely on making the “adequate progress finding”, the California Government Code § 65007(a)(5) further requires the City to annually report to the Central Valley Flood Protection Board on its efforts in working towards completion of the 200-year flood protection system. Accordingly, SAFCA staff and consultants have prepared the 2024 ULOP: Adequate Progress Annual Report for the City to fulfill Government code requirements which document the following:
· The total project scope, schedule, and cost of the flood protection system have been developed to meet 200-year flood protection.
· That 90% of the required revenues scheduled to be received by that year have been appropriated and is being expended;
· Critical features of the Flood Protection System are under construction and progressing based upon the actual expenditures of the construction budget; and
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· The City has not been responsible for a significant delay in the completion of the system.
In summary the 2024 ULOP adequate progress annual report demonstrates that:
· Over 100% of the revenue scheduled to be received has been appropriated and are currently being expended;
· Critical features of the flood protection system are under construction and progressing based upon the actual expenditures of the construction budget in that:
All Protected Areas - All of the SAFCA protected basins benefit from the Folsom Dam Modifications. The first element of the modifications, the JFP, was largely completed in 2016.Since then the completed project has been turned over to the U.S. Bureau of Reclamation and the Water Control Manual has been formally executed.
Natomas - SAFCA has largely completed its Natomas Levee Improvement Program (NLIP), which improved levees on the north and part of the west perimeter of the basin. The ARCF 2014 Natomas Basin Project is improving the basin’s remaining levees and drainage infrastructure, which are referred to in sequential reaches starting with Reach A from the American River confluence to San Juan Road and moving around the basin in a clockwise direction (USACE, 2022b). Levee construction is underway in Reach A on the SREL. Work on the drained stability berm from City Sump 160 to Gateway Oaks Boulevard will likely be completed in 2026. Work at the RD 1000 Pump Plant 1B should be completed in 2026. ULOP conformance in 2025 will require obtaining a set of record drawings as of 2025 and engineer confirmation that the interim construction condition meets ULDC. USACE Reach B (along the SREL north of San Juan Road to Elverta Road) construction is essentially complete.
Construction of Riverside Pumping Plant in this reach is underway. Levee construction is essentially complete in Reach C (from Elverta Road to the Natomas Cross Canal) with Pritchard Pumping Plant construction scheduled for 2025. Levee construction in Reach D (Natomas Cross Canal South Levee) is complete except at Highway 99. Work continues at Pumping Plant 4, where the remaining electrical equipment is expected to be installed by the end of 2024. The construction contract for Reach E (Pleasant Grove Creek Canal West Levee) was awarded in April 2023. Reaches F and G (Natomas East Main Drainage Canal West Levee) are currently being designed. Construction award is expected in 2025 and completion in 2028. A ULDC exception for freeboard deficiencies may be required in the northern part of Reach F and would require slope hardening features. At this point, it’s unclear whether this will be constructed by the USACE. If not, then SAFCA will need to design and construct, and completion would occur in 2030. Seepage cutoff wells, levee slope flattening, and improvements to two stormwater pumping stations are essentially complete on USACE Reach H (along the NEMDC West Levee from Dry Creek to the Arden Garden Connector). Reach I Contract 1 (American River North Levee west of Northgate Boulevard) included a blanket
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drain constructed under the I-5 overpass and a cutoff wall to the west along the Garden Highway. Both of these components are now complete. Reach I contract 2 will begin construction in 2024. Natomas benefits from the Folsom Dam Modifications discussed above.
Dry Creek North Levee System - No construction projects are required for the Dry Creek North Levee.
Robla Creek to Arcade Creek - In 2017, fourteen relief wells were constructed along the Arcade Creek North Levee. Construction of cutoff walls under SAFCA construction Contract 4355 is now substantially complete. Improvements to the Magpie Creek Diversion Channel as part of ARCF 2016 are known as the Magpie Creek Project. The project is being designed now and will be constructed after 2025. A short reach of the Robla Creek south levee downstream of Dry Creek Road does not meet freeboard, but affects a small area and flooding would be less than three feet deep.
American River North Levee - Cutoff walls along the Arcade Creek South Levee and NEMDC East Levee and were completed by USACE in 2015.
American River South and Sacramento River East Levee - Structural improvements to the Sacramento River East Levee have been designed, and USACE has retained a construction contractor. Contract 1 included work in the Pocket area and a seepage berm near Front Street and Miller Park that is now complete (USACE, 2022a). The second contract along the Sacramento River East Levee in the Pocket area, includes cutoff wall construction, now complete, and relief wells to address seepage and stability issues. Construction Contract 3 is complete. SREL Contract 4 was awarded in 2023 and should be complete in 2024.
Work is also planned north of Miller Park near U.S. Highway 50. Encroachments in the construction footprint were removed by SAFCA. Under its “levee modernization” project, SAFCA acquired a property adjoining the levee and removed encroachments on it preparatory to splitting the property under the flood easement and conveying fee title to the State or City. A voluntary encroachment removal program has been initiated for other affected properties. The Morrison Creek and Beach Lake Levee Resiliency Project 65% design is complete. In 2019, SAFCA also constructed an oak woodland mitigation project to provide a wind-wave buffer for the levee.
South Sacramento Streams Group - Upstream of the UPRR, construction is complete on the Florin Creek channel improvements and the Florin Creek Multi-Use Basin project. This project was intended to meet FEMA 100 year criteria but was not designed to meet ULDC requirements. The Federal Emergency Management Agency (FEMA) issued a LOMR for that work that became effective on March 25, 2019. The City or County may choose to
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investigate whether some areas where 200-year flood depths are below 3 feet may be newly eligible for a ULOP finding based on the project providing 100-year protection. · The City of Sacramento has not been responsible for a significant delay in the completion of the flood protection system.
The annual report shows that SAFCA is meeting State standards for adequate progress on achieving the 200-year Urban Level of Flood Protection (ULOP). On July 18, 2024, this report was reviewed and approved by the SAFCA Board for distribution to and use by local agencies.
Staff recommends the Council pass a resolution accepting SAFCA’s 2024 ULOP Adequate Progress Annual Report. When considering development within a flood hazard zone, the City will rely on SAFCA’s 2016 ULOP Plan and the most recent 2024 annual report as important pieces of substantial evidence in making the “adequate progress finding”.
RESOLUTION NO. 2024-
Adopted by the Sacramento City Council
Date Adopted
ACCEPTING THE SACRAMENTO AREA FLOOD CONTROL AGENCY 2024 URBAN LEVEL OF FLOOD
PROTECTION ADEQUATE PROGRESS ANNUAL REPORT
BACKGROUND
A. The Central Valley Flood Protection Act of 2008 (the “Act”) prohibits cities and counties, beginning July 1, 2016, from entering into development agreements, approving discretionary permits or ministerial permits that would result in the construction of a new residence, or approving tentative or parcel maps for areas located within a flood hazard zone unless the city or county makes one of the findings set forth in the legislation. (See Government Code sections 65865.5, 65962, and 66474.5.)
B. On March 1, 2016, the City Council adopted Ordinance No. 2016-0012, which makes various changes to the City Code to conform to the Act.
C. One of the Act’s required findings—the “adequate-progress finding”—allows development to proceed within a flood hazard zone if the city or county finds the local flood management agency has made adequate progress (as defined in Government Code section 65007) on the construction of a flood protection system that will result in flood protection equal to or greater than the urban level of flood protection (“ULOP”) in urban or urbanizing areas or the national Federal Emergency Management Agency (“FEMA”) standard of flood protection in nonurbanized areas intended to be protected by the system.
D. The California Department of Water Resources has declared that the adequate-progress finding must be based on the following: a report prepared by the applicable local flood management agency demonstrating adequate progress; a report prepared by a professional civil engineer that documents the data and analysis for demonstrating the property, development project, or subdivision will have an urban level of flood protection at the time when the flood protection system is completed; a report by an independent panel of experts on the review of the report prepared by the professional civil engineer; a response by the professional civil engineer to the comments from the independent panel of experts; the most recent annual report prepared by local flood management agency that was submitted to the Central Valley Protection Board documenting the efforts in working toward completion of the flood protection system; and any additional data and information that cities or counties use to make the finding. (See California Department of Water Resources, Urban Level of Flood Protection Criteria, page 2-10.)
E. In 2016, consistent with these mandates, the City of Sacramento’s (City) local flood management agency—the Sacramento Area Flood Control Agency (SAFCA)—prepared documents to support the adequate-progress. On June 21, 2016, the City Council adopted
Resolution No. 2016-0226 accepting SAFCA’s urban level of flood protection plan and adequate progress baseline report and adequate progress towards an urban level of flood protection engineer’s report.
F. On November 7, 2017, the City Council adopted Resolution No. 2017-0418 accepting SAFCA’s ULOP Adequate Progress Annual Report.
G. On November 20, 2018, the City Council adopted Resolution No. 2018-0445 accepting SAFCA’s ULOP Adequate Progress Annual Report.
H. On October 22, 2019, the City Council adopted Resolution No. 2019-0398 accepting SAFCA’s ULOP Adequate Progress Annual Report.
I. On October 13, 2020, the City Council adopted Resolution No. 2020-0326 accepting SAFCA’s ULOP Adequate Progress Annual Report.
J. On November 9, 2021, the City Council adopted Resolution No. 2021-0328 accepting SAFCA’s ULOP Adequate Progress Annual Report.
K. On October 11, 2022, the City Council adopted Resolution No. 2022-0313 accepting SAFCA’s ULOP Adequate Progress Annual Report.
L. On October 24, 2023, the City Council adopted Resolution No. 2023-0337 accepting SAFCA’s ULOP Adequate Progress Annual Report
M. In 2024, SAFCA has prepared the following to support the adequate-progress finding: the Urban Level of Flood Protection Adequate Progress Annual Report. This document concludes that the levees that protect much of the City do not currently meet ULOP requirements, but SAFCA is meeting the State standards in demonstrating adequate progress towards achieving ULOP in urban or urbanizing areas or the national Federal Emergency Management Agency standard of flood protection in nonurbanized areas for property located within a flood hazard zone, intended to be protected by the system, by 2025.
N. On July 18, 2024, the SAFCA Board of Directors approved the ULOP Adequate Progress Annual Report for distribution to and use by the City and other agencies.
O. The 2024 ULOP Adequate Progress Annual Report is an informational document that describes actions already being undertaken or planned by SAFCA and is not subject to the California Environmental Quality Act (CEQA). The environmental effects of the projects have been addressed at a program level by the 2016 Updated Local Funding Mechanisms for Sacramento Area Flood Control Improvements Subsequent Environmental Impact Report (EIR) and the underlying 2007 Program EIR. Policies to achieve a 200-year level of flood protection were included in the 2040 General Plan and evaluated in the certified Master Environmental Impact Report. The City’s acceptance of the SAFCA 2024 Urban Level of Flood Protection Adequate Progress Annual Report will enable the City to use that document and the ULOP and Engineer’s Report for flood related findings in compliance with State law. Acceptance of these
documents constitutes an administrative action that will not result in direct or indirect physical changes in the environment, and the action is not a project that requires environmental review under the California Environmental Quality Act (CEQA). See CEQA Guidelines sections 15378(b)(5) and 15060(c)(3). The need for additional CEQA compliance for individual projects will need to be considered at the time those projects are advanced.
BASED ON THE FACTS SET FORTH IN THE BACKGROUND, THE CITY COUNCIL RESOLVES AS FOLLOWS:
Section 1. The City Council accepts SAFCA’s 2024 ULOP Adequate Progress Annual Report, attached as Exhibit A and by this reference made a part of this resolution
Section 2. When considering development within a flood hazard zone, the City may rely on the 2024 ULOP Adequate Progress Annual Report, the ULOP and the Engineer’s report referenced in Resolution No. 2016-0226, as substantial evidence that SAFCA has made adequate progress (as defined in Government Code section 65007) on the construction of a flood protection system that will result in flood protection equal to or greater than the urban level of flood protection in urban or urbanizing areas or the national Federal Emergency Management Agency standard of flood protection in nonurbanized areas for property located within a flood hazard zone, intended to be protected by the system.
Table of Contents:
Exhibit A – SAFCA’s 2024 ULOP Adequate Progress Annual Report
2024
Urban Level of Flood Protection
Annual Report
Final – August 2024
1325 J Street Suite 1700
Sacramento, CA 95814
(916) 874-7606
Final 2024 Urban Level of Flood Protection Annual Report 1
TABLE OF CONTENTS
1. Introduction ............................................................................................................................. 2
2. Planned scope, Schedule, and Cost ......................................................................................... 2
2.1 Project Scope .................................................................................................................... 3
2.2 Schedule ............................................................................................................................ 6
2.3 Costs, Revenues, and Appropriations.............................................................................. 10
3. Construction of Critical Features .......................................................................................... 11
4. Delays .................................................................................................................................... 13
5. References for Data Used ...................................................................................................... 14
FIGURES
Figure 1: SAFCA Projects .............................................................................................................. 4
TABLES
Table 1: Timeline for Projects ........................................................................................................ 7
Table 2: ARCF Natomas Basin Project Status Detail ..................................................................... 8 Table 3: ARCF 2016 Project Status Detail ..................................................................................... 9 Table 4: Morrison Creek and Beach Lake Levee Resiliency Project Status Detail ...................... 10 Table 5: Planned Expenditures ($millions, all sources)................................................................ 10 Table 6: Cumulative Planned Expenditures, Actual Appropriations and Actual Expenditures Through 2023-2024 ($millions, all sources) ................................................................................. 11
Final 2024 Urban Level of Flood Protection Annual Report 2
1. INTRODUCTION
California Government Code (CGC) Section 65007(a)(5) requires local agencies to “annually report to the Central Valley Flood Protection Board on the efforts in working toward completion of the flood protection system.” State requirements are further described in the Urban Level of Flood Protection Criteria (ULOP Criteria; DWR, 2013).
This report describes Sacramento Area Flood Control Agency (SAFCA)’s efforts in improving the regional flood protection system over the fiscal year ending on June 30, 2024. Section 5 of the SAFCA Final Urban Level of Flood Protection Plan and Adequate Progress Baseline Report (ULOP Plan) noted that the majority of funding for SAFCA’s projects comes from State and Federal agencies over which SAFCA has no control (SAFCA, 2016).
This annual report only addresses the State Plan of Flood Control (SPFC) facilities. The local land use agencies, acting as floodplain managers, must consider this plan along with their own data to determine whether residual risks, including interior drainage and flood sources not managed by SPFC facilities, affect development projects to such a degree that the projects would be subject to flood protection findings under state law. If a land use agency is required to make a flood protection finding, the finding must be selected from one of those summarized below:
(1) Existing facilities provide ULOP in urban areas or meet the Federal Emergency Management Agency (FEMA) standard in nonurbanized areas;
(2) Conditions on the project will protect it to the applicable standard;
(3) The local flood management agency has made adequate progress on a flood system providing the applicable level of protection. For urban and urbanizing areas protected by project levees, ULOP will be achieved by 2025; or
(4) The property in an undetermined risk area has met ULOP based on substantial evidence in the record.
Development in areas dependent on flood risk reduction projects that are still under construction typically relies on the third finding listed above. In the event that ULOP has not been or cannot be achieved by 2025 under one of the possible findings, the local agency may not approve certain development activities within the affected area. This report is not intended to be a substitute for the independent judgment of the local agencies in adopting their findings.
2. PLANNED SCOPE, SCHEDULE, AND COST
CGC Section 65007(a)(1) requires the local flood management agency to report “the total project scope, schedule, and cost” of meeting ULOP with the agency’s flood protection system. This information was detailed in the ULOP Plan and is summarized here.
Final 2024 Urban Level of Flood Protection Annual Report 3
2.1 Project Scope
The following projects, illustrated in Figure 1, will help attain the Urban Level of Flood Protection in SAFCA’s protected areas.
Folsom Dam Modifications – Folsom Dam Modifications include three related projects: the Folsom Joint Federal Project (JFP), the Folsom Dam Raise Project, and the Folsom Dam Water Control Manual Update.
The JFP is a joint project of the US Bureau of Reclamation, US Army Corps of Engineers (USACE), DWR, and SAFCA. The JFP created a new, gated auxiliary spillway on the east abutment of the dam, enabling the dam to be operated to accommodate a 200-year flood with a discharge of about 115,000 cubic feet per second (cfs) into the lower American River. The design flow accommodated by full use of the dam's river outlets and the auxiliary spillway is 160,000 cfs.
The Folsom Dam Raise Project is increasing the height of the main dam, wing dams, and dikes that contain Folsom Reservoir. Congress has authorized raising the height of the wing dams and dikes by 3.5 feet. This will allow flood operators to store more flood water when forecasted inflows are decreasing (resulting in no imminent threat to the dam) and the additional storage is required to maintain releases from the dam at a level that can be safely contained by the downstream levee system. The project also includes improving the flood gates on the main dam (USACE, 2017).
The Folsom Dam Water Control Manual was updated in 2019 to optimize operations at the dam with the JFP improvements. Once the Folsom Dam Raise Project is completed, the manual will be adjusted again to reflect the increased reservoir storage capacity created by that project.
American River Common Features (ARCF) 2014 Natomas Basin Project (formerly called the Natomas Basin USACE Project) – The Natomas levees are being improved in two phases.
Physical construction of the Natomas Levee Improvement Program (NLIP) Local Project, led by SAFCA, is complete and comprised eighteen miles of improvements to the Natomas Cross Canal south levee and the Sacramento River East Levee. The ARCF 2014 Natomas Basin Project consists of levee improvements around the remainder of the 42-mile Natomas Basin perimeter.
The USACE is planning and implementing the remaining elements (USACE, 2015):
• American River North Levee adjacent to Natomas Basin – widen 2 miles of levee in place and install a seepage cutoff wall through the levee and foundation. • Sacramento River East Levee adjacent to Natomas Basin – construct 5 miles of adjacent levee, 3.3 miles of deep seepage cutoff walls, and 4.3 miles of seepage berms • Pleasant Grove Creek Canal adjacent to Natomas Basin - Widen 3.3 miles of levee in place and install a soil bentonite cutoff wall on the Pleasant Grove Creek Canal West Levee.
• Natomas East Main Drainage Canal (NEMDC)/Steelhead Creek West Levee – widen
12.8 miles of existing levee and install 10.7 miles of cutoff wall.
2022 Urban Level of Flood Protection Annual Report 4
Figure 1: SAFCA Projects
2022 Urban Level of Flood Protection Annual Report 5
• Natomas Cross Canal (NCC) South Levee – complete construction at gaps not remediated as part of NLIP at Bennett and Northern pumping plants and at the State Route 99 closure structure.
ARCF 2016 (formerly called American River Common Features General Reevaluation Report (GRR)) – The ARCF GRR was authorized by Congress in the Water Resources Development Act (WRDA) 2016 and is now known as ARCF 2016. ARCF 2016 features include additional bank protection along the American and Sacramento Rivers; levee height and seepage improvements along Arcade Creek; levee improvements, levee extension, purchase of flowage easements, and channel widening on the Magpie Creek Diversion Channel (MCDC); and changes to the Sacramento Weir and Bypass. On the Sacramento River East Levee downstream of the American River, ARCF 2016 is improving deficient sites with features like the following:
• Slurry cutoff walls to address levee seepage and stability • Rock bank protection to address erosion
• Geotextile slope stabilization to address levee stability • Slope flattening to address levee stability
• Levee raise to address freeboard deficiency
Bank protection along the American River consists of rock revetment with planting berms where feasible. In some cases “launchable rock” trenches, when undermined by erosion, are designed to release rocks onto the erosion surface.
Levee Accreditation Project (LAP) – The LAP is a locally-led construction project that advanced portions of the ARCF 2016 prior to congressional authorization and funding. The LAP includes slurry cutoff walls along the Arcade Creek North Levee, the NEMDC East Levee, and the Arcade Creek South Levee (AECOM, 2015). SAFCA also began design along the Sacramento River East Levee (SREL) downstream of the American River. SAFCA’s design project included stability berms, relief wells, relief well improvements, cutoff walls, and toe drains. The project also included erosion repairs. The USACE took over design efforts along the Sacramento River in 2018 and is leading construction. Structures and vegetation encroaching on the levees will be removed if necessary to meet National Flood Insurance Program (NFIP) standards and the State’s Urban Levee Design Criteria (ULDC).
The southernmost reach of the SREL at its junction with the Beach Lake Levee was evaluated in 2018 (MBK, 2018). MBK recommended improving the Beach Lake Levee and the Sacramento River East Levee downstream of the Beach Lake Levee. The recommendations included raising the Beach Lake Levee to meet ULDC requirements, possibly in conjunction with a riparian wind-wave buffer and DWR improvements to the levees of the McCormack-Williamson Tract.
These improvements can provide ULOP. SAFCA has proceeded with the wind-wave buffer and is designing potential levee improvements consistent with ULDC known as the Morrison Creek and Beach Lake Levee Resiliency Project. In 2022 SAFCA submitted a grant request to FEMA to complete the levee raise with additional nature-based features for resiliency. The grant was awarded in 2024.
Final 2024 Urban Level of Flood Protection Annual Report 6
South Sacramento County Streams Group (SSSG) Project – USACE was the lead agency on this completed project, which consisted of improvements to the Beach Levee, levees and channels along Morrison Creek and its tributaries in South Sacramento, including Florin Creek, Elder Creek, and Unionhouse Creek. Physical work is now complete.
Florin Creek Multi-Use Basin Project – In moderate and larger flood events, the completed Florin Creek Multi-Use Basin Project can store up to 30 acre-feet of Florin Creek flows at Florin Creek Park on the north bank of Florin Creek (ESA, 2014). It provides at least 100-year flood protection within its floodplain in conjunction with the Florin Creek capacity improvements constructed by USACE as part of the South Sacramento County Streams Group Project.
Non-Structural Actions – The state’s ULDC (DWR, 2012) are incorporated by reference in the ULOP Criteria and require many actions that are good practices for the effective operation and maintenance of levee systems to sustain system performance. These actions include such measures as engineering evaluation and documentation, development of security and safety plans, and other items. The non-structural actions and their necessity are described in greater detail in the Adequate Progress Engineer’s Report (MBK, 2016). Ongoing operation, maintenance, repair, and rehabilitation may be considered ongoing non-structural actions that to the extent required are funded by SAFCA and its land use agency and local maintaining agency partners. Progress on these actions is not reported here unless the actions are “critical features” under the meaning of CGC Section 65007(a)(3).
2.2 Schedule
The Urban Level of Flood Protection must be achieved by the year 2025 in order for land use agencies, in approving new development, to make a finding that adequate progress is being made on the construction of a flood protection system (CGC §65865.5, §65962, and §66474.5). Table 1 on the next page lists the schedule for SAFCA projects. Table 2 provides additional detail on the ARCF 2014 Natomas Basin Project, Table 3 provides additional detail on the ARCF 2016 Project, and Table 4 provides additional detail on the Morrison Creek and Beach Lake Levee Resiliency Project.
Final 2024 Urban Level of Flood Protection Annual Report 7
Table 1: Timeline for Projects
Project
Natomas
Levee
System
Dry
Creek
Levee
System
Robla
Creek –
Arcade
Creek
Levee
System
American
River
North
Levee
System
American
River South
and
Sacramento
River East
Levee
System
South
Sacramento
Streams
Levee
System
Construction
Status
Folsom Dam
Modifications
- JFP
JFP
required for
ULOP
Not
required
JFP
required for
ULOP
JFP
required
for ULOP
JFP required
for ULOP
JFP required
for ULOP
JFP complete.
Folsom Dam
Modifications
- Raise
Not
required for
ULOP
Not
required
for
ULOP
Not
required for
ULOP
Not
required
for ULOP
Not required
for ULOP
Not required
for ULOP
Not required
for ULOP
ARCF 2014
Natomas
Basin Project
Required
for ULOP
(Table 2)
Not
required
Not
required
Not
required
Not required Not required See detail in
Table 2
NLIP Local
Project
Required
for ULOP
Not
required
Not
required
Not
required
Not required Not required Complete
ARCF 2016
(elements
required for
200-year
protection)
Provides
resiliency
(lowers
water
surface)
Not
required
Provides
resiliency
Some
elements
required
for ULOP
(Table 3)
Some
elements
required for
ULOP
(Table 3)
Provides
resiliency
See detail in
Table 3
LAP Not
required
Not
required
Required
for ULOP
Required
for ULOP
Not required Not required Complete by
2023
SSSG Not
required
Not
required
Not
required
Not
required
Not required Site
specific*
Complete
Florin Creek
Multi-Use
Basin
Not
required
Not
required
Not
required
Not
required
Not required Site
specific*
Complete
Additional
South
Sacramento
SPFC
Project(s) at
Beach Lake
Levee
Not
required
Not
required
Not
required
Not
required
Some
elements
required for
ULOP
(Table 4)
Not
Required
See detail in
Table 4
*This plan provides 200-year design flood risk reduction in the South Sacramento Streams area downstream of the Union Pacific Railroad (UPRR), subject to the evaluation of additional south Sacramento SPFC projects. Upstream of UPRR, the land use agency’s determination of whether ULOP is attained will depend on the specific site and development proposal as some areas of residual flooding over 3 feet deep remain. At some sites, the listed projects will help attain ULOP.
Final 2024 Urban Level of Flood Protection Annual Report 8
Table 2: ARCF Natomas Basin Project Status Detail
Element Status
Elements
Required
for ULOP
ULOP Ready
for
Engineer’s
Report*
Reach A
Gateway Oaks Dr
to Farm Rd
Cutoff wall work upstream of I-80 to be
completed in 2024, with the full adjacent
levee to be completed in 2025. Pumping
Plant 1B and drained stability berm from
Sump 160 to Gateway Oaks Drive to be
finished in 2026.
All Complete by
2025**
Reach B
San Juan Rd to
W. Elverta Rd
Levee construction complete. Pumping
Plant #3, and I-5 window complete.
Riverside Pumping Plant underway.
Elkhorn Pumping Plant to begin in 2025.
All Complete by
2025**
Reach C
W. Elverta Rd to
Sankey Rd
Levee construction completed by SAFCA.
Pritchard Pumping Plant to begin
construction in 2025.
All Complete by
2025**
Reach D
Sankey Rd to
Howsley Rd
Levee construction completed by SAFCA.
Highway 99 window work begins 2024.
Pumping Plant #4 to be completed 2024.
All Complete by
2025
Reach E
Howsley Rd to
Sankey Rd
Levee construction began Spring 2023 and
continues in 2024.
All Complete by
2025
Reaches F&G
Sankey Rd to
NEMDC
Pumping Station
Levee construction and slope improvements
to start in 2025 and be completed in 2028
(2030 if landside slope hardening features
aren’t contracted by USACE). Pumping
Plant #6 to begin Summer 2024.
All Construction
underway by
2025.***
Reach H
NEMDC
Pumping Station
to Northgate Blvd
Contract 1 - NEMDC Pump Station to
Arden-Garden: Work has been completed.
Contract 2 - Arden-Garden to Northgate:
Landside levee work and installation of
maintenance road to begin 2024.
All Complete by
2025
Reach I
Northgate Blvd to
Gateway Oaks Dr
Contract 2: Landside levee improvements
and installation of maintenance road to
begin 2024.
All Complete by
2025
Sources: USACE 2022b, SAFCA.
*Reflects status at the time of this report based on the substantial completion of construction features sufficient to complete an Engineer’s Report showing attainment of ULOP. Estimates are subject to change. SAFCA cannot control the schedule of projects led by other agencies. **Construction is expected to be substantially complete by the end of 2025. Final completion and documentation may go into 2026.
***The schedule for reaches F&G is contingent on continued full funding from the federal government and continued actions by the SAFCA Board of Directors authorizing necessary real estate purchases as well as the USACE constructing the landside slope hardening.
Final 2024 Urban Level of Flood Protection Annual Report 9
Table 3: ARCF 2016 Project Status Detail
Element Status Elements Required
for ULOP
ULOP
Attainment*
Sacramento River
East Levee –
Seepage,
Stability, &
Overtopping
Contracts C1 and C2 complete.
Contract C3 complete.
SREL C4 under construction.
All Complete by
2025
Sacramento River
East Levee –
Erosion
Contract C1 complete. C2 to be
constructed in 2023 and 2024.
Only C1 and C2 are
required for ULOP.
Contracts C1
and C2
complete by
2025.
Magpie Creek Construction will begin after
2025.
Areas where flood
depths are greater
than 3 feet and
buildings cannot be
elevated.
Attainment
will be after
2025.
North Area
Streams
Work on Arcade Creek is
complete except for utility
remediation at NEMDC to be
completed by 2025. A short
reach of the Robla Creek South
Levee does not meet freeboard
but the area protected is below the
applicable 3-foot flood depth
criterion LOC-1 in the ULOP
Criteria.
All Complete by
2025. An
isolated
floodplain
with
insufficient
freeboard on
Robla Creek
South levee
may remain.
American River –
Erosion
Contract C1 under construction.
C2 – under construction.
C3A – under construction in 2024
Only C1 and C2 are
required for ULOP.
Complete by
2025.
Sources: USACE 2022c, USACE 2022d, SAFCA
*Attainment status reflects the most current information at the time of this report. These estimates are subject to change. SAFCA cannot control the schedule of projects led by other agencies.
Final 2024 Urban Level of Flood Protection Annual Report 10
Table 4: Morrison Creek and Beach Lake Levee Resiliency Project Status Detail Element Status
Elements
Required for
ULOP
ULOP
Attainment*
Up to 1.7 Foot
Levee and
Floodwall Raise,
Seepage berm
and Pump Station
Improvements
Major pump station maintenance is
planned to start in 2024. Backwater
freeboard will be provided under an
emergency management plan in the
event of a rural levee failure on the
Sacramento River downstream of
Beach Lake Levee.
Required for
ULOP.
SAFCA is
investigating
whether a ULDC
exception is
feasible allowing
interim findings to
be made under the
Urban Level of
Flood Protection
Criteria until
completion of
construction
within five years.
Source: SAFCA
*Attainment status reflects the most current information at the time of this report. These estimates are subject to change. SAFCA cannot control the schedule of projects led by other agencies.
2.3 Costs, Revenues, and Appropriations
System improvement costs, or planned expenditures, were shown in the ULOP Plan as required by CGC Section 65007(a)(1). Revenues to fund those expenditures were also identified pursuant to CGC 65007(a)(2)(A). Table 5 shows combined planned expenditures for all agencies along with actual expenditures. Table 5 demonstrates that expenditures are keeping pace with or exceeding the planned level.
Table 5: Planned Expenditures ($millions, all sources)
Fiscal
Year
2015-
2016
2016-
2017
2017-
2018
2018-
2019
2019-
2020
2020-
2021
2021-
2022
2022-
2023
2023-
2024
2024-
2025
2025-
2026
Original
ULOP
Plan
Costs*
$171.6 $141.0 $111.3 $149.9 $125.5 $125.5 $163.6 $126.6 $126.6 $108.8 $53.9 Actual
Spent** $167.8 $114.3 $123.1 $171.3 $428.3 $644.5 $608.3 $242.7 $199.0 N/A N/A * Original ULOP Plan Costs include capital projects and levee modernization. Values in the 2016 ULOP Plan included system operations and maintenance (O&M) which are no longer shown. ** Actual expenditures are SAFCA actuals plus estimates of other agency expenditures based on funding agreements and/or the progress of the projects.
SAFCA, State, and Federal appropriations also remain consistent with the plan, as shown in Table 6. CGC Section 65007(a)(2)(A) specifies that adequate progress means that 90 percent of the revenues scheduled to be received by that year have been appropriated and are currently
Final 2024 Urban Level of Flood Protection Annual Report 11
being expended. Table 6 shows this requirement has been met with over 100 percent of scheduled revenues appropriated to date. The Federal and State appropriations reflect Congressional authorizations and executed funding agreements. SAFCA appropriations reflect past spending and current year appropriations. Section 3 of this report will describe how these appropriations are being expended.
Table 6: Cumulative Planned Expenditures, Actual Appropriations and Actual Expenditures Through 2023-2024 ($millions, all sources) Agency
Planned
Expenditures*
Actual
Appropriations**
Actual
Expenditures***
Percent
Appropriated
Versus Planned
Expenditures****
Federal $1,489.9 $2,736.8 $2,801.5 >100%
State $870.0 $1,056.6 $867.1 >100%
Local $47.5 $47.4 $47.5 100%
SAFCA $388.7 $538.73 $548.3 >100%
Total $2,796.1 $4,379.53 $4,264.4 >100%
Notes:
*Planned expenses are the planned cumulative capital project expenses from Fiscal Year 2006-2007 through Fiscal Year 2021-2022 as shown in the 2016 ULOP report. ** For purposes of this report, State appropriations represent the amount of executed State funding agreements with SAFCA. Amounts listed as SAFCA appropriations include past spending plus current year appropriations to avoid double-counting unspent appropriations from prior years. *** Actual expenditures are SAFCA actuals plus estimates of other agency expenditures based on funding agreements and/or the progress of the projects. June 2024 expenditures projected and subject to revision.
**** The federal and total percent appropriated exceed 100% because the federal Bipartisan Budget Act of 2018 (Public Law 115-123) included full funding for the American River Common Features and Folsom Dam Raise.
3. CONSTRUCTION OF CRITICAL FEATURES
Pursuant to Government Code Section 65007(a)(3), adequate progress on construction of a flood protection system means that critical features of the system are under construction and progress is indicated by the expenditure of the budgeted construction funds. The preceding section documented that SAFCA expenditures are on track. This section provides a brief summary of the construction progress in each of the SAFCA protected areas. This report does not distinguish between expenditures for physical construction and those for pre-construction permitting, engineering, and design because the cash flow and planned expenditures in the ULOP Plan do not provide line items for construction alone; and the pre-construction work is a planned and necessary component of ULOP Plan implementation.
All Protected Areas – All of the SAFCA protected basins benefit from the Folsom Dam Modifications. The first element of the modifications, the JFP, was largely completed in 2016.
Final 2024 Urban Level of Flood Protection Annual Report 12
Since then the completed project has been turned over to the U.S. Bureau of Reclamation and the Water Control Manual has been formally executed.
Natomas – SAFCA has largely completed its Natomas Levee Improvement Program (NLIP), which improved levees on the north and part of the west perimeter of the basin. The ARCF 2014 Natomas Basin Project is improving the basin’s remaining levees and drainage infrastructure, which are referred to in sequential reaches starting with Reach A from the American River confluence to San Juan Road and moving around the basin in a clockwise direction (USACE, 2022b). Levee construction is underway in Reach A on the SREL. Work on the drained stability berm from City Sump 160 to Gateway Oaks Boulevard will likely be completed in 2026. Work at the RD 1000 Pump Plant 1B should be completed in 2026. ULOP conformance in 2025 will require obtaining a set of record drawings as of 2025 and engineer confirmation that the interim construction condition meets ULDC. USACE Reach B (along the SREL north of San Juan Road to Elverta Road) construction is essentially complete. Construction of Riverside Pumping Plant in this reach is underway. Levee construction is essentially complete in Reach C (from Elverta Road to the Natomas Cross Canal) with Pritchard Pumping Plant construction scheduled for 2025. Levee construction in Reach D (Natomas Cross Canal South Levee) is complete except at Highway 99. Work continues at Pumping Plant 4, where the remaining electrical equipment is expected to be installed by the end of 2024. The construction contract for Reach E (Pleasant Grove Creek Canal West Levee) was awarded in April 2023. Reaches F and G (Natomas East Main Drainage Canal West Levee) are currently being designed. Construction award is expected in 2025 and completion in 2028. A ULDC exception for freeboard deficiencies may be required in the northern part of Reach F and would require slope hardening features. At this point, it’s unclear whether this will be constructed by the USACE. If not, then SAFCA will need to design and construct, and completion would occur in 2030. Seepage cutoff wells, levee slope flattening, and improvements to two stormwater pumping stations are essentially complete on USACE Reach H (along the NEMDC West Levee from Dry Creek to the Arden Garden Connector).
Reach I Contract 1 (American River North Levee west of Northgate Boulevard) included a blanket drain constructed under the I-5 overpass and a cutoff wall to the west along the Garden Highway. Both of these components are now complete. Reach I contract 2 will begin construction in 2024. Natomas benefits from the Folsom Dam Modifications discussed above.
Dry Creek North Levee System – No construction projects are required for the Dry Creek North Levee.
Robla Creek South Levee, NEMDC East Levee, and Arcade Creek North Levee – In 2017, fourteen relief wells were constructed along the Arcade Creek North Levee. Construction of cutoff walls under SAFCA construction Contract 4355 is now substantially complete.
Improvements to the Magpie Creek Diversion Channel as part of ARCF 2016 are known as the Magpie Creek Project. The project is being designed now and will be constructed after 2025. A short reach of the Robla Creek south levee downstream of Dry Creek Road does not meet freeboard, but affects a small area and flooding would be less than three feet deep.
American River North Levee – Cutoff walls along the Arcade Creek South Levee and NEMDC East Levee and were completed by USACE in 2015.
Final 2024 Urban Level of Flood Protection Annual Report 13
American River South and Sacramento River East Levee – Structural improvements to the Sacramento River East Levee have been designed, and USACE has retained a construction contractor. Contract 1 included work in the Pocket area and a seepage berm near Front Street and Miller Park that is now complete (USACE, 2022a). The second contract along the Sacramento River East Levee in the Pocket area, includes cutoff wall construction, now complete, and relief wells to address seepage and stability issues. Construction Contract 3 is complete. SREL Contract 4 was awarded in 2023 and should be complete in 2024.
Work is also planned north of Miller Park near U.S. Highway 50. Encroachments in the construction footprint were removed by SAFCA. Under its “levee modernization” project, SAFCA acquired a property adjoining the levee and removed encroachments on it preparatory to splitting the property under the flood easement and conveying fee title to the State or City. A voluntary encroachment removal program has been initiated for other affected properties. The Morrison Creek and Beach Lake Levee Resiliency Project 65% design is complete. In 2019, SAFCA also constructed an oak woodland mitigation project to provide a wind-wave buffer for the levee.
South Sacramento Streams Group – Upstream of the UPRR, construction is complete on the Florin Creek channel improvements and the Florin Creek Multi-Use Basin project. This project was intended to meet FEMA 100 year criteria but was not designed to meet ULDC requirements.
The Federal Emergency Management Agency (FEMA) issued a LOMR for that work that became effective on March 25, 2019. The City or County may choose to investigate whether some areas where 200-year flood depths are below 3 feet may be newly eligible for a ULOP finding based on the project providing 100-year protection.
4. DELAYS
Adequate progress towards achieving an Urban Level of Flood Protection means, according to Government Code section 65007(a)(4), that “the city or county has not been responsible for a significant delay,” among other things. In SAFCA’s flood protected areas, this standard has been achieved. As Table 6 demonstrated, to date local agencies have exceeded 100% of their planned expenditures for flood protection.
The ULOP Criteria recommend that annual progress reports address “any delay in State funding appropriation consistent with an agreement between a State agency and a local flood management agency.” As demonstrated earlier, State appropriations to date exceed their planned level.
As the December 31, 2025 deadline for ULOP attainment draws near, it is evident that new delays to remaining scheduled construction activities could constrain attainment for affected portions of the subject basins. Should such a delay arise, the affected jurisdiction or jurisdictions would need to choose whether to temporarily suspend development approvals as required by current ULOP legislation, or to seek a legislative extension that may entail the assumption of some liability for future flood damage to any developments approved without ULOP.
Final 2024 Urban Level of Flood Protection Annual Report 14
5. REFERENCES FOR DATA USED
AECOM. 2015. Draft Environmental Impact Report. North Sacramento Streams, Sacramento River East Levee, Lower American River, and Related Flood Improvements Project. State Clearinghouse No. 2008072060. Prepared for Sacramento Area Flood Control Agency. March.
DOF (California Department of Finance). 2019. State budget detail. Department of Water Resources. May Revise. Available at:
http://www.ebudget.ca.gov/2019-
20/pdf/GovernorsBudget/3000/3860.pdf. Accessed 5/31/2019.
DWR (California Department of Water Resources). 2012. Urban Levee Design Criteria. May.
DWR. 2013. Urban Level of Flood Protection Criteria. November.
DWR. 2017. Central Valley Flood Protection Plan 2017 Update. August.
EPS (Economic & Planning Systems, Inc.). 2016. Sacramento Area Flood Control Agency Development Impact Fee Program 2016 Update. Prepared for Sacramento Area flood Control Agency (SAFCA). October.
ESA, 2014. Florin Creek Multi-Use Basin Project. Initial Study with Intent to Adopt a Mitigated Negative Declaration. State Clearinghouse No. 2014032030. Prepared for Sacramento Area Flood Control Agency. March.
MBK (MBK Engineers). 2016. Sacramento Area Flood Control Agency Adequate Progress Towards an Urban Level of Flood Protection Engineer’s Report. Prepared for SAFCA.
MBK. 2018. Status of ULDC Evaluation of the Beach Lake Levee. Memo to Pete Ghelfi, SAFCA, from Ric Reinhardt, P.E., MBK Engineers.
SAFCA. 2016. Sacramento Area Flood Control Agency Final Urban Level of Flood Protection Plan and Adequate Progress Baseline Report. Prepared for the City of Sacramento and parts of Sacramento and Sutter counties. June 10.
SAFCA. 2017. 2017 Urban Level of Flood Protection Adequate Progress Annual Report.
Prepared for the City of Sacramento and parts of Sacramento and Sutter counties. August 9.
USACE (United States Army Corps of Engineers). 2015. American River Common Features General Reevaluation Report. Final Report. Sacramento District. December. Available at:
http://www.spk.usace.army.mil/Portals/12/documents/civil_works/CommonFeatures/Final_ARC F_GRR_Jan2016.pdf. Accessed June 3, 2016.
USACE. 2017. Record of Decision. Folsom Dam Raise Project. Placer, Sacramento, and El Dorado Counties, California. December 18. Available at:
https://www.spk.usace.army.mil/Portals/12/documents/civil_works/JFP/Raise/ROD_FolsomDam _Raise_Signed_18Dec2017.pdf?ver=2018-03-09-124144-317. Accessed 7/31/2019.
Final 2024 Urban Level of Flood Protection Annual Report 15
USACE. 2022a. Sacramento Levee upgrades. Available at:
https://www.spk.usace.army.mil/Missions/Civil-Works/Sacramento-Levee-Upgrades/ . Accessed
5/18/2022.
USACE. 2022b. Natomas Basin. Available at: https://www.spk.usace.army.mil/natomas/ .
Accessed 5/18/2022.
USACE. 2022c. Unpublished schedule information on American River Common Features 2016.
May 19.
USACE. 2022d. Unpublished schedule information on Lower American River erosion contracts.
June 17.
WSP Parsons Brinckerhoff (PB). 2016. Engineer’s Report. Sacramento Area Flood Control Agency. Consolidated Capital Assessment District No. 2. June 13.
Office 916-874-7606
Fax 916-874-8289
1325 J Street, Suite 1700
Sacramento, CA 95814
August 22, 2024
Mr. Remi Mendoza Mr. Kevin Siu
Planning Division Department of Water Resources
City of Sacramento County of Sacramento
300 Richards Blvd, 3rd Floor 827 Seventh St, Room 301
Sacramento, CA 95811-0218 Sacramento, CA 95814
Mr. David Tomm
Public Works
County of Sutter
1130 Civic Center Blvd.
Yuba City, CA 95993
Subject : URBAN LEVEL OF FLOOD PROTECTION ADEQUATE PROGRESS
ANNUAL REPORT
Dear Sirs:
Enclosed please find the Sacramento Area Flood Control Agency (SAFCA) 2024 Urban Level of Flood Protection Annual Report. This report identifies SAFCA’s progress on achieving the Urban Level of Flood Protection (ULOP) for State Plan of Flood Control (SPFC) facilities within our jurisdiction. On July 18, 2024, the SAFCA Board of Directors approved Resolution No. 2024-056 approving distribution of this report. Because this progress is germane to the authorities vested in your agency, I encourage your agency to use the information provided herein in conjunction with your own data and judgment in reporting annual progress to the Central Valley Flood Board prior to September 30.
SAFCA staff recommend a close reading of the enclosed report. No local or state delays in ULOP funding have occurred, and SAFCA, State, and Federal appropriations remain consistent with the ULOP plan. SAFCA is working diligently with our state and federal partners to have major ULOP projects substantially complete by the December 2025 deadline and will continue to coordinate with you, especially as we begin work on an interim Engineer’s report in early 2025.
2024 ULOP Annual Report
SAFCA appreciates the opportunity to work with your agency on flood matters of mutual interest and looks forward to continued cooperation in achieving adequate progress in this and future years.
Sincerely,
Gary Bardini, P.E.
Director of Planning
Enclosure
cc (w/o enclosure):
Jason Campbell
Melanie Saucier
Mick Klasson