Agenda packet, regular meeting, second session — San Clemente City Council, July 18, 2023 (part 6 of 11)

The resource agencies commented that the baseline surveys for surfgrass and rocky reef were conducted at a cursory reconnaissance level and, therefore, were inadequate to depict their respective distributions.

It should be clear that the Corps rocky reef and surfgrass surveys were conducted at more than just reconnaissance or cursory levels. The absence of surfgrass and reef in some transects should not be construed as an absence of scrutiny, e.g., the seagrass did not disappear. Above all, the surveys provided the information needed to assess potential impacts, and the basis needed for discussion and evaluation of project alternatives, along with potential monitoring and mitigation. 202
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Figure 5-7 UC San Diego Nearshore Mapping Program
University of California, San Diego Nearshore Mapping Program (http://nearshore.ucsd.edu.). Notice the raster data of the kelp canopy in the blue green color. 203
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Figure 5-8 UCSD Nearshore Program Data 500 Feet From Shoreline UCSD Nearshore Mapping Program does not map the nearshore environs approximately 500 feet from the shoreline, off-shore whereas the Corps GPS mapping, which included 25 transects, did map rocks and surfgrass inside the 500 feet zone. 204
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Figure 5-9 UCSD Nearshore Program Data
UCSD Nearshore Mapping Program does not map the nearshore environs approximately 500 feet from the shoreline, off-shore whereas the Corps GPS mapping which included 25 transects did map rocks and surfgrass inside the 500 feet zone. 205
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5.4.5.2 Mitigation Ratios
The resource agencies want mitigation to be provided for prior to or concurrent with project impacts, and supplemented as needed to offset any additional, significant long-term adverse impacts documented under the monitoring program. If mitigation is not provided in advance of project impacts, the mitigation plan should address temporal losses of resources and include adequate compensation to address such losses at a greater than 1:1 mitigation ratio. The value and amount of “out of kind” mitigation proposed also needs further evaluation and discussion with the resource agencies. Out of kind mitigation is generally considered adequate only if conservation to impact ratios is proposed at a greater than 1:1 ratio.

The Corps does not see any effects or impacts to the T-Street reef and the surfgrass vegetation, and thus concludes that no mitigation is required. Nonetheless, if effects are observed a monitoring, mitigation and reporting plan (MMRP) has been developed in concert with the resources agencies. This plan will undergo further scrutiny during the PED by a team including ERDC Submerged Aquatic Vegetation Restoration Research Program (SAVRRP) experts and the resources agencies. If impacts are not observed, the Corps will continue to monitor for effects and will continue to collaborate with ERDC and the resources agencies to identify an appropriate mitigation design in the future if determined to be needed.

No ATR or IEPR comments raised this as a concern, and uncertainty persists as to whether there will be any impacts at all to rocky reef and surfgrass vegetation from the recommended alternative. Because of this, monitoring and adaptive management are included as an integral component of the project's implementation plan. If and when impacts are detected, they will be compensated for.

Corps planning policy is clear on the use of functional habitat evaluation assessment or functional assessments (FA):

Mitigation Planning Objectives. Mitigation planning objectives are clearly written statements that prescribe specific actions to be taken to avoid and minimize adverse impacts, and identifies specific amounts (units of measurement, e.g. , habitat units) of compensation required to replace or substitute for remaining, significant unavoidable losses” [ER 1105-2-100, App C, Paragraph C-3.b (13)] and “habitat-based evaluation methodologies…shall be used to describe and evaluate ecological resources and impacts” [ER 1105-2-100, App C, Paragraph C-3 d)]
The Corps does not use ratios, but instead a scientific based approach through the use of functional habitat evaluation assessment (FA). A basic FA was used in the best professional judgment (BPJ) approach, and a more robust FA will be accomplished in PED during monitoring of the project and reference sites. The Corps impact analysis was thorough in its thought process, and based in collaboration with the resources agencies during a series of conference meetings.

A BPJ analysis was used to determine if impacts would occur in part and to what extent to the rocky reef and corresponding surfgrass vegetation. A BPJ approach was taken because: 1) there 206
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are no functional habitat evaluation assessment models or accounting systems for rocky reef habitat certified, or otherwise accepted, by the Corps Environmental Professional Center of Expertise (PCX), and 2) potential impacts to the rocky reef and surfgrass vegetation, as analyzed using a certified coastal engineering model, would be negligible on ecological resources.

The Corps doesn’t have any type of "functional assessment" or "habitat assessment" designed, in turn, specifically for seagrasses (D Shafer. PhD, ERDC, personal communication, March 2011).

The problem with developing a Habitat Suitability Index (HSI) type analysis for surfgrass is that there is insufficient information to construct standard HSI curves. Surfgrass has been so little studied that it is not clear if investigators could even come up with a species list of organisms unique to that habitat, much less create a curve that shows the relationship between surfgrass percent cover and "habitat value" (D. Shafer, PhD, ERDC, personal communication, March 2011).

This lack of data dictated a simpler interim approach based on presence/absence of surfgrass.

Absence could be subdivided into areas that have the potential to function as surfgrass habitat (e.g. suitable depth, hard substrate) and those that have habitat unsuitable to support surfgrass (e.g. soft bottom, below depth limits) (D. Shafer, PhD, ERDC, personal communication, March 2011).

Scientific literature (Wyllie-Echeverria et. al 2007) indicates that surfgrass Phyllospadix torreyi is distributed widely along the entire Pacific Coast; and occurs from the northern tip of Vancouver Island, Canada to Isla Santa Margarita (Phillips 1979, Ramirez- Garcia et al. 2002), Baja, California, with its primary abundance south of Monterey, California (Phillips 1979). It is, however, unknown if P. torreyi is unique for a certain array of marine organisms or if it provides foraging, cover, and spawning habitat for obligate fish.

Based again on the coastal engineering beach profiles, it is uncertain if the rocky reef and surfgrass vegetation will be affected at all by project implementation. The marine ecologists who sampled the T-street reef (Rick Ware, M.S., Coastal Resources Management [15 years], and Noel Davis, PhD, Chambers Group [35 years]) are extremely experienced and knowledgeable in their sampling design, implementation of data collection, and data analysis.

The best available scientific data suggest that the 50 foot (15 meters) proposed action will have negligible effects on the habitat value of surfgrass beds. The coastal engineering model shows the predicted equilibrium cross-section footprint of the 50 ft (15 m) Beach Width Alternative at T-street reef. This profile indicates that most of the sediment accumulation will occur in the inshore area. Surfgrass in this area grows on 1 to 2 ft (0.3 to 0.6 m) boulders and has average blade lengths of 2 to 3 ft (0.6 to 0.9 m). The equilibrium footprint of the 50 ft (15 m) Beach Width Alternative likely would result in a range of negligible effects of no burial of surfgrass on the larger rocks to partial burial on the smaller boulders. Burial of surfgrass on the outer portions of T-street reef would not occur. Surfgrass is adapted to partial sand burial, routinely survives seasonal sand burial of part of its blades, and can recover quickly via regrowth if the root system is intact. The degree of sand burial surfgrass can withstand, however, is not well documented (SANDAG 2000). However, Coastal Resources Management (CRM 2000) observed surfgrass in 207
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the deepest portion of T-Street reef with 2/3 of its blades covered with sand, which suggested surfgrass could withstand temporary burial of up to 2/3 of its blade length.

To predict the potential burial of surfgrass at San Clemente, CRM and Moffatt and Nichol analyzed impacts to surfgrass from a similar proposed beach fill project at Linda Lane and TStreet (CRM 2000). Their analysis predicted that placement of 175,000 cy (133,000 m3 ) of sand
at Linda Lane and T-Street would result in a maximum 1 ft (0.3 m) burial of surfgrass for less than six months. Approximately 1 ft (0.3 m) of burial would bury less than 50 percent of the surfgrass blade length at these sites. Based on observation of burial of existing offshore surfgrass in the area, CRM (2000) proposed a criterion of sand burial of no more than 2/3 of the blade length for six months or less as a level that surfgrass can withstand, and concluded that burial of less than half the blade lengths for less than six months would not be expected to result in long-term damage (CRM 2000).

The estimate that approximately 20 percent of the reef or 1 acre would experience significant burial was determined by superimposing the sand distribution cross section predicted by Corps coastal engineers on the offshore bathymetry and by delineating the reef as well as the surfgrass locations measured in the field by Chambers Group. The sand distribution analysis predicted that the equilibrium footprint of the beach fill would extend to about 60 percent of the reef and to the entire identified surfgrass habitat, but that only the inner portion of the reef would receive substantial sand burial. Beyond the inner portions of the reef, the sand layer was predicted to be just a thin layer that would not bury surfgrass blades. The inner portion of the reef where the cross section showed burial was about 20 percent of the reef. Because the reef is about 5 acres in extent, the area of impact was estimated to be 1 acre.

A recent laboratory study of Phyllospadix scouoleri suggested that short term sand burial may result in shoot mortality, decreased shoot counts, and reduced growth of surfgrass (Craig et al. 2008). The study found that shoot density decreased compared to controls for a burial depth of

0.8 feet (25 cm), but not shallower burial depths. Mean shoot growth rate decreased in all burial treatments. Therefore, the 50 ft (15 m) Beach Width Alternative may result in some negligible degradation of the shallower portion (inner T-Street reef) of the surfgrass habitat, but would not result in loss of surfgrass. For the 50 ft (15 m) Beach Width Alternative, the sand from the beach fill is predicted to move out of the equilibrium footprint within 6 years.

Considerable reef habitat that supports giant kelp, feather boa kelp, gorgonians, palm kelp, and sparse surfgrass is located approximately 1,000 to 1,300 ft (300 to 400 m) from shore. None of the fill from the 50 ft (15 m) Beach Width Alternative is expected to reach this area. The CRM and Moffatt & Nichol analysis predicted that less than 0.2 ft (0.06 m) of sand from the San Clemente beach fill would accrete in the kelp beds (CRM 2000). Similarly, beach profile monitoring of a somewhat larger volume of sand placed on the beach at Oceanside detected very little movement of the sand at 1,000 ft (300 m) or more from shore. Based on this information, negligible effects of the proposed action would result in the transport of enough sand into kelp bed areas to result in a long-term net loss of the habitat.

A BPJ was accomplished by the marine ecologists who have sampled the T-street reef, as well as the rocky reefs adjacent to the project site, and who are extremely experienced and 208
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knowledgeable in their sampling design, implementation of data collection, and data analysis.

During the PED phase a more robust functional habitat evaluation assessment will be accomplished using ERDC’s Submerged Aquatic Vegetation Restoration Research Program and/or the Northwest Habitat Institute’s Combined Habitat Assessment Protocol (CHAP).

CHAP has undergone independent scientific review in the Pacific Northwest and is under review with the Corps PCX.

Mitigation funds are included as part of the contingency funds for the project. The expectation is that while there may be negligible effects to the inner rocky reef and surfgrass vegetation; actual monitoring data will be needed to support this determination, or to identify that there will be no significant impacts. Monitoring for 2 years immediately post construction is proposed to determine actual impacts.

The Project has a mitigation budget that accommodates 1 acre of impacts to surfgrass plus 1 acre of impacts to reef, for a total potential impact to 2 acres of resources as a worst-case scenario.

Initial modeling by the Corps shows that there is potential to impact 20 percent of the inshore edge of T-Street reef; and 5 acres of the T-Street reef. Twenty percent of the inshore edge is a reasonably foreseeable estimate of impacts based on a best professional judgment functional habitat evaluation assessment and the coastal engineering model. Both the BPJ FA and the coastal engineering model considered the potential depth in addition to area; however that detail is not in inches, but in feet. A greater impact area would be unlikely, but an additional acre of potential impacts was included in the contingency mitigation budget to account for an unlikely worst-case scenario.

The Corps does not use ratios, but instead a scientific-based approach through the use of functional habitat evaluation assessment. A basic FA was used in the BPJ approach and a more robust FA will be accomplished in PED during the monitoring of the project site and the reference site. As previously stated, Phyllospadix torreyi is distributed widely along the entire Pacific Coast; and occurs from the northern tip of Vancouver Island to Baja, California, with its primary abundance south of Monterey, California. It is not known if P. torreyi is unique for a certain array of marine organisms or if it provides foraging, cover, and spawning habitat for obligate fish. It has been stated by CDFG that it provides forage for juvenile lobster, a CDFG harvest taxa.

Because resource agency recommendations for mitigation were only clarified in their response to the DEIS, development and certification of a habitat model to assess surfgrass impacts was not previously contemplated. NMFS recommended using their mitigation ratio calculator and started the high end ratio at 5:1. Other agencies (EPA and CDFG) wanted to use the Corps Regulatory Division 1.5:1 as the minimum ratio. To accomplish this, $3.7 million dollars are included in the cost of the recommended alternative for monitoring, mitigation, and reporting as a contingency.

Nonetheless, contingency costs are included in total project costs, but monitoring may ultimately determine that less mitigation acres is required and thus costs may be lower.

Absent readily available models to assess potential impacts to surfgrass (such as habitat evaluation procedures habitat suitability indices) technical experts at ERDC concur that patch/size of impacts is the appropriate metric to use as the feasibility planning phase approaches 209
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closure. Model development will be pursued during PED, in turn, as a basis for monitoring, assessing and documenting any impacts immediately before and at regular intervals after initial sand placement.

Habitat Equivalency Analysis appears to be a good approach in this situation (D. Shafer, PhD, ERDC, personal communication, March 2011). According to ERDC, it has been successfully used for seagrass habitat in other settings.

Although percent cover is commonly used as a metric, there is a lack of science to justify inferring a linear relationship between SAV percent cover and habitat function. Data is lacking, for example, with which to say 80% SAV cover is twice as good as 40% cover for juvenile lobster habitat utilization (D. Shafer, PhD, ERDC, personal; communication, March 2011).

ERDC recommended consideration, for now, of patch size/area as the only metric which we can speak to now with any degree of scientific confidence. There are at least a couple of modeling (HEAT) and habitat accounting system (CHAP) approaches to for use later on, as proposed, to assess effects of San Clemente sand placement.

The Corps developed cost effectiveness/ incremental cost analysis (CE/ICA) table in the mitigation plan/report showing costs and acres (where acres are our substitute for outputs) for various mitigation alternatives (L. Skaggs, Corps South Pacific Division [SPD], personal communication, March 2011). Surfgrass restoration is estimated to cost $2 million per acre, a linear relationship; while kelp forest restoration costs $500k per acre. A simple graphic display of the costs and acres for the various alternatives reveal why the recommended alternative represents the "best" mitigation plan (L. Skaggs, Corps SPD, personal communication, March 2011). Since costs and outputs/acres are linear, in the sense that there are no efficiencies or inefficiencies as surfgrass production rates change, the selection of the alternative becomes a question of "how much surfgrass output is needed to compensate for estimated impacts" (L.

Skaggs, Corps SPD, personal communication, March 2011).

An Institute for Water Resources (IWR) Planning Suite analysis on the costs and outputs was accomplished and provided for mitigation alternatives (Figure 5-10 and Figure 5-11). Figure 5-10 shows the cost effectiveness of the contingent mitigation based upon the IWR Planning Suite analysis illustrates that kelp is the Best Buy followed by surfgrass for all alternatives.

Figure 5-11 shows the cost effectiveness of the contingent mitigation based upon the IWR Planning Suite analysis illustrates that kelp is the Best Buy. The distributions show, that Group C kelp restoration is the most cost effective and the only Best Buy solution. If the kelp restoration is excluded from the mix, then Group C surfgrass would be the most efficient (and the only Best Buy solution). Acres were the only metric used to characterize outputs, since no other habitat values are available. It is critical to note that if kelp is acceptable as a restoration outcome, the natural resources would obtain as much kelp as surfgrass for 1/14 the cost (for 5 acres). If the Corps were to only plan to recommend 1 acre of surfgrass for mitigation, then the natural resources could gain 5 times as much kelp (5 acres) for less than 1/3 the cost. 210
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Figure 5-10 San Clemente Shoreline Protection Mitigation Alternatives Figure 5-11 San Clemente Shoreline Protection Mitigation Plans Group AͲ Kelp Group BͲ Kelp Group CͲ Kelp
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5.4.5.3 Opportunistic Beach Nourishment
The City of San Clemente has adopted a program to actively pursue opportunities for obtaining suitable sand for placement on San Clemente's beaches for erosion control and recreational benefits. The program is designed to obtain surplus sand from upland construction, development, or dredging projects in the region and place it on the City's beaches as nourishment. The purpose of the program is to capitalize on opportunities to obtain beach quality sand from construction projects and other sources when it becomes available. If the sand is determined to be beach-compatible, the material will be placed on the beach or nearshore area at a selected location, rather than disposing of it at an inland disposal site.

The four placement sites and one stockpile site include:

1. The beach at North Beach, just south of the San Clemente Metrolink train station and at the terminus of Avenida Pico, extending a distance of 1,500 feet, referred to as the North Beach Fill Site;

2. The beach near Linda Lane, south of Mariposa Point and north of the pier, extending a distance of 1,500 feet, referred to as the Linda Lane Beach Fi11Site;

3. The beach north of the beach commonly known as T-Street Beach, extending from the pier 1,000 feet south, referred to as the T-Street North Beach Fill Site;

4. The beach south of the beach commonly known T-Street Beach, extending south a distance of 1,200 feet referred to as the T-Street South Beach Fill Site; and

5. The Animal Shelter stockpile site located east of Avenido Pico and north of 'El Camino Real.

During the last five renewals of the Corps Regulatory opportunistic beach nourishment permit, the applicant did not use the permit even once. The key point the opportunistic program takes into consideration is the condition of the beach before sand placement. If beach locations at San Clemente do not need sand, it is not placed. Multiple placement sites are considered in an opportunistic program, and there are no guarantees that San Clemente will receive any sand at all. Sand is not placed at every site every time sand is available. Opportunistic programs, moreover, typically have volumes of sand magnitudes smaller than would be required at this beach (e.g., 10,000 to 40,000 cy instead of 200,000 cy). In addition, any future renourishment for this project will be based on the need for said sand. It does not automatically get renourished every 5 years. That is simply the estimated time frame when the beach is expected to retreat to a width of zero ft (0 m). If there is no need for renourishment at 5 years, the beach will not be renourished. There is no additive effect of both projects, in sum, that would result in overnourishing the project site. Over-nourishment is unlikely since the beach has already retreated dramatically from the historic width.

The City of San Clemente’s Corps Regulatory permit will be conditioned (J. Lambert, personal communication, March 2011) to not allow any opportunistic beach nourishment once the PED phase has commenced, most likely sometime in FY2012. The opportunistic beach nourishment cannot affect the Shoreline Protection project’s reference site at Mariposa Point or and down coast littoral zone sand movement.
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5.4.6 Upfront mitigation, endowments, third party agreements and implementation It is the Corps policy in ER 1105-2-100, App C, Paragraph C-3 d. (1) (a) and following:
e. Mitigation Planning and Recommendations.
(1) General. District commanders shall ensure that project-caused adverse impacts to ecological resources have been avoided or minimized to the extent practicable, and that remaining, unavoidable impacts have been compensated to the extent justified. The recommended plan and the NED plan, if not one in the same, shall contain sufficient mitigation ecological resources (Section 906(d), WRDA`86). Any such mitigation measures will be fully justified.

The Corps typically plans to implement mitigation features, along with other project features, in the construction phase. While this scenario is typically based on known impacts to be mitigated, in this case there may be a planned lag to truly define the impacts that the models suggest may occur. Mitigation funds are included as part of the contingency funds for the project because effects to the inner rocky reef and surfgrass vegetation, if any, are uncertain. The expectation is that at most negligible effects and impacts to the inner rocky reef and surfgrass vegetation will occur; however, actual monitoring data are needed to support said predicted negligible effects.

Mitigation is typically conducted before construction, but typically the likely impacts are known, which is not the case for this project. Monitoring for 2 years immediately post construction is proposed to determine what actual impacts are.

No direct placement of sand on the reef is proposed. The equilibrium footprint is that demonstrated as potentially extending to inner portions of the reef. Based on the best available scientific and coastal engineering data, it is predicted that there will be negligible effects to the rocky reef and surfgrass vegetation. Monitoring for 2 years immediately post construction is proposed to determine what actual impacts, if any, do occur. After the first four years (2 years pre-action, 2 years post-action) of monitoring, if the rocky reef and surfgrass vegetation illustrate effects based on triggers specifically determined by the marine ecologists deemed most knowledgeable and experience, the current plan is to attempt “in-kind” mitigation as the primary mode. If “in-kind” mitigation is not successful, based on success criteria developed in PED in consultation with said experts, the mitigation would be adjusted to “out-of-kind” mitigation.

Because of numerous uncertainties surrounding surfgrass restoration, that is, the Corps will develop a compensatory secondary mitigation plan (out-of-kind). In sum, mitigation funds are included as part of the contingency funds for the project because impacts cannot reasonably be determined at this time.

Federal funds cannot be provided to establish an endowment fund for long-term mitigation because of the prohibition against "advance payments" set forth in 31 U.S. Code Section 3324.

Federal law prohibits payment under a contract to provide goods and services may not be for more than the value of the goods or services already delivered or provided. The Corps cannot provide funds unless and until it receives goods or services. 213
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The Corps can obtain mitigation services only under a competitively solicited FAR contract. It cannot fund a designated “third party” for mitigation services. Finally, funds obligated under an FY 11 contract must be spent in FY 11.

5.5 Cultural Resources

5.5.1 Significance Criteria
Adverse effects to sites and properties listed on, or eligible for, the NRHP are evaluated based on the Criteria of Adverse Effect as outlined in 36 (CFR) 800.5 of the regulations implementing Section 106 of the NHPA. The criteria of adverse effect is as follows:

An adverse effect is found when an undertaking may alter, directly or indirectly, the characteristics of a historic property that qualify the property for inclusion in the National Register in a manner that would diminish the integrity of the property's location, design, setting, materials, workmanship, feeling, or association. Consideration shall be given to all qualifying characteristics of an historic property, including those that may have been identified subsequent to the original evaluation of the property's eligibility for the National Register. • An adverse effect is found when an undertaking may alter, directly or indirectly, the characteristics of an historic property that qualify the property for inclusion in the National Register in a manner that would diminish the integrity of the property's location, design, setting, materials, workmanship, feeling, or association. Consideration shall be given to all qualifying characteristics of an historic property, including those that may have been identified subsequent to the original evaluation of the property's eligibility for the National Register.
• Adverse effects may include reasonably foreseeable effects caused by the undertaking that may occur later in time, be farther removed in distance or be cumulative. • Adverse effects on historic properties include, but are not limited to: (i) Physical destruction of or damage to all or part of the property; (ii) Alteration of a property, including restoration, rehabilitation, repair, maintenance, stabilization, hazardous material remediation and provision of handicapped access, that is not consistent with the Secretary's Standards for the Treatment of Historic Properties (36 CFR part 68) and applicable guidelines; (iii) Removal of the property from its historic location; (iv) Change of the character of the property's use or of physical features within the property's setting that contribute to its historic significance; (v) Introduction of visual, atmospheric, or audible elements that diminish the integrity of the property's significant historic features; (vi) Neglect of a property which causes its deterioration, except where such neglect and deterioration are recognized qualities of a property of religious and cultural significance to an Indian tribe or Native Hawaiian organization; and, (vii) Transfer, lease, or sale of property out of Federal ownership or control without adequate and legally enforceable restrictions or conditions to ensure long-term preservation of the property's historic significance.
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5.5.2 Impacts Related to the 50 ft (15 m) Beach Width Alternative Based on investigations conducted by Los Angeles District archeologists, the USACE has determined that there are no historic properties within the onshore portion of the Area of Potential Effect (APE). However, the San Clemente Municipal Pier is located within the APE, and it is considered locally significant and is listed on the City’s Historic Structures List. Project activities along the onshore portion of the Project area involve the placement of dredged sands onto the beach. This alternative will most likely not impact the San Clemente Municipal Pier in any way. The proposed construction staging areas will be in nearby paved parking lots adjacent to the beach and Pier; these areas are already disturbed by development.

As for the offshore portions of the APE, the USACE has yet to determine whether or not these areas contain historic properties. Remote sensing surveys will be used to locate submerged cultural resources.

Mitigation Measures:

MM-CR-50-1: Any earthmoving associated with this Project that will involve previously undisturbed soil will be monitored by a qualified archeologist who meets the Secretary of Interior’s Standards for an Archeologist (see 36 CFR Part 61). Earthmoving includes grubbing and ground clearing, grading, and excavation activities. If a previously unidentified cultural resource (i.e., property) that may be eligible for the NRHP is discovered, all earthmoving activities in the vicinity of the discovery shall be diverted until the USACE complies with 36 CFR § 800.13(a)(2).

MM-CR-50-2: Prior to construction, offshore borrow areas 1 and 2 will be subjected to an underwater remote sensing survey in order to determine if submerged cultural resources are present within these areas. The USACE will comply with Section 106 of the NRHP and its implementing regulations at 36 CFR 800, as amended. This compliance involves the identification and evaluation of cultural resources and consultation with the California State Historic Preservation Officer (SHPO), Native American tribes, and interested parties.

Significant and Unavoidable Impacts: None.

5.5.3 Impacts Related to the 115 ft (35 m) Beach Width Alternative As with the 50 ft Beach Width Alternative, there are no historic properties within the onshore portion of the Area of Potential Effect (APE). However, the San Clemente Municipal Pier is located within the APE, and it is considered locally significant and is listed on the City’s Historic Structures List. Project activities along the onshore portion of the Project area involve the placement of dredged sands onto the beach. This alternative will most likely not impact the San Clemente Municipal Pier in any way. The proposed construction staging areas will be in nearby paved parking lots adjacent to the beach and Pier; these areas are already disturbed by development.
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As for the offshore portions of the APE, the USACE has yet to determine whether or not these areas contain historic properties. Remote sensing surveys will be used to locate submerged cultural resources.

Mitigation Measures: Implement MM-CR-50-1 and MM-CR-50-2.

Significant and Unavoidable Impacts: None.

5.5.4 Impacts Related to the No Action Alternative
Under the No Action Alternative, it is likely that emergency seawalls would be constructed to protect structures. This alternative would not result in any impacts to historic properties and thus would not disturb the site of the Proposed Action.

Mitigation Measures: None.

Significant and Unavoidable Impacts: None.

5.6 Ground and Vessel Transportation

5.6.1 Significance Criteria
An impact to transportation will be considered significant if a project alternative:
• Causes an increase in traffic which is substantial in relation to the existing traffic load and capacity of the street system (i.e., result in a substantial increase in either the number of vehicle trips, the volume to capacity ratio on roads, or congestion at intersections); • Exceeds, either individually or cumulatively, a level of service standard established by the county congestion management agency for designated roads or highways; • Results in a change in air traffic patterns, including either an increase in traffic levels or a change in location, that result in substantial safety risks; • Substantially increases hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment); • Results in inadequate emergency access;
• Results in inadequate parking capacity;
• Conflicts with adopted policies, plans, or programs supporting alternative transportation (e.g., bus turnouts, bicycle racks).
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5.6.2 Impacts Related to the 50 ft (15 m) Beach Width Alternative Impact T-50-1: Causes an increase in traffic which is substantial in relation to the existing traffic load and capacity of the street system (i.e., result in a substantial increase in either the number of vehicle trips, the volume to capacity ratio on roads, or congestion at intersections).

The initial beach nourishment proposes no trucking of materials for disposal. The only ground traffic that will be associated with the Project will be associated with the construction workers traveling to and from the construction site. The increase in ground traffic would not be substantial in relation to the existing traffic load or capacity of the street system. The initial beach nourishment would involve a barge and associated tow boats traveling from Oceanside Harbor to the Project site. Offshore dredge equipment has the potential to result in a hazard to boat traffic. However, during dredging and nourishment operations, proper advanced notice to mariners would be provided, and navigational traffic would not be allowed within the offshore borrow site area or mooring/discharge area directly offshore of Oceanside Harbor or San Clemente Pier. In addition, the proposed Project is not in an area of active navigation. Longterm maintenance would create the same impacts as the proposed action approximately every 6 years. The dredging operator shall pre-coordinate all planned dredging and transport operations with Camp Pendleton. Construction and maintenance impacts would be considered less than significant.

Mitigation Measures: None.

Significant and Unavoidable Impacts: None.

Impact T-50-2: Exceeds, either individually or cumulatively, a level of service standard established by the county congestion management agency for designated roads or highways.

The initial beach nourishment proposes no trucking of materials for disposal. The only traffic that will be associated with the Project will be that associated with the construction workers traveling to and from the construction site. The Project would not exceed, either individually or cumulatively, a level of service standard established by the county congestion management agency for designated roads or highways. Therefore, impacts would be considered not significant.

Mitigation Measures: None.

Significant and Unavoidable Impacts: None.

Impact T-50-3: Results in a change in air traffic patterns, including either an increase in traffic levels or a change in location that results in substantial safety risks.

The only traffic that will be associated with the Project will be that associated with the construction workers traveling to and from the construction site. The proposed Project involves 217
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dredging and beach nourishment only and would not result in a change in air traffic patterns.

Therefore, impacts would be considered not significant.

Mitigation Measures: None.

Significant and Unavoidable Impacts: None.

Impact T-50-4: Substantially increases hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment).

The proposed Project involves dredging and beach nourishment only and would not increase hazards due to design features or incompatible uses. Therefore, impacts would be considered not significant.

Mitigation Measures: None.

Significant and Unavoidable Impacts: None.

Impact T-50-5: Results in inadequate emergency access.

The initial beach nourishment involves the building of sand berms to create fill areas; however, only one of these areas will be constructed at any given time and shall be small segments of the beach so that minimal impacts to the beach would occur. In addition, there will always be alongshore beach access during this process. The Project would have a less than significant impact on emergency access.

Mitigation Measures: None.

Significant and Unavoidable Impacts: None.

Impact T-50-6: Results in inadequate parking capacity.

The initial beach nourishment proposes no trucking of materials for disposal. The only traffic that will be associated with the Project will be that associated with the construction workers traveling to and from the construction site. Parking lots are located at Linda Lane Park, across the street from the Pier, and at T-Street. In addition, there is street parking on the local streets.

Parking capacity will not be impacted. Therefore, impacts would be considered not significant.

Mitigation Measures: None.

Significant and Unavoidable Impacts: None.
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Impact T-50-7: Conflicts with adopted policies, plans, or programs supporting alternative transportation (e.g., bus turnouts, bicycle racks).

The proposed Project involves dredging and beach nourishment only and would not conflict with adopted policies, plans, or programs supporting alternative transportation. Therefore, impacts would be considered not significant.

Mitigation Measures: None.

Significant and Unavoidable Impacts: None.

5.6.3 Impacts Related to the 115 ft (35 m) Beach Width Alternative Impact T-115-1: Causes an increase in traffic which is substantial in relation to the existing traffic load and capacity of the street system (i.e., result in a substantial increase in either the number of vehicle trips, the volume to capacity ratio on roads, or congestion at intersections).

The 115 ft Beach Width Alternative proposes no trucking of materials for disposal. The only ground traffic that will be associated with this alternative will be associated with the construction workers traveling to and from the construction site. The number of construction workers would be the same as for the proposed action and therefore the associated daily traffic would be the same. The length of the construction period associated with this alternative would be greater than the proposed action but the repetition of the long-term maintenance would be less frequent.

The increase in ground traffic would not be substantial in relation to the existing traffic load or capacity of the street system.

As with the 50 ft Beach Width Alternative, the 115 ft Beach Width Alternative would involve a barge and associated tow boats traveling from Oceanside Harbor to the Project site. The number of daily trips would be the same as the proposed action. The length of the construction period associated with this alternative would be greater than the proposed action but the repetition of the long-term maintenance would be less frequent. Offshore dredge equipment has the potential to result in a hazard to boat traffic. However, during dredging and nourishment operations, proper advanced notice to mariners would be provided, and navigational traffic would not be allowed within the offshore borrow site area or mooring/discharge area directly offshore of Oceanside Harbor or San Clemente Pier. In addition, the 115 ft Beach Width Alternative is not in an area of active navigation. Long-term maintenance would create the same impacts as the proposed action though at a less frequent rate of approximately every 10 years. Construction and maintenance impacts would be considered less than significant and the similar to the proposed action.

Mitigation Measures: None.

Significant and Unavoidable Impacts: None.

Impact T-115-2: Exceeds, either individually or cumulatively, a level of service standard established by the county congestion management agency for designated roads or highways. 219
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As with the 50 ft Beach Width Alternative, the 115 ft Beach Width Alternative proposes no trucking of materials for disposal. The only traffic that will be associated with this alternative will be that of the construction workers traveling to and from the construction site. The number of construction workers would be the same as for the proposed action and therefore the associated daily traffic would be the same. The length of the construction period associated with this alternative would be greater than the proposed action but the repetition of the long-term maintenance would be less frequent. This alternative would not exceed, either individually or cumulatively, a level of service standard established by the county congestion management agency for designated roads or highways. Therefore, impacts would be considered not significant and the similar to the proposed action.

Mitigation Measures: None.

Significant and Unavoidable Impacts: None.

Impact T-115-3: Results in a change in air traffic patterns, including either an increase in traffic levels or a change in location that results in substantial safety risks.

The only traffic that will be associated with this alternative will be that associated with the construction workers traveling to and from the construction site. As with the proposed action, the 115 ft Beach Width Alternative involves dredging and beach nourishment only and would not result in a change in air traffic patterns. Therefore, impacts would be considered not significant and the same as the proposed action.

Mitigation Measures: None.

Significant and Unavoidable Impacts: None.

Impact T-115-4: Substantially increases hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment).

As with the 50 ft Beach Width Alternative, the 115 ft Beach Width Alternative Project involves dredging and beach nourishment only and would not increase hazards due to design features or incompatible uses. Therefore, impacts would be considered not significant and the same as the proposed action.

Mitigation Measures: None.

Significant and Unavoidable Impacts: None.
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Impact T-115-5: Results in inadequate emergency access.

As with the 50 ft Beach Width Alternative, the 115 ft Beach Width Alternative involves the building of sand berms to create fill areas; however, only one of these areas will be constructed at any given time and shall be small segments of the beach so that minimal impacts to the beach would occur. In addition, there will always be alongshore beach access during this process. This Alternative would have a less than significant impact on emergency access and the similar to the proposed action.

Mitigation Measures: None.

Significant and Unavoidable Impacts: None.

Impact T-115-6: Results in inadequate parking capacity.

The 115 ft Beach Width Alternative proposes no trucking of materials for disposal. The only traffic that will be associated with this alternative will be that associated with the construction workers traveling to and from the construction site. The number of construction workers would be the same as for the 50 ft Beach Width Alternative and, therefore, the associated daily traffic would be the same. The length of the construction period associated with this alternative would be greater than the proposed action but the repetition of the long-term maintenance would be less frequent. Parking lots are located at Linda Lane Park, across the street from the Pier, and at T-Street. In addition, there is street parking on the local streets. Parking capacity will not be significantly impacted. Therefore, impacts would be considered not significant and the similar to the proposed action.

Mitigation Measures: None.

Significant and Unavoidable Impacts: None.

Impact T-115-7: Conflicts with adopted policies, plans, or programs supporting alternative transportation (e.g., bus turnouts, bicycle racks).

The 115 ft Beach Width Alternative involves dredging and beach nourishment only and would not conflict with adopted policies, plans, or programs supporting alternative transportation.

Therefore, impacts would be considered not significant and the same as the proposed action.

Mitigation Measures: None.

Significant and Unavoidable Impacts: None.
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5.6.4 Impacts Related to the No Action Alternative
Under the No Action Alternative, it is likely that emergency seawalls would be constructed to protect structures. This alternative would not result in any impacts to ground or vessel transportation and thus would not disturb the proposed Project area.

5.7 Land Use and Policy

5.7.1 Significance Criteria
An impact to land use will be considered significant if a project alternative:
• Physically divides an established community;
• Conflicts with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project (including, but not limited to the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect; and/or
• Conflicts with any applicable habitat conservation plan or natural community conservation plan.

5.7.2 Impacts Related to the 50 ft (15 m) Beach Width Alternative Impact LU-50-1: Physically divides an established community.

The construction and long-term maintenance of the proposed Project will neither disrupt nor divide any established community and, therefore, will have no impact on an established community.

Mitigation Measures: None.

Significant and Unavoidable Impacts: None.

Impact LU-50-2: Conflicts with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project (including, but not limited to the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect.

The construction and long-term maintenance (i.e., renourishment) of the proposed Project does not conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the Project adopted for the purpose of avoiding or mitigating an environmental effect and there would be no impact.

Mitigation Measures: None.
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Significant and Unavoidable Impacts: None.

Impact LU-50-3: Conflicts with any applicable habitat conservation plan or natural community conservation plan.

The City of San Clemente became a signatory agency in the Orange County Southern Natural Community Conservation Plan (NCCP)/Habitat Conservation Plan (HCP) subregional plan in May 1993. The construction and long-term maintenance of the proposed Project will not conflict with the OC southern NCCP/HCP and, therefore, impacts would be considered not significant.

Mitigation Measures: None.

Significant and Unavoidable Impacts: None.

5.7.3 Impacts Related to the 115 ft (35 m) Beach Width Alternative Impact LU-115-1: Physically divides an established community.

The construction and long-term maintenance of the 115 ft Beach Width Alternative will neither disrupt nor divide any established community and, therefore, will have no impact on an established community, same as the proposed action.

Mitigation Measures: None.

Significant and Unavoidable Impacts: None.

Impact LU-115-2: Conflicts with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project (including, but not limited to the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect.

The construction and long-term maintenance of the 115 ft Beach Width Alternative does not conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the Project adopted for the purpose of avoiding or mitigating an environmental effect and there would be no impact, same as the proposed action.

Mitigation Measures: None.

Significant and Unavoidable Impacts: None.
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Impact LU-115-3: Conflicts with any applicable habitat conservation plan or natural community conservation plan.

The City of San Clemente became a signatory agency in the Orange County Southern NCCP/ HCP subregional plan in May 1993. The construction and long-term maintenance of the 115 ft Beach Width Alternative will not conflict with the OC Southern NCCP/HCP and, therefore, impacts would be considered not significant, same as the proposed action.

Mitigation Measures: None.

Significant and Unavoidable Impacts: None.

5.7.4 Impacts Related to the No Action Alternative
The No Action Alternative would not involve any dredging or beach nourishment activity. No impacts to land use would occur from the lack of these construction activities. Under the No Action Alternative, it is likely that emergency seawalls would be constructed to protect structures. Potential maintenance activities by SCRRA would have no impact on land use.

5.8 Noise

5.8.1 Significance Criteria
For stationary sources, the applicable noise standards include criteria established by local as well as any State regulations applicable to the proposed Project. Mobile-source noise (i.e., vehicle and vessel noise) is preempted from local regulation. Here an impact is considered significant if the existing noise levels exceed the objectives of the General Plan (i.e., 60 dBA CNEL for residential and noise sensitive areas) and the Project were to increase this noise level by 3 dBA (barely noticeable in an exterior environment); or if the Project adds 5 dBA (noticeable to most people) and the resultant noise level remains under the objectives of the General Plan.

All projects constructed in the City of San Clemente are subject to standard conditions set forth in the Municipal Code. The City of San Clemente noise standards are identified in Municipal Code Ch 8.48 (Noise Control) (Table 5-9).
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Table 5-9 San Clemente Noise Standards
7:00 AM to 10:00 PM 10:00 PM to 7:00 AM
Residential
Exterior 55 dBA 50 dBA
Interior 50 dBA 40 dBA
Commercial 65 dBA 60 dBA
Industrial 70 dBA 70 dBA
Compliance with these provisions is mandatory and as such, does not constitute mitigation under CEQA. Those conditions specific to noise are included below:
• City Municipal Code Section 8.48.090, Exemptions from Chapter, that exempts noise sources associated with construction activities, provided said activities do not take place outside the hours of 7:00 a.m. and 6:00 p.m. Monday through Friday and 8:00 a.m. to 6:00 p.m. on Saturday, with no construction allowed on Sundays and City-observed holidays unless a permit is granted by the Community Development Director or his or her authorized representative.
• Any activity or equipment to the extent that design regulation thereby has been preempted by State or Federal law. This would include noise generated from the use of on-road and ocean-going vehicles.

5.8.2 Impacts Related to the 50 ft (15 m) Beach Width Alternative Impact N-50-1: Exposure of Persons to or Generation of Noise Levels in Excess of Standards Established in the Local General Plan or Noise Ordinance, or Applicable Standards of Other Agencies.

In accordance with the City of San Clemente Municipal Code, sensitive residential land uses carry a daytime noise standard of 55 dBA between the hours of 7:00 a.m. and 10:00 p.m. and a nighttime standard of 50 dBA between the hours of 10:00 p.m. and 7:00 a.m.

However, in accordance with the City Municipal Code, construction is exempt from these standards so long as it is restricted to between the hours of 7:00 a.m. and 6:00 p.m., Monday through Friday and 8:00 a.m. to 6:00 p.m. on Saturday, with no construction allowed on Sundays and City-observed holidays unless a permit is granted by the Community Development Director or his or her authorized representative. These hours are requisite within the City and therefore, adherence to these hours is mandatory and does not constitute mitigation.

Because on-shore construction would not be performed outside of these hours, it is exempt from the stationary-source noise standards and therefore would not expose local residents to noise levels in excess of any regulatory standards and the impact is less than significant.

Mitigation Measures: None.
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Significant and Unavoidable Impacts: None.

Impact N-50-2: Exposure of Persons to or Generation of Excessive Groundborne Vibration or Groundborne Noise Levels.

The 50 ft Beach Width Alternative would result in the addition of sand to the City of San Clemente beach. Excessive groundborne vibration is typically associated with such activities as large-scale demolition, pile driving, or blasting, none of which would be required during site construction. Only minimal groundborne vibrations would be created during Project construction activities associated site development and no significant vibration impacts would result from Project development.

Mitigation Measures: None.

Significant and Unavoidable Impacts: None.

Impact N-50-3: A substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project.

The 50 ft Beach Width Alternative represents a construction effort with a duration of 46 days.

The Project would not result in any new structures nor is it expected to increase beach attendance and its associated traffic. As such, there would not be a permanent increase in the ambient noise levels and the impact is less than significant.

Mitigation Measures: None.

Significant and Unavoidable Impacts: None.

Impact N-50-4: A substantial temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the project.

Noise levels associated with construction activities would be higher than the ambient noise levels in the Project area, but would subside once construction of the Project is completed. Two types of noise impacts could occur during the construction phase. First, the transport of workers and equipment to the construction site would incrementally increase noise levels along site access roadways. Four pieces of heavy construction equipment would initially be delivered to the staging area and would be removed at the end of the construction period. Additionally, 10 workers (and vehicles) would make the daily commute to the construction site. Even though there could be a relatively high single event noise exposure potential with passing trucks during the mobilization and demobilization of the heavy equipment (a maximum noise level of 86 dBA at 50 feet), the increase in daily construction traffic is minimal and any addition to on-road noise would be less than 1 dBA when averaged over a 24-hour period, and would therefore have a less than significant impact on noise receptors along the vehicle routes. 226
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The second type of impact is related to noise generated by onsite construction equipment and local residents would be subject to elevated noise levels due its operation. The FHWA provides noise data for construction equipment in its publication FHWA Highway Construction Noise Handbook (August 2006). The 50 ft Beach Width Alternative would use two front-end loaders and two dozers to conduct the on-shore activities. The FHWA document notes that of 55 measurements taken of bulldozers, the maximum measured levels (Lmax) averaged 82 dBA as measured at a distance of 50 feet. The logrithmetic average (Leq) noise is projected at 78 dBA also as measured at a distance of 50 feet. Similarly, front-end loaders are averaged at 79 dBA Lmax (75 dBA Leq) at 50 feet based on 96 measurements. If a loader and dozer were to work together in unison, the Leq is calculated at approximately 80 dBA as measured at a distance of 50 feet. This value is then used to determine the potential impact of the project.

The nearest existing residents are located to the northeast at a distance of about 55 - 60 meters from the closest point of the Project area. Assuming that these pieces generated a noise level of 80 dBA Leq at 50 feet, the resultant exterior noise at the receptor is calculated at 68 dBA Leq.

Interior noise levels with windows closed would be reduced by over 20 dBA from this value.

Most of the time, these levels (both exterior and interior) would be considerably lower due to increased distance as this represents the point where the equipment is operating most proximate to any given resident.

As noted above, the beach is located within the 65 dBA CNEL contour while the proximate receptors are estimated at about 60 dBA CNEL. Assuming that the daytime noise levels approximate the CNEL (i.e., 60 dBA at the receptors), the Project could raise noise at the most proximate receptors to approximately 69 dBA for an increase of 9 dBA. This level exceeds the 3-dBA threshold where the resultant noise is anticipated to exceed the goals of the Noise Element (i.e., 60 dBA CNEL for sensitive land uses) and the impact is considered as potentially significant.

Assuming that two pieces of heavy equipment work in unison, the equipment would produce a noise level of 60 dBA Leq as measured at a distance of approximately 500 ft (152 m). This also is the assumed ambient noise level at the residents and the addition of this construction noise would result in a composite noise level of 63 dBA Leq. This 500 ft (152 m) then represents the distance to the point of a 3-dBA increase for a significant impact. As such, any construction within 500 ft (152 m) of the proximate residents could create a significant impact.

On occasion, beach-based heavy equipment may be required to operate at night to keep up with the dredge. Any use of land-side equipment outside of the hours of 7:00 a.m. and 6:00 p.m. on weekdays, 8:00 a.m. and 6:00 on Saturdays, or at any time on Sundays or City-observed holidays represents a potentially significant impact.

Use of the dredge would also create noise. The dredge would use diesel engines for propulsion, dredging activities, and to provide on-board electric power. Dredge operations are projected to occur 24-hours per day, 7-days per week. A tug boat would be used to position the unit. 227
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The noise produced by the dredge is based on data obtained by Mestre Greve and documented by Helix Environmental (Upper Newport Bay Unit III Sediment Control and Enhancement Project, Volume II Initial Study Technical Appendices, October 15, 1996). That report addressed the use of a 500 hp hydraulic dredge and measured a noise level of 67 dBA at a distance of 100 feet.

The Project could use a dredge that is as much as 10 times more powerful than the unit measured by Helix. Assuming that the noise level is directly related to the power level, dredge noise would be approximately 10 dBA louder than that measured by Helix and here a value of 77 dBA as measured at 100 feet is assumed for dredging operations. The dredge would be assisted by a tug boat of approximately 4,268 horsepower. This would essentially double the use of offshore horsepower increasing this noise by 3 dBA. As such, offshore activities are estimated at 80 dBA as measured at a distance of 100 feet, or roughly 6 dBA louder than the two pieces of shore equipment working in unison if the noise was projected at a similar distance.

At its nearest point, the dredge would be positioned at about 2,500 ft (763 m) from receptors at San Clemente during pump-out, and about 4,200 ft (1,280 m) from the Oceanside receptors at the borrow site. Assuming that the dredge and tug work in unison off San Clemente, the noise at the proximate receptors is calculated at 52 dBA Leq. When added to the 60-dBA ambient level, at the receptor locations, the composite noise is calculated at 60.6 dBA for an increase of 0.6 dBA.

When added to the on-shore construction noise when heavy equipment operates proximate to the residents (i.e., 69 dBA Leq at the receptors), the composite noise is calculated at 69.1 dBA for an increase of 0.1 dBA. In summary, while the noise from the dredge may be audible when working late at night, its increase to the ambient noise is too small to be significant.

Furthermore, the noise of the dredge is too low to add substantially to the noise of the on-shore equipment.

At a distance of approximately 4,200 ft (1,280 m) from receptors at the Oceanside borrow site, the dredge would produce a noise level of 44.5 dBA Leq. Assuming that the receptors in the Oceanside area also are subject to an existing level of 60 dBA, the addition of 44.5 dBA results in a composite level of 60.1 dBA for an increase of just 0.1 dBA. This level of increase is too small to be notable and is well under the 3-dBA threshold and would not be significant.

Mitigation Measures:

MM-N-50-3.1: The City of San Clemente Noise Element discusses the potential impacts of construction noise on the residents and requires construction to employ feasible and practical techniques and practices that minimize the generation of excessive noise on adjacent land uses.

The Applicant shall implement the following:
• Regardless of dredge activity timing, on-shore equipment shall be restricted to the hours included in the City of San Clemente Noise Ordinance discussed above. • To reduce the nuisance value of on-shore construction noise, on-shore construction activities located within 500 ft (152 m) of any residential unit shall not begin before 8:00 a.m. (as opposed to 7:00 a.m. as allowed in the Noise Ordinance). Work beyond may be performed in accordance with the hours included in the City Noise Ordinance. This 228
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provision shall not apply to any equipment mobilizing from the staging area that may pass within 500 ft (152 m) so long as it is not actively engaged in the movement of sand. • During all construction, the Project contractors shall equip all on-shore construction equipment with properly operating and maintained mufflers and engine shrouds consistent with manufacturers’ standards.
• All heavy equipment shall be maintained in a proper state of tune as per the manufacturers’ specifications.
• The Project contractor shall place any stationary construction equipment as far as feasible from proximate receptor locations and oriented such that emitted noise is directed away from sensitive receptors.

Implementation of these, or equally effective, measures would reduce the impact to less a less than significant level.

Significant and Unavoidable Impacts: None.

Impact N-50-5: For a Project Located Within an Airport Land Use Plan or, Where Such a Plan Has Not Been Adopted, Within Two Miles of a Public Airport or Public Use Airport, Would the Project Expose People Residing or Working in the Project Area to Excessive Noise Levels.

The Project site is not located within two miles of any airports and would not result in significant exposure to aircraft noise.

Mitigation Measures: None.

Significant and Unavoidable Impacts: None.

Impact N-50-6: For a Project Within the Vicinity of a Private Airstrip, Would the Project Expose People Residing or Working in the Project Area to Excessive Noise Levels.

The proposed Project is not located in the vicinity of a private airstrip and would not be impacted by private airport operations.

Mitigation Measures: None.

Significant and Unavoidable Impacts: None.

5.8.3 Impacts Related to the 115 ft (35 m) Beach Width Alternative Impact N-115-1: Exposure of Persons to or Generation of Noise Levels in Excess of Standards Established in the Local General Plan or Noise Ordinance, or Applicable Standards of Other Agencies.
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As with the 50 ft Beach Width Alternative, because on-shore construction would not be performed outside of these hours, it is exempt from the stationary-source noise standards and, therefore, would not expose local residents to noise levels in excess of any regulatory standards and the impact is less than significant.

Mitigation Measures: None.

Significant and Unavoidable Impacts: None.

Impact N-115-2: Exposure of Persons to or Generation of Excessive Groundborne Vibration or Groundborne Noise Levels.

The 115 ft Beach Width Alternative would result in the addition of sand to the City of San Clemente beach. Excessive groundborne vibration is typically associated with such activities as large-scale demolition, pile driving, or blasting, none of which would be required during site construction. Only minimal groundborne vibrations would be created during Project construction activities associated site development and no significant vibration impacts would result from Project development.

Mitigation Measures: None.

Significant and Unavoidable Impacts: None.

Impact N-115-3: A substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project.

The 115 ft Beach Width Alternative represents a construction effort with a duration of 108 days.

Mitigation Measures: None.

Significant and Unavoidable Impacts: None.

Impact N-115-4: A substantial temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the project.

As with the 50 ft Beach Width Alternative, noise levels associated with construction activities would be higher than the ambient noise levels in the Project area, but would subside once construction of the Project is completed. Two types of noise impacts could occur during the construction phase. First, the transport of workers and equipment to the construction site would incrementally increase noise levels along site access roadways. Additionally, 10 workers (and 230
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vehicles) would make the daily commute to the construction site. Even though there could be a relatively high single event noise exposure potential with passing trucks during the mobilization and demobilization of the heavy equipment (a maximum noise level of 86 dBA at 50 feet), the increase in daily construction traffic is minimal and any addition to on-road noise would be less than 1 dBA when averaged over a 24-hour period, and would therefore have a less than significant impact on noise receptors along the vehicle routes.

The second type of impact is related to noise generated by onsite construction equipment and local residents would be subject to elevated noise levels due its operation. The 115 ft Beach Width Alternative would use two front-end loaders and two dozers to conduct the on-shore activities. The nearest existing residents are located to the northeast at a distance of about 55 - 60 meters from the closest point of the Project area. Assuming that these pieces generated a noise level of 80 dBA Leq at 50 feet, the resultant exterior noise at the receptor is calculated at 68 dBA Leq. Interior noise levels with windows closed would be reduced by over 20 dBA from this value. Most of the time, these levels (both exterior and interior) would be considerably lower due to increased distance as this represents the point where the equipment is operating most proximate to any given resident. As with the 50 ft Beach Width Alternative, any construction within 500 ft (152 m) of the proximate residents could create a significant impact.

Similar to the 50 ft Beach Width Alternative, offshore activities are estimated at 80 dBA as measured at a distance of 100 feet, or roughly 6 dBA louder than the two pieces of shore equipment working in unison if the noise was projected at a similar distance. At its nearest point, the dredge would be positioned at about 2,500 ft (763 m) from receptors at San Clemente during pump-out, and about 4,200 ft (1,280 m) from the Oceanside receptors at the borrow site.

Assuming that the dredge and tug work in unison off San Clemente, the noise at the proximate receptors is calculated at 52 dBA Leq. When added to the 60-dBA ambient level, at the receptor locations, the composite noise is calculated at 60.6 dBA for an increase of 0.6 dBA. 231
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When added to the on-shore construction noise when heavy equipment operates proximate to the residents (i.e., 69 dBA Leq at the receptors), the composite noise is calculated at 69.1 dBA for an increase of 0.1 dBA. In summary, while the noise from the dredge may be audible when working late at night, its increase to the ambient noise is too small to be significant.

Furthermore, the noise of the dredge is too low to add substantially to the noise of the on-shore equipment.

At a distance of approximately 4,200 ft (1,280 m) from receptors at the Oceanside borrow site, the dredge would produce a noise level of 44.5 dBA Leq. Assuming that the receptors in the Oceanside area are also subject to an existing level of 60 dBA, the addition of 44.5 dBA results in a composite level of 60.1 dBA for an increase of just 0.1 dBA. This level of increase is too small to be notable and is well under the 3-dBA threshold and would not be significant.

Mitigation Measures: Implement MM-N-50-4.1.

Significant and Unavoidable Impacts: None.

The Project site is not located within 2 miles of any airports and would not result in significant exposure to aircraft noise.

Mitigation Measures: None.

Significant and Unavoidable Impacts: None.

Impact N-50-6: For a Project Within the Vicinity of a Private Airstrip, Would the Project Expose People Residing or Working in the Project Area to Excessive Noise Levels.

The proposed Project is not located in the vicinity of a private airstrip and would not be impacted by private airport operations.

Mitigation Measures: None.

Significant and Unavoidable Impacts: None.

5.8.4 Impacts Related to the No Action Alternative
The No Action Alternative would not involve any dredging or beach nourishment activity and no impacts to noise would occur from the lack of these construction activities. Under the No Action Alternative, it is likely that emergency seawalls would be constructed to protect structures.

Potential maintenance activities by SCRRA may create noise associated with equipment used to 232
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maintain the railroad ballast and tracks. The amount of equipment and time needed to conduct potential maintenance activities is anticipated to be adverse, but less than significant.

5.9 Recreation

5.9.1 Significance Criteria
An impact to recreation will be considered significant if a project alternative:
• Increases the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated; and/or
• Includes recreational facilities or require the construction or expansion of recreational facilities, which might have an adverse physical effect on the environment.

5.9.2 Impacts Related to the 50 ft (15 m) Beach Width Alternative Impact REC-50-1: Increases the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated.

During the beach nourishment, portions of the beach, nearshore zone, and potentially the Pier would be closed to public use. Recreational beach users would be limited to the amount of beach available to them during construction, based on the various closure periods, and may choose to visit a nearby beach instead. Given the short-term period of construction (up to four months), impacts would be considered significant, but temporary. The displacement of recreational users to the various nearby beaches would be temporary and short-term.

Long-term maintenance activities would create similar impacts as the initial construction.

Therefore, physical deterioration of other recreational facilities associated with these other beaches would be less than significant.

Mitigation Measures: None
Significant and Unavoidable Impacts: None.

Impact REC-50-2: Includes recreational facilities or requires the construction or expansion of recreational facilities, which might have an adverse physical effect on the environment.

The beach nourishment provides for a wider beach area and greater opportunities for beach activities, enhancing the beach available for recreation users. The 50 ft Beach Width Alternative would not result in the construction or expansion of any recreational facilities that would have an adverse physical effect on the environment. Long-term maintenance activities would create similar impacts as the initial construction. The wider beach would be a benefit to beach recreation users.
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Mitigation Measures: None.

Significant and Unavoidable Impacts: None.

Impact REC-50-3: Results in a substantial degradation of the recreational experience at San Clemente Beach.

As discussed in Section 5.3 under Impact WR-50-3, some of the sediment placed on San Clemente Beach to widen the beach to 50 ft would be carried offshore. Some of this sediment would settle on T-Street reef, a popular surfing area south of San Clemente Pier. The T-Street surfing location is within the alongshore extent of the proposed beach nourishment. The reef at T-Street is a seabed perturbation such that its elevation, shape, and orientation to incoming waves are a unique combination that tends to shoal waves to a peak with a resulting plunging “left” (from the surfer’s perspective, wave that breaks from right to left) and “right” (from the surfer’s perspective, wave that breaks from left to right), which results in a variety of waves and favorable surfing characteristics. The configuration and orientation of the reef to incoming waves create consistent surfing waves, making T-Street a popular break in the Orange County coastal area. High steepness waves result in plunging breakers, which are associated with beaches with steeper gradients. Plunging breakers descend very quickly and with substantial force; noted for a “lip,” or shoreward facing edge, at the top of the wave. With the proper set of conditions, the plunging lip can create a “tube” or barrel.” The consistent steepness of the wave coupled with the structure of the lip enables surfers to consistently reach higher speeds and perform more maneuvers.The surfing extends from the beach to about 600 ft (200 m) offshore and typically is in water depths less than 15 ft (5 m). The surfing area is closer to the beach than the actual reef location, as incoming waves require time and space to be transformed by the reef bathymetry.
• As discussed in Section 5.3.2, most of this sediment would settle in the inshore portion of the reef and would not affect the refractive abilities of the reef or the characteristics of the “takeoff.” However, as the wave encounters the straightened bathymetry inshore, it may “closeout,” resulting in a shorter ride. This condition would be temporary and would lessen as the sediment moved off the reef steadily over the course of 6 years at a long-term erosion rate of 13 ft (4 m) per year. Although impacts due to the wider beach may occur, historic aerial photographs of San Clemente Beach at the Pier (Figure 5-6) indicate that the beach width in 1990 was approximately 55 ft (17 m) wide and no records have been found that indicate surfing ceased within the Project area during that time. Because the shorter rides are a temporary condition, impacts to surfing would not be significant.

The wider beach would improve the recreational experience for sunbathers, walkers/joggers, and picnickers. More beach area would be available for these activities.

Mitigation Measures: None
Significant and Unavoidable Impacts: None
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Impact REC-50-4: Results in a safety hazard to recreational beach users Heavy equipment working in an active public use area poses safety issues for adults and children. Children may be prone to come close to the equipment both during equipment operation on the beach and storage within staging areas.

Offshore dredge equipment has the potential to result in a hazard to boat traffic. During dredging and nourishment activities, proper advanced notice to mariners would be obtained and navigational traffic would not be allowed within the offshore borrow site area or mooring/discharge area offshore of Oceanside. It is unlikely that recreational vessels, such as kayaks, sailboats, jet-skiers, and paddleboards would use this area close to shore and close to the Pier.

A beach fill project has the potential to create public safety impacts to swimmers and waders.

The two major impacts are derived from deeper water and reflected waves (Appendix D). When sand is introduced artificially into the littoral system, a beach fill can create deeper water conditions than the naturally occurring conditions (Appendix D). During construction of the beach fill, it is typical that the construction foreshore (beach) slope is steeper than the naturally occurring foreshore (beach) slope. It also is typical that the foreshore slope remains steeper than the natural condition for a period of time during the profile adjustment (equilibration) process.

The newly created foreshore area, created by advancing the foreshore seaward, is now in deeper water than the previously existing natural condition. Also, during the profile equilibration process, an alongshore trough may form or the existing condition may become deeper. The swimming/wading public often perceives this trough as a “drop-off”. Recreational beach goers may have become accustomed to the shallow waters normally associated with the existing swash zone. Swimmers and waders, thus, may be unexpectedly confronted with deeper water resulting in hazardous conditions. Furthermore, deeper water in the surf zone allows larger waves to propagate than the naturally occurring shallow water condition. This increased water depth in the surf zone enables larger waves to break very close to the shore. This is commonly referred to as “shore break” or “shore pound”. The recreating public, which may have become accustomed to a mild wave condition, is suddenly confronted with a higher energy wave climate.

Reflected waves also can potentially degrade the surfing experience. Reflected waves propagating seaward can pass through normal incoming waves with no effect, or can meet incoming waves and create a condition known as destructive interference. The outbound and inbound waves meet and the resulting transfer of energy can cause the waves to pitch up in a chaotic sea state. The surfing experience could be degraded by the presence of these outbound waves as well as the resultant chaotic sea state.

In some locations nationwide, an increase in lifeguard rescue missions follow immediately after a beach fill construction project. In addition, signage would be provided to inform swimmers of potential hazards. The beach closure would prevent surfers from accessing the beach near the Pier, and the resulting wider beach would create a longer path for surfers to cross before reaching the water. In addition, the contract specifications shall require the contractor to fence/secure off areas of construction from public access, including construction staging areas and active 235
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construction areas, including the beach and nearshore zone. The effects on public safety while the beach fill Project is reaching equilibrium would be a significant, but temporary, impact.

Mitigation Measures:

MM-REC-50-4.1: Provide signs to warn swimmers, waders and surfers of potentially hazardous surf conditions. Provide extra lifeguards.

Significant and Unavoidable Impacts: None

5.9.3 Impacts Related to the 115 ft (35 m) Beach Width Alternative Impact REC-115-1: Increases the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated.

Like the 50 ft Beach Width Alternative, the 115 ft Beach Width Alternative would result in recreational beachgoers being precluded from portions of the beach and ocean during beach construction. The construction period for the 115 ft Beach Width Alternative is 108 days compared to 46 days for the 50 ft Beach Width Alternative. Therefore, portions of the area around San Clemente Pier would be closed to the public for a longer period. Because portions of San Clemente Beach would still be open to the public at all times, the use of other beaches during construction of the 115 ft Alternative would not be expected to result in a significant impacts to other beaches, parks, or recreational facilities.

Mitigation Measures: None
Significant and Unavoidable Impacts: None.

Impact REC-115-2: Includes recreational facilities or requires the construction or expansion of recreational facilities, which might have an adverse physical effect on the environment.

The beach nourishment provides for a wider beach area and greater opportunities for beach activities, enhancing the beach available for recreation users. The 115 ft Beach Width Alternative would not result in the construction or expansion of any recreational facilities that would have an adverse physical effect on the environment. Long-term maintenance activities would create similar impacts as the initial construction. The wider beach would be a benefit to beach recreation users.

Mitigation Measures: None.

Significant and Unavoidable Impacts: None.
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Impact REC-115-3: Results in a substantial degradation of the recreational experience at San Clemente Beach.

The impacts of the 115 ft Beach Width Alternative on the waves at T-Street reef is discussed in Section 5.3.3. Some of the sediment placed on the beach for the 115 ft Beach Width Alternative would move offshore and settle on T-Street reef. The 115 ft Beach Width Alternative could result in a sand layer of up to 6 ft (2 m) thickness on T-Street reef. This burial would have unquantifiable, but significant adverse effects to the wave breaking characteristics of the reef.

The refractive abilities of the reef may be modified or lost, lessening the focusing effect of the reef and removing the point break characteristics of T-Street reef. Flattening of the slope in the reef area due to sedimentation has the potential to change the characteristic plunging point break to a quasi-spilling beach break and less desirable surfing conditions. Sedimentation in the shallow portion of the reef may result in “close-out” conditions and shorter rides. The sediment from the 115 ft Beach Width Alternative may be present on T-Street reef for up to 10 years.

Because the 115 ft Beach Width Alternative has the potential to substantially modify the waves at T-Street reef and because these differences could persist for as much as 10 years, the impact on recreation is considered significant.

The much wider beach that would be created by the 115 ft Beach Width Alternative than the 50 ft Alternative would be a beneficial impact for sunbathers, walkers/joggers, and picnickers.

Mitigation Measure: Implement MM-WR-115-3.1.

Summary of Significant Unavoidable Impacts: The 115 ft Beach Width Alternative would result in substantial burial of T-street Reef and adverse modification of the wave characteristics there.

The surfing experience would be degraded. The impacts may occur for about 10 years.

Monitoring and documentation of impacts and the avoidance of future beach fills, would allow the wave characteristics to recover. Creation of an artificial surfing reef would replicate some of the surfing values, but an artificial surfing reef may not generate wave profiles equivalent to those at T-Street
Impact REC-115-4: Results in a safety hazard to recreational beach users As described for the 50 ft Beach Width Alternative, immediately following beach construction, there may be changes in the surf zone that would result in conditions that could be hazardous to swimmers, waders, and surfers until the beach reaches equilibrium. Hazardous conditions to beachgoers would be a significant adverse impact.

Mitigation Measures: Implement MM-WR-50-4.1.

Summary of Significant Unavoidable Impacts: None
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5.9.4 Impacts Related to the No Action Alternative
The No Action Alternative would not involve any dredging or beach nourishment activity. No impacts to recreation would occur from the lack of these construction activities. However, the narrowing beach profile, or potential lack of any sandy beach, would prevent recreational beach use. Under the No Action Alternative, it is likely that emergency seawalls would be constructed to protect structures. Potential maintenance activities by SCRRA may prevent use of the narrow beach because of equipment used to maintain the railroad ballast and tracks. The amount of equipment and time needed to conduct potential maintenance activities is anticipated to be less than significant.

5.10 Aesthetics

5.10.1 Significance Criteria
An impact to aesthetics will be considered significant if a project alternative:
• Has a substantial adverse effect on a scenic vista;
• Substantially damages scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a State scenic highway; • Substantially degrades the existing visual character or quality of the site and its surroundings; and/or
• Creates a new source of substantial light or glare which would adversely affect day or nighttime views in the area.

5.10.2 Impacts Related to the 50 ft (15 m) Beach Width Alternative Impact AES-50-1: Has a substantial adverse effect on a scenic vista.

The beach and Pier at the Project site at San Clemente is visible from the surrounding area, and views from the beach include the Pacific Ocean. Potential closure of the Pier and the viewing area it provides would interfere with the public enjoyment of the surrounding visual environment. Construction equipment on the beach may obstruct visual views of recreational users at ground level. The dredge equipment may also disrupt visual resources of the ocean vista. The visual enjoyment of the public would be temporarily interrupted or obstructed by the presence of the construction equipment on either a concentrated, small section of the beach or spread out along the length of the beach. The impacts to the scenic vista would be short-term and temporary, which would be less than significant. Long-term maintenance activities would create similar impacts as the initial construction. The resulting wider beach would enhance the view of the beach and result in a visual benefit.

Mitigation Measures: None.

Significant and Unavoidable Impacts: None.
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Impact AES-50-2: Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway.

The California Department of Transportation (Caltrans) designates roadways that provide scenic views as official Scenic Highways or Corridors. A highway can be officially designated a State Scenic Highway when the local jurisdiction adopts a scenic corridor protection program, applies to Caltrans for scenic highway approval, and receives notification that the highway has been designated as an official State Scenic Highway. The Project site is not located near a designated State scenic highway. Therefore, the proposed Project would have no impact on scenic resources within a State highway.

Mitigation Measures: None.

Significant and Unavoidable Impacts: None.

Impact AES-50-3: Substantially degrade the existing visual character or quality of the site and its surroundings
The proposed Project would result in a wider beach, which would be a minor alteration of the visual character of the existing environment. During the construction phase, the visual character of the site would be affected by construction activities and the presence of construction equipment and materials; however, the construction phase is temporary, and as such, would not result in permanent adverse effects to the visual character of the site. The resulting wider beach would enhance the view of the beach and result in a visual benefit. Long-term maintenance activities would create similar impacts as the initial construction. Therefore, the Project would not substantially degrade the existing visual quality of the surrounding area, and impacts would be less than significant.

Mitigation Measures: None.

Significant and Unavoidable Impacts: None.

Impact AES-50-4: Create a new source of substantial light or glare, which would adversely affect day or nighttime views in the area.

No light and glare impacts would occur as a result of the beach nourishment because no lighting or new source of glare is proposed. The dredge would potentially use lights during nighttime dredging activities; however, the dredging activities are short-term and temporary, if used, and would not create a new source of substantial light or glare that would impact visual resources.

Long-term maintenance activities would create similar impacts as the initial construction.

Therefore, the proposed Project would have less than significant impacts on day or nighttime views in the area.
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Mitigation Measures: None.

Significant and Unavoidable Impacts: None.

5.10.3 Impacts Related to the 115 ft (35 m) Beach Width Alternative Impact AES-115-1: Has a substantial adverse effect on a scenic vista.

As with the 50 ft Beach Width Alternative, potential closure of the Pier and the viewing area it provides would interfere with the public enjoyment of the surrounding visual environment.

Construction equipment on the beach may obstruct visual views of recreational users at ground level. The dredge equipment may also disrupt visual resources of the ocean vista. The visual enjoyment of the public would be temporarily interrupted or obstructed by the presence of the construction equipment on either a concentrated, small section of the beach or spread out along the length of the beach. This temporary impact would be of a longer duration than with the 50 ft Beach Width Alternative. However, the impacts to the scenic vista would be short-term and temporary, which would be less than significant. Long-term maintenance activities would create similar impacts as the initial construction. These long-term maintenance activities would occur less frequently than with the 50 ft Beach Width Alternative. The resulting wider beach would enhance the view of the beach and result in a visual benefit. This benefit would be potentially greater with this alternative, due to greater width of the beach.

Mitigation Measures: None.

Significant and Unavoidable Impacts: None.

Impact AES-115-2: Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway.

As with the 50 ft Beach Width Alternative, the 115 ft Beach Width Alternative is not located near a designated State scenic highway. Therefore, this Alternative would have no impact on scenic resources within a State highway, same as the proposed action.

Mitigation Measures: None.

Significant and Unavoidable Impacts: None.

Impact AES-115-3: Substantially degrade the existing visual character or quality of the site and its surroundings
The 115 ft Beach Width Alternative would result in a wider beach, which would be a minor alteration of the visual character of the existing environment. During the construction phase, the visual character of the site would be affected by construction activities and the presence of construction equipment and materials. This temporary impact would be of a longer duration than 240
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with the 50 ft Beach Width Alternative. However, the construction phase is temporary, and as such, would not result in permanent adverse effects to the visual character of the site. As with the 50 ft Beach Width Alternative, the resulting wider beach would enhance the view of the beach and result in a visual benefit. This benefit would be potentially greater with this Alternative, due to greater width of the beach. Long-term maintenance activities would create similar impacts as the initial construction. These long-term maintenance activities would occur less frequently than with the 50 ft Beach Width Alternative. Similar to the the 50 ft Beach Width Alternative, this Alternative would not substantially degrade the existing visual quality of the surrounding area, and impacts would be less than significant.

Mitigation Measures: None.

Significant and Unavoidable Impacts: None.

Impact AES-115-4: Create a new source of substantial light or glare, which would adversely affect day or nighttime views in the area.

As with the 50 ft Beach Width Alternative, no light and glare impacts would occur as a result of the 115 ft Beach Width Alternative because no lighting or new source of glare is proposed. The dredge would potentially use lights during nighttime dredging activities; however, the dredging activities are short-term and temporary, if used, and would not create a new source of substantial light or glare that would impact visual resources. Long-term maintenance activities would create similar impacts as the initial construction. Similar to the 50 ft Beach Width Alternative, the 115 ft Beach Width Alternative would have less than significant impacts on day or nighttime views in the area.

Mitigation Measures: None.

Significant and Unavoidable Impacts: None.

5.10.4 Impacts Related to the No Action Alternative
The No Action Alternative would not involve any dredging or beach nourishment activity. No impacts to aesthetics would occur from the lack of these construction activities. However, the narrowing beach profile, or potential lack of any sandy beach, would prevent visual enjoyment of the sandy beach vista. Under the No Action Alternative, it is likely that emergency seawalls would be constructed to protect structures. Potential maintenance activities by SCRRA may include views of additional rocks/rip-rap used to maintain the railroad ballast and tracks. The change in the visual environment due to potential maintenance activities is anticipated to be less than significant.
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5.11 Public Health and Safety

5.11.1 Significance Criteria
An impact to public health and safety will be considered significant if a project alternative would result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:
• Fire protection;
• Police protection;
• Schools;
• Parks; and/or
• Other public facilities.

5.11.2 Impacts Related to the 50 ft (15 m) Beach Width Alternative Impact PHS-50-1: Substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for fire protection, police protection, schools, parks, and/or other public facilities.

The proposed Project would not provide new or physically altered government facilities that would impact fire protection, police protection, schools, parks, and/or public facilities. However, as stated in the recreation analysis, the 50 ft Beach Width Alternative may potentially expose the public to potential safety hazards. Heavy equipment working in an active public use area poses safety issues for adults and children. Children may be prone to come close to the equipment both during equipment operation on the beach and storage within staging areas. In addition, offshore dredge equipment has the potential to result in a hazard to boat traffic. The dredge would be equipped with markings and lightings in accordance with the U.S. Coast Guard regulations. The location and schedule of the dredge would be published in the U.S. Coast Guard Local Notice to Mariners. The dredge would travel at very low speeds (approximately 1.5 knots) during dredging operations. The travel speed during transport would be approximately 5 knots. During dredging and nourishment activities, proper advanced notice to mariners would be obtained, and navigational traffic would not be allowed within the offshore borrow site area or mooring/discharge area offshore of Oceanside. It is unlikely that recreational vessels, such as kayaks, sailboats, jet-skiers, and paddleboards would use this area close to shore and close to the Pier; however, signage would be provided to inform these recreational users of potential hazards.

In addition, signage would be provided to inform swimmers of potential hazards. Long-term maintenance activities would create similar impacts as the initial construction. The proposed Project would be temporary and short-term, and impacts would be less than significant. 242
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Mitigation Measures: Implement MM-WR 5.9.2-4.1.

Significant and Unavoidable Impacts: None.

5.11.3 Impacts Related to the 115 ft (35 m) Beach Width Alternative Impact PHS-115-1: Substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for fire protection, police protection, schools, parks, and/or other public facilities.

The same potential, temporary, safety hazards to the public would occur during the construction of the 115 ft Beach Width Alternative as with the 50 ft Beach Width Alternative. These temporary impacts would be of a longer duration than with the proposed action. Long-term maintenance activities would create similar impacts as the initial construction. The long-term maintenance activities associated with this alternative would occur less frequently than with the 50 ft Beach width alternative. Similar to the proposed action, the 115 ft Beach Width Alternative would be temporary and short-term, and impacts would be less than significant.

Mitigation Measures: Implement MM-WR-50-4.1.

Significant and Unavoidable Impacts: None.

5.11.4 Impacts Related to the No Action Alternative
Under the No Action Alternative, it is likely that emergency seawalls would be constructed to protect structures. As a result of the continued beach erosion throughout San Clemente Beach, a number of public safety concerns have surfaced. Public restrooms are located on the beach, seaward (west) of the railroad tracks. Continued damages to these facilities may require their relocation to the landward side (east) of the railroad tracks. This would require pedestrians to continually cross the tracks to use the restrooms. A public safety issue is created because many will cross the railroad tracks in an unsafe manner. Furthermore, the loss of sand within the active nearshore profile has exposed underlying hard substrate and man-made structures. A public safety issue is created because the exposed material, in many cases, remains underwater and hidden from sight, posing a number of potential dangers to unwary recreational swimmers.

The City of San Clemente is liable for accidents resulting from exposed man-made structures.

The economic impact associated with the City’s liability has the potential to be substantial. 243
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5.12 Socioeconomics/Environmental Justice

5.12.1 Significance Criteria
An impact to socioeconomics/environmental justice will be considered significant if a project alternative:
• Impacts a sector of the economy, productivity, competition, prices, or jobs; • Impacts the welfare of minority or low-income populations; and/or • Impacts the fiscal and physical ability of the local governmental agencies to meet the needs of the public following the project-related changes in the local population.

5.12.2 Impacts Related to the 50 ft (15 m) Beach Width Alternative Impact SEJ-50-1: Impacts a sector of the economy, productivity, competition, prices, or jobs.

Maintaining the beach will maintain or increase tourism according to King and Symes (2003).

The socioeconomic effects of beach replenishment at San Clemente would be considered a beneficial impact. The wider sandy beach would provide greater recreation opportunity, opportunity for public access, enhance tourism in the region, and increase local recreation revenue due to increased numbers of visitors to the beaches. In addition, the creation of construction jobs associated with the shoreline improvements would be a beneficial impact to the study area.

No significant direct population, employment, income, or housing impacts are expected to result from the offshore construction activities, either on a local basis or regional basis. Long-term maintenance activities would create similar impacts as the initial construction. Offshore construction operations (i.e., vessel traffic and dredging) may potentially conflict with local commercial fishing operations during winter months, including gear/equipment damage and the disruption of fishing locations. Thirty days prior to the start of construction, the local commercial fishermen’s association shall be provided with written notification of the intended start date of on shore construction, offshore construction, maps of Project-related vessel transportation routes, and its duration. Noticing shall include a point of contact throughout the entire construction phase to respond to concerns regarding interference and/or other issues associated with local commercial fishing operations. Impacts would be considered less than significant.

Mitigation Measures: None
Significant and Unavoidable Impacts: None.

Impact SEJ-50-2: Impacts the welfare of minority or low-income populations. 244
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The construction and long-term maintenance of the proposed Project would not be expected to have any negative effect on minority or low-income populations. In addition, the expansion of the beach width would be a public improvement that would benefit residences and businesses alike.

Mitigation Measures: None.

Significant and Unavoidable Impacts: None.

Impact SEJ-50-3: Impacts the fiscal and physical ability of the local governmental agencies to meet the needs of the public following the project-related changes in the local population.

No significant direct population, employment, income, or housing impacts are expected to result from the proposed action, either on a local basis or regional basis. Although the shoreline protection improvements may increase opportunities for recreation, the Project alone would not increase the need for housing in the area, nor would it contribute to an environmental justice concern. The personnel required for the operation activities related to the proposed action are not expected to create population immigration, either directly or indirectly, into the area. Longterm maintenance activities would create similar impacts as the initial construction. Therefore, the proposed Project would not alter regional or local population projections and would have no significant impacts related to population immigration, such as a decrease in housing availability or an increase in the number of jobs in the area.

Mitigation Measures: None.

Significant and Unavoidable Impacts: None.

5.12.3 Impacts Related to the 115 ft (35 m) Beach Width Alternative Impact SEJ-115-1: Impacts a sector of the economy, productivity, competition, prices, or jobs.

Maintaining the beach will maintain or increase tourism according to King and Symes (2003).

As with the proposed action, the socioeconomic effects of beach replenishment at San Clemente would be considered a beneficial impact. The wider sandy beach would provide greater recreation opportunity, opportunity for public access, enhance tourism in the region, and increase local recreation revenue due to increased numbers of visitors to the beaches. This benefit would be potentially greater with this alternative, due to greater width of the beach. In addition, the creation of construction jobs associated with the shoreline improvements would be a beneficial impact to the study area. The length of the construction effort would be longer with this Alternative than with the proposed action. No significant direct population, employment, income, or housing impacts are expected to result from the offshore construction activities, either on a local basis or regional basis. Long-term maintenance activities would create similar impacts as the initial construction but would occur less frequently than with the proposed action.

Offshore construction operations (i.e., vessel traffic and dredging) may potentially conflict with 245
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local commercial fishing operations during winter months, including gear/equipment damage and the disruption of fishing locations. Thirty days prior to the start of construction, the local commercial fishermen’s association shall be provided with written notification of the intended start date of on shore construction, offshore construction, maps of Project-related vessel transportation routes, and its duration. Noticing shall include a point of contact throughout the entire construction phase to respond to concerns regarding interference and/or other issues associated with local commercial fishing operations. Impacts would be considered less than significant, similar to the proposed action.

Mitigation Measures: None
Significant and Unavoidable Impacts: None.

Impact SEJ-115-2: Impacts the welfare of minority or low-income populations.

Similar to the proposed action, the construction and long-term maintenance of the 115 ft Beach Width Alternative would not be expected to have any negative effect on minority or low-income populations. In addition, the expansion of the beach width would be a public improvement that would benefit residences and businesses alike.

Mitigation Measures: None.

Significant and Unavoidable Impacts: None.

Impact SEJ-115-3: Impacts the fiscal and physical ability of the local governmental agencies to meet the needs of the public following the project-related changes in the local population.

As with the proposed action, no significant direct population, employment, income, or housing impacts are expected to result from the 115 ft Beach Width Alternative, either on a local basis or regional basis. Although the shoreline protection improvements may increase opportunities for recreation, this alternative alone would not increase the need for housing in the area, nor would it contribute to an environmental justice concern. The personnel required for the operation activities related to this alternative are not expected to create population immigration, either directly or indirectly, into the area. Long-term maintenance activities would create similar impacts as the initial construction. Therefore, similar to the proposed action, the 115 ft Beach Width Alternative would not alter regional or local population projections and would have no significant impacts related to population immigration, such as a decrease in housing availability or an increase in the number of jobs in the area.

Mitigation Measures: None.

Significant and Unavoidable Impacts: None.
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5.12.4 Impacts Related to the No Action Alternative
No population immigration-related socioeconomic impacts (e.g., impacts on housing or employment) are expected under the No Action Alternative. However, beaches would continue to erode in the future, which may increase the potential for some loss of recreational uses and access to beaches. Also, it is likely that emergency seawalls would be constructed to protect structures. There may be a net loss in economy due to the lack of beach visitors, which would be a potentially significant impact.
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6.0 CUMULATIVE IMPACT ANALYSIS

6.1 Description of Cumulative Projects

6.1.1 Dana Point Harbor Maintenance Dredging
Dana Point Harbor is located in Capistrano Bay on the southern Orange County coastline, approximately half way between Los Angeles and San Diego. The main elements of the project include (1) maintenance dredging of the navigational channels, anchorages, turning basins, and areas under docks affected by sediment build up, (2) disposal of dredged material, and (3) reuse of suitable clean material to enhance the sediment quality of the interior harbor beach and nourishment for the County Park portion of Capistrano Beach. The design project depths in the dredging area vary from -8 ft (-2 m) MLLW at the Boat Launch Ramp and Youth and Group Docks to -15 ft (5 m) MLLW in the East Anchorage and Main Channel, and 1 foot (0.3 m) of removal of the top layer of fine sand at “Baby Beach.” The project is anticipated to take up to four months to complete.

The total quantity of dredge material is estimated to be up to 155,700 cy (119,041 m3 ). Up to
63,200 cy (48,319 m3) will be disposed at an EPA approved site (LA-3), located approximately 14 mi (23 km) from the entrance of Dana Point Harbor. Up to 9,500 cy (7,263 m3 ) of clean
coarse sand material will be used to replace the top layer of fine sand material removed from “Baby Beach,” and up to 83,000 cy (63,458 m3
) of clean coarse sand material is anticipated to be
used to nourish San Juan Capistrano County Beach, placed either directly on the dry beach or placed in the nearshore littoral zone.

Material will be removed using clamshell dredge equipment, loaded onto bottom-dump scows, and transported to the LA-3 ocean disposal site offshore of Capistrano Beach, or to Baby Beach.

For Capistrano or Baby Beach, tugboats would then position the scow for bottom dumping into the nearshore/surfzone area. The alternative method would be to remove material using a cutter/suction head dredge and hydraulically pump via pipeline to Capistrano or Baby Beach, potentially with the assistance of a booster pump. The material would be placed into fill dikes on the beach and final grading would be performed using bulldozers.

6.1.2 San Onofre Nuclear Generating Station Kelp Reef Project The Wheeler J. North Reef, or the San Onofre Nuclear Generating Station (SONGS) kelp mitigation reef, is located offshore of San Clemente, California, in water depths of approximately 38 to 49 ft (11.5 to 15 m). The entire kelp reef project area is an 862-acre (349 hectares) leased parcel located 0.6 mi (1 km) offshore of the San Clemente beach between the San Clemente Pier and San Mateo Point. The southern end of the reef is about two miles north of SONGS and just north of San Mateo Point and extends north three miles to the City of San Clemente Pier. The kelp reef project is approximately 3,200 ft offshore from the seaward boundary of the Project footprint (Figure 6-1).
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Figure 6-1 Proximity of Wheeler North Reef to Project Site 249
Legend
D Project Footprint
- Final Reef Design
Wheeler Reef Experimental Modules
(-320011 from Project Site)
:®t
0 250 500 1,000 1,500 2,000
- Feet
Figure 6.1-1
Proximity of Wheeler North Reef to Project Site
~hambers Group Inc'.

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The kelp reef was proposed to be constructed in two phases. Phase 1, constructed in September 1999, covers 22.4 ac (9.1 ha) of sea floor. This was the experimental stage and 56 modules were designed to test the viability of using different types and densities of material (e.g., quarry rock versus concrete rubble). Each module has a two-dimensional footprint of 132 ft x 132 ft (40 m x 40 m). The modules are grouped into seven clusters or blocks in the leased area.

The Phase 2 reef was begun in June 2008 and is a 127.6-ac, (51.6 ha) low profile (< 3 ft [1 m]), single-layer reef constructed of quarry rock, which will be distributed on the benthos in quantities similar to those of the lowest substrate density (i.e., 42% bottom coverage) used for the Phase 1 experimental reef. The design of the Phase 2 mitigation reef consists of 11 polygons, varying in area from 2.4 to 37.5 ac (1 to 15.2 ha). The reef construction duration was estimated at 100 working days.

The final reef design locates the Phase 2 mitigation reef in close proximity to the San Mateo Kelp Bed, avoids hard substrate areas, maintains the integrity of the Phase 1 reef modules, provides for navigation channels, and avoids areas of historical kelp growth as well as areas of special interest to local fisheries.

6.1.3 Railroad Operations
Commuter rail stops at San Clemente Pier include two daily Amtrak trains between late April and October and weekend and holiday service year round, as well as two Metrolink weekend train stops. Presently, rail service safety requires occasional preventative maintenance in the form of monitoring the rail bed for erosion and utilizing riprap to prevent erosion. Due to chronic beach erosion, the railroad corridor between the bluff and the beach is threatened by undermining. In response, OCTA has been randomly placing riprap stones along the most critical segment between North Beach and the Marine Safety Building to reduce wave impacts on the railroad tracks. The cumulative impact of stone placement over the years has resulted in a reduction of lateral beach access.

6.2 Analysis of Cumulative Impacts

6.2.1 Air Quality and Meteorology
Construction of the related projects would be short-term and depending on the extent of construction, could have effects similar to or greater than that of the proposed Project. Even with the prescribed mitigation, the proposed action is anticipated to exceed the significance threshold limitations for NOx and PM2.5. In accordance with SCAQMD methodology, projects that exceed the daily threshold values and cannot be mitigated to less than the SCAQMD thresholds add significantly to the cumulative impact. As such, the beach fill Project also is considered as significant at the cumulative level.

With respect to cumulative emissions concentrations and their potential impact on sensitive receptors, the localized impact analysis demonstrates that all emissions levels would remain within their respective threshold values and the beach fill Project would not result in emissions in 250
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excess of the Ambient Air Quality Standards. As such, the Project does not add to a cumulative violation of the standards.

6.2.2 Geology and Topography
The placement of approximately 117,800 cy (90,117 m3
) of sediment from the dredging of Dana
Point Harbor on the beach or into the nearshore zone at Capistrano Beach would add sediment to the Oceanside littoral cell. Capistrano Beach is approximately 4 mi (6.4 km) upcoast from San Clemente Pier. Some of the Dana Point Harbor sediment would be expected to be moved gradually downcoast by littoral processes and would act cumulatively with either action alternative to widen the beach at San Clemente. The Dana Point Harbor Dredging project would act cumulatively with the Project to offset the impacts of coastal erosion.

Some of the sediment from the Dana Point Dredging may be deposited offshore in the vicinity of shallow reefs off San Clemente where it would act cumulatively with either action alternative to increase the sand accumulation in and around the reefs. However, the monitoring of the large SANDAG beach fill at Oceanside Beach indicates that little sediment from the project would be expected to accumulate in the nearshore area beyond naturally occurring variations. The incremental addition of a percentage of a smaller volume of sand discharged upcoast would not be expected to significantly add to sand build-up on reefs. The cumulative impacts of the Dana Point Dredging project and the proposed action would not result in a substantial adverse modification of nearshore topography.

Sediment from the proposed Project and the Dana Point Dredging project would not be expected to affect Wheeler J. North Reef, which is approximately 3,200 ft offshore, beyond the area of the final proposed Project beach profile.

6.2.3 Water Resources
The discharge of sediment from the Dana Point Harbor Dredging project to Capistrano Beach will act cumulatively with the proposed action to add sediment to the Oceanside littoral cell. The proposed action will act in a cumulative fashion with the Dana Point Harbor Dredging project to offset erosion on beaches in south Orange County and northern San Diego County. Most of the sediment from these projects is expected to accumulate on downcoast beaches or in the very shallow nearshore area between the foreshore and the bar. Beach fill would be deposited onshore and would be expected to move offshore in a manner that would not alter the wave characteristics of popular surf breaks, such as T-Street, and would not be expected to affect Wheeler J. North Reef approximately 3,200 ft seaward of the proposed Project footprint.

Like the proposed action, the Dana Point Harbor Dredging project would discharge sediments to the beach or nearshore zone and thus may cause a temporary localized increase in turbidity in nearshore waters. The discharge of sediments from Dana Point Harbor dredging would occur at Capistrano Beach approximately 4 mi (6.4 km) from the proposed action. Even if the projects occurred at the same time, the turbidity plumes would be sufficiently distant that they would not interact with each other. Monitoring of turbidity and adjustment of operations to avoid extensive turbidity plumes would mitigate any cumulative impacts of turbidity from these projects. 251
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6.2.4 Biological Resources
Like the proposed action, the Dana Point Harbor Dredging project would generate temporary turbidity that could interfere with the foraging activities of visual predators including the State and Federal endangered California least tern and State and Federal endangered California brown pelican. Theoretically, the turbidity from both projects could have a cumulative impact on these sensitive bird species if both projects generated extensive turbidity at the same time, thus reducing foraging potential for least terns and brown pelicans over a greater area than would occur from either project alone. Neither the Dana Point Harbor project nor San Clemente Pier is near a least tern or a brown pelican nesting site. The Dana Point Harbor project would not contribute to cumulative effects of turbidity on nesting least terns. The Dana Point Harbor project could contribute to cumulative effects of turbidity on foraging least terns and brown pelicans away from their breeding areas, but turbidity plumes from these projects would be limited in time and area.

Neither the Project action nor the Dana Point Harbor project is near a nesting colony of the federal threatened western snowy plover. Therefore, the projects will have no cumulative effects on nesting plovers.

Both the proposed Project action and the Dana Point Dredging project would avoid placing sediment directly on sensitive biological habitats. The placement of pipelines to pump sand to the beach has the potential to damage sensitive marine resources if the pipeline or anchors are placed on rocky habitat. Because the projects are in different locations, any impacts of pipeline placement would affect different areas and would not act cumulatively to impact the same area.

The impacts of pipeline and anchor placement could be mitigated to not significant by locating pipelines in areas that would minimize impacts on sensitive habitats based on a biological survey of the area.

There is potential that movement of discharged sediments could result in accumulation around sensitive biological habitats, including rocky intertidal, surfgrass, offshore reefs, and kelp beds.

Because sand from the Dana Point Dredging project eventually will be transported downcoast towards San Clemente, there is some potential that sediment from both projects could accumulate at the same reefs. If sensitive habitat were buried for an extended period, impacts could be significant. However, the monitoring of the large SANDAG beach fill at Oceanside Beach indicates that little sediment from the proposed action would be expected to accumulate in the nearshore area beyond naturally occurring variations. The incremental addition of a percentage of a smaller volume of sand discharged upcoast from the dredging of Dana Point Harbor would not be expected to significantly add to sand build-up on reefs. Of sensitive resources in the Project area, surfgrass is most likely to be affected by sand accumulation because it grows in shallow nearshore areas where sand is most likely to be deposited. Surfgrass is adapted to periodic sand movement, and the analysis in Section 5.4.2 indicates that sediment from the proposed action would not be deposited in sufficient volume and for a long enough period to harm surfgrass. The incremental addition of a portion of a smaller amount of sediment discharged over 4 mi (6 km) upcoast is unlikely to add sufficient sediment to adversely affect surfgrass. Sediment from the proposed action and the Dana Point Dredging Project would not be 252
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expected to affect Wheeler J. North Reef, which is approximately 3,200 ft offshore, beyond the area where beach fill sand would be transported.

6.2.5 Cultural Resources
The proposed Project would not be expected to contribute to the loss of cultural resources. The Dana Point Harbor and Wheeler North Reef projects also would not impact cultural resources.

There would be no cumulative effect on cultural resources.

6.2.6 Ground and Vessel Transportation
The Dana Point Harbor project proposes limited, if any, trucking of materials for disposal. The proposed Project does not propose any trucking of materials. If both projects were to occur simultaneously and dredging equipment for both projects were active at the same time, there would be an increase in the number of vessels in the Project areas. However, the dredge equipment for the Dana Point Harbor project would be separate from the dredging efforts for the proposed Project at San Clemente, which would originate out of Oceanside Harbor. The dredges for both projects would not be expected to present a navigation hazard for fishing or recreational boaters either in the harbors or offshore, as these vessels near the harbors often operate in the presence of other vessels and obstacles with little incident. The proposed Project would create cumulative impacts to vessel traffic that would be less than significant.

The proposed Project would occur at least two years after the construction of the Wheeler North Reef project and, therefore, would not have any cumulative impacts to transportation in conjunction with that project.

6.2.7 Land Use and Policy
Construction and future periodic beach nourishment for the proposed Project would occur as necessary and would have no adverse impact to land use or any policies or plans. As such, the proposed Project would not contribute to any cumulative land use impacts in conjunction with either the Dana Point Harbor or Wheeler North Reef projects.

6.2.8 Noise
Because the cumulative projects are spaced apart both in time and location, the stationary noise from both construction and operations is not measurably additive and any cumulative impact would stem from the incremental addition of traffic associated with the various projects. The beach fill Project includes no operational traffic and contributes only 10 vehicles to the roads through the Project area during construction. Any cumulative impact would be less than significant.

6.2.9 Recreation
There is the possibility that the initial beach fill or future maintenance nourishment activity may occur simultaneously along with the Dana Point Harbor project. There is a potential for dredge 253
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equipment for the proposed Project to be present at the same time as the Dana Point Harbor project. The cumulative presence of dredging equipment may interrupt recreational activity in the Project vicinity for the duration of construction. Assuming beach use is low during the construction period, cumulative impacts may be potentially significant, but temporary and shortterm.

The proposed Project would occur at least two years after the construction of the Wheeler North Reef project and, therefore, would not have any cumulative impacts to recreation in conjunction with that project.

6.2.10 Aesthetics
The impacts to aesthetics from the proposed Project and Dana Point Harbor project both are temporary and construction related and will not result in the permanent obstruction of any scenic vistas or open views, nor will the Project create an aesthetically offensive viewshed. If both projects were to occur at the same time, there would be multiple dredges within 5 miles of each other, in addition to the associated tug boats, barge, and crew boats during construction. The temporary impacts of the construction equipment are temporary and less than significant.

The proposed Project would occur at least two years after the construction of the Wheeler North Reef project; because impacts to aesthetics for the proposed Project are construction related only, the proposed Project would not have any cumulative impacts to aesthetics in conjunction with the Wheeler North Reef project.

6.2.11 Public Health and Safety
The proposed Project and Dana Point Harbor Dredging projects are both temporary and construction related only; they will not impact the capacities of public services or utilities. If both projects were to occur at the same time, there may be a potentially significant impact on the safety of recreation users on the beach and in the water. For both projects, the dredge would be equipped with markings and lightings in accordance with the U.S. Coast Guard regulations. The location and schedule of the dredge would be published in the U.S. Coast Guard Local Notice to Mariners. The dredge would travel at very low speeds (approximately 1.5 knots) during dredging operations. The travel speed during transport is approximately 5 knots. The dredge would not be expected to present a navigation hazard for fishing or recreational boaters either in the harbor or offshore of the project sites, as these vessels often operate in the presence of other vessels and obstacles with little incident. Even if both the proposed Project and Dana Point Harbor Dredging project were to occur at the same time, implementation of mitigation measures for each project would create cumulative impacts that would be temporary and short-term and would be less than significant.

The Wheeler North Reef project has been constructed; because impacts to public health and safety for the proposed Project are construction related only, the proposed Project would not have any cumulative impacts to public health and safety in conjunction with the Wheeler North Reef project.
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6.2.12 Socioeconomics/Environmental Justice
The Dana Point Harbor Dredging project would not have any impacts on socioeconomics/environmental justice; therefore, no cumulative impacts would result in conjunction with the proposed Project. The proposed Project would occur at least two years after the construction of the Wheeler North Reef project; because impacts to socioeconomics/environmental justice for the proposed Project are construction related only, the proposed Project would not have any cumulative impacts to socioeconomics/environmental justice in conjunction with the Wheeler North Reef project. 255
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7.0 ENVIRONMENTAL COMMITMENTS
The following table lists the actions committed to be undertaken by the USACE for the proposed action to ensure environmental impacts are reduced to the extent possible. These actions may be part of design of the Project as may be best management practices or specific features to reduce environmental impacts; there may be monitoring activities to alert the USACE and the contractor to potential environmental impacts; and there may be mitigation measures to compensate for actual impacts to the environment.

Table 7-1 Summary of design features and monitoring commitments Design Features Purpose Timing
Implementation
Responsibility
Air quality
Use of BACTs and Contingency
Measures for construction
activities
To reduce air
emissions
During all
construction
activities
Construction
contractor
Construction equipment will be
properly maintained and tuned
To reduce air
emissions
During all
construction
activities
Construction
contractor
Maintain at least a 12 percent
saturation level of the sand
To reduce air
emissions
During beach fill
activities
Construction
contractor
Prohibit truck idling in excess of
five minutes
To reduce air
emissions
During all
construction
activities
Construction
contractor
Where feasible, use aqueous or
emulsified diesel fuel for
construction equipment.

To reduce air
emissions
During all
construction
activities
Construction
contractor
Where feasible, use diesel
oxidation catalytic converter
To reduce air
emissions
During all
construction
activities
Construction
contractor
Where feasible, require the use of
newer, lower-emitting trucks to
transport construction workers as
well as equipment and material to
and from construction sites
To reduce air
emissions
During all
construction
activities
Construction
contractor
Water Quality, Sediments, Oceanography
Construct “L”-shaped berms
Anchor sand
placement
operations and
reduce nearshore
turbidity
During beach fill Construction
contractor
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Table 7-1 Summary of design features and monitoring commitments (continued) Design Features Purpose Timing
Implementation
Responsibility
Monitor turbidity To reduce impacts
related to turbidity
During dredging and
beach fill activities Construction contractor
Prepare SWPPP and
OSPRP
Ensure minimal
contamination from
fuel leaks, if any
During all construction
activities Construction contractor
Biological Resources
An underwater survey
for kelp and surfgrass
shall be conducted by
marine biologists prior to
the initiation of beach fill
activities. Based on the
survey, a mooring
location and a pipeline
route shall be selected
that minimizes contact
with surfgrass and kelp
habitat. If kelp and
surfgrass cannot be
avoided completely,
immediately following
beach fill activities,
another survey of the
mooring and pipeline
areas shall be conducted
to determine whether
kelp and surfgrass were
damaged. If substantial
damage to surfgrass or
kelp occurs, an
additional survey shall
be conducted six months
after the beach fill to
determine if kelp and
surfgrass have recovered.

If substantial damage to
kelp and eelgrass is still
observed, restoration of
habitat shall be
implemented in
consultation with the
resource agencies.

Mooring Location
and pipe placement
to ensure avoidance
and minimization to
marine resources
During dredging and
beach fill activities
USACE qualified
marine ecologist or
his/her designated
marine ecologist.

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Table 7-1 Summary of design features and monitoring commitments (continued) Cultural Resources
Prior to construction,
offshore borrow areas 1
and 2 will be subjected
to an underwater remote
sensing survey in order
to determine if
submerged cultural
resources are present
within these areas.

Avoid potentially
undisturbed,
submerged cultural
resources.

Prior to dredging
activities
USACE qualified
archaeologist or his/her
designated
archaeologist
Noise
On-shore construction
activities must be limited
to less than 9 hours per
day.

Minimize noise
emissions
During beach
nourishment/notch fill Construction contractor
Recreation
The contract
specifications shall
require the contractor to
fence/secure off areas of
construction from public
access, including
construction staging
areas and active
construction areas,
including the beach and
nearshore zone.

Avoid safety hazards
to recreation-goers
During beach
nourishment Construction contractor
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Table 7-1 Summary of design features and monitoring commitments (continued) Design Features Purpose Timing
Implementation
Responsibility
Public safety
The dredge would be equipped
with markings and lightings in
accordance with the U.S. Coast
Guard regulations. The location
and schedule of the dredge would
be published in the U.S. Coast
Guard Local Notice to Mariners.

The dredge would travel at very
low speeds (approximately 1.5
knots) during dredging operations.

The travel speed during transport
would be approximately 5 knots.

During dredging and nourishment
activities, proper advanced notice
to mariners would be obtained, and
navigational traffic would not be
allowed within the offshore borrow
site area or mooring/discharge area
offshore of Oceanside.

Warn boaters/
fishermen of
dredging activities
to ensure avoidance
Before and during
dredging activities
and beach
nourishment
USACE resident
engineer
Socioeconomics
The local commercial fishermen’s
association shall be provided with
written notification of the intended
start date of on shore construction,
offshore construction, maps of
project-related vessel
transportation routes, and its
duration. Noticing shall include a
point of contact throughout the
entire construction phase to
respond to concerns regarding
interference and/or other issues
associated with local commercial
fishing operations.

Avoid gear conflicts
and provide for
compensation if loss
occurs
Thirty days prior to
the start of
construction
Coast Guard (via
construction
contractor) and
USACE
Monitoring Commitments
Monitor turbidity levels
To avoid turbidity
impacts to fish and
aquatic species
During dredging
operations and
beach fill activities
Construction
Contractor
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Table 7-1 Summary of design features and monitoring commitments (continued) Design Features Purpose Timing
Implementation
Responsibility
Any earthmoving associated with
this Project that will involve
previously undisturbed soil will be
monitored by a qualified
archeologist who meets the
Secretary of Interior’s Standards
for an Archeologist (see 36 CFR
Part 61). If a previously
unidentified cultural resource (i.e.,
property) that may be eligible for
the NRHP is discovered, all
earthmoving activities in the
vicinity of the discovery shall be
diverted until the USACE
complies with 36 CFR §
800.13(a)(2).

Avoid any
potentially
undisturbed cultural
resources.

During beach fill
activities
USACE qualified
archaeologist or
his/her
designated
archaeologist
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8.0 OTHER NEPA/CEQA REQUIRED ANALYSES

8.1 Effects Found Not to be Significant
Issues that were found not to be significant for the proposed Project included land use and policy. Issues that were found to be less than significant without the need for mitigation measures were geology and topography, noise, transportation, recreation, aesthetics, and public health and safety. The construction and long-term maintenance of the proposed Project would not have a significant effect on these elements and the analyses of these issues are detailed in the environmental consequences section.

8.2 Unavoidable Significant Impacts
The environmental impacts of the proposed Project are described in the environmental consequences section of this Final EIS/EIR. The proposed Project presents one impact that may be significant and cannot be reduced to less than significant levels through the application of feasible mitigation measures are summarized below. A complete description of this impact is presented in the environmental consequences section.

8.3 Irreversible and Irretrievable Commitment of Resources Section 15126(c) of the CEQA Guidelines requires an EIR to address any significant irreversible environmental changes and irretrievable commitment of resources that may occur as a result of alternative implementation. Resources which are irreversibly or irretrievably committed to a project are those that are typically used on a long-term or permanent basis; however, some are considered short-term resources that cannot be recovered and are thus considered irretrievable.

These resources may include the use of non-renewable resources, such as fuel, wood, or other natural or cultural resources. Human labor also is considered a nonretrievable resource because labor used for the proposed action would not be used for other purposes. The unavoidable destruction of natural resources which limit the range of potential uses of that particular environment would also be considered an irreversible or irretrievable commitment of resources.

The proposed Project would result in the placement of approximately 251,000 cy (192,000 m3 )
of dredged beach-compatible fill material along a 3,412 ft long and 50 ft wide beach adjacent to the San Clemente Pier. The Project would nourish the eroded existing beach, which would provide recreational opportunities not only for residents, but also contribute to the regional tourist industry. The proposed action would result in the consumptive use of nonrenewable energy sources and labor required to operate dredges, trucks, pumping equipment, and grading equipment. These commitments of resources could have otherwise been applied to projects other than the proposed action. However, the proposed Project would not result in the use of a substantial amount of resources. Additionally, no natural resources would be permanently destroyed and beach replenishment would be considered beneficial to the region. 261
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8.4 Growth Inducing Impacts
Under CEQA Guidelines Section 15126.2(d), an EIR must discuss the ways in which the proposed action and alternatives could foster economic or population growth or the construction of additional housing, either directly or indirectly, in the area of population growth or the construction of additional housing, either directly or indirectly, in the area surrounding the proposed action. Analysis of growth-inducing effects includes those characteristics of the action that may encourage and facilitate activities that, either individually or cumulatively, would affect the environment. Population increases, for example, may impose new burdens on existing community service facilities. Similarly, improvement of access routes may encourage growth in previously undeveloped areas. Growth may be considered beneficial, adverse, or of no significance environmentally, depending on its actual impacts to the environmental resources present.

A benefit of the proposed Project would be the enhancement or continuation of the recreational usage of the beach at San Clemente Pier. Protection of the beach shoreline provides an amenity for local residents and tourists. The resulting temporary recreational benefits derived from the additional beach area would not be expected to increase the demand for public services and utilities, nor create a need for additional recreational facilities above current projections. Fewer than 100 workers would be involved in construction of the proposed Project, and they would be expected to primarily be drawn by the local work force. The San Clemente Shoreline Protection Project would not involve any new development or add any people to the local population. The proposed Project would have no growth-inducing impacts.

8.5 Energy Requirements and Conservation Potential of Alternatives and Mitigation Measures
Under Appendix F of the CEQA Guidelines, EIRs are required to include a discussion of the potential energy impacts of proposed projects, with particular emphasis on avoiding or reducing inefficient, wasteful, and unnecessary consumption of energy. Potential energy considerations include energy consuming equipment and processes for construction, operation, and/or removal of the Project, energy requirements by fuel type for each Project stage, energy conservation and design features, energy costs and supplies, and transportation use requirements (e.g., estimated daily trips by mode).

The proposed Project would implement several mitigation measures that would reduce inefficient, wasteful, and unnecessary consumption of energy. The energy requirements for the proposed construction activity would be confined to fuel for the dredge, labor transportation, and other construction equipment. Examples of mitigation measures include use of a diesel oxidation catalytic converter for the dredge and the use of newer, lower-emitting trucks to transport construction workers as well as equipment and material to and from construction sites, such as the use of “low-sulfur diesel for construction equipment and diesel particulate filters for diesel equipment and trucks.” The use of alternative clean fuel, such as electric or compressed natural gas-powered construction equipment with oxidation catalysts instead of gasoline- or diesel262 Section 8.0
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powered engines, is also recommended. However, where diesel equipment has to be used because there are no practical alternatives, it is recommended the construction contractors use low-sulfur diesel. In addition, the proposed Project does not involve the trucking of materials, which would decrease the use of trucking equipment typically associated with a beach nourishment project. The minimal use of pieces of construction equipment and implementation of the mitigation measures recommended would allow impacts to energy to be less than significant.

8.6 Relationship between Short-term Uses of the Environment and Maintenance and Enhancement of Long-Term Productivity
The CEQ under NEPA Regulations (40 CFR Part 1500 et seq.) require that an EIS discuss issues related to environmental sustainability. The discussion relates to environmental consequences, including consideration of “the relationship between local short-term uses of man’s environment and the maintenance and enhancement of long-term productivity” (42 USC Section 4332[C] [iv]).

Implementation of the proposed Project would not result in any environmental impacts that would significantly narrow the range of beneficial uses of the environment or pose long-term risks to health, safety, or the general welfare of the public communities surrounding the beach at San Clemente Pier. Rather, the Project would provide for future beneficial beach resources (e.g., recreational activities, sandy shoreline habitat).
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9.0 PUBLIC INVOLVEMENT AND INTERAGENCY COORDINATION

9.1 Required Coordination
This EIS/EIR was circulated for a public review period of 45 days, from August 6 through September 20, 2010, to appropriate resource agencies, local interest groups, and individuals (see Section 13 for distribution list). A public meeting was held at the Community Development Office at 910 Calle Negocio, San Clemente, CA 92673, on August 19, 2010, at 7 p.m. All comments and concerns that were received during the review period have been incorporated into the Final EIS/EIR.

9.2 Public Involvement
Public involvement is a process by which interested and affected individuals, organizations, agencies, and government entities are consulted and included in the decision-making process of a planning effort. In providing public service, the Federal role in water resources planning is to respond to what the public perceives as problems and opportunities and to formulate and select alternative plans that reflect public preferences. In addition, the National Environmental Policy Act (PL 91-190), among other Federal laws and regulations, mandate public involvement.

Federal planning policies, USACE practice, and regulations have consistently required and encouraged this practice. All this must occur, however, with the awareness that the USACE cannot relinquish its legislated decision-making responsibility.

9.2.1 Public Participation
Two of the milestones in the Corps of Engineers South Pacific Division (CESPD) milestone system have been established specifically for the purpose of providing a public forum to receive public input. Public participation through the NEPA/CEQA review process is through both a formal public scoping period and a public and agency review period.

To announce the start of the report scoping, a public notice was issued to local residents, Federal, State, and Local agencies, and interested groups. The recipients were invited to provide input to the study, including the scoping of the environmental issues that should be addressed throughout the study. The Notice of Intent (NOI) was published in the Federal Register. The Notice of Preparation (NOP) was distributed with the NOI and has been approved by the lead CEQA agency, the City of San Clemente. The notice announced a public workshop, where the public were given the opportunity to comment.

A 45-day public review of the Draft EIS/EIR was conducte in August and September of 2010. A final public meeting was held on August 19, 2010 to present the findings of the study and to provide the public an opportunity to express their views on the results and recommendations of the pre-authorization study. Comments included concerns with some of the engineering and environmental assumptions and analyses and the need to develop an acceptable “monitoring and mitigation plan”. All comments have been addressed and our responses are included in the Section 14.0. Additional conference calls and meetings with the Resource Agencies were held to 264
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address some of their concerns over the “monitoring and mitigation plan” and revisions have been made to Appendix B based on these discussions.

9.3 Interagency Coordination
The USACE is the lead agency for NEPA, and the City of San Clemente is the lead/responsible agency for CEQA. This Final EIS/EIR is prepared as a joint document. The implementation or construction phase of the proposed action will be cost-shared with the local sponsor, the City of San Clemente. Therefore, this document is prepared in compliance with NEPA and CEQA regulations.

The proposed action was coordinated with the concerned resource agencies during preparation of the Final EIS/EIR to ensure that the proposed action complies with the requirements of the applicable laws and regulations. A summary of coordination is provided in the following sections.

Pursuant to specific legislative mandates and to assist in the preparation of this document, formal and informal coordination has been initiated with various agencies. The following summarizes the coordination and consultation efforts.

9.3.1 U.S. Fish and Wildlife Service
Coordination with USFWS regarding biological impacts and mitigation has been on-going. The Final EIS/EIR has been prepared to determine the effect of the proposed action on Federal listed species (Section 5.4). In compliance with the FWCA, the USACE has conducted on-going coordination efforts during initial and current stages of planning for this Project. The USACE met with resource agencies, including the USFWS, NOAA Fisheries, and CDFG on October 16, 2007, May 15 and December 16, 2008, July 16, 2009, and January 31, 2011, to discuss the proposed Project and alternatives. The main topics of discussions included the current status of the proposed Project, Project alternatives, and potential environmental issues.

9.3.2 U.S. Army Corps of Engineers, Regulatory Branch
The proposed Project has been coordinated with the USACE Regulatory Branch, which is responsible for issuing the Section 404 permit for dredging. Coordination with USACE Regulatory Branch is on-going. The USACE does not issue itself a 404 permit, but must comply with the CWA. The USACE will complete a 404(b)(1) analysis to ensure Project compliance with the CWA.

9.3.3 U.S. Environmental Protection Agency
The USACE has coordinated with the USEPA throughout the NEPA process and construction activities.
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9.3.4 National Marine Fisheries Service
The USACE met with resource agencies, including NOAA Fisheries, on October 16, 2007 and December 16, 2008, to discuss the proposed Project and alternatives. The USACE has been coordinating with the NOAA Fisheries regarding EFH. Dredging and fill placement construction activities are not anticipated to have significant impacts to EFH. USACE shall continue to coordinate with the NOAA Fisheries throughout the NEPA process and construction activities.

9.3.5 California Coastal Commission
USACE shall continue to coordinate with the CCC throughout the NEPA process and construction activities. The Corps is preparing a Coastal Consistent Determination (CCD) in accordance with Federal Coastal Zone Management Act (CZMA), 16 U.S.C. §1455(d), and regulations at 15 C.F.R. §930 et seq. It is the responsibility of the Corps to determine if a proposed federal activity affects the coastal use of resources in a manner that is not consistent with the California Coastal Management Plan (CCMP) that California has adopted and implemented.

9.3.6 California State Lands Commission
USACE has coordinated with the CSLC throughout the NEPA process and construction activities.

9.3.7 California Department of Fish and Game
The USACE met with resource agencies, including CDFG, on May 15 and December 16, 2008 and July 16, 2009 to discuss the proposed Project and alternatives. USACE has been coordinating with the CDFG regarding State listed species. Dredging and fill placement construction activities are not anticipated to have significant impacts to State listed species.

USACE shall continue to coordinate with the CDFG throughout the CEQA process and construction activities.

9.3.8 California State Historic Preservation Officer/Advisory Council on Historic Preservation
An initial letter was sent to the California SHPO in accordance with Section 106 implementing regulations 36 CFR 800, as amended. This initial consultation described the APE and outlined the steps the USACE has taken to identify historic properties within the APE.

Based on identification efforts to date, there are no historic properties within the APE. A report on these efforts was prepared and sent to the SHPO, with a determination as to whether the Project will affect historic properties. The Project is in compliance with the Act. 266
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9.3.9 Regional Water Quality Control Board
To satisfy requirements of the Federal CWA, USACE would submit this Final EIS/EIR and appropriate technical documentation to the San Diego RWQCB, tasked with implementing the CWA within the region, for their review for CWA Section 401 certification, pursuant to 33 CFR 336.1(a)(1). Upon review of the submittal, the RWQCB would evaluate if issuance of a 401- water quality certification is appropriate. The USACE shall continue to coordinate with the RWQCB throughout the CWA process and construction activities.

9.3.10 Other Agencies/Public Interest Groups
In addition to the above, USACE shall continue coordination efforts with various agencies to minimize impacts to fishing activities and marine resources that may result from placement of beach fill.
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9.4 Required Permits and Approvals
Table 9-1 List of Federal, State, and Local Project Approvals Agency Permit/Approval
Federal
USACE • Permit under Section 404 of the Clean
Water Act, 33 U.S.C. Section 1344
• Section 10 of the River and Harbors Act of
1899, 33 U.S.C Section 403
USFWS • Fish and Wildlife Coordination Act, 16
U.S.C. Section 661-666
NMFS • Magnuson-Stevens Fishery Management
and Conservation Act, 1996 amendments
State
CSLC • Long-term management lease to CDFG or
USFWS
RWQCB • Section 401 Water Quality Certification
• Compliance with waste discharge
requirements for dredge and fill
SHPO • Compliance and Coordination with SHPO
under NHPA 1966, Section 106 (as
defined in 36 CFR 60 and 36 CFR 800)
CCC • Federal Consistency Determination
Local/Regional
County of Orange • Grading permit
County of Orange Vector Control • Review for public health concerns South Coast Air Quality Management District
(SCAQMD)
• Construction-related air permits
SCAQMD/EPA • Federal Air Conformity Determination
• The RWQCB may use the Joint EIS/EIR to consider Water Quality Certification under Section 401 of the Clean Water Act, as well as to consider granting permits for waste discharge requirements for dredge and fill.
• The SCAQMD may use the Joint EIS/EIR to consider construction-related air permits and for the Federal Air Conformity Determination.
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10.0 LIST OF PREPARERS AND REVIEWERS
Agencies and contractors responsible for the preparation and review of this EIS/EIR include the following:

United States Army Corps of Engineers, Los Angeles District P.O. Box 532711
Los Angeles, CA 90053-2325
(Lead Agency)
Chambers Group, Inc.
5 Hutton Centre Drive, Suite 750
Santa Ana, CA 92707
(Consultant)

10.1 Reviewers
Individuals responsible for review of this EIS/EIR included:

10.1.1 U.S. Army Corps of Engineers
Thomas W. Keeney – environmental coordination and Project ecologist; Planning Division, Environmental Resources Branch

10.2 Preparers
Individuals responsible for preparation of this EIS/EIR and/or the associated appendices included:

10.2.1 U.S. Army Corps of Engineers
Joseph Johnson Project Manager, Coastal & Navigation Branch Heather Schlosser Plan Formulator, Planning Division, Plan Formulation Branch Chuck Mesa Coastal Engineer, Engineering Division, Coastal Engineering Section
Amy Holmes Archeology; Planning Division, Environmental Resources Branch Lydia Lopez-Cruz Archeology, Planning Division, Environmental Resources Branch Jeffrey Devine Geotechnical Branch
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10.2.2 Chambers Group, Inc.

Name Section(s) Prepared / Role
Lisa Louie Planning (NEPA/CEQA, Ground and Vessel Transportation, Land Use and Policy, Recreation, Aesthetics, Public Health and Safety, Socioeconomics/Environmental Justice), Water Resources, Project Management
Noel Davis Marine Biology, Water Quality, Oceanography
Laurie Gorman Terrestrial Biology
Linette Lina Water Quality
Sean Tondre GIS
Todd Brody Air Quality, Noise
Paula Fell Planning (Ground and Vessel Transportation, Land Use and Policy, Aesthetics, Public Health and Safety, Socioeconomics/ Environmental Justice)
Linda St. John Technical Editor
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11.0 GLOSSARY, ACRONYMS, AND ABBREVIATIONS

11.3 Acronyms
AAQS Ambient Air Quality Standards
ACHP Advisory Council on Historic Preservation
A.D. After Christ, of the Christian era
a.m. Ante meridiem, before noon
APE Area of Potential Effects
AQMP Air Quality Management Plan
BA Biological Assessment
BACT Best Available Control Technology
B/C Benefit/Cost ratio
B.C. Before Christ, before the Christian era
BO Biological Opinion
BP Before present
CAA Clean Air Act
CAAQS California Ambient Air Quality Standards
CARB California Air Resources Board
CCC California Coastal Commission
CCD Coastal Consistency Determination
CCR California Code of Regulations
CCSTWS Coast of California Storm and Tidal Waves Study
CDIP Coastal Data Information Program
CDFG California Department of Fish and Game
CEQ Council on Environmental Quality
CEQA California Environmental Quality Act of 1970
CESA California Endangered Species Act
CFR Code of Federal Regulations
CHRIS-SCCIC California Historical Resources Information System at the South Central Coastal Information Center
CNEL Community Noise Equivalent Level
CSC California Species of Special Concern
CSDM Coastal Storm Drain Outfall Monitoring
CSLC California State Lands Commission
CWA Clean Water Act of 1977
CZMA Coastal Zone Management Act
DOD Department of Defense
EFH Essential Fish Habitat
EIR Environmental Impact Report
EIS Environmental Impact Statement
ENSO El Niño-Southern Oscillation
ER Engineer Regulation
ER-L Effects Range-Low
ER-M Effects Range-Median
ESA Federal Endangered Species Act of 1973
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ESU Evolutionarily Significant Unit
FE Federal-listed, endangered species
FT Federal-listed, threatened species
FWCA Fish and Wildlife Coordination Act of 1958
GIS Geographic Information System
HCP Habitat Conservation Plan
HHW Higher High Water
HLW Higher Low Water
HUD Department of Housing and Urban Development
I-5 Interstate 5 Freeway
LCP Local Coastal Program
LHW Lower High Water
LLW Lower Low Water
LOSSAN Los Angeles to San Diego
LST Localized Significance Threshold
LUP Land Use Plan
MBTA Migratory Bird Treaty Act
MCBCP U.S. Marine Corps Base, Camp Pendleton
MHHW mean higher high water
MHTL mean high tide line
ML maximum level
MLW mean low water
MLLW mean lower low water
MMPA Marine Mammal Protection Act of 1972
MSL Mean Sea Level
MSAA Master Streambed Alteration Agreement
NAAQS National Ambient Air Quality Standards
NAHC National Historic Preservation Act
NCCP Natural Communities Conservation Plan
NEPA National Environmental Policy Act of 1969
NGVD National Geodetic Vertical Datum
NHPA National Historic Preservation Act
NOAA National Oceanographic and Atmospheric Administration NOAA Fisheries National Marine Fisheries Service
NOI Notice of Intent
NOP Notice of Preparation
NPDES National Pollutant Discharge Elimination System
NRHP National Register of Historic Places
NTU Nephelometric Turbidity Units
OCTA Orange County Transportation Authority
OSPRP Oil Spill Prevention and Response Plan
p.m. Post meridiem, after noon
PRC Public Resources Code
PSSDA Puget Sound Dredged Disposal Analysis
ROD Record of Decision
RWQCB Regional Water Quality Control Board
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SANDAG San Diego Association of Governments
SCAG Southern California Association of Governments
SCAQMD South Coast Air Quality Management District
SCB Southern California Bight
SCRRA Southern California Regional Rail Authority
SE State-listed, endangered species
SHPO State Historic Preservation Officer
SIP State Implementation Plan
SL screening level
SQG Sediment Quality Guidelines
SRA Source Receptor Area
ST State-listed, threatened species
SWPPP Storm Water Pollution Prevention Plan
SWRCB California State Water Resources Control Board
T-BACT Toxics Best Available Control Technology
USACE United States Army Corps of Engineers, Los Angeles District USC United States Code
USEPA United States Environmental Protection Agency
USFWS United States Fish and Wildlife Service
USGS United States Geological Survey
WRDA Water Resources Development Act

11.4 Chemical Abbreviations
CO carbon monoxide
DDT dichlorodiphenyltrichloroethane
NO2 nitrogen dioxide
NOx oxides of nitrogen
O3 ozone
PAHs polycyclic aromatic hydrocarbons
Pb lead
PCBs polychlorinated biphenyls
PM10 particulate matter equal to or less than 10 microns in size PM2.5 fine particulate matter equal to or less than 2.5 microns in size ROG reactive organic gases
SO2 sulfur dioxide
SOx oxides of sulfur
TAC toxic air contaminants

11.5 Units of Measurement
ac acre(s)
ºC degrees Celsius
dB decibels
dBA decibels using A weighted measurements
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ºF degrees Fahrenheit
ft foot/feet
ft/sec feet per second
ft2 square feet
ha hectare
hp horsepower
H:V horizontal:vertical
kg kilograms
km kilometer(s)
lbs pounds
Ldn Day-night average noise level
Leq equivalent noise level
mg/kg milligrams per kilogram
mg/L milligrams per liter
m meter(s)
m2 square meter(s)
m3 cubic meter(s)
mi mile(s)
mi2 square mile(s)
mL milliliter(s)
mm millimeter(s)
mph miles per hour
NTU Nephelometric Turbidity Unit(s)
ppm parts per million
ppt parts per thousand
yd yard(s)
yd2 square yard(s)
yd3 cubic yard(s)
yd3
/ft cubic yard(s) per foot
yr year
μg/kg micrograms per kilogram
μg/L micrograms per liter
% percent
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12.0 REFERENCES
ADL
1984 Point Arguello Field and Gaviota Processing Facility Area Study and Chevron/Texaco Development Plans EIR/EIS. Prepared for the County of Santa Barbara, Minerals Management Service, CA State Lands Commission, California Coastal Commission, and California Secretary of Environmental Affairs. Prepared by Arthur D. Little, Santa Barbara Ca.

AMEC Earth and Environmental, Inc. (AMEC)
2002 Regional Beach Sand Project Preconstruction and Construction Monitoring Report.

Prepared for San Diego Association of Governments.
2005 Regional Beach Sand Project Year 4 (2004-2005) Post-Construction Monitoring Report for Intertidal, Shallow Subtidal, and Kelp Forest Resources and Comprehensive Analysis Report (2001-2005). Prepared for San Diego Association of Governments (SANDAG).

Aspen Environmental Group
2005 Environmental Information document for Post-Suspension Activities on the Nine Federal Undeveloped Units and Lease OCS-P 0409 Offshore Santa Barbara, Ventura, and San Luis Obispo Counties. Prepared for Minerals Management Service Pacific OCS Region.

Barlow, J., and T. Gerrodette
1996 Abundance of cetaceans in California waters based on 1991 and 1993 ship surveys.

NOAA Tech. Mem. NOAA-TM-NMFS-SWFSC-233.

Barlow, J., R.L. Brownell, Jr., D.P. DeMaster, K.A. Forney, M.S. Lowry, S. Osmek, T.J. Ragen, R.R. Reeves, and R.J. Small
1995 S. Pacific Marine Mammal Stock Assessments. NOAA Technical Memorandum NMFS, NOAA-TM-NMFS-SWFSC-219. 162 pp.

Barlow, J., K.A. Forney, P.S. Hill, R.L. Brownell, Jr., J.V. Carretta, D.P. DeMaster, F. Julian, M.S. Lowry, T. Ragen, and R.R. Reeves
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Bean, Lowell John, and Florence C. Shipek
1978 Luiseño. In Handbook of North American Indians, edited by Robert F. Heizer. 8:550-562.

Bonnell, M.L., B.J. Le Boeuf, M.O. Pierson, D.H. Dettman, G.D. Farrens, and C.B. Heath 1981 Pinnipeds of the Southern California Bight. Summary Report, 1975-1978, Part I, In: Vol. III, Principal Investigator's reports, marine mammal and seabird survey of the Southern California Bight area. NTIS No. PB 81-248-71. 535 pp. 275
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Bonnell, M.L., M.O. Pierson, and G.D. Farrens
1983 Pinnipeds and sea otters of central and northern California, 1980-1983: status, abundance, and distribution. Final Report to U.S. Department of the Interior, Minerals Management Service, Pacific OCS Region under Contract 14-12-0001- 29090. OCS Study MMS 84-0044. 220 pp.

Bonnell, M.L., and M.D. Dailey
1993 Marine mammals. In: Ecology of the Southern California Bight: A Synthesis and Interpretation, M.D. Dailey, D.J. Reish, and J.W. Anderson (eds.). Berkeley, CA:

University of California Press. pp. 604-681.

Briggs, K.T., W.B. Tyler, D.B. Lewis, P.R. Kelly, and D.A. Croll 1983 Brown pelicans in central and northern California. Journal of Field Ornitholigy, Vol. 54(4): 353-466.

Brock, James and Mark A. Roeder
1985 Archaeological and Paleontological Assessment Report for a Proposed 4.5 Acre County Park at San Clemente State Beach Park, San Clemente, Orange County, California. Prepared for Kenneth Wood Associates, Laguna Beach, CA.

Brown, Joan C.
1997 Cultural Resource Reconnaissance For a Coastal Pedestrian and Bicycle Path in San Clemente, Orange County, California. Prepared for Michael Brandman Associates, Irvine, California.

Burkett, E.E., N.A. Rojek, A.E. Henry, M.J. Fluharty, L. Comrack, P.R. Kelly, A.C. Mahaney, and K. M. Fien
2003 Report to the California Fish and Game Commission: Status review of Xantus’ murrelet (Synthliboramphus hypoleucus) in California. Calif. Dept. of Fish and Game, Habitat Conservation Planning Branch Status Report 2003-01. 96 pp+appendices.

California Department of Transportation (Caltrans)
1998 Traffic Noise Analysis Protocol for New Highway and Reconstruction Projects, including Technical Noise Supplement. October 1998.

California State Lands Commission, United States Fish and Wildlife Service, and United States Army Corps of Engineers (CSLC, USFWS and USACE)
2001 Final EIR/EIS for the Bolsa Chica Lowlands Restoration Project.

Carretta, J.V., K.A. Forney, M.M. Muto, J. Barlow, J. Baker, B. Hanson and M. Lowry 2007 U.S. Pacific Marine Mammal Stock Assessments: 2006. NOAA Technical Memorandum NOAA-TM-NMFS-SWFSC-398
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Chambers Group, Inc.
1992 Draft Environmental Impact Statement/Environmental Impact Report (EIS/EIR) for the Proposed Bolsa Chica Project. Prepared for the U.S. Army Corps of Engineers and the City of Huntington Beach.
1996 Biological, Chemical and Physical Survey of the North Energy Island Pit. Prepared for the U.S. Army Corps of Engineers.
2002 Draft Environmental Baseline Report for the Huntington Beach Bluff Top Park Storm Feasibility Study. Prepared for U.S. Army Corps of Engineers (USACE), Los Angeles District, October 2002.
2005 Monitoring Report for Western Snowy Plover at the Talbert Channel. For County of Orange.
2007 Monitoring of Kelp Beds, Eelgrass and Surfgrass off Goleta Beach. Prepared for Santa Barbara County Parks.
2007 Draft Environmental Impact Report Goleta Beach County Park Long-Term Protection Plan Prepared for Santa Barbara County Parks.

City of San Clemente Planning Department
1993 City of San Clemente General Plan, Noise Element, amendments through 2003. 2003 City of San Clemente Municipal Code
Clarke, D.G. and D. H. Wilbur
2000 Assessment of Potential Impacts of Dredging Operations Due to Sediment Resuspension. DOER Technical Notes Collection, ERDC TN-DOER E9, U.S.

Army Engineer Research and Development Center, Vicksburg, MS.

Coastal Resources Management (CRM)
2000 Marine Biological Impact Assessment, City of San Clemente Beach Replenishment Program. Prepared for Moffatt & Nichol Engineers
Continental Shelf Associates
1984 Environmental Assessment of the Palm Beach County Erosion Control Program:

Phase I: Ocean Ridge. Final report for the Palm Beach County Board of County Commissioners. 110 pp.

County of Orange, the Cities of Orange County, and the Orange County Flood Control District 2003 Drainage Area Management Plan. County of Orange, Santa Ana, CA. Submitted to the Santa Ana Regional Water Quality Control Board and the San Diego Regional Water Quality Control Board.
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2006 2005-06 Unified Annual Progress Report/ Program Effectiveness Assessment.

County of Orange, Santa Ana, CA. Submitted to the Santa Ana Regional Water Quality Control Board and the San Diego Regional Water Quality Control Board.

Crane, N.
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Martin, K.
2006 Ocean Outlets and Grunion in the County of Orange
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MEC Analytical Systems Inc. (MEC)
1997 Least Tern and Water Turbidity Monitoring Seal Beach Pier to Warner Avenue Summary Report. Prepared for U.S. Army Corps of Engineers, Los Angeles District.
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Prepared for U.S. Army Corps of Engineers (USACE), Los Angeles District, December 2002.

Mills, K.L, W.J. Sydeman, and P.J. Hodum (eds.)
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Moratto, Michael
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2001 Field Guide to Birds of North America, 3rd ed. Natl. Geog. Society, Washington, D.C. 480 pp.

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1999 Small Takes of Marine Mammals Incidental to Specified Activities; Seismic Hazards Investigation in Southern California. Federal Register, Notices, Vol 64 (112): 31548-31553. Friday, June 11, 1999.

Page, G. W., J. S. Warriner, J. C. Warriner, and P. W. C. Paton. 1995 Snowy Plover (Charadrius alexandrinus). In The Birds of North America, No. 154 (A. Poole and F. Gill, eds.). The Academy of Natural Sciences, Philadelphia, PA, and The American Ornithologists’ Union, Washington, D.C. 281
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2005 Coastal Habitat Study, 2003-2004: Influence of Beach Nourishment on Biological Resources at Beaches in the City of Encinitas, California. Prepared for City of Encinitas.

San Diego Association of Governments and U.S. Department of the Navy (SANDAG) 2000 San Diego Regional Beach Sand Project EIR/EA. Prepared for SANDAG and U.S.

Department of the Navy, June 2000. Final Environmental Impact Report/ Environmental Assessment by KEA Environmental, MEC Analytical Systems, Moffatt and Nichol Engineers, and GeoArch Marine Archaeology Consultants.

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D.R. Browne, K.L. Mitchell, and H.W. Chaney (eds.), Proceedings of the Fifth California Islands Symposium, 29 March to 1 April 1999, Santa Barbara Museum of Natural History, Santa Barbara, CA. Sponsored by the U.S. Minerals Management Service, Pacific OCS Region, 770 Paseo Camarillo, Camarillo, CA 93010. OCS Study No. 99-0038.

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13.0 DISTRIBUTION LIST

FEDERAL
Senator Dianne Feinstein
750 "B" Street,
Suite 1030
San Diego, CA 92101
Senator Dianne Feinstein
Hart Office Building
Room 331
Washington, D.C. 20510
Senator Barbara Boxer
600 B Street, Suite 2240
San Diego, CA 92101
Senator Barbara Boxer
112 Hart Senate Office Building
Washington, D.C. 20510
Congressman Ken Calvert
44th District
2611 Antonio Parkway, Suite 300
Las Flores, CA 92688
Congressman Ken Calvert
44th District
2201 Rayburn Building
Washington, DC 20515
John M. Fowler, Executive Director
Advisory Council on Historic Preservation
1100 Pennsylvania Avenue, NW, Suite 803
Old Post Office Building
Washington, DC 20004
Director
Environmental Policy and Compliance
Department of the Interior
Main Interior Building, MS 2340
1849 C Street, NW
Washington, DC 20240
Ms. Pearl Young
US EPA, NEPA Compliance Division
Office of Federal Activities
EIS Filing Section
Ariel Rios Building (South Oval Lobby)
Room 7220
1200 Pennsylvania Avenue, NW
Washington, DC 20004
Mr. Jim Bartel
Field Supervisor
U. S. Fish and Wildlife Service
6010 Hidden Valley Road
Carlsbad, California 92009
U.S. Department of Commerce
National Oceanic Atmospheric
Administration
National Marine Fisheries Service
501 West Ocean Blvd., Suite 4200
Long Beach, CA 90802-4221
Environmental Protection Agency, Region IX
75 Hawthorne Street
San Francisco, CA 94111
Commanding Officer
Marine Corps Base
Box 555010
Camp Pendleton, CA 92055-5010
Southern California Agency
Bureau of Indian Affairs
2038 Iowa Avenue, Suite 101
Riverside, CA 92507-0001
Office of Ocean and Coastal Resource
Management
NOAA Ocean Service
1305 East West Highway
Silver Spring, MD 20910
286
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Juaneno Band of Mission Indians
Acjachemen Nation
David Belardes, Chairperson
31742 Via Belardes
San Juan Capistrano, CA 92675
Juaneno Band of Mission Indians
Acjachemen Nation
Anthony Rivera, Chairman
31411-A La Matanza Street
San Juan Capistrano, CA 92675-2674
Juaneno Band of Mission Indians
Acjachemen Nation
Joyce Perry, Tribal Manager & Cultural
Resources
31742 Via Belardes
San Juan Capistrano, CA 92675
Juaneno Band of Mission Indians
Alfred Cruz, Cultural Resources
Coordinator
P.O. Box 25628
Santa Ana, CA 92799
Juaneno Band of Mission Indians
Adolph “Bud” Sepulveda, Chairperson
P.O. Box 25828
Santa Ana, CA 92799
Juaneno Band of Mission Indians
Sonia Johnston, Tribal Vice Chairperson
P.O. Box 25628
Santa Ana, CA 92799
Juaneno Band of Mission Indians
Anita Espinoza
1740 Concerto Drive
Anaheim, CA 92807
STATE
Milford Wayne Donaldson
State Historic Preservation Officer
Office of Historic Preservation
1725 23rd Street, Suite 100
Sacramento, CA 95816
Department of Water Resources
1416 9th Street
Sacramento, CA 95814
California Coastal Commission
45 Fremont St, Ste 2000
San Francisco, CA 94105
California Coastal Commission
South Coast District Office
200 Oceangate, 10th Floor
Long Beach, CA 90802-4416
California Department of Fish and Game
South Coast Region (Region 5)
4949 Viewridge Ave.

San Diego, CA 92123
Caltrans District 12
3347 Michelson Drive, Suite 100
Irvine, CA 92612
State Clearing House
1400 Tenth Street
Sacramento, CA 95812-3044
California Coastal Conservancy
1330 Broadway, 13th Floor
Oakland, CA 94612
California State Lands Commission
100 Howe Ave, Suite 100 South
Sacramento, CA 95825-8202
San Diego Regional Water Quality Control
Board
9174 Sky Park Court, Suite 100
San Diego, CA 92123-4340
287
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Native American Heritage Commission
915 Capitol Mall, Room 364
Sacramento, CA 95814
COUNTY
South Coast AQMD
21865 Copley Dr.

Diamond Bar, CA 91765-4182
Organizations
Natural Resources Defense Council
1314 Second Street
Santa Monica, CA 90401
Southern California Edison
P.O. Box 800
Rosemead, CA 91770
Center for Biological Diversity
351 California Street, Suite 600
San Francisco, CA 94104
Center for Biological Diversity
PMB 447, 8033 Sunset Blvd.

Los Angeles, CA 90046-2401
Sierra Club Angeles Chapter
3435 Wilshire Blvd #320
Los Angeles, CA 90010-1904
Surfrider Foundation
South Orange County
34145 Pacific Coast Hwy, #619
Dana Point, CA 92629-2808
Mark Rauscher
Surfrider Foundation
942 Calle Negocio
San Clemente, CA 92673
Local
Tom Bonigut
City of San Clemente
910 Calle Negocio, Suite 100
San Clemente, CA 92673
San Clemente Library
242 Avenida Del Mar
San Clemente, CA 92673
Don Kunze
107 Ave. San Diego
San Clemente, CA 92672
George Gregory
139 Avenida Florencia-A
San Clemente CA 92672
Keith Aiken
[email protected]
Lynn Hughes
2675 Queda Way
Laguna Beach, CA 92651
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14.0 RESPONSE TO COMMENTS
No. Commenter Comment Response
Federal Agencies D.F. Levi, Commanding Officer, Marine Corps Base, Camp Pendleton, September 15, 2010 1 Marine Corps General. The location of the proposed borrow site depicted in Figures 1.1-1, 1.3-1 and throughout the DEIR/DEIS would be more accurately identified as located off Camp Pendleton since it is directly west of Camp Del Mar and the Del Mar Boat basin not the Oceanside Harbor area as currently stated.

The borrow site (Area 2) is offshore of both the Camp Del Mar Boat Basin and Oceanside Harbor as shown in Geotechnical Appendix Plate 1, ranging from 0.75 to 1.0 miles. This will be clarified throughout the report(s). 2 Marine Corps General. The proposed borrow site and transit routes appear to be in close proximity or through nautical restricted areas that exist in the vicinity of the Camp Del Mar area and further up the coast off Red Beach of Marine Corps Base Camp Pendleton. The Coast Guard has listed and, described these restricted areas off Camp Pendleton in detail in their publication: Coast Pilot 7 in §334.900, §334.905 and §334.91O. Regulations for these areas prohibit several activities including dredging and anchoring. As sites are in close proximity to the proposed borrow site the Draft EISIEIR should incorporate some information regarding their existence and restrictions.

Inquiry was made with the Marine Corps Base Camp Pendleton (MCBCP), Land Management Branch as well as the US Coast Guard publication Coast Pilot 7 in §334.900, §334.905 and §334.910. Both sources have indicated that the borrow site and the transit location are not within a restricted area. The FEIS/R will replace a figure that depicts the borrow site location as Figure 3.4-1, page 3-9 in reference to "restricted areas 334.900 and restricted area 334.910” (U.S. Coast Pilot 7). 3 Marine Corps Page 1-1 Study Area -the proposed borrow area is outside the described study area. Does it have its own study area? If so where is it addressed? Detail is focused on the San Clemente beach placement site because 1) there are no onshore impacts associated with dredging at the Oceanside borrow site and because 2) information on the Oceanside borrow side was included in the EIR/EA for the San Diego Regional Beach Sand Project (SANDAG 2000) and is incorporated by reference. Where pertinent, information on the Oceanside borrow site is included in Section 4.0. Section 4.2.1 describes the location and substrate of the borrow site. Section 4.3.1 is a general description of water column physical and chemical characteristics and is applicable to the Oceanside borrow site. Section 4.3.3 specifically contains information on sediments at the Oceanside borrow site. Section 4.3.4 on 289
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No. Commenter Comment Response
oceanographic characteristics and coastal processes is applicable to the Oceanside borrow site as well as San Clemente because both sites are in the same littoral cell. Section 4.4.2 includes information on the biology of the Oceanside borrow site. 4 Marine Corps Page 3-1 Evaluation Criteria. Were any planning constraints considered for the impact caused by the dredging at the borrow site? Such as -"Preserve water quality characteristics along the coast and near shore areas in the vicinity of the borrow site" Impacts of dredging at the borrow site were evaluated against the significance criteria for the relevant issue areas (Section 5). To the extent feasible, it was a project objective to avoid or mitigate for significant impacts. The relevant significance criteria for water quality that were applied to dredging at the borrow site were: “Impacts to marine water quality are considered significant if any of the following apply:
• The water quality objectives in the California
Ocean Plan (SWRCB 2005) are violated;
and/or
• Project operations or discharges that change
background levels of chemical and physical constituents or elevate turbidity would produce long-term changes in the receiving environment of the site, area, or region that would impair the beneficial uses of the receiving water.

Impacts are considered less than significant if the project would result in elevation of contaminants, but the levels remain below water quality criteria or if elevation of contaminant concentrations above criteria occurs only within a couple of hundred feet or less of the point of discharge for a few hours or less.” 5 Marine Corps Page 3-3 Beach Fill. Lines 27 and 28 states "Beach nourishment may use offshore or onshore borrow sites. In the study area, offshore sources have historically been used for several reasons." Please include the reasons for excluding onshore borrow sites.

Offshore sites were chosen using the SANDAG (2000) study discussed, which identified offshore sources in the project vicinity. Onshore sources were not carried forward as they were not as technically or economically feasible. 290
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No. Commenter Comment Response
6 Marine Corps Page 3-9. Figure 3.4-1-Oceanside Borrow Site Map.

Recommend that this graphic be changed to a Navigational Chart for more clarity of the borrow site's location.

The FEIS/R will replace a figure that depicts the borrow site location as Figure 3.4-1, page 3-9 in reference to "restricted areas 334.900 and restricted area 334.910 (U.S. Coast Pilot 7). A navigational chart is not necessary and would be more confusing to the general public. The dredge operator will know and will be well versed on navigation charts for the dredge. 7 Marine Corps Page 4-1 Affected Environment Since part of the project includes dredging material at the borrow site, information on that location should be included in the Affected Environment Chapter.

Please see the Response to Comment 3. The affected environment at the borrow site is discussed for the relevant issue areas in Section 4. 8 Marine Corps Page 4-1 Meteorology and Air Quality needs to include discussions about San Diego Air Pollution Control District (SDAPCD) since there will be emissions in that Air District.

Information for the San Diego Air Basin has been added to the FEIS/R. 9 Marine Corps Page 4-13 Water Quality, Sediments, and Oceanography should discuss discharges in the vicinity of the borrow site.

Section 4.3.1 has been amended to include information on discharges near the Oceanside borrow site. 10 Marine Corps Page 4-38 Biological Resources Lines 7 and 8 states - "These sections describe biological resources found in the vicinity of the proposed beach fill and borrow site areas along the San Clemente coastline." The proposed borrow site is along the Camp Pendleton/Oceanside coastline. Does this section cover that site or only the potential borrow site near San Clemente? Some sections like Page 4-45 lines 26-36 provide information on the proposed borrow site along the Camp Pendleton/Oceanside coastline and others like Table 4-14 focus only on the San Clemente site ignoring biological resources in the immediate vicinity of the proposed borrow site.

The biological resources section addresses both the San Clemente beach placement site and the Oceanside borrow area. Some additional text has been added to clarify the relationship between sensitive resources and the borrow site. 11 Marine Corps Table 4-14 Special Status Listed Species that May Occur in the San Clemente Pier or Oceanside Borrow Site Areas:
-Southern steelhead has also been found in the Santa Margarita River near the proposed borrow site.

Table 4-14 will be revised to indicate taxa that will not be present and those that could be present, but their occurrence is negligible or very low.

1. Southern steelhead will not be affected
because the project action implementation will occur at a time when they are not present. 291
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No. Commenter Comment Response
-Western snowy plover nesting sites are located within about one mile of the proposed Oceanside borrow site as such the "Potential For Occurrence in the Project Area" should be high. -California least tern nesting sites are located within about one mile of the proposed Oceanside borrow site as such the "Potential For Occurrence in the Project Area" should be high.

2. Snowy plover will not be affected by the
action implementation because these charadrids will not be breeding during the project implementation. Sea and Sage Audubon performed a 2010 winter survey. San Clemente Beaches were not included. Beach habitat within the project placement footprint, as well as in Oceanside, are narrow and heavily used by people. Philip Unitt, San Diego Natural History Museum, Birds of San Diego County, Memoir 13, 1984, does not show snowy plovers in north portion of the county. California State Parks has tracked snowy plovers during winter window surveys and has driven San Clemente State Beach many times with zero plovers observed over the years (David Pryor, personal communication, February 2011). Snowy plovers will not use the borrow site and any wintering activity will not be affected by actions at the borrow site off-shore. Potential for occurrence remains negligible to low, at best. In comparison, the Landing Craft, Air Cushion (LCAC) Transport would be expected to have orders of magnitude greater effect on snowy plovers than the borrow site operations.

3. Least terns will not be affected by the action
implementation because these larids will not be breeding during the project implementation. Least terns will be on their southern latitude wintering grounds during project implementation. Potential for occurrence remains negligible. 12 Marine Corps Page 4-51 Section 4.4.3.3 Steelhead Trout (Federal Endangered) -Southern steelhead has also been found in the Santa Margarita River near the proposed borrow site.

It is recognized that southern steelhead migrate up the Santa Margarita River and this information will be added to the FEIS/R. However, there will be no effect to southern steelhead because this taxon will not be 292
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present during sand placement activities due to the season and the fish would be expected to avoid the barge activities at the borrow site in the same manner they would avoid any other vessel in the area. 13 Marine Corps Page 4-51 Section 4.4.3.5 California Least Tern (Federal and State Endangered)-Lines 3 & 4 Large numbers of California least tern nesting sites are located within about one mile of the proposed Oceanside borrow portion of the project area and are likely to forage at the proposed borrow site.

Least terns will not be affected by the action implementation because these larids will not be breeding during the project implementation. Least terns will be on their southern latitude wintering grounds during project implementation. Potential for occurrence remains negligible. 14 Marine Corps Page 4-51 Section 4.4.3.6 Western Snowy Plover (Federal Threatened) Lines 37 & 38-The Santa Margarita River nesting site is located within about one mile of the proposed Oceanside borrow portion of the project area.

Snowy plover will not be affected by the action implementation because these charadrids will not be breeding during the project implementation. Wintering snowy plovers will be few, if any on the beaches opposite the borrow site and the site is 0.75 to 1.0 miles off-shore and thus will not be affected by borrow site activities. 15 Marine Corps Page 4-57 Section 4.5.2 Area of Potential Effects (APE) states "The offshore portion of the APE includes two offshore borrow sites, Areas 1 and 2. Area 1 is located southwest of the San Clemente Municipal Pier, and Area 2 is located off the coast of Oceanside." Section 4.5.3 summarizes the archaeology within and adjacent to the southern California coastline from Doheny State Beach to San Mateo Point. Where is the summary for Area 2 which is located off the coast of Camp Pendleton/Oceanside? During the Design Phase, an underwater remote sensing survey of the borrow site (Area 2) will be conducted for the purpose of identifying any resources that may be present. If resources are identified, they will be evaluated for inclusion in the National Register of Historic Places (NRHP). If any are determined to be eligible for the NRHP, avoidance or mitigation efforts would be implemented. These compliance procedures will be coordinated with the SHPPO officer and consistent with Section 106 of the National Historic Preservation Act (36CFR800). 16 Marine Corps Page 4-64 Section 4.6.2 Vessel Transportation - Oceanside Harbor may be 20 miles from the San Clemente portion of the project area but it is within one mile of the Proposed Borrow Site. The section should also address Marine Corps and Navy use of the area near and between the two portions of the project site and dredge barge impacts on those uses. This may also be the place to address the nautical restricted areas listed and described in the Coast Guard publication known as Coast Inquiry was made with the Marine Corps Base Camp Pendleton (MCBCP), Land Management Branch and as well as the US Coast Guard publication Coast Pilot 7 in §334.900, §334.905 and §334.910. Both sources have indicate that the borrow site and the transit location are not with a restricted area. The FEIS/R will replace a figure that depicts the borrow site location as Figure 3.4-1, page 3-9 in reference to “restricted areas 334.900 and restricted area 334.910 293
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Pilot 7 that are in the vicinity of the Camp Del Mar area (in addition to a 3rd restricted area located further up the coast off Red Beach). The planned borrow site for this project is located within the Camp Pendleton Amphibious Vehicle Training Area (CPAVTA), as noted on most nautical charts (extends approximately 5.5 miles out from the southern end of the Camp Pendleton/Oceanside Harbor north breakwater and north to just south of San Mateo point). While that should not be a problem and dredging operations would not be prevented off the southern coast of Camp Pendleton, nevertheless, advance coordination of any planned dredging operations in or near the CPAVTA is required.The Final EIR/EIS for this project should include a provision that the dredging operator pre-coordinate all planned dredging and transport operations with Camp Pendleton. If the Base is made aware of such offshore dredging operations and transport in advance, this activity can be incorporated into the Daily Training Schedule and efforts can be made to deconflict any potential Naval or Marine Corps amphibious training operations that may also be planned in close proximity to the dredging site and throughout the CPAVTA. (U.S. Coast Pilot 7). Dredging will occur in the winter months outside environmental (e.g., nesting least tern) windows. Dredging will occur between early September and the end of March. Oceanside Harbor Days are held at the end of September/beginning of October and will be avoided. All other annual sailing events that occur near the Harbor will be coordinated and avoided. The Corps will contact the CPAVTA and obtain schedules of training activity occurring in the ocean and coordinate dredging activities to avoid and conflict/interference. The FEIS/R now includes a provision that the dredging operator shall pre-coordinate all planned dredging and transport operations with Camp Pendleton. 17 Marine Corps Page 4-80 Section 4.9.1 Beaches -fails to address Camp Pendleton and Oceanside beaches which are located within one mile of the proposed borrow site.

MCBCP beaches will be added to the FEIS/R.
18 Marine Corps Page 4-81 Section 4.9.2 Annual Events -fails to address Camp Pendleton Del Mar Recreation Beach and Oceanside Harbor Events which are located within one mile of the proposed borrow site.

Dredging will occur between early September and the end of March. Dredging activities will occur approximately 0.75 to 1.0 miles from the shoreline and would not be expected to have any effects on the Oceanside Harbor Events occurring onshore except for the aesthetic view of a dredge in the distance. The addition of one relatively small dredge in the area near the harbor where naval vessels are common would not be expected to affect the general public during this event. All other annual sailing events that occur near the Harbor will be coordinated and 294
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avoided.
19 Marine Corps Page 5-1 Section 5-1 Air Quality and Meteorology -Where is the discussion for emissions within the SDAPCD?
Information for the San Diego Air Basin has been added to the FEIS/R. 20 Marine Corps Page 5-25 Impact WR-50-2: Would there be any potential impact from turbidity during dredging to southern steelhead attempting to enter the Santa Margarita River during the rainy season? As described in Section 5.3.2, turbidity generated during dredging at the Oceanside borrow site is expected to affect a relatively small area. Observations during dredging at the Oceanside borrow site for the San Diego Regional Beach Sand Project identified only small plumes that did not exceed 2,700 square yards in extent. Southern steelhead enter southern California streams during the winter season when streams are flowing and nearshore waters are naturally turbid from stream discharges. Turbidity from dredging at the Oceanside borrow site would not be expected to have a significant effect on southern steelhead. 21 Marine Corps Page 5-35 Section 5.4 Biological Resources -Lines 25 & 26 -with the discovery of southern steelhead in the Santa Margarita River its potential to occur in the project area (borrow site) is higher than identified in the draft EISIEIR.

The assessment of potential to occur is accurate as currently stated in the document. The potential for southern steelhead to occur at the Santa Margarita River during project implementation remains negligible to low. Because steelhead may change the stream they inhabit from one year to the next, the discovery of southern steelhead in the Santa Margarita River in one year does not increase the potential for the species to occur in the project area; further discoveries within the river would need to validate that the recent occurrence was not a chance occurrence. 22 Marine Corps Page 5-45 -Impact BR-115-1: A direct adverse effect on the population of a special status listed species or the loss or disturbance of important habitat for a listed species. Lines 34-36Western snowy plovers also breed on the beaches of Camp Pendleton near the Oceanside borrow area.

The Corps will contact the CPAVTA and obtain schedules of training activity occurring in the ocean and coordinate dredging activities to avoid and conflict/interference. 24 Marine Corps Page 5-60, Section 5.8 -Noise -What are the noise standards/criteria on shore in the vicinity of the borrow site? This would seem important to support the statement in lines 1 and 2 on page 564, and 26 through 30 on page 5-67.

As described in Section 5.8.2, the noise of the dredging activities at the Oceanside borrow site to onshore receptors would be 44.5 dBA leq. The increase in noise to sensitive receptors would be imperceptible. The noise of the dredge onshore would be less than the noise of breaking waves. Therefore, noise criteria for the City of Oceanside would not be applicable because noise from the dredge would not be discernible to sensitive receptors onshore. 25 Marine Corps Page 5-77, Section 5.11 -Public Health and Safety -It appears the planned borrow site for this project is located within the Camp Pendleton Amphibious Vehicle Training Area (CPAVTA), as noted on most nautical charts. While that should not be a problem and dredging operations Inquiry was made with the Marine Corps Base Camp Pendleton (MCBCP), Land Management Branch and as well as the US Coast Guard publication Coast Pilot 7 in §334.900, §334.905 and §334.910. Both sources have indicate that the borrow site and the transit 296
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would not be prevented off the southern coast of Camp Pendleton, nevertheless, advance coordination of any planned dredging operations in or near the CPAVTA is strongly recommended. The Final EIRIEIS for this project should include a provision that the dredging operator precoordinate all planned dredging and transport operations with the Camp Pendleton Range Scheduling department in the Range Operations Division. If the Base is made aware of such offshore dredging operations and transport in advance, this activity can be incorporated into the Daily Training Schedule and efforts can be made to deconflict any potential Naval or Marine Corps amphibious training operations that may also be planned in close proximity to the dredging site and throughout the CPAVTA. location are not with a restricted area. The FEIS/R will replace a figure that depicts the borrow site location as Figure 3.4-1, page 3-9 in reference to “restricted areas 334.900 and restricted area 334.910” (U.S. Coast Pilot 7). As with all US Army Corps projects that are within DoD Ranges, coordination will ensue during project implementation. 26 Marine Corps Page 6.1 Description of Cumulative Projects -Why isn't the Oceanside Harbor Dredging project include in the Cumulative Impact Analysis since it is located within one mile of the borrow site? Oceanside Harbor dredging is not included as a cumulative project for the dredging at the Oceanside borrow site because the impacts of the two dredging projects would not be expected to interact cumulatively. The dredging at the Oceanside borrow site would not affect the shoreline environment, including Oceanside Harbor. Dredging at Oceanside Harbor would not be expected to affect the environment in the vicinity of the borrow site about 1 mile offshore. 27 Marine Corps Page 7-1 Section 7.0 Environmental Commitments -Since the planned borrow site for this project is located within the Camp Pendleton Amphibious Vehicle Training Area (CPAVTA), as noted on most nautical charts the commitment that the dredging operator pre~coordinate all planned dredging and transport operations with Camp Pendleton should be added. If the Base is made aware of such offshore dredging operations and transport in advance, this activity can be incorporated into the Daily Training Schedule and efforts can be made to deconflict any potential Naval or Marine Corps amphibious training operations that may also be planned in close proximity to the dredging site and throughout the CPAVTA.

Inquiry was made with the Marine Corps Base Camp Pendleton (MCBCP), Land Management Branch and as well as the US Coast Guard publication Coast Pilot 7 in §334.900, §334.905 and §334.910. Both sources have indicate that the borrow site and the transit location are not with a restricted area. The FEIS/R will replace a figure that depicts the borrow site location as Figure 3.4-1, page 3-9 in reference to “restricted areas 334.900 and restricted area 334.910” (U.S. Coast Pilot 7). As with all US Army Corps projects that are within DoD Ranges, coordination will ensue during project 297
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implementation.
28 Marine Corps Page 9-3 Section 9.3.10 Other Agencies/Public Interest Groups -Coordination with MCB Camp Pendleton is required for all activity that takes place in the Camp Pendleton Amphibious Vehicle Training Area (CPAVTA), as noted on most nautical charts.

Kathleen M. Goforth, Manager, Environmental Review Office, EPA, September 20, 2010 29 EPA Project Purpose and Need:

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It is recognized that the shoreline change data set used in the present analysis is limited at best. However, this was the most recent data available for this area at the time this analysis was conducted; there was no other data available. While data intensive information resulting in conclusive findings is preferred, the best available data provided the results in this analysis. It is further recognized that the shoreline change data set results in a less than desired numerical presentation. However, the results are consistent with the overall shoreline change scenario in this region. The sediment budget indicates the shoreline is in balance, neither accretional nor erosional (+0.03 m/yr). Inclusion of recent monitoring data results in a marginally erosive shoreline (-0.10 m/yr). The very small annual change signal is masked within the much larger envelope of seasonal changes. The seasonal variations are on order of 15 m and thus are two orders of magnitude larger than the mean annual 298
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recent studies cited on DEIS p. 4-35 that appear to support the downward trend of beach width in the project location. However, according to the DEIS, it has been eight years since the last study, the most recent beach width being measured in 2002 (Table 4.3-6). Due to the time elapsed, the high variability of beach width in the past, and the appearance of conflicting information with the historical and long-term analyses, we recommend that the DElS include the results of more recent beach width monitoring in the project location. Other project purposes include protection of railroad infrastructure from wave erosion. Section 4.6.1.2 of the DEIS states that the Orange County Transportation Authority has placed "riprap along the most critical segment between North Beach and the Marine Safety Building to decrease wave erosion impacts"; however much of this segment is not within the project footprint, and the project area south of the Marine Safety Building has no protecting riprap. The DElS should address why the project area south of the Marine Safety Building has no protecting riprap. If this area is not considered part of the "critical segment", the DElS should explain the purpose and need of including the area in the project. Recommendations: The FElS should include an analysis of all existing data to clearly demonstrate a net loss of sediment deposition over the project area, and that local beach profiles show the effects of such erosion and thus are in need of replenishment. The FElS should also provide clarification of the U.S. Army Corps of Engineers' (USACE) anticipated erosion rate of 12.8 feet per year (see Section 3.4.2.5) and why this rate is higher than historical erosion rates (-2 ft/year at T-street). For additional clarity, we also recommend that the sediment budget (Table 4-9) and long-term shoreline change (Table 4.3-6) sections include long term signal. The three survey lines SC 1680 (Linda Lane), SC 1660 (T Street), and SC 1623 (State Beach) are south of Mariposa Point (Reach 7) whereas SC 1720 (Shorecliffs) is north of Mariposa Point. Mariposa Point, although physically small, is morphologically significant as it represents a salient feature in an otherwise uniform section of shoreline. This salient is a micro morphological separation between Shorecliffs and the other three survey lines. These three lines south of Mariposa Point are consistent in erosional trend whereas the Shorecliffs trend is accretional. Uncertainties in the results of this analysis are assumed captured within the design long term shoreline change distribution. The design distribution is a triangular form with a minimum (max erosion) of -0.46 m/yr, a maximum (max accretion) of +0.38 m/yr, a peak of -0.21 m/yr, resulting in a mean value of -0.10 m/yr.The Coastal Engineering Appendix has been amended to include a narrative that summarizes the sediment budget and erosion rates. This narrative discusses the larger littoral cell, the smaller project reach within, and their relationship to the measured sediment budget and erosion rates. This narrative further emphasizes the marginally negative long-term erosion rate and the implications on observed and future damages. 299
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a map and description of the sampling stations, as well as a depiction of shoreline change during each of the represented periods. 30 EPA The FEIS should include more information on the National Security issues surrounding the single track LOSSAN railroad adjacent to the project area. Page 4-65 of the DEIS states that the Department of Defense has designated this right-of-way as a Strategic Rail Corridor with great significance to National Defense. However, little information. is given regarding how or when this determination was made. We note that the Federal Railroad Administration filed a Environmental Impact Statement in 2007 (Final Program Environmental Impact Statement for LOSSAN, Los Angeles to San Diego Proposed Rail Corridor Improvements in the State of California (CEQ# 20070465)) calling for the relocation of the LOSSAN railroad away from the Shoreline with plans to run a new line adjacent to Interstate 5. Recommendation: The FEIS should include the results of consultation with the Department of Defense to ensure that all project alternatives are consistent with current National Security policy.

The FEIS is consistent with NEPA and Corps plan formulation policy. It is not the responsibility of the US Army Corps of Engineers to describe the Department of Defense designation of this right-of-way as a Strategic Rail Corridor with great significance to National Defense. It is not crucial to this project if the Federal Railroad Administration filed a Environmental Impact Statement in 2007 calling for the relocation of the LOSSAN railroad away from the Shoreline with plans to run a new line adjacent to Interstate 5. The purpose of this Project is not predicated on the protection of the LOSSAN Railroad. EPA should discuss the railroad relocation project directly with Department of Defense. Recommendation is noted. 31 EPA Alternatives Analysis: The DEIS includes a no-action alternative and two action alternatives. The two action alternatives include nourishment of the same linear project area but with different beach widths, (50 feet and 115 feet). While the proposed project (50 feet width option) would have fewer impacts from fill activity than the 115 feet alternative, both alternatives would have similar adverse environmental and recreational impacts in the The alternatives presented in the report were developed through the Corps’ plan formulation and coastal engineering processes for a storm damage reduction study. Consideration was given to all potential impacts and benefits. The 15-m plan produces the highest net benefits to the nation while causing the least potential impacts (represents the LEDPA). Thru this plan formulation process, a 10-m plan was analyzed and it resulted in fewer net benefits, but similar potential impacts as the 15-m 300
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same linear project areas. Recommendation: The FElS should include, at a minimum, an additional alternative that reduces the amount of linear project footprint. EPA suggests that an alternative excluding fill south of the Marine Safety Building may meet the needs of the project while greatly reducing adverse impacts to surfing, coral reefs, and surfgrass. The FElS alternatives analysis should include a reasonable range of practicable alternatives that meet the project purpose and demonstrate the project's compliance with the CWA Section 404(b)(1) Guidelines and selection of the Least Environmentally Damaging Practicable Alternative LEDPA. plan. The current recommended plan contains an adaptive management element in that monitoring of the equilibrated/dispersed sediment will be done to possibly modify future renourishment activities for the purpose of reducing impacts to an acceptable level. This could entail placing sediment in different locations, within the project area, or reducing the overall volume of sediment place. 32 EPA Air Quality (General Conformity): EPA is concerned that applicability of the general conformity program has not been appropriately addressed in the DEIS. The project area is in Orange County, California. This county is part of a larger area that is not meeting federal air quality standards for ozone. The DEIS states that "The area may request a higher classification" (DEIS Vol. 2 p. 12). In fact, the area was reclassified to extreme nonattainment for the 1997 ozone national ambient air quality standards (NAAQS) on June 4, 2010. For this reason, the area now has a lower applicability threshold for general conformity. The DEIS is not clear that the applicability threshold used for analysis was 25 tons per year (tpy); however, we believe this to be the case, and want to clarify that the required threshold for analysis is 10 tpy. For more information go to: http://www.epa.gov/oaqpsOOl/greenbk/gfr2rpt2.htmi.

Information related to General Conformity, including the re-designation to extreme, was added to the document. 301
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Recommendation: The FEIS should state clearly that the general conformity threshold is 10 tpy. Provide the results of the General Conformity applicability analysis to indicate whether the preferred alternative is above or below this de minimis level. If it is over de minimis, indicate the method that will be used to demonstrate that the project conforms to the applicable state implementation plan (SIP) for the area. 33 EPA Air Quality Analysis: The DEIS reports that the project will have no long-term impacts and a temporary short term adverse impact to air quality, but does not comprehensively assess the Project's operational and construction direct, indirect, or cumulative impacts to air quality. The FEIS should include a complete description of potential impacts and ways to reduce those impacts. In particular, EPA has concerns regarding the apparent lack of both an air quality impact assessment of fill placement, and a staging area plan that minimizes exposures to sensitive receptors and residents.

The FEIS/R addresses the temporary short-term impacts related to construction and does not identify any operational long-term emissions associated with the project. Impacts from fill placement were addressed and mitigations were added to ensure the staging areas will minimize exposures to sensitive receptors. 34 EPA Construction Mitigation Measures: EPA commends
USACE for incorporating mitigation strategies to reduce or minimize air pollutant, paving, and fugitive dust emissions. However, in addition to idling restrictions, proper maintenance of equipment, and the selection of construction equipment based on low emission factors, this Project should incorporate more stringent emission controls for PM and ozone precursors for constructionrelated activity. Recommendations: Due to the serious. nature of the particulate matter of 10 microns or less (PM10) and PM2.5 conditions in the South Coast Air Basin, EPA recommends that the best available control measures (BACM) for these pollutants be implemented at all times and that the FEIS and ROD incorporate the Construction Emissions Mitigation Plan. We recommend that all applicable requirements under the Additional mitigation measures were added to the
FEIS/R. Costs have been included in the projectcontingency. 302
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South Coast Air Quality Management District (SCAQMD) Rules and the following additional measures be incorporated into the Construction Emissions Mitigation Plan.Fugitive Dust Source Controls: • Stabilize open storage piles and disturbed areas by covering and/or applying water or chemical/organic dust palliative where appropriate. This applies to both inactive and active sites, during workdays, weekends, holidays, and windy conditions. • Install wind fencing, and phase grading operations, where appropriate, and operate water trucks for stabilization of surfaces under windy conditions. • When hauling material and operating nonearthmoving equipment, prevent spillage, and limit speeds to 15 miles per hour (mph). Limit speed of earthmoving equipment to 10 mph. Mobile and Stationary Source Controls: • Reduce use, trips, and unnecessary idling from heavy equipment. • Maintain and tune engines per manufacturer's specifications to perform at California Air Resources Board (CARB) and/or EPA certification, where applicable, levels and to perform at verified standards applicable to retrofit technologies. Employ periodic, unscheduled inspections to limit unnecessary idling and to ensure that construction equipment is properly maintained, tuned, and modified consistent with established specifications. CARB has a number of mobile source anti-idling requirements. See their website at: http://www.arb.ca.gov/msprog/truckidling/truck-idling.htm • Prohibit any tampering with engines and require continuing adherence to manufacturer's recommendations • If practicable, lease new, clean equipment meeting the most stringent of applicable Federal or State Standards. In general, only Tier 2 or newer engines 303
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should be employed in the construction phase. • Utilize EPA-registered particulate traps and other appropriate controls where suitable, to reduce emissions of diesel particulate matter and other pollutants at the construction site. Administrative controls: • Identify all commitments to reduce construction emissions and incorporate these reductions into the air quality analysis to reflect additional air quality improvements that would result from adopting specific air quality measures. • Identify where implementation of mitigation measures is rejected based on economic infeasibility. • Prepare an inventory of all equipment prior to construction, and identify the suitability of add-on emission controls for each piece of equipment before groundbreaking. (Suitability of control devices is based on: whether there is reduced normal availability of the construction equipment due to increased downtime and/or power output, whether there may be significant damage. caused to the construction equipment engine, or whether there may be a significant risk to nearby workers or the public.) Meet CARB diesel fuel requirement for off-road and on-highway (i.e., 15 ppm), and where appropriate use alternative fuels such as natural gas and electric. • Develop construction traffic and parking management plan that minimizes traffic interference and maintains traffic flow. • Identify sensitive receptors in the project area, such as children, elderly, and infirm, and specify the means by which you will minimize impacts to these populations. For example, locate construction equipment and staging zones away from sensitive receptors and fresh air intakes to buildings and air conditioners. 35 EPA EPA is concerned that the air quality analysis in the DElS does not include emissions associated with the multiple collection barge trips needed to remove and transport fill The DEIS/R did include the analysis of multiple trips moving fill from the borrow site to the project site. The FEIS/R did not require revision to the air quality 304
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from the project site nor does the DElS appear to include estimates of the number of necessary collection barge trips, distance traveled, and corresponding air emissions. Recommendations: The FElS should include a revised air quality analysis and updated emissions comparison to SCAQMD significance thresholds to account for the emissions from the equipment required to transport fill. The FElS should also commit to additional minimization measures for these emissions. analysis.
36 EPA Water Resources: Although a CWA Section 404 permit is not needed for the proposed action, the project must be in compliance with the CWA Section 404(b)(l) Guidelines. Also, the FElS and ROD will serve as the basis for future permits that will be needed for maintenance of beach nourishment. Under the proposed action, sand replenishment will have to be done every five or six years to restore the design beach width and those actions may need a permit. While the project will have impacts to high value marine habitats, including special aquatic sites (defined at 40 CFR 230.3(q-1)), the Section 404(b)(1) Alternatives Analysis (Appendix A) concludes that all impacts are localized and temporary, and therefore, insignificant. There is no discussion of the basis for this conclusion. As a result of the large volumes of sand being placed on receiver beaches, the proposed project could lead to significant and unavoidable adverse impacts on surface water quality and fisheries from increased turbidity and fill in special aquatic sites. Other short-and long-term threats to water quality include construction-related containments such as oil and hydraulic fluid and increased turbidity that The basis for the conclusion that impacts to water quality and high value marine habitats will be localized and transitory is discussed in Sections 5.3.2 and 5.4.2. The conclusions were based on modeling of predicted sediment transport from the placement site and observations made during previous beach nourishment projects in southern California on turbidity and impacts to high value marine habitats. A monitoring and mitigation program is proposed for high value marine habitats to confirm that high value marine habitats are not affected and that mitigation measures are implemented if they are. The potential impacts of turbidity and construction related contaminants are addressed in Section 5.3.2. Mitigation measures MM-WR-50-1.1 and MM-WR-50-1.2 are proposed to reduce those impacts to insignificant. As discussed in Section 4.4, subtidal surveys of the project area were conducted by Coastal Resources Management in March and June 2000 and by Chambers Group in March 2008 and July 2009. A survey of the shoreline in the project area was conducted by Chambers Group on May 18, 2008. 305
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would occur during the future, associated maintenance activities for the proposed project. Recommendations: The FElS should include a comprehensive biological survey of the San Clemente shoreline. The FElS should address the potential of the project to contribute to elevated turbidity levels. The USACE should consider marine design modifications regarding factors such as location and size, to minimize these environmental impacts. Additional minimization measures for impacts to the aquatic environment should be discussed in the FElS. Minimization measures include timing and rate of fill placement. The USACE should commit to placement in fall or winter to better mimic natural shoreline turbidity processes and reduce impacts during high recreational use times, and to develop debris management plans to ensure that the borrow site materials do not deposit trash, or other debris that may be harmful to the ocean environment.

As discussed in Section 3.4.2.3 and Section 5.3.2, project construction has been designed to minimize turbidity. The sand would be placed on the beach behind an L-shaped sand berm. Retention by the berm allows sediments to settle and greatly reduces turbidity. Construction would be during the fall or winter to reduce and avoid impacts to the marine environment. 37 EPA Source & Quality of Beach Nourishment Materials: The DEIS briefly considers sources of sand such as onshore and offshore borrow sites ( DEIS p. 3-3); however, it then goes on to state, "for this project offshore dredging would be required". Any opportunities for further minimizing impacts to the aquatic environment by using sand from other USACE permitted projects, or using sources from which the dredging might provide enhancement of environmental, navigational, or recreational conditions should be discussed in the FEIS. We note that the chemical testing of the sediments in the proposed Oceanside borrow pit occurred several years As stated in the Geotechnical Engineering Appendix, an adequate level of analysis for borrow site selection and testing has been conducted (per USACE guidelines). Sections 3.5.1 and 3.5.2 describe methodology for borrow site selection and suitability based on both grain size characteristics and presence of contaminants. Borrow site Area 2 was found to be compatible and contains no contaminants. Section 4.2.2 describes the Bulk Chemistry borrow testing form the same USACE'03 Investigation 306
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ago. Due to this lapse of time, additional testing may be necessary. The DEIS did not describe the initial sampling scheme (depth of cores, how many cores) nor whether the cores went down to anticipated dredging depth. Additionally, the table did not provide a chemical reference sample along a beach transect at the proposed receiving site. The DEIS provides insufficient discussion of the regulatory approval process of material for testing. A Sampling and Analysis Plan (SAP) for tiered testing, pursuant to the Inland Testing Manual should be required for each placement within the beach nourishment program. The SAP should examine the source material and the receiver site sediments and address tiered testing requirements (including grain size and the need for other testing) and be reviewed by the USACE, USEPA, Coastal Commission, and the RWQCB for concurrence prior to any sampling of the materials. All SAP's and approvals should be reviewed by the interagency dredging group run by the Los Angeles USACE s District (SC-DMMT). Recommendation: The USACE should evaluate and discuss in the FElS the opportunity to coordinate with other projects that may produce suitable material for beach nourishment purposes. The ROD should include a commitment to consideration of opportunistic sources of beach nourishment material prior to each nourishment cycle. The discussion of the chemical testing of the proposed Oceanside borrow site should be expanded in the FElS to include pertinent information such as core depth and number of samples. The FElS should also describe, and the ROD should commit, to project review through an interagency (Attachment 1 provides detailed analysis). Stephen John (EPA, personal communication) stated that since the August USACE sampling did not identify contaminants, no additional analysis is required. 307
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regulatory approval process (i.e., SC-DMMT) to ensure that the sediments are suitable for ocean placement. 38 EPA Biological Quality Surveys and Monitoring: We
acknowledge the USACE commitment to a 50 year monitoring period (over the life of the project). As discussed in the DEIS, surveys and monitoring have typically been incorporated into beach nourishment projects. The document cites the San Diego Association of Governments' (SANDAG) "monitoring data that suggest the San Clemente fill will erode on average at a rate of 12.8 feet per year (3.9 m/yr)", (p. 3-18). To counter this erosion, the DEIS states that proposed project monitoring would be required to assess replenishment schedules. However, the document does not sufficiently discuss a biological monitoring plan. This information should be included in order to evaluate the effectiveness of the proposed action in protecting biological diversity/quality. The monitoring plan should include pre-and post-project dive surveys and benthic community sampling of the borrow site and the receiver site to ensure that each benthic community returns to its pre-project density and structure. We stress that any monitoring should have appropriate adaptive management to ensure minimal impacts to aquatic resources. The Coastal Sediment Management Workgroup is currently preparing a document outlining practices to minimize impacts to aquatic resources. The adaptive management process should allow for incorporation of these practices and associated principles and any other developments in regional sediment management over the life of the project. Recommendation: The FEIS should include a detailed description of a A biological monitoring plan is included as Mitigation Measure MM-BR-50-2.2. The biological monitoring plan is described in detail in Appendix B. 308
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survey/monitoring program for the biological impacts of the Proposed Project, and commit to its incorporation as a required project element. The monitoring program should have a clear adaptive management strategy to ensure that the aquatic environment is protected. 39 EPA Endangered Species:

The DEIS insufficiently evaluates the potential impacts to endangered species. For example, the document states, "No proposed or endangered species are expected to be present on the site" (DEIS p.A-lO). The basis for this statement is unclear due to the lack of a complete shoreline biological survey. Recommendation: The FEIS should include a comprehensive biological survey of the entire project area as well as the borrow site, including a complete review of species that may be affected by the project. The results of consultation with the United States Fish and Wildlife Service and National Oceanic and Atmospheric Administration (NOAA), if appropriate, regarding threatened or endangered species or critical habitat should be included in the FEIS. Beach nourishment activities should avoid the nesting seasons for listed species, such as the least tern.

As clearly stated and outlined in the FWS and NMFS Endangered Species Consultation Handbook: Procedures for Conducting Consultations and Conferences Activities under Section 7 of the Endangered Species Act (USFWS/NMFS 1998), the action agency (i.e., the Corps) makes the effects determination of the action on federal listed taxa. The ESA guidelines state that the “best scientific data available” be used in an analysis. Based on the concept of “available data,” new data is not required to be collected and comprehensive biological surveys do not need to be performed, where these activities would be cost prohibitive and unreasonable. For this project, these activities would yield no new substantial information that is not already known. The project action is avoiding all listed taxa, as stated. 40 EPA Cumulative Impacts:

Given that the Project will take place over the next 50 years, the FEIS should include a comprehensive list of other projects in the area that are under construction or planned within that time frame, such as ecosystem restoration opportunities at San Elijo Lagoon, and related cumulative impacts. The DEIS states, "most of the sediment from the project is expected to accumulate on down coast beaches" (p.6-4). The feasibility of periodically replenishing beaches should be analyzed and incorporated in plans for future growth. An analysis of how future projects, in conjunction with the proposed Project, In the project area, net littoral transport is southward. It is expected that the fill material will have the most influence immediately adjacent the fill area in the San Clemente State Beach area. The fill material will tend to slowly redistribute across the profile as it drifts southward. San Elijo Lagoon is approximately 36 miles south of the fill area. The fill quantity being relatively small is expected to have no down drift impacts to San Elijo Lagoon. Project monitoring will include transect lines outside of the fill area both north and south to monitor fill movement. 309
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may cumulatively impact the health of the affected resources should be addressed in this section. Recommendation: The FEIS should include a comprehensive discussion of all types of reasonably foreseeable projects that may take place in the area during the construction period, such as the LOSSAN Proposed Rail Corridor Improvements, the San Elijo Lagoon restoration, and others, and predict the cumulative impacts on affected resources. 41 EPA Climate Change: Current research estimates that climate change could cause sea level rise and change the amount, timing, and intensity of rain and storm events. The Pacific Institute has created maps estimating flood risk due to sea level rise in the San Clemente Shoreline area; to see the map go to: http://www.pacinst.org/reports/sealevelrise/hazmaps/San Clemente.pdfRecommendation: The FEIS should describe and evaluate projected climate change consequences such as sea level rise, frequency of high intensity storms, and amplified rain events; their effects on the beaches; and how these effects could change re-nourishment plans for the San Clemente Shoreline Protection Project.

Sea level change is quantitatively addressed in accordance with current USACE guidance and is included in the Coastal Engineering Appendix. Sea level change analysis includes scenarios for three rates of sea level change: existing, medium, and high. The risk and uncertainty model incorporates sea level change and the model sensitivity is discussed in the main report. The recommended plan is expected is perform functionally under all 3 predicted sea level rise scenarios as explained in the report. This study assumes stationarity relative to high intensity storms and amplified rain events. In other words, this study assumes that future high intensity storms and amplified rain events will be similar in magnitude to past high intensity storms and amplified rain events. There is no USACE guidance for escalating the magnitude of future storm and/or rain events due to climate change. The risk and uncertainty model used in this analysis incorporates extreme storm events. The risk and uncertainty model randomly selects storm events based on their probability. Extreme storm events will be selected (albeit infrequently) and their impacts incorporated into the results. 42 EPA Executive Order 11988: Floodplain Mgmnt:

Per Flood Insurance Rate Maps (FIRM), portions of the
The recommended plan is located within FIRM#: 06059C0536Jand is within a VE zone with BFE 13. 310
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project footprint may be in a Zone VE Coastal Flood Zone with velocity hazard with a established base flood elevation (BFE). See FIRM#: 06059C0536J Orange Co Uninc & Inc Areas 12/03/2009. Executive Order 11988 Floodplain Management requires federal agencies to avoid, to the extent possible, the long and short-term adverse impacts associated with the occupancy and modification of floodplains. For more information go to:http://www.fema.gov/plan/prevent/floodplain/nfipkeywords/zone_ve.shtm.Recommendation: The FEIS should discuss any impacts that the Proposed Project may have on the potential for flooding.

High velocity impacts including direct structure damages and flooding were quantitatively addressed within the risk and uncertainty model. The damage categories are fully described in the Coastal Engineering Appendix and the economic summary is fully described in the Economics Appendix. The recommended plan is designed to alleviate high velocity damages and will not induce additional flood damages. The recommended plan is not expected to encourage additional occupancy and/or development within the project footprint.

Robert S. Hoffman, Assistant Regional Administrator for Habitat Conservation, NOAA Fisheries, September 20,2010 43 NMFS NEPA (Affected Area): The DEIS should elaborate on the quantity of habitat affected by the proposed action. For example, the acreage of benthic habitat affected by dredging operations should be provided, Similarly, the estimated area affected by sediment placement should be provided, This estimate should account for both direct impacts associated with sediment placement and indirect impacts associated with the equilibrium footprint. In addition, the estimated rates and depth of burial within the equilibrium footprint should be provided.

The borrow area footprint is approximately 535,396 sq m (132.2 acre). The immediate fill construction footprint is approximately 102,271 sq m (25.3 acre). At equilibrium, the fill footprint for the 15 m alternative is approximately 534,401 sq m (132.0 acre). 44 NMFS NEPA (Submerged Reef Alternative): The objectives of the proposed project are to 1) reduce storm-related damages to public and private properties and 2) enhance and maintain beach recreation and associated economic tourism benefits. The DEIS also identified a number of planning constraints that inform the evaluation criteria for the various alternatives. These constraints are 1) preserve the nearshore ecosystem that supports commercial lobster and fishing industries and snorkeling activities; 2) preserve the opportunities for surfing; 3) preserve critical habitat that supports listed species; 4) preserve water quality characteristics; 5) preserve cultural and historical In order to be effective, a submerged reef alternative typically needs to be in relatively shallow water. Submerged reefs constructed worldwide are typically in water depths less than 6 m (20 ft). The Oil Piers project placed the submerged reef at 200 m (600 ft) offshore. At San Clemente, this depth (and distance offshore) would place an artificial reef directly on top of the natural reefs existing in the project area, including T-Street reef, thereby increasing ecosystem impacts. A properly designed submerged reef would reduce 311
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features; and 6) preserve air quality conditions. The DEIS then incorporated the objectives and constraints of the project into the following evaluation criteria: addresses purpose and need, technical feasibility, economic feasibility, environmental impacts, and public acceptability. Of the alternatives identified, NMFS believes additional analysis of the submerged reef alternative is warranted. Moreover, additional justification should be provided for the comparisons and conclusions made for the varying alternatives, as summarized in Table 3-1. NMFS is aware of initial planning efforts in Ventura County (i.e. Oil Piers) and northern San Diego County (i.e. Fletcher Cove) to evaluate the application of submerged reefs for beach protection and other benefits. The initial documents prepared for these projects support the potential feasibility of this approach. Moreover, submerged reefs provide additional habitat benefits and, if designed properly, may improve surfing conditions. According to a report developed for the Corps planning process for the Oil Piers Ventura County project, studies of benefits associated with the construction of multipurpose reefs at various locations around the world have all shown significant benefit/cost ratios. The lowest was approximately 20: 1 for a small reef in Bournemouth, UK, to over 60: I for the Narrowneck reef on the Gold Coast, Australia. A recent report for a multipurpose reef in Wellington, New Zealand, estimated a conservative benefit to cost ratio of 24:1. Although NMFS does not believe submerged reefs are a panacea for erosion control, they may impede erosion at local scales. They minimize many negative aspects of other erosion control methods and have the potential to benefit ecosystems, tourists and local communities. Thus, NMFS believes this alternative warrants further discussion and evaluation in the DEIS. wave energy in the lee of the structure with possibly ancillary benefits to recreation. Wave energy reduction in the structure lee would aid retainage of sand on the beach; however, this reduction would not eliminate the need for sand placement and/or nourishment. A beach fill would still be required. A beach fill of approximately 11,000 cu m along approximately 340 m of beach was proposed for the Oil Piers Submerged Reef Project. Based on a comparison of the beach fill to beach length, as well as the requirement to place an artificial reef on top of existing natural reefs, a submerged reef alternative would have greater impacts to the project environment than the proposed action. 312
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45 NMFS NEPA (Analysis):

Balancing Ecosystem Services The proposed project involves some inherent trade-offs. Protection of existing infrastructure and maintaining recreational opportunities associated with beach usage are obvious ecosystem services that may be provided by this project. However, repeated beach till projects may have an environmental cost to various natural resources (e.g. surfgrass, rocky reefs, intertidal and shallow subtidal invertebrate assemblages, fishery resources). These costs need to be incorporated into the analysis to ensure the benefit to cost ratio is not skewed. Prior to the commitment of federal resources, a clear evaluation should be provided that examines the expected costs over the long-term. Without such an analysis, it would be difficult to accurately predict whether the proposed project would be in the public's best interest.

According to USACE guidelines, the economic evaluation of all proposed alternatives need to account for all the positive and negative impacts related the implementation of the project. Therefore, the economic analysis included the benefits of reducing damages to the infrastructure and increasing recreational opportunities in the project area due to the implementation of the recommended project. In addition, the economic analysis should include any mitigation costs that would account for any negative impact due to implementation of the recommended project. The mitigation costs will include all the activities that will be needed to resolve any expected negative impacts due to the implementation of the Project. Currently, the environmental evaluation of the recommended project has identified not any specific environmental impacts due to project but has recommended that costs for monitoring should be accounted for in the overall costs for the project. Therefore, the benefit/cost ratio for the recommended plan includes the extra costs for monitoring of possible negative impacts due to the implementation of the project. 46 NMFS NEPA (Analysis):

Adequacy of Monitoring Studies Peterson and Bishop (2005) reviewed 46 beach monitoring studies and showed that 1) only 11 percent of the studies controlled for both natural spatial and temporal variation in their analyses; 2) 56 percent reached conclusions that were not adequately supported; and 3) 49 percent failed to meet publication standards for citation and synthesis of related work. They opined that regulatory and resource agency practices are in urgent need of reform as the risk of cumulative impacts grows in the face of sea level rise, climate change, and increased coastal development. NMFS notes that, with the exception of one project from the 1970s, all the studies that were reviewed The southern California studies cited in the document used fixed transects. Therefore, if a change on a transect is observed, the biologists can be confident that a change actually occurred and is not the result of spatial variation. What is much more difficult is to determine the cause of a change because numerous natural events affect marine communities. No southern California studies have detected major degradation of marine resources following a beach nourishment project. Therefore, the weight of the evidence does not suggest that such degradation will occur from the San Clemente project. In addition, the Corps considered sea level rise as provided in the guidance in Engineer Circular “Water 313
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were on the Atlantic or Gulf coastlines. Thus, their results may not be directly applicable to projects implemented in Southern California. However, NMFS shares the concerns expressed by the authors that the presumption that nourishment projects are ecologically benign may be based upon an incomplete and flawed body of science. If previous monitoring results in Southern California are to be used as support for conclusions that impacts to biological resources are minor and/or insignificant, NMFS believes a more rigorous examination of their sampling design, statistical analyses, and conclusions are necessary.

Resource Policies and Authorities Incorporating Sealevel Change Considerations in Civil Works Programs” (2009). The circular identifies that sensitivity of alternative plans and designs to the rates of future local mean sea level change should be determined. Design or operations and maintenance measures should be identified to minimize adverse consequences while maximizing beneficial effects. For each alternative sensitive to sea level change, potential timing and cost consequences should be evaluated during the plan formulation process. 47 NMFS NEPA (Analysis):

Cumulative Impact Analysis: The cumulative impact analysis does not include the opportunistic program that has recently been permitted by Corps Regulatory Division (SPL-2004-00838-JPL). This is a 5-year opportunistic beach nourishment program to place a maximum of 300,000 cubic yards of sediment per year on four different sites within the coastal zone of the City of San Clemente. This project would use opportunistic fill sources and cover a maximum of 29 acres of tidal habitat. The disposal sites include one at North Beach, one at Linda Lane, and two at T-Street. In addition, a stockpile site is proposed near the intersection of Avenido Pico and El Camino Road. Given the spatial overlap and proximity, NMFS believes this program should be evaluated within the cumulative impact analysis. In addition, the DEIS should evaluate how climate change may affect the frequency of nourishment events. Sea level rise, increased frequency and severity of storms, and increased wave height are expected climate change impacts that may exacerbate existing beach erosion rates and may increase the frequency of nourishment events. These may all affect the fate of sediment placed for beach The opportunistic program is not included in the cumulative impacts analysis because if the project proposed in this EIS/EIR occurs, the opportunistic program would not place sand on project area beaches. There will not be two beach nourishment projects occurring concurrently within this project area. The Corps considered sea level rise as provided in the guidance in Engineer Circular “Water Resource Policies and Authorities Incorporating Sea-level Change Considerations in Civil Works Programs” (2009). Historic trends at San Diego, California indicate a positive sea level rise of +2.45 mm/yr based on water level measurements during the period 1950-1999. If past trends are projected into the future at San Diego, a sea level rise of 0.12 m (0.4 ft) would be expected during the 50 year period of economic analysis. The NRC Curve III estimates sea level rise, during the 50 year economic period of analysis, to be 0.70 m (2.3 ft). Relative sea level rise has project impacts from two primary considerations: 1) long-term beach erosion, and 2) increased wave run-up and overtopping. The effects of sea level rise are addressed in Appendix D of the EIS/EIR. 314
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nourishment purposes and subsequent movements into the nearshore environment and should, thus, be considered in the cumulative impact analysis.

The Recommended (NED) Plan is formulated on the basis of continuous monitoring of beach fill erosion and renourishment. This monitoring would be expected to identify any rapid change in sea level through an unanticipated change in renourishment requirements. Although sea level change should be identified through the frequency of renourishment, the Recommended (NED) Plan still requires an assessment of how sensitive its performance is to sea level change. To examine the NED Plan under sea level change a sensitivity analysis was performed , based on the NRC Curve III, assuming a maximum sea-level rise of 0.70 meters over 50-years, as a point of reference the base case assumes a sea-level rise of 0.12 meters. This sea level change was incorporated into the model along with an adjustment to the construction cost of the seawall and simulated over the array of alternatives. Based on the model optimization and analysis of the costs and benefits the 50 ft beach width alternative has the greatest economic benefits and is the NED Plan for both the base sea level case and the max sea level case. If max sea level rise did occur during the 50 year life of the project then the NED plan could be adjusted to meet the max sea level rise case. For a project such as a beach nourishment project for which the beach is typically re-nourished every 5-10 years, the local mean sea level will be reevaluated every 5-10 years (in this case every 6 years), prior to renourishment, and accommodation for sea-level rise can be made during each renourishment period. The effects of the maximum sea-level rise case on the NED Plan are relatively minor. The number of fills over the project life increase from 9.11 to 9.66 with maximum sea-level rise. 48 NMFS NEPA (Analysis):

Environmental Commitments:

Section 7 of the DEIS/DEIR has been amended to include environmental commitments for biological 315
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Section 7 of the DEIS identifies a variety of environmental commitments for the proposed action. However, no commitments are provided to address biological resources. NMFS recommends that this section be amended to include mitigation measures for biological resources. resources.
49 NMFS Endangered Species Act:

Section 7 of the Endangered Species Act (ESA; see 16 U.S.C. § 1536(a)(2» requires federal agencies to consult with the Secretary of Commerce and/or the Secretary of the Interior to insure that "any action authorized, funded, or carried out by such agency ... is not likely to jeopardize the continued existence of any endangered species or threatened species .... " See also 50 C.F.R. part 400.

In Section 4 of the Joint DEIS/DEIR, the following ESAlisted species were described as having the potential to occur in the nearshore waters off San Clemente and Oceanside, CA: Guadalupe fur seal (Arctocephalus townsendi), blue whale (Balaenoptera musculus), fin whale (B. physalus), humpback whale (Megaptera
novaeangliae), Steller sea lion (Eumetopias jubatus), northern right whale (Eubalaena glacialis), sei whale (B. borealis), sperm whale (Physeter macrocephalus), loggerhead sea turtle (Caretta caretta), green sea turtle (Chelonia mydas), Pacific olive ridley sea turtle (Lepidochelys olivacea), leatherback sea turtle (Dermochelys coriacea), and white abalone (Haliotis sorenseni). Black abalone (Haliotis cracherodii) was listed as endangered under the ESA on January 14,2009 (74 FR 1937) and should also be included as having the potential to occur in the project area. If the Corps determines that their proposed project may affect any ESA-listed species under NMFS' jurisdiction, including whales, seals, sea lions, abalone and sea As part of the responsibilities under the ESA Section 7 consultation process, the Corps has made a no effect determination of the project implementation on the listed marine mammals discussed in Section 4. The discussion of no effect on these marine mammals is detailed in Section 5. Currently, black abalone does not occur within the project area. The proposed rule for listing critical habitat for the black abalone indicates that nearest locale is the Palos Verdes Peninsula to Los Angeles Harbor region. They currently do not occur on the rocky reef within the project area and the potential to occur remains negligible. 316
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turtles, the Corps should request concurrence from NMFS. 50 NMFS Marine Mammal Protection Act:

Whales, dolphins, porpoises, seals, and sea lions are protected under the MMP A. See 16 U .S.C. § 1361 et seq. Under the MMP A, it is generally illegal to "take" a marine mammal without prior authorization from NMFS. "Take" is defined as harassing, hunting, capturing, or killing, or attempting to harass, hunt, capture, or kill any marine mammal. Except with respect to military readiness activities and certain scientific research conducted by, or on behalf of, the Federal Government, "harassment" is defined as any act of pursuit, torment, or annoyance which has the potential to injure a marine mammal in the wild, or has the potential to disturb a marine mammal in the wild by causing disruption of behavioral patterns, including, but not limited to, migration, breathing, nursing, breeding, feeding, or sheltering. Harassment of marine mammals may occur if hauled animals flush the haul out site and/or move out of the immediate aquatic area to increase their distance from dredging related activities, such as noise associated with the dredging, presence of workers, or unfamiliar activity in proximity to a haul out site. The measured sound exposure levels of a clamshell dredge may range between 75-88 dBA (re 20 iJPa) at 50 feet. Animals have been observed flushing from haul out sites at a sound exposure level of less than 100 dBA, and it is possible that marine mammals may modify their behavior as a result of the noise produced by the dredging operations. NMFS recommends including detailed information on the expected impacts that dredging will or will not have on marine mammals. The DEIS/EIR indicated that it is expected that marine mammals in the vicinity of the project area, specifically The dredge area is not in the vicinity of any marine mammal haul out sites. Although marine mammals possibly could be present in the dredging area, the site has not been identified as one of importance to any marine mammal species. The area is offshore Camp Pendleton and Oceanside Harbor where large vessels capable of disturbing marine mammals come and go on a regular basis. Disturbance to marine mammals from the dredging would be minimal. The surf zone where turbidity from sand placement would temporarily occur is often naturally turbid and beach placement activities would occur during late fall and winter when turbidity is most likely to occur. Turbidity, natural or man-made, is assumed to impact marine mammals; however, because of the time of year when the project would occur, and the temporary nature of the impact, effects on marine mammals would be minimal. An Incidental Harassment Authorization under the Marine Mammal Protection Act has not been required for similar beach nourishment projects. 317
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gray whales (Eschrichtius robustus), would be expected to avoid the immediate vicinity of the dredging area, and that the turbidity plumes from the project would have an adverse impact on bottlenose dolphins (Tursiops truncatus). Please note the definition of a "take" under the MMP A and that the rapid exit from the project area could be considered harassment under the MMP A. In addition, avoidance is not considered a mitigation measure to reduce impacts to marine mammals should the action cause harassment and animals avoid the project area. Please provide more detail as to why the turbidity plumes would have an adverse impact on bottlenose dolphins. Based on the information provided in the DEIS/EIR regarding the potential take of marine mammals, it may be necessary to receive authorization from NMFS under the MMP A for this proposed project. 51 NMFS Magnuson-Stevens Fishery Conservation and
Management Act (Action Area): The proposed project occurs within EFH for various federally managed fish species within Coastal Pelagic Species, Pacific Groundfish Species, and Highly Migratory Species Fishery Management Plans (FMPs). In addition, the project occurs within areas designated as habitat areas of particular concern (HAPC) for various federally managed fish species within the Pacific Groundfish FMP. HAPC are described in the regulations as subsets of EFH which are rare, particularly susceptible to human-induced degradation, especially ecologically important, or located in an environmentally stressed area. Designated HAPC are not afforded any additional regulatory protection under MSA; however, federal projects with potential adverse impacts to HAPC will be more carefully scrutinized during the consultation process. As defined in the Pacific Groundfish FMP, San Clemente contains the following types of HAPC: surf grass, rocky reef and canopy kelp.

The FEIS/R uses the best scientific data available for inclusion into the analysis. The Corps’ marine ecology contractor conducted several dives along 25 transects, as noted in the FEIS/R. These field data were more than reconnaissance level field investigations. The data clearly and unequivocally captures the distribution extent of rocky reef, single boulders, and the extent of surfgrass distribution. The larger rocky reef was delineated by divers floating buoys to the surface demarcating the approximate edge of the reef and a biologist in a kayak at the surface recording GPS points of the surfaced buoys. There are 12 GPS points that delineated the approximate area of the T-Street Rocky Reef. Rocky intertidal habitat is addressed in Section 5.4.2. Because sand transport is expected to be primarily to the south, significant rocky intertidal upcoast of the project area is not expected to be impacted by sand placement. The extensive reef and kelp offshore San Clemente pier was mapped and is shown in Figure 318
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Figure 4.4-2 depicts the observed surf grass in relationship to the dive transects, expected impact area (i.e. equilibrium footprint), and kelp habitat. Scattered surfgrass amongst boulders have been observed in the northern portion of the Linda Lane impact area. More extensive rocky reef and surf grass habitat occur in the southern portion of the impact area at T -street. The survey information provided does not delineate areal extent of rocky reef and surfgrass within the impact area. Appendix B estimated the T –street reef to be 5 acres. No quantification of area and/or coverage was provided for the scattered boulders and surfgrass habitat. Rocky intertidal and more expansive subtidal rocky reef and associated kelp habitat exists in areas immediately adjacent to the expected impact area.

4.4-2. The scattered boulder and surfgrass habitat occurs throughout the shallow water area offshore the sand placement site. This area was characterized by several subtidal transects. The area is mostly sand with scattered boulders throughout the area at relatively low density. The entire area appears to be bedrock covered by a shallow sand layer that shifts. The lack of encrusting biota on many of the boulder suggests that rocks are covered and uncovered periodically. There currently is no available data that depicts or illustrates the rocky reef or surf grass of the entire locale. NMFS recommended using the San Diego Nearshore Program data from the UC San Diego website. The use of the website with these data was not recommended until 31 Janaury 2011, after two years of coordinating with NMFS. In a comparison of the data from the Nearshore Program (http://nearshore.ucsd.edu) to data collected from project surveys, the Nearshore Program data justifies and compliments the Corps mapping distribution of the rocky reef and single boulders. The attached noted illustrations (RTC Exhibit A) show the Corps surfgrass survey results along with the outer T- Street reef in comparison to the Nearshore Program data from the UC San Diego website. The large kelp bed mapped by the Corps Figure 4.4-2 in the FEIS/R is, in fact, more detailed and in the same geographic distribution alignment as the UCSD Nearshore program raster data. Furthermore, the Corps data is much more detailed in is distribution from the shoreline 500 feet off-shore, whereas the UCSD Nearshore data has little, if any, data within the area that is 500 feet from shore. The Corps acknowledges that there are scattered 319
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rocks within and outside the equilibrium footprint and the total acreages of those scattered rocks are not expected to change the data analysis. Nevertheless, the Corps may, during the PED phase, utilize the Corps ERDC Submerged Aquatic Vegetation Early Warning System, which is a semi-automated acousticbased measurement system that can detect and characterize submersed aquatic vegetation (SAV) while operating from a small survey boat. It uses an off-the-shelf digital echo sounder, with a narrow single-beam high-frequency transducer, and global positioning system (GPS) equipment to digitally record echo intensity and position data on a laptop. Software developed at the U.S. Army Engineer Research and Development Center (ERDC-EL) processes the distinct signature of SAV within the recorded signal to determine depth, plant height, and plant coverage every few meters along transect lines. 52 NMFS Magnuson-Stevens Fishery Conservation and
Management Act (Effects of the Action): Based on information provided in the EFH assessment and developed during consultation, NMFS concludes that proposed action would adversely affect EFH for various federally managed species within Coastal Pelagics Species, Highly Migratory Species, and Pacific Groundfish FMPs. Dredging will disturb benthic organisms within the project footprint via direct removal or indirect mortality from an associated turbidity plume. Sediment from the beach fill project will be redistributed by wave and tidal energy onto nearshore areas, which may bury rocky reef habitat, surfgrass habitat, and benthic organisms that serve as prey for a variety of fishery species. In addition, turbidity generated from the beach fill will adversely affect the light regime in the immediate nearshore area, which may reduce the quality and/or quantity of surfgrass and kelp habitat.

During the two year coordination meeting efforts, the Corps consulted with the NMFS on the EFH as required. The NMFS was part of the EFH process and did not express the concerns identified in this comment and subsequent comments regarding “Effects of the Action” during the EFH coordination two year timeframe. The Corps analyzed all alternatives (35 meter to 5 meter in 5 meter increments). The 15 meter alternative was the environmentally least impacting while maintaining the benefit/cost ratio required by the Corps policy. The borrow site is immediately off-shore from the Oceanside Harbor, an area of maximum disturbance by vessel traffic, including MCBCP Landing Craft, Air Cushion (LCAC) Transport. The Del Mar - Boat Basin, as well as Oceanside Harbor, has undergone harbor dredging for many decades and the fish populations in the nearshore environment persist. The dredging operations proposed in this project action 320
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are similar to, and not greater than, on-going dredging activities at the Oceanside Harbor Dredging borrow site. A revised monitoring, mitigation, and reporting plan has undergone several iterations reviews, several by the resources agencies and by the Crops SPD, HQ, and ERDC. 53 NMFS Surf grass habitat is likely to be impacted by beach nourishment and shoreline protection projects that place sand either directly or indirectly onto surf grass beds (Craig et al 2008). As described in the 404(b )(1) Guidelines, the discharge of dredged or fill material may reduce the value of vegetated shallows as nesting, spawning, nursery, cover, and forage areas, as well as their value in protecting shorelines from erosion and wave actions. In addition, the primary productivity of the system would be reduced if impacts were to occur. Surfgrasses exhibit late successional traits, recover very slowly from disturbance, require facilitation from algae before settling, and are strong competitors (Turner 1985). Removal of surfgrass from a rocky reef community has profound impacts to community structure (Turner 1985). Thus, surfgrass habitat is largely determined by patterns of disturbance. Repeated beach nourishment efforts likely will increase this rate of disturbance to these systems. Slow recovery times suggest that disturbances to these communities may be ecologically significant. The DEIS acknowledges that some burial will occur and that the inshore areas of the impact area will be most affected by burial. However, the DEIS asserts that the proposed action will not result in a long-term net loss in habitat value of surfgrass. In addition, it states that the proposed project will have no significant adverse effects on special aquatic sites. NMFS does not believe these conclusions are adequately supported by the analysis.

There is little surfgrass in the scattered rock and sand area. The surfgrass is confined to occurrence on some of the boulders within this area. The exposed rocks are themselves not dense and difficult to quantify. The only actual surfgrass bed within the project area is that which was mapped on T-street Reef. The potential for impacts to this reef was discussed in Section 5.4. The DEIS/R acknowledged that there may be some impacts to surfgrass habitat, particularly in the shallower portions of the reef. The mitigation, monitoring and reporting plan in the FEIS/R provides for the monitoring of surfgrass habitat and mitigation if persistent impacts are documented. 321
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Previous predictions of burial associated with placement of 175,000 cubic yards were described in the DEIS that indicated an estimated maximum 1 foot burial of surfgrass for less than six months. Short term burial at depths of 0.8 feet exhibited a statistically significant decline in shoot count within a laboratory setting (Craig et aI, 2008). Furthermore, the DEIS indicates that some portions of surf grass habitat within the equilibrium footprint already exhibit some burial. Thus, the additive impact associated with this beach fill project may exacerbate existing conditions for surf grass habitat. Based upon the above and that the proposed project involves approximately 40% more sediment than previous predictions, NMFS believes the proposed project would reduce the quality of surfgrass habitat in the project vicinity. Given the uncertainties associated with modeling, there is also a real potential for reductions in the quantity of surf grass habitat. Galst and Anderson (2008) have suggested that surf grass is important for nearshore fish communities and reductions in surf grass could negatively affect recruitment patterns. Specifically, experimental reductions in coverage of seagrass (ranging from 7 to 180 square meters) resulted in significant decreases in the density of newly recruited fish species. Similarly, NMFS expects reductions in coverage and/or density may reduce other ecological services provided by surfgrass, such as primary productivity, substrate for epibiota, and wave energy dissipation. 54 NMFS To date, NMFS is unaware of any comprehensive survey to delineate surfgrass and rocky reef in the project area. According to Appendix B of the DEIS, which describes a biological resources monitoring program, the general area of the T -street reef is approximately 5 acres. Appendix B further states that potential burial of the inshore edge of T - Street is uncertain, but, if it were to occur, it would be expected to occur in the approximately 20 percent inshore edge of the T -street reef area. Scattered patches of rocky There is little surfgrass in the scattered rock and sand area. The surfgrass is confined to occurrence on some of the boulders within this area. The exposed rocks are themselves not dense and difficult to quantify. The only actual surfgrass bed within the project area is that which was mapped on T-street Reef. The potential for impacts to this reef was discussed in Section 5.4. The mitigation, monitoring and reporting plan in the FEIS/R will document the 322
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reef and surfgrass may also exist in other areas of the footprint, but no estimates are given to quantify the extent of the impact. Given the lack of detailed habitat characterization and uncertainty associated with burial predictions, it is difficult to estimate the quantity of surfgrass habitat that may be affected. Hard-bottom habitats, such as rocky reefs, are present within and adjacent to the project area. These hardbottom habitats provide substrate for a diversity of algae and invertebrate species, which are utilized by a number of different fish species. Many organisms adapted to rocky reef habitats are highly susceptible to burial and/or sediment scour. Thus, burial and/or increased scour maydiminish the ecological functions provided by rocky reefs. Some increased level of burial and/or scour is expected to occur to rocky reef areas within the equilibrium footprint. However, the DEIS suggests that the proposed action will have only minor transitory effects, but acknowledges that unforeseen impacts may occur and that resource monitoring is appropriate. Significant burial is not expected in the rocky intertidal areas near Mariposa Point or the more extensive subtidal rocky reefs and kelp habitat found near Mariposa Point and immediately offshore (approximately 1,000 to 1,300 feet from the beach) of the estimated impact area. amount of surfgrass habitat impacted by the project and would provide for mitigation if impacts persist. 55 NMFS The proposed project will increase turbidity within the project area due to dredging and beach fill operations. Based upon monitoring conducted at another dredging operation in Oceanside, the estimated average down coast distance of the turbidity plume was between 272 and 329 feet. Turbidity monitoring of a hopper dredge operation for a regional beach sand project indicated that plumes did not exceed 2,700 square yards (0.56 acres). Construction monitoring during a regional beach sand project indicated that turbidity plumes ranged between 2,640 and 10,000 feet and were largely confined to the surf zone. Beach nourishments create turbidity plumes, an Impacts from dredging were addressed in Impact BR50-4. The DEIS/R stated that “[r]ecovery of the benthic invertebrate community would be expected to begin almost immediately with settlement of larvae and immigration of mobile species from nearby unaffected areas. Recovery of the infaunal community to values comparable to pre-dredging levels may occur in as little time as six months or as long as two years, with an average of about one year (CSLC, USFWS, and USACE 2001). The impact of dredging on invertebrates is not significant because the affected area would be small and the biota would 323
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area of water with a high concentration of suspended sediments that can last for days and cover habitats adjacent to the project site. Turbidity decreases light penetration and therefore has adverse effects on seagrass and canopy kelp habitats. These plants form the basis of highly productive systems and any losses would adversely affect nearshore EFH. In addition, turbidity plumes may alter fish behavior. Many fishes wi1llikely disperse away from the turbidity plume as fine particulates can clog gill rakers and decreased visibility can make foraging more difficult. Sessile, filter feeding invertebrates may experience mortality, as suspended sediments can clog feeding apparatus. recover quickly. There would not be a discernible impact on the population of any species.” 56 NMFS Impacts to rocky reef, surfgrass, and/or kelp habitat may also occur if anchor moorings and/or the slurry pipeline were placed on these sensitive habitats. The DEIS indicates that placement of moorings and pipelines shall avoid these sensitive habitats. However, a more detailed and comprehensive habitat survey should be conducted to properly delineate the areas to avoid.

As discussed in Section 5.4, prior to the placement of the pipeline that will pump the sand to shore from the hopper dredge, a detailed survey will be done of the area proposed for the pipeline and a route will be identified that minimizes impacts to rocks and surfgrass. 57 NMFS California grunion (Leuresthes tenuis) spawn on sandy beach habitats throughout the Southern California Bight every year from March to August. On full and new moons, eggs are deposited in the sand above the high tide line shortly after spring high tides. Two weeks later, corresponding with spring high tides, larval grunion hatch from eggs and return to the water. Beach nourishment can cause mortality by burying developing eggs. Heavy machinery and other disturbances during construction could also kill developing or juvenile grunion. However, the proposed project would not impact grunion spawning because it has committed to occur outside the grunion spawning season of March to August.

Comment noted.
58 NMFS EFH Conservation Recommendations:

As described in the above effects analysis, NMFS has determined that the proposed action would adversely The monitoring and mitigation plan in Appendix B has been revised to include mitigation for loss of surfgrass and reef habitat. If surfgrass mitigation fails, a contingency plan has been developed to plant kelp on 324
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affect EFH for various federally managed fish species within the Coastal Pelagics, Highly Migratory Species, and Pacific Groundfish FMPs. Therefore, pursuant to section 305(b)(4)(A) of the MSA, NMFS offers the following EFH conservation recommendations to avoid, minimize, mitigate, or otherwise offset the adverse effects to EFH. 1) Given the high ecological values associated with
surfgrass and rocky reef habitat, NMFS believes unavoidable reductions in quantity and/or quality of these habitats should be addressed via compensatory mitigation. The Corps and project sponsor should develop a contingency mitigation plan in consultation with NMFS and other interested agencies prior to the record of decision for the proposed project.

The contingency mitigation plan should be based upon a reasonable estimate of potential impacts to rocky reef and surfgrass habitat. This estimate should be developed and agreed upon by Corps, NMFS, and other interested agencies prior to the record of decision for the proposed project. This estimate may then be used as the basis for determining the approximate cost of implementing a mitigation project and should be incorporated into the benefit to cost ratio of the proposed project. In addition, the estimated cost can serve as the basis for providing financial assurances that will ensure a high level of confidence that the compensatory mitigation project will be completed if impacts are observed. c. The Corps and/or the project partner should
include in-kind surfgrass restoration, establishment, and/or enhancement as part of the mitigation plan.

According to the 2008 mitigation rule, compensatory mitigation is defined as the restoration (re-establishment an offshore reef.
325
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or rehabilitation), establishment (creation), enhancement, and/or in certain circumstances preservation of aquatic resources for the purposes of offsetting unavoidable adverse impacts which remain after all appropriate and practicable avoidance and minimization has been achieved. The rule suggests that compensation for unavoidable impacts to difficult to replace (DTR) resources (e.g. bogs, fens, springs, streams, etc.) should be provided through in-kind rehabilitation, enhancement or preservation. Given the slow recovery time and the difficulties associated with restoring this habitat, NMFS believes that surfgrass should be considered a DTR resource. Therefore, NMFS believes the Corps and/or the project partner should include in-kind surfgrass restoration or establishment as part of the mitigation plan. b. Given the uncertainty associated with surfgrass mitigation success, the Corps and/or the project partner should develop a contingency plan should surfgrass mitigation efforts fail. Based upon discussions with the Corps, kelp mitigation may be the most appropriate out-of-kind approach if inkind mitigation does not yield positive results. Therefore, the Corps and/or the project partner should design an artificial reef capable of supporting kelp habitat that would offset similar ecological functions that were lost due to surfgrass impacts. c. The Corps and/or the project partner should coordinate with NMFS and other interested agencies to determine an appropriate mitigation ratio for impacts to surfgrass and rocky reef habitat. 2) A scientifically defensible monitoring plan should
be developed prior to a record of decision on the proposed project. 326
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The purpose of the monitoring plan is to detect environmental impacts associated with the proposed project and serve as the basis for determining whether compensatory mitigation is appropriate. Results from the monitoring plan will inform the development of a final mitigation plan, which will be based upon the approach described in the contingency mitigation plan. The monitoring plan should be described in greater detail than the program currently described in Appendix B. The sampling design and statistical analyses should be clearly described and should be based upon fundamental principles of statistical inference. This monitoring plan should be reviewed and approved by the Corps, NMFS, and other interested resource agencies prior to a record of decision. In addition, to ensure adequate scientific rigor, consideration should be given to involving an independent review by recognized, biostatistical experts. 59 NMFS EFH Conservation Recommendations (Statutory
Response Requirements): Please be advised that regulations at section 305(b)(4)(B) of the MSA and 50 CFR 600.920(k) of the MSA require your office to provide a written response to this letter within 30 days of its receipt and at least 10 days prior to final approval of the action. A preliminary response is acceptable if final action cannot be completed within 30 days. Your final response must include a description of measures to be required to avoid, mitigate, or offset the adverse impacts of the activity. If your response is inconsistent with our EFH conservation recommendations, you must provide an explanation of the reasons for not implementing those recommendations. The reasons must include the scientific justification for any disagreements over the anticipated effects of the proposed action and the measures needed to avoid, minimize, mitigate, or offset such effects.

Comment noted.
60 NMFS EFH Conservation Recommendations (Supplemental If the project changes substantially, EFH consultation 327
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Consultation): Pursuant to 50 CFR 600.920(1), the U.S. Army Corps of Engineers must reinitiate EFH consultation with NMFS if the proposed action is substantially revised in a way that may adversely affect EFH, or if new information becomes available that affects the basis for NMFS’ EFH conservation recommendations. will be reinitiated.
61 NMFS Fish and Wildlife Coordination Act Comments:

The purpose of the FWCA is to ensure that wildlife conservation receives equal consideration, and is coordinated with other aspects of water resources development [16 U.S.C. 661]. The FWCA establishes a consultation requirement for federal departments and agencies that undertake any action that proposes to modify any stream or other body of water for any purpose, including navigation and drainage [16 U.S.C 662(a)]. Consistent with this consultation requirement, NMFS provides recommendations and comments to federal action agencies for the purpose of conserving fish and wildlife resources. The FWCA allows the opportunity to offer recommendations for the conservation of species and habitats beyond those currently managed under MSA and ESA. According to Subpart E Section 230.43 of the Section 404(b)(1) Guidelines for Specification of Disposal Sites for Dredged or Fill Material (404(b)(1) Guidelines), vegetated shallows are considered special aquatic sites (SAS). SAS are geographic areas, large or small, possessing special ecological characteristics of productivity, habitat, wildlife protection, or other important and easily disrupted ecological values. These areas are generally recognized as significantly influencing or positively contributing to the general overall environmental health or vitality of the entire ecosystem of a region. This status provides special consideration when evaluating actions involving dredged As stated, the purpose of the FWCA is to ensure that the fish and wildlife resources receive consideration in project alternative development and selection. The FWCA is an action that is taken between the FWS and the Corps, not the NMFS; these comments are noted, but inappropriate for the purposes of FWCA.Furthermore, the Corps San Clemente Shoreline Protection has, in fact, considered the fish and wildlife resources in the alternative development and selection. FWS, as well as other resources agencies, were invited and/or attended several coordination meetings in which the coastal engineering profiles were presented, given, and discussed with the resources agencies, of which NMFS was included. Effects of the project implementation of each alternatives (35m, 30m, 25m, 20m, 15m, 10m, and 5m) were discussed and the effects to fish and wildlife, including EFH as well as federal and state listed taxa, including grunion spawning season. As the action agency, the Corps has made a “no effect” determination on federal listed taxa, including green sea turtles, which are thoroughly discussed in Section 5 of the FEIS/R. Fish and wildlife resources were considered in the alternative selection by reducing the effects of the project on fish and wildlife from the 35 meter to the 15 328
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or fill material pursuant to Section 404 of the Clean Water Act. Vegetated shallows are defined as permanently inundated areas that under normal circumstances support communities of rooted aquatic vegetation. NMFS believes surfgrass should be considered a SAS and receive special consideration when evaluating actions involving discharge of dredged or fill material. Surfgrasses are considered to be among the most productive seagrass systems on the planet (RamirezGarcia et al. 1998). Galst and Anderson (2008) indicate that surfgrass beds serve as an important habitat for nearshore fishes, and the loss of surfgrass from disturbance has negative consequences for recruitment success. Surf grass also serves as an important nursery habitat for a variety of invertebrates, such as California spiny lobster (Engle 1979, as cited in MPLA Initiative 2009), and as habitat for algae (Stewart and Myers 1980, as cited in MLPA Initiative 2009). Shaw (1986) suggests that the importance of surfgrass as a nursery for juvenile lobsters in southern California is clearly apparent and the disturbance or destruction of this habitat could seriously decrease lobster abundance. Surfgrass is also important foraging habitat for the endangered green turtle on the Pacific side of the Baja Peninsula (Lopez-Mendilaharsu et aI2005). Although utilization of nearshore habitats in southern California is less understood, sub-populations of the endangered green turtle are known to utilize San Diego Bay and the Long Beach area for foraging. If surfgrass serves a similar function in southern California, then adverse effects to surfgrass habitat may have a negative impact on habitat used by this listed species. NMFS has determined that rocky reef and surfgrass habitat may be negatively impacted by proposed project activities. As such, EFH Conservation Recommendations provided above also serve as FWCA recommendations to meter alternative. Effects of the project implementation for each of the alternatives were discussed with special emphasis on rocky reef and surfgrass with emphasis with the FWS, who is responsible under FWCA to prepare the Coordination Act Report (CAR) and in which the Corps has a MIPR to prepare the CAR. A functional assessment habitat evaluation using best professional judgment was accomplished and is presented in the summary of the FEIS/R. The conclusions of implementing the 15 meter alternative are based on this functional assessment habitat assessment in which the conclusion is that there will be no impacts to rocky reef or surfgrass due to project implementation of the 15 meter alternative. It is the FWS responsibility to coordinate their actions with the CDFG and the NMFS. The NMFS comments were given to the Corps before the Corps received the FWS’s draft CAR. Lastly, the FWCA is very clear that the FWS presents the action agency with recommendations that are discretionary for implementation and are recommendations, not requirements. At the 31 Janaury 2011 project conference between the Corps and the resources agencies, there were agreements and non-agreements to the FWCA draft CAR recommendations. As previously stated, a MMRP has undergone several reviews and revisions from the resources agencies as well as Corps’s internal review with SPD, HQ, and external review with the Los Angeles District ATR review team. The document has undergone external (outside the Corps) review and currently is being 329
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compensate for these negative impacts. reviewed by the Corps ERDC Submerged Aquatic Vegetation Restoration Research Program. The revised MMRP is found as Appendix B and implementation will commence implementation in the PED phase. The Corps LAD will employ the services of the Corps ERDC Submerged Aquatic Vegetation Restoration Research Program for implementation of the MMRP, including development of mitigation triggers and success criteria alongside the resources agencies. Most importantly, it must be determined if impacts to rocky reef and surfgrass with project implementation will occur. Monitoring of rocky reef and surfgrass will commence two years prior to project implementation at the project site as well as the reference site. It must be noted and understood that the best scientific information was used in the coastal engineering model that has been certified by knowledgeable and experienced experts. A more robust functional assessment habitat evaluation will be performed during the PED phase.

State Agencies Cy R. Oggins, Chief, Division of Environmental Planning and Management, CSLC, September 15, 2010 62 State Lands Commission
COMMENT: Please be advised that both the borrow site and the receiver site involve sovereign lands under the jurisdiction of the CSLC. Use of the borrow site will require authorization from the Commission for the issuance of a dredging lease. The receiver site appears to overlap the lease area under Lease No. PRC 8567.9 issued by the CSLC to the city of San Clemente for the ‘City of San Clemente Opportunistic Beach Replenishment Program.’ Use of the receiver site will require the city of San Clemente to amend Lease No. PRC 8567.9 to accommodate the project. Lease applications can be Section 18 of the Real Estate Appendix explains that the City of San Clemente will obtain a lease for the borrow area from the CA State Lands Commission. The limits of placement under the opportunistic lease PRC 8567.9 do fall within the proposed limits of the current project and the City will request Lease 8567.9 be amended if necessary. 330
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accessed via our website at http://www.slc.ca.gov
63 State Lands
Commission
In order to provide the basis for an effective mitigation monitoring program as required by CEQA, CSLC staff recommends that the table be revised to include a comprehensive summary of all the mitigation measures and monitoring commitments relied upon in the EIS/EIR, and at a minimum reflect the following revisions:
• Table 7-1 should include several omitted
mitigation measures identified in Section 5 including Geology/Topography (MM-ER-115-2.1), Biological Resources (MM-BR-50-2.1 and 2.2), Cultural Resources (MM-CR-50.1), Noise (MM-N50-3.1), and Recreation (MM-R-50-4.1). • The table should reference or incorporate all
components of the Biological Resources Monitoring Plan in Appx B. • The mitigation measures in the table should be
numbered to indicate the corresponding section or appendix where they originated.

The mitigation measures indicated have been added to Table 7-1. The biological resources mitigation and monitoring plan in Appendix B will be referenced in the table.

Marija Vojkovich, Regional Manager, Marine Region, DFG, September 30, 2010 64 CA DFG General: The Department wants to stress the importance that the project be designed carefully in order to primarily avoid adverse biological impacts to sensitive marine species to the maximum extent possible. Our concerns relate to potential impacts to rocky reefs, surfgrass, marine algae, and the fish and invertebrate communities that utilize these for critical habitat. Many marine species, such as rockfish, Sebastes spp, and other fish species managed under the Department’s Nearshore Fishery Management Plan (NFMP), use these important habitats for breeding, shelter, spawning, foraging and resting. The NFMP species are found primarily in rocky reef or kelp habitat in nearshore waters. A list and description of NFMP fish species can be found on the Department’s website at http://www.dfg.ca.gov/marine/nfmp/pdfs/section1_chap2.pdf. Additionally, the federally endangered black Currently, black abalone does not occur within the project area. The proposed rule for listing critical habitat for the black abalone indicates that nearest locale is the Palos Verdes Peninsula in the Los Angeles Harbor region. They currently do not occur on the rocky reef within the project area and the potential to occur is negligible. The term “critical habitat” should not be used as to confuse the federal legal term of listed taxa critical habitat. There is not officially listed critical habitat for any listed taxa within the borrow site or the beach receiver site. Impacts to rocky reefs, surfgrass, marine algae, and the fish and invertebrate communities that use these habitats are discussed in Section 5.4.2. The 15 ft. (50 331
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abalone, Haliotis cracherodii, and several other abalone species could occur in the project area inhabiting kelp and rocky reef habitats. The California spiny lobster, Panulirus interruptus, a recreationally and commercially important species, also inhabits the project area. Lobsters rely upon the reefs and surfgrass in the area for spawning, foraging and shelter. m) beach width alternative minimizes impacts associated with a larger beach fill while still providing substantial project benefits. 65 CA DFG Project Alternatives: In order to reduce risk and protect important offshore sensitive species and habitats, the Department recommends that the alternatives analysis be modified to include analysis of a more conservative alternative, such as a reduced quantity of sand for the project or a different deposition location on the beach. Kelp and rocky reefs in the project area are critical habitat for the black abalone, and surfgrass habitat is essential for spawning and as a nursery for juvenile fish, lobsters and other invertebrates. Additionally, surfgrass and kelp provide root system structure that helps to stabilize sand.

During the two year coordination meeting efforts, the Corps consulted with the CDFG. The CDFG was part of the process and did not express the concerns identified in this comment during the coordination two year timeframe. The Corps analyzed all alternatives (35 meter to 5 meter). The 15 meter alternative was the environmentally least impacting while maintaining the benefit/cost ratio required by the Corps policy. Furthermore, the Corps did, in fact, perform the required Essential Fish Habitat “consultation” as required by the MSA with CDFG’s presence in the discussion. As previously stated, the Corps is aware of the marine aquatic vegetation (surfgrass and kelp). CDFG was presented the coastal engineering beach profile analysis in which discussion of the effects of the project would or would not occur. It was explained to CDFG that the beach receiver site is on the high portion of the dry sandy beach, not the surf zone or nearshore waters. It was further explained that the natural high tides and storm surge would distribute the receiver site sand onto the beach width, thus emulating a natural process; hence, the equilibrium will take four to six months to occur. No sand will be placed directly by project activities into the equilibrium footprint outside of the dry beach. As discussed in Section 3.4.2, a range of beach width alternatives were considered. The 15 meter 332
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alternative was the alternative that provided the highest benefits to cost ratio while minimizing impacts to valuable marine habitats. Based on models of post-placement sand deposition, the 10 meter beach width alternative would have similar potential impacts on sensitive marine habitats as the 15 meter alternative but would have less project benefits. A 5 meter beach fill alternative would not have a positive benefit to cost ratio. Placement of fill on a shorter length of beach would not reduce the potential impacts to rocky reef and surfgrass habitats. Based upon the coastal engineering model that has been certified by national known experts internal and external to the Corps, the 15 meter profile indicates that there would be no impact to the T-Street rocky reef or surfgrass. The Corps does discuss the potential for impacts to a small inner portion of the TStreet rocky reef and potentially to surfgrass.Nonetheless, that remains unknown. Furthermore, as previously stated, a MMRP has undergone several reviews and revisions from the resources agencies including CDFG as well as Corps’s internal review with SPD, HQ, and the external to the Los Angeles District ATR review team. The document has undergone external (outside the Corps) review and currently is being reviewed by the Corps ERDC Submerged Aquatic Vegetation Restoration Research Program. The revised MMRP is found as Appendix B and implementation will commence implementation in the PED phase with monitoring activities discussed in the MMRP. 66 CA DFG The DEIS/DEIR proposes a surfgrass compensatory mitigation plan for an experimental surfgrass transplantation contingent upon unexpected adverse Appendix B has been revised to include a back up mitigation plan. Kelp would be transplanted to an offshore reef if the experimental surfgrass transplant 333
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impacts, such as a significant loss of surfgrass area or reduction in density of surfgrass mats. There is no indication in the DEIS/DEIR of a secondary plan if the experimental surfgrass transplant is not successful. The Department suggests that a back up mitigation plan should be available in the event that the experimental surfgrass transplant does not succeed. Additionally, habitat compensation and the criteria for triggering compensatory mitigation should be further discussed and agreed upon with the Department and other resource agencies. The Department will continue to work with the Corps to develop adequate mitigation and monitoring plans that will sufficiently avoid and minimize the risk of burial and other adverse impacts to sensitive species and habitats. fails.
67 CA DFG Monitoring Plans: There are two mitigation and monitoring plans presented in the DEIS/DEIR for surfgrass habitat; one for the offshore reefs, referred to as MM-BR-50-2.2, and one for the habitats along the mooring and slurry pipeline route on the sea floor, referred to as MM-BR-50-2.1. The Department concurs that these two areas will need baseline surveys conducted prior to the project and post construction surveys that monitor for significant damages or degradation of surfgrass, kelp and reef habitat. The Department always advises that avoidance measures be used first and to the maximum extent practicable. The DEIS/DEIR minimization plan for surfgrass and kelp suggests that the Corps has already determined that avoidance measures are not feasible. However, the Department believes that the mooring and sea floor pipeline plan could be revised so that the routes avoid impacts completely. The Department is willing to work with the Corps to discuss and develop an alternative pipeline route. The MM-BR-50-2.2 surfgrass and reef habitat mitigation and monitoring plan of the DEIS/DEIR is limited to pre- and post- construction, with no monitoring during construction. The Department believes that it is appropriate to monitor surfgrass and reefs during the As discussed in Section 5.4.2, mitigation measure MM-BR-50-2.1 specifies that based on the preconstruction surveys, a pipeline route be selected that minimizes contact with surfgrass and kelp habitat. A route that completely avoids contact with these resources would be the route that minimizes impacts if such a route exists. A route that has some contact with kelp and/or eelgrass would only be selected if a route that avoids these resources completely cannot be found. Mitigation measure MM-BR-50-2.2 proposes pre- and post-construction monitoring of reefs and surfgrass, because impacts, if any, would not be expected to be observed during construction when sand is placed directly on the beach, but following construction as the waves re-distribute this sand and move some of it offshore and downcoast where it may deposit in reef and surfgrass habitats. 334
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construction activities because of the uncertainty of adverse impacts predicted in the DEIS/DEIR. The Department’s recommendation for additional monitoring to avoid potential impacts is based mainly on the fact that there has not been consistent success from surfgrass transplantation projects in the past. Additionally, the best available transplantation techniques for surfgrass are still considered experimental at this time. The Department also recommends that if monitoring during the sand deposition indicates signs of adverse effects (i.e. significant burial) to surfgrass and/or reef habitat, then construction activity should be stopped and re-evaluated before permanent damages are done. The project could continue with possible modifications, such as re-locating the deposition area on the beach, to avoid or minimize adverse impacts. Monitoring should continue to evaluate the effectiveness of any modifications to project activities. A revised monitoring plan should incorporate these recommendations. 68 CA DFG Reporting: Reporting procedures are lacking from all plans. The Department expects to receive all survey and monitoring reports, within three to five days for preliminary results and 30 days for final reports, in order to have time to review and respond to potential impacts to marine habitats.

CDFG will receive all survey and monitoring reports, as requested.

Local Agencies and Organizations Mark Rauscher, Beach Campaigns Manager, Surfrider, E-mail, September 20, 2011 69 Surfrider Section 1.2 Project Background Thoroughly describe the private property threatened by shoreline changes.The document states: “Changes to the beach shoreline caused by erosion have reduced recreational opportunities and are threatening the stability of City facilities, private property, and a major Southern CA commuter rail corridor.” There are no private structures on the ocean side of the SCRRA rail line within the project area. All references to private structures have been removed from the document. 335
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It is unclear what “private property” is under threat by shoreline changes, and what protection it would be afforded by the proposed project. It is our understanding that all structures all structures constructed west of the railroad within the project area are public facilities. It is important to describe the structures accurately as their storm-damage protection provides the economic benefits of such a project. This lack of private property should also be reflected in Sections 2.1: Purpose and Need and 2.2: Project Objective. 70 Surfrider Section 2.1.2: Threat to the Railroad Corridor Provide clear and supported justification for the future necessity of seawall construction in a no-project alternative. As noted, the railroad corridor has varying levels of hard protection along the project stretch. Yet the railroad has successfully managed erosion and wave attack issues for relatively low cost. The document does not explicitly describe which sections are more at risk, nor why the presumption is made that continued rock placement will not be allowed in the future, necessitating the need for a highly engineered and costly seawall as described in Coastal Engineering Appendix, Section 4.4. Given that the bulk of the economic justification for this project relies on this particular prediction of future conditions, it requires a more robust explanation. Section 4.4 states: “It will become mandatory for the SCRRA to construct seawalls in the future. Project formulation indicates that due to evolving law and coastal structure construction regulations, the ability for the SCRRA to use revetment methods will expire.” Yet the previous language within the section does not Future necessity of seawall is documented in a July 19, 2005 letter from OCTA (owner of the Orange County region LOSSAN) stating they would expect to support future construction of a seawall. 336
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support this statement. In addition, this project does not even encompass the most threatened portion of the railroad, as areas to the north (Mariposa) and to the south (Calafia) are at much higher risk of wave impact damages, yet OCTA has not attempted to gain permits for a permanent vertical seawall at these sections. 71 Surfrider Section 2.1.3: Public Safety and Liability. Correct the discussion of the public safety issues due to moved infrastructure in a “managed retreat” alternative. The document claims that erosion threatens public restrooms, which could require relocation if erosion trends continue. It goes on to state that such a relocation would cause a public safety issue due to the resultant increase in pedestrian railroad crossings. This premise is incorrect.

The public restrooms which are located west of the railroads within the project area occur at T--ǦStreet and the Pier. T--ǦStreet already has a railroad overpass preventing any direct pedestrian crossings. The Pier already has a railroad underpass allowing safe passage below the railroad. Hence, no increase in pedestrian crossings need occur if restroom facilities are relocated east of the railroad.

Report will be revised to reflect the following: “Depending on the location of construction of restrooms, if necessary under managed retreat, crossing the tracks may be dangerous if beachgoers decide to do so rather than use the designated pedestrian crossings. There are currently safe pedestrian crossings for beachgoers to cross the tracks and access the beach.” 72 Surfrider 4.3.4.3: Littoral Processes and Sediment Transport.

Documented processes do not support the need for the project. The Sediment Budget section shows that the long--Ǧtermsediment budget for this section is essentially in equilibrium, with net erosion equaling net accretion. The Long Term Shoreline Change section also finds variable net positive and net negative changes both along shore and through time. This would indicate that in the long term San Clemente’s shoreline is nearly unchanged, and that sediment likely moves alongshore in pulses with portions It is recognized that the shoreline change data set used in the present analysis is limited at best. However, this was all the data available for this area at the time this analysis was conducted. While data intensive information resulting in conclusive findings is preferred, the best available data resulted in this analysis. It is further recognized that the shoreline change data set results in a less than desired numerical presentation. However, the results are consistent with the overall shoreline change scenario in this region. 337
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of the city’s beaches growing while others are shrinking. Particularly striking is the quote: “During the period 1980-1989, the shoreline was predominantly positive with accretion rates ranging from + 1.4ft/yr (+0.43 m/yr) to +7.2 ft/yr (+2.16 m/yr).” This is the period that experienced the strong 1983 El Nino winter storms, but which apparently survived with little net erosion. The Recent Shoreline Change Rate attempts to show moderate shoreline width reductions, but is not consistent throughout the study area, with beach widening shown at Shorecliffs. There are also an extremely low number of data points (at least 12 years missing in the recent past) to be able to conclusively define the nature or extent of observed shoreline change. Because of this it is unclear if the single data point at the end of the time series represents a long term negative trend, or simply a perturbation in a highly active shoreline as seen in the first ten years of the time series. In other words, does the beach come and go with the weather and storm conditions, and we’re only observing a single point in time? The sediment budget indicates the shoreline is essentially in balance, neither accretional nor erosional (+0.03 m/yr). Inclusion of recent monitoring data results in a marginally erosive shoreline (-0.10 m/yr). The very small annual change signal is masked within the much larger envelope of seasonal changes. The seasonal variations are on order of 15 m and thus are two orders of magnitude larger than the mean annual long term signal. The three survey lines SC 1680 (Linda Lane), SC 1660 (T Street), and SC 1623 (State Beach) are south of Mariposa Point whereas SC 1720 (Shorecliffs) is north of Mariposa Point. Mariposa Point, although physically small, is morphologically significant as it represents a salient feature in an otherwise uniform section of shoreline. This salient is a micro morphological separation between Shorecliffs and the other three survey lines. These three lines south of Mariposa Point are consistent in erosional trend whereas the Shorecliffs trend is accretional. Uncertainties in the results of this analysis are assumed captured within the design long term shoreline change distribution. The design distribution is a triangular form with a minimum (max erosion) of -0.46 m/yr, a maximum (max accretion) of +0.38 m/yr, a peak of -0.21 m/yr, resulting in a mean value of -0.10 m/yr. This means that some years will be erosional, some years will be accretional, and the average value will be slightly negative (-0.3 ft/yr). 73 Surfrider Impact WR--50--3: Nearshore wave characteristics (50 ft alternative). Monitoring of surfing quality should be designated as mitigation under all project alternatives. There is potential for adverse impacts on surfing as described in this section as well as in the Engineering The following text was revised in the Coastal Appendix; revised text is underlined. Survey methods will consist of topographic measurements, bathymetric measurements, surf quality observations, and video stereo
photogrammetric methods. The monitoring period will
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Appendix (6.3.4), yet no mitigation measures are provided. The 115 ft alternative predicts definitively adverse impacts to wave characteristics and does suggest monitoring of surf conditions followed by adjustment of subsequent renourishments if surfing is degraded and does not recover. Based on the description of potential impacts within the Engineering Appendix, in particular, there is a possibility of severe degradation of surfing quality. As such, we request that monitoring of surfing quality before and after construction be provided as mitigation of any chosen project, including the 50 ft alternative. Potential impacts as described could pose a significant degradation of wave quality: “The surfing experience might consist of a normal “take--Ǧoff,” but then “close--Ǧout” as the wave encounters the
straightened bathymetric contours inshore” and would justify the need for monitoring and mitigation if these impacts are experienced. In addition, meeting notes in the appendices specifically state that monitoring of surfing quality is to be undertaken. This needs to be reflected within the body of the impacts analysis. This monitoring and mitigation should reflect the discussion of impacts from the 115 ft alternative below. Impacts to wave characteristics in the designated surfing zone north of the pier must be evaluated and described. Within section Impact WR-50-3 and WR-115-3, there is no mention of surfing anywhere aside from T-Street. While TStreet is a consistently high-quality surfing area, surfing is often restricted there under “black ball” conditions when the lifeguards ban hard-board surfing for the bulk of the day during the summer. At these times surfing within the project stretch is restricted to the area directly north of the pier, causing the pier zone to become incrementally more begin one year before construction (for the surf quality observations) and continue for the 50-year period of
Federal involvement. The table of monitoring costs has been modified to reflect the surf quality monitoring. 339
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valuable for use.
74 Surfrider Impact MM--WR--115--3.1: Nearshore waves
characteristics (115 ft alternative). Timing for mitigation measure should be shortened. Under the 115 ft alternative, it is estimated that surfing waves could be significantly degraded for a period of 10 years. This is beyond the estimated period of return for future nourishments. An allowance of 10 years degradation and monitoring before future plans are adjusted is unacceptable. Similar to surfgrass, direct mitigation or reconstruction of the resource is not currently possible, and no time allotment is provided for the surfgrass mitigation (MM--ǦER--Ǧ115--Ǧ2.1). In addition, artificial surfing reefs are not viable as mitigation for lost surfing resources, and a greater emphasis on adverse impact prevention should be made.

Due to the likelihood of significant impacts to both habitat and surfing resources (nearshore waves), the 115 ft alternative was not chosen as the Recommended Plan. Following the process of first trying to avoid, if necessary, then minimize, and as a last resort to mitigate impacts, the recommended plan of a 50-ft wide beach was identified as the Recommended Plan.

Tom Bonigut, P.E., Assistant City Engineer, City of San Clemente - Public Works Dept., September 10, 2010 75 City Staff Sand compatibility and acceptability. Is there a QA/QC process to ensure that the borrow site sand will be suitable for placement on San Clemente beaches, and if for some reason it is not, what is the backup plan for borrow sites? This is a really important one, as we are receiving feedback that the Oceanside borrow site does not provide quality beach sand, and that a borrow site further site (name escapes me) is actually better.

The usual Corps or Los Angeles District specific procedure QA check for borrow site consistency is to perform random grain size analysis tests of the dredged material collected in the dredge process during the final construction phase of project: For example: Assuming on-the-beach placement: Most of the time, the majority of the QA samples will be collected at the end of pipe discharge for on beach placement. If hopper dredge is used, then additional sampling should occur from the hopper to confirm or collaborate sediment sizes discharged from hopper discharge pipe prior to discharge onto beach or onto nearshore. The number of such samples is dependent on the amount of material placed per event. For nearshore placement, the samples would be collected from the dredge containment device prior to placement (e.g., from hopper bin if hopper dredge used). The answer is that QA samples are collected 340
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from both at the end of dredge pipe and in the container of dredge if hopper dredge is used. The Los Angeles Geotechnical Branch policy on the frequency, and number of samples is as follows: For total dredge material placement volumes of less than about 500,000 cubic yards, the frequency of sampling is = 1 QA sample per 35,000 cubic yards of material placed or per 35,000 cubic yard event. For greater than 500,000 cubic yards and up to 1,000,000 cubic yards, the frequency of sampling is = 1 QA sample per 50,000 cubic yard event. For greater than 1,000,000 cubic yards, the frequency of sampling is = 1 QA sample per 75,000 cubic yards. The QA is performed during the construction phase and included in construction specs for the Contractor to actually perform the collection and laboratory testing of QA samples as such. The purpose of the QA is to provide actual test data to show the consistency of dredge material over time and to provide information for Corps mgmt to make decisions on quality of dredge material and/or to make recommendations or direct the Contractor to move into a better area of the designated borrow area, during the actual dredging event. At this time, there is not a backup plan is for poor quality material that will eventually be dredged, other than that we have already made a selection of the most suitable borrow site, based on expected grain size compatibility that best matches the San Clemente beach renourishment study needs. The borrow site(s) selected and identified within the feasibility study can have sediment quality that is variable depending on 341
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areas dredged within this selected borrow site(s). The dredged sediment can be expected to changes over time with depth of sediment stratigraphy encountered during actual dredging (i.e., it can better or worse depending on, for example, if a specific poor quality layer of sediment or borrow material is encountered and dredged in a specific time event, and then another better layer or increasing quality of sediment or material is encountered in another specific time event). However, the geotech explorations and sieve analysis thus so far provided, indicate that the borrow area(s) selected are overall acceptable for compatibility with the San Clemente study area. 76 City Staff Beach monitoring. Is there any discussion about what we think would happen to beaches south of the project area? I.e. since there is a net southward sand movement, what might happen to those beaches and surf breaks? Would or should the monitoring plan address some of those areas too? We certainly need to ensure, to the extent possible, that we don’t impact surf breaks south of the project area.

Net littoral transport is southward. It is expected that the fill material will have the most influence immediately adjacent the fill area up to the state beach area. The fill material will tend to slowly redistribute across the profile as it drifts southward. The fill quantity being relatively small is expected to have little or no impacts down drift of Cottons Point (Trestles). Project monitoring will include transect lines outside of the fill area both north and south to monitor fill movement. 77 City Staff Can the discussion about the reference line for the project be improved? It’s unclear to some what the starting point is for determining where the 15-meter beach width starts? Is it fixed throughout the project area (e.g. some offset from the rail line), or does it vary according to some other criterion? Also, is it fixed in time according to current conditions? I.e. what if our beach erodes significantly between now and the time an actual project is constructed? Will the beach berm width reference line be shifted also, or would the project be as described currently? Is it possible to define a seaward project limit instead of using a reference line that could change over time? The fill line is the location of the +5.2 m contour (+17 ft) at the time of the fill. The fill will be a uniform 15 m parallel to this contour, thus the fill will mimic the existing shoreline in shape. The report will be amended to strengthen this description. The model does show renourishments will be conducted when the beach erodes back to the berm position at the time of fill. Project Authorization will specify actual renourishment interval (every 6 years) and quantity; however, implementation is sometimes dependent on funding available. 342
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PublicGeorge Gregory, E-mail, September 17, 2010 78 George Gregory it seems ludicrous to replenish the beach sands without promoting erosion and passive replenishment
The fill is expected to undergo an initial equilibration process then form a stable beach, which hopefully will not produce a more rapid rate of erosion than currently experienced. 79 George Gregory if sands will migrates south may we please replenish north beach first thus supplying the pier area 2nd
Pumping onshore will be conducted to maximize the efficiency of operation and minimize negative environmental impacts. 80 George Gregory if the near costal quarry's where relocated away would this not help with passive and aggressive replenishment of san clement ,capo beach, beaches & soils In general, the presence of sand mining operations within the San Juan Creek portion of the watershed could have an overall impact of sediment supply to the beaches in the San Clemente area. 81 George Gregory are their plans to use the spoils from any excavation or tunneling up in the ortages ,For costal replenishment or building material .Thus using the spoils to replace native soils and or releasing and allowing to pass thru the quarry native soils to the shore All sediment will be hopper dredged from Borrow Area 2 offshore of Camp Del Mar Boat Basin and Oceanside Harbor and pumped onshore via pipeline. 82 George Gregory it seam important to keep up the allusion of success that a supply of sand can bring. with constant permits equipment and plans in place ,available and maintained for train transportation of sand and soils for the grooming and maintenance of the coastal resources. possibly hedging are bet and augmenting strategic and civil and possible emergency capabilities (the volley ball court is like playing on dull broken glass)train car loads are fairly efficient and affordable compared to truck loads. Possible improving the quality of soils from distant and local sources Comment noted.
83 George Gregory lastly it seems to be a shame the energy used to harvest the soils do not seem to be of any benefit in the first place as in deepening a harbor or entrance improving wet lands or impoundments or importing away proofed soils from a site like Santa Ana river basin and flood control projects The Corps study process identified dredging material from Borrow Area 2 as the alternative in the Federal Interest. 343
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Lynn Hughes, Letter, September 14, 2010 84 Lynn Hughes Page 9: Problem Identification. Does not include the economic impacts from erosion that would reduce the income to local visitor/tourist serving businesses, and loss of taxes and other revenues to the city, including bedroom taxes, sales taxes, and property taxes; and beach parking and beach concession revenues. It does not include the added cost to provide lifeguard and other protective services to safely keep the public away from hazardous conditions and to protect, relocate, or replace public improvements. Additionally, it does not speak to the potential liability or defense costs from lawsuits due to the injury or death to beach goers as the result of exposed natural and man-made dangers.

Concur with your comment that the economic evaluation did not account for regional economic impacts related to the erosion of the shoreline. It would be expected that the local economy will be impacted by the erosion of the shoreline. However, the USACE guidelines for determining federal interest in coastal shoreline project is mainly based on reducing infrastructure damages( recreational buildings, future protection measures, and impacts on transportation) instead on regional impacts like tourism, local taxes and decreases in concession sales. Based on the availability of funding for the study and schedule for the study, the economist for the study determined that any evaluation of the regional impacts will be limited for the study. 85 Lynn Hughes Page 9: Problem Identification, mentions potential danger of exposed underlying hard substrate and man-made. Page 10, Problem Statement, mentions reduces recreational space on an already space-limited beach. I would suggest that more emphasis be placed in both areas regarding the fact that the erosion not only causes a reduction of recreational space, but can present public dangers from exposed man-made and natural hard structures. This condition can make shoreline and offshore ocean areas unsafe, hence unusable by the public. San Clemente City Lifeguards have had to post and, at times, restrict the use of some near shore and off shore ocean areas due to these dangers. This is no easy task, since these hazardous conditions can become exposed overnight and are difficult to detect during changing tidal and surf conditions. This task is further complicated by strong wave and currents. A swimmer can enter the water in a location that is relatively safe and be swept down the beach hundreds of feet in a matter of a few minutes where Comment is understood and has already been emphasized throughout the report(s), including the Coastal Engineering Appendix and Draft Main Report (page 17 and page 60 paragraph 1). 344
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there might be exposed dangers that are under water and, therefore, undetectable. 86 Lynn Hughes ES-1, under Overview, the same point regarding the dangers of exposed hard structures and its economic impacts should be made here as well. Also, it should be further emphasized, possibly under the Executive Summary, Project Background, page 1-4, that the LOSSAN railroad Riprap is not engineered and therefore subject to continual undermining and failure during periods of erosion. It is possible that the tracks could be undermined to the extent that the railroad tracks could not safely carry the load of railway cars brought in to drop addition rock.

Discussion will be inserted in this section regarding dangers of hard structures. Discussion will be placed in Executive Summary, pg 1-4 explaining that most of the placed rip-rap is un-engineered and, thus, not guaranteed to provide any level of protection.

Keith Aiken, E-mail, September 23, 2010 87 Keith Aiken The train track running on top of San Clemente beaches is at the root of the problem.

Correct, much of the project justification lies in the without project assumption that the railroad would need to be protected by a seawall. 88 Keith Aiken It’s hard to believe an alternate rail route cannot be found – especially with the desire of Amtrak to increase rail traffic.

Potential for an alternative route is discussed in the main report. No plans currently exist to relocate/reroute the railroad at this time and any efforts would be astronomically costly. 89 Keith Aiken Experience has shown that sea walls accelerate beach erosion. The sea walls already built by Amtrak, to protect rail lines, are accelerating beach sand erosion. Why isn’t Amtrak being held responsible for its part in adding to the problem and mandated to help with sand replenishment costs? This is an issue separate of the study area (specifically Reach 6) being considered for this project as no seawalls exist in Reach 6. Basis for this Federal cost-shared project lies in protection of shoreline infrastructure in Reach 6 and the associated benefits versus costs of doing this. 90 Keith Aiken We were told by the geologists that most all sand migrates southward; so why not add sand at North Beach? North Beach has been severely impacted and is in need of sand replenishment. Plus the sand eroded from North Beach would help to replenish sand on all San Clemente beaches as it migrates south. At the very least, sand could be deposited at North Beach and not in the T-street area – as sand will naturally move into that area from sand replenishment on beaches north of T-street.

Placement of sand will occur along the beach within only Reach 6, as described in the report. Adaptive management will be used as explained in the report to minimize environmental impacts and create a uniform 15-m wide beach through equilibration of the sand.

Don Kunze, Public Meeting, August 19, 2010
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91 Don Kunze Where did San Clemente sand go?? Why?? Why not bring it back.

Littoral (sediment) transport in the San Clemente region is predominantly towards the south (San Onofre). This movement of sand along the coast is a natural occurrence; therefore, the sand transported to the south is needed to supply sediment to those beaches. 92 Don Kunze Did Dana Point Harbor affect us? How about nuclear plant affect?
Dana Point Harbor as well as the nuclear power plant have no known effect on the beaches in San Clemente. 93 Don Kunze What about new rock reef and kelp? The reference to new rock reef and kelp is unclear. If in reference to Southern California Edison Reefs constructed as mitigation for the impacts of the San Onofre Nuclear Power Plant, a separate environmental document was prepared specifically for that project and is not included as part of this proposed Project. 94 Don Kunze Seems to be less sand and more rock (pebbles) than ever. Why?? Since 1983.

There is less sand and more rock because of natural erosive processes, this caused the need for this project. 95 Don Kunze Being a taxpayer cost to me? The initial nourishment event will be cost-shared 65% Federal and 35% non-Federal. Each of the subsequent renourishment events will be cost-shared 50% Federal and 50% non-Federal. 346
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APPENDIX A – 404(b)(1)
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SECTION 404(b)(1) EVALUATION OF THE EFFECTS

OF THE DISCHARGE OF DREDGED OR FILL MATERIAL
INTO WATERS OF THE UNITED STATES:

SAN CLEMENTE SHORELINE PROTECTION PROJECT
I. Introduction:

The following evaluation is provided in accordance with Section 404(b)(1) of the Federal Water Pollution Control Act Amendments of 1972 (Public Law 92-500) as amended by the Clean Water Act of 1977 (Public Law 95-217). The intent of this document is to state and evaluate information regarding the effects of the discharge of dredged or fill material into waters of the United States.

II. Project Description:
a. Location: San Clemente Beach in the City of San Clemente, Orange County, California
b. General Description: The City of San Clemente is located along the coast of southern California about 60 miles (100 kilometers) south of Los Angeles at the southern end of Orange County near the border of San Diego County. The study area is on the beach near San Clemente Pier within the City of San Clemente and extends approximately 3,412 feet (1,040 meters) from Linda Lane to T-Street and is located within the San Clemente 7.5-minute U.S.

Geological Survey (USGS) topographic quadrangle in Section 4 of Township 9 South and Range 7 West. The Proposed Project consists of dredging material from offshore Oceanside, then hauling and placing it at San Clemente Beach. The proposed Project is a 50 foot (15 m) resultant beach width.

Beach fill would be 3,412 ft (1,040 m) long with a +17 ft (+5.2 m) crest elevation. The dredge volume is estimated to be approximately 251,130 cubic yards (192,000 m3
). Construction is anticipated to begin in 2012.
c. Authority and Purpose: The purpose of the San Clemente Shoreline Project (Project) is to provide shore protection through nourishment of the beach at the San Clemente Municipal Pier. Developing and maintaining the beach is needed to prevent the severe beach erosion that results from winter storms and to prevent damage to adjacent beachfront structures, including the heavily used rail line that runs along the beach through the city. In addition to the above, the loss of sand at the beach would have a negative impact on recreation, which supports the local economy, and would reduce the ecological functioning of the sand beach/littoral zone. 348
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d. General Description of Dredged or Fill Material:

1. General Characteristics of Material: Dredge material gradation is 6-12 percent of fines, 5-8 percent of gravel/cobbles, and the rest is sand. Material classification assumed is 10 percent fines, 83 percent sand and 7 percent gravel.

2. Quantity of Material: The recommended plan will require approximately 251,000 cy (192,000 m3) of beach compatible sand.

3. Source of Material: The recommended plan consists of dredging material from offshore Oceanside, then hauling and placing it at San Clemente Beach.
e. Description of the Proposed Discharge Sites:

1. Location: The discharge site is approximately 3,412 ft (1,040 m) of shoreline within the City of San Clemente. The area is approximately centered about San Clemente Pier; the south limit of the proposed beach fill is located immediately south of the T-Street overpass, while the north limit is located immediately north of the Marine Safety Headquarters. A major passenger rail line linking the coastal cities of Southern California runs between the beach and the coastal bluffs.

2. Size: The pier area beach profile indicates a typical berm elevation of +17 ft (+5.2 m), a typical foreshore slope of 8H:1V – 10H:1V, an offshore slope of 110H:1V, and a railroad elevation of approximately +21 ft (+6.4 m).

3. Type of Site: The shoreline in the Project area consists mainly of narrow, gently to moderately sloping sandy beaches backed by high, coastal bluffs.

This sandy beach grades into a foreshore consisting of cobble and gravel pockets at the water’s edge.

4. Type(s) of Habitat: The Project area consists of sandy beach, upland vegetation, intertidal habitat, and low-to-high relief patch reef.

5. Timing and Duration of Discharge: Dredging would be performed 24 hours a day, 7 days a week. Shore equipment would work 9 hours a day, 6 days a week. The Project duration is estimated at four months.

Construction is anticipated to begin in 2012.
f. Description of Disposal Methods: The proposed project will be constructed with hopper dredging equipment with pump ashore capability and conventional earthmoving equipment. At the receiver beach, the dredge will be attached to a moored floating section of pipeline extending 1,500 ft (457 m) to the shoreline. The material would be re-suspended and discharged through the on-board pumping 349
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system to the receiver site. Existing sand at the receiver site would be used to build a small, “L”-shaped berm to anchor the sand placement operations. The short side of the “L” would be transverse (crosswise) to the shoreline and would be the proposed width. The long side would be parallel to the shore at the seaward edge and would be approximately 200 ft (61 m) long. The slurry would be pumped onto the beach between this berm and toe. The berm reduces ocean water turbidity by allowing all the sand to settle out inside the bermed area while the seawater is channeled along the berm until it reaches the open end where it drains into the ocean. Temporary dikes within the berm will allow sand to settle in designated areas. Once a 200 ft (61 m) section of berm is filled in with sand, another 200 ft (61 m) of berm will be created, the pipeline will be moved or extended into the new berm area, and the process would begin again. As the material is deposited behind the berm, the sand would be spread using two bulldozers and one front-end loader to direct the flow of the sand slurry and form a gradual slope to the existing beach elevation.

III. Factual Determinations
A. Physical Substrate Determinations:

1. Substrate elevation and slope: Because of various seasonal cycles of sand deposition and erosion and the lack of adequate natural beach re-nourishment, the beach varies in width from 0 to 200 ft (0 to 60 m). The Proposed Project would construct a 50 ft (15 m) wide beach with a + 17 ft (+5.2 m) crest elevation along 3,412 ft (1,040 m) of beach in the Project area.

2. Sediment type: The beach in San Clemente is composed of fine to medium grained sands and silty sands. Material classification assumed is 10 percent fines, 83 percent sand and 7 percent gravel.

3. Dredged/fill material movement: Within the Project area, the beach width meanders from 0 ft wide to 76 ft (23 m) to 0 ft to 129 ft (39 m) and back to 0 ft along the reach.

4. Physical effects on benthos: The Project will alter topography by excavating soft bottom offshore of Oceanside and placing the sediment on the beach at San Clemente to widen the beach. Neither the relatively featureless ocean bottom offshore Oceanside nor the sand beach at San Clemente is a unique geologic feature. Excavation of sand offshore Oceanside would not result in a substantial modification of nearshore bathymetry. There may be temporary burial impacts in the nearshore area, including partial burial of T-Street reef in the inshore portions; however, this burial would be short term if it were to occur.

5. Actions taken to minimize impacts: There are no significant impacts to the physical substrate. No minimization measures are required. 350
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B. Water Circulation, Fluctuation, and Salinity Determinations

1. Water
a. Salinity
Salinity would not be altered by the proposed project.
b. Water chemistry
Water chemistry would not be altered by the proposed project. c. Clarity
Clarity would not be altered by the proposed project.
d. Color
Water color would not be altered by the proposed project. e. Odor
Water odor would not be altered by the proposed project. f. Taste
Water taste would not be altered by the proposed project. g. Dissolved gas levels
Dissolved gas levels would not be altered by the proposed project. h. Nutrients
Nutrients would not be altered by the proposed project. i. Eutrophication
Eutrophication would not be altered by the proposed project. j. Others as appropriate
No other water characteristics would be altered by the proposed project. 351
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2. Current patterns and circulation
a. Current patterns and flow:

The Project area is within the littoral zone where waves are the primary force in generating the alongshore currents that are responsible for moving sand, suspended by wave action, along the coast. Approximately 91 percent of the waves off San Clemente approach from the relatively narrow 20-degree band between 230º-240º, and all other approach directions are minor or negligible. This predominately westerly wave approach means that alongshore currents in the project area are mainly downcoast. b. Velocity:

The proposed project would not impact the velocity of the waves within the project area.
c. Stratification:

Because the proposed project occurs within a dynamic environment, there would be no impacts to stratification.
d. Hydrologic regime:

Because the proposed project occurs within ocean waters, the hydrologic regime would not be impacted.

3. Normal water level fluctuations: The proposed project would not alter normal water level fluctuations.

4. Salinity gradients: The proposed project would not alter salinity gradients.

5. Actions that will be taken to minimize impacts: The proposed project does not impact water circulation, fluctuation, or salinity; no actions are required to minimize impacts.

C. Suspended Particulate/Turbidity Determinations

1. Expected changes in suspended particulates and turbidity levels in vicinity of disposal site: Turbidity plumes generated during the discharge of offshore sediments to the receiver site have the potential to degrade nearshore waters.

However, turbidity plumes would be expected to be confined primarily to the naturally turbid surf zone and associated rip currents. Construction monitoring during the SANDAG project in San Diego County documented that beach fill operations generated turbidity plumes that ranged between 2,640 and 10,000 ft (800 and 3,000 m) and were greatly influenced by rip currents. The turbidity 352
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plumes remained in the surf zone unless rip currents carried them offshore (SANDAG 2002). The proposed project method of discharging the sediments behind an L-shaped berm allows fine particles to settle prior to introduction to the ocean and reduces the potential for nearshore turbidity. Because turbidity plumes generated during initial placement of sediments on receiver beaches would primarily be confined to the surf zone and rip currents, areas that are naturally turbid, degradation of coastal waters by turbidity from the proposed project would not be expected to occur.

2. Effects on chemical and physical properties of the water column:
a. Light penetration:

With the exception of temporary elevations of turbidity within the surf zone during discharge to the receiver site, the proposed project would not alter light penetration of the water column.
b. Dissolved oxygen:

Because of the dynamic environment of the project area, the proposed project would not alter dissolved oxygen levels in the water column. c. Toxic metals and organics:

The proposed project may introduce non-detectable to very low levels of toxic metals and organics; however the levels would be below all the thresholds in the Sediment Quality Guidelines.
d. Pathogens:

The proposed project would not introduce pathogens into the water column.
e. Aesthetics:

With the exception of temporary elevations of turbidity within the surf zone during discharge to the receiver site, the proposed project would not alter the aesthetics of the water column.
f. Others as appropriate
There are no other chemical or physical properties of the water column that would be affected by the proposed project.
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3. Effects on biota
a. Primary production, photosynthesis:

Although temporary elevations of turbidity within the surf zone during discharge to the receiver site may occur, the proposed project would not alter light penetration of the water column and, therefore, would not impact primary production or photosynthesis.
b. Suspension/filter feeders:

The effect of project related turbidity on local suspension and filter-feeding invertebrate and fish populations is unknown, but even complete loss would result in immediate recolonization, and impacts would be expected to be short-term and insignificant. Any appreciable turbidity increase may cause clogging of respiratory and feeding apparatus of sedentary bottom fish and filter feeders. Motile organisms, however, would evacuate and avoid the area and temporarily relocate to adjacent undisturbed areas. Most of the impacts would be confined to the immediate vicinity of disposal activities. Algae and non-motile marine invertebrates may experience higher localized mortality rates during rock placement. Those species currently inhibitory exposed surfaces would be destroyed, but new surfaces would be quickly recolonized. Most studies have found that the diversity, biomass, and abundance of sandy intertidal invertebrates declines following beach nourishment, but that the community recovers within a few months.
c. Sight feeders:

The proposed placement of sediments behind a dike would reduce the suspended sediment concentrations in the discharge. Turbidity plumes generated during beach fill operations at the receiver sites could interfere with foraging by visually-feeding birds such as gulls, terns, pelicans and cormorants. However, turbidity plumes would be expected to be confined primarily to the naturally turbid surf zone and associated rip currents.

Therefore, the impacts of turbidity from the discharge of sediments to receiver beaches would not be expected to be significant.

4. Actions taken to minimize impacts: The proposed project has been designed to minimize impacts by placing sandy material behind a berm before introduction to ocean waters. Impacts to biota are not expected to be significant; therefore, no further minimization efforts are required.

D. Contaminant Determinations: The sediments proposed for the beach fill have been tested and found to contain very low levels of contaminants. Contaminant concentrations of metals, pesticides, polychlorinated biphenyls (PCBs), polycyclic 354
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aromatic hydrocarbons (PAHs), phthalates, and phenols were non-detectible to low and well below all the thresholds in the Sediment Quality Guidelines. No dichlorodiphenyltrichloroethane (DDT) or chlorinated pesticides were detected in the samples.

E. Aquatic Ecosystem and Organism Determinations

1. Effects on plankton: Project related turbidity plumes would be expected to be confined primarily to the naturally turbid surf zone and associated rip currents No significant reduction in plankton is expected due to project generated turbidity.

2. Effects on benthos: Most of the benthic invertebrates within the area dredged from offshore Oceanside would be killed by the dredging. Some mobile organisms such as crabs may escape the dredge. Recovery of the benthic invertebrate community would be expected to begin almost immediately with settlement of larvae and immigration of mobile species from nearby unaffected areas. Recovery of the infaunal community to values comparable to predredging levels may occur in as little time as six months or as long as two years, with an average of about one year. Discharge of offshore sand onto receiver beaches would bury intertidal invertebrates living in the sand of receiver beaches. Most studies have found that the diversity, biomass, and abundance of sandy intertidal invertebrates declines following beach nourishment but that the community recovers within a few months. Therefore, the effects of beach nourishment on sandy intertidal invertebrates would be temporary and would not be expected to be significant.

3. Effects on nekton: Nearshore fishes are highly unlikely to be exposed to suspended sediment concentrations that would have lethal or sublethal effects.

Because the turbidity would be limited in extent and would be confined to the naturally turbid surf zone and rip current areas, significant impacts of turbidity to nearshore fishes are unlikely. Some fishes may avoid the turbid areas.

Temporary turbidity within a limited area in the vicinity of the surf zone would not have a discernible impact on the population of any fish species.

4. Effects on aquatic food web: As discussed above, impacts to the aquatic food web are expected to be temporary and insignificant.

5. Effects on special aquatic sites:
a. Sanctuaries and refuges:

There are no sanctuaries or refuges on the project site. 355
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b. Wetlands:

There are no wetlands on the project site.
c. Mud flats:

There are no mudflats on the project site.
d. Vegetated shallows:

Special aquatic sites in the project area include surfgrass beds and kelp beds. The sand placement footprint does not include any kelp beds, surfgrass, or rocky intertidal areas. Therefore, no direct impacts to sensitive habitats would occur from the placement of sand on the beach. In addition, the Proposed Project would not place anchors for the monobuoy, where the hopper dredge will moor while it discharges sand to the beach, or place the sinker pipeline that will pump the sediment to shore from the hopper dredge on any sensitive habitat. The Project also will avoid side to side movement of the anchors or pipeline as they are placed, which could abrade surfgrass, algae, or attached invertebrates. Sediment placed on the beach may gradually move offshore and downcoast. The nearest kelp bed is located 1,200 ft (360 m) offshore of the San Clemente Beach fill area.

Because most of the surfgrass in the Project area grows on T-Street reef, it is possible to avoid surfgrass by avoiding the reef when laying the pipeline.

In addition, to avoid impacts to reefs that support kelp and other sensitive species such as gorgonians and surfgrass, the hopper dredge should moor inshore of these reefs, which are located approximately 1,000 to 1,300 ft (300 to 400 m) from the beach. Based on beach profile monitoring of a similar volume of fill at Oceanside and a previous analysis for a lower volume of fill near San Clemente Pier, very little of the sand placed on the beach at San Clemente would be expected to migrate offshore into the kelp beds. The only significant surfgrass in the project area is at T-Street Reef in the surfzone. Because of the high wave energy in this area, any sand from the beach fill that was moved into the T-Street surfgrass bed would be expected to be rapidly resuspended and moved downcoast by wave action.

However, if impacts to surfgrass in this area are observed, mitigation will be implemented as described in the Biological Resources Monitoring Plan (Appendix B of the EIS/EIR).
e. Coral reefs:

There are no coral reefs on the project site.
f. Riffle and pool complexes:

There are no riffle and pool complexes on the project site. 356
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6. Threatened and endangered species:

There are no federal or state listed taxa that would use or inhabit the project site during project implementation and no habitat is present. There is no designated critical habitat on the site. No proposed or endangered species are expected to be present on the site and there is no proposed critical habitat on the site.

7. Other wildlife:

The greater amount of sand on San Clemente Beach following beach nourishment would be expected to have a beneficial effect on shorebird birds in a marine environment by increasing resting habitat. Several beach nourishment projects have documented greater use of the beach for resting by a variety of birds such as gulls, shorebirds, and other larids following the placement of sand on the beach. The increased sand beach also may increase foraging opportunities for shorebirds that feed on sandy intertidal invertebrates.

The Corps continues on-going coordination with USFWS regarding biological impacts and mitigation in compliance with the Fish and Wildlife Coordination Act. The USACE met with resource agencies, including the USFWS, on several occasions, to discuss the proposed project and alternatives. Other invitees and attendees included NOAA Fisheries and CDFG. The main topics of discussion included the proposed project, project alternatives, and potential environmental issues.

8. Actions to minimize impacts: The proposed project has been designed to minimize impacts by placing sandy material behind a berm before introduction to ocean waters. Impacts to the aquatic ecosystem and organisms are not expected to be significant; therefore, no further minimization efforts are required.

F. Proposed Disposal Site Determinations

1. Mixing zone determination:

Discharge will be onto the beach behind a berm not into the water column.

The berm will tend to trap particles but some of the water will run back into the surf zone temporarily generating turbidity. Construction monitoring during a similar beach nourishment project in San Diego County documented that beach fill operations generated turbidity plumes that ranged between 2,640 and 10,000 ft (800 and 3,000 m) and were greatly influenced by rip currents. The turbidity plumes remained in the surf zone unless rip currents carried them offshore.
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2. Determination of compliance with applicable water quality standards

3. Potential effects on human use characteristic:
a. Municipal and private water supply:

The proposed project would have no effect on municipal or private water supplies or water conservation.
b. Recreational and commercial fisheries:

On shore construction may temporarily interfere with shore fishing activities in the immediate project area. Offshore construction operations (i.e., vessel traffic and dredging) may potentially conflict with local commercial fishing operations during winter months, including gear/equipment damage and the disruption of fishing locations. Thirty days prior to the start of construction, the local commercial fishermen’s association shall be provided with written notification of the intended start date of on shore construction, offshore construction, maps of projectrelated vessel transportation routes, and its duration. Noticing shall include a point of contact throughout the entire construction phase to respond to concerns regarding interference and/or other issues associated with local commercial fishing operations. Impacts would be considered less than significant.
c. Water related recreation:

During the beach construction, portions of the beach, nearshore zone, and potentially the Pier would be closed to public use. Impacts would be temporary (up to four months) During dredging and nourishment activities, proper advanced notice to mariners would be obtained and navigational traffic would not be allowed within the offshore borrow site area or mooring/discharge area. In addition, signage would be provided to inform swimmers of potential hazards. The beach closure would prevent surfers from accessing the beach near the Pier. Recreational users would be required to visit a different beach or different portions of the beach during the closure periods. The displacement of recreational users to the various nearby beaches would be temporary and short-term. However, the proposed project would not impact surfing conditions or other water sports once completed.

In the long-term, the beach nourishment would create a wider beach area and greater opportunities for beach activities, enhancing the beach available for recreation users. The wider beach would be a benefit to beach 358
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recreation users. Long-term maintenance activities would create similar impacts as the initial construction.
d. Aesthetics:

The proposed project would result in a wider beach, which would be a minor alteration of the visual character of the existing environment.

During the construction phase, the visual character of the site would be affected by construction activities and the presence of construction equipment and materials; however, the construction phase is temporary, and as such, would not result in permanent effects to the visual character of the site. In the long term, the resulting wider beach would enhance the view of the beach and result in a visual benefit. Long-term maintenance activities would create similar impacts as the initial construction. e. Parks, National and historical monuments, National seashores, wilderness areas, research sites, and similar preserves:

The proposed project would have temporary construction impacts to San Clemente City Beach, but in the long-term would enhance the beach by providing a wider sandy beach. The proposed project would not have any effect on national and historic monuments, national seashores, wild and scenic rivers, wilderness areas or research sites.

G. Determination of cumulative effects on the aquatic ecosystem: All the potential effects of the project would occur at the site. No indirect offsite effects are anticipated. The Proposed Project would not cause downcoast erosion. The only cumulative project that has the potential to interact with the proposed project is the Dana Point Dredging Project, which would place about 83,000 cubic yards of sediment dredged from the harbor either on Capistrano Beach or in the nearshore zone off of Capistrano Beach. The discharge of sediment from the Dana Point Harbor Dredging project to Capistrano Beach will act cumulatively with the proposed action to add sediment to the Oceanside littoral cell. The proposed action will act in a cumulative fashion with the Dana Point Harbor Dredging project to offset erosion on beaches in south Orange County and northern San Diego County. Most of the sediment from these projects is expected to accumulate on downcoast beaches or in the very shallow nearshore area between the foreshore and the bar. Beach fill would be deposited onshore and would be expected to move offshore in a manner that would not alter the wave characteristics of popular surf breaks, such as T-Street, and would not be expected to affect Wheeler J. North Reef approximately 3,200 ft seaward of the proposed project footprint.

Like the proposed action, the Dana Point Harbor Dredging project would discharge sediments to the beach or nearshore zone and thus may cause a temporary localized increase in turbidity in nearshore waters. The discharge of sediments from Dana Point Harbor dredging would occur at Capistrano Beach approximately 4 miles (6.4 359
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km) from the proposed action. Even if the projects occurred at the same time, the turbidity plumes would be sufficiently distant that they would not interact with each other. Monitoring of turbidity and adjustment of operations to avoid extensive turbidity plumes would mitigate any cumulative impacts of turbidity from these projects. The incremental addition of a portion of a smaller amount of sediment discharged over 4 mi (6.4 km) upcoast is unlikely to add sufficient sediment to affect surfgrass or shallow reefs in the San Clemente area.

The Proposed Project will not have any indirect effects on the human environment.

Impacts of the Proposed Project on the human environment include temporary impacts to air quality, transportation, noise, recreation, aesthetics, navigation, and public safety during construction. The only project that would act cumulatively with the Proposed Project on the human environment would be the Dana Point Dredging Project if it occurred simultaneously with the Proposed Project. Because the Dana Point Dredging Project would be 4 miles upcoast from the Proposed Project and because construction of both projects would be temporary, the cumulative effects of these two projects on the human environment would be negligible.

There have been no previously permitted cumulative actions on the site. The proposed sediment source area offshore of Oceanside was used to supply sand to San Diego beaches for the SANDAG project. The San Onofre Nuclear Generating Station Kelp Reef Project involved construction of a reef of quarry rock offshore San Clemente in the summer of 2008. The San Onofre Nuclear Generating Station Kelp Reef Project occurred offshore the Proposed Project. Because construction of these two projects would occur at different times, there would be no cumulative construction impacts. The San Onofre Nuclear Generating Station Kelp Reef would be too far offshore from the Proposed Project to be affected by sediment placed on San Clemente Beach.

H. Determination of secondary effects on the aquatic ecosystem: Impacts of the Proposed Project are all temporary construction impacts. Significant impacts to sensitive species are avoided. Other temporary construction impacts are minimized by the design features and environmental commitments of the Proposed Project.

Findings of Compliance
A. Adaption of the Section 404(b)(1) Guidelines to this Evaluation: No significant adaptations of the guidelines were made relative to this evaluation.

B. Evaluation of Availability of Practicable Alternatives to the Proposed Discharge Site Which Would Have Less Adverse Impact on the Aquatic Ecosystem: Section 3.2 of the EIS/EIR identifies the measures that were considered, but not carried forward for the project, including the various (5 m to 35 m) scales of beach nourishment not discussed further in the EIS/EIR. Sections

3.3 and 3.4 of the EIS/EIR discuss the beach nourishment alternative and the 15 m and 35 m scales of beach nourishment. There are no alternative disposal methods 360
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available for this project which would be 1) more consistent with the project authorization that mandates disposal into the littoral drift system, or 2) have a less environmentally damaging resultant.

C. Compliance with Applicable State Water Quality Standards: To satisfy requirements of the Federal CWA, the Corps will submit this Final EIS/EIR and appropriate technical documentation to the San Diego RWQCB, tasked with implementing the CWA within the region, for their review for CWA Section 401 certification, pursuant to 33 CFR 336.1(a)(1). Upon review of the submittal, the RWQCB would issue a 401 certification. The Corps will continue to coordinate with the RWQCB throughout the CWA process and construction activities.

D. Compliance with Applicable Toxic Effluent Standard or Prohibition Under Section 307 of the Clean Water Act: No toxic materials are known or likely to occur in the project area.

E. Compliance with Endangered Species Act of 1973: Formal consultation was not required with the USFWS under the ESA because the Corps, as the action agency, made a no effect determination and is avoiding all federal listed taxa.

However, under Section 7(a)(2) of the ESA, Federal agencies must consult with Federal resource agencies (i.e., USFWS, NOAA Fisheries) and prepare a Biological Assessment (BA) if listed species and/or critical habitat are present in an area to be impacted by Project activity. The USFWS and/or NOAA Fisheries then would prepare a Biological Opinion (BO) on how the action would affect the species and/or its critical habitat, and would suggest reasonable and prudent measures to avoid jeopardizing the continued existence of the species or adversely modifying its critical habitat. If prior to and/or during construction it is determined that Federal endangered and threatened species would be adversely impacted, the USACE would initiate Section 7 consultation.

F. Compliance with Specified Protection Measure for Marine Sanctuaries Designated by the Marine Protection, Research, and Sanctuaries Act of 1972:

No sanctuaries as designated by the Marine Protection, Research and Sanctuaries Act of 1972 will be affected by the proposed project.

G. Evaluation of Extent of Degradation of the Waters of the United States

1. Significant adverse effects on human health and welfare:
a. Municipal and private water supplies
The proposed project will have no significant adverse effects on municipal and private water supplies.
b. Recreation and commercial fisheries
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The proposed project will have no significant adverse effects on recreation and commercial fisheries.
c. Plankton
The proposed project will have no significant adverse effects on plankton. d. Fish
The proposed project will have no significant adverse effects on fish. e. Shellfish
The proposed project will have no significant adverse effects on shellfish. f. Wildlife
The proposed project will have no significant adverse effects on wildlife. g. Special aquatic sites
The proposed project will have no significant adverse effects on special aquatic sites.

2. Significant adverse effects on life stages of aquatic life and other wildlife dependent on aquatic ecosystems: The proposed project will have no significant adverse effects on life stages of aquatic life and other wildlife dependent on aquatic ecosystems.

3. Significant adverse effects on aquatic ecosystem diversity, productivity, and stability: The proposed project will have no significant adverse effects on aquatic ecosystem diversity, productivity, and stability.

4. Significant adverse effects on recreational, aesthetic, and economic values:

The proposed project will have no significant adverse effects on recreational, aesthetic, and economic values.

H. Appropriate and Practicable Steps Taken to Minimize Potential Adverse Impacts of the Discharge on the Aquatic Ecosystem
Avoidance
o Beach fill will avoid the grunion spawning season since there will be no construction during this time period. However, if beach fill would to occur during the grunion spawning season of March to August, a qualified biologist shall observe the receiver beach during all predicted grunion runs and mark areas 362
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where grunion spawning occurs. All beach construction activities shall avoid these designated spawning areas until the next predicted high tide series to allow grunion eggs to hatch.
o Beach nourishment will avoid the least tern nesting season by implementing the project outside the season. The least tern nesting season is April 15 to September 15; nearest colony is 15 miles south (down coast) of the Project site. o Prior to construction, offshore borrow areas 1 and 2 will be subjected to an underwater remote sensing survey in order to determine if submerged cultural resources are present within these areas. If cultural resources are indicated, dredging will avoid those areas.
o To avoid public safety impacts to beach goers, the contract specifications shall require the contractor to fence/secure areas of construction from public access, including construction staging areas and active construction areas, including the beach and nearshore zone.

Minimization
o To minimize air quality impacts, use Best Available Control Technology during construction.
o To minimize turbidity, discharge sediments to the beach behind L-shaped berms. o To minimize turbidity, monitor turbidity during sediment discharge and if significant turbidity is observed, modify operations (such as by slowing rate of discharge) until turbidity abates
o To minimize potential for contaminant leaks and spills during construction, prepare and adhere to a Storm Water Pollution Prevention Plan and Oil Spill Response Plan.
o To minimize noise impacts, limit construction activities to less than 9 hours per day.
o To minimize navigation impacts and threats to vessel safety, the dredge would be equipped with markings and lightings in accordance with the U.S. Coast Guard regulations. The location and schedule of the dredge would be published in the U.S. Coast Guard Local Notice to Mariners. The dredge would travel at very low speeds (approximately 1.5 knots) during dredging operations. The travel speed during transport would be approximately 5 knots. During dredging and nourishment activities, proper advanced notice to mariners would be obtained, and navigational traffic would not be allowed within the offshore borrow site area or mooring/discharge area offshore of Oceanside.
o To minimize conflicts with fishermen, the local commercial fishermen’s association shall be provided with written notification of the intended start date of on shore construction, offshore construction, maps of project-related vessel transportation routes, and its duration. Noticing shall include a point of contact throughout the entire construction phase to respond to concerns regarding interference and/or other issues associated with local commercial fishing operations.

Compensation
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o Mitigation would be triggered only if conditions observed during the monitoring period reach thresholds identified in the monitoring plan and persist through the two year post-construction monitoring period, as there may be transitory effects and subsequent recovery.
o If significant impacts to surfgrass and reef habitat are observed, renourishment events would be modified to avoid impacts. Although several studies currently are being conducted to successfully transplant surfgrass and may show potential for success, to date success rates have not been consistent and studies are ongoing. Mitigation will be based on the results of monitoring conducted before and after sand placement, as identified in the Mitigation Plan in Appendix B of the EIS/EIR. The Corps will coordinate these efforts with the resource agencies.

I. On the Basis of the Guidelines, the Proposed Disposal Sites(s) for the Discharge of Dredged or Fill Material is
Specified as complying with the requirements of these guidelines; or, _ Specified as complying with the requirements of these guidelines, with the inclusion of appropriate and practical conditions to minimize pollution or adverse effects on the aquatic ecosystem; or,
Specified as failing to comply with the requirements of these guidelines. 364

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APPENDIX B – BIOLOGICAL RESOURCES MONITORING PLAN
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Rocky Reef/Surfgrass Monitoring, Mitigation, and Reporting Plan Rocky Reef/Surfgrass Habitat
This appendix outlines 1) a pre- and post-construction monitoring program for rocky reef/surfgrass habitat in the San Clemente Pier area (Reach 6) to determine if project mitigation would be necessary; 2) a preliminary mitigation implementation plan, if mitigation is determined to be necessary; and 3) a preliminary mitigation monitoring plan, if mitigation is determined to be necessary. The final monitoring plan will be prepared during the pre-construction engineering design (PED) phase of the project. The details of these plans will be finalized in conference with knowledgeable, experienced, and qualified marine ecologists. The monitoring shall be performed by knowledgeable, experienced, and qualified marine biologists. These knowledgeable, experienced, and qualified marine ecologists may come from a variety of various agencies, organizations, institutions, or community centers of practice and expertise, such as academia - University of California, Corps Engineer Research and Development Center (ERDC), NOAA National Marine Fisheries Southwest Fisheries Sciences Center, USGS Western Ecological Research Center, other federal and state agencies, as well as consulting marine ecologists. CDFG, FWS, and NMFS regulatory resources agency staff will also be involved with the review process.

Pre- and Post-Construction Monitoring Plan
The Proposed Project has been designed to avoid or minimize impacts to sensitive biological resources to the maximum extent practicable. Currently, potential project impacts have been identified using a conservative coastal engineering model. The nature of the coastal engineering model has uncertainties due to multiple variables within the natural environment. Impacts to rocky reef and surfgrass reef are expected to be none to very minor, but currently are unknown.

A post-construction monitoring strategy has been developed to determine if the project results in permanent loss of either rocky reef and/or surf grass. Based on the model, it is estimated that in a worst case about 20 percent of the reef or 1 acre may be impacted by the beach fill. For the purpose of costing, it is assumed that 1 acre of surfgrass and an additional 1 acre of reef without surfgrass could be impacted and require compensatory mitigation.

Mitigation would be triggered only if certain conditions occur during, and persist through, the two year post-construction monitoring period, as there may be transitory effects and subsequent recovery that would not be apparent in a shorter period of time. Persist means that observed sand burial of reef and/or loss of surfgrass continues to be significantly different on T-street reef compared to controls in all monitoring periods after the initial observed effect. During the two year post-construction monitoring, the reference site will be monitored to assess the natural variation, if possible, in rocky reef and surfgrass reef. Other published and unpublished literature will also be used in this analysis.

The following criterion is suggested as a potential trigger for implementing the potential mitigation.
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• A persistent decrease in surfgrass cover or surfgrass density and an increase in sand cover and/or depth that is statistically significantly different than the controls and the baseline at the 0.05 confidence level (i.e., p-value = 0.05).

Actual triggers would be determined in coordination with knowledgeable, experienced, and qualified marine biologists and specific resource agencies prior to initiation of post-construction monitoring activities. These knowledgeable, experienced, and qualified marine ecologists may come from a variety of various agencies, organizations, institutions, or community centers of practice and expertise, such as academia - University of California, Corps Engineer Research and Development Center (ERDC), NOAA National Marine Fisheries Southwest Fisheries Sciences Center, USGS Western Ecological Research Center, other federal and state agencies, as well as consulting marine ecologists. CDFG, FWS, and NMFS regulatory resources agency staff will also be involved with the review process.

Proposed Pre- and Post-Construction Monitoring Activities Prior to the implementation of the monitoring program, the extent of reef habitat throughout the entire predicted equilibrium footprint for the project will be mapped using side scan sonar or another appropriate method. This information will be used in the Monitoring Plan to establish transect lines.

Transects shall be established in the rocky reef area containing the surfgrass bed on T-Street reef (Project area) and in a control area of similar depth upcoast of the beach fill near Mariposa Point.

Mariposa Point is considered an appropriate control because 1) it is close to the Project area and thus subjected to a similar wave climate, 2) supports surfgrass at a range of depths similar to TStreet reef, and 3) is upcoast of the beach fill out of the path of littoral drift, which is strongly downcoast in the San Clemente area. The transects shall be permanent transects with repeated use during all monitoring stages. Transects should cover, at a minimum, the inshore portion, middle, and offshore portion of the reef. The same number of transects should be established in the control area as in the T-Street reef area and the transects should be at similar depths. On each transect, the following parameters should be monitored at a minimum: 1) surfgrass density (i.e., number of shoots per square meter), 2) percent cover of surfgrass, sand, and rock, and 3) sand depth. The line intercept method is recommended for measuring percent cover and sand depth.

Transects should be monitored at the following intervals:

Pre-project monitoring (two years previous to beach nourishment):
- Twice within winter/spring
- Twice within summer/fall
Pre-project baseline monitoring (one year previous to beach nourishment):
- within one month prior to start
- 3 months prior to start
- 6 months prior to start
- 1 year prior to start
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Post-construction:

Year One
- within one month after completion
- 3 months after completion
- 6 months after completion
- 1 year after completion
Year Two
- Twice within winter/spring
- Twice within summer/fall
Biological resources within the project area identified as potentially being impacted include surfgrass patches and rocky reef habitat at T-Street. Because a survey was not conducted to delineate the T-street reef, the general area of the T-street reef was based on the outer extent of mapped surfgrass locations (approximately 5 acres). Actual delineation of the T-street reef will need to be identified prior to the pre-construction survey. This survey would use side scan sonar or another appropriate methodology to delineate T-street reef and other reef habitat within the potential equilibrium footprint of the sand placement. Potential project impacts to these resources were based on modeling that indicates sand movement may extend to the offshore/outer edge of the reef; however, sand at the offshore/outer edge of the reef would be thin and not significant. Potential burial of the inshore edge of T-Street reef is uncertain; however, in a reasonable worst case scenario, approximately 20 percent of the inshore edge of the T-Street reef area (about 1 acre) may be buried. These knowledgeable, experienced, and qualified marine ecologists may come from a variety of various agencies, organizations, institutions, or community centers of practice and expertise, such as academia - University of California, Corps Engineer Research and Development Center (ERDC), NOAA National Marine Fisheries Southwest Fisheries Sciences Center, USGS Western Ecological Research Center, other federal and state agencies, as well as consulting marine ecologists. CDFG, FWS, and NMFS regulatory resources agency staff will also be involved with the review process. If significant impacts to these biological resources are observed, renourishment events would be modified to avoid or minimize impacts to the extent practicable and project mitigation would be implemented.

Pre- and Post-Construction Monitoring Costs
Pre-construction Monitoring
This cost assumes that permanent transects will be established. One day is allotted to install the markers and up to four days to conduct the survey at both the reference site and T-street reef, taking into consideration the wave environment in the project area and assuming three transects.

This survey is assumed to occur within one year prior to construction activities. a. Side-scan sonar survey $200,000
b. Pre-construction Monitoring:
(two years prior to beach nourishment):
o Twice within winter/spring; Twice within summer/fall: $131,000 370
B-5
c. Pre-construction Baseline Monitoring:
(one year prior to beach nourishment):
o 4 events (one month, 3 months, 6 months, 1 year) $120,000 d. Pre-construction Report (2 years prior and 1 year prior) $ 10,000 Subtotal $461,000
Post-Construction Monitoring
This cost assumes that permanent transects will be established. One day is allotted to find or reinstall the markers and up to four days to conduct the survey at both the reference site and Tstreet reef, assuming three transects. a. Year One
o 4 events (one month, 3 months, 6 months, 1 year): $120,000 b. Year Two
o Twice within winter/spring; Twice within summer/fall: $ 131,000 c. Post-construction Report (Years One and Two) $ 10,000 Subtotal $261,000
Renourishment Pre- and Post-Construction Surveys
A standardized and consistent survey protocol will be developed during the PED phase for future beach renourishment cycles. The information collected from monitoring during the initial nourishment event will provide baseline information to compare future beach conditions.

Because baseline information will be readily available for the Project site, the survey protocol for renourishment activities will focus on a single pre- and post-construction survey rather than the monitoring period proposed for initial nourishment activities.

Project Mitigation
If mitigation were required based on results of the post-construction monitoring, rocky reef and surfgrass mitigation shall each be conducted at an equivalent functional value to the impacted area. Because it will take at least two years to identify impacts, some temporal loss of surfgrass, if impacts were to occur, is unavoidable. Recovery of impacted resources will also occur as sand is redistributed within the littoral cell. Additionally, if impacts were to occur, future beach fills would be modified to avoid future impacts; any observed burial of reef or surfgrass would be temporary because sand would be expected to move out of the project area.

Reef habitat mitigation shall be constructed at an equivalent functional value of shallow and deep water reef proportional to the area of surfgrass on reef impacted. The area of surfgrass loss will be mitigated with an equal area of shallow water reef; the area of reef without surfgrass will be mitigated as deep water reef. Shallow water reef would be constructed on the offshore/outer edge of the existing reef; deep water reef would be constructed at approximately 30 foot water depth. Shallow water reef shall be constructed with a final top elevation of -10 to -14 feet Mean Lower Low Water. Construction of a reef that is shallower than the outer edge of T-Street reef is not proposed because construction methods would not be practical (e.g., a barge with the reef 371
B-6
construction materials would not be able to operate in very shallow water). Construction of a very shallow reef would need to be constructed by building a temporary road from shore; such a road would have significant impacts. Although the surfgrass mitigation reef would be deeper than the impact area, if surfgrass transplants are successful, the slightly deeper reef would replace the lost surfgrass resource. Deep water reef shall be constructed similar to the Southern California Edison Reefs constructed as mitigation for the impacts of the San Onofre Nuclear Power Plant. For example, if the monitoring shows 1 acre of reef impact and 1 acre of surfgrass impact, 1 acre of shallow water reef would be constructed and 1 acre of deep water reef.

Mitigation would be implemented in the Project area at sites to be determined in coordination with knowledgeable, experienced, and qualified marine biologists. These knowledgeable, experienced, and qualified marine ecologists may come from a variety of various agencies, organizations, institutions, or community centers of practice and expertise, such as academia - University of California, Corps Engineer Research and Development Center (ERDC), NOAA National Marine Fisheries Southwest Fisheries Sciences Center, USGS Western Ecological Research Center, other federal and state agencies, as well as consulting marine ecologists.

CDFG, FWS, and NMFS regulatory resources agency staff will also be involved with the review process.

Although several studies currently are being conducted to determine how to successfully transplant surfgrass and may show potential for success, success rates to date have not been consistent. Due to the absence of an established, successful method for mitigation of loss of surfgrass itself, proposed mitigation currently is focused upon restoration of the rocky reef that surfgrass currently uses as habitat. However, as previously described, if it is determined that surfgrass has been affected by the Project and a change is shown not to be due to natural variation, an experimental surfgrass transplant shall be implemented in addition to the construction of a shallow rocky reef. Currently, surfgrass transplant success is much higher for subtidal than for intertidal conditions and, therefore, surfgrass mitigation efforts for this project will focus on subtidal transplants only. The methodology for the surfgrass transplant shall be the transplant of sprigs from a donor bed to the new reef using the method developed by Bull et al. (2004). The contractor may propose an alternative transplant method, if evidence can be presented that the alternative method has as great or greater chance of success as the sprig transplant method. To avoid harvesting effects to the subject surfgrass bed, donor material will be taken from a larger area of surfgrass.

A fraction of the shallow water reef shall be test planted with surfgrass. The transplant will be conducted in the late summer/early fall, the time of year when most surfgrass seeds are released and germinate in southern California.

An area equal to approximately 25 percent of the surfgrass impact area (not to exceed 0.1 acre) will be test planted. Success of the transplant shall be determined after six months based on survivorship, percentage change in the number of leaves and the amount of areal coverage. The experimental transplant will be considered successful if the sprigs survive and there is a net increase in number of leaves and aerial coverage. Experimental surfgrass transects have shown that if the transplant is not successful, the transplants die and the reef is bare. If the transplants survive, surfgrass grows. If the test transplant is successful, the remainder of the surfgrass impact area will be planted on the shallow water reef with surfgrass. If the test transplant is 372
B-7
unsuccessful, mitigation will be conducted out of kind using kelp transplant on the deep water reef at an equivalent functional value; one acre, in the case of the costed scenario.

Project Mitigation Monitoring Plan
Similar to the Post-Construction Monitoring Plan, transects shall be established in the rocky reef area containing the surfgrass bed on the mitigation reef (if the experimental surfgrass transplant is successful) and in a reference site (control area) of similar depth upcoast near Mariposa Point.

The transects shall be permanent transects. The same number of transects should be established in the control area as in the mitigation areas and transects should be at similar depths. On each surfgrass transect, the following parameters should be monitored at a minimum: 1) surfgrass density (i.e., number of shoots per square meter), 2) percent cover of surfgrass, sand, and rock, 3) sand depth, and 4) identification and quantity of flora and fauna. The line intercept method is recommended for measuring percent cover and sand depth.

Transects should be monitored at the following intervals, if successful:

Post-mitigation implementation:

Year One
- within one month after completion
- 3 months after completion
- 6 months after completion
- 1 year after completion
Years Two through Five
- Once within winter/spring
- Once within summer/fall
Success Criteria
Success criteria of surfgrass would include determining if measured parameters are significantly different than the reference transects. Success criteria for the mitigation reef itself would include no complete permanent burial of the reef. Because of the predominantly sandy bottom environment in the project area, placement of the deep water rocky reef would be considered successful if a characteristic invertebrate and fish community were to become established. On each surfgrass transect, the following parameters should be monitored and evaluated at a minimum: 1) surfgrass density (i.e., number of shoots per square meter), 2) percent cover of surfgrass, sand, and rock, 3) sand depth, and 4) identification and quantity of flora and fauna.

The line intercept method is recommended for measuring percent cover and sand depth. Specific success criteria will be developed during the Preconstruction, Engineering and Design (PED) phase. General success criteria will consist of the following:

1. Approximately 50% - 60% of the fish, invertebrates, and algae found at the reference site occur at the mitigation site two years post-mitigation.

2. Approximately 50% - 60% of surfgrass survival at the mitigation site two years postmitigation implementation. 373
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Project Mitigation Monitoring Costs
Reef Construction and Transplant Costs
Costs for reef construction and transplant costs would be based on actual impacts. The estimated costs for one acre of shallow surfgrass reef and one acre of deep water reef are provided below for reference. This scenario assumes successful test transplant operations. If test transplant operations are not successful, then compensatory mitigation would be triggered.

Shallow water reef design and construction (1 acre) $2 million

Deep water reef construction (1 acre) $500,000
Surfgrass transplant (1 acre)
Test (0.1 acre) $25,000
Mitigation – if Test successful (0.9 acre) $225,000
Subtotal (test successful) $2,750,000

Deep water reef construction (1 acre) $500,000

Surfgrass transplant (1 acre)
Test (0.1 acre) $25,000
Subtotal (test not successful) $525,000
Project Mitigation Monitoring Activities
a. Year One $120,000
o after implementation - 4 events (one month, 3
months, 6 months, 1 year)
b. Year Two $65,500
o 2 events (once within winter/spring; once within
summer/fall)
c. Annual Report Years One and Two $5,000
Subtotal (test successful) $190,500
Compensatory Mitigation
If the surfgrass test planting is not successful, then out-of-kind and potentially off-site compensatory mitigation that has an equivalent functional value to the area of surfgrass on reef impacted is to occur via kelp planting on the deep water reef constructed during the previous project mitigation. Using the example of 1 acre of reef impacts and 1 acre of surfgrass impacts, if the surfgrass transplant is not successful, 1 acre of kelp will be planted on the 1 acre of deep water reef built during the project mitigation. All mitigation for kelp shall be monitored for 5 years.
374
B-9
Compensatory Mitigation Monitoring Plan
Similar to the Post-Construction Monitoring Plan, transects shall be established in the rocky reef area containing the kelp bed on the deep water mitigation reef (if the surfgrass transplant is unsuccessful) and in a reference site (control area) of similar depth upcoast near Mariposa Point.

The transects shall be permanent transects. The same number of transects should be established in the control area as in the mitigation areas and transects should be at similar depths. On each kelp transect, the following parameters should be monitored at a minimum: 1) kelp density (number of kelp plants per square meter) of each age class, 2) holdfast diameter of each adult kelp plant on the transect, 3) number of stipes of each adult kelp plant on the transect and 4) identification and quantity of associated flora and fauna.

Transects should be monitored at the following intervals:

Post-compensatory mitigation implementation:

Year One
- within one month after completion
- 3 months after completion
- 6 months after completion
- 1 year after completion
Years Two through Five
- Once within winter/spring
- Once within summer/fall
Success Criteria
Success criteria of kelp would include determining if the measured parameters are significantly different than the reference transects. Success criteria for the mitigation reef itself (if it is not planted with kelp) would include no complete permanent burial of the reef. Because of the predominantly sandy bottom environment in the project area, placement of the deep water rocky reef would be considered successful if a characteristic invertebrate and fish community were to become established. On each kelp transect, the following parameters should be monitored and evaluated at a minimum: 1) kelp density (number of kelp plants per square meter) of each age class, 2) holdfast diameter of each adult kelp plant on the transect, 3) number of stipes of each adult kelp plant on the transect and 4) identification and quantity of associated flora and fauna.

Specific success criteria will be developed during the Preconstruction, Engineering and Design (PED) phase. General success criteria will consist of the following:

1. Approximately 50% - 60% of the fish, invertebrates, and algae found at the reference site occur at the mitigation site two years post-mitigation.

2. Approximately 50% - 60% of kelp survival at the mitigation site two years postmitigation implementation. 375
B-10
Compensatory Mitigation Installation/Implementation Costs Kelp Transplant Costs
Costs for transplant costs would be based on actual impacts. The costs of reef construction are included above in Project Mitigation for the surfgrass mitigation. This assumes the shallow water reef and deep water reef that were constructed during the Project Mitigation will not be removed; the costs for the compensatory mitigation would be in addition to the Project Mitigation costs above. The estimated costs for a one acre kelp transplant are provided below for reference. This scenario assumes unsuccessful test surfgrass transplant operations.

Kelp Transplant (1 acre) $50,000
Subtotal (test unsuccessful) $50,000
Compensatory Mitigation Monitoring Activities (Only if test transplant is unsuccessful and deep water rocky reef is constructed)
a. Year One $120,000
o after implementation - 4 events (one month, 3
months, 6 months, 1 year)
b. Year Two $65,500
o 2 events (once within winter/spring; once within
summer/fall)
c. Annual Report Years One and Two $5,000
Subtotal (test unsuccessful) $190,500

376
B-11
Summary of Pre and Post Construction Monitoring
Activity Cost
Pre-construction monitoring
Side-scan sonar1 [$200,000]
2 years prior to construction - 4 events $131,000
1 year prior to construction – 4 events $120,000
Pre-construction report $10,000
Subtotal $261,000
Post-construction monitoring
Year 1 – 4 events $120,000
Year 2 – 4 events $131,000
Post-construction report $10,000
Subtotal $261,000
Total Pre and Post Construction Monitoring2 $522,000
1 = Side scan sonar is already within coastal engineering monitoring and it will be completed and shared data 2 = the pre and post monitoring costs are not part of the mitigation costs; they are scheduled for implementation whether mitigation is necessary and implemented or not necessary and therefore not implemented. 377
B-12
Summary of Mitigation and Monitoring Costs
Mitigation and Monitoring - Surfgrass
1 acre shallow reef construction $2,000,000
1 acre deep reef construction $500,000
1 acre surfgrass transplant
Test (0.1 acre) $25,000
Mitigation – if test successful (0.9 acre) $225,000
Year 1 monitoring - 4 events (if test successful) $120,000 Year 2 monitoring - 2 events (if test successful) $65,500 Report (if test successful) $5,000
Subtotal $2,940,500
Mitigation and Monitoring - Kelp
1 acre shallow reef construction $2,000,000
1 acre deep reef construction $500,000
1 acre surfgrass transplant
Test (0.1 acre) $25,000
1 acre kelp transplant (if test not successful) $50,000 Year 1 monitoring - 4 events (if test not successful) $120,000 Year 2 monitoring - 2 events (if test not successful) $65,500 Report (if test not successful) $5,000
Subtotal $2,765,500
Summary Mitigation and Monitoring Cost3
Mitigation – Surfgrass successful (Transplant
Surfgrass)
$2,940,500
Mitigation – Surfgrass not successful (Transplant
Kelp)
$2,765,500
3 = The cost for the Mitigation – Surfgrass successful (Transplant Surfgrass) includes the cost of constructing both shallow and deep rocky reef as does Mitigation – Surfgrass not successful (Transplant Kelp). 378
FINAL

JOINT ENVIRONMENTAL IMPACT STATEMENT/

ENVIRONMENTAL IMPACT REPORT

APPENDICES
Volume II

SAN CLEMENTE SHORELINE PROTECTION PROJECT
San Clemente, CA
Prepared for:

Los Angeles District
U.S. Army Corps of Engineers
Environmental Resources Branch
915 Wilshire Blvd.

Los Angeles, CA 90017
Prepared by:

CHAMBERS GROUP, INC.
5 Hutton Centre Drive, Suite 750
Santa Ana, CA 92707
(949) 261-5414
in Association with
Noble Consultants, Inc.
-XQH ATTACHMENT 3
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APPENDIX C – AIR QUALITY ANALYSIS REPORT
381
C H A M B E R s G 0 u p

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AIR QUALITY ANALYSIS REPORT

SAN CLEMENTE SHORELINE PROJECT

SAN CLEMENTE, CALIFORNIA
Prepared for:

LOS ANGELES DISTRICT

US ARMY CORPS OF ENGINEERS

ENVIRONMENTAL RESOURCES BRANCH
915 Wilshire Boulevard
Los Angeles, California 90017
Prepared by:

CHAMBERS GROUP, INC.
5 Hutton Centre Drive, Suite 750
Santa Ana, California 92707
March 2011
383
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EXECUTIVE SUMMARY
This air quality evaluation was prepared in accordance with the requirements of the California Environmental Quality Act (CEQA) to determine if significant air quality impacts are likely to occur in conjunction with the type and scale of development associated with the proposed San Clemente Shoreline Project (Project).

The Project considered in this analysis proposes replenishing the sand at San Clemente Beach due to ongoing erosion. Two alternatives are addressed. The first examines the placement of approximately 251,127 cubic yards of sand over an area of about 4 acres and a period of about 46 working days. The second alternative examines the placement of approximately 585,962 cubic yards of sand over an area of about 9 acres and a period of 108 working days. In either case the sand would be dredged and hauled from a borrow site approximately 21 miles down coast from the San Clemente Beach site, in Oceanside, California. The Project is approximately centered about the San Clemente Pier; the south limit of the proposed beach fill is located immediately south of the T-Street overpass while the north limit is located immediately north of the Marine Safety Headquarters in the City of San Clemente.

The impact analysis contained in this report was prepared in accordance with the methodologies provided by the South Coast Air Quality Management District (SCAQMD) as included in its CEQA Air Quality Handbook (Handbook) as well as the SCAQMD Internet web site updates.

Localized impacts from construction were determined using methodology provided by the SCAQMD in its document Final Localized Significance Threshold Methodology (Methodology).

Regional operational and long-term localized impacts are not analyzed as there is no long-term operational phase to the Project. Once the beach is replenished there are no on-going operational/maintenance activities that are associated with the project and no construction of any buildings is associated with the Project.

The analysis finds that short-term emissions of NOx, ROG, and PM2.5 particulate matter have the potential to exceed their respective threshold values leading to a significant cumulative impact.

The included mitigation could reduce ROG to below significant thresholds; however NOx and PM2.5, primarily from ocean-going vessel traffic, will remain significant for the Project.

The proposed Project would not involve growth-inducing impacts or cause an exceedance of established population or growth projections. Furthermore, with the included mitigation discussed below, emissions of all criteria pollutants are reduced as feasible. However, even with the included mitigation, the Project would remain significant for short- term construction emissions of NOx and PM2.5. Because the Project incorporates the most current viable mitigation (i.e., Tier II onshore heavy equipment) and because these emissions are short-term and do not occur beyond the Project’s construction period, they do not represent a violation of the goals and objectives of the Air Quality Management Program (AQMP). Additionally, the project would not result in significant localized air quality impacts. As such, the project is consistent with the goals of the AQMP, and in this respect does not present a significant impact. 384
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MITIGATION MEASURES
Construction Period NOx, ROG, and PM2.5 Emissions Mitigation Measures:
The Applicant shall specify that the construction contractors shall use onshore heavy equipment that meets Tier II or higher air pollutant emission standards where these standards are applicable and equipment available.
All heavy equipment shall be maintained and tuned per manufacturer's specifications to perform at California Air Resources Board (CARB) and/or EPA certification, where applicable, levels and to perform at verified standards applicable to retrofit technologies. 385
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TABLE OF CONTENTS
Page
EXECUTIVE SUMMARY ...........................................................................................................1 MITIGATION MEASURES .....................................................................................................2 SECTION 1.0 – METHODOLOGY ............................................................................................1 SECTION 2.0 – EXISTING CONDITIONS ...............................................................................2

2.1. CLIMATE/METEOROLOGY .........................................................................................2

2.2. AMBIENT AIR QUALITY..............................................................................................3

2.2.1 Affected Environment ............................................................................................3

2.2.2 Criteria Air Pollutants.............................................................................................4

2.2.3 Toxic Air Contaminants .........................................................................................7

2.2.4 Other Effects of Air Pollution ................................................................................8

2.3. FEDERAL AMBIENT AIR QUALITY STANDARDS (AAQS)...................................8

2.4. AIR QUALITY MANAGEMENT PLANNING ...........................................................10

2.4.1 Federal Clean Air Act Requirements ...................................................................11

2.4.2 2007 Air Quality Management Plan (AQMP)......................................................12

2.4.3 Greenhouse Gas Emissions ..................................................................................13

2.5. BASELINE AIR QUALITY ..........................................................................................14

2.6. STANDARD CONDITIONS AND UNIFORM CODES..............................................16

2.7. SENSITIVE RECEPTORS.............................................................................................18 SECTION 3.0 – THRESHOLDS OF SIGNIFICANCE...........................................................19

3.1. REGIONAL THRESHOLDS OF SIGNIFICANCE ......................................................19

3.2. LOCALIZED THRESHOLDS OF SIGNIFICANCE (LST) .........................................20

3.3. ADDITIONAL INDICATORS ......................................................................................21 SECTION 4.0 – ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES........22

4.1. PROJECT CONSISTENCY WITH THE APPLICABLE AIR QUALITY PLAN .......22

4.2. PROJECT POTENTIAL TO VIOLATE OR ADD TO A VIOLATION OF AN AIR QUALITY STANDARD.........................................................................................................22

4.2.1 Localized Construction Impacts...........................................................................23

4.3. PROJECT POTENTIAL TO RESULT IN A CUMULATIVELY CONSIDERABLE INCREASE IN CRITERIA POLLUTANTS..................................................................24

4.3.1 Site Construction ..................................................................................................24

4.3.1.1 Mitigation Measures ...............................................................................27

4.3.1.2 NOx, ROG, and PM2.5 Emissions Mitigation Measures.........................27

4.3.1.3 Residual Impacts.....................................................................................27

4.3.2 Site Operations .....................................................................................................28 386
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TABLE OF CONTENTS
Page

4.4. PROJECT POTENTIAL TO EXPOSE SENSITIVE RECEPTORS TO SUBSTANTIAL POLLUTANT CONCENTRATIONS ...............................................28

4.4.1 Short-Term (Construction) Impacts .....................................................................29

4.4.2 Long-Term (Operational) Impacts .......................................................................29

4.5. PROJECT POTENTIAL CREATE OBJECTIONABLE ODORS ................................29

4.6. GREENHOUSE GAS EMISSIONS...............................................................................29

4.6.1 Construction .........................................................................................................29 SECTION 5.0 – CUMULATIVE IMPACTS ............................................................................31 SECTION 6.0 – REFERENCES.................................................................................................32

APPENDICES

APPENDIX A CALCULATION OF UNMITIGATED CONSTRUCTION EMISSIONS

APPENDIX B CALCULATION OF MITIGATED CONSTRUCTION EMISSIONS

APPENDIX C LOCALIZED SIGNIFICANCE THRESHOLD DISPERSION

MODELING METHODOLOGY FOR CONSTRUCTION AND OPERATION

EMISSIONS
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LIST OF TABLES
Page
Table 1 Ambient Air Quality Standards for Priority Pollutants ..................................................... 9 Table 2 Attainment Status for the Basin....................................................................................... 11 Table 3 Ambient Air Quality Monitoring Summary .................................................................... 15 Table 4 Required Best Available Control Measures for Fugitive Dust (Applicable to All Construction Activity Sources)..................................................................................................... 17 Table 5 Contingency Control Measures for Fugitive Dust During High Winds in Excess of 25 MPH.............................................................................................................................................. 17 Table 6 Thresholds of Significance .............................................................................................. 20 Table 7 Localized Construction Emissions Concentrations1 ........................................................ 24 Table 8 Comparison of Unmitigated Projected Construction Emissions and Criteria Values ..... 25 Table 9 Comparison of Mitigated Construction Emissions and Criteria Values.......................... 28 388
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LIST OF ACRONYMS AND ABBREVIATIONS
OF degrees Fahrenheit
μg microgram
AAQS Ambient Air Quality Standards
ADP Attainment Demonstration and Reasonable Further progress Plan ADT Average Daily Trips
AQMP Air Quality Management Program
BACT Best Available Control Technology
C Annual average concentration in μg/m3
CAA Federal Clean Air Act
CAAQS California Ambient Air Quality Standards
CAPCOA California Air Pollution Control Officers Association CARB California Air Resources Board
CAT Climate Action Team
CEC California Energy Commission
CEQA California Environmental Quality Act
CO Carbon Monoxide
CO2 Carbon Dioxide
DPM Diesel Particulate Matter
EMFAC2007 On-Road Emission Factors published by the CARB in 2007 EPA Environmental Protection Agency
Gal gallon
Handbook CEQA Air Quality Handbook
Lbs pounds
LOS Level of Service
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LST Localized Significance Thresholds
MMTCO2E million metric tons of carbon dioxide
Methodology Final Localized Significance Threshold Methodology m3 cubic meters
mph miles per hour
NAAQS National Ambient Air Quality Standards
N2O Nitrous Oxide
NO Nitrogen Oxide
NO2 Nitrogen Dioxide
NOx Nitrogen Oxides
O3 Ozone
OEHHA Office of Environmental Health Hazard Assessment
Pb Lead
PM Particulate Matter
PM10 Particulate Matter of 10 microns or less in size
PM2.5 Particulate Matter of 2.5 microns or less in size ppm Parts per Million
PUC Public Utilities Commission
REL Reference exposure level
ROC Reactive Organic Compounds
ROG Reactive Organic Gases
SCAB South Coast Air Basin
SCAG Southern California Association of Governments
SCAQMD South Coast Air Quality Management District
SIP State Implementation Plans
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SO2 Sulfur Dioxide
SO3 Sulfur Trioxide
SOx Sulfur Oxides
SRA source Receptor Area
TAC Toxic Air Contaminant
T-BACT Best Available Control Technology for Toxic Air Contaminants USEPA United States Environmental Protection Agency
VOC Volatile Organic Compound
Yr year
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1 SECTION 1.0 – METHODOLOGY
This air quality evaluation was prepared in accordance with the requirements of the California Environmental Quality Act (CEQA) to determine if significant air quality impacts are likely to occur in conjunction with the type and scale of development associated with the proposed San Clemente Shoreline Project (Project).

The impact analysis contained in this report was prepared in accordance with the methodologies provided by the South Coast Air Quality Management District (SCAQMD) as included in its Handbook as well as its Internet web site updates. Localized impacts from construction were determined using methodology provided by the SCAQMD in its document Methodology.

Regional operational and long-term localized impacts are not analyzed as there is no long-term operational phase to the Project. Once the beach is replenished there are no additional construction or operational/maintenance activities associated with the Project.

The proposed Project involves the restoration of a stretch of beach that is either approximately 15 or 35 meters wide by 1,040 meters long. The two widths would accommodate either 251,127 or 585,962 cubic yards of sand, respectively, that will be dredged from a borrow site approximately 21 miles down coast from the existing beach. The existing site is vacant and relatively flat land. For the purposes of this analysis, construction is estimated to occur in 2010 and take approximately 46 or 108 working days for the two alternatives, respectively. 392
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2 SECTION 2.0 – EXISTING CONDITIONS

2.1. CLIMATE/METEOROLOGY
The proposed Project lies in the South Coast Air Basin (SCAB) that includes all of Orange County, as well as the non-desert portions of Los Angeles, Riverside, and San Bernardino Counties. In addition, the project borrow area is located in the San Diego Air Basin.

2.1.1 South Coast Air Basin (SCAB)
The SCAB is located in a coastal plain with connecting broad valleys and low hills, bounded by the Pacific Ocean in the southwest quadrant with high mountains forming the remainder of the perimeter. The general region lies in the semi-permanent high-pressure zone of the eastern Pacific. As a result, the climate is mild, tempered by cool sea breezes. This usually mild climatological pattern is interrupted infrequently by periods of extremely hot weather, winter storms, or Santa Ana winds.

The annual average temperature varies little throughout the SCAB, ranging from the low to middle 60s, measured in degrees Fahrenheit (o
F). With a more pronounced oceanic influence,
coastal areas show less variability in annual minimum and maximum temperatures than inland areas. The climatological station located in Laguna Beach (to the north) reports a yearly average of 61o
F. The average low is reported at 44oF in January while the average high is 77oF in August and September.

In contrast to a very steady pattern of temperature, rainfall is seasonally and annually highly variable. Almost all rain falls from November through April. Summer rainfall is normally restricted to widely scattered thundershowers near the coast with slightly heavier shower activity in the east and over the mountains. Rainfall averages around 12.45 inches per year in the Project area, again, as measured at Laguna Beach.

Although the SCAB has a semi-arid climate, the air near the surface is typically moist because of the presence of a shallow marine layer. Except for infrequent periods when dry, continental air is brought into the SCAB by off shore winds, the ocean effect is dominant. Periods of heavy fog, especially along the coastline, are frequent; and low stratus clouds, often referred to as “high fog” are a characteristic climatic feature. Annual average humidity is 70 percent at the coast and 57 percent in the east portions of the SCAB.

Wind patterns across the south coastal region are characterized by westerly and southwesterly onshore winds during the day and easterly or northeasterly breezes at night. Wind speed is somewhat greater during the dry summer months than during the rainy winter season. Annually, typical winds in the project area average about 6 to 8 miles per hour during the day and 2 to 8 miles per hour during the night.

Between the periods of dominant airflow, periods of air stagnation may occur, both in the morning and evening hours. Whether such a period of stagnation occurs is one of the critical determinants of air quality conditions on any given day. During the winter and fall months, surface high-pressure systems over the SCAB, combined with other meteorological conditions, 393
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3 can result in very strong, downslope Santa Ana winds. These winds normally have duration of a few days before predominant meteorological conditions are reestablished.

In conjunction with the two characteristic wind patterns that affect the rate and orientation of horizontal pollutant transport, there are two similarly distinct types of temperature inversions that control the vertical depth through which pollutants are mixed. These inversions are the marine/subsidence inversion and the radiation inversion. The height of the base of the inversion at any given time is known as the “mixing height.” This mixing height can change under conditions when the top of the inversion does not change. The combination of winds and inversions are critical determinants in leading to the highly degraded air quality in summer, and the generally good air quality in the winter in the project area.

2.1.2 San Diego Air Basin (SDAB)
The SDAB covers 4,260 square miles and lies in the southwest corner of California and comprises the entire San Diego region. The topography in the San Diego region varies greatly, from beaches on the west to mountains and desert on the east. Much of the topography in between consists of mesa tops intersected by canyon areas. The topography in the San Diego region, along with local meteorology, influences the dispersal and movement of pollutants in the basin.

The weather of the San Diego region, as in most of southern California, is influenced by the Pacific Ocean and its semi-permanent high-pressure systems that result in dry, warm summers and mild, occasionally wet winters. The average temperature ranges from the mid 40s to the high 90s. Most of the county’s precipitation falls from November to April, with infrequent (approximately ten percent) precipitation during the summer.

The interaction of ocean, land, and the Pacific High Pressure Zone maintains clear skies for much of the year and drives the prevailing winds. Local terrain is often the dominant factor inland, and winds in inland mountainous areas tend to blow through the valleys during the day and down the hills and valleys at night.

2.2. AMBIENT AIR QUALITY
The following characterization of the baseline atmospheric environment includes an evaluation of the ambient air quality and applicable rules, regulations, and standards for the area. Because the Project has the ability to release gaseous emissions of criteria pollutants and dust into the ambient air, it falls under the ambient air quality standards promulgated on the local, state, and federal levels.

2.2.1 Affected Environment
The proposed Project site is subject to the rules and regulations imposed by the SCAQMD; however, the SCAQMD reports to the California Air Resources Board (CARB). Therefore, all emissions are also governed by both the California Ambient Air Quality Standards (CAAQS) as well as the National Ambient Air Quality Standards (NAAQS). 394
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4 Topographical features that affect the transport and diffusion of pollutants in the project area include the mountain ranges to the northeast that prevent the transport of pollutants. Air quality in the SCAB generally ranges from fair to poor and is similar to air quality in most of coastal Southern California. The entire region experiences heavy concentrations of air pollutants during prolonged periods of stable atmospheric conditions. During the past 20 years, the SDAB has experienced a decline in the number of days with unhealthy levels of ozone despite the region’s growth in population and vehicle miles traveled, which both contribute to air pollution problems.

This improvement in air quality clearly shows that our efforts to reduce air pollution are working.

Pollutants emitted into the air from stationary and mobile sources affect the ambient air quality.

Stationary sources can be divided into two major subcategories: point sources and area sources.

Point sources consist of one or more emission sources at a facility with an identified location and are usually associated with manufacturing and industrial processing plants. Area sources are widely distributed and produce many small emissions, such as residential water heaters.

Mobile sources refer to emissions from motor vehicles, including tailpipe and evaporative emissions, and are classified as either on-road or off-road. On-road sources are a combination of emissions from automobiles, trucks, and indirect sources. Indirect sources are sources that by themselves may not emit air contaminants; however, they indirectly cause the generation of air pollutants by attracting vehicle trips or consuming energy. Examples of indirect sources include an office complex or commercial center that generates commuter trips and consumes energy resources through the use of natural gas for space and water heating. Indirect sources also include actions proposed by local governments, such as redevelopment districts and private projects involving the development of either large buildings or tracts. In addition, indirect sources include those emissions created by the distance vehicles travel. Off-road sources include aircraft, ships, trains, and self-propelled construction equipment.

2.2.2 Criteria Air Pollutants
Federal and State laws regulate the air pollutants emitted into the ambient air by stationary and mobile sources. These regulated air pollutants are known as “criteria air pollutants” and are categorized as primary and secondary pollutants. Primary air pollutants are those that are emitted directly from sources. Carbon monoxide (CO), reactive organic gases (ROG), nitrogen oxides (NOx), sulfur dioxide (SO2), and most fine particulate matter (PM10, PM2.5) including lead (Pb) and fugitive dust; are primary air pollutants. Of these CO, SO2, PM10, and PM2.5 are criteria pollutants. ROG and NOx are criteria pollutant precursors and go on to form secondary criteria pollutants through chemical and photochemical reaction in the atmosphere. Ozone (O3) and nitrogen dioxide (NO2) are the principal secondary pollutants.

Presented below is a description of each of these primary and secondary criteria air pollutants and their known health effects.

Carbon Monoxide (CO) is a colorless, odorless, toxic gas produced by incomplete combustion of carbon substances (e.g., gasoline or diesel fuel). The primary adverse health effect associated with CO is the interference of normal oxygen transfer to the blood, which may result in tissue 395
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5 oxygen deprivation. The major sources of CO in the SCAB are on-road vehicles, aircraft, and off-road vehicles and equipment (CARB 2006).

Reactive Organic Gases (ROGs) are defined as any compound of carbon, excluding carbon monoxide, carbon dioxide, carbonic acid, metallic carbides or carbonates, and ammonium carbonate, which participates in atmospheric photochemical reactions. ROGs consist of nonmethane hydrocarbons and oxygenated hydrocarbons. Hydrocarbons are organic compounds that contain only hydrogen and carbon atoms. Non-methane hydrocarbons are hydrocarbons that do not contain the un-reactive hydrocarbon, methane. Oxygenated hydrocarbons are hydrocarbons with oxygenated functional groups attached.

It should be noted that there are no state or national ambient air quality standard for ROGs because they are not classified as criteria pollutants. They are regulated, however, because a reduction in ROGs emissions reduces certain chemical reactions that contribute to the formulation of ozone. ROGs are also transformed into organic aerosols in the atmosphere, which contribute to higher PM10 and lower visibility. Although health-based standards have not been established for ROGs, health effects can occur from exposures to high concentrations because of interference with oxygen uptake. In general, concentrations of ROG are suspected to cause eye, nose, and throat irritation; headaches, loss of coordination, nausea, damage to liver, kidney, and the central nervous system (EPA 2005).

The major sources of ROG in the SCAB are on-road motor vehicles and solvent evaporation.

Nitrogen Oxides (NOx) serve as integral participants in the process of photochemical smog production. The two major forms of NOx are nitric oxide (NO) and nitrogen dioxide (NO2). NO is a colorless, odorless gas formed from atmospheric nitrogen and oxygen when combustion takes place under high temperature and/or high pressure. NO2 is a reddish-brown irritating gas formed by the combination of NO and oxygen.

NOx acts as an acute respiratory irritant and increases susceptibility to respiratory pathogens.

NOx is also an ozone precursor. A precursor is a directly emitted air contaminant that, when released into the atmosphere, forms, causes to be formed, or contributes to the formation of a secondary air contaminant for which an Ambient Air Quality Standard (AAQS) has been adopted, or whose presence in the atmosphere will contribute to the violation of one or more AAQS. When NOx and ROG are released in the atmosphere, they can chemically react with one another in the presence of sunlight to form ozone.

The major source of NOx in the SCAB is on-road vehicles (CARB 2006). Stationary commercial and service source fuel combustion also contribute to the total NOx emissions in the SCAB (CARB 2006).

Nitrogen Dioxide (NO2) is a byproduct of fuel combustion. The principal form of NO2 produced by combustion is NO, but NO reacts to form NO2, creating the mixture of NO and NO2 commonly called NOx. The U.S. Environmental Protection Agency (USEPA) has concluded that the only form of NOx that exists at a level to cause public health concerns is NO2 (EPA 1997).

NO2 acts as an acute irritant and, in equal concentrations, is more injurious than NO. At atmospheric concentrations, however, NO2 is only potentially irritating. There is some indication 396
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6 of a relationship between NO2 and chronic pulmonary fibrosis. Some increase in bronchitis in children (two and three years old) has also been observed at concentrations below 0.3 part per million (ppm). NO2 absorbs blue light; the result is a brownish-red cast to the atmosphere and reduced visibility. NO2 also contributes to the formation of PM10 (particulates having an aerodynamic diameter of 10 microns or 0.0004 inch or less in diameter).

Ozone (O3) is one of a number of substances called photochemical oxidants that are formed when reactive organic compounds (ROC) and NOx (both byproducts of the internal combustion engine) react with sunlight. Ozone is present in relatively high concentrations in the SCAB, and the damaging effects of photochemical smog are generally related to the concentrations of Ozone. Ozone may pose a health threat to those who already suffer from respiratory diseases as well as healthy people. Additionally, Ozone has been tied to crop damage, typically in the form of stunted growth and pre-mature death. Ozone can also act as a corrosive resulting in property damage such as the embrittlement of rubber products.

Lead (Pb) is a heavy metal that can exist in air pollution as an aerosol particle component. An aerosol is a collection of solid, liquid, or mixed-phase particles suspended in the air. Lead was first regulated as an air pollutant in 1976. Leaded gasoline was first marketed in 1923 and was used in motor vehicles until around 1970. The exclusion of lead from gasoline helped to decrease emissions of lead in the United States from 219,000 to 4,000 short tons per year between 1970 and 1997.

Lead ore crushing, lead-ore smelting, and battery manufacturing are currently the largest sources of lead in the atmosphere in the United States. Other sources include dust from soils contaminated with lead-based paint, solid waste disposal, and crustal physical weathering. The mechanisms by which lead can be removed from the atmosphere (sinks) include deposition to soils, ice caps, oceans, and inhalation.

Lead accumulates in bones, soft tissue, and blood and can affect the kidneys, liver, and nervous system. The more serious effects of lead poisoning include behavior disorders, mental retardation, and neurological impairment. Low levels of lead in fetuses and young children can result in nervous system damage, which can cause learning deficiencies and low IQs. Lead may also contribute to high blood pressure and heart disease. Lead concentrations once exceeded the state and national air quality standards by a wide margin, but have not exceeded state or national air quality standards at any regular monitoring station since 1982. Lead is no longer an additive to normal gasoline, which is the main reason that the concentration of lead in the air is low. The proposed Project will not emit lead, and therefore, it is eliminated from further review in this analysis.

Sulfur Dioxide (SO2) is a colorless, pungent gas. At levels greater than 0.5 ppm, the gas has a strong odor, similar to rotten eggs. Sulfuric acid is formed from sulfur dioxide, which is an aerosol particle component that may lead to acid deposition. Acid deposition into water, vegetation, soil, or other materials can harm natural resources and materials. Sulfur oxides (SOx) include sulfur dioxide and sulfur trioxide (SO3). Although sulfur dioxide concentrations have been reduced to levels well below state and national standards, further reductions are desirable because SO2 is a precursor to sulfates. Sulfates are a particulate formed through the photochemical oxidation of SO2. Long-term exposure to high levels of SO2 can cause irritation 397
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7 of existing cardiovascular disease, respiratory illness, and changes in the defenses in the lungs.

When people with asthma are exposed to high levels of SO2 for short periods of time during moderate activity, effects may include wheezing, chest tightness, or shortness of breath.

Particulate Matter (PM) consists of finely divided solids or liquids such as soot, dust, aerosols, fumes, and mists. Two forms of fine particulate are now recognized. Coarse particles, or PM10, include that portion of the particulate matter with an aerodynamic diameter of 10 microns (i.e., ten one-millionths of a meter or 0.0004 inch) or less. Fine particles, or PM2.5, have an aerodynamic diameter of 2.5 microns that is 2.5 one-millionths of a meter or 0.0001 inch or less.

Particulate discharge into the atmosphere results primarily from industrial, agricultural, construction, and transportation activities; however, wind action on the arid landscape also contributes substantially to the local particulate loading. Both PM10 and PM2.5 may adversely affect the human respiratory system, especially in those people who are naturally sensitive or susceptible to breathing problems.

Fugitive Dust poses primarily two public health and safety concerns. The first concern is that of respiratory problems attributable to the suspended particulates in the air. The second concern is that of motor vehicle accidents caused by reduced visibility during severe wind conditions.

Fugitive dust may also cause significant property damage during strong windstorms by acting as an abrasive material agent (much like sandblasting activities). Finally, fugitive dust can result in a nuisance factor due to the soiling of proximate structures and vehicles.

Diesel Particulate Matter (DPM) is a mixture of many exhaust particles and gases that is produced when an engine burns diesel fuel. Many compounds found in diesel exhaust are carcinogenic, including 16 that are classified as possibly carcinogenic by the International Agency for Research on Cancer. DPM includes the particle-phase constituents in diesel exhaust.

Some short-term (acute) effects of diesel exhaust include eye, nose, throat and lung irritation, and can cause coughs, headaches, light-headedness and nausea. Diesel exhaust is a major source of ambient particulate matter pollution as well, and numerous studies have linked elevated particle levels in the air to increased hospital admission, emergency room visits, asthma attacks, and premature deaths among those suffering from respiratory problems (Office of Environmental Health Hazard Assessment 2002). DPM in the SCAB poses the greatest cancer risk of all the toxic air pollutants.

2.2.3 Toxic Air Contaminants
The public's exposure to toxic air contaminants (TACs) is a significant environmental health issue in California. In 1983, the California Legislature enacted a program to identify the health effects of TACs and to reduce exposure to these contaminants to protect the public health. The Health and Safety Code defines a TAC as “an air pollutant which may cause or contribute to an increase in mortality or in serious illness, or which may pose a present or potential hazard to human health.” A substance that is listed as a hazardous air pollutant pursuant to subsection (b) of Section 112 of the Federal Act (42 USC Sec. 7412[b]) is a toxic air contaminant. Under State law, the California EPA, acting through the CARB, is authorized to identify a substance as a TAC if it determines the substance is an air pollutant which may cause or contribute to an increase in mortality or an increase in serious illness, or which may pose a present or potential hazard to human health.
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8 California regulates TACs primarily through AB 1807 (Tanner Air Toxics Act) and AB 2588 (Air Toxics “Hot Spot” Information and Assessment Act of 1987). The Tanner Air Toxics Act sets forth a formal procedure for CARB to designate substances as TACs. Once a TAC is identified, CARB adopts an “airborne toxics control measure” for sources that emit designated TACs. If there is a safe threshold for a substance at which there is no toxic effect, the control measure must reduce exposure to below that threshold. If there is no safe threshold, the measure must incorporate toxics best available control technology (T-BACT) to minimize emissions.

Air toxics from stationary sources are also regulated in California under the Air Toxics “Hot Spot” Information and Assessment Act of 1987. Under AB 2588, toxic air contaminant emissions from individual facilities are quantified and prioritized by the air quality management district or air pollution control district. High priority facilities are required to perform a health risk assessment and, if specific thresholds are exceeded, required to communicate the results to the public in the form of notices and public meetings.

To date the CARB has designated nearly 200 compounds as TACs. Additionally, the CARB has implemented control measures for a number of compounds that pose high risks and show potential for effective control. The majority of the estimated health risks from TACs can be attributed to a relatively few compounds, the most important being PM from diesel-fueled engines.

2.2.4 Other Effects of Air Pollution
Just as humans are affected by air pollution, so too are plants and animals. Animals must breathe the same air and are subject to the same types of negative health effects. Certain plants and trees may absorb air pollutants that can stunt their development or cause premature death.

There are also numerous impacts to the human economy including lost workdays due to illness, a desire on the part of business to locate in areas with a healthy environment, and increased expenses from medical costs. Pollutants may also lower visibility and cause damage to property.

Certain air pollutants are responsible for discoloring painted surfaces, eating away at stones used in buildings, dissolving the mortar that holds bricks together, and cracking tires and other items made from rubber.

2.3. FEDERAL AMBIENT AIR QUALITY STANDARDS (AAQS)
The Federal Clean Air Act Amendment of 1971 (CAA) established NAAQS with states retaining the option to adopt more stringent standards or to include other pollution species. These standards are the levels of air quality considered safe, with an adequate margin of safety, to protect the public health and welfare. They are designed to protect those “sensitive receptors” most susceptible to further respiratory distress such as asthmatics, the elderly, very young children, people already weakened by other disease or illness, and persons engaged in strenuous work or exercise. Healthy adults can tolerate occasional exposure to air pollutant concentrations considerably above these minimum standards before adverse effects are observed.

Both the State of California and the Federal government have established health based AAQS for six air pollutants. As shown in Table 1, these pollutants include ozone, carbon monoxide, 399
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9 nitrogen dioxide, sulfur dioxide, suspended particulate matter (PM10, PM2.5), and lead. In addition, the State has set standards for sulfates, hydrogen sulfide, vinyl chloride, and visibility reducing particles. These standards are designed to protect the health and welfare of the populace with a reasonable margin of safety.

Table 1
Ambient Air Quality Standards for Priority Pollutants
Pollutant Averaging
Time
California
Standard
Federal
Primary
Standard
Major Pollutant Sources
Ozone (O3) 1 hour 0.09 ppm * Motor vehicles, paints, coatings, 8 hours 0.070 0.075 ppm and solvents.

Carbon
Monoxide (CO)
1 hour 20 ppm 35 ppm Internal combustion engines,
primarily gasoline-powered
motor vehicles. 8 hours 9.0 ppm 9 ppm
Nitrogen
Dioxide (NO2)
Annual
Average * 0.053 ppm Motor vehicles, petroleumrefining operations, industrial sources, aircraft, ships, and
railroads. 1 hour 0.18 ppm *
Sulfur Dioxide
(SO2)
Annual
Average * 0.03 ppm Fuel combustion, chemical
plants, sulfur recovery plants,
and metal processing. 1 hour 0.25 ppm *
24 hours 0.04 ppm 0.14 ppm
Suspended
Particulate
Matter
(PM10)
Annual
Arithmetic
Mean
20 µg/m3 50 µg/m3
Dust and fume-producing
construction, industrial, and
agricultural operations,
combustion, atmospheric
photochemical reactions, and
natural activities (e.g., windraised dust and ocean sprays). 24 hours 50 µg/m3 150 µg/m3
Suspended
Particulate
Matter
(PM2.5)
Annual
Arithmetic
Mean
12 µg/m3 15 µg/m3
Dust and fume-producing
construction, industrial, and
agricultural operations,
combustion, atmospheric
photochemical reactions, and
natural activities (e.g., windraised dust and ocean sprays). 24 hours * 35 µg/m3
Lead (Pb)
Monthly 1.5 µg/m3 * Present source: lead smelters,
battery manufacturing and
recycling facilities. Past source:
combustion of leaded gasoline.

Quarterly * 1.5 µg/m3
Sulfates (SO4) 24 hours 25 µg/m3 * Industrial processes.

Ppm: parts per million; µg/m3: micrograms per cubic meter 400

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10 * = standard is not used for this pollutant/duration by this entity.

In addition to primary and secondary AAQS, the State of California has established a set of episode criteria for ozone, carbon monoxide, nitrogen dioxide, sulfur dioxide, and particulate matter. These criteria refer to episode levels representing periods of short-term exposure to air pollutants that actually threaten public health.

2.4. AIR QUALITY MANAGEMENT PLANNING
The SCAQMD and the Southern California Association of Governments (SCAG) are the agencies responsible for preparing the Air Quality Management Plan (AQMP) for the SCAB.

Since 1979, a number of AQMPs have been prepared. The 1997 AQMP, updated in 1999 and replaced in 2003, was based on the 1994 AQMP and ultimately the 1991 AQMP, and was designed to comply with State and Federal requirements, reduce the high level of pollutant emissions in the SCAB, and ensure clean air for the region through various control measures. To accomplish its task, the 1991 AQMP relied on a multilevel partnership of governmental agencies at the Federal, State, regional, and local level. These agencies (i.e., the USEPA, CARB, local governments, SCAG, and SCAQMD) are the cornerstones that implement AQMP programs.

The 2003 AQMP, adopted in August 2003, updated the attainment demonstration for the Federal standards for ozone and PM10; replaced the 1997 attainment demonstration for the Federal CO standard and provided a basis for a maintenance plan for CO for the future; and updated the maintenance plan for the Federal NO2 standard that the SCAB has met since 1992.

The most recent comprehensive plan is the 2007 AQMP adopted on July 13, 2007. The 2007 AQMP is designed to meet the State and Federal CAA planning requirements and focuses on ozone and PM2.5. The 2007 AQMP incorporates significant new emissions inventories, ambient measurements, scientific data, control strategies, and air quality modeling.

Areas that meet the ambient air quality standards are classified as “attainment” areas while areas that do not meet these standards are classified as “non-attainment” areas. The classifications for ozone non-attainment include and range in magnitude from: marginal, moderate, serious, severe, and extreme. The State and Federal attainment status for the SCAB are included in Table 2. 401
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11 Table 2
Attainment Status for the SCAB
Pollutant State Status Federal Status
Ozone (1-
hour) Extreme Non-attainment Extreme Non-attainment (under the prior standard) Ozone (8-
hour) Extreme Non-Attainment Extreme
PM10 Serious Non-attainment Serious Non-attainment
PM2.5 Non-attainment Non-attainment
CO Attainment Attainment/Maintenance
NO2 Attainment Attainment/Maintenance
On April 15, 2010, EPA signed a final rule to grant requests to reclassify SCAB from "severe17" to "extreme". The SCAB also is designated as attainment of the CAAQS for SO2, lead, and sulfates. Areas that are designated as Severe 17 for the ozone standard must meet attainment of the 8-hour standard by 2021 (2024 if reclassified to Extreme). Areas considered as serious nonattainment of the PM10 standards must have reached attainment by the end of 2006, or as expeditiously as possible. The PM2.5 attainment date is to be met in the year 2015.

2.4.1 Federal Clean Air Act Requirements
The Federal CAA requires plans to provide for the implementation of all reasonably available control measures including the adoption of reasonably available control technology for reducing emissions from existing sources. Emission control innovations in the form of market-based approaches are explicitly encouraged by the CAA. The SCAQMD is the first local agency in the country to adopt a market-based approach for controlling stationary source emissions of oxides of nitrogen and sulfur. Other Federal requirements addressed include mechanisms to track plan implementation and milestone compliance for O3 and CO.

The USEPA has recently phased out the federal 1-hour ozone standard and replaced it with a new 8-hour standard to protect against longer exposure periods. However, the SCAB still experiences ozone levels over the prior federal 1-hour standard on more than 20 days per year.

The 2007 AQMP shows that by 2010, the SCAB will still exceed the federal 1-hour ozone standard by 20 percent despite the implementation of existing air quality programs. The SCAQMD and a number of environmental organizations have litigated against USEPA’s revocation of the 1-hour standard with the case still pending.

The new 8-hour ozone standard is set at a concentration of 0.08 parts per million (ppm) and represents a tightening of the existing 1-hour ozone standard that was set at 0.12 ppm. Under the form of the standard adopted by the USEPA, areas are allowed to disregard their three worst measurements every year and average their fourth highest measurements over three years to determine if they meet the standard.
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12 For particulate matter, the USEPA established new annual and 24-hour standards for PM2.5 to complement the existing PM10 standards. The new annual PM2.5 standard is set at 15 micrograms per cubic meter and the new 24-hour PM2.5 standard was set at 65 micrograms per cubic meter.

This level has now been further reduced to 35 micrograms per cubic meter. The annual component of the standard was set to provide protection against typical day-to-day exposures as well as longer-term exposures, while the daily component protects against more extreme shortterm events. For the new 24-hour PM2.5 standard, the form of the standard is based on the 98th percentile of 24-hour PM2.5 concentrations measured in a year (averaged over three years) at the monitoring site with the highest measured values in an area. This form of the standard will reduce the impact of a single high exposure event that may be due to unusual meteorological conditions and thus provide a more stable basis for effective control programs.

While USEPA has retained the current annual PM10 standard of 50 micrograms per cubic meter, it has modified the form of the 24-hour PM10 standard set at 150 micrograms per cubic meter.

More specifically, USEPA revised the one-expected exceedance form of the current standard with a 99th percentile form, averaged over three years.

The State Implementation Plans (SIP) that will incorporate attainment demonstrations with the new 8-hour ozone and PM2.5 standards are expected to be required within three years of the air quality designations or by 2007. Therefore, the current regulatory control strategies will continue to focus on attaining the 1-hour ozone standard with the recognition that these controls will have benefits toward attaining the 8-hour ozone and PM2.5 standards. The USEPA is considering several options in transitioning from the 1-hour to the 8-hour standard, while ensuring that no backsliding will occur. Based on the recent consent decree guidance, it is most likely that the SCAB will have to meet the federal PM2.5 standards by 2015 and the 8-hour ozone standard by 2021 or 2024 if the area is redesignated as “Extreme.”

2.4.2 2007 Air Quality Management Plan (AQMP)
The South Coast Air Quality Management District (SCAQMD) and the Southern California Association of Governments (SCAG) are the agencies responsible for preparing the AQMP for the SCAB. Since 1979, a number of AQMPs have been prepared. The 1997 AQMP, updated in 1999 and replaced in 2003, was based on the 1994 AQMP and ultimately the 1991 AQMP and was designed to comply with State and federal requirements, reduce the high level of pollutant emissions in the SCAB, and ensure clean air for the region through various control measures. To accomplish its task, the 1991 AQMP relied on a multilevel partnership of governmental agencies at the federal, State, regional, and local level. These agencies (i.e., the USEPA, CARB, local governments, SCAG, and SCAQMD) are the cornerstones that implement the AQMP programs.

The most recent comprehensive plan is the 2007 AQMP adopted on July 13, 2007. The 2007 AQMP employs up-to-date science and analytical tools and incorporates a comprehensive strategy aimed at controlling pollution from all sources, including stationary sources, on-road and off-road mobile sources, and area sources.

The 2007 Plan proposes attainment demonstration of the federal PM2.5 standards through a more focused control of SOx, directly emitted PM2.5, and NOx supplemented with VOC by 2014. The 8-hour ozone control strategy builds upon the PM2.5 strategy, augmented with additional VOC 403
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13 reductions to meet the standard by 2020. An extended attainment date (i.e., additional three years) is allowed under the Clean Air Act if a “bump-up” request is made by the state showing the need for such extension.

The 2007 AQMP proposes policies and measures currently contemplated by responsible agencies to achieve federal standards for healthful air quality in the SCAB and those portions of the Salton Sea Air SCAB (formerly named the Southeast Desert Air Basin) that are under SCAQMD jurisdiction (Coachella Valley).

The 2007 Plan also addresses several federal planning requirements and incorporates significant new scientific data, primarily in the form of updated emissions inventories, ambient measurements, new meteorological episodes, and new air quality modeling tools.

The 2007 Plan builds upon the approaches taken in the 2003 AQMP for the SCAB for the attainment of the federal ozone air quality standard. However, this new Plan highlights the significant amount of reductions needed and the urgent need to identify additional strategies, especially in the area of mobile sources, to meet all federal criteria pollutant standards within the timeframes allowed under federal Clean Air Act.

The 2007 AQMP updates the attainment demonstration for the federal standards for ozone and particulate matter (PM10); replaces the 1997 attainment demonstration for the federal carbon monoxide (CO) standard and provides a basis for a maintenance plan for CO for the future; and updates the maintenance plan for the federal nitrogen dioxide (NO2) standard that the SCAB has met since 1992.

The SCAB is also designated as attainment of the CAAQS for SO2, lead, and sulfates. Areas that are designated as Severe 17 for the ozone standard must meet attainment of the 8-hour standard by 2021 (2024 if reclassified to Extreme). Areas considered as serious non-attainment of the PM10 standards must have reached attainment by the end of 2006, or as expeditiously as possible.

The PM2.5 attainment date is to be met in the year 2015.

2.4.3 Greenhouse Gas Emissions
In 2005, in recognition of California’s vulnerability to the effects of climate change, Governor Schwarzenegger established Executive Order S-3-05, which sets forth a series of target dates by which statewide emission of greenhouse gas would be progressively reduced, as follows:
By 2010, reduce greenhouse gas emissions to 2000 levels; By 2020, reduce greenhouse gas emissions to 1990 levels; and 404
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14 By 2050, reduce greenhouse gas emissions to 80 percent below 1990 levels.

In 2006, California passed the California Global Warming Solutions Act of 2006 (AB 32; California Health and Safety Code Division 25.5, Sections 38500, et seq.), which requires CARB to design and implement emission limits, regulations, and other measures, such that feasible and cost-effective statewide greenhouse gas emissions are reduced to 1990 levels by 2020 (representing an approximate 25 percent reduction in emissions).

In June 2007, CARB directed staff to pursue 37 early actions for reducing greenhouse gas emissions under AB 32. The broad spectrum of strategies to be developed – including a Low Carbon Fuel Standard, regulations for refrigerants with high global warming potentials, guidance and protocols for local governments to facilitate greenhouse gas reductions, and green ports – reflects that the serious threat of climate change requires action as soon as possible.

In addition to approving the greenhouse gas reduction strategies, CARB directed staff to further evaluate early action recommendations made at the June 2007 meeting, and to report back to CARB within 6 months. The general sentiment of CARB suggested a desire to try to pursue greater greenhouse gas emissions reductions in California in the near-term. Since the June 2007 CARB hearing, CARB staff has evaluated all 48 recommendations submitted by several stakeholder and several internally-generated staff ideas and published the Expanded List of Early Action Measures To Reduce Greenhouse Gas Emissions In California, recommended for board consideration in October 2007. Based on its additional analysis, CARB staff is recommending the expansion of the early action list to a total of 44 measures. Nine of the strategies meet the AB 32 definition of discrete early action measures. Discrete early action measures are measures that will be in place and enforceable by January 1, 2010. The discrete early action items include: (1) a Low Carbon Fuel standards for ethanol, biodiesel, hydrogen, electricity, compressed natural gas, liquefied petroleum gas, and biogas; (2) restrictions on High Global Warming Potential Refrigerants; (3) Landfill Methane Capture; (4) Smartway Truck Efficiency; (5) Port Electrification; (6) Reduction of perfluorocarbons from the semiconductor industry; (7) Reduction of propellants in consumer products; (8) Tire inflation; and (9) Sulfur Hexafluoride (SF6) reductions from non-electricity sector.

The 2020 target reductions are currently estimated to be 174 million metric tons of carbon dioxide (CO2) equivalent (MMTCO2E). In total, the recommended early actions have the potential to reduce greenhouse gas emissions by at least 42 MMTCO2E emissions by 2020, representing about 25 percent of the estimated reductions needed by 2020. The CARB Board adopted Resolution 07-55 in December 2007, approving 427 MMTCO2E as the statewide greenhouse gas emissions limit for 2020, which is equivalent to the 1990 emissions level. The measures are in the sectors of fuels, transportation, forestry, agriculture, education, energy efficiency, commercial, solid waste, cement, oil and gas, electricity, and fire suppression.

2.5. BASELINE AIR QUALITY
Existing levels of ambient air quality and historical trends and projections in the project area are best documented by measurements made by the SCAQMD. The project is located within the southern portion of Source Receptor Area (SRA) 21 Capistrano Valley. The closest monitoring station to the San Clemente area is located at Lake Forest (Saddleback Valley SRA 19). 405
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15 Excepting NO2 that is not monitored in this area, data from the monitoring station in SRA 19 are summarized in Table 3. Data for NO2 included in Table 3 are as monitored in the North Coastal SRA 18. The borrow area is located near Oceanside. The nearest monitoring station to the borrow site is located at Camp Pendleton. The Camp Pendleton site measures ozone, PM2.5, and NO2. Table 3 also includes ambient data for Camp Pendleton.

Table 3
Ambient Air Quality Monitoring Summary
Pollutant/Standard
Number of Days Thresholds Were Exceeded and Maximum
Levels During Such Violations
2003 2004 2005 2006 2007
Ozone – Lake Forest
State 1-Hour > 0.09 ppm
State 8-Hour > 0.07 ppm
Federal 1-Hour > 0.12 ppm
Federal 8-Hour > 0.08 ppm
Max. 1-Hour Conc. (ppm)
Max. 8-Hour Conc. (ppm)
16 ND
4 8

0.153

0.105
11 20
0 0

0.116

0.089
3 6
1 1

0.125

0.085
13 17
0 6

0.12 0.105
5 10
0 2

0.108

0.089
Ozone – Camp Pendleton
State 1-Hour > 0.09 ppm
State 8-Hour > 0.07 ppm
Federal 1-Hour > 0.12 ppm
Federal 8-Hour > 0.08 ppm
Max. 1-Hour Conc. (ppm)
Max. 8-Hour Conc. (ppm)
4 10
0 5

0.099

0.084
4 12
0 6

0.110

0.095
0 2
0 0

0.090

0.074
0 5
0 0

0.086

0.073
0 4
0 0

0.083

0.074
Carbon Monoxide – Lake Forest
State 8-Hour > 9.0 ppm
Federal 8-Hour > 9.5 ppm
Max 1-Hour Conc. (ppm)
Max. 8-Hour Conc. (ppm)
0 0
3 1.8
0 0
2 1.6
0 0
2 1.6
0 0
2 1.8
0 0
3 2.1
Nitrogen Dioxide – SRA 18
State 1-Hour > 0.25 ppm
Max. 1-Hour Conc. (ppm)
0 0.11
0 0.10
0 0.09
0 0.10
0 0.07
Nitrogen Dioxide – Camp Pendleton
State 1-Hour > 0.25 ppm
Max. 1-Hour Conc. (ppm)
0 0.11
0 0.10
0 0.09
0 0.10
0 0.07
Inhalable Particulates (PM10)
2 – Lake Forest
State 24-Hour > 50 μg/m3
Federal 24-Hour > 150 μg/m3
Max. 24-Hour Conc. (μg/m3)

3.5 0.0
64 0.0

0.0 47

0.0 0
41 2.0
0 57
5 0
74 Inhalable Particulates (PM2.5)
2 – Lake Forest
Federal 24-Hour > 65 μg/m3
Max. 24-Hour Conc. (μg/m3)

0.0 50.6

0.0 49.4

0.0 35.4

0.9 47.0

0.0 46.9 1 NO2 as measured at the North Coastal Orange County monitoring station. All other pollutants as measured at the Saddleback monitoring station.
2 Percent of samples exceeding standard.
ppm: parts per million; μg/m3
: micrograms per cubic meter
Source: South Coast Air Quality Management District
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16 At the SCAG monitoring sites, ozone pollution decreased between 2004 and 2005 with an increase again in 2006 and decrease in 2007 with 5 days experiencing a violation of the federal hourly standard. The SCAG data show recurring violations of and fluctuations in both the State and Federal ozone standards and no clear trend is apparent. The SCAG data also indicate that the area occasionally exceeds the PM10 and PM2.5 State and Federal standards with only one day in 2006 that exceeded the standards for either pollutant. The CO and NO2 standards have not been violated in the last five years at this station.

At the SDAG monitoring sites, ozone pollution stayed fairly steady between 2004 and 2005 and actually decreased between 2005 and 2007 with an average of 3 days experiencing a violation of the State hourly standard during those three years. The NO2 standards have not been violated in the last five years at this station.

2.6. STANDARD CONDITIONS AND UNIFORM CODES
All projects constructed in the SCAB are subject to Standard Conditions and Uniform Codes.

Compliance with these provisions is mandatory and as such, does not constitute mitigation under CEQA. Those conditions specific to air quality that would apply to the project are included below:
Adherence to SCAQMD Rule 403, which sets requirements for dust control associated with grading and construction activities.
Adherence to SCAQMD Rules 431.1 and 431.2, which require the use of low sulfur fuel for stationary construction equipment.

During construction, the project would be subject to SCAQMD Rule 403 (fugitive dust).

SCAQMD Rule 403 does not require a permit for construction activities, per se, but rather, sets forth general and specific requirements for all construction sites (as well as other fugitive dust sources) in the SCAB. The general requirement prohibits a person from causing or allowing emissions of fugitive dust from construction (or other fugitive dust source) such that the presence of such dust remains visible in the atmosphere beyond the property line of the emissions source.

SCAQMD Rule 403 also prohibits a construction site from causing an incremental PM10 concentration impact at the property line of more than 50 micrograms per cubic meter as determined through PM10 high-volume sampling, but the concentration standard and associated PM10 sampling do not apply if specific measures identified in the rule are implemented and appropriately documented.

In accordance with Rule 403, the SCAQMD requires that contractors implement Best Available Control Technology (BACT) for construction activities. Rule 403 identifies a set of specific measures for projects less than 50 acres. These requirements are included in Table 4. Note that these measures are regulatory requirements and as such, do not constitute mitigation under CEQA.

The conditions included in Table 4 apply to construction activities conducted during normal wind conditions (i.e., with wind gusts less than 25 miles per hour). The contingency measures, 407
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17 included in Table 5, shall be applied to those periods when instantaneous wind gusts meet or exceed 25 miles per hour (mph).

Table 4
Required Best Available Control Measures for Fugitive Dust (Applicable to All Construction Activity Sources)
Source Category Control Measures Guidance
Disturbed soil • Stabilize disturbed soil throughout the construction site; and
• Stabilize disturbed soil between structures.
• Limit vehicular traffic and disturbances on
soils where possible;
• If interior block walls are planned, install
as early as possible;
• Apply water or a stabilizing agent in
sufficient quantities to prevent the
generation of visible dust plumes; and
• This measure applies to both inactive and
active sites, during workdays, weekends,
holidays, and windy conditions.

Earth-moving
activities
• Pre-apply water to depth of proposed cuts;
• Re-apply water as necessary to maintain
soils in a damp condition and to ensure that
visible emissions do not exceed 100 feet in
any direction;
• Stabilize soils once earth-moving activities
are complete; and
• Limit speed of earthmoving equipment to
10 mph.
• Grade each project phase separately, timed
to coincide with construction phase;
• Upwind fencing can prevent material
movement on site; and
• Apply water or a stabilizing agent in
sufficient quantities to prevent the
generation of visible dust plumes.

Staging areas • Stabilize staging areas during use; and • Stabilize staging area soils at project
completion.
• Locate construction equipment and staging
zones away from sensitive receptors and
fresh air intakes to buildings and air
conditioners.
• Limit size of staging area;
• Limit vehicle speeds to 15 miles per hour
(24 kilometers per hour); and
• Limit number and size of staging area
entrances/exits.

Paved road trackout • Cover all haul vehicles • Comply with the vehicle freeboard requirements of Section 23114 of the
California Vehicle Code for both public
and private roads.

Traffic areas for
construction
activities
• Stabilize all off-road traffic and parking
areas;
• Stabilize all haul routes;
• Direct construction traffic over established
haul routes; and
• Limit speeds to 15 miles per hour
(mph).
• Apply gravel/paving to all haul routes as
soon as possible to all future roadway
areas; and
• Barriers can be used to ensure vehicles are
used only on established parking
areas/haul routes.
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18 Table 5
Contingency Control Measures for Fugitive Dust
During High Winds in Excess of 25 MPH
Fugitive Dust Source Category Control Measures
Earth-moving • Cease all active operations; or
• Apply water to soil not more than 15 minutes prior to moving such soil.

Disturbed surface areas • Apply water to all unstabilized disturbed areas three times per day. If there is any evidence of wind-driven fugitive dust, watering frequency is increased to a minimum of four times per day.

Unpaved roads • Apply water twice per hour during active operation.

Open storage piles • Apply water twice per hour; or
• Install temporary coverings.

All categories Executive Officer and the USEPA as equivalent to the methods specified in this table may be used.

2.7. SENSITIVE RECEPTORS
Some land uses are considered more sensitive to air pollution than others due to the types of population groups or activities involved. Sensitive population groups include children, the elderly, the acutely ill, and the chronically ill, especially those with cardio-respiratory diseases.

Residential areas are considered to be sensitive to air pollution because residents (including children and the elderly) tend to be at home for extended periods of time, resulting in sustained exposure to any pollutants present. Schools are also considered as sensitive as children are present for extended durations and engage in regular outdoor activities. Recreational land uses are considered moderately sensitive to air pollution because exercise places a high demand on respiratory functions, which can be impaired by air pollution. Sensitive receptors in the Project vicinity include several residential neighborhoods approximately 196 feet from the Project site. 409
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19 SECTION 3.0 – THRESHOLDS OF SIGNIFICANCE
The State CEQA Guidelines suggest, from an “air quality” perspective, that a project would normally be judged to produce a significant or potentially significant effect on the environment if the project were to:
Conflict with or obstruct implementation of the applicable air quality plan. Violate any air quality standard or contribute substantially to an existing or projected air quality violation.
Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable Federal or State AAQS. Expose sensitive receptors to substantial air pollutant concentrations. Create objectionable odors affecting a substantial number of people.

As indicated in Section 15064(i)(1) of the State CEQA Guidelines, “cumulatively considerable” is defined to mean “that the incremental effects of an individual project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects.”
In order to determine whether or not a proposed project would cause a significant effect on the environment, the impact of the project must be determined by examining the types and levels of emissions generated and its impacts on factors that affect air quality. To accomplish this determination of significance, the SCAQMD has established air pollution thresholds against which a proposed project can be evaluated and assist lead agencies in determining whether or not the proposed project is significant. If the thresholds are exceeded by a proposed project, then it should be considered significant.

While, the final determination of significance thresholds is within the purview of the lead agency pursuant to the State CEQA Guidelines, the SCAQMD recommends that the following air pollution thresholds be used by lead agencies in determining whether the construction or operational phase of a proposed project is significant. If the lead agency finds that the proposed project has the potential to exceed any of the air pollution thresholds, the project should be considered significant. These threshold factors are included below.

3.1. THRESHOLDS OF SIGNIFICANCE
The following significance thresholds (Table 6) for air quality have been established by the SCAQMD on a daily basis for construction and operations emissions and Table 6 also shows the SLTs for San Diego County:
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20 Table 6
Thresholds of Significance
SCAG Regional SDAG Screening Level
Construction
Emissions
Operations
Emissions
Total
Emissions
Total
Emissions
Total
Emissions
Pollutant (lbs/day) (lbs/day) (lbs/hr) lbs/day tons/year ROG 75 55
NOx 100 55 25 250 40
CO 550 550 100 550 100
PM10 150 150 ---- 100 15
PM2.5 55 55 ---- 55 10
SOx 150 150 25 250 40
Lead and lead
compounds
NA NA ---- 3.2 0.6
VOC NA NA ---- 75 13.7
During construction or operation, if any of the identified daily air pollutant thresholds are exceeded by the proposed Project, then the project’s air quality impacts may be considered significant. The SCAQMD indicates in Chapter 6 of its Handbook that it considers a project to be mitigated to a level of insignificance if its primary effects are mitigated below the thresholds provided above.

In the SDAG, the event that project emissions exceed the SLTs, specific modeling will be required for NO2, SO2, CO, and lead to demonstrate that the project’s ground-level concentrations, including appropriate background levels, do not exceed the NAAQS and CAAQS. For ozone precursors, PM10 and PM2.5, exceedances of the SLTs results in a significant impact.

3.2. LOCALIZED THRESHOLDS OF SIGNIFICANCE (LST)
In addition to the mass daily threshold values presented above, the SCAQMD has established the following threshold criteria to determine if a project has the potential to contribute to an exceedance of the State Ambient Air Quality Standards (SAAQ) as included in Table 1, Section

2. California State 1-hour CO standard of 20.0 ppm
California State 8-hour CO standard of 9.0 ppm
California State 1-hour NO2 standard of 0.25 ppm
SCAQMD 24-hour construction PM10 /67RIȝJP3
SCAQMD 24-hour construction PM2.5 /67RIȝJm3
SCAQMD 24-hour operational PM10 /67RIȝJP3
SCAQMD 24-hour operational PM2.5 /67RIȝJP3
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21 The significance of localized emissions impacts depends on whether ambient levels in the vicinity of the Project are above or below State standards. In the case of CO and NO2, if ambient levels are below the standards, a project is considered to have a significant impact if project emissions result in an exceedance of one or more of these standards. If ambient levels already exceed a State or federal standard, then project emissions are considered significant if they increase ambient concentrations by a measurable amount. This would apply to both PM10 and PM2.5; both of which are non-attainment pollutants. In these cases, local emissions are FRQVLGHUHGDVVLJQLILFDQWLIWKH\H[FHHGȝJP3 GXULQJFRQVWUXFWLRQRUȝJP3 during the subsequent operation of the site, both as measured at the proximate sensitive receptor locations.

3.3. ADDITIONAL INDICATORS
The SCAQMD recommends that “additional indicators” should be used as screening criteria with respect to air quality. Additional factors relevant to the project at hand identified in the Handbook include the following significance criteria:
Interference with the attainment of the Federal or State AAQS by either violating or contributing to an existing or projected air quality violation. Emit carcinogenic or toxic contaminants that exceed the maximum individual cancer risk of 10 in one million.

Again, the SCAQMD indicates in Chapter 6 of its Handbook that it considers a project to be mitigated to a level of insignificance if its effects are mitigated below the thresholds provided above.
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22 SECTION 4.0 – ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES The Project involves the nourishment of a 1,040-meter stretch of San Clemente Beach. Projected air emissions are prepared in accordance with the methodologies provided by the South Coast Air Quality Management District (SCAQMD) as included in its CEQA Air Quality Handbook, April 1993 (Handbook) as well as its Internet updates included on its web site. For the purposes of this analysis, construction is estimated to occur in 2010 with the 15-meter width alternative taking approximately 46 working days and the 35-meter width alternative taking 108 working days.

The calculated emissions of the project are compared to thresholds of significance for individual projects using the SCAQMD Handbook as well as updates included on the SCAQMD Internet Web site. The Handbook recommends assessing emissions of reactive organic compounds (ROC) as an indicator of ozone. For ease of the reader, the included analysis follows the outline of the CEQA Checklist.

The San Diego Air Pollution Control District does not provide quantitative thresholds for determining the significance of construction or mobile source-related impacts. However, the District specifies Air Quality Impact Analysis (AQIA) trigger levels for new or modified stationary sources. If these incremental levels for stationary sources are exceeded, an AQIA must be performed for the proposed new or modified source. Although these trigger levels do not generally apply to mobile sources or general land development projects, for comparative purposes San Diego County has established AQIAs as screening-level thresholds (SLTs). The County has stated that the SLTs may used to evaluate the increased emissions which would be discharged to the SDAB from proposed land development projects.

The information on San Diego’s thresholds are presented for informational purposes since all onshore emissions are located in the SCAB and off-shore sources are not under the jurisdiction of the local air district’s, therefore not subject to thresholds.

4.1. PROJECT CONSISTENCY WITH THE APPLICABLE AIR QUALITY PLAN The Project action represents the placement of sand on the beach. The Project would not result in significant localized air quality impacts at the proximate receptor locations and would implement those measures included in the AQMP considered as feasible and, as such, the Project is consistent with the goals of the AQMP and does not present a significant impact.

4.2. PROJECT POTENTIAL TO VIOLATE OR ADD TO A VIOLATION OF AN AIR

QUALITY STANDARD
CEQA inquires as to whether a project would violate any air quality standard or contribute substantially to an existing or projected air quality violation. A violation could occur over the short-term during project construction, or over the long-term during its subsequent operation. As there is no long-term operation portion of this project, only the short-term construction portion is discussed below.
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23 4.2.1 Localized Construction Impacts
Project construction has the potential to raise local ambient pollutant concentrations. This could present a significant impact if these concentrations were to exceed the allowable emissions as a function of receptor distance from the site boundary.

The analysis makes use of methodology included in the SCAQMD Methodology. In accordance with the Methodology, the analysis is only to include exhaust and dust emissions associated with those pieces of equipment that actually operate on-site and omits vehicle trips that are distributed over a large area. This omission would include vessel traffic that travels 21 miles between Oceanside and the offshore pump-out area near the Project site.

In the Methodology, the SCAQMD notes receptor locations as “off-site locations where persons may be exposed to the emissions from project activities. Receptor locations include residential, commercial, and industrial land use areas; and any other areas where persons can be situated for an hour or longer at a time.”
In accordance with the Methodology, receptor locations are to consider the actual location of the receptors. If these locations are unknown, or varied, they may be assumed to be located at distances of 25, 50, 100, 200, and 500 meters. In cases where proximate receptors may be closer than 25 meters, as per the Methodology, a value of 25 meters is to be used in the analysis as a worst-case scenario. In addition to the actual closest receptors to the Project area at approximately 55 meters away, the recommended SCAQMD default distances were used in this analysis for comparison.

In the cases of CO and NO2, the projected concentration is then added to an assumed ambient concentration in order to determine if the State AAQS would be exceeded. This ambient concentration is source-area dependant and is based on the peak value observed over the last three years of accumulated data at the nearest air monitoring station (Table 3). Because PM10 and PM2.5 are non-attainment pollutants, no ambient concentration is added. Instead, in both cases, a short-term construction standard defined as a measurable increase of 10.4 μg/m3 is to be applied at the proximate sensitive receptor locations. Table 7 presents the daily projected emissions from on-site construction as well as the projected concentrations at the various default and actual receptor distances. Note that all concentrations are within their respective criteria and the impact is less than significant.
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24 Table 7
Localized Construction Emissions Concentrations1
Distance CO (1-Hr
Conc.)2
CO (8-Hr
Conc.)3
NO2 (1-Hr
Conc.)4
PM10 (24-Hr
Conc.)
PM2.5 (24-Hr
Conc.)
Peak Daily Onsite Emissions
(lb/day) 43.6 43.6 94.9 9.7 4.0
Concentration at 25 meters 3.08 2.16 0.11 10.31 3.83
Concentration at 50 meters 3.07 2.15 0.11 8.50 3.31
Concentration at 55 meters
(Nearest Actual Receptor) 3.07 2.15 0.11 8.20 3.21
Concentration at 100 meters 3.06 2.14 0.11 6.25 2.51
Concentration at 200 meters 3.04 2.13 0.11 4.10 1.67
Concentration at 500 meters 3.02 2.11 0.11 1.91 0.78
Ambient Air Quality Standard 20 ppm 9.0 ppm 0.18 ppm 10.4 μg/m3 10.4 μg/m3 Exceeds Standard? No No No No No
1 CO and NO2 are in ppm, PM10 and PM2.5 are in μg/m3
. 2 Includes a background concentration of 3.0 ppm.
3 Includes a background concentration of 2.1 ppm.
4 Includes a background concentration of 0.10 ppm.

4.3. PROJECT POTENTIAL TO RESULT IN A CUMULATIVELY CONSIDERABLE

INCREASE IN CRITERIA POLLUTANTS
CEQA inquires as to whether a project would result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable Federal or State AAQS (including releasing emissions which exceed quantitative thresholds for ozone precursors).

4.3.1 Site Construction
Air quality impacts may occur during site preparation, grading, and sporadic maintenance activities required for implementation of the proposed land use. Maintenance could take place once every six years depending on need and financial ability. Maintenance would result in a repetition of the initial construction activities.

The Project includes two alternatives that involve approximately 4 and 9 acres of beach nourishment for the 15- and 35-meter widths, respectively. There is no building construction or paving activities associated with this project. Construction would occur over approximately 46 and 108 working days, respectively. Values used for analysis are included in Appendix A.

Table 8 summarizes the daily emissions for construction in comparison with the SCAQMD regional thresholds of significance. Emissions associated with onshore heavy equipment are 415

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25 based on the OffRoad2007 model runs as provided by the SCAQMD on their Internet web site for year 2010 construction equipment. The SCAQMD presents emissions for most pieces of heavy construction equipment at differing horsepower levels generated using the OffRoad2007 Computer Model. The actual horsepower of the anticipated pieces of equipment (i.e., Cat D10 dozers at 580 hp and 988 Front-end loaders at 430 hp) were then extrapolated from the two pieces of similar equipment with the nearest horsepower ratings above and below the expected piece of equipment.

Some dust with its attendant PM10 and PM2.5 would also be generated from the onshore movement of sand. The 15- and 35-meter Project alternatives would encompass approximately 4 and 9 acres, respectively. The daily area of disturbance would be approximately the same for both alternatives, with the difference being in the duration of the disturbance.

The URBEMIS2007 model developed to determine the emissions associated with land-use projects estimates that each acre disturbed generates 20 pounds of PM10 and that 25 percent of the construction area is active at any one time. As such, using the URBEMIS model would result in 1 acre of disturbance daily for the 15-meter alternative and 2.25 acres daily for the 35-meter alternative. As a conservative approach, this analysis assumes that 25 percent of the larger area is disturbed for either alternative resulting in a disturbance of approximately 2.25 acres daily and, in the absence of any dust suppression, 45 pounds of PM10.

Like all projects in the South Coast Air Basin, the construction would be subject to SCAQMD Rule 403 requiring dust control. The URBEMIS2007 model estimates that twice daily watering reduced the dust by about 50 percent whereas thrice daily watering raises this value to about 65 percent. The materials to be placed on the beach are ocean bottom and are pumped onto the beach as a slurry. Because the material is totally saturated, little if any dust is released during its movement. As such, a control efficiency value of 85 percent was assumed for dust suppression as a conservative estimate.

Since the borrow site is in the SDAB and the project site is in the SCAB, emissions were assigned to the separate basins by assigning all of the loading emissions, half of the idling emissions and 81 percent of the sailing emissions to the SDAB and all of the unloading emissions, half of the idling emissions, 19 percent of the sailing emissions and all of the on-shore emissions to the SCAB. In total, all the on-shore and 32 percent of the off-shore emissions will be in the SCAB and the other 68 percent of the off-shore emissions would be in the SDAB.

Table 8
Comparison of Unmitigated Projected Construction Emissions and Criteria Values CO NOx ROG SOX
Total
PM101
Total
PM2.52 CO2
Lbs/Day
On Shore
Equipment 43.2 94.9 12.4 0.1 3.9 3.4 8,277.0
Dust 0 0 0 0 6.8 1.4 0
On Shore
Vehicles 2.5 0.2 0.3 0.0 0.0 0.0 291.8
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26 Off Shore
Sources 327.4 2,185.5 63.9 140.4 66.2 58.9 108,722.6
All Sources 373.1 2,280.6 76.6 140.5 76.9 63.7 117,291.4 On Shore
Sources 45.7 95.1 12.7 0.1 10.7 4.8 8,568.8
Daily
Threshold: 550 100 75 150 150 55 NT3
Significant
? NO NO NO NO NO NO NO
Pounds and Tons/Alternative
50 Feet (15 Meter) Width Alternative
Pounds 17,163.0 104,906.5 3,519.2 6,463.9 3,532.9 2,833.3 5,395,405.4 Tons 8.6 52.5 1.8 3.2 1.8 1.5 2,697.7
115 Feet (35 Meter) Width Alternative
Pounds 1,853,603.2 11,329,898.3 380,072.7 698,095.8 381,553.7 316,792.3 582,703,786.0 Tons 926.8 5,664.9 190.0 349.0 190.8 158.4 291,351.9 1 Assumes 85 percent control efficiency for wet material. 2 Based on 99 percent of the PM10 for on-road emissions, 89 percent of the PM10 for off-road emissions, and 21 percent of the PM10 for fugitive dust.
3 NT – No Threshold.

Data and emissions for the watercraft are based on data supplied by Moffatt & Nichol. The barge is estimated at approximately 4,300 hp for propulsion and 1,700 hp for the dredge pump.

Additionally, a generator and auxiliary power source would also be used and are each rated at 565 hp. A tug would assist unloading operations and is estimated at 4,268 hp.

Emissions would also be generated from the construction crew in their daily commutes and by the on-site use of two pick-up trucks. Emissions for these vehicles were based on the EMFAC2007 computer model and assume Year 2010 emission factors. The total daily emissions generated by vehicle travel in Orange County projected by the EMFAC2007 model was divided by the total number of daily miles by vehicle type and a grams-per-mile by vehicle type is determined. Members of the construction crew are each estimated to travel 25.4 miles round-trip in accordance with the URBEMIS2007 computer model for home-to-work travel distances in Orange County.

In this case, the total number of vehicles was raised from 10 to 12 to account for the use of two on-site pick-up trucks during the day. Actual miles for these two pick-ups would be less than the

25.4-mile value used in the analysis, but these emissions are minimal relative to those of the offshore and heavy equipment and more accurate data as to their use would not change the outcome of the analysis.
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27 The two Project alternatives would use the same level of equipment on a daily basis with the difference being in the timeframe involved. As shown in Table 8, NOx, ROG, and PM2.5 emissions could exceed their respective thresholds of 100, 75, and 55 pounds per day. These exceedences represent a potentially significant impact. Model results appear in Appendix A.

4.3.1.1 Mitigation Measures
Site construction could exceed the daily threshold for NOx, ROG, and PM2.5 emissions.

Particulate emissions, including PM10 and PM2.5 are subject to Rule 403 and mitigation for an exceedance condition is usually in the form of additional soil wetting. However, as noted in the analysis, the material is pumped to the beach as a slurry and is completely saturated resulting in very little fugitive dust and its resultant particulates. As such, enhanced watering is neither prescribed nor should it be necessary. Because the bulk of the PM2.5 is produced by offshore sources, there is little control over these emissions. Applicable mitigation for NOx and ROG are included below. The included measures would also reduce PM2.5 for onshore heavy equipment exhaust.

4.3.1.2 NOx, ROG, and PM2.5 Emissions Mitigation Measures The Applicant shall specify that the construction contractors shall use onshore heavy equipment that meets Tier II or higher air pollutant emission standards where these standards are applicable and equipment available.
All heavy equipment shall be maintained and tuned per manufacturer's specifications to perform at California Air Resources Board (CARB) and/or EPA certification, where applicable, levels and to perform at verified standards applicable to retrofit technologies.

4.3.1.3 Residual Impacts
The requirement for Tier II heavy equipment, where applicable, could reduce NOx emissions by about 40 percent and particulate emissions by about 25 percent over Tier I equipment levels. A higher percentage reduction would be achieved over the use of equipment-produced prior to Tier I requirements. Because the status of the actual equipment assemblage, as well as those pieces subject to Tier II requirements, is variable, the overall reduction in NOx emissions could be less than the 40 percent reduction noted for the use of Tier II equipment. Based on the NOx levels included in Table 8, even if a 40 percent reduction were obtained for all onshore heavy equipment, the NOx impact is expected to remain significant and unavoidable as do PM2.5 emissions assuming this TIER II equipment reduces particulate levels by 25 percent.

CO and ROG levels associated with onshore heavy equipment construction would also be reduced. If the 40 percent reduction associated with NOx control is also applied to ROG, onshore heavy equipment ROG would be reduced from 12.4 to 7.4 pounds per day. Total daily ROG would be reduced to 71.6 pounds per day and the impact of ROG could be reduced to less than significant.
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28 Table 9 presents the results of the mitigation. Note that even with mitigation, NOx and PM2.5 emissions remain above their respective daily significance thresholds. Modeling details are included as Appendix A.

Table 9
Comparison of Mitigated Construction Emissions and Criteria Values CO NOx ROG SOX Total
PM101
Total
PM2.52 CO2
Lbs/Day
On Shore
Equipment 43.2 56.9 7.4 0.1 2.9 2.6 8,277.0
Dust --- --- --- --- 6.8 1.4 ---
On Shore
Vehicles 2.5 0.2 0.3 0.0 0.0 0.0 291.8
Off Shore
Sources 327.4 2,185.5 63.9 140.4 66.2 58.9 108,722.6
All Sources 373.1 2,242.6 71.6 140.5 76.8 63.8 117,291.4 On Shore
Sources 45.7 57.1 7.7 0.1 9.7 4.0 8,568.8
Daily
Threshold: 550 100 75 150 150 55 NT3
Significant
? NO NO NO NO NO NO NO
Pounds and Tons/Alternative
15 Meter Width Alternative4
Pounds 17,163.0 103,161.1 3,291.4 6,463.9 3,532.9 2,833.3 5,395,405.4 Tons 8.6 51.6 1.6 3.2 1.8 1.5 2,697.7
35 Meter Width Alternative5
Pounds 1,853,603.2 11,141,399.7 355,468.2 698,095.8 381,553.7 316,792.3 582,703,786.0 Tons 926.8 5,570.7 177.7 349.0 190.8 158.4 291,351.9 1 Assumes 85 percent control efficiency for wet material. 2 Based on 99 percent of the PM10 for on-road emissions, 89 percent of the PM10 for off-road emissions, and 21 percent of the PM10 for fugitive dust.
3 NT – No Threshold.
4 Based on 46 working days.
5 Based on 108 working days.

4.3.2 Site Operations
The Proposed nourishment project does not include an operational phase. Therefore, there are no operational emissions associated with the Proposed Project.

4.4. PROJECT POTENTIAL TO EXPOSE SENSITIVE RECEPTORS TO

SUBSTANTIAL POLLUTANT CONCENTRATIONS
Construction of the Project presents the potential to expose sensitive receptors to substantial pollutant concentrations. This consideration is addressed below. 419

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29 4.4.1 Short-Term (Construction) Impacts
As demonstrated in Section 4.2.1 above, daily emissions for CO, NOx, PM10, and PM2.5 were modeled to determine their concentration and contribution to the ambient concentrations within the Project vicinity and as shown in Table 7 above, the concentrations of emissions are below the localized significance threshold criteria. As such, Project construction activities will not result in potential exposure of sensitive receptors to substantial pollutant concentrations.

4.4.2 Long-Term (Operational) Impacts
The Proposed nourishment project does not include an operational phase. Therefore there are no long-term impacts associated with the Proposed Project.

4.5. PROJECT POTENTIAL CREATE OBJECTIONABLE ODORS
Project construction would involve the use of heavy equipment creating exhaust pollutants from on-site earth. With regard to nuisance odors, any air quality impacts will be confined to the immediate vicinity of the equipment itself. By the time such emissions reach any sensitive receptor sites away from the Project site, they will be diluted to well below any level of air quality concern.

Sediments to be placed on the beach would not contain a high level of organic debris and thus, while an odor may be noted, it would be typical of any odor associated with low tide conditions.

This impact is therefore considered not significant.

4.6. GREENHOUSE GAS EMISSIONS
At this time, greenhouse gases (primarily CO2) are not regulated as a criteria pollutant and there are no significant criteria for these emissions. Furthermore, the Final 2007 AQMP does not set CEQA targets that can be used to determine any potential threshold values. Nevertheless, in order to provide decision-makers with as much information as possible, this analysis quantifies, to the extent feasible, potential greenhouse gas emissions associated with the proposed development.

4.6.1 Construction
Construction activities would consume fuel and result in the generation of greenhouse gases.

Construction CO2 emissions associated with the use of onshore heavy equipment are as projected by the OffRoad2007 model included on the SCAQMD Internet web site. CO2 emissions for the ocean-going vessels are based on fuel use factors included in Table A9-3-E (Fuel Use Estimates Per Horsepower Hour) of the SCAQMD Handbook and CO2 emissions are based on the BAAQMD document, Source Inventory of Bay Area Greenhouse Gas Emissions, Table B: Generalized GHG Emission Factors (Lbs/Usage Unit) and are included in Table 8, above. In accordance with the Project construction schedule, approximately 5,395,405.4pounds (2,697.7 tons) of CO2 would be produced during the 46 working days associated with the 15- meter width alternative and approximately 582,703,786.0 pounds (291,351.9 tons) would be produced during the 108 working days associated with the 35-meter width alternative. 420
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30 In accordance with the 2007 AQMP, the emission levels in California are estimated to be 532 million metric tons (568.4 short tons) CO2 equivalent for 2010. At approximately 2,697.7 tons, the 15-meter width alternative represents about 0.0005 percent of this State’s annual CO2 emissions budget. At about 291,351.9 tons, the 35-meter width alternative represents about 0.05 percent if the State’s annual CO2 emissions budget.
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31 SECTION 5.0 – CUMULATIVE IMPACTS
The CEQA Guidelines require that projects be evaluated with respect to their contribution to the cumulative effects resulting from past, present, and probable future projects. This contribution with respect to air emissions would typically include both construction and operational emissions. In this case, the Project represents a construction effort. There are no physical structures to be built nor would the Project increase attendance at the beach.

Construction of the related projects would be short-term and depending on the extent of construction, could have effects similar to or greater than that of the proposed project. Even with the prescribed mitigation, the Project is anticipated to exceed the significance threshold limitations for NOx and PM2.5. In accordance with SCAQMD methodology, projects that exceed the daily threshold values and cannot be mitigated to less than the SCAQMD thresholds add significantly to the cumulative impact. As such, the Project is also considered as significant at the cumulative level.

With respect to cumulative emissions concentrations and their potential impact on sensitive receptors, the localized impact analysis demonstrates that all emissions levels would remain within their respective threshold values and the Project would not result in emissions in excess of the AAQS. As such, the Project does not add to a cumulative violation of the standards. 422
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32 SECTION 6.0 – REFERENCES
Bay Area Air Quality Management District
Source Inventory of Bay Area Greenhouse Gas Emissions, December 2008.

California Air Pollution Control Officers Association
Air Toxics Assessment Manual, October 1, 1987.

California Air Resources Board
EMFAC2007 Computer Model, Version 2.3, November 1, 2006.

URBEMIS2007 Computer Model, Version 9.2.2, September 2007.

South Coast Air Quality Management District
A Climatological Air Quality Profile, California South Coast Air Basin, January 1980.

Air Pollution Data Monitoring Cards (2003, 2004, 2005, 2006, 2007).

Rules and Regulations, 2007.

Final 2007 AQMP, July 13, 2007.

Final 2003 AQMP, August 1 2003.

Off-Road Mobile Source Emission Factors, October 10, 2008.

Final-Methodology to Calculate Particulate Matter (PM) 2.5 and PM 2.5 Significance Thresholds, October 2006.

Sample Construction Scenarios for Projects Less than Five Acres in Size, February 2005.

Final Localized Significance Threshold Methodology, June 2003 SCAQMD CEQA Air Quality Handbook, April 1993.

Southern California Association of Governments
1997 Air Quality Management Plan, 1997.

United States Environmental Protection Agency
SCREEN3 Dispersion Model, Version Dated 95250
Western Regional Climate Center
http://www.wrcc.dri.edu/Climsum.html
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APPENDIX A – CALCULATION OF UNMITIGATED CONSTRUCTION EMISSIONS 424
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APPENDIX A

CALCULATION OF UNMITIGATED CONSTRUCTION EMISSIONS
The included spreadsheet may be used to determine average daily emissions associated with project construction. Heavy equipment emission factors are as projected using the OFFROAD2007 Model runs as included on the SCAQMD Internet web site. Dredge and tug criteria pollutant emissions are based on emission factors provided by Jim McNally of Moffatt & Nichol. Dredge and tug CO2 emissions are based on the BAAQMD document, Source Inventory of Bay Area Greenhouse Gas Emissions. Vehicle Emissions are based on an Orange County Year 2010 model run of the CARB EMFAC2007 computer model. The total daily vehicle emissions for each vehicle class included in the model was divided by the total number of vehicles miles traveled in each class so that an average emission rate per mile could be determined. Worker vehicles are a composite of light duty autos, light duty trucks less than 3,750 pounds, and light trucks between 3,751 and 5,150 pounds. Per the URBEMIS2007 computer model, Orange County trip lengths are set at 25.4 miles per trips for workers and 30 miles per trips for trucks. While 10 workers are anticipated, 12 vehicles are assumed to account for the two to be used on-site during the day. PM10 emissions associated with dust are based on the assumptions included in the URBEMIS2007 computer model. The model reports that 20 pounds of PM10 are generated per acre disturbed per day and the active area is 25 percent of the site. This analysis assumes 25 percent of the 35-meter width, 9-acre site. A conservative control efficiency of 85 percent is then assumed for the movement of saturated beach sand.

PM2.5 emissions are based on 99 percent of vehicle emissions, 89 percent of off-road diesel emissions, and 21 percent of fugitive dust.
425

INPUT ASSUMPTIONS
Heavy Equipment Emissions (All Diesel Except Where Noted) Exhaust Emission Factors (Pounds per Horsepower-Hour) Equipment Type #Days Hr/Day Hp Load % CO NOx ROG SOx PM10 CO2Dredge Propulsion Loading 1 4.58 4300 65 0.0044 0.0296 0.0008 0.0019 0.0009 1.4784Dredge Propulsion Sailing 1 11.99 4300 80 0.0044 0.0296 0.0008 0.0019 0.0009 1.4784Dredge Propulsion Unloading 1 3.2 4300 5 0.0044 0.0296 0.0008 0.0019 0.0009 1.4784Dredge Propulsion Idling 1 1.83 4300 5 0.0044 0.0296 0.0008 0.0019 0.0009 1.4784Dredge Pump/Jets Loading 1 4.58 1700 65 0.0044 0.0296 0.0008 0.0019 0.0009 1.4784Dredge Pump/Jets Sailing 1 11.99 1700 5 0.0044 0.0296 0.0008 0.0019 0.0009 1.4784Dredge Pump/Jets Unloading 1 3.2 1700 70 0.0044 0.0296 0.0008 0.0019 0.0009 1.4784Dredge Pump/Jets Idling 1 1.83 1700 0 0.0044 0.0296 0.0008 0.0019 0.0009 1.4784Tug Unloading 1 3.2 4268 40 0.0044 0.0296 0.0008 0.0019 0.0009 1.4784Dredge Generators 1 7.67 565 35 0.0044 0.0296 0.0008 0.0019 0.0009 1.4784Auxiliary 1 7.67 565 35 0.0044 0.0296 0.0008 0.0019 0.0009 1.4784Crew Boat (in gal/hr) 1 20 2.8 50 0.14 0.34 0.18 0.027 0 1.4784Dozer (@ rated load factor) 2 10 580 100 0.003002328 0.005529528 0.000725584 4.48243E-06 0.000236143 0.456676738Front-End Loader (@ rated load factor) 2 10 430 100 0.000979162 0.003571376 0.000461013 3.89824E-06 0.000130941 0.346457444Mobile Source Emissions Exhaust Emission Factors (Pounds per Mile)Vehicle Class # Trips Mi/Trip CO NOx ROG SOx PM10 CO2 Workers (Inc. Autos & Trks Under 5,151
Lbs) 12 25.4 0.008152033 0.000729368 0.000894025 9.1476E-06 8.3548E-05 0.95744843 Heavy-Heavy Trucks (33,001 - 60,000 lb) 0 30 0.0225 0.034684466 0.003859223 4.85437E-05 0.001553398 4.004854369 Dust Emissions PM10 Emission factor (Pounds per Acre per Day) Area Disturbed # Acres # Days % Control
PM10
(#/Acre)
Active Area 2.25 1 85 20.00
426

OUTPUT VALUES
Heavy Equipment Emissions Exhaust Emissions (Pounds Total)Equipment Type CO NOx ROG SOx PM10 PM2.5 CO2Dredge Propulsion Loading 56.3 378.9 10.2 24.3 11.5 10.3 18,925.1Dredge Propulsion Sailing 181.5 1,220.9 33.0 78.4 37.1 33.0 60,977.5Dredge Propulsion Unloading 3.0 20.4 0.6 1.3 0.6 0.6 1,017.1Dredge Propulsion Idling 1.7 11.6 0.3 0.7 0.4 0.3 581.7Dredge Pump/Jets Loading 22.3 149.8 4.0 9.6 4.6 4.1 7,482.0Dredge Pump/Jets Sailing 4.5 30.2 0.8 1.9 0.9 0.8 1,506.7Dredge Pump/Jets Unloading 16.8 112.7 3.0 7.2 3.4 3.1 5,629.7Dredge Pump/Jets Idling 0.0 0.0 0.0 0.0 0.0 0.0 0.0Tug Unloading 24.0 161.7 4.4 10.4 4.9 4.4 8,076.6Dredge Generators 6.7 44.9 1.2 2.9 1.4 1.2 2,242.4Auxiliary 6.7 44.9 1.2 2.9 1.4 1.2 2,242.4Crew Boat 3.9 9.5 5.0 0.8 0.0 0.0 41.4Dozer 34.8 64.1 8.4 0.1 2.7 2.4 5,297.5Front-End Loader 8.4 30.7 4.0 0.0 1.1 1.0 2,979.5Total Daily Emissions (Pounds) 370.6 2,280.4 76.2 140.5 70.0 62.3 116,999.6Total Daily Emissions (Tons) 0.2 1.1 0.0 0.1 0.0 0.0 58.5 427

OUTPUT VALUES
Mobile Source Emissions Exhaust Emissions (Pounds Total)Vehicle Class CO NOx ROG SOx PM10 PM2.5 CO2Workers (Inc. Autos & Trks Under 5,151 Lbs) 2.5 0.2 0.3 0.0 0.0 0.0 291.8Heavy-Heavy Trucks (33,001 - 60,000 lb) 0.0 0.0 0.0 0.0 0.0 0.0 0.0Total Mobile-Source Emissions (Pounds) 2.5 0.2 0.3 0.0 0.0 0.0 291.8Total Mobile-Source Emissions (Tons) 0.0 0.0 0.0 0.0 0.0 0.0 0.1Dust Emissions Dust PM10 Emissions (Pounds Total)Area Disturbed PM10 PM2.5Active Area 6.8 1.4Total PM10 From Dust Emissions (Pounds) 6.8 1.4Total PM10 From Dust Emissions (Tons)Total Daily Emissions CO NOx ROG SOx PM10 PM2.5 CO2Pounds 373.1 2,280.6 76.5 140.5 76.8 63.8 117,291.4Tons 0.2 1.1 0.0 0.1 0.0 0.0 58.6Emissions for 46 daysPounds 17,163.0 104,906.5 3,519.2 6,463.9 3,532.9 2,933.3 5,395,405.4Tons 8.6 52.5 1.8 3.2 1.8 1.5 2,697.7Emissions for 108 daysPounds 1,853,603.2 11,329,898.3 380,072.7 698,095.8 381,553.7 316,792.3 582,703,786.0Tons 926.8 5,664.9 190.0 349.0 190.8 158.4 291,351.9 428
APPENDIX B – CALCULATION OF MITIGATED CONSTRUCTION EMISSIONS 429
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APPENDIX B

This analysis assumes 25 percent of the 35-meter width, 9-acre site. A conservative control efficiency of 85 percent is then assumed for the movement of saturated beach sand. PM2.5 emissions are based on 99 percent of vehicle emissions, 89 percent of off-road diesel emissions, and 21 percent of fugitive dust.
430

4.48243E06 0.000236143 0.456676738
Front-End Loader (@ rated load factor) 2 10 430 100 0.000979162 0.003571376 0.000461013

3.89824E06 0.000130941 0.346457444
Mobile Source Emissions Exhaust Emission Factors (Pounds per Mile)Vehicle Class # Trips Mi/Trip CO NOx ROG SOx PM10 CO2Workers (Inc. Autos & Trks Under 5,151 Lbs) 12 25.4 0.008152033 0.000729368 0.000894025

9.1476E06 8.3548E-05 0.95744843
Heavy-Heavy Trucks (33,001 - 60,000 lb) 0 30 0.0225 0.034684466 0.003859223

4.85437E05 0.001553398 4.004854369
Dust Emissions PM10 Emission factor (Pounds per Acre per Day)Area Disturbed # Acres # Days % Control PM10
(#/Acre)
Active Area 2.25 1 85 20.00
431

OUTPUT VALUES
Dust Emissions Dust PM10 Emissions (Pounds Total)Area Disturbed PM10 PM2.5Active Area 6.8 1.4Total PM10 From Dust Emissions (Pounds) 6.8 1.4Total PM10 From Dust Emissions (Tons)Total Daily Emissions CO NOx ROG SOx PM10 PM2.5 CO2Pounds 373.1 2,280.6 76.5 140.5 76.8 63.8 117,291.4Tons 0.2 1.1 0.0 0.1 0.0 0.0 58.6Emissions for 46 daysPounds 17,163.0 104,906.5 3,519.2 6,463.9 3,532.9 2,933.3 5,395,405.4Tons 8.6 52.5 1.8 3.2 1.8 1.5 2,697.7Emissions for 108 daysPounds 1,853,603.2 11,329,898.3 380,072.7 698,095.8 381,553.7 316,792.3 582,703,786.0Tons 926.8 5,664.9 190.0 349.0 190.8 158.4 291,351.9 433
APPENDIX C – LOCALIZED SIGNIFICANCE THRESHOLD DISPERSION MODELING

METHODOLOGY FOR CONSTRUCTION AND OPERATION EMISSIONS
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APPENDIX C

LOCALIZED SIGNIFICANCE THRESHOLD DISPERSION MODELING

METHODOLOGY

FOR CONSTRUCTION AND OPERATIONAL EMISSIONS
In accordance with the SCAQMD criteria, peak daily emissions for CO, NO2, PM10, and PM2.5 were modeled to determine their concentration and contribution to the ambient concentrations within the project vicinity. The analysis makes use of methodology included in the SCAQMD Methodology (SCAQMD, June 2003).

Modeling was performed using the USEPA SCREEN3 dispersion model and includes those emissions sources that operate continually at the site (i.e., heavy equipment) and two pick-up trucks. Mobile source emissions (i.e., worker commutes and haul trips) are not to be included in the analysis as these emissions are spread over a large area and do not represent a localized source. The maximum daily unmitigated emissions for CO, NOx, PM10, and PM2.5 were determined based on emissions projections included in the analysis.

For construction, highest values are as presented in Table 8 of the analysis. PM10 and PM2.5 were further broken down into fugitive dust and exhaust particulates as these are released at differing heights.

An average hourly emission rate was determined and the average hourly emission rate in grams per second was calculated.

CO = 43.6 lb/day x 454 gm/lb / 10 hr/day / 60 min/hr / 60 sec/min = 0.55 gm/sec NOx = 94.9 lb/day x 454 gm/lb / 10 hr/day / 60 min/hr / 60 sec/min = 1.20 gm/sec PM10 dust = 6.8 lb/day x 454 gm/lb / 10 hr/day / 60 min/hr / 60 sec/min = 0.09 gm/sec PM10 exhaust = 2.9 lb/day x 454 gm/lb / 10 hr/day / 60 min/hr / 60 sec/min = 0.04 gm/sec PM2.5 dust = 1.4 lb/day x 454 gm/lb / 10 hr/day / 60 min/hr / 60 sec/min = 0.02 gm/sec PM2.5 exhaust = 2.6 lb/day x 454 gm/lb / 8 hr/day / 60 min/hr / 60 sec/min = 0.03 gm/sec These values were then divided by the project area and a 1-hour concentration was derived. In accordance with the URBEMIS2007 model, the daily disturbed area represents 25 percent of the site (i.e., 2.25 acres) and the total site is based on the 9-acre area. 9 acres x 43,560 ft2/acre x 0.0929 ft2/m2 = 36,421 m2
CO = 0.55 gm/sec / 36,421 m2 = 0.00001510 gm/sec/m2
NOx = 1.20 gm/sec / 36,421 m2 = 0.00003286 gm/sec/m2
PM10 dust = 0.09 gm/sec / 36,421 m2 = 0.00000235 gm/sec/m2 PM10 exhaust = 0.58 gm/sec / 36,421 m2 = 0.00000100 gm/sec/m2 PM2.5 dust = 0.02 gm/sec / 36,421 m2 = 0.00000048 gm/sec/m2 PM2.5 exhaust = 0.03 gm/sec / 36,421 m2 = 0.00000090 gm/sec/m2 435

These values were then modeled as an area source using the USEPA SCREEN3 dispersion model. Model parameters were selected in accordance with the Methodology. Accordingly, the emissions plume was set at an elevation of 5 meters while the receptors were set at an elevation of 2 meters. As a reasonable worst-case, the highest atmospheric stability class was used in the modeling effort. In accordance with the discussion of local meteorology, daily wind speed was set at 6 mph (2.68 m/sec), the minimum average daily wind speed through the project area.

According to the Methodology, receptors are to be located at their actual distances or may be assumed to be located at distances of 25, 50, 100, 200, and 500 meters. In cases where proximate receptors may be closer than 25 meters, as per the Methodology, a value of 25 meters is to be used in the analysis as a worst-case scenario. The closest receptors are actually about 55 meters from the site.

In the case of the 1-hour CO standard, the modeled concentration was added directly to an assumed ambient concentration. This ambient concentration is source-area dependant and is based on the peak 1-hour value observed over the last three years of accumulated data (i.e., 3 ppm). In the case of CO, SCREEN3 reports results in terms of μg/m3 . However, the standard is
in ppm and the value obtained from the SCREEN3 model must be converted.

For CO, the conversion factor is:

Conc. (ppm) / Conc. (μg/m3
) = pressure (mb) / Temp (k) x molecular wt / 8.314E-2
Conc. (ppm) / Conc. (μg/m3
) = 1,013.25 mb / 293.15 k x 28 / 8.314E-2
= 1,164.1
As an example, in the case of CO, the SCREEN3 Model projects a CO concentration of 93.78 μg/m3 at 25 meters.

93.78 μg/m3 / 1,164.1 = 0.08 ppm
This value is then added to the ambient concentration (i.e., 3 ppm).

For the 8-hour CO standard, the 1-hour concentration is multiplied by a persistence factor of 0.7 as recommended by the California Air Pollution Control Officers Association (Air Toxics Assessment Manual, October 1, 1987). The resultant value was added to the peak 8-hour value observed over the last three years of accumulated data, (i.e., 2.1 ppm).

In the case of NO2 the calculation is slightly more complex. The ambient air quality standards are written in terms of NO2. However, heavy equipment primarily emits NO that then goes on to form NO2. As such, the Methodology includes factors than can be used to determine NO2 concentrations at varying distances. These factors are included in the following table.

The NOx concentration modeled using the SCREEN3 model was then multiplied by the NO2/NOx ratio. Like CO, SCREEN3 reports NOx concentrations in μg/m3 while the standard is in ppm. In this case, the conversion is:

Conc. (ppm) / Conc. (μg/m3
) = 1,013.25 mb / 293.15k x 46 / 8.314E-2
= 1,912.4
436

NO2-to-NOx Ratio as a Function of Downwind Distance
Downwind Distance (m) NO2/NOx Ratio
20 0.053
251 0.054
50 0.059
551 0.060
100 0.074
200 0.114
500 0.258
1 Value is not included in the SCAQMD methodology and is extrapolated.

As an example, in the case of NOx, the SCREEN3 Model projects a concentration of 204.1 μg/m3 at 25 meters.
204.1 μg/ m3 x 0.054 / 1,912.4 = 0.0058 ppm
The resultant value is added to the peak 1-hour value observed over the last three years of accumulated data, (i.e., 0.10 ppm).

In the cases of PM10 and PM2.5, no ambient concentration is added. However, in both cases, construction is subject to a 24-hour concentration standard of 10.4 μg/ m3 . For the 24-hour
standard, the 1-hour concentration is multiplied by a persistence factor of 0.4 as recommended by the California Air Pollution Control Officers Association (Air Toxics Assessment Manual, October 1, 1987). Because exhaust emissions and fugitive dust are produced at different heights (i.e., 5 and 1 meter, respectively), these emissions were modeled separately and their resultant concentrations added at the receptor locations. Results of the analysis are included below.

Review of Table 7 shows the CO, NOx, PM10, and PM2.5 values associated with on-site emissions sources. Table 9 presents the peak daily projected emissions from on-site construction as well as the projected concentrations at the various default receptor distances. Note that both PM10 and PM2.5 are projected to exceed their thresholds at local receptor locations and the impact is potentially significant.
437

Localized Construction Emissions Concentrations1
Distance
CO
(1-Hr
Conc.)2
CO
(8-Hr
Conc.)3
NO2
(1-Hr
Conc.)4
PM10
(24-Hr
Conc.)
PM2.5
(24-Hr
Conc.)
Peak Daily Onsite
Emissions (lb/day) 43.6 43.6 94.9 9.7 4.0
Concentration at 25
meters 3.08 2.16 0.11 10.31 3.83
Concentration at 50
meters 3.07 2.15 0.11 8.50 3.31
Concentration at 55
meters (Nearest
Receptor)

3.07 2.15 0.11 8.20 3.21
Concentration at 100
meters 3.06 2.14 0.11 6.25 2.51
Concentration at 200
meters 3.04 2.13 0.11 4.10 1.67
Concentration at 500
meters 3.02 2.11 0.11 1.91 0.78
Ambient Air Quality
Standard 20 ppm 9.0 ppm 0.18 ppm 10.4 μg/m3 10.4 μg/m3
Exceeds Standard? No No No No No
1 CO and NO2 are in ppm, PM10 and PM2.5 are in μg/m3
. 2 Includes a background concentration of34 ppm.
3 Includes a background concentration of 2.1 ppm.
4 Includes a background concentration of 0.10 ppm.
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APPENDIX D – COASTAL ENGINEERING REPORT
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San Clemente Shoreline Feasibility Study
Orange County, California

COASTAL ENGINEERING

APPENDIX
Final Report
U.S. Army Corps of Engineers
Los Angeles District
JULY 2011
441
i

TABLE OF CONTENTS
1 GENERAL............................................................................................................................... 1

1.1 Introduction ...................................................................................................................................... 1

1.1.1 Risk and Uncertainty ............................................................................................................... 1

1.1.2 Significant References ............................................................................................................ 1

1.1.3 Units ........................................................................................................................................ 1

1.2 Previous Reports.............................................................................................................................. 2 2 BASELINE COASTAL AND OCEANOGRAPHIC CONDITIONS............................................. 3

2.1 Study Area Definition ....................................................................................................................... 3

2.1.1 Project Baseline....................................................................................................................... 3

2.1.2 Reach Description ................................................................................................................... 3

2.2 Water Levels .................................................................................................................................... 8

2.2.1 Tides........................................................................................................................................ 8

2.2.2 Storm Surge ............................................................................................................................ 9

2.2.3 Relative Sea Level Change..................................................................................................... 9

2.3 Topography / Marine Geophysical .................................................................................................10

2.3.1 Topography ...........................................................................................................................10

2.3.2 Marine Geophysical...............................................................................................................11

2.4 Wave Climatology ..........................................................................................................................15

2.4.1 Wave Heights ........................................................................................................................16

2.4.2 Wave Periods ........................................................................................................................18

2.4.3 Wave Directions ....................................................................................................................18

2.5 Littoral Processes and Sediment Transport...................................................................................20

2.5.1 Oceanside Littoral Cell ..........................................................................................................20

2.5.2 Sediment Sources .................................................................................................................20

2.5.3 Sediment Budget...................................................................................................................22

2.5.4 Long Term Shoreline Change ...............................................................................................24

2.5.5 Cross-shore Profiles..............................................................................................................27

2.5.6 Foreshore Slopes ..................................................................................................................30

2.5.7 Storm Induced Beach Change ..............................................................................................31

2.5.8 Sediment Profile Thickness...................................................................................................33

2.5.9 Geologic Control....................................................................................................................35

2.5.10 Sea Level Change.................................................................................................................36

2.5.11 SANDAG Beach Fills.............................................................................................................37 3 DESIGN METHODOLOGY AND CONDITIONS.....................................................................54

3.1 Design Storm Water Levels ...........................................................................................................54

3.2 Design Waves ................................................................................................................................54

3.3 Design Wave Periods.....................................................................................................................56

3.4 Design Wave Runup ......................................................................................................................57

3.4.1 Runup on Plane Beach .........................................................................................................57

3.4.2 Runup on Revetment ............................................................................................................58

3.5 Design Foreshore Slopes...............................................................................................................59

3.6 Design Beach Widths.....................................................................................................................60

3.7 Design Long Term Shoreline Change Rate...................................................................................61 442
______________________________________________________________Coastal Engineering Appendix ii

3.7.1 Without-Project......................................................................................................................61

3.7.2 With-Project...........................................................................................................................62

3.8 Design Storm Induced Beach Change...........................................................................................63

3.9 Damage Mechanisms ....................................................................................................................65

3.9.1 Long Term Erosion................................................................................................................65

3.9.2 Storm-Induced Erosion..........................................................................................................66

3.9.3 Inundation..............................................................................................................................66

3.9.4 Wave Impact Forces – Structures.........................................................................................67

3.9.5 Railway Traffic Service Delay................................................................................................69 4 WITHOUT-PROJECT AND WITH-PROJECT CONDITIONS .................................................71

4.1 General Project Formulation and Policy Considerations ...............................................................71

4.2 Existing SCRRA Track Maintenance Procedures..........................................................................71

4.3 Existing SCRRA Construction and Operations and Maintenance Costs.......................................72

4.3.1 Existing Condition..................................................................................................................73

4.3.2 Engineered Revetment..........................................................................................................73

4.4 Future SCRRA Track Maintenance Practices................................................................................74

4.5 Future SCRRA Construction and Operations and Maintenance Costs .........................................75 5 NUMERICAL MODEL DESCRIPTION ...................................................................................76

5.1 Risk and Uncertainty Analysis .......................................................................................................76

5.2 Global Model Considerations.........................................................................................................76

5.2.1 Reach Subdivision – Cells.....................................................................................................77

5.2.2 Seasonality............................................................................................................................77

5.2.3 Single Storm..........................................................................................................................77

5.2.4 Independent Sediment Transport Processes........................................................................78

5.2.5 Numerical Simulation Concepts ............................................................................................78

5.3 Specific Model Parameters and Criteria ........................................................................................79

5.3.1 Railroad Reach Conversion Criteria......................................................................................79

5.3.2 LOSSAN Traffic Service Delay..............................................................................................80

5.3.3 Structure Damages ...............................................................................................................81

5.3.4 Structure Erosion Loss Criterion ...........................................................................................82

5.3.5 Recreational Beach ...............................................................................................................82

5.4 Methodology and Flowchart...........................................................................................................82

5.4.1 Structures ..............................................................................................................................82

5.4.2 Railroad .................................................................................................................................84 6 PLAN SELECTION ................................................................................................................86

6.1 Description of Alternatives .............................................................................................................86

6.1.1 Sacrificial Beach Width..........................................................................................................86

6.1.2 Nourishment Interval .............................................................................................................86

6.1.3 Sea Level Change.................................................................................................................86

6.2 Plan Parameters ............................................................................................................................87

6.2.1 Alongshore Length ................................................................................................................88

6.2.2 Berm Width............................................................................................................................89

6.2.3 Berm Crest Elevation ............................................................................................................89

6.2.4 Foreshore Slope....................................................................................................................89 443
______________________________________________________________Coastal Engineering Appendix iii

6.2.5 Quantity .................................................................................................................................90

6.3 Tentatively Recommended Plan – Model Output ..........................................................................91

6.3.1 Plan Performance..................................................................................................................92

6.3.2 Public Safety........................................................................................................................100

6.3.3 Southern California Edison Artificial Reefs .........................................................................100

6.4 Construction Considerations........................................................................................................102

6.4.1 Construction Equipment ......................................................................................................102

6.4.2 Contractors Work and Storage Area ...................................................................................103

6.5 Operation and Maintenance Costs ..............................................................................................104

6.6 Monitoring Plan ............................................................................................................................104

6.6.1 Beach Width ........................................................................................................................106

6.6.2 Topography / Bathymetry....................................................................................................106

6.6.3 Surf Quality (Surfability) ......................................................................................................106

6.6.4 Video Based Photogrammetry ............................................................................................107 7 REFERENCES ....................................................................................................................108

LIST OF TABLES
Table 2-1 Tidal Datum Elevations at La Jolla, CA ....................................................................................... 9 Table 2-2 Annual Maximum Wave Heights, 1983-1998 (CDIP, 2009) ....................................................18 Table 2-3 Sediment Discharge from Rivers and Streams .........................................................................20 Table 2-4 Sediment Budget for Oceanside Littoral Cell (North – San Clemente) in 1000 m3 / yr .............23 Table 2-5 Long Term Shoreline Change Rates in San Clemente Area......................................................25 Table 2-6 San Clemente Area Beach Profile Transects .............................................................................25 Table 2-7 Summary of Recent Long Term Shoreline Change Rates .........................................................27 Table 2-8 Sample Beach Monitoring Measurements at T-Street ..............................................................30 Table 2-9 Summary of Sand Thickness.....................................................................................................34 Table 2-10 SANDAG Beach Fills ................................................................................................................37 Table 3-1 Railroad Damage Functions ......................................................................................................69 Table 4-1 Construction and O&M Unit Prices............................................................................................73 Table 5-1 Reach Refinement .....................................................................................................................77 Table 6-1 Alternative Plan Parameters ......................................................................................................87 Table 6-2 Tentatively Recommended Plan Footprint Burial Values ..........................................................94 Table 6-3 Monitoring Costs......................................................................................................................105 444
______________________________________________________________Coastal Engineering Appendix iv

LIST OF FIGURES
Figure 2-1 Study Area Reach....................................................................................................................... 6 Figure 2-2 Typical View of Beach, North From Pier .................................................................................... 7 Figure 2-3 Typical View of Beach, South From Pier.................................................................................... 7 Figure 2-4 Typical View of Beach and Railroad............................................................................................ 8 Figure 2-5 Seabed Imagery in Project Vicinity............................................................................................13 Figure 2-6 Surficial Features Map in Project Vicinity ..................................................................................14 Figure 2-7 Swell Windows for San Clemente (from Surfline, 2009) ...........................................................16 Figure 2-8 Significant Wave Height Histogram, 1983-1998........................................................................17 Figure 2-9 Significant Wave Height Histogram, Winter Data, 1983-1998 .................................................17 Figure 2-10 Spectral Peak Period Histogram, 1983-1996 .........................................................................19 Figure 2-11 Wave Direction Histogram, 1983-1996 ...................................................................................19 Figure 2-12 Oceanside Littoral Cell ............................................................................................................21 Figure 2-13 Major Rivers and Drainage Basins, Oceanside Littoral Cell ..................................................22 Figure 2-14 Recent Shoreline Change in San Clemente Area...................................................................27 Figure 2-15 Typical Cross-shore Section for Reach 2, Reach 4, Reach 6, Reach 8 (No Revetment)......28 Figure 2-16 Typical Cross-shore Section for Reach 1, Reach 3, Reach 5, Reach 7 (Revetment) ...........28 Figure 2-17 Repetitive Cross Sections at Linda Lane (from Coastal Frontiers, 2005) ...............................29 Figure 2-18 Repetitive Cross Sections at T-Street (from Coastal Frontiers, 2005)...................................29 Figure 2-19 Foreshore Slope Histogram....................................................................................................31 Figure 2-20 Storm Induced Beach Change Histogram..............................................................................33 Figure 2-21 Site Location for Imperial Beach Fill (from SANDAG, 2010)..................................................38 Figure 2-22 Site Location for Mission Beach Fill (from SANDAG, 2010) ..................................................39 Figure 2-23 Site Location for Torrey Pines Fill (from SANDAG, 2010) .....................................................40 Figure 2-24 Site Location for Del Mar, Fletcher Cove, and Cardiff Fills (from SANDAG, 2010) ...............41 Figure 2-25 Site Location for Moonlight, Leucadia, Batiquitos, and South Carlsbad Fills (from SANDAG, 2010) ..................................................................................................................................................42 Figure 2-26 Site Location for North Carlsbad and Oceanside Fills (from SANDAG, 2010) ......................43 Figure 2-27 Silver Strand Littoral Cell ........................................................................................................45 Figure 2-28 Imperial Beach Receiver Site (from SANDAG, 2010) ............................................................46 Figure 2-29 Mission Bay Littoral Cell .........................................................................................................47 Figure 2-30 Mission Beach Receiver Site (from SANDAG, 2010).............................................................48 Figure 2-31 Torrey Pines Receiver Site (from SANDAG, 2010)................................................................49 Figure 2-32 Del Mar Receiver Site (from SANDAG, 2010)........................................................................49 Figure 2-33 Fletcher Cove Receiver Site (from SANDAG, 2010)..............................................................50 Figure 2-34 Cardiff Receiver Site (from SANDAG, 2010)..........................................................................50 Figure 2-35 Moonlight Receiver Site (from SANDAG, 2010).....................................................................51 Figure 2-36 Leucadia Receiver Site (from SANDAG, 2010)......................................................................51 Figure 2-37 Batiquitos Receiver Site (from SANDAG, 2010) ....................................................................52 Figure 2-38 South Carlsbad Receiver Site (from SANDAG, 2010) ...........................................................52 Figure 2-39 North Carlsbad Receiver Site (from SANDAG, 2010)............................................................53 Figure 2-40 Oceanside Receiver Site (from SANDAG, 2010)...................................................................53 Figure 3-1 Probability Distribution for Significant Wave Height, Winter Data, 1983-1998.........................55 Figure 3-2 Probability Distribution for Spectral Peak Period, Winter Data, 1983-1998 .............................57 Figure 3-3 Probability Distribution for Foreshore Slopes ...........................................................................60 Figure 3-4 Probability Distribution for Without-Project Long Term Erosion Rate ......................................61 Figure 3-5 Mean Sea Level Shoreline Change from 2001 SANDAG project ............................................62 Figure 3-6 Probability Distribution for With-Project Long Term Erosion Rate ...........................................63 Figure 3-7 Probability Distribution for Storm Induced Beach Change .......................................................64 Figure 4-1 Seawall Typical Cross Section .................................................................................................75 Figure 5-1 Illustration of Methodology for Structure Damages ..................................................................84 Figure 5-2 Illustration of Methodology for Railroad Damages ...................................................................85 Figure 6-1 Overlay of Construction and Equilibration Profiles for Tentatively Recommended Plan on Existing Profile, Existing Sea Level Change Condition......................................................................88 Figure 6-2 Footprint of 15 m Tentatively Recommended Plan, Existing Sea Level Rise Condition..........88 445
______________________________________________________________Coastal Engineering Appendix v
Figure 6-3 Model Output Histogram for Number of Fills Required for Reach 6.........................................92 Figure 6-4 Beach Fill Performance at SANDAG Oceanside Beach ..........................................................93 Figure 6-5 Plan View of T-Street Surf Break Bathymetry ...........................................................................98 Figure 6-6 T Street Surfing Area (from Surfline, 2009)..............................................................................99 Figure 6-7 Surfers at T Street (from Wright, 1973) ....................................................................................99 Figure 6-8 Spilling Wave............................................................................................................................99 Figure 6-9 Southern California Edison Artificial Reefs.............................................................................102 Figure 6-10 Contractor’s Work and Storage Area ...................................................................................103 446
______________________________________________________________Coastal Engineering Appendix 1 1 GENERAL

1.1 Introduction
This appendix describes technical design aspects for the San Clemente Shoreline Feasibility Study for shoreline improvements in the City of San Clemente, California. The purpose of this appendix is to conduct a detailed evaluation of the existing conditions and of the proposed alternatives for determination of the recommended plan. Evaluation of these alternatives includes an analysis of baseline coastal processes, detailed technical design, and potential design impacts on shoreline processes.

1.1.1 Risk and Uncertainty
This study at San Clemente is conducted using the principles of Risk & Uncertainty (R/U) in compliance with U.S. Army Corps of Engineers policy that requires all new Federally funded flood control and flood damage reduction studies incorporate the principles of R/U. U.S. Army Corps of Engineers policy guidelines for R/U are defined in Engineer Regulation 1105-2-101 (Dept. of Army 1996). R/U is intrinsic in water resources planning and design and arises from measurement errors and the inherent variability of complex physical phenomena.

The model used in the present study is an integrated coastal engineering – economics analytical framework for evaluating the physical performance and economic costs of shore protection projects, particularly, beach nourishment along sandy shores. The model has been implemented as an event-based Monte Carlo life cycle simulation tool that is run on desktop computers. This model initiates with coastal engineering data and input, performs a series of engineering and economic computations, and concludes with economic outputs. The model inputs consist of probability distributions for various coastal engineering parameters. The model outputs consist of histograms of individual damage benefit categories. The model is fully described in Section 5.

1.1.2 Significant References
This study references significantly a predecessor document. The Coast of California Storm and Tidal Wave Study (CCSTWS) prepared by the Los Angeles District (USACE-SPL, 1991). The CCSTWS study was a thorough, comprehensive, and complex analysis of a portion of the southern California shoreline which includes the San Clemente area.

This technical appendix also references significantly a predecessor construction project. A regional shoreline nourishment project was performed in 2001 by the San Diego Association of Governments (SANDAG). The project entailed dredging 1.6 million cubic meters (m3 ) (2.1
million cubic yards (yd3
)) of beach compatible sediments from six borrow sites for placement on twelve receiver beaches in San Diego County. The similarities of this construction project make this project directly comparable to this study. A complete description of the twelve receiver beaches is described in Sec 2.5.11.

1.1.3 Units
This study at San Clemente is conducted under the SI (metric) system of measurement as part of the U.S. Army Corps of Engineers compliance with Federal policy that requires all new Federally funded construction work be conducted in SI units, if requested by the local sponsor.

Much of the existing coastal processes analyses were originally developed utilizing the Imperial 447
______________________________________________________________Coastal Engineering Appendix 2 measurement system (feet). All units and/or dimensions are converted to metric equivalents using standard conversion factors. Some dimensions are shown in both systems (Imperial units in parentheses) to aid in understanding comparisons with historical documents.

1.2 Previous Reports
There are no previous Federal reports that directly address the San Clemente study area being considered under this authority. Some previous reports exist which incorporate the San Clemente area indirectly as a component of the larger coastal region, such as the aforementioned CCSTWS. The prevailing literature typically emphasizes San Juan Creek and the immediate adjacent coastal area encompassed by Doheny State Beach, or the San Onofre area.
448
______________________________________________________________Coastal Engineering Appendix 3 2 BASELINE COASTAL AND OCEANOGRAPHIC CONDITIONS

2.1 Study Area Definition
The Oceanside Littoral cell is approximately 86 km (53.5 miles) long extending from Dana Point to the La Jolla submarine canyon. Dana Point, the north end of the cell is a near complete barrier to the littoral transport of sand. Point La Jolla at the south end of the cell, is also a nearcomplete barrier. Analysis of shoreline changes in the Oceanside Cell address six sub-reaches within the cell. The sub-reach inclusive of the study area is the San Mateo – Dana Point cell.

The Oceanside Littoral cell boundaries were selected based on geomorphic and cultural features such as river and lagoon entrances, harbor structures, and other shoreline change features.

The current study area is bounded between San Mateo Point and Dana Point. The study area is approximately 12.1 km (7.5 miles) long. The study area is further sub-divided into ten reaches for reference purposes numbered consecutively Reach 1 – Reach 10. The study area is shown in Figure 2-1; close-up views are shown in Figures 2-2 thru 2-4.

2.1.1 Project Baseline
The seaward rail of the Southern California Regional Railroad Authority (SCRRA) is considered to be the project baseline. The SCRRA railroad line bisects the length of the project area. The railroad is constructed on conventional elevated crushed rock ballast. The railroad is constructed along the base of the bluff throughout the reach and is a prominent feature that completely separates the active beach from the bluff. The beach is only accessible via pedestrian underpasses/overpasses or storm water culverts interspersed along the length.

Whereas typically the beach and bluffs are considered joined together as components in an active littoral system, the presence of the railroad completely isolates the bluff from the beach.

Virtually all sediment inputs and bluff-related influences are restricted. Furthermore, the railroad resembles and acts as a protective revetment. In several areas the railroad is the primary structural feature that protects the bluffs and upland development from direct wave attack. In several areas the beach has completely eroded and exposed the railroad, thus, the railroad has fixed the position of the shoreline. Thus the railroad is the de facto protective structure for the bluffs. The railroad, acting as a protective structure and fixing the position of the shoreline, is assumed to be permanent and always exist throughout the project lifecycle. Therefore, the railroad is considered the landward boundary and no storm damages are considered landward of the railroad. The project baseline is assumed to be the seaward rail of the SCRRA railroad.

Since the railroad is assumed to be a constant feature throughout the project lifecycle, the seaward rail provided a convenient feature to define a horizontal alignment.

2.1.2 Reach Description
SCRRA has incorporated discontinuous levels of protective rock armoring along the railroad length. Four of the reaches consist of conventional rock ballast gradation which ranges from ¾” – 2-1/2”. Four of the reaches have been improved with rock armoring of approximately 100 lbs – 4 tons (~1 ft – 4 ft) on the seaward slope. The general condition of the revetment is not uniform and appears to be fair/poor along the entire length. Information obtained from SCRRA indicates that the revetment armor stone was not individually placed in the same manner in which conventional coastal armor stone structures are constructed. Instead the revetment was constructed via rail car side dump methods. However, even though the design and methods of construction were inconsistent with conventional coastal engineering practice, the larger armor 449
______________________________________________________________Coastal Engineering Appendix 4 stone affords substantially greater protection against hydraulic forces over conventionally sized rock ballast and offer substantial benefits to the railroad structure. This improvement in protective armoring is a primary consideration for project reach delineation.

The reach boundaries are defined in meters northward from San Mateo Point and shoreline features located within each reach are described. The project reaches are defined based on an arbitrary assumed Station 0+000 at San Mateo Point.

Reach 1: Reach 1 extends from San Mateo Point at Sta 0+146 to Sta 1+115. The reach is 969 m long and is the southern portion of San Clemente State Beach. The beach width is zero at the southern boundary and gradually increases to 41 m wide. The railroad track elevation is approximately +6.4 m1
. The railroad seaward slope incorporates the improved armor stone protection, has a slope of 1H:1V, and a crest elevation of approximately +7.0 m. There are no structures seaward of the railroad; some residential structures exist immediately landward of the railroad.

Reach 2: Reach 2 extends from Sta 1+115 to Sta 1+795. The reach is 680 m long and is encompassed within San Clemente State Beach. The beach width is approximately 40 m wide at the southern boundary and gradually decreases to 9 m wide. The railroad track elevation is approximately +6.4-7.6 m. The railroad seaward slope incorporates the conventional ballast construction, has a slope of 1H:1V, and a crest elevation of approximately +6.4-7.6 m. There are no structures seaward of the railroad; the underpass for San Clemente State Beach is included within this reach.

Reach 3: Reach 3 extends from Sta 1+795 to Sta 2+395. The reach is 600 m long is encompassed within San Clemente State Beach. The beach width is approximately 9 m wide at the southern boundary and quickly becomes zero throughout the remainder of the reach. The railroad track elevation is approximately +6.4 m. The railroad seaward slope incorporates the improved armor stone protection, has a slope of 1H:1V, and a crest elevation of approximately +7.0 m. There are no structures seaward of the railroad; Calafia Beach Park is on the landward side of the railroad.

Reach 4: Reach 4 extends from Sta 2+395 to Sta 3+127. The reach is 732 m long and encompasses San Clemente State Beach on the southern 30% and City of San Clemente on the northern 70%. The beach width is approximately 30 m wide at the southern boundary, transitions to 60 m wide in the middle, and transitions to 10 m wide at the northern boundary.

The railroad track elevation is approximately +6.3 m. The railroad seaward slope incorporates the conventional ballast construction, has a slope of 1H:1V, and a crest elevation of approximately +6.3 m. There are no structures seaward of the railroad; some residential structures exist immediately landward of the railroad.

Reach 5: Reach 5 extends from Sta 3+127 to Sta 3+540. The reach is 413 m long and is encompassed within the City of San Clemente. The beach width is 0 m wide throughout the reach. The railroad track elevation is approximately +6.5 m. The railroad seaward slope incorporates the improved armor stone protection, has a slope of 1H:1V, and a crest elevation of approximately +6.5 m. There are no structures seaward of the railroad; some residential structures exist immediately landward of the railroad.

1 All elevations and/or depths are in meters referred to Mean Lower Low Water (MLLW) unless otherwise noted.
450
______________________________________________________________Coastal Engineering Appendix 5 Reach 6: Reach 6 extends from Sta 3+540 to Sta 4+580. The reach is 1040 m long and is encompassed within the City of San Clemente. The beach width meanders from 0 m wide to 23 m to 0 m to 39 m and back to 0 m along the reach. The railroad track elevation is approximately +6.3 m. The railroad seaward slope incorporates the conventional ballast construction, has a slope of 1H:1V, and a crest elevation of approximately +6.9 m. This reach includes the majority of the significant structures along the beach.

Reach 7: Reach 7 extends from Sta 4+580 to Sta 5+661. The reach is 1081 m long and is encompassed within the City of San Clemente and is known as “Mariposa Point”. The beach width is 0 m wide throughout the reach. The railroad track elevation is approximately +6.5 m.

The railroad seaward slope incorporates the improved armor stone protection, has a slope of 1H:1V, and a crest elevation of approximately +6.9 m. Historical information indicates that this reach has been armored with revetment since at least the 1930’s. There are no structures seaward or landward of the railroad.

Reach 8: Reach 8 extends from Sta 5+661 to Sta 6+008. The reach is 347 m long and is encompassed within the City of San Clemente. The beach width varies from 40 m wide at the southern boundary to 0 m at the northern boundary. The railroad track elevation is approximately +6.3 m. The railroad seaward slope incorporates the conventional ballast construction, has a slope of 1H:1V, and a crest elevation of approximately +6.9 m.

Reach 9: Reach 9 extends from Sta 6+008 to Sta 7+109. The reach is 1101 m long and is encompassed within the City of San Clemente and is known as “Capistrano Shores”.

Capistrano Shores is a private community of manufactured housing constructed in the 1950’s.

A timber seawall that is fronted by a rubblemound rock revetment protects the reach. The armor stone is estimated to be 2-5 tons, has a slope of 1H:1V, and a crest elevation of approximately +6.0 m. The general condition of the revetment is not uniform and appears to be fair/poor along the entire length. The beach width is 0 m wide throughout the reach. The railroad is located substantially landward of the revetment and as such is no longer considered the project landward boundary. There are no structures seaward of the revetment.

Reach 10: Reach 10 extends from Sta 7+109 to Dana Point Harbor. The reach is approximately 5,000 m long and extends to the northern boundary of the study area. The Reconnaissance Report identified the potential project area from San Mateo Point to Capistrano Shores (Reach 1-9). The area north of Capistrano Shores is designated Reach 10 and will be considered only in the context of engineering considerations where physical continuity is required and/or necessary for the analysis.
451
______________________________________________________________Coastal Engineering Appendix 6 Figure 2-1 Study Area Reach
452
______________________________________________________________Coastal Engineering Appendix 7 Figure 2-2 Typical View of Beach, North From Pier
Figure 2-3 Typical View of Beach, South From Pier
453
______________________________________________________________Coastal Engineering Appendix 8 Figure 2-4 Typical View of Beach and Railroad

2.2 Water Levels

2.2.1 Tides
Tides at San Clemente are unequal mixed semi-diurnal. There is no tidal data available for the immediate San Clemente area, however, the tidal datum elevations at La Jolla, CA are shown in Table 2-1 and are assumed representative of those at San Clemente. The tidal epoch is 1983 to 2001. The La Jolla National Ocean Service (NOS) Primary Tide Station is located approximately 81 km (50 miles) from the San Clemente Pier. In southern California, tides typically have spatial characteristics on the order of hundreds of kilometers. Datum information for an NOS tidal station located at Newport Bay Harbor (station discontinued in 1994) located approximately 30 km (19 miles) from San Clemente indicates MSL and MHHW differences of

0.02 m and 0.03 m respectively. Therefore, the sea level variation between La Jolla and San Clemente is assumed to be negligible.
454
______________________________________________________________Coastal Engineering Appendix 9 Table 2-1 Tidal Datum Elevations at La Jolla, CA
Tidal Datum Elevation
m, (ft)
Highest observed water level (11/13/97) +2.33 (7.65)
Mean Higher High Water (MHHW) +1.62 (5.33)
Mean High Water (MHW) +1.40 (4.60)
Mean Sea Level (MSL) +0.83 (2.73)
Mean Tide Level (MTL) +0.84 (2.75)
North American Vertical Datum – 1988
(NAVD) +0.06 (0.19)
Mean Low Water (MLW) +0.28 (0.90)
Mean Lower Low Water (MLLW) 0.00
Lowest observed water level (12/17/33) -0.87 (-2.87)
Elevations are referenced to MLLW.

2.2.2 Storm Surge
Storm surge is the super-elevation of the tidal level at the coast due to wind stresses and atmospheric pressure fluctuations acting upon the sea surface. Wind and atmospheric fluctuations associated with strong storms in southern California typically produce 0.3-0.6 m (1-2 ft) storm surges (CCSTWS). Due to a narrow continental shelf and the absence of tropical storms and/or hurricanes, storm surge heights on the California coast are small compared to those on the east and Gulf coasts where extreme surge heights of 1-3 m (3-10 ft) are more typical and a peak 8 m (25 ft) was documented during Hurricane Camille in 1969. West coast storm surges typically have time scales of 1-3 days, with longer surge episodes possible due to bunching of successive storms.

2.2.3 Relative Sea Level Change
The U.S. Army Corps of Engineers considers potential relative sea level change in every feasibility study undertaken within the coastal zone. Corps of Engineers policy guidelines for sea level rise is defined in Engineer Regulation 1105-2-100 (Dept. of Army 2000). This regulation requires that relative sea level change be considered for a range of scenarios.

Project planning should consider what impact a higher relative sea level rise (or fall) rate would have on the design compared to the historical rate. A sensitivity analysis should be conducted to determine what effect (if any) changes in sea level would have on plan evaluation and selection. This analysis should be based, as a minimum, on the extrapolation of the local, historical record of relative sea level rise as the low level and Curve 3 from the National Research Council report as the high level.

Historic regional sea level trends based on yearly mean sea level records are published by the NOS (National Ocean Service, 2001). Monthly mean sea level variations are analyzed for 117 stations of the NOS National Water Level Observation Network having between 25 and 146 years of data. Monthly MSL data are used to obtain the average seasonal cycle, the residual time series, and the autoregressive coefficient of the residual with accurate estimates of 455
______________________________________________________________Coastal Engineering Appendix 10 standard errors. Historic trends at San Diego, California indicate a positive sea level rise of +2.45 mm/yr based on water level measurements during the period 1950-1999. If past trends are projected into the future at San Diego, a sea level rise of 0.12 m (0.4 ft) would be expected during the 50 year period of economic analysis.

In establishing its current policy, the U.S. Army Corps of Engineers has chosen to follow the recommendations of the National Research Council (NRC), as described in the publication Responding to Changes in Sea Level: Engineering Implications (National Research Council, 1987). This publication assumes three possible scenarios for eustatic sea level rise to the year 2100, where Curve 3 (the third scenario) is identified as the extreme sea level case which should be considered for feasibility studies. These scenarios are described by the equation E(t) = 0.0012t + bt2 (1)
t represents years, starting in 1986, b is a constant, and E(t) is the eustatic sea level rise, in meters, as a function of t.

For the three scenarios proposed by the NRC, b is equal to 2.8E-5 for Curve 1, 6.6E-5 for Curve 2, and 1.05E-4 for Curve 3 resulting in eustatic sea level rise values, by the year 2100, of 0.5 meters, 1.0 meters, and 1.5 meters, respectively. Adjusting for the study time period (where the economic base year is 2012) results in a total sea level rise during the 50 year economic period of analysis of 0.70 m (2.3 ft).

No additional sea level change to account for geologic displacement was added to the NRC Curve 3 estimate. The NRC accounts for eustatic sea level change only; the Curve 3 sea level change is considered very conservative and results in a total 50 year sea level change of 0.7 m, or approximately 14 mm/yr. This is compared to the 50 year sea level change of 0.12 m, or

2.45 mm/yr based on actual measurements. In general the EC assumes that 1.8 mm/yr in sea level change for historic conditions is contributed to the water level rising and the balance is due to geological displacement. It is noted that the measured historic rate of 2.45 mm/yr includes both eustatic and geologic components. Therefore, 0.65 mm/yr can be attributed to geologic displacement. As the Curve 3 estimate is 5.7 times greater than the combined measured rate, it is believed that an additional 0.65 mm/yr is negligible and was not incorporated into the Curve 3 estimate.

San Clemente City CouncilJuly 18, 2023

San Clemente City Council
July 18, 2023