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                               : • :4j •
ENVIRONMENTAL IMPACT  STATEMENT



Regional Wastewater Treatment System
Aliso Water Management Agency
August  1975

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       UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                              REGION IX
                        1OO CALIFORNIA STREET
                    SAN FRANCISCO, CALIFORNIA 941J1
                                                     SEP 3  1975

To the Interested Public:

     The Final Environmental Impact Statement for the Aliso Water
Management Agency Regional Wastewater Treatment System,  is hereby
submitted for your information.  The statement has been prepared in
compliance with the National Environmental Policy Act of 1969 (P.L.
91-190), and subsequent regulations prepared by the  Council on
Environmental Quality and the Environmental Protection  Agency.

     Upon the Council on Environmental Quality's receipt of this
Final Environmental Statement, a 30-day period for council review
will commence.  After 30 days, EPA may make a grant  offer for Phase
I of the project.

                                   Sincerely,
                                        De Falco, Jr.
                                     agional Administratoi
Enclosure

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            FINAL ENVIRONMENTAL IMPACT STATEMENT

                       D-EPA-24011-CA

                ALISO WATER MANAGEMENT AGENCY




            REGIONAL WASTEWATER TREATMENT SYSTEM
Prepared by:  U. S. Environmental Protection Agency
              Pacific Southwest Region IX
              100 California Street
              San Franc isco/xCA  94111
Responsible Official:

                          aul De Falco, Jr.   /
                         Regional Administrator

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SUMMARY
ENVIRONMENTAL IMPACT STATEMENT
DRAFT
FINAL

Prepared by:
(X)

United States Environmental Protection Agency
Pacific Southwest Region IX
San Francisco, California  94111
1.   Type of Action:

     Administrative

2.   Description of Project:

     The purpose of the Aliso Water Management Agency (AWMA)
     project is to implement a local or regional wastewater
     treatment and disposal system to eliminate the existing
     water quality problems in the various systems and pre-
     vent future problems.   Various alternatives are consid-
     ered, from one regional system to the expansion of the
     various individual systems,  as well as comparing the
     effects of land disposal for reclamation with the
     effects of ocean discharge.

     The applicant proposed construction of alternative 2G,
     a regional system with central treatment and ocean dis-
     posal of wastes with some reclamation during the summer.
     In the draft EIS, LPA proposed for additional analysis
     modified alternative 1A, a regional disposal system
     with local treatment.   Final determination of the
     appropriate alternative was  deferred until after com-
     pletion of the comment portion of the impact statement
     process.

     During the comment portion of the impact statement pro-
     cess, problems were identified with both of the favored
     alternatives,  and there was  not enough time within the
     time constraints of the process to resolve all of the
     issues involved.   Therefore,  EPA currently supports a
     phased project as the  proposed project.   The phased
     project will consist of three construction phases,  and
     a planning effort to resolve the issues  which are not

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resolved in this EXS.  The planning effort will  take  the
form of a Facilities Plan addendum and  environmental
impact report.  The issues which must be resolved  are
that of treatment concept for  the upper Aliso  Creek
area, treatment plant  site, air quality mitigation
measures, and sludge treatment and disposal.   The
Facilties Plan addendum and environmental impact report
will undergo environmental review by EPA and if  necessary
a  supplemental EIS will be prepared.

Phase I will include the Aliso Creek ocean outfall,
onshore and offshore portions; and the  North Coast
Interceptor.  These project elements were included
in both of the alternatives favored in  the draft EIS.
In addition, Phase I will include the expansion  of the
South Laguna treatment plant and minor  modifications  to
the plant as proposed  in alternative 1A in the draft  EIS.

Phase II of the project will consist of sludge treat-
ment facilities for the South  Laguna treatment plant.
Prior to construction of Phase II facilities,  the
Facilities Plan addendum and environmental impact  report
must be sufficiently complete  to resolve all the technical
and environmental issues related to sludge treatment and
disposal.

Phase III will consist of construction  of facilities for
the upper Aliso Creek area.  It has not yet been decided
whether to serve the upper Aliso Creek  area through
a  satellite concept using existing treatment plants with
disposal through a treated effluent line, or through a
system involving a treatment plant serving the entire
upper Aliso Creek area.  The appropriate site(s) for
serving the upper Aliso Creek  area have also not been
determined.   The Facilities Plari addendum and environ-
mental impact report,  which must be completed prior to
Phase III construction, will resolve these issues.

Impacts of Projects:

All projects will involve construction and its associated
environmental impacts.   Construction will take place at
treatment plant sites,  along roads and streams, and for
ocean disposal alternatives,  on the beach and the ocean
floor off Aliso Creek.   Construction will involve noise,
dust,  traffic disruption,  and  inconvenience.

Operation of any alternative will involve environmental
impacts.   Energy will  be consumed,  occasional odors may
occur,  and receiving waters will be affected by the
                         i-2

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     effluent.  In the case of land disposal, the receiving
     waters are streams and groundwater; in the case of
     ocean disposal, the ocean will be the receiving waters.
     The statement indicates that on a year-round basis  the
     ocean is the most tolerant receiving water.

     All alternatives will involve secondary air quality
     impacts associated with the population growth which
     they accomodate.  Measures will be implemented to miti-
     gate this impact.  Possible mitigation measures include
     nonextension of utilities to undeveloped areas, high
     density cluster development, car pooling, buses, housing
     to serve the GSA facility, and two park-and-ride con-
     cepts.  The time constraints involved in the EIS did
     not allow determination of the appropriate mitigation
     measures.  This issue is unresolved at present; however,
     it will be resolved prior to any construction of Phase
     III facilities.  Resolution will be insured by limiting
     the use of the Phase I outfall in the grant contract.

4.   Alternatives:

     Seven alternatives were considered:  local treatment
     and a regional outfall (1A); central treatment and  a
     regional outfall (2E); reclamation (3C); drainage of
     the upper area through San Diego Creek Basin (4A);
     stream discharge for the upper area (4C);  central
     treatment and a regional outfall with some upper basin
     reclamation to relieve summer peak flows (2F);  and  the
     alternative of taking no action.  Subsequently, 2F was
     modified to alternative 2G to take advantage of natural
     drainage patterns.

5.   Dates Available to CEQ and the Public:

     Draft:   February 14,  1975

     Final:    S£p g  1975

6.   Distribution  List Attached.
                             i-3

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                          LIST OF PARTICIPANTS
The Draft and Final Impact Statements for the Aliso Water Management Agency
Project were prepared under the auspices of the Air and Water Programs
Division, Environmental Protection Agency Region IX.  An interdisciplinary
EPA staff team was  supported by the independent consulting firms of
Chapman Phillips Brandt Reddick and Associates, Inc. and Don Owen Associates.
The following persons participated in the development of this Environmental
Impact Statement.

ENVIRONMENTAL PROTECTION AGENCY

              EIS COORDINATOR	Jim McGrath
              SECONDARY IMPACTS	Jim McGrath
                                                         Peter Perey
              AIR QUALITY IMPACTS	Fred Leif

CHAPMAN PHILLIPS BRANDT REDDICK

              PROJECT COORDINATOR	Michael Brandman, PhD
              URBAN GROWTH ANALYSIS	Richard E. Ramella
              ENVIRONMENTAL ANALYSTS	Theodore J. Reynolds
                                                         Niall Fritz
                                                         Susan E. Nilsen
              AIR QUALITY IMPACTS   	Gary M. Allen
              ARCHAEOLOGY	N. Nelson Leonard III
              PALEONTOLOGY	Carol Stadum
              BIOLOGY	Michael Brandman, PhD
                                                         J. Edward Guilmetter, Jr.
              GRAPHICS COORDINATOR	Steven J. Malefyt
              TYPING COORDINATOR	Ronald Smebye

DAN OWEN ASSOCIATES

              PRINCIPLE IN CHARGE	Langdon W. Owen
              PROJECT COORDINATOR	James R. Cofer
              SENIOR SANITARY ENGINEER	Robert C. Gumerman,  PhD
              COMMUNITY RELATIONS MANAGER	Lawrence H. Buxton

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                      AWMA EIS  DISTRIBUTION LIST
 FEDERAL  AGENCIES
 Environmental  Protection  Agency,  Washington,  D.C.
   Office  of  Legislation,
     Congressional Affairs Division
   Office  of  Federal Activities
   Office  of  Public Affairs
 Office  of Public Affairs,  Region  IX

 Council on Environmental  Quality
 722  Jackson  Place, N.W.
 Washington,  D.C.  20006

 Assistant Secretary, Program Policy
 Attn:   Office  of Environment Project Review
 Department of  the Interior
 Washington,  D.C.  20240

 Department of  Health, Education and Welfare
 Region  IX
 50 Fulton Street
 San  Francisco, CA 98102

 Department of  Housing and  Urban Development
 San  Francisco  Area Office
 One  Embarcadero Center, Suite 1600
 San  Francisco, CA 94111

 U.S. Army Corps of Engineers
 Sacramento District
 650  Capitol Mall
 Sacramento, CA 95814

 U.S. Department of Transportation
 450  Golden Gate Avenue
 San  Francisco, CA 95814

 U.S. Department of Commerce
Attn:  Dr. Sidney Galler
Commerce  Building,  Room 2816
Washington, D.C.  20230

U.S. Geological Survey
345 Middlefield Road
Menlo Park, CA 94025

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 Operational  Planning Staff
 General  Services  Administration
 PBS
 Mail  Slot 30A
 525 Market Street         :
 San Francisco,  CA 94105

 Department of the Army
 L.A.  District Corps  of  Engineers
 P.O.  Box 2711
 Los Angeles,  CA 90053
 STATE AGENCIES

 The  Resources Agency
 1416: Ninth  Street
 Sacramento,  CA  95814;

 California  SWRC Board
 1416 Ninth  Street
 Sacramento,  CA  95814

 California  State Air Resources Board
 1709-11th Street
 Sacramento,,  CA  958,14

 California State Department of Fish and Game
 1416  Ninth Street
 Sacramento,  CA  95814

 State of California
 Department of Public Health
 2151  Berkeley Way
 Berkeley, CA 94704

 State of California
 Department of Parks and: Recreation
 P.O.  Box 2390
 Sacramento,  CA  95811

 State, of California
 Council on Intergovernmental Relations
 1400 Tenth Street
 Sacramento,  CA  95814

 State of California
Office of Intergovernmental Management
Attn:  Mark  Briggs
 1400 Tenth Street
Sacramento, CA 95814
                                 11.1-2

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 State Land Division
 Attn:  Ed Chatfield
 16600 "L" Street
 Sacramento, CA 95814

 California State Department of Fish and Game
 350 Golden Shore
 Long Beach, CA
 LEGISLATORS

 Honorable John  Tunney,  U.S.  Senate
 Attn:   Mr.  Ward Wardman
 450 Golden Gate Avenue, Room 17432
 San Francisco,  CA 94102

 Honorable Alan  Cranston
 U.S. Senate
 Room 2102 NSPB
 Washington, D.C.   20510

 Governor  of California
 Sacramento, CA   95814

 Honorable Andrew Hinshaw
 U.S. Congress
 Washington, D.C.
ECOLOGY GROUPS

American Institute of Planners
San Diego Section
285 Moss Street No. Ill
Chula Vista, CA 92011

Coastal Area Protective League
P.O. Box 313
Corona Del Mar, CA 92624

Beach Action Group
Box 99214
San Diego, CA 92109

Buena Vista Audubon Society
Box 776
Vista, CA

Citizens Coordinate Century-3
1549 El Prado
San Diego, CA 92101

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 The  Laguna  Greenbelt*  Inc.
 P.O.  Box 1611
 Laguna  Beach,  CA 92652

 Environmental  Crisis  Bulletin
 435  Canyon
 SolahO  Beach,  CA 92075

 Environmental  Council  of  Fall brook,  Inc.
 44 Hi 11 crest Lane
 Fall brook,  CA  92028

 Environmental  Development Council
 401  Bank of America
 1 City  Boulevard West
 Orange,  CA  92668

 Escondido Citizens Ecology  Committee
 Box  223
 Escondido,  CA  92025

 Tri-County  Conservation League
 20131 Shorewood  Circle
 Huntington  Beach, CA 92646

 Totuava  Bay Association,  South Laguna
 25311 Mainsail Drive
 Dana Point, CA 92629

 Friends  of  the Earth
 P.O. Box 16177
 San Diego,  CA 92116

 Pro Environment  People
 2111 Crestview Drive
 Laguna Beach, CA 92651

 Irvine Tomorrow
 3572 Carmel Avenue
 Irvine,  CA  92664

 Izaak Walton League
 5406 West Third  Street
 Santa Aha, CA 92603

 S.L.C.A.
 31558 Summit
 South Laguna, CA 92677

California Roadside Council, Orange County Group
 1306 Olavista
San Clemente, CA 92672
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 Saddleback Coordinating Council
 P.O. Box 357
 El Toro, CA 92630

 San Diego Audubon Society, Inc.
 3942 Hughes Court
 San Diego, CA 92115

 San Diego Ecology Centre
 P.O. Box 16177
 San Diego, CA 92116

 San Eli jo Alliance
 P.O. Box 82
 Solano Beach, CA 92075
 31791  South  Coast Highway
 South  Laguna,  CA 92677

 Citizens'  Town Planning  Association
 P.O. Box  1132
 Laguna Beach,  CA 92651

 Sierra Club
 San Diego  Chapter
 Box 525
 San Diego, CA  92112

 Sierra Club
 North  County Group
 P.O. Box 2481
 Escondido, CA  92025

 Sierra  Club-Orange County Group
 1314 Skyline Drive
 Fullerton, CA  92631

 Village Laguna
 500 Broadway
 Laguna Beach,  CA  92651

American Cetacean Society
 San Diego Chapter
4405 Arizona Street
 San Diego, CA 92116

Center for Environmental  Education
6401  Linda Vista Road
San Diego, CA 92111
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 Citizens  to Save Open  Space
 5635  Tamres Drive
 San Diego,  CA 92111

 Common  Cause
 P.O.  Box  6000
 La Jolla, CA 92037

 Environmental  Action Council
 P.O.  Box  99114
 San Diego,  CA 92109

 Environmental  Law Society of  San  Diego,  Inc.
 P.O.  Box  99154
 San Diego,  CA 92109

 Irvine  Tomorrow
 18051 Butler
 Irvine, CA  92664

 The Nature  Conservancy
 3923  Lament Street
 San Diego,  CA  92109

 San Diego Chamber of Commerce
 233 A Street
 San Diego,  CA  92101

 San Diego County  Floodplain Technical Committee
 5377 Redding Road
 San Diego,  CA  92115

 San Diego County  Wildlife  Federation
 P.O. Box 1029
 San Diego,  CA  92112

 San Diego Gas  and Electric Company
 Director of Public Relations
 P.O.  Box 1831
 San Diego,  CA  92112

Center for  Regional  Environmental Studies (CREST)
San Diego University
5402 College Avenue
San Diego,  CA 92115

Center for  Urban and Human Development
U.S.  International University
8655 Pomerado Road
San Diego,  CA 92124
                               iii-6

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 Scripps Institution of Oceanography
 University of California, San Diego
 P.O.  Box 109
 San Diego, CA 92037

 American Institute of Architects
 233 A Street
 San Diego, CA 92101

 Conservation Call
 3942  Hughes Court
 San Diego, CA 92115

 Environmental  Education Clearinghouse
 P.O.  Box 2422
 San Diego, CA 92112

 Environmental  Quality Control  Committee
   of  the County Republican  Central  Committee
 2520  San Marcos Avenue
 San Diego, CA 92104

 Students for Environmental  Awareness
 University of San  Diego
 Alcala  Park
 San Diego, CA 92110

 Government Information Office
 (Environmental  Information)
 202 C Street
 San Diego, CA  92101

 San Diego  County Medical  Society
 Environmental  Health  Committee
 P.O. Box 3949
 San Diego,  CA  92103

 Human Ecology
 San Diego  High  School
 12th Avenue  and Russ  Boulevard
 San Diego, CA  92101

 Ecology Action
 San Diego  University
 202-1/2  Physical Sciences Building
 5402 College Avenue
 San Diego, CA 92115

Committee  for Legal Environmental Action
  and Research  (CLEAR)
California Western School of Law
3902 Lomaland Drive
San Diego, CA 92106
                                iii-7

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 CONCERNED INDIVIDUALS AND ORGANIZATIONS

 Environmental  Coalition  of Orange County
 206 West 4th Street,  Suite 316
 Santa  Ana,  CA  92701

 League of Women  Voters
 c/o Jeanette Turk,  President
 15271  New Castle Lane
 Huntington  Beach, CA  92647

 League of Women  Voters
 c/o Judith  Swayne
 1159 Noria
 Laguna Beach,  CA 92651

 GUARD
 c/o Lyn Harris Hicks
 3908 Ariana
 San Clentente,  CA

 Citizens  Direction  Finding Commission
 County Administrative Building
 515 N.  Sycamore, Room 106
 Santa  Ana,  CA

 Joseph  Tasker  Edmiston
 Southern  California Coastal Coordinator
 Sierra  Club
 2410 Beverly Boulevard
 Los Angeles, CA  90057

 Coalition of Neighborhood  Associations  (CONA)
 c/o Mr. Harry Jeffrey, President
 2065 San  Remo Drive
 Laguna  Beach, CA 92651

 Citizens Town Planning Association
 c/o Mr. Bill Vernor,  President
 1305 La Mirada
 Laguna  Beach, CA 92651

Adele Drewitz
25256 Pike
 Laguna  Hills, CA 92653

Marian Parks
233 Morning Canyon
Corona Del Mar, CA 92625

Roberta S. Greenwood
725 Jacon Way
Pacific Palisades, CA 90272
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 Society for California Archeology
 1400 I  Street Extension
 Petaluma,  CA 94952

 Archaeological  Research,  Inc.
 1643 Monrovia
 Costa Mesa, CA 92627

 Santa Ana  Watershed Planning Agency
 P.O.  Box 2678
 Attn:   Mr.  Robert  E.  Moore, Manager
 Riverside,  CA 92506

 Dr.  Stephen Murray
 Biological  Sciences Department
 California  State University, Fullerton
 800  State  College  Boulevard
 Fullerton,  CA 92634

 Mrs.  J.  E.  Murley
 American Association  of University  Women
 1733  Candlestick Lane
 Newport  Beach,  CA  92660

 Dr.  Don  B.  Bright
 Biology  Department
 California  State University, Fullerton
 800  State College  Boulevard
 Fullerton,  CA 92634

 Ms. Sally Spurgeon
 California  Coastal Alliance
 17731 Palmento Way
 Irvine, CA  92664

American Association of University Women
 c/o Jean Brotherton
 3144 Bonn Drive
 Laguna Beach, CA 92651

Town Hall Association
P.O. Box 842
San Juan Capistrano, CA 92675

Capistrano Beach Community Association
P.O. Box 27
Capistrano Beach, CA 92624

Kathy Drocco
32916 Avenue Descanso
San Juan Capistrano, CA
                                iii-9

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 United South Orange Coast Communities
 P.O.  Box 375
 Dana  Point,  CA 92629

 J.  Edward Guilmette, Jr., President
 Appolmage, Inc.
 7204-10 Pacific  Coast Highway
 Newport Beach, CA 92660

 Ms. Elsie Kroesche
 Open  Space Action Group
 254 B.  Cabrillo  Street
 Costa Mesa,  CA 92627
 PUBLIC AGENCIES

 State Department of Water  Resources
 P.O. Box  6598
 Los Angeles, CA 90055

 Commanding General
 U.S. Marine Corps Base
 Camp Pendleton, CA 92055

 State Department of Parks  and Recreation
 1350 Front Street
 San Diego, CA 92101

 Orange County Water Pollution Department
 P.O. Box  1978
 400 Civic Center Drive West
 Santa Ana, CA 92702

 Orange County Planning Commission
 Attn:  Mr. Ron Yeo
 500 Jasmine
 Corona Del Mar, CA

 Orange County Air Pollution Control District
 1010 South Harbor
Anaheim, CA 92801

Orange County Health Department
 P.O. Box 355
Santa Ana, CA 92702

State Department of Public Health
1449 West Temple Street
Los Angeles, CA 90026
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 Orange County Harbors,  Beaches and Parks District
 1901  Bayshore Drive
 Newport Beach,  CA 92662

 Orange County Planning  Department
 400 Civic  Center Drive  West
 Santa Ana, CA 92701

 Mr.  Victor C.  Andrews,  President
 Coastal  Area  Protective League
 P.O.  Box 313
 Corona Del Mar,  CA 92624

 Ecology Action  Councils
 California State University,  Fullerton
 800 State  College Boulevard
 Fullerton, CA 92634

 Ecology Action  Councils
 University of California
 Irvine,  CA 92664

 Izaak  Walton  League
 5406  West  Third  Street
 Santa  Ana,  CA  92603

 League  of  Women  Voters  of Orange  County
 2409  N.  Orange Avenue
 Costa  Mesa, CA 92627
 Attn:   Mrs. Alex Price

 Open Space Action  Group  - Project  21
 20342 Acacia  Street
 Santa Ana,  CA 92707
 Attn:   Mr.  Reed  Flory

 Planning and Conservation League
 226 Park Avenue
 Laguna Beach, CA
 Attn:  Mr.  William Wilcoxen

 Project 21
 24592 Overlake Drive
 El Toro, CA 92630
Attn:  Mr.   Bob Snyder

Mr. Dan Langton
Santa Ana College
17th and Bristol
Santa Ana,  CA 92706

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 Sea  and Sage Audubon Society
 Orange  County Chapter
 P.O.  Box 1779
 Santa Ana,  CA 92702

 Sierra  Club and  Orange  County Health  Planning  Council
 10322 Brightwood Drive
 Santa Ana,  CA 92705
 Attn:   Mr.  Verlyn N.  Jensen

 Zero  Population  Growth
 Orange  County Chapter
 P.O.  Box 596
 Orange,  CA  92669

 Mrs.  H.  T.  Read
 California  Roadside  Council
 Orange  County Group  Area  Representative
 1306  Olavista
 San Clemente, CA 92672

 Environmental  Development Council
 Orange  County Chamber of Commerce
 401 Bank of America
 1 City  Boulevard West
 Orange,  CA  92668

 Mr. Nathanial  Lamm,  Chairman
 Orange  County Environmental  Education
  Advisory  Council
 Orange  County Department of  Education
 14404 Civic  Center Drive West
 Santa Ana,  CA 92701

 Mr. Ralph Kaiser, Secretary
 Orange County  Coast Association
 2701 Fairview Road
 Costa Mesa,  CA 92626

 Marine Sciences  Program
 Orange County  Department of Education
 1104 Civic Center Drive West
 Santa Ana, CA  92701

Marine Studies Institute
 1104 Civic Center Drive West
Santa Ana, CA 92701

Dr. Stephen Murray
Department of Biological Sciences
California State University, Fullerton
800 State College Boulevard
Fullerton, CA 92634
                                iii-12

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 Avco  Community Developers,  Inc.
 3  Monarch  Bay  Plaza
 Laguna  Niguel,  CA  92677
 Attn:   George  L. Hamill

 Dana  Point Citizens  for Action Association
 P.O.  Box DF
 Dana  Point, CA 92629
 Attn:   Harris  Angell

 Emerald Bay Community Association
 600 Emerald Bay
 Laguna  Beach,  CA 92651
 Attn:   Merline  L.  Dake, Secretary-Manager

 Laguna  Niguel  Homeowners and  Community Association
 801 Glenneyre  Street
 Laguna  Beach,  CA 92651
 Attn:   Jack E.  Cressman, AIA

 Three Arch Bay  Association
 5  Bay Drive
 South Laguna,  CA 92677
 Attn:   Waldo Drake,  Chairman  of
        Architectural Committee

 State Division  of  Highways
 District 7
 P.O. Box 2304 - Terminal Annex
 Los Angeles, CA 90054
 Attn:   A.  K. Hashimoto

 CEEED
 620 Newport Center Drive, Suite 322
 Newport Beach, CA  92660
 Attn:   Mr.   Gilbert Ferguson

 Southern California Association of Governments
 1111 West Sixth Street, Suite 400
 Los Angeles, CA 90017

 California  Regional Water Quality Control Board
 6154 Mission Gorge Road, Suite 205
 San Diego,  CA 92120

 Southeast Regional  Reclamation Authority
City of San Juan Capistrano
P.O. Box 967
San Juan Capistrano,  CA 92675
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 South Coast Regional  Zone Conservation Commission
 666 East Ocean Boulevard, Suite 3107
 P.O.  Box 1450
 Long  Beach, CA 90801

 Alexander Bowie,  Incorporated
 Attorney at Law
 610 Newport Center Drive, Suite 500
 Newport Beach, CA 92660

 Aliso Water Management Agency
 27281  Aliso Creek Road
 Laguna Niguel, CA 92667

 Irvine Ranch Water District
 P.O.  Box D-I
 Irvine,  CA 92664

 Emerald  Bay Service District
 600 Emerald Bay
 Laguna Beach,  CA  92651

 City  of  Laguna Beach
 505 Forest
 Laguna,  CA 92652

 South  Laguna Sanitary  District
 31652  Second Avenue
 South  Laguna,  CA  92677

 Supervisor Riley
 Attn:  Scott Ferguson
 P.O. Box 687
 Santa  Ana,  CA  92702

 Mr. Dick Mayer
 Los Angeles  Parks  District
 155 Washington  Boulevard
 Los Angeles, CA

 Regional Planning  Commission
 320 W. Temple  Street
 Los Angeles, CA 90012

 Moulton-Niguel Water District
 27281  Aliso  Creek  Road
 Laguna Niguel, CA  92677

 El Toro Water District
401 Civic Center Drive West
Santa Ana, CA 92702
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Los Allsos Water District
P.O. Box 156
El Toro, CA 92630
Chapman Phillips Brandt Reddick
Environmental Systems Research Group
17835 Sky Park Circle, Suite H
Irvine, CA 92707
                              iii-15

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                               TABLE OF CONTENTS

SUMMARY                                                                 i-1

PARTICIPANTS                                                           ii-1

DISTRIBUTION LIST                                                     iii-1

TABLE OF CONTENTS                                                      iv-1

LIST OF EXHIBITS                                                        v-1

LIST OF TABLES                                                         vi-1

1.0      INTRODUCTION/DESCRIPTION OF THE PROBLEMS                        1-1
                                     \
                                                                        1-1
                                                                        1-1
                                                                        1-3
                                                                        1-3
                                                                        1-5
                                                                        1-6
                                                                        1-6
                                                                        1-7
                                                                        1-7
                                                                        1-8
                                                                        1-8
                                                                        1-8
                                                                        1-9
                                                                        1-11
                                                                        1-12
                                                                        1-12

                                                                        2-1

                                                                        2-1
                                                                        2-1
                                                                        2-2
                                                                        2-2
                                                                        2-3
                                                                        2-3
                                                                        2-4
                                                                        2-5
                                                                        2-5

                                                                        2-5

                                                                        2-6
1.1
1.1.1
1.2
1.2.1
1.2.2
1.2.3
1.2.4
1.2.5
1.2.6
1.2.7
1.3
1.3.1
1.3.2
1.3.3
1.3.4
1.3.5
2.0
2.1
2.1.1
2.1.2
2.1.3
2.1.4
2.1.5
2.1.6
2.1.7
2.1.8
2.2
2.3
BACKGROUND
Relationship to Other Projects
EXISTING WASTE WATER TREATMENT
AND THEIR PERFORMANCE
Moulton-Nicjuel Water District
South Laguna Sanitaj^y District
Los Alisos Water District
El Toro Water District
Cit^of Laguna Beach
Emerald Bay Service District
Irvine Ranch Water District
DESCRIPTION OF THE PROBLEMS IN
WATER TREATMENT FACILITIES
South Laguna Sanitary District
City of Lajuna Beach
El Toro Water District
Los Alisos Water District
Moulton-Niguel Water District
in Orange County
FACILITIES
EXISTING WASTE
DESCRIPTION OF THE EXISTING ENVIRONMENT
GEOGRAPHIC SETTING
Introduction
Ali so Creek Watershed
Irvine Ranch Coastal Area
San Diego Creek Watershed
Laguna Canyon Watershed
Salt Creek Watershed
Laguna Beach and South Laguna
San Juan Creek Watershed
TOPOGRAPHY
GEOLOGY
Beach Watersheds

                                     iv-1

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2.3.1    General                                                   2-6
2.3.2    Topography              •                                  2-6
2.3.3    Stratigraphic Description                                 2-7
2.3.4    Geologic Processes                                        2-9
2.3.5    Mass Movements                                            2-10
2.3.6    Structure                                                 2-10
2.3.7    Mineral Resources                                         2-11
2.3.8    Geologic Constraints                                      2-11

2.4      SOILS                                                     2-12

2.4.1    General Soils Map of Orange County                        2-12
2.4.2    Soil Characteristics                                      2-13
2.4.3    Soil Interpretations                     -                 2-14
2.4.4    Agricultural Soils                                        2-15

2.5      HYDROLOGY                                                 2-16

2.5.1    Surface Water                                             2-16
2.5.2    Ground Water                                              2-21

2.6      METEOROLOGY                                               2-22

2.6.1    Climate                                                   2-22
2.6.2    Air Resources                                             2-23

2.7      OCEANOGRAPHY                                              2-24

2.7.1    Coastal and Sub-marine Physiography                       2-24
2.7.2    Water Characteristics                                     2-25
2.7.3    Nearshore Circulation   •                                  2-26
2.7.4    Sedimentation Characteristics                             2-27

2.8      BIOLOGICAL RESOURCES                                      2-28

2.8.1    Terrestrial Biology                                       2-28
2.8.2    Marine Biology                                            2-38

2.9      ARCHAEOLOGICAL RESOURCES                                  2-43

2.9.1    Introduction                                              2-43
2.912    The AWMA Region                                           2-44
2.9.3    Description of the Archaeological Sites                   2-45
2.9.4    Density of Archaeological  Sites                           2-45
                                iv-2

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2.10     PALEONTOLOGICAL RESOURCES                                  2-46

2.10.1   Introduction                                               2-46
2.10.2   Previous Work                                              2-46
2.10.3   Fossil Zones of Primary Concern                            2-47
2.10.4   Site Locations                                             2-47
2.10.5   Geologic Formations                                        2-48

2.11     LAND USE                                                   2-50

2.12     WATER SUPPLY AND ITS QUALITY                               2-51

2.12.1   Metropolitan Hater                                         2-51
2.12.2   Water Quality2-53

2.13     POPULATION AND WASTE WATER FLOWS                           2-58

2.14     INSTITUTIONAL FRAMEWORK AFFECTING
         THE ENVIRONMENT                                            2-59

2.14.1   Moulton-Niguel Water District                              2-59
2.14.2   South Laguna Sanitary District                             2-59
2.14.3   El Toro Water District                                     2-60
2.14.4   Los Alisos Water District                                  2-60
2.14.5   Irvine Ranch Water District                                2-61
2.14.6   City of Laguna Beach2-61

2.15     NOISE                                                      2-62

2.16     HISTORICAL RESOURCES                                       2-62

2.16.1   Historical Background                                      2-62
2.16.2   Historical Landmarks                                       2-64

3.0      WASTEWATER MANAGEMENT ALTERNATIVES
         AND THEIR PRIMARY IMPACTS                                  3-1

3.1      DESCRIPTION OF THE PROPOSED ALTERNATIVES                   3-1

3.1.1    Alternative 1A - Local Treatment,
         Regional  Disposal3-1
3.1.2    Alternative 2E - Central Treatment,
         Regional  Disposal3-4
3.1.3    Alternative 3C - Reclamation                              3-5
3.1.4    Alternative 4A - Partial Regional System
         with Stream Discharge in Upper Aliso Creeks Area          3-6
3.1.5    Alternative 2F - Regional  Treatment, RegionaT
         Disposal  with Upstream Reclamation                        3-6
3.1.6    Alternative 4C - Intermittent Stream Discharge
         from the  Upper Aliso Area                                  3-7
3.1.7    Alternative 2G - Modified  Alternative 2F                  3-8
                                iv-3

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 3.2       PRIMARY  IMPACTS OF  ALTERNATIVES                                 3-8

 3.2.1     Alternative  1A -  Local  Treatment,  Regional
          Disposal                                                        3-8
 3.2.2     Alternative  2E -  Central  Treatment,  Regional
          Disposal                                                        3-16
 3.2.3     Alternative  3C -  Reclamation                                    3-22
 3.2.4     Alternative  4A -  Partial  Regional  System with
          Stream Discharge  in Upper Aliso Creek Area                      3-23
 3.2.5     Alternative  4C -Intermittent Stream Discharge
          from the Upper Aliso Area3-25
 3.2.6     Alternatives 2F and 2G  -  Regional  Treatment,
          Regional Disposal with  Upstream Reclamation                     3-25
 3.2.7     No  Project Alternative3-26

 4.0       SECONDARY IMPACTS OF PROJECT ELEMENTS                           4-1

 4.1       INTRODUCTION - THE  RELATIONSHIP BETWEEN
          PUBLIC UTILITIES                                                4-1

 4.2       DYNAMICS OF  GROWTH                                              4-1

 4.2.1     County Dynamics                                                 4-1
 4.2.2     Aliso Area Growth Dynamics                                      4-3
 4.2.3     Growth Rate Analysis                                            4-4

 4.3       FUTURE DEVELOPMENT .PROSPECTS                                    4-8

 4.3.1     Population Projections                                          4-8
 4.3.2     Formal Land  Use Planning                                        4-9
 4.3.3     Availability of Utilities         .                              4-10
 4.3.4     Regulatory Programs                                             4-12
 4.3.5     External Stimuli                                                4-15
 4.3.6     Social Attitudes                                                4-15
 4.3.7     Conclusion4-15

 4.4       ROLE OF THE PROJECT                                             4-15

4.4.1     Introduction                                                    4-15
4.4.2     Variation by Alternative                                        4-16

4.5       IMPACTS OF DEVELOPMENT                                          4-18

4.5.1    Air Quality                                                     4-18
4.5.2    Water                                                           4-22
4.5.3     LaTid"                                                           4-23

4.6       POTENTIAL MITIGATION MEASURES  . '                                4-23

4.6.1     Summary of Mitigation Measures Evaluated
         by  the Applicant                                                4-24
                                      iv-4

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4.6.2    Additional Measures                                             4-24
4.6.3    Economic  Impact of Potential Mitigation
         Measures                                                        4-25

4.7      OPTIONS AVAILABLE TO EPA                                        4-28

4.7.1    Fund the  Project as Proposed by the Applicant                   4-28
4.7.2    Fund the  Project as Proposed by the Applicant
         if the Applicant Agrees to  Implement Mitigation
         Measures  Within Their Legal Authority                           4-28
4.7.3    Construct a Regional System, -Treat the
         Upper Aliso Area Hastes Locally, Require
         Mitigation                                                      4-28
4.7.4    Don't Participate in the Project Since it
         Will Facilitate Growth Which Will in Turn
         Have a Significant Air Quality Impact
4.7.5    Construct a Regional System with a Smaller
         Outfall  (or other portions)4-28

5.0      SELECTED  ALTERNATIVE                                            5-1

5.1      PROPOSALS IN THE DRAFT EIS                                      5-1

5.2      PUBLIC REVIEW AND THE SELECTION PROCESS                         5-1

5.2.1    Alternative Selection and Plant Site Location                   5-1
5.2.2    Mitigation Measures                                             5-2

5.3      PROPOSED  PROJECT                                                5-3

5.3.1    Introduction                                                    5-3
5.3.2    Phase I                                                          5-3
5.3.3    Phase II                                                        5-4
5.3.4    Phase III                                                       5-4

5.4      UNRESOLVED ISSUES AND PROCEDURES FOR RESOLUTION                 5-5

5.4.1    Treatment Concept                                               5-5
5.4.2    Treatment Plant Site                                            5-5
5.4.3    Mitigation Measures                                             5-5
5.4.4    Sludge Treatment and Disposal                                   5-6
5.4.5    California Coastal  Zone Conservation
         Permit                                                          5-6

6.0      UNAVOIDABLE ADVERSE IMPACTS OF THE PROPOSED PROJECT             6-1

7.0      RELATIONSHIP BETWEEN LOCAL SHORT-TERM USES OF THE
         ENVIRONMENT AND MAINTENANCE AND ENHANCEMENT OF
         LONG-TERM PRODUCTIVITY                                          7-1

7.1      INTRODUCTION                                                    7-1

                                       iv-5

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7.1.1
7.1.2
7.2
7.2.1
8.0
8.1
8.2
8.3
8.4
8.4.1
8.4.2
8.4.3
9.0
9.1
9.2
9.3
9.4
9.5
9.6
0.0
Construction
Operation
INFLUENCES OF THE PROPOSED PROJECT UPON GROWTH IN THE
IN THE AWMA AREA
Impacts on Land Value
IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS
OF RESOURCES
LAND USE COMMITMENTS
ENERGY REQUIREMENTS
WATER RESOURCES
SCIENTIFIC RESOURCES
Pal eon to logical Resources
Archaeological Resources
Biological Resources
PUBLIC INPUT
COMMENTS RECEIVED ON THE DRAFT EIS
CHRONOLOGY
COMMENTS ON THE PLANT SITE AND ALTERNATIVES
COMMENTS RECEIVED AT THE PUBLIC HEARING
REQUIRING A RESPONSE
COMMENTS RECEIVED DURING THE DRAFT EIR
REVIEW PERIOD REQUIRING A RESPONSE
COMMENTS RECEIVED DURING THE DRAFT EIR
REVIEW PERIOD NOT REQUIRING A RESPONSE
BIBLIOGRAPHY
7-1
7-2
7-2
7-3
8-1
8-1
8-1
8-2
8-3
8-3
8-4
8-5
9-1
9-1
9-1
9-3
9-5
9-11
9-168
10-1
APPENDIX A - ENVIRONMENTAL PROTECTION AGENCY
             PREPARATION OF ENVIRONMENTAL
             IMPACT STATEMENTS                                           A-l.

APPENDIX B - ALTERNATIVE MITIGATION PLANS TO REDUCE
             POTENTIAL ADVERSE AIR QUALITY IMPACTS IN
             THE AWMA AREA                                               B-l

APPENDIX C - SAN DIEGO REGIONAL WATER QUALITY CONTROL
             BOARD REQUIREMENTS                                          C-l

APPENDIX D - CALIFORNIA COASTAL ZONE CONSERVATION
             COMMISSION REQUIREMENTS                                     D-l

                                      iv-6

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                               LIST OF EXHIBITS

 INTRODUCTION/DESCRIPTION OF THE PROBLEMS

 1-1      Regional Location Map
 1-2      County Location Map
 1-3      AWMA Member Agencies
 1-4      Existing Facilities (Map)
 1-5      Existing Facilities (Diagram)

 DESCRIPTION OF THE EXISTING ENVIRONMENT

 2-1      Seismic Index Map
 2-2      Agricultural Land
 2-3      Vegetation Communities
 2-4      Wildlife Habitats
 2-5      Endangered Habitat Types
 2-6      Historical  Variations in the Occurrence and Extent of Kelp
         Beds between Laguna Beach and Dana Point
 2-7      Marine Life Refuges
 2-8      Existing Land Use
 2-9      Noise Contours

 WASTEWATER MANAGEMENT ALTERNATIVES AND THEIR PRIMARY IMPACTS

 3-1      Alternative 1A (Map)
 3-2a     Alternative 1A (Diagram)
 3-2b     Alternative 1A - Modified (Map)
 3-2c     Alternative 1A - Modified (Diagram)
 3-3      Alternative 2E (Map)
 3-4      Alternative 2E (Diagram)
 3-5      Alternative Sites Regional  Treatment Facility
 3-6      AWMA Proposed Regional  Treatment Plant Site
 3-7      Area North  of Proposed Plant Site
 3-8      Area South  of Proposed Plant Site
 3-9      Aliso Creek Channel  Adjacent to  Proposed Regional  Treatment Plant
 3-10
 3-11
 3-12
 3-13
 3-14
3-15
 3-16
 3-17
3-18
3-19
3-20
3-21
3-22     Service Road Alternative  Alignments
                                      v-1
Alternative 3C (Map)
Alternative 3C (Diagram)
Alternative 4A (Map)
Alternative 4A (Diagram)
Alternative 2F (Map
Alternative 2F (Diagram)
Alternative 4C (Diagram)
Alternative 2G (Map)
Alternative 2G (Diagram)
Dilution Contours
Regional Treatment Plant
Regional Treatment Plant
View from West Side of Aliso Creek
View from East Side of Aliso Creek

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SECONDARY IMPACTS OF PROJECT ELEMENTS

4-1      Cities and Urbanization in Orange County
4-2      Pattern of Urbanization within AWMA
4-3      Existing Land Use
4-4      Existing Zoning
4-5      Land Values
4-6      Existing Water Distribution Facilities
4-7      Existing Facilities (Waste Water Treatment)
4-8      Orange County Alternative Population Forecasts
4-9      AWMA Alternative Population Forecasts
4-10     Projected Wastewater Flows
4-11     Adopted Land Use
4-12     Proposed Land Use
4-13     Basic Planning Categories-1983 Land Use Element
4-14     Arterial Highways
4-15     New Freeway Construction Affecting Region
4-16     External Stimuli
4-17     Present Traffic Flow into AWMA
                                     v-2

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                               LIST OF EXHIBITS

 INTRODUCTION/DESCRIPTION OF THE PROBLEMS

 1-1      Regional Location Map
 1-2      County Location Map
 1-3      AWMA Member Agencies
 1-4      Existing Facilities (Map)
 1-5      Existing Facilities (Diagram)

 DESCRIPTION OF THE EXISTING ENVIRONMENT

 2-1      Seismic Index Map
 2-2      Agricultural Land
 2-3      Vegetation Communities
 2-4      Wildlife Habitats
 2-5      Endangered Habitat Types
 2-6      Historical  Variations in the Occurrence and Extent of Kelp
         Beds between Laguna Beach and Dana Point
 2-7      Marine Life Refuges
 2-8      Existing Land Use
 2-9      Noise Contours

 WASTEWATER MANAGEMENT ALTERNATIVES AND THEIR PRIMARY IMPACTS

 3-1      Alternative 1A (Map)
 3-2a     Alternative 1A (Diagram)
 3-2b     Alternative 1A - Modified (Map)
 3-2c     Alternative 1A - Modified (Diagram)
 3-3      Alternative 2E (Map)
 3-4      Alternative 2E (Diagram)
 3-5      Alternative Sites Regional  Treatment Facility
 3-6      AWMA Proposed Regional  Treatment Plant Site
 3-7      Area North  of Proposed Plant Site
 3-8      Area South  of Proposed Plant Site
 3-9      Aliso Creek Channel  Adjacent to  Proposed Regional  Treatment Plant
 3-10     Alternative 3C (Map)
 3-11     Alternative 3C (Diagram)
 3-12     Alternative 4A (Map)
 3-13     Alternative 4A (Diagram)
 3-14     Alternative 2F (Map
 3-15     Alternative 2F (Diagram)
 3-16     Alternative 4C (Diagram)
 3-17     Alternative 2G (Map)
 3-18     Alternative 2G (Diagram)
 3-19     Dilution Contours
 3-20     Regional Treatment Plant View from West Side of Aliso Creek
3-21     Regional Treatment Plant View from East Side of Aliso Creek
3-22     Service Road Alternative Alignments
                                      v-1

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SECONDARY IMPACTS OF PROJECT ELEMENTS

4-1      Cities and Urbanization in Orange County
4-2      Pattern of Urbaniza.tion within AWMA
4-3      Existing Land Use
4-4      Existing. Zoning
4-5      Land Values
4-6      Existing Water Distribution Facilities
4-7      Existing Facilities (Waste Water Treatment)
4-8      Orange County Alternative Population Forecasts
4-9      AWMA Alternative Population Forecasts
4-10     Projected Wastewater Flows
4-11     Adopted Land Use
4-12     Proposed Land Use
4-13     Basic Planning Categories-1983 Land Use Element
4-14     Arterial Highways
4-15     New Freeway Construction Affecting Region
4-16     External Stimuli
4-17     Present Traffic Flow into AWMA
                                     v-2

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                                 LIST OF TABLES
 INTRODUCTION/DESCRIPTION OF THE  PROBLEMS

 1-1       Existing  Facilities/Performance
 1-2       1973 Average Treated Wastewater Characteristics

 DESCRIPTION OF THE EXISTING ENVIRONMENT

 2-1       Watershed Systems of the AWMA Area
 2-2       Slope AnalysisBreakdown for the AWMA Area
 2-3       Maximum Probable Earthquakes and Seismic Shaking Characteristics
 2-4       Geologic Constraints on Population Growth in the AWMA Region
 2-5       Specific Soil Properties of the AWMA Area
 2-6       Land Capability Classification and Limitations to Development
 2-7       Federal Air Quality Standards 1973
 2-8       California Air Quality  Standards 1973
 2-9       Selected Characteristics of Offshore Water
 2-10      Orange County Natural Biotic Communities
 2-11      Biotic Communities
 2-12      Declining species of Birds Expected to Frequent the AWMA Region
 2-13      Marine Life Refuges
 2-14      Existing Land Use-Orange County/AWMA
 2-15      Analysis of Metrpolitan Water District Water Supplies
 2-16      Blending of Colorado River Water and State Project Water
 2-17      Range in Values of Analysis of Colorado River Water 1963-1972
 2-18      Population and Wastewater Flows
 2-19      Summary of Governmental Authority

 WASTEWATER MANAGEMENT ALTERNATIVES AND THEIR PRIMARY IMPACTS

 3-1       Projected Mass Emissions (Pounds Per Day) to Ocean
 3-2       Anticipated Subsequent Dilution and Total Reduction in Coliform
          Organisms for the Aliso Creek Ocean Outfall
 3-3       Comparison of Alternative Sites
 3-4       Alternative Site Information AWMA Regional  Wastewater Treatment
          Plant

 SECONDARY IMPACTS OF PROJECT ELEMENTS

4-1       Demographic/Building Trends
4-2      Housing/Employment
4-3       Population Growth within AWMA
4-4      Orange County 1970 Census
4-5      Breakdown of Maximum Portion to Member Agencies of the Total
         Capacity of the Proposed AWMA Facilities
4-6      Member Agency Outfall  Capacity - California  Coastal  Zone Conser-
          vation Commission
4-7      Surface Runoff Pollution Coefficients
4-8      Land Use Acreage
4-9      Surface Runoff Pollution from Existing Land  Uses
                                   vi-1

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4-10     Surface Runoff Pollution from Adopted Land Uses
4-11     Surface Runoff Pollution from Proposed Land Uses
4-12     Summary of Surface Runoff Pollution

IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES

8-1      Energy Expenditure for Pumping Raw Sewage Up Grade as
         Designated in Project Alternative 1A
8-2      Energy Expenditure for Pumping Raw Sewage Up Grade as
         Designated in Project Alternative 2G
8-3      Energy Expenditure for Pumping Raw Sewage Up Grade as
         Designated in Project Alternative 4A
8-4      Energy Expenditure for Pumping Raw Sewage Up Grade as
         Designated in Project Alternative 2E and 2F
8-5      Energy Expenditure for Pumping Raw Sewage Up Grade as
         Designated in Project Alternative 3C
                                    vi-2

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 INTRODUCTION/DESCRIPTION OF PROBLEMS

 1.1   BACKGROUND

 The  Aliso Water Management Agency  (AWMA) was established on March 1, 1972
 by the execution of a joint powers agreement in accordance with Article 1,
 Chapter  V,  Division II, Title 1 of the Government Code, State of California.
 The  Agency  has seven members:  The Moulton-Niguel Water District, the South
 Laguna Sanitary District, the Irvine Ranch Water District, the El Toro Water
 District, the Los Alisos Water District, the City of Laguna Beach, and the
 Emerald  Bay Service District.  The jurisdictional boundaries of each dis-
 trict is shown on Exhibit 1-3.

 AWMA is  a legal entity created, operating, and functioning in response to
 the  needs for a regional body to plan, construct and operate facilities
 for  a water management program within the Aliso Valley Watershed Basin and
 related  contiguous areas.  Included in the management programs are the col-
 lection, transmission, treatment and disposal of wastewater; the reclamation
 of wastewater; and the use of reclaimed wastewater for beneficial purposes.

 The  member  agencies of AWMA comprise an area of Orange County encompassing
 approximately 48,905 acres extending from Dana Point on the southeast coast
 to the southeasterly city limits of the City of Corona del Mar (Exhibits
 1-1  and  1-2).  The agency boundaries extend northerly from the coast 15
 miles inland to the foothills of the Santa Ana Mountains in Northern El
 Toro.  The  entire service area lies between the Santa Ana River basin on
 the  northwest and the San Juan Creek watershed on the east.

 1.1.1  Relationship to Other Projects in Orange County

 There are two related Facilities Planning Areas in Southern Orange County
which merit discussion; the South East Regional Reclamation Authority (SERRA)
 area and the Irvine Ranch Water District (IRWD) area.

 1.1.1.1   South East Regional  Reclamation Authority (SERRA)

 SERRA is located directly to  the south of AWMA (Exhibit 1-2) and is  made
 up of the cities of San Clemente and San Juan Capistrano, the Santa  Margarita
 Water District, the Moulton Niguel  Water District's Improvement District
 Number 3, the Dana Point Sanitary District and the Capistrano Beach  Sani-
 tary District.

 From 1969 through 1972 a series of projects were undertaken in the SERRA
 area which  tied all  members except San Clemente into a regional  system
with a regional  sewage treatment plant.   Through the existing Dana Point
outfall, treated wastewater is currently being discharged.

The Dana Point outfall  does not have sufficient hydraulic capacity for
long-range flows; indeed,  existing  flows are now pumped.   Further,  the
outfall  terminates in  shallow water near the mouth of the Dana Point Har-
bor.   Consequently,  a  project to replace the existing outfall  was formulated
                                    1-1

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                                ,.                 .
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Exhibit  1-1

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                             'Orange
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                                                 Irvine Lake
                Disneyland
                                               IRVINE RANCH
                                               WATER DISTRICT
                Garden G
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                        .^J^PHuntingtgi
                                 Mesa^B^
                                                   Irvine
                                                 UC4
                                                                        V'
                                                           ALISO WATER
                                                           MANAGEMENT AGENCY
                                       SOUTH CAST REGIONAL
                                       RECUMMATION AUTHORITY
                     Laguna
3
               Beach
                                                                                     Point
 COUNTY  LOCATION  MAP
                    PACIFIC OCEAN
Exhibit  1-2

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 and  is  the  subject  of  an  EPA environmental impact statement which was cir-
 culated for comment on March 28, 1975.

 1.1.1.2  Irvine  Ranch  Water District  (IRWD)

 IRHD is a water  district  located almost entirely within the boundaries
 of the  Irvine  Company's land holdings  (see Exhibit 1-2).  IRWD was initial
 ly  created to secure  a water supply  for  irrigation and domestic use.  With
 changes in  the California Water District  law, IRWD began to provide sewer
 service after  specific authorization  by electors of the district in March,
 1965.   Part of the  Irvine Ranch Water  District lies within the boundaries
 of AWMA.

 The  IRWD currently  has a  5.0 mgd treatment plant and reclamation system.
 The  treatment  plant was funded partially  by EPA's predecessor agency with
 a  grant dated  July  15, 1969.  Part of  the reclamation system, the Rattle-
 snake outfall  from  the plant to Rattlesnake Reservoir, was also funded with
 EPA  assistance in the  form of a grant  offer dated June 25, 1974.

 The  IRWD is  considering adding an additional 5 mgd of treatment capacity
 since their service area  is being developed by the Irvine Company and flows
 are  increasing rapidly.  The State of  California has instructed the IRWD
 to prepare  a Facilities Plan for their entire service area to determine
 optimum long-term solutions for water  quality problems.  This Facilities
 Plan and an  EIR, required under the California Environmental  Quality Act
 are  currently  nearing  completion and it is anticipated that the IRWD will
 hold a  public  hearing  on the Facilities Plan and EIR on about August 1,
 1975.

 The  Facilities Plan  and EIR will be eligible for Federal and State grants
 as a "Step  1"  project  (advance planning).  However, it has not yet been
.determined whether  design and construction (Steps 2 and 3) of any facili-
 ties will be eligible  for State or Federal funding.  Should it be deter-
 mined that  facilities  are eligible, the entire project will  be subjected
 to an environmental  review by EPA.   At that time, EPA will decide whether
 or not  to prepare an EIS on the project.  Since the likelihood of funding
 is speculative at present, it is premature to consider the effects of the
 project in  this  EIS.

 1.1.1.3 Relationship  to the AWMA Project

 Several  comments on  the draft EIS indicated that a single EIS should have
 been prepared  to cover the entire southern portion of Orange  County,  which
 is largely  undeveloped.  Since the South County area is expected to urban-
 ize  rapidly, and since sewerage services can play a significant role in
 urbanization,  this  is  a logical  suggestion and EPA's EIS regulations recog-
 nize that individual projects can have fairly minor environmental  effects
 while leading  to a  significant cumulative effect.  However,  EPA has decided
 that an  overall  EIS  is not the ideal  approach in the current  situation.
 First of all, all of the three projects are in different stages.   The Aliso
 project proposed the initial'consolidation of six agencies with sanitary
                                    1-2

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                                              \
                                               \
                                                 \
                                                  N

            EMERALD BAY
            SERVICE DISTRICT
Legend
        IRVINE RANCH
        WATER DISTRICT
        LAGUNA BEACH
        WATER DISTRICT
        SOUTH LAGUNA
        SANITARY  DISTRICT
        LOS  ALISOS
        WATER DISTRICT
        EL TORO
        WATER DISTRICT
        MOULTON  NIGUEL
        WATER DISTRICT
 Exhibit 1-3

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 responsibilities.   In  the SERRA service area,, regionalization is about 80
 percent  completed.  And  in the Irvine Ranch area, current facilities are
 adequate and  it  is  not certain whether new facilities will be eligible for
 grant  funds.  Secondly,  Aliso is under the time constraints of the California
 Coastal  Zone  Conservation Commission and NPDES permit requiring timely upgrading
 of  the system (see  Appendix C and D).  Finally, both the AWf-IA and the SERRA
 projects have been  determined to have significant environmental impacts
 in  and of themselves.  Consequently, an EIS was prepared for each project.
 Consideration was given  to preparing a joint EIS on the two projects, but
 this approach was rejected because of timing problems.  The EISs were coor-
 dinated  internally  within EPA and with the AWMA and SERRA consultants; in-
 formation developed for  the AWMA EIS was used in the SERRA EIS and vice-
 versa.

 1.2 EXISTING WASTEWATER TREATMENT FACILITIES AND THEIR PERFORMANCE

 1.2.1  Moulton-Niguel  Hater District

 1.2.1.1    Moulton-Niguel Water District - Improvement District No. 1A

 Moulton-Niguel Water District Improvement District No. 1A contains approx-
 imately  8,200 acres of land and is located on the southerly portion of the
 Moulton-Niguel Water District (Exhibit 1-3).  It ranges from approximately
 one mile  to seven miles  inland from the coast and is adjacent to and nor-
 therly of South Laguna Sanitary District and easterly of the City of Laguna
 Beach.   This  area is commonly referred to and has the postal  address of
 Laguna Niguel.

 Improvement District No. lA's wastewater treatment facilities consists of
 a local  inland plant and capacity in a jointly owned local  plant located
 along Aliso Creek approximately one mile inland from the ocean.   These
 facilities are jointly owned by the Moulton-Niguel  Water District Improve-
 ment Districts Nos.  2A and 3A as well as the South Laguna Sanitary District.
 The District's inland plant is a secondary treatment plant consisting of
 an activated  sludge process which is patented by Chicago Pump and is known
 as a rapid block type.  The present treatment capacity of the plant is
 0.5 million gallons per day (Table 1-1).   Various facilities  existing in
 the plant were built for future expansion to a capacity of 2  million gal-
 lons per  day.  The District's flow is conveyed to the plant by a combina-
 tion of pumping stations and gravity sewers  terminating in  a  gravity sewer
 feeding the plant.

One of the existing major pumping stations located just south of the El
 Niguel  Golf Course along Crown Valley Parkway and Pacific Island Drive must
 be rebuilt.  The sewage flow is  accumulated  at this  point and pumped via
 Crown Valley  Parkway with the option of bypassing the 1A plant and down
Aliso Creek.

 Plant effluent is conveyed to four oxidation ponds.   These  ponds  serve
as holding reservoirs for reclaimed water which ultimately  is  pumped to
 the Laguna Niguel Golf Course.   Proposals  and negotiations  are underway
 to develop additional  areas  for  the use  of reclaimed water  to  enhance and
                                  1-3

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                                                                       TABLE 1-1
                                                      EXISTING  FACILITIES/PERFORMANCE
     FACILITY
                         DESIGN
                         CAPACITY
                         (MGD)
             AVERAGE
               FLOW
               (MGD)
TREATMENT
 PROCESS
METHOD OF FINAL
   DISPOSAL

Effluent	Sludge
OPERATIONAL
PERFORMANCE
& CONDITION
TREATMENT PLANTS:
M-N WD Improvement
District No. 1A
                           0.5
                                          0.13
                          Secondary (Activated  Reclamation
                          Sludge and Rapid Bloc)
                                            Diverted to South
                                            Laguna Treatment
                                            Plant
                                        .Satisfactory,  now, but not
                                        usable during  rainy season
                                        .Not economically feasible for
                                        expansion
                                        .Waste reclamation is satis-
                                        factory	
M-N WD Improvement
District No. 2A
                           0.35
                          Secondary (Activated
               0.05       Sludge Evaporation
                          and Rapid Bloc)
                       Evaporation          Local Drying       .Satisfactory, now, but not econ-
                                            Beds                omically feasible for expansion
                                                               .Waste reclamation is satisfact.
                                                               .Does not have aeration in ponds;
                      	not usable during winter mos.
South Laguna Sanitary
District - MNWD
               0.80-
3.2            1.14
 Secondary (Activated   Ocean
 Sludge)
                                                                                                Landfill
                                        . Satisfactory now
                                        .Overall operational problems;
                                        not adequate flexibility
                                        .Solids handling needs improv.
                                        . Effective capacity proposed to
                                        be modified to 2.5 MGD to
                                        meet waste discharge require-
                                        ments and  nitrification require-
                                        ments (State Coastal Comm.)
Los Alisos Water
District
                           4.0
                                           1.04
                          Secondary (Activated  Reclamation
                          Sludge and Rapid Bloc)
                                                                                                Landfill
                                                               .Satisfactory now, and no
                                                                modifications will be necessary
                                                                after construction of regional
                                                                facilities
                                                               . High quality effluent
                                                               .Unsatisfactory winter storage
El Toro Water District
                           4.0
                                          2.12
                                                     Secondary (Activated
                                                     Sludge)
                                                Reclamation         Landfill and         . Satisfactory now, and also
                                                                     Agricultural         after construction of regional
                                                                     use                 facilities
                                                                                         .High quality effluent
                                                                                         . Secondary treated effluent pro-
                                                                                         hibited for discharge into San
                                                                                         Diego Creek
                                                	. Unsatisfactory winter storage
City of Laguna Beach
                           4.0
                                          1.81
                                                     Primary
                                                                           Ocean
                                                                                                Landfill
                                                                                                                   . Unsatisfactory now
                                                                                                                   -Outdated, inadequate treatment
                                                                                                                    facilities
                                                                                                                   . Primary treatment only
                                                                                                                   . Poor quality effluent	
OCEAN OUTFALLS:
Aliso Creek Outfall
                           3.2
                                        1.6-2.2
                                                                           Ocean
                                                                                                                   .Under Interim NPDES Permit
                                                                                                                    until completion of AWMA
                                                                                                                    outfall
                                                                                                                   . Inadequate capacity
                                                                                                                   . Too shallow to meet ocean plan
Laguna Beach Outfall
                           4.0
                                        1.8-3.5
                                                                           Ocean
                                                                                                                   . Unsatisfactory now
                                                                                                                   .NPDES application is currently
                                                                                                                    being reviewed by EPA and
                                                                                                                    RWQCB
                                                                                                                   .Too shallow to meet ocean plan

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Newport
Beach
Legend
......... RAW SEWAGE INTERCEPTOR
^— LAND OUTFALL
	  OCEAN OUTFALL
nmmmmmmi FORCE MAIN
   A    PUMP STATION
  d   SECONDARY TREATMENT PLANT
  A   PRIMARY TREATMENT PLANT
Dana Point i
Exhibit  1-4

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                        LAWD PLANT
                        4.0 MGD
                    3
ROSSMOOR PLANT
4.0 MGO
                      IIBI
                 8"/0.5 MGD
              4"/4.2 MGD-6.6MGD
                33"/23.5 MGD
                 18"/4.5 MGD
         MNWD 2A PLANT
         0.35 MGD
                       30"-33"/ 15.5-20 MGD
                       (•(•(•(•(•I
           MNWD 1A
I           PLANT
           0.5 MGD
          1
                                   21"


                                   15"



                                   12"
  10"-20"
 IIIIIBIBI
       CITY OF LAGUNA
       BEACH PLANT
       2.0 MGD
           10"-18"
                           JOINT
                           MNWD-
                           SLSD PLANT
                           3.2 MGD
     18"/2.5MGO
    IBIBIBIIIIMHBI
EXISTING FACILITIES
Exhibit 1-5

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stimulate open space conservation.  Contracts with Orange County and AVCO
Community Developers for reclaimed water have been executed.  Effluent chlo-
rination facilities are provided both before and after the oxidation ponds.
The sludge is aerobically digested and dried on a series of drying beds
at the plant site.

In addition to the inland plant, Improvement District No. 1A has treatment
and disposal capacity at the South Laguna Sanitary District treatment fa-
cilities in Aliso Creek.  Moulton-Niguel Water District Improvement District
No. 1A owns 0.7 million gallons per day capacity in the facility.  This
facility is further described later in this chapter.

1.2.1.2   Moulton-Niguel Water District - Improvement District No. 2A

The Moulton-Niguel Water District Improvement District No. 2A has an area
of approximately 1,225 acres and is located in the north central portion
of the Moulton-Niguel Water District extending from the San Diego Freeway
southerly approximately 1.5 miles and lying adjacent to and south of the
El Toro Water District.  This community is referred to and has a postal
address of the Laguna Hills.

The MNWD 2A wastewater treatment plant provides secondary treatment of wastes
with activated sludge process and the Chicago Pump patented Rapid Block
System.  It has a capacity of 0.35 million gallons per day designed for
expansion to an ultimate size of 1.35 mgd (Table 1-1).  Raw sewage is pumped
to the plant.  Reclaimed water is pumped to several  evaporation ponds for
ultimate disposal.  The sludge is conveyed to sludge drying beds after being
aerobically digested.

Reclaimed water is of good quality and is sufficient for irrigation for
agricultural  use.  Improvement District No.  2A has previously contracted
with a surrounding landowner for use of the reclaimed water for irrigation
of. field crops.  Two additional  uses are being investigated.  Consideration
is being given to development of a greenbelt barrier completely surrounding
the plant.   The greenbelt could be used for a park and the reclaimed water
from the plant would be used to irrigate the park.  Consideration is also
being given to the construction of a dam and lake on Aliso Creek just north-
westerly of the plant site.   The lake could have a twofold purpose:  first,
flood control and secondly,  recreation with a park surrounding the lake.
The reclaimed water would replenish the lake and irrigate the greenbelt
area around the park.

This plant was constructed in 1965.   At the  present  time, the plant can
be bypassed utilizing the pumping station to pump incoming sewage to the
interceptor down Aliso Valley to the joint South Laguna  Sanitary District
Moulton-Niguel  Water District treatment facilities near  the mouth of Aliso
Creek.
                                   1-4

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 1.2.1.3   Moulton-Niguel Water District - Improvement District No. 3A

 The Moulton-Niguel 3A plant is a 0.5 mgd treatment plant constructed in
 1967 and located west of Interstate Highway 5 at Oso Creek (Exhibit 1-4
 and 4-7).  The plant effluent is utilized entirely for golf course irriga-
 tion with no discharge.  The plant is located within the boundary of the
 South  East Regional Reclamation Authority and will not be considered in
 this EIS.  The treatment plant, however, is interconnected with those in
 improvement districts No. 1A and 2A by way of an interceptor (Exhibit 4-
 7).  This pipeline was installed as a safety feature for overflows from
 these  plants during emergency conditions.  If this were to occur, discharge
 of effluent would proceed through the Dana Point outfall.

 1.2.2  South Laguna Sanitary District

 The South Laguna Sanitary District contains approximately 2,700 acres and
 is located along the coast adjacent to and southerly of the Moulton-Niguel
 Water  District extending inland approximately one mile (Exhibit 1-3).
 On the northwest of the South Laguna Sanitary District is the City of Laguna
 Beach.  To the south is Dana Point and the recently constructed Dana Point
 Harbor.  The South Laguna Sanitary District constructed and owns one-half
 of the capacity of a secondary wastewater treatment plant constructed near
 the mouth of Aliso Creek.  Of the one-half capacity owned by Moulton-Niguel
 Water  District, 0.7 mgd each is owned by Improvement Districts Nos. 1A and
 3A and 0.2 mgd by 2A, as previously stated.   The South Laguna Sanitary Dis-
 trict has the option to terminate service to Moulton-Niguel Water District's
 1.6 mgd capacity upon giving 18 months advance notice (Table 1-1).  Total
 capacity of this plant is 3.2 million gallons per day.   The plant is a sec-
 ondary activiated sludge treatment plant.   Ultimate disposal  is through
 an ocean outfall.

 The ocean outfall is located off the coast at Aliso Creek and was constructed
 in 1953.  The land portion of the outfall  which passes  through the Laguna
 Beach Golf Course is 15 and 21-inch pipe.   The ocean portion extends approx-
 imately 1,800 feet from the coast and is 18-inch concrete cylinder pipe.
 The discharge is at a depth of 60 feet.   The diffusers  are 80 feet long.
 Both primary and waste activated sludge  are  conveyed into two sludge thickener
 tanks, then to a purifax conditioning unit and sludge drying beds.

 The first 1.6 mgd plant was constructed  in 1968 and expanded to 3.2 mgd
 in 1969.  The treatment plant site has been  master planned for expansion
 to a capacity of 10 mgd.  The ability to expand the existing sites to this
 capacity is questionable.

 In the past,  proposals have been considered  for use of  reclaimed water
 for irrigation of the Laguna Beach Golf  Course just south of the plant
 along Aliso Creek.   In addition,  the County  of Orange has investigated
 the potentials of developing a  perimeter greenbelt and  open space park
along Aliso Park and Aliso Creek to the  north of the plant.   The reclaimed
water could be used for potential  beneficial  uses such  as irrigation of
 greenbelt areas.
                                  1-5

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 1.2.3  Los Allsos Water District

 The Los Alisos Water District is located in the northern portion of the
 Aliso Water Management Agency (Exhibit 1-3).  It is approximately one and
 one-half miles east of the El Toro Marine Corps Air Station and to the north
 of and adjacent to the El Toro Water District and contains approximately
 5,380 acres.  The major residential area of the Los Alisos Water District
 is in the southerly portion of the District and is referred to as Lake Forest.

 The Los Alisos Water District treatment plant provides secondary treatment
 of wastes utilizing a series of three oxidation ponds, plus additional
 headwork facilities.  The initial capacity of the plant, constructed in
 1964, was 0.5 mgd.  Recently the capacity has been expanded to 4.0 mgd (Table
 1-1).  The headworks and other plant facilities have a capacity for an addi-
 tional 1.5 mgd.  A portion of the treated wastewater flow from the treatment
 plant goes through a series of aeration and treatment lagoons to settling
 and naturation ponds for reclamation.  From the ponds, the reclaimed water
 passes through the chlorine contact chamber and is pumped to the Irvine
 Ranch property where it is utilized by the Irvine Company for irrigation
 of agricultural lands.  In addition, the District has a connection to one
 of the Irvine Company's irrigation pipelines which conveys the reclaimed
 water to the Laguna Reservoir located along Laguna Canyon Road approximately
 two miles south of the San Diego Freeway and three miles directly west of
 the Los Alisos Water District treatment plant.

 The Los Alisos Water District has leased land from the Irvine Company northwest
 of the plant site on which the District is proposing to operate a land spray
 irrigation system.  The District has also considered use of the reclaimed
water for park irrigation along Serrano Creek adjacent to and southerly
 of Trabuco Road.   There is an extensive agricultural development in the
 northerly portion of the District and the District has authorized the trans-
 mission of reclaimed water to these areas for use as irrigation water.
 In addition, consideration has been given to the use of reclaimed water
 for replenishment of manmade lakes located in the Lake Forest development.
 The District has  transported effluent to grading contractors in the area
 for use in earth  moving projects.

 1.2.4  El  Toro Water District

The El Toro Water District is located approximately two miles directly
 south of the El  Toro Marine Corps Air Station and is adjacent to both the
 Los Alisos Water  District and the Moulton-Miguel  Water District (Exhibit
 1-3).  The area of El  Toro Water District is approximately 4,750 acres.
There are basically two separate communities within the District,  separated
by the San 'Diego  Freeway.  On the southwest is the community of Rossmoor
 Leisure World, commonly referred to as  Laguna Hills.  On the northeast is
 the community of  El  Toro.

Rossmoor Sanitation, Inc., presently provides all  collection, treatment
and disposal  services  within the El  Toro Water District through a service
agreement.  In early 1971, the El  Toro  Water District undertook the necessary
legal  proceedings to become a servicing agency,  and on June 30, 1972,  adopted
                                  1-6

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a resolution authorizing the issuance of general obligation bonds for the
construction of sewage, collection, treatment and disposal facilities.

The Rossmoor wastewater treatment facilities utilize a pre-aeration reservoir
ahead of the treatment plant headworks facilities which includes selecto
strainers and metering facilities.

The plant has a rated capacity of 4.0 mgd (Table 1-1).  The activated sludge
treatment process occurs in the pre-aeration reservoir.  The remainder of
the plant is a circular compartmentalized chamber consisting of the aeration
unit, the contact unit and the clarifier.  Waste sludge from the system
is thickened, chemically treated and partially dewatered in the sludge
concentrator and hauled to a site for land reclamation.

The reclaimed water from the plant is stored in a forty acre-foot reservoir
just west of the plant located on the Leisure World Golf Course.  The effluent
is chlorinated in a contact chamber adjacent to and southerly of the plant.
Effluent is then pumped to several large rainbird sprinklers on undeveloped
lands within and outside the district for spray irrigation.  Rossmoor Sani-
tation, Inc., also leases 200 acres of agricultural lands from the Irvine
Company where the reclaimed water is used for irrigation.

1.2.5  City of Laguna Beach

The City of Laguna Beach is the only incorporated community within the
Aliso Water Management Agency and encompasses approximately five square
miles of land fronting the Pacific Ocean.  The city is bounded on the south
by the South Laguna Sanitary District and extends northerly a distance of
approximately four and one-half miles to the northerly limits of the Aliso
Water Management Agency.  The initial sewage system serving the City of
Laguna Beach was constructed in 1923 and has been modified several  times
since the initial  construction.  At the present time,  the existing treatment
plant, owned and operated by the City of Laguna Beach, is a primary treatment
plant with a rated capacity of 2 mgd (Table 1-1).   This plant is currently
being expanded to a rated capacity of 3 mgd, with ferric chloride and polymer
treatment.   The final  effluent from the wastewater treatment facilities
is discharged through a 3,200 foot-long ocean outfall  terminating at a water
depth of approximately 80 feet.  Sludge treatment consists of digestion,
followed by drying of digested sludge on drying beds at a remote site from
the wastewater treatment facility.

1.2.6  Emerald Bay Service District

The sewage facilities presently serving the Emerald Bay Service District
consists primarily of a collector system and pumping stations  which  ultimately
discharge into the existing facilities of the City of  Laguna  Beach.   The
waste generated within the service district is  treated and disposed  of through
the Laguna  Beach Facilities through a contract  with the City  of Laguna  Beach.
                                   1-7

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• J.2.7  Irvine  Ranch Water District

The Irvine  Ranch Water  District is located in the northwestern portion
of the  Aliso Water Management Agency area (Exhibit 1-3).  The total area
of the  Irvine  Ranch Water District includes approximately 67,850 acres.
However,  only  8,560 acres lies within the boundaries of the Aliso Water
Management  Agency.  This area is currently in a rural, undeveloped condition
with  a  negligible population.

Wastewater  facilities on this portion of the IRWD are nonexistent; however,
inasmuch  as the lands are a portion of the drainage area of the Aliso Watershed
the IRWD  elected to be  a member in order to participate in the overall planning
of  the  regional sewage  facilities.

The waste that is generated by the few homes within this portion of the
IRWD  is handled through septic tank facilities.

1.3  DESCRIPTION OF THE PROBLEMS IN EXISTING WASTEWATER TREATMENT FACILITIES

Table 1.2 summarizes the 1973 average treated wastewater characteristics
for the six treatment plants within the AWMA area.  The information given
for total suspended solids and BOD is1 based on available data.  Data collection
methods may frequently  vary but it is believed the analyses shown are represen-
tative of existing performance.

1.3.1  South Laguna Sanitary District

Until recently, the South Laguna Sanitation District (SLSD) treatment plant
was frequently loaded at or beyond the capacity for which it was designed,
and compliance with water discharge requirements was not achieved.   This
situation was caused by variable discharges from the frequently overloaded
upstream  Moulton-Niguel plants.  Not only were discharge requirements violated,
but the hydraulic capacity of the outfall became over taxed.

With completion of the sewage treatment plant in San Juan Capistrano and
operational  improvements in the M-NWD and SLSD plants,  most of the above
problems were temporarily solved.   Currently,  an average discharge of 1.8
mgd of wastewater is treated at the SLSD plant; 0.8 mgd is collected from
the M-NWD sewerage system and transported to the plant  via a  trunk line.
The treated effluent is discharged through a 1,800 foot ocean outfall  which
terminates in 60 feet of water.

SLSD system is experiencing the following problems:

1.    South Coast Beach Interceptor

Leakage from the South Coast Beach Interceptor has posed serious  pollution
problems over the past decade.   The interceptor is currently  being replaced
because of its deterioration,  leakage,  and cracking due to the generation
of hydrogen  sulphide gas,  which has been attacking the  existing facility
since its  installation in  the  mid-1950's.
                                  1-8

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 2.    Solids  Handling

 The existing SLSD plant uses the purifax process to stabilize their sludge.
 This  process  has not been reliable and odors from drying beds have been
 a problem.   This sytem is also costly and fairly inflexible, and is not
 a good  basis  for any further plant expansion.  In addition, the sludge drying
 beds  are located fairly close to Aliso Creek and could be inundated by flood-
 ing,  or sludge could wash into the creek during heavy rains.

 3.    The Design and Placement of the Ocean Outfall

 The SLSD ocean outfall violates the State Water Resources Control Board
 Water Quality Control Plan, Ocean Haters of California,  adopted on July
 6, 1972.  The existing outfall is too short (1,800 feet), lacks a terminating
 diffuser system, and terminates in too shallow a depth of water (60 feet).
 It not  only  violates the required dilution ratio of 100/1, but it is a po-
 tential hazard to the health of bathers at Aliso Beach.  Studies of ocean
 currents in  the vicintiy of the outfall indicate that during certain portions
 of the  day, currents are essentially shoreward.  Ocean beaches and waters
 in the  area are heavily used for water contact sport activities, as well
 as both commercial and sport fishing.  Effluent discharge also presents
 a potential  threat to marine biological resources and reserves within a
 few thousand feet of the outfall.

 The land portion of the outfall is also unsatisfactory.  Poor construction
 practices (use of a caulking compound which has swollen from water absorption)
 has cracked many of the joints along the line.   This in turn has led to
 infiltration and occasional  overflow of the lines.

 4.    Effluent Quality

 Use of  the SLSD plant to treat M-NWD's Plants 1A and 2A's sludge has interfere
with efficient operation of the SLSD plant.   The plant is too small  to be
 able to handle the fluctuations in flow volumes and strengths which  have
 resulted from this sort of operation.  Consequently, effluent is of poor
 quality.  Coliform violations have also been detected, although  this is
an operational problem.

 1.3.2  The City of Laguna Beach

The treatment system for the City of Laguna  Beach has experienced the followin
 problems.

 1.   Condition of the Treatment Plant

The City's treatment plant was constructed in 1932,  and the useful  life
of a treatment plant is generally calculated to be twenty to thirty  years.
As is  to be expected, the treatment plant is not in good shape,  and  because
of its age, replacement parts are very hard  to  obtain.  The treatment plant
 has not been well  maintained lately,  and is  in  generally dilapidated condition
                                  1-9

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                             TABLE 1-2

          1973 AVERAGE TREATED WASTEWATER CHARACTERISTICS
                        Total                         % Total
                      Suspended                     Suspended       %  BOD
Treatment Plant      Solid mg/1*      BOD mg/1*  Solid Removal*    Removal*

Los Alisos               22.0           24.0           91              89
Rossmoor Sanitation       7.0            6.4           97              97
Moulton-Niguel 1A        26.0           20.3           98              89
Moulton-Miguel 2A        24.1            24.3           94              87
South Laguna             52.1            17.7           90              94
City of Laguna Beach    109.0          157.0           56              25


*Federal Environmental Protection Agency Standards  for Secondary  Treat-
 ment Wastewater Discharge

Biological Oxygen Demand - A minimum removal  of 90%,  according  to
the Coastal  Zone Commission.  Depending upon the initial concentration,
the following EPA requirement may govern:

     (1)  The arthmetic mean of the values for effluent samples collected
          in a period of 30 consecutive days shall  not exceed 30  milli-
          grams per liter.

     (2)  The arthmetic mean of the values for effluent samples collected
          in a period of seven consecutive days  shall  not exceed  45
          milligrams per liter.

Suspended Solids - According to  the EPA:

     (1)  The arthmetic mean of the values for effluent samples collec-
          ted in a period of 30 consecutive days  shall  not exceed 30
          milligrams per liter.

     (2)  The arthmetic mean of the values for effluent samples collec-
          ted in a period of seven consecutive days shall not exceed
          45 milligrams per liter.

     (3)  The arthmetic mean of  the values for effluent samples collec-
          ted in a period of 30  consecutive days  shall  not exceed 15%
          of the arthmetic mean  of the  values  for influent samples col-
          lected at approximately the same times  during the same  period
          (85% removal).
                              1-10

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2.   Solids Handling

The anaerobic digestion at the plant is not adequate because of the limited
capacity and the poor condition of the equipment.  Thus, when the sludge
is pumped into "drying lagoons," it is still putrescent.  Odors and insects
result, and leaching or runoff of pollutants is possible.

3.   Ocean Outfall

The Laguna Beach ocean outfall violates the State Water Resources Control
Board Water Quality Control Plan, Ocean Maters of California adopted on
July 6, 1972.  The existing outfall is too short (3,200 feet), and terminates
in too shallow a depth of water (80 feet).  It not only violated the required
dilution ratio of 100/1, but also endangers the health of bathers at the
Main Street Beach.  During a typical  adverse current, "with the current
direction being inshore during the day, the minimum time of travel  into
the area of intensive recreational  use of a float released 2,450 feet off
Laguna Beach would be about 1.3 hours." Ocean beaches and waters in the
area are heavily used for water contact sports activities, as well  as both
commercial and sport fishing.  Effluent discharge also presents a potential
threat to marine biological resources and preserves within 2,000 feet of
the outfal 1.

The Laguna Beach outfall is also located within approximately 2,000 feet
of the Heisler Park Ecological Reserve, an area of Special Biological  Signifi-
cance.  The Department of Fish and Game is concerned about potentially toxic
levels of chlorine and the attendant impact on the reserve.

4.   Effluent Qualtiy

The quality of the Laguna Beach effluent was shown earlier in Table 1-2.
It can be seen that this effluent is  not satisfactory, and must be  improved
considerably to meet secondary treatment standards.  The Laguna Beach plant
violates even its less stringent primary requirements for both suspended
solids and coliform.  The ongoing modifications may improve the effluent
some, but the treatment plant is over its hydraulic capacity during seasonal
peaks, and thus cannot operate properly.

1.3.3  El Toro Water District

The Rossmoor Sanitation Inc.  treatment plant,  which serves the El  Toro
Water District, has been having trouble disposing of their effluent.   Four
different customers use Rossmoor's  effluent, but not on a year-round  basis.
Demand for irrigation water is very low during the winter months,  and Rossmoor
must store most of the effluent.  Operational  problems,  both in the treatment
system and in the reclamation systems have allowed treated effluent to get
into the stream course in the past.   This represents a minor source of nutrient
inflow to Newport Bay, and a  potential  health  hazard to recreationists using
the stream or Bay who may be  exposed  to sewage borne pathogens.   The  Rossmoor
treatment plant effluent does not currently meet the sulfate and boron incremen
tal limitations which are required  in their NPDES permit to protect the
groundwater (SWRCB,  1975).
                                  1-11

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1.3.4  Los Allsos Mater District

No serious problems now exist in the Los Alisos system.  However, like
Rossmoor, they anticipate problems with storage as their service area grows
or if neighboring Irvine Ranch, which uses their effluent, undergoes devel-
opment.

Salinity requirements have been added to the discharge requirements for
LAWD.  These requirements will not take full effect until  1977,  but unless
the area obtains a water supply with fewer salts, the effluent will violate
these requirements.  LAWD is currently in violation of the incremental  limita-
tions for dissolved chloride and sulfate as established in the NPDES permit
(Appendix C).

1.3.5  Moulton-Niguel Water District

The Moulton-Niguel Water District, Improvement Districts Nos.  1A and 2A
both produce an effluent which is usually of acceptable quality.   Although
not hydraulically or organically overloaded, these plants  are  restricted
in operational  flexibility by their basic design, which is the rapid block
process.  It is doubtful  that the quality of either plant  could  be signifi-
cantly improved through operational changes, as each is operated correctly
and according to the basic design criteria.
                                  1-12

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2.0  DESCRIPTION OF EXISTING ENVIRONMENT

2.1  GEOGRAPHIC SETTING

2.1.1   Introduction

The Aliso Water Management Agency service area lies on the Pacific Slope of
Southern California (see Exhibit 1.1) and comprises 48,905 acres in the
south-central portion of Orange County (see Exhibit 1.2).  The Agency has a
frontage of approximately 15 miles along the coastal area between Corona del
Mar and Dana Point and extends northeasterly inland approximately fifteen
miles to the northeasterly limits of the Los Alisos Water District (see Ex-
hibit 1.3).  The area is easily accessible by way of the San Diego Freeway
(Interstate 5) which traverses the northerly portion of the area.  In addi-
tion, the Pacific Coast Highway (California Route 1) runs along the southerly
limits of the area adjacent to the Pacific Coast.  The facilities of the
Atcheson, Topeka & Santa Fe Railroad, running between Los Angeles and San
Diego, pass through the area following the approximate alignment of the San
Diego Freeway.  The El Toro Marine Corps Air Station lies one mile westerly
of AWMA and is adjacent to El Toro and Los Alisos Water Districts.

The Aliso Water Management Agency is divided into eight separate watershed
areas.  Table 2-1 indicates watershed acreage, percent of total watershed
area, and percent of the AWMA area.

                                  TABLE 2-1

                     Watershed Systems of the AWMA Area

      Name of           Number            Percent of             Percent
     Watershed         of Acres        Total  Watershed          of AWMA

Aliso Creek             19,995                87%                40.8
Irvine Ranch Coastal
  Area                   8,700                -                 17.8
San Diego Creek          6,500                 7%                13.3
Laguna Canyon            5,800               100%                11.8
Salt Creek               4,450                98%                 9.1
Laguna Beach             2,150                 -                  4.4
South Laguna Beach         850                 -                  1.7
San Juan Creek             500                 0.4%               1.0

                        48,905                                  100.0


The major portion (over 40%)  of the  AWMA service area  drains into the Aliso
Creek which traverses  the Study Area in a southwesterly direction from the
northerly boundary of the Los Alisos Water District.   Smaller portions of
the AWMA service area  fall  within  the watershed systems of San Diego  Creek,
Laguna Canyon, Salt Creek and San  Juan Creek.   The Irvine Ranch Coastal,
Laguna Beach and South Laguna Beach  drainage  areas each represent a series of
sub-watershed zones draining  directly to the  ocean from the first west-east
n'dgeline.


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 Although  the  major  portion of  the AWMA service area is generally moderately
 hilly,  the  study  area may be divided  into  three major topographic areas:

      1.   The coastal zone with alluvial fans and terraces.  Much of the
          population resides within this narrow band and is represented by
          the communities of Emerald  Bay,  City of Laguna Beach, South Laguna
          Beach,  and Laguna Miguel.

      2.   Stream  valleys and flood plains, which include AlisOj San Diego,
          Laguna  and Salt Creeks, and other smaller tributaries.

      3.   Hilly region of the  coastal and  Santa Ana Mountain Foothills, with
          extremely rough terrain found in the Irvine Ranch Coastal area,
          Laguna  Canyon and lower Aliso Canyon.

 The remainder of  this section  and Section  2.1.5 Hydrology describes each of
 the watershed areas in some detail.

 2.1.2  Aliso  Creek Watershed

 The Aliso Creek Watershed System lies entirely within the south central por-
 tion of Orange County.  Aliso  Creek originates in the lower slopes of the
 Santa Ana Mountains, and flows in a southwesterly direction for approximately
 20 miles to the Pacific Ocean, just south of Laguna Beach.   The stream drains
 an area of approximately 23,000 acres within Orange County and is bounded on
 the northeast by  hilly coastal uplands and on the southeast and northwest by
 rolling coastal uplands.  Land forms range in elevation from sea level to
 about 2,300 feet  above mean sea level in the Santa Ana Mountains.  Stream
 gradients range from an average of about 25 feet per mile upstream of the
 ocean to about 125 feet per mile near the source of the creek.  The stream is
 well defined  and  contains short reaches of channel  improvements.  Vegetation
 in the watershed  varies considerably.  In the higher regions there is dense
 growth of chaparral, scattered brush and grasses while in the lowlands
 coastal sage  and  grasses predominate.

 Aliso Creek has three major tributaries:   Wood Canyon (2,752 acres) and
 Sulphur Creek  (5,952 acres) in the lower watershed and English Canyon (1,792
 acres) in the upper watershed.

 Runoff in the basin is very erratic with almost no flow for many months at
 a time.  Climate and watershed area characteristics are not conducive to
 continuous flow; therefore, little streamflow occurs except during and
 immediately following rains.   Runoff increases rapidly in response to rain-
 fall excess.

 2.1.3  Irvine Ranch Coastal  Area

 The Irvine Ranch Coastal  Area represents  a series  of north-south trending
 canyons originating on the San Joaquin Ridgeline and all  individually
 draining into the Pacific Ocean.   This area extends  along the coast from
 the city limits of Corona del  Mar to the western city limits of the City
of Laguna Beach.  The total  drainage area represents over 8,700 acres  and
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 ranges  in  elevation  from' sea  level  to about  1,000 feet above mean sea level
 along the  San  Joaquin  Ridge.   Vegetation  is  represented primarily by coastal
 sage  scrub and chaparral, with  grass cover near the coast.

 The major  canyons  include:  Buck Gully, Los  Trancos, Muddy, Moro and Emerald
 Canyon.  Water flow  in  the  canyons  is ephemeral and runoff increases rapidly
 in response to excessive  rainfall.

 2.1.4  San Diego Creek  Watershed

 Only  7% of the 96,000 acre  San  Diego Creek Watershed lies within the AWMA
 service area.   The total  drainage area is bounded on the northeast by hilly
 coastal uplands (within AWMA),  on the southeast and southwest by rolling to
 steep coastal  uplands  (within AWMA), and  on  the west by level alluvium.  The
 entire watershed area ranges  in elevation from sea level at Newport Bay, to
 about 1,700 feet above  mean sea level in  the Santa Ana Mountain foothills.
 The stream gradients in the AWMA area reach  25 feet per mile.  The stream
 channel is  well defined over  its entire length.  Vegetation in the AWMA area
 is represented by a  dense growth of coastal  sage scrub, chaparral, scattered
 brush and  grasses in the northern portion and urbanized landscaping and
 eucalyptus  rows in the  south.   Citrus tree development has occurred exten-
 sively  in  the  Serrano Creek watershed north  of Trabuco Road.

 The major  tributary  to  San  Diego Creek in the AWMA area is Serrano Creek
 which comprises almost  50%  (about 3,200 acres) of this portion of the water-
 shed.   In  addition,  San Diego Creek makes its origin near the intersection of
 Trabuco Road and El  Toro Road,  making up  the remaining 3,200 acres.

 Runoff from the watershed is  very erratic with almost no flow for many months
 at a  time.  Climatic and drainage area characteristics are not conducive to
 continuous  flow, therefore streamflow occurs during and immediately follow-
 ing rains.  Runoff increases  rapidly in response to rainfall excess.

 Until  recently, percolation to  the creek  from the Rossmoor Treatment Plant
 spray-irrigation disposal  maintained some flow in the portion of the creek
 just  downstream of the plant.  Spraying has  recently been abandoned due to
 the potential  pollution of Upper Newport Bay.

 2.1.5  Laguna  Canyon Watershed
       Canyon, from its headwaters in the San Joaquin Hills to the mouth of
the Pacific Ocean, drains an area of some 5,800 acres.  The entire watershed
area lies within AWMA and is bounded by the rolling hills of the San Diego
Creek watershed to the north.,  the steep canyons of the Aliso Creek water-
shed to the east, the rough and steep terrain Irvine Ranch Coastal area to
the west and the Pacific Ocean to the south.

The watershed (see plate 1) is oriented with its long axis roughly north,
about 6 miles in length and averages about 1.4 miles in width.  The highest
elevation in the basin is 1,063 feet.  About 80 percent of the area in the
basin consists of rugged hills:  the remainder consists of. well-defined
canyon floor and the coastal plain.   Vegetation in the watershed varies
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 considerably.  In the higher regions there is a dense growth of chaparral,
 scattered brush and grasses while in the lowlands coastal  sage and grasses
 predominate.  Laguna Canyon also contains several endangered plant species
 and the unique marsh habitat of the Laguna Lakes.

 The total fall of Laguna Canyon from its headwaters to the ocean is 450 feet,
.with an average fall of 67 feet per mile.

 The only significant tributary to Laguna Canyon is the East Fork of Laguna
 Canyon (about 2 000 acres) located along El  Toro Road.

 As with most other creeks in Orange County,  runoff in Laguna Creek is  very
 erratic.   Existing flood control  facilities  consist of a shallow lagoon in
 the uppermost reach of the watershed and an  improved channel in the lower
 reaches which extends for 2 miles to the Pacific Ocean.   Urban runoff  in this
 channel maintains somewhat a flow of water during the dry season.

 2.1.6  Salt Creek Watershed

 The Salt Creek Watershed area located in the southeast portion of the  AWMA
 service area consists of approximately 4,550 acres, roughly bounded on the
 west and northwest by the Miguel  Hills, on the east and  southeast by the ridge
 of Salt Creek and Trabuco/San Juan Creek watersheds, and on the south  by the
 Pacific Ocean between Dana Point  and Monarch Bay.  Only  a  small  portion of
 the watershed in  its southeastern corner lies outside the  AWMA area.  For
 the most part, the drainage area  is defined  by natural  ridgelines  which clearly
. form major watershed boundaries.

 The topography of the area is dominated by rolling hills,  with hillsides
 varying from mode"rate inclines to 50+ percent slopes, and  several  stream
 courses interlacing the area.  Elevations range from sea level  to  936  feet
 atop Niguel  Hill  and 700 feet along the Trabuco-San Juan Watershed divide.
 Vegetation is comprised primarily of overgrazed grassland  with  only remnants
 of the coastal sage community east of Arroyo Salada.

 The Salt  Creek Watershed consists of several  branch tributary  streams,  in-
 cluding Arroyo Salada and San Juan Canyon (not the San Juan Creek  located
 adjacent  to San Juan Capistrano).  About 50% of the Laguna Niguel  drainage
 area ultimately drains  into Salt  Creek.   The total  length  of the main  Salt
 Creek  Stream is about four miles.

 The Salt  Creek Watershed is the smallest watershed system  in the AWMA
 service area.   Runoff characteristics  are similar to other watersheds  of the
 area,-except that this  drainage system will  probably display even  more
 erratic patterns  of flow and  is dryer for longer periods throughout the year.
 Salt Creek and San  Juan  Canyon  are well  defined water courses, with relatively
 steep  canyon sides.
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2.1.7  Laguna Beach and South Laguna Beach Watersheds

The Laguna Beach and South Laguna Beach Watersheds represent about 6% of
the AWMA  service area.  Their combined 3,000 acre drainage area is very
similar to the  Irvine Ranch Coastal Watershed with the exception that ex-
tensive residential growth has occurred along the coast and into the hills
above the communities of Laguna Beach and South Laguna.  Elevations reach
up to 900 feet  on the ridgelines separating these drainage areas from Aliso
Creek and Laguna Canyon Watershed Systems.

2.1.8  San Juan Creek Watershed

Although  the San Juan Creek Watershed comprises over 110,000 acres in South-
eastern Orange  County, only 500 acres or 0.4% is represented in the AWMA
service area.   Most of the terrain is sloping hillside east of the Salt Creek
Ridge!ine divide.  Elevations extend from 600 feet atop the ridge down to
about 250 feet.  No defined tributary system exists; only a series of easterly
trending gullies cut the broad slope.  The entire area is covered with annual
grasses.

2.2  TOPOGRAPHY

The general  topographic features of the Aliso Water Management Agency were
described in Section 2.1, Geographic Setting.   This section summarizes an
analysis of the slope characteristics for each watershed and their relation-
ship to future  urbanization.   The analysis is  based on information derived
from the North American Rockwell Natural  Resources Study prepared for the
County of Orange and soils data supplied by the U.S.  Soil  Conservation Ser-
vice, Orange County.

Table 2-2 describes the slope analysis breakdown for the AWMA area.   About
57% of the area represents slopes over 31% in  grade and can generally be
classified as undevelopable.   11% of the AWMA  area is represented by slopes of
16 to 30% and could be developed, but with some difficulty.  Only 32% of the
AWMA region  has slopes in the 0 to 15% range,  which could be easily developed;
however, most of these lowland areas have already been urbanized.   Develop-
ment in these areas will  be discussed in  more  detail  in Sections  2.11,  Land
Use and 4.0,  Secondary Impacts.

Based upon the above topographic analysis, future urbanization  in  the AWMA
region will  probably fill  the remaining low lying areas with higher  densities
and develop  the foothills (16 to 30% slopes) with low density and  clustered
units.   The  vast majority of  the area will  remain in  natural  open  space.
Additional development constraints  (to be discussed in the  following  section
of this chapter),  such as geologic  faults, landslides,  flood plains,  sensi-
tive  ecologic areas,  etc.,  will  probably  demand that  more  than  75%  of the AWMA
region be  left in  natural  open space.
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                                  TABLE 2-2
                          SLOPE ANALYSIS BREAKDOWN
                              FOR THE AWMA AREA
Name of Watershed

Aliso Creek Watershed
Irvine Ranch Coastal
Laguna Beach
Laguna Canyon
Salt Creek Watershed
San Diego Creek Watershed
San Juan Creek Watershed
South Laguna Beach

Total Figures for Water-
shed Systems of AWMA Area
                                0-15%
                                Slope
        % of
 Acres  Area
 5,987
 1,044
 1,505
 1,160
 1,558
 4,225
30%
12%
70%
20%
35%
65%
   510   60%
                   16-30%
                    Slope
Acres

2,993
  696

  290

1,300
% of
Area

 15%
  8%

  5%

 20%
                           +31%
                          Slope
                                 Total
                                 Acres
                       Acres  Watershed
10,975
6,960
645
4,350
2,892
975
500
340
55%
80%
30%
75%
65%
15%
100%
40%
19,
 8,
 2,
 5,
 4,
 6,
955
700
150
800
450
500
500
850
15.989   32%    5,279    11%    27.637    57%    48.905
2.3  GEOLOGY

2.3.1  General
The AWMA region lies in the southeastern part of Orange County.   It is also the
most southeasterly portion of the large geologic province known  as the Los
Angeles Basin.  The rock formations found within this area were  deposited in a
trough called the Capistrano Embayment.  There have been many periods of sub-
mergence when fairly thick marine sediments accumulated.  These  periods were
followed by slow uplifts which resulted in the deposition of nearshore sedi-
ments and finally continental deposits, with erosional  features  being developed
on the uplifted surface.  The probable basement rock in this locale is the
crystalline plutonic complex that is exposed in the higher parts of the Santa
Ana Mountains.  This complex is not exposed within the area of study.

2.3.2  Topography

Topographically, the area can be divided into three provinces.  Along the
northerly boundary there is a narrow band of low, rounded hills.  These are
the outer expression of the foothills of the Santa Ana Mountains.   South of
these hills lies a portion of  theElToro Plain which has been formed by the
outwash material from the mountains.  By far the largest portion is the re-
mainder  which is made up of rather steep-sided hills and well-eroded valleys
of the San Joaquin Hills.  The soil mantel on the hills is normally very thin,
but some of the large valleys can have up to 200 feet of soil deposited within
them.  This  topography continues to the ocean, which is the southerly boundary
of the area.
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2.3.3  Stratigraphic Description

There are numerous geologic formations exposed within the boundaries of the
agency.  These have been mapped by California Divison of Mines and Geology
and appear  in their 1973 Report Number 15.  By far the greater percentage
consists of rather weakly cemented marine deposits which may have small areas
of more resistant rocks incorporated within them.  The oldest formation that
has been mapped is a medium- to coarse-grained sandstone and grit  that con-
tains stringers of conglomerate and clay.  This has been named the Silverado
Formation and is dated geologically in the Paleocene Epoch.  There are only
minor outcrops of this rock, chiefly in the western section making up about
1% of the AWMA area.  This formation has been mined extensively in the Santa
Ana Mountain foothills.

In ascending order the next series of rocks is the Vaqueros-Sespe Formations,
which make  up about 7% of the AWMA area.  These consist of beds of buff, red,
white, or green sandstones and gritty conglomerates.  In places these beds
become very well cemented, forming the steeper cliffs seen along Laguna Can-
yon Road, especially in the area north of the El  Toro Road intersection.
These two formations are extremely similar, lithologically, and are often
mapped together as Vaqueros-Sespe, undifferentiated.   The Sespe is somewhat
older, having started in the Upper Eocene Epoch,  continuing perhaps through
the Oligocene, and terminating in the Lower Miocene Epoch.  The Vaqueros
has been placed in the Upper Oligocene and Lower Miocene by some workers.
There has been some intrusion of diabasic and andesitic igneous dikes and
sills into  these formations.  These intrusions are located west of Laguna
Canyon Road.  Both of these formations are easily excavated and serve as
good fill  material.

Next in the sequence of rocks is the Topanga Formation, representing over 25%
of the AWMA area, primarily in the San Joaquin Hills.   The formation is fairly
widespread north of the City of Laguna Beach and  also outcrops along the nor-
therly boundary of the agency.   Like the Vaqueros-Sespe, it contains well
cemented horizons on the east side of Laguna Canyon below the El  Toro Road
intersection and the cave areas in Temple Hills.   It  is composed of medium-
to coarse-grain sandstones and grit,  with some rather extensive conglomerate
beds.   Incorporated within this unit are some welded-tuff volcanic ash beds
which are very resistant to erosion.   Generally,  this  formation is found north
of the City of Laguna Beach, between  Laguna Canyon and Aliso Creek.   The
Topanga has been placed in the Middle Miocene Epoch.   The Topanga  Formation
would require hard continuous heavy duty ripping  and  probable moderate blast-
ing in sandstone.  It serves as poor to fair fill  material, depending on the
percentage of large blocks derived from ripping and/or blasting.

The next formation to be noted is  the well  known,  but controversial  Middle
Miocene Epoch San Onofre Breccia,  which makes up  about 5% of the AWMA area,
and occurs primarily in the south  coastal  area.   Lithologically,  this unit
varies from a very coarse earthy breccia containing rocks up to 10 feet or
more in size, to fine weak sandstones,  and  even lenses of fine-grained dia-
tomaceous  shales and silts.   These variations can  take place in remarkably
short lateral or vertical  distances.   The coarse  breccia phase is  believed
to have been formed  by submarine lands!iding or the sliding of continental
(land formed) deposits  into an  existing marine environment.   The  rocks making
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 up  the  breccia are  glaucophane schists of the Catalina type, and obviously came
 from the west.   In  some areas, the breccias are generally well cemented and
 form the prominent  sea bluff south of Laguna Beach and at Dana Point.  Some
 of  the  cementing may be attributed to highly siliceous submarine volcanic
 emanations  that may have been occurring during the depositional period of the
 breccias.   This formation is generally located near the mouth of Aliso Creek
 south to Dana Point.  Smaller outcrops are noted further inland, and recent
 work  indicates that this unit may be more widespread than previously thought.

 At  places,  interbedded with the San Onofre Breccia is the next unit of the
 geologic column.  It has been named Monterey Shale and consists of beds of
 diatomite, sandy silts, sandstones, and limestones.  The limestones are highly
 fossiliferous in some localities, containing pectens, clams, and bryozoans.
 The main outcrops of Monterey Shale are found west of Aliso Creek, extending
 westerly and northerly of the area of El Toro Road.  Some of the silty shales
 are highly  diatomaceous and very light weight.  Small outcrops are found along
 the northern boundary, and at places on the Tustin Plain where a limestone
 phase is found just under the soil surface.  Monterey Shale is placed in
 the Middle  Miocene  Epoch.

 Above the Monterey  Shale lie two formations which are similar in lithology.
 These are the Pliocene sediments named the Capistrano and Miguel Formations.
 They are fine-grained interbedded silts and sands, with lenses of conglomer-
 ate occurring occasionally.   The Capistrano has a fairly well-defined zone
 of limestone concretions near the base.   In the northern portion of the area,
 the predominate outcrops are of the Oso Member of the Capistrano Formation.
 This consists of a  poorly cemented white- to light-grey sand of remarkably
 even size.   This sand is highly susceptible to erosion and is forming a bad-
 land type of topography at various places.   The Pliocene Miguel  Formation has
 fairly coarse conglomerates  within it, which help in distinguishing it from
 the Capistrano.   These two formations are found primarily in the rolling area
 east of the middle  reaches of Aliso Creek in the central  area, Salt Creek
 in the southern  area,  and Trabuco Creek on  the east.   They also outcrop ex-
 tensively in the northeast portion of the agency.   Here the silty shales are
 interbedded with  the sands of the Oso Member.   Some of the dark green shales
are well indurated where they have not been weathered.

The Monterey, Miguel,  and Capistrano Formations, combined, make up about 42%
of the AWMA region,  primarily in the eastern half of the area.  All  of these
bedrock units are readily excavated.   They  all  also represent fair to good fill
material; however,  Monterey  and Capistrano  material  may require some special
compaction  effort.   Landsliding,  erosion and expansive top soils are also
characteristic of these bedrock units.

Occurring particularly along the present coastline, and otherwise generally
scattered throughout the area,  are the youngest of the  geologic  units.  These
are identified as the  Quaternary (Pleistocene)  terrace deposits.   There are
three types of deposits here.   The first is marine terrace material  which
represents  a beach  type of deposit with  perhaps  some lagoonal  deposits inter-
bedded.   These were  deposited on  wavecut terraces,  indicative  of periods when
the sea level was higher than at the present time.   The second type  of terrace
is found further  inland.   They  represent what  originally  was old depositional
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surfaces of the outwash fans from the mountains.  Subsequent regional uplift
or tilting has given rise to greater velocities in the existing streams, thus
allowing the streams to cut down into the deposits, leaving these stream
terraces perched above the present stream beds or capping the mesas between
drainage courses.  The third type of terrace is found near the present coast
and  is formed of a combination of marine terrace material and colluvium or
outwash material from the adjacent hills.  All of these terraces consist of
beds of rounded cobbles and pebbles, coarse sands, and reddish, earthy ma-
terial.  Some beds have been slightly tilted or deformed, indicating that they
have been in existence since the Lower Pleistocene Epoch.

Recent alluvium is found in most of the creekbeds excepting the steep upper
reaches and depths from 20 to 100 feet.   The alluvium consists of gravel,
sand and loam which were washed from the valley walls and accumulated in the
streambeds.

Terrace and alluvial units make up about 20% of the AWMA region and are
easily excavated.  Some alluvial deposits may be good sources of sand and
gravel, but none reach the proportions of those found in Arroyo Trabuco or
San Juan Canyon.

2.3.4  Geologic Processes

Stream and marine wave erosion during the Pleistocene Epoch cut into under-
lying bedrock.  Subsequently, sporadic uplift combined with a gradual  world-
wide lowering of sea level resulting in  the elevation of these surfaces above
the level  of active erosion and their preservation to the present day.

Beginning about 15,000 years ago, sea level  began to rise again.   Aliso,
Arroyo Trabuco and San Juan Creeks formed broad, alluviated valleys that cut
several hundred feet deep in the sedimentary bedrock of the surrounding,
steep-sided, rounded hills.

Continental  and marine terrace deposition took place during the Pleistocene
Epoch and consist of silt, sand, gravel  and  rubble.   Terrace deposits  are
stream, marine and non-marine cover in origin.

Extensive  terrace deposits are found parallel  and adjacent to the coast.
Smaller erosional remnants of the terrace deposits are scattered at higher
elevations  throughout the hills of the AWMA  region.

Outside of the flood plain areas, erosion has  been the dominant geologic
force acting in the past few thousand years.   The uplifted,  relatively  weak
sedimentary bedrock of the Monterey and  Capistrano Formations  has been  in-
cised by intermittent streams,  forming small  steep-sided valleys.   The
characteristically rounded hills are the result of erosion and a  combina-
tion of climatic and geologic factors.

Significant in the geomorphic process has been the generally deeply weathered
and moderately to highly fractured nature of the bedrock in  the eastern  por-
tion of the AWMA area.   Even where fresh, the  bedrock typically possesses
rather poor strength characteristics.   It is  the weak physical  state of the
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of  the bedrock in combination with infrequent intense rainstorms that saturate
the bedrock and raise groundwater levels that cause the majority of the bed-
rock  landslides in the area.  Structural features of the bedrock, particularly
bedding, jointing and shear zones, undoubtedly contribute to the potential
for slope  failure in some areas.  Wherever planar surfaces in the bedrock
(such as bedding) are inclined in an unsupported manner out-of-slope, a
natural surface of potential failure exists.

2.3.5  Mass Movements

Many  of the landslides present in the AWMA region are probably quite ancient,
dating back several thousand years.  They probably occurred during a more
humid period or periods when sea level was lower and local streams were
actively .downcutting their channels.  These older slides present a subdued
hummocky topography in contrast to more recent slides where bedrock is fre-
quently exposed in paged scraps and where the topography is more blocky and
irregular.

Relatively few landslides or suspected landslides in the general area have
been  investigated in detail, but it does appear that many of the older slides
have  not moved in many years and have become naturally stabilized.  Those
which have been investigated in detail were confirmed to be landslides or were
shown to be erosionally related features.

Landsliding in the area is due primarily to faulting and secondarily to over-
steepening caused by erosion of the arroyos.  All other landslide areas are
superficial slumps or creep zones.

2.3.6  Structure

Not unlike the rest of the Pacific Coast, this area has been subjected to
considerable tectonic stress and strain.  A detailed mapping of this area
appears in Report 15 Geologic (1973) by California Division of Mines and
Geology.   This is particularly noted in the area to the west of Laguna
Canyon, where a complex of northwesterly trending faults have been mapped
in the older rocks.   The Pelican Hill and Shady Canyon Fault Zones originate
in this area.   In the younger rocks to the east the tectonic forces are ex-
pressed by more or less gentle folding and warping.   These fault zones pro-
bably limit the development over about 5% of the AWMA area, primarily in the
southwestern area.  The area north  of the San Diego Freeway is devoid of
faults.   There are undoubtedly faults in the eastern portion that have been
obscured due to the relative incompetency of the sediments.  There is a
regional  system of rather steeply dipping jointing in the younger rocks.
This accounts  for the "blocky" appearance of material  on some erosional
surfaces.   In  many cases, these joints have been filled with deposits of
gypsum or calcite by water percolating through the formations.

Although  presently there are no obvious zones of seismic activity within
thejuagency area,  there are surrounding zones which have been, active in re-
cent: time.   The most important of these is the Newport-Inglewood zone of
deformation to the southwest.   Movement along this point is believed to  have
beerti responsible  for the earthquake of 1933.   This quake caused considerable
                                  2-10

-------
 property  damage  throughout  Long  Beach,  Compton,  and western  Orange  County,
 as  well as  more  than  100  deaths.   The partial  destruction of the  San  Juan
 Capistrano  Mission  in 1812  has been  attributed to  movement on the Christian!to?
 Fault,  located to the northeast  of AWMA.   Since  this  event occurred long before
 the advent  of scientific  instruments to properly locate and  record  seismic
 disturbances, it is conjectural  that the  Christianitos was responsible and
 this fault  has been considered to  be inactive.   However, in  January,  1975, tv/o
 small earthquakes were  recorded  which are  believed to have originated on the
 Christianitos Fault near  Trabuco Canyon.   The  epicenters were  not precisely
 located,  but  they were  estimated to  have  been  at a depth of  3  and 4^ miles
 with magnitudes  of  3.8  and  3.3 on  the Richter  Scale,  respectively.  No sur-
 face disturbance has  been discovered, although the earthquakes were of suf-
 ficient strength to have  caused  visual surface evidence.  The  Christianitos
 Fault can now be considered potentially active.

 Groundshaking may also  be initiated by seismic and fault activity outside of
 the southern  Orange County  region.  The Elsinore,  Whittier,  San Jacinto, and
 San Andreas Faults have in  the past, and probably will in the  future, impact
 the AWMA area.   Table 2-3 describes the potential  effect of  these faults
 on  the geologic  units of  the AWMA  region.  The Table also gives the average
 distance of each fault  from the AWMA area  and  Exhibit 2-1 indicates the loca-
 tion of each  fault.

 2.3.7  Mineral Resources

 The geology exhibited within the boundaries of the Aliso Water Management
 Agency is fairly typical of the coastal  areas of Southern California.   Eco-
 nomically, the only resource being obtained within the boundary at the present
 time  is sand  and gravel (Site 128 on California  Division of Mines and Geology
 Report Number 15, 1973).  Many of the major oil companies have done extensive
 studies in the area, but have failed to bring in any producing wells.   Com-
 mercial clay  deposits occur just north of  the area and may also occur within
 the boundary.  The State of California Division of Mines and  Geology Report No
 15,  1973, indicates additional  areas containing mineral  resources, primarily
 within the Moulton Ranch Planning Reserve.  These are:

     Site Number 43 - Diatomite Deposits
     Site Number 62 - Lime Deposits - mined before 1953
     Site Number 73 - Phosphate Beds
     Site Number 93 - Borrow Site

 2.3.8  Geologic  Constraints

 Table 2-4 summarizes the geologic constraints  on  urbanization in  the AWMA
 area.  These figures are only approximations  and  may  be  inaccurate to  15%.

Approximately 401^ of the AWMA  area will  be limited to urbanization  by geo-
 logic constraints.   This represents about  19,502  acres,  primarily  occurring  in
 the San Joaquin  Hills to the north  and  the Laguna HiTls  to  the south.
                                  2-11

-------
TABLE  2-3
MAXIMUM PROBABLE EARTHQUAKES AND SEISMIC SHAKING CHARACTERISTICS
Important
Regional
Faults
Cristianitos
Newport-
Inglewood
Elsinore
Whittier
San Jacinto
San Andreas
Approximate
Distance to
AWMA
(miles)
3-4
to
Newport Bay
20±
53*
Maximum
Magnitude
(Richter)
of
Historic
Earthquakes
Maximum
Probable
Earthquake
Magnitude
(Richter)
Considered
to be poten-
tially active
6.3 6.6
(1933)
5.5 7.2
(1938)
3.2 6.8
(1971)
7.1 7.5
(1940)
(Seven quakes
of M greater
than 6.0 since
1918)
6.5 7.7
(1948)
Estimated (1)
Maximum
Base Rock
Acceleration
(g)
0.21
0.24
0.21
0.14
0.10
Estimated (2)
Maximum
Ground
Acceleration
(g)
0.35
0.40
0.30
0.20
0.20
Predominant (3)
Period of
Base Rock
Motion
(Seconds)
0.3
0.35
0.3
0.4
0.5
Probable
Duration
Strong
Shaking
(Seconds)
19
30
22
40
46
(4)
of
-
 (1)  Schnable and Seed, 1972
 (2)  Matthiesen, et al, 1972
 (3)  Seed, et al, 1969
 (4)  Geological Survey Circular 672, 1972

-------
 property  damage  throughout  Long  Beach,  Compton,  and western Orange  County,
 as  well as  more  than  100  deaths.   The partial  destruction of  the  San Juan
 Capistrano  Mission  in 1812  has been  attributed to movement on the Christianitos
 Fault,  located to the northeast  of AWMA.   Since  this event occurred long before
 the advent  of scientific  instruments to properly locate and record  seismic
 disturbances, it is conjectural  that the  Christianitos was responsible and
 this  fault  has been considered to  be inactive.   However, in January, 1975, two
 small earthquakes were  recorded  which are  believed to have originated on the
 Christianitos Fault near  Trabuco Canyon.   The  epicenters were not precisely
 located,  but  they were  estimated to have  been  at a depth of 3 and 4^ miles
 with  magnitudes  of 3.8  and  3.3 on  the Richter  Scale, respectively.  No sur-
 face  disturbance has  been discovered, although the earthquakes were of suf-
 ficient strength to have  caused  visual surface evidence.  The Christianitos
 Fault can now be considered potentially active.

 Groundshaking may also  be initiated by seismic and fault activity outside of
 the southern  Orange County  region.  The Elsinore, Whittier, San Jacinto, and
 San Andreas Faults have in  the past, and probably will in the future, impact
 the AWMA area.   Table 2-3 describes the potential effect of these faults
 on  the geologic  units of  the AWMA  region.   The Table also gives the average
 distance of each fault  from the AWMA area and  Exhibit 2-1 indicates the loca-
 tion of each  fault.

 2.3.7  Mineral Resources

 The geology exhibited within the boundaries of the Aliso Water Management
 Agency is fairly typical of the coastal  areas of Southern California.  Eco-
 nomically, the only resource being obtained within the boundary at the present
 time is sand  and gravel (Site 128 on California  Division of Mines and Geology
 Report Number 15, 1973).  Many of the major oil companies have done extensive
 studies in the area,  but have failed to bring in any producing wells.   Com-
 mercial clay  deposits occur just north of the area and may also occur within
 the boundary.  The State of California Division of Mines and  Geology Report No
 15, 1973, indicates  additional  areas containing mineral  resources, primarily
 within the Moulton Ranch Planning Reserve.  These are:

     Site Number 43  - Diatomite Deposits
     Site Number 62  - Lime Deposits - mined before 1953
     Site Number 73  - Phosphate Beds
     Site Number 93  - Borrow Site

 2.3.8  Geologic  Constraints

Table 2-4 summarizes the geologic constraints on  urbanization  in  the AWMA
area.  These figures are only approximations  and  may  be  inaccurate to  15%.

Approximately 40%+ of the AWMA  area will be limited  to urbanization  by  geo-
 logic constraints.   This represents about  19,502  acres,  primarily  occurring in
the San Joaquin  Hills  to the north  and  the Laguna Hills  to  the south.
                                  2-11

-------
TABLE  2-3
MAXIMUM PROBABLE EARTHQUAKES  AND SEISMIC  SHAKING CHARACTERISTICS
Important
Regional
Faults
Cristianitos


Newport-
Ingle wood

Elsinqre

Whittier

San Jacinto



Approximate
Distance to
AWMA
(miles)
3-4


17-
to
Newport Bay
20-

21*

43-



Maximum
Magnitude
(Ri enter)
of
Historic
Earthquakes
Considered
to be poten-
tially, active
6.3
(1933)

5.5
(1938)
3.2
(1971)
7.1
(1940)
(Seven quakes
of M greater
Maximum
Probable
Earthquake
Magnitude
(Richter)



6.6
- 	

7.2

6.8

7.5



Estimated (1)
Maximum
Base Rock
Acceleration
(g)



0.21


0.24

0.21

0.14



Estimated (2)
Maximum
Ground
Acceleration
(g)



0.35


0.40

0.30

0.20



Predominant (3)
Period of
Base Rock
Motion
(Seconds)



0.3


0.35

0.3

0.4



Probable (4)
Duration of
Strong
Shaking
(Seconds)



19


30

22

40



than 6.0 since

San Andreas


53±

1918)
6.5
(1948)

7.7


0.10


0.20


0.5


46

(1)  Schnable and Seed, 1972
(2)  Matthiesen, et aU 1972
(3)  Seed, et al, 1969
(4)  Geological Survey Circular 672,  1972

-------
                                                                   SAN BERNARDINO
  TORRANCE
           HUNTINGTON BEACH S    COSTA MESA
                        NEWPORT BEACH
                           'LACUNA BEACH
Earthquake Epicenters
             4.0-4-4
             4.5-4.9
              >5.0
                                      :SANCLEMENTE
SEISMIC INDEX MAP
Exhibit 2-1

-------
                                  TABLE 2-4

                     GEOLOGIC CONSTRAINTS ON POPULATION
                          GROWTH IN THE AWMA REGION
                                      Percent of AWMA           Number of
                                      	Area	             Acres

 Excavation Constraints                      30                   14,626

 Mass Movements                              20                    9,751

 Fault Zones                                 _5_                    2.438

     TOTAL                                  55                   26,815

     Minus Overlap                          15                    7,313

 TOTAL GEOLOGIC CONSTRAINTS AREA             40%+                 19,502


 2.4  SOILS

 2.4.1  General Soil Map of Orange County

 The Soil Conservation Service under the auspices of the United States De-
 partment of Agriculture is responsible for the classification and distribu-
 tion of information about soils in the United States.  A general  Soils Map
 of Orange County was published in 1966 (currently under revision) by the Soil
 Conservation Service which offers delineation of different geographic areas
 and shows the general pattern of soils which occur within each area.  Each
 area on the map is made up of one or two extensive soils, usually similar in
 major soils characteristics.   Included within these areas are minor areas of
 contrasting soils.  Each of these areas on the map is called the  soil associa-
 tion and is named for the major soils it contains.

 The General Soils Map is useful for providing information about soil resources
of communities, districts, or counties.   This information can be  used for
 preliminary planning for agriculture, urban, engineering, watershed, recrea-
 tion or wildlife development.  For example, it can be used to identify areas
of "prime" agricultural  land, areas which may have severe restrictions for
septic tank filter field, or  places where expansive soils may be  a  problem
 in constructing roads or for  building foundations.   Collectively, soil asso-
ciation characteristics  may be used to predict the location and density of
 future land uses in the  AWMA  region.   Further discussion of this  concept is
presented below in Section 2.4.3.
                                   2-12

-------
 2.4.2   Soils  Characteristics

 Soils of  the  AWMA  region are characteristic of the Southern California
 Coastal Plain physiographic area.  The United States Department of Agri-
 culture,  Soil Conservation Service is currently preparing revised Soil Survey
 for  the Orange County area and categorizes the area into 13 Soil Associa-
 tions.  These soils associations are basically representative of the coastal
 and  foothill  areas of the Southern California Coastal Zone.  Table 2-5 indi-
 cates each soil association occurring in the AWMA area and its specific prop-
 erties  and characteristics.

 The  soil  associations may be further categorized to reflect the general
 characteristics of soils derived from different geologic units.  Four basic
 "super-associations" occur in the AWMA region.

 2.4.2.1   Soils on Recent Alluvial Fans and Plains

 These include well-drained permeable soils located on nearly-level, to
 gently-sloping (1 to 5 percent slope) alluvial fans and plains.  The Cor-
 ral i ties  (ciAB), Mocho-Sorrento (MM-sb-B) and Sorrento-Mocho (sb-MM-A)
 Associations  are derived from these geologic units and represent approxi-
 mately  12.5%  of the AWMA area.

 2.4.2.2   Soils on Older Alluvial Fans and Terraces

 These soils are well-drained with moderate-to-slow permeability, located on
 gently-to-moderately sloping (0 to 9 percent slope) alluvial  fans and ter-
 races.  The Bicknell (Bu-BC), Botella (Bk-BC), Huerhuero-Aliso (He-AM-BD2),
 and  Marina-Garey (Mg-Gd-BC) Associations are derived from these geologic
 units and represent approximately 16% of the AWMA area.

 2.4.2.3  Soils on Marine Sediments

 These soils are well-drained, moderately deep and moderately alkaline to
 slightly acid with medium-to-slow permeability.   The Altament-Diablo (An-Dl-
 E2 and An-Dl-F2), Newville (Nn-EF-2) and San Andreas-San Benito (Se-SF-FG2)
 Associations are derived from this geologic unit and represent approximately
 66.5% of the AWMA area.

 2.4.2.4  Miscellaneous Types

These include beaches (sand and gravel),  riverwash (barren alluvial  land
subject to frequent changes), rough broken land  (RB, steep land broken by
numerous intermittent streams with chaparral  and other similar vegetation),
and  terrace escarpments  (TY,  steep even fronts of alluvial  terraces).   Uses
of these soils include recreation and urban purposes (beaches); groundwater
 recharge and construction materials (riverwash);  and wildlife and watershed
 (rough broken land and terrace escarpments).   They represent about 5% of the
AWMA area.
                                  2-13

-------
                TABLE  2-5



SPECIFIC SOIL PROPERTIES OF THE AWMA AREA
Percent of
Soil AWMA Percent
Assoc. Area Slope
ci-AB
MM-sb-B
sb-MM-A
Bu-BC
BK-BC
HE-AM-BD2
Mg-Gd-BC2
An-Dl-DE2
An-Dl-F2
Nn-EF2
Se-Sf-F62
RB-TY
.5
7.0
5.0
5.0
.5
10.0
.5
5.0
30.0
1.5
30.0:
5.0
0-5
2-5
0
2-9
2-9
2-9
2-15
2-9
9-30
30-50
'15-50
30-75
Capability
Unit
IIIs4
Ilel
1-1
Ilel
Ilel
IVe3
IIIs4
IVe5
VIe5
VIel
Vllel
VHIel
Perm- AWH
eability Capacity
Rapid
Mod.
Mod.
Mod.
Mod.
Slow
Clay pan
Very
Slow
Mod.
Slow
Slow
Slow
Mod.
Varies
3-4.5
10-12
10-12
7.5-8.5
10-12
2-3.5
7.5-815
5,0-7.0
5.0-7.0
3.0-5.0
3.0-6.5
Varies
Runoff
Slow
Med.
Slow
Med.
Med.
Med.-
Rapid
Med.
Med.-
Rapid
Rapid
Med.-
Rapid
Very
Rapid
Rapid
Erosion Depth to
Potential Fertility Bedrock
None
SI i ght to
Moderate
None
Slight to
Moderate
Slight to
Moderate
Med. -
High
Mod. -
High
Mod.
High
Med.-
High
Very
High
Very
High
Low
Med.
High
Med.
High
Low
Med.
High
Low
Low
High-
Med.
High-
Med
Med.
Med.
Very
Low
60+
60+
60+
60+
60+
10-
20"
60+
20-
40"
20-
40"
20-
40"
20-
40"
0-
10"
Shrink-
Swell
Poten.
Low
Mod.
Mod.
Low
Mod.
High
Low
High
High
High
Mod.
Low
Hy-
drol.
Grp.
A
B
B
B
C
D
A
D
D
D
C
D

-------
 2.4.3.  Soil  Interpretations       "

 The General  Soil  Map shows^ the general  pattern  of  dominant soils  for Orange
 County.   Several  interpretations  can  be made  of these soil association map
 units for general  land planning purposes.   These interpretations  are based on
 soil  characteristics and qualities  and  predictions for  the major  soils within
 the mapping  unit  as  to their  behavior for  a specific purpose.  All interpre-
 tations  are  based on a soil depth of  five  feet  or  less  than five  feet where
 bedrock  is encountered at a lesser  depth.

 The soil  association map units for  th AWMA Region  are interpreted into several
.different groupings  and are noted in  Table 1.   Some of  these are  shown in the
 Index of Soil  Mapping Units and Interpretive  Groupings  in the SCS 1966 report.
 All  ratings  are very general  and  not  suited for on-site planning.  Some of
 the more  important groupings  are  analyzed  below to their relationship in pre-
 dicting  future urban growth in the  AWMA area.   Probably the most  important
 classification is  that of land capability.

 2.4.3.1   Land  Capability Classification

 The Land  Capability  Classification  provides a comprehensive compilation of
 characteristics similar for a  number  of soil  associations which can be used
 for preliminary planning in agriculture, urban,  engineering, watershed, re-
 creation  or  wildlife development.   These classifications are further broken
 down  into sub-groups based on  some  of the  characteristics described in Table
 2-5 (refer to  SCS, 1966,  General Soils  Report).

 The capability groups  do not  take into  account  major alterations of the land
 that  would change  slope,  depth or other characteristics of the soils.

 Class  I soils  have few limitations, the widest  range of use, and the least
 risk  of damage when  used.  Soils in other  classes  have progressively greater
.natural limitations.   In  the AWMA Region,  approximately 6,300 acres (13
 percent)  are Class I and  II soils,  suitable for permanent cultivation, with
 Tittle or no alterations  necessary.   There  are  about 7,800 acres  (16 percent)
 of  Class  III and  IV  soils.  Crops may be cultivated on these soils for only
 short periods  of  time,  and intense  conservation  practices are necessary.
 Classes VI-VII cover about 32,200 acres  (66 percent) of the watershed, not
 suitable  for agricultural use.  Class VIII  is about 2,400 acres (5 percent)
 of  the watershed,  unsuitable for cultivation or  grazing use, and may be
 steep, shallow, rocky,  severely eroded, or  subject to periodic stream over-
 flow.

 In  general,  the Land Capability Classifications  reflect land suitable for
 intense urbanization.   Classes  I through IV, or  29% of the AWMA area, are
 capable of supporting  urban land uses according  to today's grading and con-
 struction  practices  sensitive  to the natural terrain.   This figure is based
primarily  on the slope,  runoff, and erosion characteristics of the region.
71% of the area displays slopes over 15% in grade and over 66% of the AWMA
area have  slope characteristics of  30% and above.  Low density development
and clusters of high density development may occur in areas displaying slopes
 in excess  of 15%., Above. 30%,   mass  grading would be necessary to accommodate
                                     2-14

-------
 future urban growth.  Due to the environmental  sensitivity of the governmental
 agencies having jurisdiction in the AWMAarea, approval  of land uses involving
 mass grading would probably be denied.   Table 2-6 categorizes the percent
 coverage of each Soil Class in the AWMA area and assigns a value of limita-
 tion to intense urban development.

 2.4.3.2  Erosion Potential

 AIT soils occurring in the AWMA area have  erosion hazards of differing de-
 grees.  Over 65% of the AWMA area has soils with high to very high erosion
 potential.

 Soils with  the highest erosion potential occur on rough-broken land and
 terrace escarpments along the coast.

 Erosion (including soil  failures) is quite severe in numerous locations of
 the hillside portion of the AWMA area.   Several  factors working in combina-
 tion are responsible for this condition.   These factors include:

      1.   Climate - Sparse  rainfall, uneven distribution throughout the
          year, results  in relatively sparse vegetation with little sta-
          bilizing influence.  Over-grazing has also contributed  to this
          condition.  Although rainfall  is low,  sporadic intense  storms
          with high erosion potential are  not uncommon.

      2.  Bedrock Type - Sedimentary formations  (Capistrano, Monterey,  Miguel)
          within the planning area are  weak and highly  susceptible to erosion
          and slope failure.   Their generally fine  grain size and low inter-
          granular strength contribute  to  their high credibility.   Rainfall
         . and bedrock masses  consisting of broken blocks of bedrock are also
          susceptible to erosion (and are  indicative of the need  for correc-
          tive grading).

      3.  Soil  Type - Bedrock generally weathers  to a highly expansive, rela-
          tively impermeable  clayey soil with a  high tendency to  "creep"
          downslope when  saturated.   This  feature,  in combination with  steep
          topography, is  chiefly responsible for the large  number of soil
          failures.

 Because the  residual  soils  are rather thin on the steeper slopes,  natural
 soil  failures are generally shallow and do not  present  a stabilization  prob-
 lem of. nearly the same magnitude as  even the smaller landslides.

 2.4.4   Agricultural  Soils

 2.4.4.1   Regional

 Southern  Orange County is  lacking in  prime agricultural  soils  of  Class  I and
 II.   These soil  types  are  limited in  this  area  to alluvial  and  major  creek
 flood  plain  (see Exhibit  2-2).  Over  40% existing  agricultural  crop  land in
 Orange  County,  however, occurs  in the south.  More  than  70% of  the  170,000
.acres  of  prime  agricultural fosils have been  converted  to urban uses, primarily
 in  northern  Orange  County,  making the southern portion an important agricul-
 tural  area.
                                     2-15

-------
Agricultural Land
iji Prime Agricultural Soils  Class (I&ID
5jj^ Existing Agricultural Cropland
	Agricultural Preserves
                    Pacific     Oceai

     Source: Orange County Progress Report, Volume 10
     Exhibit  2-2

-------
 Soils  of the  coastal  hills  and  foothills of  the  Santa Ana Mountains are
 developed on  marine  and  sediments  and  have been  generally used for grazing
 of livestock.   Almost all southwestern Orange  County is covered by range
 land soils.

 2.4.4.2   The  AWMA  Region

 The  AWMA area  contains representative  soils  of the Southern California
 Coastal  Plain.   Valley alluvium and terrace  covered by sandy loam soils are
 representative  of  most valley and  canyon floors.  These soils are considered
 prime  agricultural soils and represent about 13% of the AWMA region.  About
 50%  of the area covered  by  these soils has been  under cultivation for a number
 of years.

 Much of  the hillside  areas  of the  region are represented by Al tamont-Diablo
 clay soils.  While the inherent fertility is medium to high, the high erosion
 hazard of the  steep  slopes  renders them unsuitable for cultivation.  They are
 well suited for pasture  or  range land and have been used as such for at least
 a  century.  These  soils  represent  about 35%  of the AWMA area.

 A  portion  of the AWMA Region has been set aside as an Agricultural Preserve
 under  the  guidelines  established by the Williamson Act.  About 95% of the area
 within this preserve, however,  is  not suitable for agricultural development
 and  has  been placed  in the  preserve status primarily for future planning pur-
 poses.   Only about 5% of the preserve is capable of producing crops and repre-
 sents  only about 1% of the  entire AWMA Region.  Much of the remaining 12% of
 prime  agricultural soils have been eliminated by or are currently being planned
 for  urbanization.

 2.5  HYDROLOGY

 2.5.1  Surface  Water

 2.5.1.1  Aliso  Creek

 The  Aliso Creek Watershed is drained by Aliso Creek and its tributaries.
 This drainage system  begins  in the foothills of the Santa Ana Mountains and
 from there Aliso Creek flows in a southwesterly direction for a distance
 of approximately 18 miles.   It enters  the ocean at Aliso Beach just north of
 South  Laguna.    From the Creek's source, at the northwesterly corner of the
 watershed at elevation 1,500 feet,  the Creek and its  tributaries  flow through
 a steep canyon  carved in an  exposed rock formation covered with little or no
 soil.  From there to  the San Diego  Freeway,  the Creek flows through a some-
 what wide alluvium filled valley planted with citrus  groves.   After crossing
 under  the freeway, the Creek meanders  through an open rolling plain until  it
 reaches the Miguel  Hills close to the  sea.   From here the Creek has cut a
 steep  canyon down to  the ocean.

 Before 1900, Aliso Creek only had running water during  the rainy  months of
 November through March.  At  the turn of the  century,  the cultivation  of citrus
occurred in the upper reaches of the watershed, while the lower,  drier water-
 shed was  devoted to cattle  grazing  as  well  as dry farming.   To irrigate the
                                     2-16

-------
 orchards, water was retrieved from the underground water basin1through wells.
 The  Metropolitan Water District line was installed to accommodate farming and
 the  increasing pressures of urbanization.  Because of the increase1 of urbani-
 zation and  its supportive facilities along with farming in upper Aliso Water-
 shed, there is now a yearly minimal flow down Aliso Creek.  In Lower Aliso
 Creek there is now standing water which used to be a seasonal  occurrence.

 Three types of storms produce precipitation in the area:  general winter storms,
 thunderstorms and general summer storms (including tropical  cyclones).  Most
 past flooding has been caused by high-intensity rainfall associated with general
 winter storms characteristic of the area.  Floodflow stages  can rise from nearly
 dry streambeds to extreme flood peaks in a matter of hours.

 During floods, the mountain reaches of the tributaries and of the upper Creek
 are heavily laden with debris.  On leaving the steeper mountain section, the
 Creek loses its sediment transporting power and the debris load is dropped
 except for the fine material  which is moved farther downstream.   This is where
 the Creek enters the more open valleys with potential  spreading grounds.

 Damaging floods occurred in the study area in 1916, 1927, 1937 and 1969.
 The largest flood of record along Aliso Creek occurred in February,  1969.
 Severe storms occurred in Orange County in 1862, 1884, 1923, 1938 and 1952.
 However, no information could be obtained for these storms concerning the
 severity of the damage in the study area.

 The Orange County Flood Control  District has maintained a stream gaging
 station on Aliso Creek from 1932 to the present.  The  gaging station is located
 just upstream from the Second Street bridge.  To supplement  the records from
 the gaging station, newspaper files and historical  documents were searched
 for information concerning past floods.   These records have  aided in the
 development of an understanding of floods that have occurred on  Aliso Creek.

 The most devastating floods of record in the study  area occurred in  January
 and February of 1969.   Monetary losses from the January flood  were estimated
 at $336,000 and from the February flood at $604,000.   Most of  the damage
 from the January and February floods were in bridge and road washouts and
 inundation of several  resort  dwellings along Aliso  Creek.  Water supplies
 and beaches were contaminated from high  runoff and  damage to the South Laguna
 Sanitation District.   Some agricultural  and utility damage also  occurred.

 Around the San Diego Freeway,  where urbanization has occurred,  surface water
 is directed through the use of flood control  channels  or heavily landscaped
 streambeds (such as through Leisure World).   In the lower part of the Creek
 below the freeway,  the reduced gradient  causes  the  storm waters  to overflow
 the shallow creek banks,  leaving the fine sediment.   In extreme  floods,  the
 water which leaves  the streambed washes  the valley  topsoil down  to the ocean,
 thus  replenishing beach sand  at  Aliso Beach.

.Presently, there are  no flood control  dams  or structures to  impede the flow
 of surface water to the ocean.   There are pressures  from interest groups to
 leave Aliso Creek in  a natural state and to preserve it as a regional  recrea-
 tional amenity that would allow  unlimited access from  the  ocean  to Cleveland
 National  Forest.
                                     2-17

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2.5.1.2  Salt Creek       ,   .......

The Salt Creek Watershed is drained by Salt Creek and several  branch tribu-
taries including Arroyo Salada ,and San Juan Canyon (not the San Juan Creek
located adjacent to San Juan Capistrano).  The length of Salt  Creek is  approx-
imately 4 miles from its outlet at Pacific Ocean to its headwaters just north
of San Juan Capistrano.  The entire Salt Creek drainage area consists of
approximately 7.1 square miles.

The drainage area is roughly bounded on the west and northwest by the Miguel
Hills, on the east and southeast by the ridge Salt Creek and Trabuco/San Juan
Creek watersheds, and on the south by the Pacific Ocean between Dana Point and
Monarch Bay.  For the most part, the study area is defined by  natural ridge-
lines which clearly form major drainage boundaries.

The topography of the area is dominated by rolling hills, with hillsides
varying from moderate inclines to 50 percent slopes, and several  stream
courses interlacing the area.  The relief ranges from sea level to several
hundred feet.

The area is bisected generally from north to south by Crown Valley Parkway,
a major arterial highway which crosses many of the natural watercourses.
The culverts that were installed as part of the road construction are,  in
most cases, adequate for an ultimate drainage system.

Pacific Coast Highway, extending across the southwest portion  of the drainage
study area, produces no major drainage problems, as it has been adequately
crossed by various culverts in the vicinity.  The only major drainage course
crossing Pacific Coast Highway in the Laguna Miguel area is Salt Creek, which
at present passes underneath and is enclosed in a concrete culvert to its
outlet at the Pacific Ocean.  Other than the underground culvert at Coast
Highway, Salt Creek is unimproved from there to its origin above San Juan
Capistrano.

In the upper reaches of Salt Creek (Bear Brand Ranch), the creek passes through
well defined steep sided canyons encompassing approximately two square  miles
of drainage area.

At least 50 percent of Laguna Miguel  drainage area ultimately  drains into
Salt Creek.  Within Laguna Miguel  the Creek has been extensively altered
because of grading operations for future residential  and golf  course use.

The grading has been extensive and is readily apparent from Pacific Coast
Highway.   Cut and fill operations were conducted to minimize off-site dis-
posal  of surplus materials.  As a result the cut material  was  deposited in
low areas along streams and on top of layers of permeable sand covered  drainage
courses.

Thus,  there is the potential hazard of extensive erosion and siltation  into
the ocean if a heavy rain occurred.  As a preventative measure, a siltation
basin  was installed in Salt Creek at Pacific Coast Highway.  It is gunnite
                                    2-18

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 lined and acts as an overflow weir.  The siltation basin is a temporary
 mitigative measure until the drainage system, culverts, storm drain pipes
 and  final sedimentation basins are completed when final grading activities
 are  accomplished.

 Arroyo Salada is a tributary to Salt Creek, draining much of the area im-
 mediately west of Crown Valley Parkway in the southern portion of Laguna
 Niguel.  For most of its length, Arroyo Salada passes through the El Niguel
 Country Club private golf course; the grassed swale provides adequate drain-
 age  for the ultimate development of the surrounding hills.  In addition,
 several of the culverts under Crown Valley Parkway have outlets at the
 side of the golf course, and will not require extension as long as Arroyo
 Salada is left as an open swale.

 San Juan Canyon, a tributary to Salt Creek in the upper watershed area, is
 presently unimproved.  Because of the relatively steep canyon sides and the
 well defined watercourse, this canyon may also be left in its natural state
 depending on the adjacent development.  San Juan Reservoir is a privately-
 owned, spring-fed storage pond for the watering of cattle which graze in the
 area, and as such it has no effect on storm flows.

 To date there is little information on floods within the Salt Creek water-
 shed.  Because there was no development within this area there was nothing
 man-made to damage, thus no records.

 2.5.1.3  Laguna Canyon

 Laguna Canyon watershed drains the area known as San Joaquin Hills and flows
 in a southerly direction down Laguna Canyon to the Pacific Ocean.   The drain-
 age area of Laguna Canyon and its tributaries is about 8 square miles.

 The upper part of the watershed has a small  discontinuous channel  which opens
 into a larger continuous channel near El  Toro Road.   This channel  merges at
 the Big Bend (mile 2.1) and into a concrete lined channel  extending to the
 Pacific Ocean.   This channel  has been extended in a series of short reaches
 since construction began in 1928.

 Development in the Canyon ranges from dense settlement at the mouth of the
Canyon (the original  City of Laguna Beach)  to sparse development in the
area at the upper limit of the watershed.   Most of the commercial  develop-
ments are in the lower part of the canyon.   Residential  development is pre-
dominant in the area between Woodland Drive and El  Toro Road on the west
side of Laguna Canyon Road.   Beyond El  Toro Road there is very little devel-
opment.  Leisure World has developed within  the northeast section  of the
watershed.

 Several areas in the lower part of the canyon can be considered as either
completely developed or very nearly so, and this development,  as well  as
development in other areas,  has extensively encroached upon  the 100 year
flood plain.
                                     2-19

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 Records  of flow  stages and discharges have not been kept, and information
 on  past  flooding is  limited  to historical accounts and the memories of those
 persons  witnessing the event.

 Existing flood control facilities in the study reach consist of a shallow
 lagoon in the uppermost reach of the watershed and an improved channel in
 the  lower reaches.   These lagoons are called the Laguna Lakes or "Las Lagunas"
 and  are  the only known examples of natural lakes remaining in Orange County.
 The  flood control capacity of Laguna Lakes is very small and does not materially
 affect the flood control of  the area.  The improved channel, consisting of both
 open and covered concrete lined trapezoidal and rectangular sections, extends
 from the Big Bend at about mile 1.9 to the ocean.  Construction of this chan-
 nel, which has been  piecemeal, began in 1928 with the construction of a section
 through  the downtown area from the Pacific Ocean to Forest Avenue.  The latest
 section,  completed in 1968,  extends northward to mile 1.9.  The channel improve-
 ments, in general, have been extended upstream to keep pace with develop-
 ment.  The channel has been  designed for the 25-year frequency flood and will
 be inadequate for the 100-year frequency flood or the Standard Project Flood.
 Many of  the homes in the area are surrounded by low masonry fences with specially
 designed openings that may be closed off during a flood, leaving the fenced
 area as  an  island within the flood plain.  The Orange County Flood Control Dis-
 trict proposed that  a dam be constructed at El Toro Road; however, funds were
 never authorized  for its construction.

 The Army  Corps of Engineers  also did a study for Laguna Canyon in 1972 and
 found that  the average annual damage that would be caused from a flood did
 not warrant the  cost of installing flood control  devices.  Their recommenda-
 tions were  that  flood plain management be used by the Orange County Flood
 Control  District.

 In addition to agricultural  land in the flood plain of the study reach, the
 following are subject to flooding:   the main business area of downtown Laguna
 Beach, the  sewage treatment plant,  and numerous commercial and private struc-
 tures extending  to El Toro Road.   Also,  the Coast Highway (California State
 Highway 1) at the lower limit of the study area,  will  be inundated.

 Thirty bridges span the streambed or the improved channel in the study reach.
Most of the bridges are small and provide access  to property beyond the
streambedj and only four can be classified as major structures.   These are the
 Forest Avenue (Third Street) bridge,  the Laguna Canyon Frontage Road Bridge,
 the Woodland Drive bridge,  and the  Canyon Acres Drive bridge.   In addition to
 the sections covered by bridges,  the channel  is covered in several  places for
considerable distances, including the last 0.'21 mile through the business
 section of Laguna Beach.   This covered channel, or culvert,  acts as a bridge
 for two major crossings,  Beach Street and the Coast Highway (California State
Highway 1).  There is another major crossing at El  Toro Road which consist of
two 3-foot diameter corrugated metal  culverts and at Laguna Canyon Road (above
 El Toro Road)  consisting of a 2-foot by  4-foot concrete culvert.

Recent large floods occurred in Laguna Canyon on  February 6,  1937;  March  1
to March  3, 1938; February 173 1941;  January 19-27,  1969; and February 22-26,
1969.  Exact rates of floodflow are  not  available;  however,  historical  data
                                     2-20

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 indicate  that  the  1937, 1939 and 1941 floods resulted in extensive damage to
 homes,  primarily due to erosion and undercutting.

 Flood damage that  would result from recurrence of major floods would be sub-
 stantial.   Extensive damage has been caused by past floods to commercial
 buildings  and  private dwellings.  Consequently, the probability exists that
 the  intermediate Regional Flood and the Standard Project Flood would cause
 substantially  greater damages because of their greater depths and higher
 velocities  and the continuing development in the area.

 Main flood  season  for Laguna Canyon is from December through March.  Storms
 occurring during these winter months last for several days, are widespread,
 and produce the greater floods.  However, floods caused by intense local
 thunderstorms  may  occur at any time of the year.

 Duration of floods is very short on the study reach of Laguna Canyon.  Stages
 would rise  from streambed to extreme flood peaks in about 4 hours from the
 beginning of rainfall.  The floodwaters would remain on the flood plain for
 about 2 hours  after cessation of rainfall.

 Hazardous conditions would occur during large floods as a result of the
 rapidly rising streams, high velocities and deep flows.

 Flood damage prevention measures consist of the locally constructed flood
 control channel from the Pacific Ocean to mile 1.9 at the Big Bend.  Other-
 wise, no other county or federal flood control  projects are authorized or
 proposed in the study area.  The occupancy of the flood plain is controlled
 to some degree by  subdivision regulations and zoning ordinances which require
 Planning Commission approval  of new developments.

 2.5.2  Groundwater

 Groundwater quality is generally determined by the time of contact with the
 percolated rainwater from the soil  and by the types of different geological
 formations contacted.  As previously mentioned  in the geological section,  the
 formations in  the Study Area are mostly of marine origin and thus contain  more
 salts and ocean-related minerals than formations of continental  origin.  This
 is especially  true for the southern portion of the watershed which is charac-
 terized by highly mineralized groundwaters.   Descriptive names  like Sulphur
 Creek in the lower watershed and Salt Creek to  the south of the Aliso water-
 shed indicate ground water quality.

 In general, the Aliso groundwater basin is high in total  dissolved solids  and
 chlorides with a high percentage of sodium and  would be classed doubtful  in
 quality for irrigation water.   The  estimated capacity of this  ground water
 basin is 9,000 acre-feet and has been  suggested as a potential  storage basin
 as a result of a previous study made in 1961 by Engineering Science,  Inc.
 More recently,  the Orange County Flood Control  District prepared a study on
 the Aliso basin between the San Diego  Freeway and Trabuco Road.   This report
 confirmed much of the data contained in the 1961  report and indicated that one
could safely assume that a minimum  of 1,000 AF  annually could be percolated
and withdrawn by pumping in the upper  portion of the basin.  Agricultural
                                     2-21

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 uses  require  approximately 3-5 acre feet per acre per year of farmland.  So
 at 1,000  acre feet minimum that would support 3,000-5,000 acres minimum of
 agricultural  used within the upper watershed.

 Combining this with proper management of the lower portion of the Basin, the
 usable  storage capacity of the total Basin could be increased.  Additionally,
 groundwater recharge could be produced.

 As  stated above, the water basin as it exists today, is not suitable for
 agricultural  uses because of the high salinity of the water.  There are
 plans by  AWMA to remove the saline water and replenish with secondary
 treated IDS supplies that would be reclaimed by the existing plants of the
 Los Alisos and Rossmoor Sanitation Districts.

 After the basin had been drafted for approximately three years, either rain-
 fall or tertiary treated effluent would be discharged into the basin for a
 flushing  action.  It is estimated that there are about 50,000 tons of cur-
 rently accumulated salt in the basin.  This accumulation of salt would have
 to be reduced to something on the order of 20,000 tons before the water coming
 out of the groundwater basin would meet an agricultural purpose requirement.

 After the first ten years of operation, essentially when enough salt has
 been removed  and the tertiary treatment process is in operation, the dis-
 tribution  system would be incorporated into the greenbelt irrigation system
 for the Aliso Greenbelt area.

 The Aliso Creek Greenbelt concept as outlined in the UCI-SACC study team final
 report on August 1974, is for a recreational corridor in Aliso Creek stretch-
 ing from  the ocean to Cleveland National  Forest.  The corridor would consist
 of natural, naturalistic low intensity and high intensity recreation areas.
 The higher the use the higher the water requirements would be.  An example
 of high intensity recreation would be public parks and golf courses.

 It is the objective of the Aliso Water Management Agency, through proper water
 management, to maximize the use of this natural  storage capability.   This will
 be accomplished through properly planned and controlled upgrading of the water
 stored in the basin.   Controlled pumping and percolation of reclaimed water
 out of and into the basin for further use is one of the agency's goals.

 2.6  METEOROLOGY

 2.6.1   Climate

 The study area has a  climate typical  of the Southern California coastal plain
with mild summers and winters.   Freezing temperatures  occur infrequently with
 a duration of only a  few hours.   Generally, the majority of the precipitation
 can be expected to occur during a four-month period from November through
 March with mean seasonal  precipitation varying from 12 inches at the coast
 to 21  inches in the foothills.   The average daily temperature at El  Toro
Marine Corps Air Station is  60.2 degrees  Fahrenheit with a high monthly
average temperature of 69 degrees Fahrenheit recorded  in July and a  low
average of 50.9 degrees Fahrenheit in  December.   The relative humidity varies
                                     2-22

-------
 from  an average monthly low of 65 percent in February to a high of 75 percent
 in August, with a yearly average relative humidity of 71 percent.  Evaporation
 records from the Irvine Railroad Station average 59.75 inches per year for
 the period from 1946 to 1954, with a low and high monthly average of 2.5
 inches in January and 7.96 inches in July, respectively.  The lowest yearly
 evaporation recorded was 56.33 inches in 1949 and the highest was 68.58
 inches in 1953.  The prevailing wind is westerly with light to moderate
 velocity.

 2.6.2  Air Resources

 2.6.2.1  Introduction

 In the assessment of any air pollution problem, one consideration must be
 meteorology.  Any analysis of air pollution must inevitably concern itself
 with the medium into which the pollutant is disgorged.

 The medium is, of course, the atmosphere.  The basic question is always:
 to what extent do the pollutants concentrate?  The obvious answer is that the
 degree of concentration is a function of the dispersion characteristics of
 the atmosphere.

 Local air quality depends primarily upon the dispersion of the pollutants
 released from within and surrounding the AWMA area.  Temperature inversions
 and land-sea breezes affect the dispersion of pollutants and are factors  in
 determining air quality.  Inversion layers combine temperature variations with
 altitude to present an'adverse meteorological condition and intensifies the
 air pollution problem by limiting dispersion of the pollutants.

 In the South Coast Air Basin, air quality is an interaction of meteorological
 factors with both primary and secondary pollutants.  The best known and most
 severe air pollution problem is photochemical smog.  This pollution problem
 results from a chemical  reaction between reactive hydrocarbons (RHC)  and
 nitrogen oxides (NOX), which occurs in the presence of sunlight.

 Temperatures generally decrease with altitude in the lower atmosphere (1  -
 11,000 feet).   At lower altitudes (ground level  or within the first few thou-
 sand feet of ground level), the temperatures may decrease less rapidly than
 the prevailing rate or in some cases the temperature will  actually increase
with height.   An increasing temperature with altitude creates the inversion
condition.   When an inversion persists,  the vertical  transport of pollutants
 upward is hindered.   The inversion  may be a few hundred feet to  a few thou-
sand feet high.  Throughout the South Coast Air Basin, 90% of the days have
a persistent inversion layer at heights  of 200  to 500 feet during the late
summer and fall months.   Little or  no data is available documenting the
 variation of inversion heights and  inversion strengths as a function  of
location in the South Coast Air Basin.
                                    2-23

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 2.6.2.2   Air  Quality

 The  AWMA area is  located  in  the South Coast Air Basin.  The Orange County
 Air  Pollution Control  District (OCAPCD) is responsible for controlling and
 enforcing regulations  upon stationary sources of pollution within Orange
 County,  while the State of California Air Resources Board is charged pri-
 marily with controlling motor vehicle emissions.

 Despite  the fact  that  the entire County has been designated a critical air
 area  by  the State Air  Resources Board, air quality and emission levels for
 the whole County  do not represent an accurate estimate of the air quality
 and emission  levels in this area of the County.  The AWMA region is quite
 varied in topography and  meteorology, which results in differences in air
 quality  throughout AWMA..

 Air quality data  is collected by the Orange County Air Pollution Control
 District.  Of the seven air monitoring stations located throughout the
 County,  three stations are situated in or around the AWMA area and can
 provide  a viable  indication of the air quality in the AWMA area (See Table
 2-7 and  2-8).  The El Toro air monitoring station has been monitoring all
 types of primary  pollutants for a longer period of time than the other two
 monitoring stations.  The air monitoring station located at the San Juan
 Capistrano City Hall has  monitored only ozone levels since August, 1973.
 The third air monitoring  station is located in Laguna Beach and has provided
 data on  primary pollutant types since April  1974.
               {''->••
 While Laguna  Beach experienced low levels of oxidant in 1974, the El  Toro
 air monitoring station recorded the second highest oxidant levels out of
 the seven stations operating in Orange County.  The maximum hourly average
 at El Toro was .48 ppm, while the highest level in Orange County was only
 slightly  higher at .54 ppm.  Air quality can therefore be characterized
 as deteriorating with greater distance from the coast.

 2.7  OCEANOGRAPHY

 2.7.1  Coastal- and Sub-marine Physiography

 The ocean environment off AWMA region is part of the Southern California
 Bight.  The Bight  is the open embayment of the Pacific Ocean extending   ,
 from Point Conception (north of Santa Barbara) to  Cabo Colnett (south of
 Ensenada, Mexico). ,Its western boundary is  roughly defined by the
 California Current.  The Bight is in a region of extensive faulting.

 The topography'of the ocean floor off the Orange County coastline is  charac-
 terized by a  variety of sub-marine features  including basins, islands rising
 above the sea 'surface, canyons and flat regions.   No notable sub-marine  ,
 features exist; in the Aliso-Dana  Point region.  Along most of the coast north
of Newport Bay, the shelf is about six miles  wide.   South of the Bay, the
 shelf width averages two to three miles.   The 120  foot isobath (depth of
 proposed outfall  terminus) varies  from 6,600  feet  to 11,600 feet offshore.
                                     2-24

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                                                                     TABLE 2-7
                                                              FEDERAL STANDARDS
                                                               AIR QUALITY FOR 1974
                                                                                AIR MONITORING STATIONS


POLLUTANT
OXIDANT
(Ozone)
NITROGEN
DIOXIDE
(N02)
CARBON
MONOXIDE
/ f*/~\\
(CO)
SULFUR
DIOXIDE
(S02)

SUSPENDED
PARTICULATE
MATTER

HYDROCARBONS
(Corrected for
Methane)
FEDERAL
AIR QUALITY
STANDARDS
0.08 ppm
1 Hr. Avg.
0.05 ppm
Annual Avg.

9 ppm
8 Hr Avg.
35 ppm
1 Hr Avg.
0.14 ppm
24 Hr Avg.
0.03 ppm
Annual Avg.
75 ug/m3
AGM 3
260 ug/m3
24 Hr Avg.
0.24 ppm
3 Hr. Avg.
(6-9 a.m.)


DATA
FORMAT
Days ]•
Max. '
Annual
Avg.

Days
Max.

Days
IvlixT
Annual
Avg.
AGM 3'

% Over 4'
Max.
Days
Max.



Anaheim Costa Mesa
73/.31 93/.27




8/14 24/18
0/17 0/23

0/.04 0/.03

	 	

94 64

0%/223 0%/181

178/4 	
(9 mo.)



La Habra El Toro
163/.54 133/.48
(10 mo.)



59/25 0/6
(9 mo.)
0/33 0/8
(9 mo.)
0/.03 0/.02
(8 mo.)
	 	

115 69

1%/273 0%/188

	 175/2
(9 mo.)


Santa Ana
Los Alamitos Canyon
123/.34 7/.14
(10 mo.) (1 mo.)



5/13
(8 mo.)
0/19
(8 mo.)
0/.03
(8 mo.)
	 	

100 	

0%/229 	

158/8
(9 mo.)


San Juan County
Capistrano Laguna Beach Wide
97/.31 68/.20 218/.54
'(11 mo.) (9 mo.)



0/9 66/25
(9 mo.)
0/13 0/33
(9 mo.)
0/.02 0/.04
(8 mo.)
	 	 	

	 69 	

0%/203 .2%/273

	 	 259
(11 mo.)

            AIR POLLUTION EPISODES
Pollutant'  Criteria (ppm/time)   Stage   Episodes Declared
Oxidant
Sulfur
Dioxide
Carbon
Monoxide
0.20/1 hr
0.40/1 hr
0-50/1 hror
0.20/24 hr
40/1 hror
20/12 hr
1
2
1
1
37
2
0
0
                                                                                1. Days -  Number of days standard exceeded.
                                                                                2. Max. -  Highest value over averaging time.
                                                                                3. AGM -  Annual Geometric Mean.
                                                                                4. % Over - Percent of samples over criterion.

                                                                                (Federal Ambient Air Quality Standards are not danger levels.
                                                                                 These are levels required to protect public health with an
                                                                                 adequate margin of safety.) •

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                                                                  TABLE 2-8
                                                           CALIFORNIA STANDARDS
                                                              AIR QUALITY FOR 1974
                                                                                   AIR MONITORING  STATIONS


POLLUTANT
OXIDANT
(Ozone)
NITROGEN
DIOXIDE
(N02)
CARBON
MONOXIDE
(CO)

SULFUR
DIOXIDE
(S02)

SUSPENDED
PARTICULATE
MATTER

LEAD
^ t^AL^
(PARTir.UI ATF1
CALIFORNIA
AIR QUALITY
STANDARDS
0.10 ppm
1 Hr. Avg.
0.25 ppm
1 Hr. Avg.

10 ppm
12Hr.Avg.
40 ppm
1 Hr. Avg.
0.10 ppm
24 Hr. Avg.
0.50 ppm
1 Hr. Avg.
60 ug/m3
AGM 3.
100 ug/m3
24 Hr. Avg.
1.5ug/m3
30 Day Avg.

DATA
FORMAT
Days ]•
Max. ...
Days
Max.


Days
Max.


Days
Max.

AGM 3.
% Over 4-
Max.
Months 5-
Max.


Anaheim
61 /.31

12/.37


3/12

0/17

0/.04

0/.08

94
46%/223

11 Mo.
3.76


Costa Mesa
67/.27
•-,
1/.30


6/15

0/23

0/.03

0/.14

64
17%/181

6 Mo.
3.89


La Habra
141/.54
t
. . 7/.32


37/22

0/33

0/.03

0/.15

115
64%/273

9 Mo.
3.67
r\i t \ \\

El Toro
118/.48
(10 mo.)
6/.S3
(3 mo.)

0/4
(9 mo.)
0/8
(9 mo.)
0/.02
(8 mo.)
0/.04
(8 mo.)
69
24%/188

3 Mo.
2.15
nwiNi iwiiiiivj w i r-\ i iv/iv<-r
Santa Ana
Los Alamitos Canyon
112/.34 5/.14
(10 mo.) (1 mo.)
3/.50 	
(1 mo.)

2/11 	
(8 mo.)
0/19 	
(8 mo.)
0/.03 	
(8 mo.)
0/.18 	
(8 mo.)
100 	
50%/229 	
(10 mo.)
5 Mo. 	
4.85

San Juan
Capistrano Laguna Beach
79/.31 53/.20
(11 mo.) (9 mo.)
	 3/.S2
(9 mo.)

	 0/8
(9 mo.)
	 0/13
(9 mo.)
	 0/.02
(8 mo.)
	 0/.08
(8 mo.)
	 69
	 16%/203
(10 mo.)
	 5 Mo.
2.76

County
Wide
194

20/.50


37/22

0/33

0/.04

0/.18

	
37%/273

	

            AIR POLLUTION EPISODES
Pollutant   Criteria (ppm/time)
             0.20/1 hr
Oxidant
             0.40/1 hr
Sulfur
Dioxide
Carbon
Monoxide
0.50/1 hr or
0.20/24 hr
40/1 hr or
20/1 2 hr
Stage   Episodes Declared
  1           37
  2            2
                               1
1.  Days -  Number of days standard equalled or exceeded.
2.  Max. -  Highest value over averaging time.
3.  AGM-  Annual Geometric Mean.
4.  % Over • Percent of samples over criterion.
5.  Months - Number of mon ths standard equalled or exceeded.

(California Ambient Air Quality Standards are not danger levels.
These are levels required to protect public health with an adequate
margin of safety.)

-------
 A rough,  useful  classification of the shoreline in this area is rocky and
 sandy.   In  general, rocky shorelines were shaped by erosional processes,
 whereas  sandy  beaches backed by deltas, alluvial fans, or mudflats are
 depositional.  Sandy shorelines backed by cliffs were influenced by both
 processes;  i.e., erosional on a long-term basis, but with short-term depo-
 sitional  characteristics.

 The AWMA  coastal region is characterized by all three shoreline types.
 However,  the greater portion of the shoreline is erosional in nature.
 Northwest of Aliso Beach, the coastline is rocky with numerous small pocket
 beaches  frequently interrupted by rock outcroppings.  These are most fre-
 quently  found  in Laguna Beach.  The greater portion of the shoreline is    ;
 backed by escarpments rising to heights of 30 to 130 feet.

 There are three marine life refuges in this area:  South Laguna Beach, Niguel,
 and Dana.  A significant portion of the shoreline has been dredged, filled,
 or reshaped for the development of ports, harbors, marinas, jetties, and for
 other developmental purposes.

 2.7.2  Water Characteristics

 The water characteristics of the AWMA offshore waters are summarized
 in Exhibit 2-10.

                                  TABLE 2-9

                         SELECTED CHARACTERISTICS OF
                               OFFSHORE WATER
                                             Surface    180 Feet    270 Feet
Temperature (°C)


Salinity (o/o)


Density (gm/cm3)


Dissolved Oxygen (mg/1)
Max
Min

Max
Min

Max
Min

Max
Min
Dissolved Phosphate (mg/1)    Max
                              Min
21
16

33.7
33.7

 1.0248
 1,0238

12
 9

0.06
0.03
14
11
            33.7
            33.4
 1.0260
 1.0252
             7
             6

            0.20
            0.16
Ammonia - N (mg/1)


Nitrate - N (mg/1)
Max
Min

Max
Min
0.01
0.16
            0.2
            0.4
                                    2-25

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 Table 2-9 (Continued)



 Dissolved Silica  (mg/1)


 Transparency  (m)
               Surface    180 Feet    270 Feet
Max
Min

Max
Min
 0.6
 0.4

 1
15
2.8
1.4
 Temperatures  of the  coastal waters  vary significantly more than in open
 ocean.   This  is due  to  relative shallowness of the water and, to some
 extent,  the mixing of fresh waters  from the land or because of upwelling.
 The  density of  seawater and its vertical distribution is important to the
 stratification  of marine waters and is determined by the temperature and
 salinity of the waters.  During summers the temperature decreases more sharply
 with depth resulting in a stronger  stratification of the water than during
 winter months when the  thermocline  sinks to greater depth or may be des-
 troyed by the winter mixing of the  water.

 2.7.3 Near Shore Circulation

 In the offshore waters  of the AWMA  region, currents are complex and quite
 variable in direction.  Longshore components (southeasterly currents and
 northwesterly counter-currents) are predominant.  These are part of the
 North Pacific Ocean's system of currents.

 The  major circulation pattern in the North Pacific Ocean is a wind-driven,
 clockwise gyre  that  encompasses the entire North Pacific.  The California
 Current  is the  name  given to the eastern limb of this gyre and is character-
 ized by  a meandering, diffused current flowing southeastward past the states
 of Washington,  Oregon and California, and Baja California.  There is no true
western  boundary to  this current, but more than 90 percent of the south-
 eastward transport is within 450 miles of the coast of California.   North
 of Point Conception, California, the California Current has a mean speed of
 approximately 30 ft/min (0.30 knots).  South of Point Conception, the
 California Current becomes more diffused, and the inshore portion turns north-
ward to  flow  through the channel islands and to become the nearly permanent,
 counterclockwise Southern California Eddy.   The inshore portion of this eddy
 is called the Southern  California Countercurrent.  Surface speed in the
 countercurrent  averages from lOft/min to 20 ft/min (0.10 knot to 0.20 knot).
 The  flow pattern is complicated by  the presence of small eddies within the
 channel   island  region and fluctuates seasonally.   The countercurrent is
.swiftest in the  fall and early winter when  the winds are from the south-
 east.  In spring and early summer, winds from the northwest strengthen the
 California Current and weaken the countercurrent.

 Very  near to  the California coast,  local  currents are influenced primarily
by a  combination of wind, tide, and local  topography.   The total  current
 is ordinarily the sum of its components which include wind, tide,  and
perhaps large-scale ocean circulation.
                                    2-26

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 Wind-induced currents, which are superimposed on the tidal motion, usually
 have a  strong diurnal character resulting from local wind patterns.  There-
 fore, short-term observations of currents near the coast often vary in both
 direction and speed as a result of the combined wind-induced and tidal
 motions.

 An  important consideration in the analysis of nearshore surface currents
 is  the  presence of absence of a thermocline, a layer of water which sepa-
 rates warmer surface water from colder and denser deep water.  Speed and
 direction of currents above the thermocline are usually controlled almost
 wholly  by wind, especially when the thermocline is strong.  When wind blows
 across  a body of water, surface currents are induced which have a direction
 similar to that of the wind.  The magnitude of the current speed depends
 on wind velocity and duration, the orientation and characteristics of the
 adjacent coastline and the depth of the thermocline.  When the thermocline
 exists  at a relatively shallow depth, surface waters may be accelerated rapidly
 by  the wind.  When a weak thermocline exists at relatively greater depth, the
 wind must move a greater volume of water and the induced current speeds are
 slower.  Under these conditions, effects of tidal  action are more evident
 above the thermocline and surface and subsurface water masses tend to move
 more as a unit.  Nearshore currents below the thermocline are governed
 primarily by tidal movement.  Subsurface currents should, therefore, theore-
 tically be onshore and upcoast during flood tide and offshore and downcoast
 during ebb tide.

 Tides along the California coast are of the common mixed type, where two
 unequal high tides and two unequal  low tides usually occur during a 25-
 hour period.  In the eastern North Pacific Ocean,  the tide wave rotates in
 a counter-clockwise direction with the result that the tide occurs progres-
 sively later in the day proceeding northwards along the coast.  As a result
 of this rotation, flood tide flows  upcoast and ebb tide flows downcoast.
 Close to shore, tidal  currents generally parallel  the coast, quadridiurnally
 reversing direction with the change of tide.

 Added to the sum of tidal  and wind  influences, the larger-scale ocean cir-
 culation offshore also influences currents near the coast, although its
 effect is not as strong.   A final  variable is the  result of topography of
 the ocean bottom and the shoreline.

 Current studies conducted off Aliso Creek beach show that longshore currents
 predominate with only occasional  currents directed shoreward at angles
 approaching 45 degrees relative to  the coastline.   The speed of surface
 currents measured off Aliso Creek beach typically  ranged from less than
 0.01 knot (0.01  ft/sec)  to 0.5 knot (0.9 ft/sec) with an average of 0.13
 knot (0.22 ft/sec).

2.7.4  Sedimentation and Characteristics

The offshore sediments of the AWMA  region are generally sand or sandsilt
combinations.   They  are  low in calcium carbonate and consist principally  of
 grains  of sand and silt recently derived from adjacent beaches on the shore-
 line.   Beach sand recharge has decreased over the  years due  to flood control
                                   2-27

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 procedures and reduced stream flows.  The South Coast Regional Coastal Com-
 mission has  recommended that the following watershed areas in the AWMA dis-
 trict remain  in their natural state:  San Joaquin Hills Canyon, Upper Laguna
 Canyon and Aliso Creek.

 2.8  BIOLOGICAL RESOURCES

 The wildlife  areas within the boundaries of the Aliso Water Management
 Agency encompass a large fraction of the relatively undisturbed habitat
 associations  that still remain in Orange County.  Specific site surveys have
 been conducted in El Toro, Laguna Niguel, Moulton Ranch, Capistrano Valley,
 Colinas de Capistrano and the San Joaquin Hills.  Since on-site analysis and
 standardized  species check lists have been prepared for these locations,
 there will be no attempt to duplicate these studies for the AWMA district.
 Rather, a general description of the major terrestrial and marine environ-
 ments will be provided with greater detail being allocated to those areas
 deemed unusually sensitive.

 The terrestrial section will deal with the flora and fauna of the four major
 biotic communities to be found in this area:'  e.g., Coastal Sage Scrub,
 Grassland, Riparian Woodland and Cismontane Rural and Urban.  Wastewater
 management policies have their greatest terrestrial influence within the
 Riparian communities.  Reference will'be made to the South Coast Regional
 Commission recommendations concerning watershed management and restoration.
                                      *,
 Information concerning the Marine Biology of the AWMA district has been
 obtained from the Dawson studies of the Allan Handcock Foundation (1959,
 1965), a study of Ocean Outfall  Locations in Southeastern Orange County
 (1972) and Marine Biological Conditions in the Vicinity of Dana Point
 (Lowery & Associates, 1973).  Comparisons will be made of Intertidal Flora
 and Fauna, Benthic Flora and Fauna, Kelp (Macrocystis), Phyto-Plankton and
 Fisheries.

 2.8.1   Terrestrial  Biology

 2.8.1.1   Regional

 The Aliso Water Management Agency lies within the coastal  hills of southern
Orange County.  Biologically, the coastal  hills region encompasses a range
of Upper Sonoran terrestrial  habitats from coastal  sage scrub to Littoral
marsh.   Since the region is a typical section of the Southern California
 coast,  it represents an ecological  community that is much  like the coastal
 hill  areas southward for several  hundred miles.

The Orange County Planning Department finds that approximately 50% of the
County is covered by natural  vegetation, with most of this occurring in the
northeastern and southern portions  of the County.   Exhibits 2.3 and 2.4 show
the distribution of the biotic,  or vegetative communities  in Orange County
and Exhibit 2-11  gives  the number of acres and percent each community repre-
sents  of the total  County acreage and open space acreage.
                                    2-28

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VEGETATION  COMMUNITIES
                                                          •SACi.ESC.RvjB
                                                        A
                                                          CHAAMSE
                                                          CHAPARRAL
                                                          OAK-
    4 CUt.TlVA.TBD


 RIPARIAN

 (/v\A70R AREAS ONLY)


<' R.OAD PROVIDED FOR
                                                          CSEE TOWR A^AP FOR
         •xhibit 2-3

         Souret: Th« Physical Environment of Orange County

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Wildlife   Habitats
       Upland Birds, Large & Small Mammals
       Upland Birds & Small Mammals
       Small Mammals
Waterfowl & Waterbirds
Marine Life Refuges
  Source: Orange County Progress Report, Volume 10
  Exhibit 2-4

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                                 TABLE 2-10
                 \
                 ' ORANGE COUNTY NATURAL BIOTIC COMMUNITIES

 Community                    # Acres           % of County        % of 0.  Space

 Grassland'"                     77,796             15.22               29.66
 Coastal  Sage Scrub            126,548             24.76               48.25
 Chaparral     ;•                18,165              3.55                6.92
 Oak Woodland   \                6,028              1.18                2.29
 Pine Woodland                  2,371               .46                 .90
 Riparian Woodland              24,649              4.82                9.39
 Freshwater Marsh               1,600               .31                 .61
 Coastal  Salt Marsh             1,729               .34                 .65
 Lakes, Reservoirs              1,743               .34                 .65

                              262,229             50.98


 Coastal  sage scrub and grassland represent the most abundant biotic commun-
 ities in Orange County.  More  than 75% of the Grassland Community occurs in
 an area  encompassing the San  Joaquin and coastal hills south of Laguna Canyon
 and north of the San Diego Freeway at La Paz Road and southeast to the San Diego
 County line.  The remaining 25% occurs in the foothills bordering the north
 and southeastern mountains of the County.  Several large patches of coastal
 sage scrub occur in the coastal hills grassland areas.  However, most scrub
 vegetation occurs in the central  San Joaquin Hills south to Aliso Canyon.

 The extensive tributary system of the County make riparian woodland the third
 most abundant biotic community, although these areas are considerably de-
 graded due to intermitent  stream flow during the summer months.  Laguna
 Canyon, Aliso Canyon, Salt Creek, Oso Creek, Arroyo Trabuco, and San Juan
 Creek represent major riparian woodlands of the southern region.  These
 bands of vegetation provide ecological corridors of the Santa Ana Mountain's
 Cleveland National Forest.
Fresh water marsh is very limited in occurrence in Orange County and almost
nonexistent in the southern region.  Marsh communities of the area are meager
in terms of species diversity and abundance, and only appear in their isolated
springs or on the margins of reservoirs, including Sulphur Creek Reservoir
(now known as Niguel Lake) in the Laguna Niguel, Laguna Lakes and Watershed,
El Toro Reservoir and Lake Forest.

Although cismontane rural vegetation is not indicated on the Orange County
Vegetation Community Map, row and field crops, orchards and eucalyptus
windbreaks in the AWMA district are an important addition to the biotic
communities of the County.  They provide cover and habitat for wildlife
and enhance the quality of the environment  especially on the perimeter of
natural open areas.
                                    2-29

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 Cismontane  urban  vegetation  has  replaced natural  grassland or cismontane
 rural  vegetation  in  San Juan, Oso, Aliso, Laguna  Canyon and Arroyo Trabuco
 Valleys  and along the  coastal terrace.  More recently with the rapid rate of
 land conversion of agricultural  lands to urban, development has taken place
 in  the hillside areas.  Coastal  sage scrub and grassland are now the primary
 vegetation  types  being converted to urban use; however, incorporation of
 native trees and  shrubs within the urban landscaping can enhance the wildlife
 capabilities of surrounding  grassland and scrub areas.

 The relationship  of  Coastal  Sage Scrub and Grassland Communities to the
 Riparian Communities of Aliso, Oso, Laguna, "San  Juan" and Salt Creek Can-
 yons creates an environment  suitable for a wide variety of terrestrial verte-
 brates.  All of these  creeks serve as interconnecting wildlife corridors and
 would enhance the  quality of nearby surrounding grassland and coastal sage
 scrub habitats.

 The AWMA Region lies within  an area described as  habitat suitable for up-
 land birds  and small mammals by the Orange County Planning Department (see
 Exhibit 204).  The Conservation Element (1973) also recognizes the area as an
 important deer habitat.  Nearly all the undeveloped locations in this area
 serve as wildlife  habitat for larger mammals, smaller mammals and upland
 birds, representing about 25.4% of the total habitat available in the
 County.  16.0% of  the  total  County habitat available to waterfowl  and marsh
 birds is represented by the  riparian and fresh water "pond" habitats in the
 area.

 Exhibit 2-12 gives the approximate number of acres, percent of total  site
 each community occupies, and the percent of each Orange County natural
 biotic community occurring in the AWMA area.

                                 TABLE 2-11

                             BIOTIC COMMUNITIES
                                                                  % of County
 Community                    # Acres           % of Site       Natural  Community

Grassland                     9,780              20                  12.6
Coastal Sage Scrub           12,720              26                  10.1
Riparian                      2,200               4.5                 8.9
 Freshwater "Pond"                240               0.5                 7.1
Cismontane Urban-Rural        23,470              48
Chaparral                       490               1.0                 2.7

                TOTAL        48,900             100.0%
                                    2-30

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2.8.1.1  Grassland Community

2.8.1.1.1  Flora

Grassland is a dominant biotic community in the AWMA area and is usually
restricted to soils of high clay content.  Originally, the grasslands of
California were composed of perennial bunch grasses.  The grassland com-
munities have been utilized as open range land for more than a century,
resulting in almost complete destruction of the native grassland species.
Large areas of coastal sage scrub were also converted to grass areas by
early settlers.  Before extensive grazing, probably over 50% of the pre-
sent grassland existed as coastal sage.  Now, these areas maintain a
dense vegetative covering dominated by weedy, non-native annuals such as
Black Mustard (Brassica m'gra), Wild Barley (Hordeum leporinum), Chess
Grasses (Bromus, sp.) and Fescue Grass (Festuca myuros).  Wild Artichoke,
or Milk Thistle (Silybum marianum) appears in dense stands mainly on the
northeast portion of the site.

A wide assortment of wildflowers occur in variable distribution throughout
the Grassland Community.  Most wildflowers ;are rapid growers, shooting up
out of the soil in a matter of a week or two when the weather is satisfac-
tory.  When the weather becomes hot and dry, they disappear with the same
rapidity.  The distribution of annuals has been well documented in (A
Checklist of Orange County Flowering Plants, (Boughey, A.S., 1968, Univer-
sity of California, Irvine).

2.8.1.1.2  Fauna

Aside from its history, the Grassland Community is natural in terms of
plant-animal interactions, although it may contain more introduced and
naturalized species than those native to the area.  The grassland community
is a valuable food source for many animals; it is important to seed eating
birds and those that feed on flying insects.  Rodents and rabbits are also
seed eaters and are preyed upon snakes, raptors, and mammalian predators.

The grasses are also an important food source for animals from adjacent
plant communities.  Many species utilize other communities for nesting   ,
activities and refuge and the grassland community as foraging habitat.

The predominant fauna (greatest biomass) of the grassland community are
the rodents.  The most common varieties are the California Ground Squirrel
(Otospermophilis beecheyi) and mice (Perognathus spp.).   Pocket Gopher
(Thomonys bottae) signs are also commpn throughout the cultivated and
and naturalized grassland.
                                     I
Representing the most common avifauna are Mourning Dove, Western Meadowlark
and the House Finch.   The abundance of prey in the form of small birds and
mammals supports a variety of raptors (vultures, eagles, hawks,  falcons,
and owls).   The raptors require vast areas of grassland or scrub as foraging
territory and the AWMA planning area represents a large county segment of
suitable territory for these species.   Urban development, occurring in ran-
dom sections of the County, can disrupt the territorial  boundaries of raptors,
                                    2-31

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 especially  if that  development  is  close  to  prime  nesting areas.   Since  rap-
 tors  are  an essential  limiting  factor  in  the  control  of rodent populations,
 it is  important  that their  territory be  protected from excessive  urban
 pressure.

 Common  reptiles  are the  Western  Fence  Lizard  (Uta stansburiana).  Gopher Snake
 (Pituophis  eatenifer)  and the Red  Diamond Rattlesnake (CrotaTus ruber)  (this
 species is  becoming less common  because  of  urban  pressures).Amphibians
 are not common to the  grassland  community unless  it is adjacent to a stream
 or reservoir.

 Mule  Deer are a  common visitor  to  the  undisturbed grassland community as
 are Coyote,  Grey Fox and Bob Cat although these animals are more  cautious
 in their  habits.  Since  these animals  cover tremendous amounts of terri-
 tory  during their foraging  activities, it is  important to recognize the  im-
 portance  of community  corridors.   The  blending of a grassland and riparian
 community would  be  considered.an ecotone.   The organisms that colonize  these
 are common  to both  communities along with a number of versatile species  that
 have  a tendency  to  colonize such transition areas.  This tendency has also
 been  described as the  zonation effect.  But whatever  the terminology, one
 can expect  to find  the greatest  amount of species  diversity and population
 numbers within these zones.  The National Audubon  Society strongly recommends
 the preservation and planting of zonation areas to upgrade the habitats avail-
 able  to wildlife suffering  from  urban pressures.

 2.8.1.2   Coastal Sage  Scrub Community

 2.8.1.2.1   Flora

 The Coastal  Sage Scrub Community encompasses approximately 28% of the AHMA
 area.  Much  of the  San Joaquin Hills, the hills above Laguna Beach, and
 the area  throughout  Laguna and Aliso Canyons provide examples of  this coastal
 sagebrush.   The dominant shrub,  California  Sagebrush  (Artemisia californica),
 appears in dense stands.  Sawtooth Goldenweed (Haplopappus squarrosas), and
 California Buckwheat (Eriogonum  fasciculatum), two major subdominants, appear
 scattered throughout the community and occur in high concentrations on its
 periphery.   Turkey Mullein  (Eremocarpus setigerus), a low, grey herbacious
 plant, occurs  in wide expanses along the periphery of the Coastal  Sage
 Scrub community mainly on its western boundary.

 The Coastal  Sage Scrub Community usually serves as an excellent wildlife
 habitat.  The  diverse floral component of the community can result in an
equally diverse faunal component although urban and grazing pressure
have substantially reduced the Coastal  Sage Scrub Community within the AWMA
area.

Areas adjacent to Serrano Creek  (El Toro) exhibit typical  native  wildlife
populations characteristic of scrub communities.   Pure stands  of sagebrush
and buckwheat support comparatively reduced numbers of vertebrates,  since
dry soils are typically compacted and foot diversity is  reduced.   On the
other hand, Prickly  Pear Cactus  associations,  north facing slopes  and
arroyos that exist along the San Joaquin  Hills, Laguna Canyon  and  Aliso
Canyon can provide adequate  habitats for  a mixed  and stable variety  of
native vertebrates.
                                    2-32

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The avifauna for the scrub community, is represented by California Quail,
Western Roadrunner, Cactus Wren, Loggerhead Shrike, Brown Towhee, Common
Bushtit and the California Thrasher.  Common Reptiles are the Western
Whiptail (Cnemidophorus tigris) and the Coachwhip (Masticophis flagellum).
The blacktailed hare (Lepus caliform'cus) and the Brush Rabbit (SylviVaus^
brachmani) are common.TnT rodents are represented by the Pacific Kangaroo
Rat (Pipodmys agi,lis), Desert Woodrat (Neototna lipida) and the Deer Mouse
(Peromyscus man icu1 atus).

Undisturbed areas of Coastal Sage Scrub habitat are now scarce in the coas-
tal hills.  They are subject to damage by vehicles and by too heavy pedes-
trian use, as well as the larger threats posed by housing developments.
There are some excellent sites in the San Joaquin Hills (Pelican Hill being
one).

True chaparral communities do occur in association with the Coastal Sage
Scrub and can be identified by the presence of Chamise (Adenostoma fascicu-
latum), Toyon (Photi nla arbuti foli a) and Scrub Oak (Quercus dumosa).  Cha-
parral is one of Southern California's most fascinating plant communities.
It is a unique vegetation type.  There are only four other places in the world
where vegetation comparable to coasta-l  chaparral is found.  It is a dense,
well-developed habitat type, growing in a rather inhospitable region and
exhibiting unique adaptations for survival.' It is part of our cultural,
as well as our natural, heritage.  In this report, however, the chaparral
has been grouped with the coastal sage scrub since the habitat and animal
associations are quite similar.

Two bird species are endemic to coastal  sage scrub and chaparral, the
California Thrasher and the Wrentit.  (Endemic means native to a region
or habitat type and not found elsewhere.)

At present, chaparral is relatively abundant.  This is a good time to
designate large areas for preservation.   The acreage for each would have
to be extensive (1,000+ acres) in order to support the larger mammals which
reside there.   The South Laguna Hills have choice areas of chaparral.

2.8.1.3  Riparian Communities

2.8.1.3.1  Flora

The AWMA district contains approximately 16% of the undeveloped riparian
and freshwater pond habitat in Orange County.  The South Coast Regional
Coastal Commission has designated the, San Joaquin Hills and Canyons, Laguna
Lakes and Watershed, Aliso Creek and Watershed and the South Laguna Hills
as priority areas that must be protected from intensive development.  The
quality of the riparian habitat in these areas is dependent on the avail-
ability of water and its inaccessibility to human influence.

Stream flow augmentation during periods  of summer drought has been pro-
posed by AWMA and would utilize secondary and tertiary treated wastewater.
This concept has been endorsed by the California Department of Fish and
Game and the South Coast Regional  Coastal Commission.   Live stream flow
                                    2-33

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 throughout  the year  has  the potential  to  increase the species diversity
 and  productivity  of  riparian habitats.

 The  intermittent  streams  usually carry just enough subsurface water to
 support  scattered patches of Mule  Fat  (Baccaris viminea), Mugwort (Artemesia
 douglasiana), Tree Tobacco (Nicotiana  glauca), Horehound (Murribium vulgare),
 and  a  few individuals of  Arroyo WillowsTSaTix, spp.).  Other important
 herbacious  species include Graphalium, Brassica, Erodium, and a variety of
 annual grasses.   With a slight increase in topography away from the stream,
 riparian vegetation  is quickly replaced by grassland.

 Riparian communities with continual stream flow display large canopy pro-
 ducing trees.  Cottonwoods (Populus fremonti), California Sycamores (Platanus
 racemosa),  and California Black Willows (Salix goodingii) are dominant trees
 that require good stream  flow in order to survive.  The survival of these
 species  ensures the availability of habitat for predatory birds so essential
 for  the  balance of rodent populations.  When stream flow is maintained it
 will be  possible  to transplant these trees into presently degraded riparian
 habitats.

 The  lack of tall,  full riparian, woodland trees, and insufficient amounts
 and  duration of running water have caused the riparian community to be low
 in plant species  diversity and stratification.  The condition of low faunal
 diversity has resulted.  The occurrence of dense stands of Mule Fat, Mug-
 wort, and Tree Tobacco limits the total variety of wildlife species possible,
 but  does allow populations of a few species to flourish.

 Water is a  limiting factor in wildlife distribution, and animals are often
 concentrated where it occurs.  All  of the larger predators of the region
 are  found around  the reservoir margins and live streams.  Various species
 of amphibians are  restricted to the freshwater habitat and waterfowl and
 marsh birds will   utilize the reservoir for refuge and foraging activity.

 2.8.1.3.2   Fauna

 Riparian fauna is  perhaps the most diversified of all  the associations when
 adequate habitat  and water are available.   Sections  of Serrano Creek and
 Aliso Creek that  remain moist throughout the year express maximum wildlife
 diversity.   Several amphibians, salamanders and frogs  such as the slender
 salamander  (Batrachoseps spp.) and  the Pacific Tree  Frog (Myle regilla)
 are  restricted to  the moist micro-environments occurring along creeks  and
 reservoirs.   Rodent diversity is somewhat reduced on the steep slopes  of
 ravines,  but the California Mouse (Peromyscus cal iform'cus)  and Dusky-
 footed Woodrat (Neotoma fuscipes) are well represented.

 Bird diversity and activity is correspondingly greater within the Riparian
 Community since available habitats, food and nesting sites  are maximal  when
compared  to  grassland and coastal sage scrub.   Large covies  of Quail  are
 to be found  in thickets of poison oak and  foraging in  nearby open fields.
Several  other ground-dwelling birds such as the Ground Dove,  Horned  Lark,
and the Rufous-sided  Towee also prosper here  while in  the upper tree canopy
predator  species  of Red-tailed Hawk,  Marsh Hawk and  Sparrow  Hawks can
                                    2-34

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occasionally be observed nesting.  One endangered species, the Peregrine
Falcon (Falco peregrinus), is probably an infrequent visitor to the
riparian areas of the AWMA district.

Riparian woodland is extremely scarce in the coastal zone.  It is also
endangered because the canyons are so desirable for housing developments.
There are still several  choice canyons in the AWMA area, notably Moro,
Emerald, Los Trancos, Aliso in the San Joaquin Hills.

2.8.1.3.3  Southern Oak Woodland

The Southern Oak Woodland is found chiefly inland and is rare in the coas-
tal zone.  It is often associated with the Riparian Woodland Community
and is therefore included,in acreage represented by this community.  This
community is found in upper Wood Canyon along Aliso Creek, in Willow and
Camarillo Canyons which drain into Laguna Canyon, in the middle and upper
reaches of Los Trancos,  Moro, and Emerald Canyons, and in Shady Canyon.

Plant species include the Coast Live Oak and Engleman Oak (Quercus
agrifolia and Q. engelmanii), and the California Walnut (Juglans cali-
form'ca) "as the dominant trees.  Sumacs (Rhus sp.) are the main shrubs.

Amphibians include several more species of salamander than are found in
chaparral, like the Arboreal Salamander (Aneides lugubris).  The reptiles
are similar.  Birds are  numerous.  Most of the species found in coastal
sage scrub and chaparral are here.  Hawks, owls, and ravens nest here.  In
addition, migratory passerines (perching birds) use the oak woodlands en
route.  Several species  come to breed, such as the Warbling Vireo (Vireo
gilvus) Northern Oriole (Icterus galbula), and Western Wood Pewee (Conto-
pus sordidulus).

2.8.1.4  Rare and Endangered Species

2.8.1.4.1  Fauna

Society has acknowledged both on the federal  and state level  its respon-
sibility to protect and  preserve wildlife species threatened with extinc-
tion.   The Federal  Endangered Species Preservation Act of 1966 and the
California Endangered Species Act of 1970 defined such species and auth-
orized measures to protect them.  Lists of endangered species were drawn
up and are periodically  updated.  As of January 1974, there are several
birds  on the federal and state rare and endangered species lists which
reside in or frequent the AWMA Region.

The AWMA area is ornithologically important because of the role it plays
in the lives of a number of rare and endangered species of birds, as well
as several birds fast approaching the endangered status.  A pair of
Golden Eagles are known  to nest in the vicinity of lower Aliso Creek and
appear to be permanent residents of the AWMA region.  During the spring
of 1975 a pair of immature eagles were observed in addition to the
adults; however, it is not known whether these are transitory or off-
spring of the adult breeding pair.  In 1974,  the California Fish and Game
                                  2-35

-------
 Commission extended  full  legal  protection  to  Golden  Eagles as well as the
 Osprey and White-tailed  Kite which  have also  been observed in AWMA.
 These species  are  not considered  rare or endangered, but their declining
 populations warrant  special attention.


 The  endangered Peregrine  Falcon and Brown  Pelican may be infrequent visi-
 tors to the area.  Prairie Falcons  have been  observed more regularly in
 the  area  and have  been considered threatened  by the  U.S. Fish and Wildlife
 Service.   These  rare  species may be approaching the  endangered status.
 The  Bel dings Savannah  Sparrow has recently been added to the California
 Fish and  Game's  endangered status and may occur in isolated habitats along
 the  AWMA  coast.  The  Yellowbilled Cuckoo (Coccyzus americanus), indicated
 as rare by the California Fish and  Game Commission,  may also frequent the
 area during its  migration flights and is primarily restricted to the Riparian
 woodland  community.

 Twenty avian species which have been observed or can be assumed to fre-
 quent the  area are exhibiting rapid population declines and limited
 distribution.  These  species appear on the 1973 edition of the Audubon
 Society Blue List  (See Table 2-12).  All of these rare, endangered, or
 threatened species except for the small passerines,  require vast areas
 in order  to  maintain  themselves.  The area most of the AWMA area repre-
 sents  is  an  important  foraging habitat for the birds of prey, representing
 a significant  portion of their total foraging territory.

 Although  no  reptiles occurring in this locality are  included in the Cali-
 fornia  Department of  Fish and Game  listing of California's Endangered
 Species and  Rare Fish and Wildlife, Southern California populations of
 Southern Alligator Liazrd, California Legless Lizard, Rosy Boa, Orange
 Throated Whiptail and  Ring-necked Snakes are considered threatened due to
 heavy  collection pressure by amateur naturalists and commercial pet dealers.

 There are  no amphibians occurring within the AWMA region that are con-
 sidered rare or endangered although the Large Blotched Salamander, Southern
 Slender Salamander and the California Canyon Tree Frog population are
 considered  threatened in Southern California.   None of the mammals or
 rodents occurring within AWMA area are considered rare or endangered,
 however, the numbers of larger carnivores are declining rapidly over much
 of the  region.

 2.8.1.4.2  Flora

At the present time, rare and endangered plant species are not given legal
 protection such as that extended to animal  species.   Essentially,  the
same arguments, however,  can  be made for preservation of the  necessary
habitat to sustain threatened plants as can be made for animals.   It is
 part of man's responsibility  for stewardship and it is  a necessary step
 in understanding the complicated natural  systems which  are found  on the
earth.  Such preservation may yield practical  benefits  not now anticipated.
A species  lost through man's  carelessness  by technological  solutions.   Man
does  not (and never will) possess  enough knowledge to consciously  choose
extinction over other alternatives.
                                  2-36

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                             TABLE 2-12

                     DECLINING SPECIES OF BIRDS
                EXPECTED TO FREQUENT THE AWMA REGION
                            ,  Endan-
                        Rare   gered
Brown Pelican
Black-crowned Night Heron
White-faced Ibis
Sharp-shinned Hawk
Cooper's Hawk
Red-shouldered Hawk
Swainson's Hawk
Ferruginous Hawk
Marsh Hawk
Prarie Falcon
Peregrine Falcon
Sparrow Hawk
Yellow-billed Cuckoo
Barn Own
Burrowing Owl
Purple .Martin
BewickVs Wren
Western Bluebird
Mountain Bluebird
Loggerhead Shrike
Bell's Vireo
Gray Vireo
Yellow Warbler
Bel ding's Savannah Sparrow
Pelecanus occidental is
Nycticorax nycticorax
Plegadis chihi
Accipter striatus
Accipter cooperii
Buteo lineatus
Buteo swainsoni
Buteo regal is
Circus cyaneus
Falco mexicarius
Falco peregrinus
Falco spaverius
Coccyzus americanus
Tyto alba
Speotyto cunicularia
Progne subis       -
Thryomanes bewickii
Sialla mexicana
Sialia curruoides
Lanius ludovicianus3
Vireo bellii
Vireo vicinior
Dendroica petechia
Passerculus sandwichenis
  beldingii
                                                                        Rare*1
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
1 Listing of California's Endangered and Rare Fish a.n,d Wildlife adopted
 by the California Fist) and Game .Commission, :May .21, 19.71..
2A'Udubon Sociiety Blue List
3
 Observed

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 The  California  Native  Plant  Society  has  prepared a  list, by county, of the
 native  plants which  appear to  be  rare or endangered.   In Orange County,
 there are  six endangered  species, all of which grow in the coastal zone.
 Three are  in the  same  Genus  (Dudleya) of the Stonecrop family.

      1.    Cardamine  gambelii - Common name, Bittercress.  Grows in
           coastal  sage scrub and  chaparral.

      2.    Chorizanthe  chrysaacantha  - Grows only in  Orange County on
           ocean bluffs  in coastal sage scrub.

      3.    Cordylanthus  maritimus  - Common name, Bird's Beak.  Saltmarsh
           plant found  only in  this habitat.

      4.    Dudleya  multicaulis  - Common name, Live Forever.  Grows in coastal
           sage scrub and  chaparral.  Grows in hills  of Laguna Beach.  Also
           found in the Santa Monica  area.

      5.    Dudleya  stolonifera  - Found only in Laguna, Willow, and Aliso
           Canyons.

      6.    Dudleya  viscida - Grows in coastal sage scrub in San Juan
           Capistrano area.

2.8.1.4.3  Endangered  Habitat Types

An endangered habitat  type is as real an entity as an endangered species.
In many cases, loss of  habitat is the prime cause for the decline in num-
bers of a  species  to endangered status.   Preservation of critical  habitats
means protection of potentially endangered species.   It is preventative
medicine,  and is far easier to apply at  the endangered habitat stage than
at the endangered species stage.   In recognition of  this situation, the
State Legislature passed the Ecological   Reserve Act  in 1968 to protect
rare or endangered wildlife or aquatic organisms or  specialized habitat
types by authorizing the acquisition of  land and water areas as Ecological
Reserves.

Of the eight major habitat types  in the south coast zone,  only one is
abundant in Southern, California,  the chaparral  community.   Six are rare
in an undisturbed state:  coastal  strand, coastal  sage scrub,  riparian
woodland, oak woodland, saltmarsh and freshwater marsh.  One is close  to
extinct, natural  grassland.   Freshwater and saltwater marshes are our
rarest and most endangered habitat types.

An endangered habitat priority list has  been compiled from many sources,
including  the Los Angeles County  Environmental  Resource Committee Report,
the California  Coastline Preservation and Recreation Plan  (1971),  the  Cali-
fornia Comprehensive Ocean Area Plan (Appendix  LX),  and recommendations
from experts in  the fields of Biology,  Ecology  and  Conservation.

The following Priority Areas  occur in the AWMA  region:
                                  2-37

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       N
                                      ENDANGERED HABITAT TYPES
SO. ANAHEIM BA
S1. GOLDEN WEST
     PONDS

    BS. BOLSA BAY
  HABITA
  SAND SUPPLY
     B3. NEWPORT MARINA
     a*.  UPPER NEWDORT
       •Lun^s AND BIG CANYON
EB. SAN JOAQUIN

        BB. PELICAN
   E7. SAN JOAQUIN
         EB. LAC


            BB

     3O. ALISO CREEK

                3B
                                                                 RANGE
                                                                COUNTY

                                                                PRIORITY
                                                                 SITES
                                                                 HABITATS
                                                                 AIMO
                                                                SUPPLY  AREAS
                        33. SAN
                                                                  Exhibit  2-5

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 Pelican  Hill  -  Coastal sage scrub.   Favorite local field trip site for
 school groups.   Good example of  unspoiled coastal sage scrub.  Area of
 unusual  geological and archaeological  interest.

 San  Joaquin Hills - Riparian woodland, oak woodland, coastal sage scrub.

 Chaparral, grassland.  Several undisturbed canyons which are choice habi-
 tats.  Los Trancos, Moro, and Emerald-Boat, Shady and Willow Canyons are
 exceptionally fine, unspoiled areas.  One or more endangered plant species.
 At least several canyons and the hills between should be preserved as
 natural areas.

 Resident deer herd.

 Open spaces on  surrounding hills are fine hunting grounds for the large
 birds of prey.

 Laguna Lakes  and Watershed - Freshwater marsh, grasslands, coastal sage
 scrub adjacent  to one lake.  Good bird habitat.  Flora includes several
 uncommon aquatic species.

 Aliso Creek and Watershed - Riparian woodland, coastal sage scrub, cha-
 parral, grasslands.  Very rich habitat, varied flora.  Several  endangered
 plant species.  Many water-associated bird species in lower creek.

 South Laguna  Hills - Coastal sage scrub and chaparral outstanding.

 Wood Canyon - Oak woodland.  Part of the watershed of Aliso Creek (#30).
 An oak-wooded canyon, rare in the coastal hills.

 Niguel Lake (Sulphur Creek Reservoir) - Freshwater marsh.

 Approximately 60% of the AWMA area represents unique or endangered.habitat.
 Current trends  in environmental  concern and sensitivity will limit growth
 in these areas  to very low densities, and in many critical  habitats  no
 development will be allowed.

 2.8.2  Marine Biology

 The marine biology of the AWMA is currently subject to heavy urban pres-
 sure in the form of tide pool  collecting and waste water discharge.   The
 scientific value of the coastal  sections of the AWMA district has been >
emphasized by the creation of marine life refuges in the Laguna  Beach,
Aliso Beach and the Salt Creek areas.  The South  Coast Regional  Coastal
 Commission has recommended that an additional  refuge be dedicated along  the
coastal  area of the San Joaquin  Hills between  Newport Beach  and  Laguna
Beach.

 Information sources have already been cited in  the introduction  to the
Biological  Resources  Section.   Analysis will  be limited to  five  categories:
 Intertidal  Flora and  Fauna, Benthic subtidal  Biota,  Kelp Populations,
Phytoplankton  and Fish  Populations.   Discussion will  be centered  on Aliso
Beach and vicinity,  the location of the proposed  AWMA ocean  outfall.
                                  2-38

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 2.8.2.1   Intertidal Flora and Fauna

 The diversity of the intertidal and near subtidal flora and fauna of any
 area,  in  terms of the number of species and their abundance, depends on
 the interaction of many factors.  The nature of the substrate is probably
 the most  critical.  Hard rock always supports more luxuriant biota than a
 substrate which is friable, while a friable but solid substrate supports
 more than cobbles, travel or sand.  The surface topography also has an
 important effect in that the presence of tide pools increases the luxuriance
 by comparison with areas where tide pools are lacking.  Sand beaches contain
 quantities of plants and animals of small size, even unicellular, which
 normally  descend below the surface during low tide periods.  The total
 productivity of such sandy areas is low by comparison with the rocky areas
 of intertidal and immediate subtidal.  It should be appreciated that there
 are marked seasonal variations in the quantity of plants and animals pre-
 sent in both the rocky and sandy areas of the intertidal and near subtidal.
 In the vicinity of large urban populations, various factors are operating
 which  depress the quantities of plants and animals which occur in the inter-
 tidal   and immediate subtidal.  The most immediate of these factors is "people
 pressure" due to collecting by investigators, the large-scale depredations
when large school  classes are taken to the. beach and the indiscriminate
 general trampling by the merely curious.   Air pollution components have been
 shown  to have an inimical effect on-the intertidal flora.   Effluent discharges
have often been blamed for changes in flora and fauna although direct proof
 is lacking that they are responsible; other than in very close proximity
 (10m.) to the actual  outfall.

At the mouth of Aliso Creek where it meets the sea, a sandy beach and a
 fishing pier mark the site of the well-developed recreational  facility of
Aliso Beach.  The beach is of coarse sand with a steep surf scrap.  The
reefs   to the north and south of the beach are used for fishing and there is
considerable slaughter of mussels and other shell  fish for bait.  These
reef areas are characterized by large blocks of stone covered with curtains
of yellowish-green Enteromorphora.

The surf pounds heavily against these formations,  causing  the movement of
large quantities of sand which has  a pronounced effect on  the marine flora
and fauna.  Sandy channels at the base of the blocks are lined with
Gracilariopsis andersonii.  In the surf grass region sparse populationsjof
red algae (Laurencia) exist while filamentous diatoms inhabit the higher
shallow tide pools.   There are numerous barnacles  and sea  urchin and star-
fish remaining.  In summary, it can be stated that the Aliso Beach area is
subject to heavy people predation and the remaining biota  i.s quite unre-
markable.

Just north of Aliso Beach is an area named Goffs Island that is more repre-
sentative of the marine life along tihe  AWMA coastline.   The substrate is
composed of broken concrete slabs and reinforced concrete  bulwarks which
lessen the force of the waves and maintain a small  sandy beach.   The
stripped shore crab (Pachygrapsus crassipes) and the purple sea urchin
(Strongylocentrotus  purpuratus)  cause considerable damage  to algae growths.
                                   2-39

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 The high  intertidal region supports a fine series of the common brown
 algae  (Pelvetia, Hesperophycus, Halidrys, Egregia, and Eisenia).  Rocky
 pools  support  red algae  (Gelidium and theheavily grazed Prionitis) and green
 algae  (Ulva, Enteromorpha, and Chaetomorpha).  Extensive "meadows" of these
 also form on top of mussels in flat areas.  Many warm shallow pools contain
 the jointed corallines,  particularly Corallina and some Bossiella.  There
 are heavy, dense turfs of Lithothrix occupying large areas of the mid-
 intertidal platforms, and lower down it completely dominates concrete
 blocks on the  sheltered  side of the large reef.  The naturally occurring
 reef rock is heavily occupied by Halidrys, other brown algae, and other
 corallines.  The outer,  surf-exposed sheer face supports a large mussel
 population and great quantities of common red algal species (Laurencia,
 Erythrocystis, corallines) as well as brown algae (Egregia and Eisenia)
 and numerous tufts of the less frequent green, Derbesia.  At times the
 kelp beds offshore at this location are especially apparent.

 The diversity of the marine life in this area is a close approximation
 of the natural state of  a relatively undisturbed intertidal habitat along
 the AWMA  coastline.  It  is recommended that this area be considered a repre-
 sentative coastal community for any future coastal  impact studies.

 2.8.2.2   Benthic Subtidal Biota

 The submarine coastal .topography of Southern California differs markedly
 from most other parts  of the world because the continental  shelf is very
 narrow here.  It has a width of approximately one mile off Aliso Beach.
 The area  under study has a bottom composition of soft sand with increasing
 amounts of rocks adjacent to headlands and points.

 North  (1971 a) attempted to update the work of the Alan Handcock Foundation
 Studies (1959, 1965 b)  and the Southern California Coastal  Water Research
 Project Report (SCCWRP 1973) by studying the benthic biota of the Aliso
 Beach sewer outfall and other locations.

 Previous  studies have  shown that between Newport and San Diego, the rela-
 tively narrow shelf was occupied by an outer zone characterized by the
 Amphiodia community, in which several  species of the brittle-star genus
 Amphiodia occur.

 Inshore and in shallower water several  associations occur in various  parts
 of Southern California.  The Diopatra ornata association occurs in areas
where kelp, broken rock, gravel  and shells are prominent.   A second asso-
 ciation dominated by Northria (a polychaete worm) and Tellina (a clam)
 occurs particularly on  sandy bottoms.   It should be appreciated that,
 unlike most terrestrial  associations  where the fauna often  occur in rela-
 tively precise numbers, subtidal  communities or associations characterized
 by particular animal species are much more imprecise so that they are  often
 regarded as too subjective for any purpose of classification.

 The most recent work by North tended  to collaborate earlier findings of
 population density and  made note of high numbers of Listriolobus  recorded
within the sampling areas.  All  stations sampled demonstrated a high
                                  2-40. .

-------
 amount of species diversity which may be interpreted as indications of a
 normal benthic community, relatively free of pollutant materials.

 2.8.2.3  Kelp Populations (Macrocystis pyrifera)

 There has been a considerable decline in kelp beds off the AWMA district's
 coastline from 1950 to 1960.  At present there are only a few isolated
 patches of macriocystis off the coast of Laguna Beach, and their survival is
 in considerable doubt.  The ecology of kelp beds has been described in con-
 siderable detail by North (1971 b) and the economic benefits of kelp bed
 resources has been studied by North and Hubbs (1968).

 It is presently impossible to pinpoint the cause of the disappearance of
 kelp off the Orange County coastline, but a popular hypothesis places the
 blame on warmer ocean temperatures as the cause of the decline.   The
 effects of discharged wastes on kelp has been studied by North (1964).
 Although no definitive conclusions were reached, the study does  seem
 to indicate that ocean discharge does not have a serious impact on the
 surfival of Macrocystis.  Exhibit 2-6 provides a visual summary of the
 decline of kelp.

 2.8.2.4  Phytoplankton
                                  i
 The phytoplankton are the major primary producers in Southern California
 ocean waters.  Phytoplankton serve as the base of the marine food chain
 and in this sense are critically important when one considers biological
 concentration of toxic wastes and tolerance limits of nutrient levels.

 Numerous studies have been conducted on the cyclic nature of phytoplankton
 populations.  The results are summarized in the SCCWRP report of 1973.  No
 attempt will be made to summarize the data at this time.  However, it must
 be noted that ocean outfalls displacing primary effluent and digested sludge
 have been shown to exert a pronounced localized effect on phytoplankton
 growth cycles.

 Studies, other than those described in the SCCWRP report, have not been
 attempted along the coastline of the AWMA district.   However, the new •
 Federal  and State Ocean Discharge Requirements are expected to reduce the
 levels of nutrient enriched wastewater that is discharged to the ocean.

 2.8.2.5  Fish Populations

 Although innumerable publications are available dealing with some aspect
 of fish, fishing or fisheries in Southern California, general summary
 compilations oriented with respect to the present type of study  are rare.
 The recent SCCWRP Report (1973)  gives an excellent general  summary of
existing information as it applies to the Southern California Bight.

 Regarding the fish populations reported from the immediate vicinity of
Aliso Beach, the best summary of data is, understandably, in the posses-
 sion of the Department of Fish and Game, and we acknowledge with thanks
 the opportunity to consult their manuscript sources.
                                 2-41

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                                                             0       I       2
                                                                 Stct. Wilas
 1958
 (96!
 196?
 1970
         Historical variations  in the occurrence and extent of kelp beds
         between Laguna Beach and Dana Point (North, 1972).
Exhibit  2-6

-------
 If  one  considers  the area within a radius of three miles of Aliso Beach,  •
 one can consider  the fish populations in a number of broad categories, as
 follows:

 Pelagic species.  These are species characteristic of deep ocean waters
 and only some have  the habit of entering the immediate coastal waters.
 Albacore and Blue-fin rarely come within 10 miles of the coast except
 occasionally in late summer (September).  Pelagic species found most fre-
 quently off Dana  Point include Jack Mackerel, Pacific Mackerel, California
 Barracuda and the Northern Anchovy.

 Bottom-living species on sandy bottoms.  Such habitats are characterized
 by  Grunion, Corbina, various Croakers and Surfperches.

 Rocky inshore bottoms, including kelp beds.  Such habitats are exceedingly
 diverse  in the number of species which occur because of the widely diverse
 conditions which prevail, particularly in the presence of kelp.  Species
 found include numerous Rockfishes, Cabezon, Basses and Perches.

 Fish populations are significant as recreational and commercial resources
 and, from the aspect of public health, may serve to transmit to man unde-
 sirable  materials through man's consumption of seafood.  There are several
 hundred  coastal marine fishes listed for the State of California as occurring
 in  shallow water  (i.e., less than 300 feet).  The diversity of fish popula-
 tions found at any one place or time is related to a large number of factors,
 such as  depth, bottom relief, substrate, etc.  It is therefore difficult to
 discuss  fish populations other than in general  terms because of the complex-
 ities of diversity and of food preference and availability.   The presence
 of  kelp  improves offshore values although no fish specie's associated with
 the Southern California kelp beds seems to be completely dependent on the
 kelp for survival.

 Elements of all these habitats and types are the target of sport or com-
 mercial  fisheries  in the Dana Point area and represent an economic re-
 source on the order of $500,000 per annum.

 2.8.2.6  Marine Life Refuges

 Major portions of the shoreline in the AWMA study area have  been desig-
 nated by the State Legislature as Marine Life Refuges.   The  impact of
 human actions on important shorelife has been considerable in the past and
 has thus prompted  the above  legislation.   Exhibit 2-7 shows  the relation-
 ship between the preserved areas and proposed ocean outfall  line alterna-
 ti ves.

 In reviewing the importance  of these preserved  rocky shore regions in
 light of the effects of an ocean outfall,  the following factors should
be considered:

     1.    Ocean outfalls  have  already operated  for several years in  these
          regions  without apparent adverse  effects.
                                  2-42

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Exhibit 2-7

                                                                  ff*^  *  JL "   ./••*/2l«^1^ 'v"-:  //£rr^^^^*5£7"' li-'i\^
                                                                  point WS>k^l^1/?;:-\^ s
                                                                                               ;t- ?-:; LL.
                                                                                         ^.-••!l»'n«'Kia\-.VJ1f/ III


                                                                                                   ffi
LU
Li.

-------
      2.    Human  molestation of marine  life  in the area has already taken
           a  considerable  toll.

      3.    Continued  preservation of the refuges  is considered very impor-
           tant and protection should be encouraged.

      4.    In  a report entitled "An Evaluation of the Health of the Benthic
           Marine  Biota of Ventura, Los Angeles,  and Orange Counties,"
           February 1972,  prepared by Rimmon C. Fay, Ph.D. and Associates,
           for the Southern California Association of Government, Dr. Fay
           notes  that these refuges are presently not particularly productive
           of  marine  life.

                                 TABLE 2-13

                             MARINE LIFE REFUGES
Newport Beach/
   Irvine Coast
Laguna Beach


South Laguna
Niguel-Dana
  Point
Doheny Beach
Poppy Ave. in Newport     2,800
  Beach to Northern
  Limits of Laguna Beach

McKnight Drive to         5,725
  Aster Street

South of Aliso Pier       2,700
  to Eagle Rock Way

South end of Three       12,000
  Arch Bay to Dana        3,500
  Point

Doheny State Park         6,400
  200



  600


  600
1,200
1,200
  600
10905



10904


10906
10911
10907
10908
The San Diego Regional Water Quality Control Board has tentatively identified
the Marine Life Refuges as areas of "special biological significance."  In
these areas, natural water quality conditions are to be maintained and wastes
are to be discharged at a sufficient distance to maintain natural  water qua-
lity.

2.9  ARCHAEOLOGICAL RESOURCES

2.9.1  Introduction

The coastal  province of Orange County has been inhabited by Man for thousands
of years.   Relatively sedentary populations existed six to eight thousand
years ago.  Throughout the total prehistory of this region Man lived from
natural food yields; agriculture was not introduced until  the arrival  of
                                    2-43

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 the Spanish in the late eighteenth century.  Terrestrial resources, partic-
 ularly plant foods, played a major role in the diets of these people.  Seed
 bearing plants and other resources populate in the coastal sage community
 were emphasized.

 Early lifestyles focused almost exclusively upon gathering of food re-
 sources; little hunting or fishing was practiced.  Camps tended to be
 located in the rolling terrain of the foothills or along the coastal ter-
 race; each camp reflected a similar range of activities.  This type of
 settlement persisted until 500 to 1000 A.D.  During this time, trends
 toward population growth and increased cultural complexity were develop-
 ing.  A greater range of resources was exploited and the utilization of
 those previously acquired was intensified.  These changes brought about a
 gradual de-centralization of activity.  Temporary camps were founded in a
 variety of resource zones to take advantage of seasonal abundance.  Sea-
 sonal  sites were also utilized during times of stress when populations
 probably lived in small household units.  The settlement pattern of later
 peoples consisted of a basecamp and a variety of seasonal campsites.
 Historically, coastal Orange County was occupied by the Gabrielino and
 Juaneno Indians.  Aliso Creek was the dividing line between these two
 peoples.

 Archaeological  sites are the remnants of human activity.  They represent
 location used repeatedly or areas of short term intensive use.  Sites
 represent, for the most part, a significant amount of activity rather than
 an isolated event.

 Archaeological  sites are non-renewable; once disturbed, losses cannot be
 replaced.   Most archaeological  deposits are very susceptible to destruc-
 tion.   They tend to occur on the surface and are limited in depth; few
 deposits will  exceed three to four feet.  A great deal  of the knowledge to
be gained from these sites is derived from the association of objects and
 the frequency of objects per unit volume;  therefore minor disturbances may
 result in great losses.

2.9.2   The AWMA Region

The Aliso Water Management Agency (AWMA) includes foothills of the Santa
Ana's, the eastern extreme of the coastal  plain,  the San Joaquin Hills and
 the coast from Newport Beach to Dana Point.  A full  range of aboriginal occu-
pation sites may be found within this district.   Approximately 150 archaeo-
 logical  sites have been recorded within AWMA.

 Data concerning archaeological  sites in this region has been compiled since
 the 1930's;  however, the bulk  of recorded sites  have been submitted during
 the last five years.   Environmental  impact reporting has stimulated syste-
matic  archaeological  reconnaissance.   A number of archaeological  surveys
 have been conducted within AWMA in connection  with EIR's.   The data derived
are of two types:   systematic coverage yielding the location of  a  high per-
centage of the  archaeological resources or a general  reconnaissance yielding
an impression of the archaeological  resources  (but not  necessarily the loca-
tion of a high  percentage of the sites).   Despite the lack of complete
                                    2-44

-------
 coverage of  the region and the variability in reporting of those areas
 covered, AWMA  is one of the better recorded regions within Orange County.
 With  the exception of several small canyons between Newport Beach and
 Laguna Beach,  current site distributions are representative of varying
 site  densities within AWMA.  Probably 70 to 75 percent of the archaeolog-
 ical  sites have been recorded within this area.

 2.9.3 Description of Archaeological Sites

 Archaeological sites fall into several general categories defined by the
 extent of use, time period of occupation, and the associated features of
 the environment.  Middens, deposits composed usually of a variety of occu-
 pation waste,  occur in low lying areas along streams or on the coast; they
 may also be  found on knolls in the foothills, along ridges, or in associa-
 tion  with rockshelters.  Shellfish remains are common in many midden sites,
 though they  may be absent in early villages or later camps not associated
 with  the use of littoral resources.  The most common complex of tools in early
 campsites and  later multi-purpose temporary camps in the coastal sage com-
 munity is the  millingstone association:  grinding tools, large hammering and
 chopping tools, and large waste flakes of stone.  Other sites representing
 more  limited use are surface scatters or shallow deposits of manufacturing
 waste and a  few stone tools, pictograph sites not associated with middens,
 and bedrock  grinding stations not associated with deposits.  All of these
 limited use  sites are probably associated with the later occupations of this
 region and may be found throughout the region.  Cemeteries are also present;
 these are special  features associated with base camps.   Such camps may be
 found in the foothills of the Santa Ana's near Aliso or Serrano Creeks, the
 margin of the coastal plain, the upper, open region of Aliso Creek in the
 San Joaquin  Hills, the western extreme of the San Joaquin Hills, and along
 the coastal  strip.  Temporary camps or processing stations may be found
 throughout the lands included in AWMA.

 2.9.4  Density of Archaeological Sites

 High site density occurs in several areas of AWMA.   The western extreme of
 the San Joaquin Hills exhibits a number of sites probably associated with
 populations  based in and about the Newport Beach-Irvine area.   Laguna Creek
 and Aliso Creek dominate the San Joaquin Hills; over one-half of the recorded
 archaeological sites within AWMA occur within these two drainage systems and
 q.y;er one-third occur in Aliso Creek drainage.   The upper regions of these
 drainages within the San Joaquin Hills display a large  number of sites,   the
 immediate coastline also exhibits numerous campsites.   The final area of
 high site density is the Lomas de Santiago drained by Serrano and Aliso
 Creek.  The  Glenn Ranch district, systematically surveyed by Archaeological
 Research, Inc., exhibits a very high,density of remains.

 Two areas of low site density exist.  , One, the Irvine  property, probably con-
 tains a number of temporary camps as  yet unrecorded.   The other region is
 the north/south ridge from the Mission Viejo region to  Dana Point and the
western slope of this ridge (included portions of El  Toro, Laguna Hills,
Moulton Ranch, Laguna Niguel,  and Bear Brand,  and all  of the Colinas
                                    2-45

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district).   Field work on the Moulton Ranch found that nearly all archaeo-
logical  resources were within the western and central portion of this prop-
erty; additional work on the Colinas and portions of the Bear Brand proper-
ties support this trend, since only one site was recorded.  Archaeological
sites become frequent within this corridor only within 1/2 mile of the
ocean.   This is probably the only region within AWMA that displays a low
site density.

2.10  PALEONTOLOGICAL RESOURCES

2.10.1   Introduction

The Aliso Creek Watershed and the geographic area it affects, contains
one of the most important paleontological regions in the United States;
local paleontologists have indicated that this is the richest Miocene
strata in the western half of the United States.  The exposed and under-
lying sedimentary rock units represent over 100 million years of deposition.
Most of  this deposition has occurred in a coastal or marine environment
with the fossils representing terrestrial, shore, and ocean dwelling ani-
mals and plants.

2.10.2   Previous Work

Paleontologists researching this area have begun to uncover fossils whose
potential scientific value is great.  Dr. Lawrence G. Barnes, Curator of
Vertebrate Paleontology of the National  History Museum of Los Angeles
County, has recently directed fossil salvage teams in the region and has
stated that this is a classic locale for Miocene Epoch and more recent
fossils.  Dr. Barnes has made several reconnaissance surveysin the Lake
Forest-El Toro-Laguna Hills area and during every survey, fossils were
observed.  Fossil  bone is exposed in the road-cuts and stream-banks through-
out the area.

Most fossil sites, especially bone beds, are unknown until  they are un-
covered during excavation or grading.  During the excavation for a housing
tract in Lake Forest in 1973-74, the remains of thousands of vertebrate
fossils were recovered.  It will be years before this site (locally called
Pecten Reef) will  be fully evaluated, but the most important discovery to
date were the remains of crocodiles, previously believed extinct in this
hemisphere for millions of years.  This  site was known before grading al-
though its full potential  was not realized until most of the valuable
paleontological information was  lost.

Another site, also a type locale and "classic" fossil deposit, is the
Rancholabrean fossil accumulation in Costeau Pit near Leisure World.   The
pit was an ancient spring which  drained  into Aliso Creek roughly along the
present Alicia Parkway.  Dr.  Wade E. Miller begain to salvage this site in
the middle 1960's.  Hundreds  of  bones and teeth from saber-tooth cats,
lions, giant ground sloths,  mammoths, camels,  horses, dire  wolves, and other
Rancholabrean animals which  include four classes and twenty-eight families
of vertebrate animals were recovered (Miller,  1971).   Similar accumula-
tions may be discovered in the Aliso drainage  system as  scattered bones and
teeth of Late Pleistocene vertebrates have been found throughout this  region.
                                     2-46

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 Loel and Corey  (1932) surveyed the Lower-Middle Miocene fossils in this
 area.  From their survey they named many new species of marine inverte-
 brates which are used by economic paleontologists as guide fossils.  The
 fossil locales, where the new species were first described, are considered
 type locales and their locations are included in their report.

 2.10.3  Fossil  Zones of Primary Concern

 The most important fossil zone which must be carefully monitored and exca-
 vated trends generally southwest to northeast across the Aliso drainage
 system.  It is  shown on the attached map and is observed as exposures of a
 white, sandy-limestone "reef-like" structure containing abundant marine
 invertebrates,  notably Chiamys (Lyropecten) crassicardo Conrad.  This Middle
 Miocene deposit is irregularly interbedded with unconsolidated buff-colored
 marine sand which contains abundant vertebrate (terrigenous and marine) and
 invertebrate fossils, microfossils, and petrified wood.  The limestone
 "Reef" is presently included in the fossil-rich Monterey Formation.  The
 rich variety of fossils is evident not only by the "reef" but in roadcuts
 such as the one on Moulton Parkway which the county road department had to
 spray with tar  recently because so many shells, bones and shark teeth were
 falling onto the road that people were stopping to collect.  This not only
 created a traffic hazard but also affected the stability of the roadcut.

 Exceptionally rich accumulations of marine mammals occur throughout the
 area.   Large bone beds are found on the Fury Ranch, Glenn Ranch, Moulton
 Ranch, and the  Irvine Ranch.  It appears that the Upper Miocene-Lower
 Pliocene Capistrano Embayment may have been a sheltered bay similar to
 Scammon's Lagoon on the west coast of Baja California which is a calving
area for California grey whales.   Not only are whale fossils abundant but
also fossils of dolphins, porpoise, sea cows, seals, sea lions, fish, sea
 birds  and myriads of shark teeth.   Six-inch-long Carcharodon shark teeth
have been recovered from the grading screens of the El  Toro Materials sand
quarry on El  Toro Road near the Glenn Ranch.

2.10.4  Site Locations

To list and describe every known  fossil  site in the Aliso drainage system
would  be inadequate because the entire area contains fossils in varying
degrees of abundance and many sites will be discovered during future grading.
There  are,  however, references  which do contain the locations of most known
sites  and are listed below:

     1.   Vedder, J.G.;  R.F. Yerkes; and J.E. Schoellhamer, 1957 GEOLOGIC
            MAP OF THE SAN JOAQUIN HILLS-SAN JUAN CAPISTRANO AREA, ORANGE
            COUNTY, CALIFORNIA.   U.S.G.S.  Oil and Gas Investigation Map
            OM-193.

     2.   Loel, Wayne and W.H.  Corey, 1932, THE VAQUEROS FORMATION, LOWER
            MIOCENE OF CALIFORNIA.   Unjv.  Calif.  Press  Berkeley, Vol. 22,
            No. 3,  pp.  31-410,  pis.  4-65.   December 31, 1932.
                                     2-47

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      3.    Locality  Catalogue, Natural  History Museum of  Los Angeles County.

      4.    Morton, Paul  K.;  Russel V. Miller; and  Don Fife, ms., GEOLOGY
             OF ORANGE  COUNTY, CALIFORNIA.  Calif.  Div. Mines and Geology
             (to  be  published soon).

 2.10.5   Geologic Formations

 A  brief  review of the  geologic  formations and the  fossils they contain has
 been  included as a  general  reference.  The oldest  formation exposed is the
 Paleocene  Silverado  Formation (Tsi) which represents a time when the county-
 area  was covered with  a marsh.  Commercial clay deposits on Piano Trabuco
 and near Cook's  Corner are  mined  from  this formation and contain low-grade
 coal  with  wood fossils, twigs,  leaves, sparse marine mollusks, e.g.,
 Turn'tell a pachecoensis Stanton,  and occasional shark teeth.

 The overlying Eocene Santiago Formation  (Tsa) contains continental and marine
 conglomerates and sandstones.   Fossils from this formation are extremely
 rare  and if  found should be salvaged and preserved.  In  1971 a large avocado-
 like  fossil  tree was recovered  from the  Irvine Dump and  is displayed at
 Chapman College  in Orange.

 The Miocene  Epoch formations are  very  thick and contain  the most diverse
 fossil assemblages within the Aliso Watershed.  The undifferentiated
 Vaqueros-Sespe Formation (Tvs)  represents a time when the land was sub-
 siding and the sea was innundating the area, producing the ancient Santa
 Ana Bay which is discussed by Loel and Corey (1932).  Where geologists are
 able  to differentiate  between the older, terrigenous Sespe Formation (Ts)
 and the younger, marine Vaqueros  Formation (Tv), the Sespe is a red sand-
 stone containing no fossils and the Vaqueros is a buff sandstone containing
 abundant marine  fossils.  Fairly  large exposures of Ts and TV occur west
 of Laguna  Canyon on Irvine Ranch  land.  The Loel and Corey sites are located
 within this  area.  Marine invertebrate fossils include Area santana Loel  &
 Corey, Dosinia santana Loel & Corey, Turritella inezana santana Loel &
 Corey, Chlamys (Macrochlamis) magnolia (Conrad), and Rapana vaquerosensis
 (Arnold) imperial is (HertleTn & Jordan).  Shark teeth, fish and marine
 mammals bones, and petrified wood are also found throughout the Vaqueros
 Formation and Vaqueros-Sespe Formation.

 The Topanga  Formation  (Tt) is considered a Middle Miocene shallow-water
 marine formation which interfingers with the San Onofre Breccia Formation
 (Tso), an accumulation of landslide rock-debris.  Fossils are rarely found
 in the breccia and those that have been recovered are the same species found
 in the Topanga Formation.   The limestone "reef" previously mentioned may
 belong within the Topanga Formation or that it may represent a local tran-
 sition between the shallow-water Topanga Formation and the deep-water
 Monterey Formation.   The same invertebrate fossil  present in the "reef" are
 also found in the Topanga Formation.  Extensive microfossil  research will
eventually resolve the age of the "reef" but it is included here because  of
 the fossils  it contains.  The marine invertebrates include Territella
ocoyana Conrad,  Turn'tell a ocoyana topangensis Merriam,  Turritella
                                    2-48

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 temblorensis Wiedey, Chlamys (Lyropecten) crassicardo Conrad, Cancellaria
 da Hiana Anderson, Ocenebra topangensis Arnold, Bittium topangensis
 (Arnold^), Miltha santaecrucis Arnold, dementia (Egesta) pertenuis (Gabb),
 Chione temblorensis  (Anderson") and Balanus sp.  Several echinoids are pre-
 sent, most important of which are the button sand dollars, Vaquerosella sp.
 Abundant whale bones and other marine vertebrate bones and teeth are found
 throughout the formation.  Petrified wood and some shore-dwelling terri-
 genous fossils are also present.

 The Santa Ana Bay extended far inland during the Middle Miocene Epoch,
 about 15 million years ago.  Deep-sea silt, volcanic ash, and diatomite
 compose the Monterey Formation (Tm) and the Puente Formation, La Vida
 Member (Tplv), which overly the Topanga Formation.  The fine-grained,
 laminated Monterey Formation is widely exposed on the Moulton Ranch and in
 Leisure World and undoubtedly unlies most of El Toro.  It is highly fossil-
 iferous and fish scales, bones, teeth, shark teeth, mammal remains, seaweed
 and leaf imprints, and several  mollusk species are common.  A small exposure
 of the Puente Formation, La Vida Member, trends across Aliso Creek east of
 the Christianitos Fault.  Fish scales, bones, and some crabs have been
 found at this site.  Vertebrate fossils, except fish debris, are not common
 in the white diatomite.

 Toward the end of the Miocene Epoch the sea began to retreat and the land
was covered with a shallow, receding sea.  The sandstone formation repre-
 senting this is the Capistrano Formation, one of the most important
 formations in the Aliso Watershed.  The formation contains abundant marine
 mammal  bones which in places litter the ground.  The formation contains
 lenses of conglomerates, limestone, and siltstone with some invertebrate
 marine shells.  The lower part of the formation is the Oso sand member.
 This extends throughout the Aliso drainage area and the El Toro Materials
sand quarry operates in the member.  Many important fossils of turtles,
sturgeon and other fish, sea mammals, sharks, and birds have been recovered
with disarticulated bones of terrestrial animals  apparently washed into
 the sea.   Within the Capistrano Formation, near its contact with the under-
 lying Monterey Formation, is found a narrow bed of phosphate cobbles or
nodules.   Apparently the abundance of phosphate has been favorable for the
preservation of fossils, as the cobbles are scattered between excellent
 fossil  bones of marine mammals  and petrified wood.  Dr. Barnes has stated
 that these phosphate beds should be preserved and that it would be advan-
 tageous to construct observation pits over these  beds for educational
 purposes.   The thickest phosphate-bone bed is found in the east side of
the Moulton Parkway road-cut directly north of La Paz Road.   It is LACM
 locality 7136.

Overlying the Capistrano Formation is the grey, silty Pliocene Miguel
Formation.   This marine formation contains local  concentrations of fossil
sea shells and some vertebrate  material  have been recovered.   Any fossil
concentrations should be salvaged carefully and all  vertebrate material
should be collected for study.   A large accumulation of sea  shells is
exposed by a stream which flows by La Paz Road, about 1/4 mile up the
stream from the intersection of La Paz Road and Moulton Parkway.   Similar
fossil  accumulations may be discovered during future excavations.
                                    2-49

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 The Quaternary terrace and alluvial  deposits  blanket  the Aliso  drainage
 system and are thickest in the  Saddleback  Valley  upon which  El  Toro  is
 built.   Fossils that occur here are  disarticulated  bones of  "Ice Age" or
 Rancholabrean animals which lived  in the velt-like  environment  of  the
 Pleistocene.   Local  accumulations  of bones should be  expected,  similar to
 the deposits  of Costeau Pit (Miller, 1971).   Mammoth  bones have been col-
 lected from many of  the drainage areas  including  Aliso Creek and Salt
 Creek.   Mammoth tusk and bone were collected  on Dana  Point in 1937 and it
 is highly possible that more bone  will  be  found.

 2.11   LAND USE

 The predominant land use in the AWMA area  is  low  intensity agriculture.
 There  are approximately 35,000  acres devoted  to the grazing of  cattle and
 seasonal  dry  farming of cereal  grains.  There are also approximately 540
 acres  of citrus and  avocados,   the primary cattle grazing areas can be
 found  on  the  Moulton Ranch southerly of Leisure World, and on the coastal
 hills  of the  Irvine  Ranch  between  the cities  of Laguna Beach and Newport
 Beach.   The citrus and avocado  producing areas can  be found in  the north-
 easterly  area  of the AWMA  region in  the foothills of the Santa  Ana Moun-
 tains  north of the Community of El Toro.

 The first community  to develop  in  the region  was  Laguna Beach,  situated on
 the coastline  at the mouth of Laguna  Canyon.  The San Joaquin Hills serve
 as  a back drop for the city.  In addition  to  providing spectacular views
 of the ocean and shoreline,  these  hills tend  to isolate the community from
 other  urban areas in  Orange  County and  provide Laguna Beach with a unique
 environmental  setting.

 Laguna Beach is  the  only city in Orange County which does not have a boun-
 dary line contiguous  with  another  city.  It is not  bisected by, nor even
 conveniently serviced by a  freeway,  and it  is one of the few cities in
 Orange County  which  does not have a  regional  shopping center within its
 boundaries.  The City does  draw  tourists from all  over the world by its
 reputation as  a  cultural and recreation center.

 Commercial and tourist commercial  land  uses have extended along the Pacific
 Coast Highway  for almost the entire  length of the city.   Limited commer-
 cial, industrial and  residential uses have extended northward along Laguna
 Canyon Road for  several miles.    Otherwise,  Laguna  Beach  is characterized by
 single family  housing which  has crept into the hills and canyons behind the
 commercial core  of the  City.  The same pattern of land use,  commercial
 along with the Coast  Highway with residential  uses spreading into the hills,
 continues  to the south of  Laguna Beach through the unincorporated community
 of  South  Laguna.

 Low Density residential uses are located on both sides of the Coast High-
way through the communities of Three Arch Bay and  Laguna  Niguel.  There is
 one community shopping center servicing the southern portion of the AWMA
 region.   Residential  development spreads inland through  Laguna  Miguel,  along
 Crown.Valley Parkway for approximately five miles.
                                     2-50

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                                                 s
Legend
         Single Family Residential


         Multi - Family Residential


         Commercial


         Industrial


         Public


         Open Space
Exhibit  2-8
                                                                                    LLJ
                                                                                    X
                                                                                    LU

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                             TABLE 2-14

                          EXISTING LAND USE
                         ORANGE COUNTY/AWMA
RESIDENTIAL
     Low density (single family)
     High density (multiples)

COMMERCIAL

INDUSTRIAL

PARKS AND RECREATION

AGRICULTURE
     Citrus and avocados
     Grazing and dry farming

OTHER OPEN SPACE

TRANSPORTATION FACILITIES

OTHER
AWMA
Acres
4,631
1,520
647
150
782
540
540
35,000
5,000
635

48,905
% ,
9.5
3.1
1.3
.3
1.6
1.1
1.1
71.6
10.2
1.3

100.0%
Orange
Acres
84,947
15,404
12,713
12,552
11,920
53,210
53,210
275,093
8,881
36,103
510,823
County
%
16.6
3.0
2.5
2.5
2.3
10.4
10.4
53.9
1.7
7.1
100. o;

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The County of Orange has recently constructed a regional civic center in
La.guna Miguel at the intersection of Crown Valley Parkway and Alicia Park-
way.  Further to the north is the General Services Administration Building
located on a 91 acre site.

Development in the coastal region of AWMA has generally followed the shore-
line  (and the Pacific Coast Highway) and then extended inland along the
arterial highways - Laguna Canyon Road and Crown Valley Parkway.

Development in the inland, or northern part of the AWMA region has occurred
along the corridor of the San Diego Freeway and then extended along the ar-
terial s which connect with the freeway.  The area on the South side of the
San Diego Freeway is generally known as Laguna Hills.  The focal point of
Laguna Hills is Leisure World.  Leisure World, located at the intersection
of El Toro Road and the San Diego Freeway is a senior citizens community
of 2,420 acres.  By Orange County standards, Leisure World is a fairly high
density residential community.  It is a planned community complete with
recreational facilities, hospital, professional center and a shopping cen-
ter designed and constructed to service the region.

Across the freeway from Leisure World is the Community of El Toro.  'It is
characterized by single family detached housing with the exception of com-
mercial and professional land uses which have developed along El Toro Road.
To the West of El Toro is the planned community of Lake Forest, a recrea-
tion oriented, predominately single family residential area.  A railroad
Tine bisects El Toro, running parallel  to the San Diego Freeway approxi-
mately one mile to the north.

2.12  WATER SUPPLY AND ITS QUALITY

2.12.1  Metropolitan Water

2.12.1.1   Introduction

All AWMA member agencies receive their water supply through the Colorado
River Aqueduct system constructed and operated by the Metropolitan Water
District of Southern California.  The Municipal Water District of Orange
County is a member agency of the Metropolitan Water District and repre-
sents the Los Alisos Water Distirct, the El  Toro Water District, the
Mpulton-Miguel Water District and the Irvine Ranch Water District on the
MWD Board of Directors.

The Coastal  Municipal  Water District is a member agency of MWD and repre-
sents the City of Laguna Beach,  the area- of the South Laguna Sanitary
District and the Emerald Bay Service District on the Metropolitan Water
District Board of Directors.

Water demands of agencies in  the AWMA area  vary depending upon the  land
use patterns, extent of development and amount of irrigated agricultural
land in each agency.   Sources of water  vary throughout Orange County;
                                     2-51

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however, all municipal and industrial demands of the agencies within the
AWMA area are served with water imported from the existing facilities of
the Metropolitan Water District, because of limited groundwater supplies.

2.12.1.2  Aqueduct Systems

Imported Metropolitan water is delivered to the AWMA area via two main
systems:  the Santiago Lateral-Aqueduct system and the East Orange County
Feeder No. 2 - Tri-Cities Transmission Main system and Coastal Trans-
mission Main.

2.12.1.2.1  Santiago Lateral-Aqueduct System

The Santiago Lateral is a Metropolitan owned and operated pipeline ex-
tending from the Santiago control  tower on the lower feeder in Santa Ana
Canyon, 7.4 miles to Santiago Reservoir above Irvine Park.  From this point,
the Lateral provides water to the Santiago Aqueduct, which carries the
water to the El Toro area.

The Santiago Aqueduct is a joint powers agreement line which begins on the
Santiago Lateral near Irvine Park and extends approximately 16 miles to
Cherry Avenue in the El  Toro area.  The line has a nominal capacity varying
from 92.9 cfs in the initial reaches to 10.5 cfs* in the El Toro Water
District.  The Santiago Aqueduct Commission composed of Los Alisos Water
District and El Toro Water District  owns the transmission main, with eight
other agencies having capacity rights.

2.12.1.2.2  East Orange County Feeder No. 2 - Tri-Cities Transmission
            Main System

The East Orange County Feeder (EOCF) No.  2 is a joint powers constructed
facility owned jointly by Metropolitan and 11 Orange County water agencies
and is operated by Metropolitan.  The line delivers water treated at the
R. B. Diemer Filtration Plant in Yorba Linda, 25 miles southerly to its
terminus at San Joaquin Reservoir, northeast of Newport Beach.  Nominal
capacity of the line varies from 310 cfs  in its initial reach to 90 cfs.
The cities of Orange and Anaheim,  the East Orange County Water District,
and the Irvine Ranch Water District take  water directly out of EOCF No. 2.
The Moulton-Niguel Water District, Santa  Margarita Water District, and por-
tions of Irvine Ranch Water District require further transmission of the
waters to the areas of demand.  This is provided by the Tri-Cities and
Aufdenkamp Transmission Mains.  Both these lines extend southeasterly from
Barranca Road and Jeffrey Road in  the Irvine Ranch area of Orange County,
at the end of Reach 3 of EOCF No.  2.

The Tri-Cities Transmission Main is a joint-powers agreement line owned by
Moulton-Niguel  Water District, Irvine Ranch Water District, Orange County
Water Works District (OCWWD) No. 4, and Tri-Cities Municipal  Water District,
and is operated by Tri-Cities Municipal Water District.  The line, and a
*cfs = cubic feet per second
                                    2-52

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branch off  it called the  Eastern Transmission Main, delivers the 45 cfs
capacity which M-NWD owns in EOCF No. 2 into the Moulton-Miguel Water
District.   Santa Margarita Water District leases a portion of the OCWWD
No. 4 capacity in both the Tri-Cities and Eastern Transmission Mains.

The Aufdenkamp Transmission Main is a line constructed under a joint
powers agreement extending from EOCF No. 2 near Barranca and Jeffrey to
Laguna Beach.  MWDOC owns 14 cfs in a reach extending approximately five
miles southeasterly from Barranca and Jeffrey.  Santa Margarita has an
option to purchase this 14 cfs capacity as a means of delivering its
capacity in EOCF No. 2 further towards its district's service area.  De-
mands on East Orange County Feeder No. 2 and Tri-Cities and Laguna Canyon
Transmission Mains are presently well below capacity.

The El Toro Water District and the Los Alisos Water District receive raw
water through a connection to the MWD Santiago Lateral.  The water is then
transported through the Santiago Aqueduct to water filtration plants oper-
ated by each separate district.  The water is filtered and chlorinated
prior to delivery to the consumer.

The Moulton-Niguel Water District receives water from the Metropolitan
Water District through a connection at the coastal junction on the East
Orange County Feeder No. 2.   This is a treated water having been filtered
and chlorinated by MWD at their Robert Diemer Filtration Plant in Yorba
Linda.  The water is then transmitted to the district through the EOCF No. 2
and the Tri-Cities Transmission Main traversing the central portion of the
District.

The water for the City of Laguna Beach and the consumers residing within
the South Laguna Sanitary District is delivered through the facilities of
the South Coast County Water District and is secured from the Metropoli-
tan Water District through two sources.   The first is through a connection
to the Orange County Feeder owned by MWD in the Corona del  Mar area of the
City of Newport Beach.   The water is then transmitted through a jointly owned
facility of the Laguna Beach County Water District and the South Coast
County Water District for the distribution within the City of Laguna Beach
and the community of South Laguna.   This water has also been filtered and
chlorinated at the Diemer Filtration Plant.   The second connection, recently
constructed, connects to the East Orange County Feeder No.  2 at the coastal
junction and transmits water to the two agencies through a newly constructed
line in Laguna Canyon.
 ir>.
2.12.2  Water Quality

2.12.2.1   Colorado River Water

Table 2-15 sets forth the analysis  of the Colorado River water for the
fiscal  year of the Metropolitan Water District ending on June 30, 1972,
and as set forth in their 34th Annual  Report.
                                   2-53

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                                   TABLE 2-15
                           METROPOLITAN WATER DISTRICT
             Analysis of Metropolitan Water District Water Supplies*
                      Average for Year Ending June 30, 1972
    Constituent
Silica
Iron
Calcium
Magnesium
Sodium
Potassium
Carbonate
Bicarbonate
Sulfate
Chloride
Nitrate
Boron
Fluoride
Total Dissolved Solids
Total Hardness as CaC03
Total Alkalinity as CaC03
Free Carbon Dioxide
Hydrogen Ion Concentration  pH
Electrical  Conductivity
Color
Turbidity
Temperature
* mg/1 = milligrams per liter
**Average for month of June 1972
                                       Colorado River Water  State Project Water
                                                                                **
Symbol
Si02
Fe
Ca
Mg
Na
K
Co3
HC03
so4
Cl
N03
B
F



C02
PH
ECx!06
@25°C

J.T.U.
OF
Natural
7.5
0.06
87.0
33.0
113.0
5.0
0.0
149.0
330.0
100.0
0.9
0.11
0.4
751.0
353.0
122.0
1.0
8.2



1.3
63.0
Softened
7.4
0.01
34.0
15.0
213.0
5.0
1.0
145.0
330.0
107.0
0.9
0.11
0.4
786.0
147.0
121.0
1.0
8.3
1,170.0

5.0
0.3
63.0
Natural
8.7
0.05
40.0
17.0
45.0
3.0
0.0
121.0
104.0
45.0
0.6
0.10
0.4
324.0
170.0
99.0
2.0
8.0
1,280.0

3.0
2.6
67.0
Fi 1 tered
8.5
0.01
40.0
17.0
47.0
3.0
0.0
121.0
104.0
48.0
0.2
0.10
0.4
329.0
170.0
99.0
2.0
8.2
547.0

4.0
0.2
67.0

-------
 2.12.2.2  State Project Water

 It  is  the current plan of MWD to modify or add to its delivery system those
 facilities which will permit delivery of a blend of 50 percent State Pro-
 ject water and 50 percent Colorado River water in almost all portions of
 the District by 1976.  It is further planned to increase the amount of
 State  water to 75 percent in 1987 - 1988 and to about 80 percent in the
 year 2000.  The MWD Box Springs Pipeline can be used to introduce State
 Project water to the lower feeder upstream of the Diemer Plant.  This will
 furnish the same 50 percent blend to the Santiago Lateral which is the
 principal supply for the Santiago Aqueduct serving the Los Alisos Water
 District and the El Toro Water District.  There are no provisions to soften
 the water carried in the Lower Feeder.

 Both the Lower Feeder and the Yorba Linda Feeder deliver water to the
 Diemer Plant.  Upon implementation of the enw plan, the Yorba Feeder will
 carry the 50 percent blend, whereas otherwise it would have only State
 Project water.  The Diemer Plant feeds the East Orange County Feeder No.  2,
 the principal source of water to the residents within the Moulton-Niguel
 Water District, South Laguna Sanitary District, Emerald Bay Service Dis-
 trict and the City of Laguna Beach, and the Irvine Ranch Water District.

 This plan of MWD's assumes that the total dissolved solids content of
 Colorado River water will  be 750 ppm while that of State Project water will
 be 250 ppm.   In this event a 50 percent blend would result in a product
 water with a content of 500 ppm.  Table 2-15 indicates the proposed time-
 table and quality of water to be available as a result of this blending.

                                 TABLE 2-16

                         BLENDING OF COLORADO RIVER
                        WATER AND STATE PROJECT WATER

                   	PERCENT OF BLEND                 Blend Quality
 Year               State Project	Colorado River            ppm

 1973-74                   0                  100                 750

 1976-77                  50                   50                 500

 1985-86                  55                   45                 475

 1986-87   .               55                   45                 475

 1987-88                  75         '          25             .    375

 1990-2000                80         ,         20                 350
While information presented above has  been based upon a plan prepared by
MWD, it is of interest to consider variations in water quality that may
                                     2-54

-------
occur in future years from the two sources.  It has been noted that the
water of the Colorado River is tending to contain more salts each year.
Some have predicted that the salinity of this water may become as high as
1000 ppm by the year 1986 unless measures to control  this salinity are
taken in the Colorado River Basin.

The quality of State Project water will  be greatly influenced by the con-
struction of the Peripheral Canal in the Delta area.   While the Canal  is
needed to enhance the quality of State Project water, there is much politi-
cal oppositon that makes timing of the construction of the Canal  uncertain
at present.

Table 2-15 shows the analysis of MWD water supplies for the year ending
June 30, 1972.   It can be seen that a 50 percent blend of the natural  water
from the two sources would result in a product water with 538 ppm of dis-
solved solids while the softened water would have 557 ppm.

Table 2-17 gives the range and values for certain constituents of Colorado
River water in  a ten year period of 1963 through 1971.

                                 TABLE 2-17

                             RANGE IN VALUES OF
                      ANALYSIS OF COLORADO RIVER WATER
                                  1963-1971
                                   Natural
Constituent
	                     Min.	Max.

Total Dissolved Solids          668.0     779.0

Total Hardness                  322.0     364.0

Chlorides                        86.0     113.0

Sulfates                        290.0     335.0

Sodium                           96.0     116.0

Calcium                          82.0      96.0

Magnesium                        28.0      34.0

Fluoride                           .4        .5

Iron                               .04       .06

pH                                8.2       8.4

Electrical Conductivity       1,055.0   1,220.0
Softened
Min.
693.0
127.0
92.0
290.0
158.0
31.0
12.0
.4
.01
8.3
1,120.0
Max.
805.0
216.0
118.0
335.0
214.0
55.0
19.0
.5
.02
8.5
1,290.0
                                    2-55

-------
 With  the  arrival of  State water  in Southern California and its blending with
 the water from the Colorado  River, the Metropolitan Water District will be
 able  to deliver to its consumers a water of higher quality than that pre-
 sently being  served.  This is especially true in the degree of hardness
 which is  a major consumer concern to the residential and industrial user;
 blending  will  reduce  the total dissolved solids thus improving the quality
 of reclaimed  water.   There are no major water producing areas contained
 within the boundaries of the Aliso Water Management Agency and it is not
 anticipated that any  other major domestic water supply will be forthcoming
 in the near future.

 Present water requirements in the AWMA area are now approximately 16.5
 mgd.  This  existing  requirement represents approximately 8.3% of the avail-
 able  water capacity  for the  AWMA area.

 2.12.2.3   Underground Water  Supply

 As stated  above, all municipal and industrial  demands of the agencies within
 the boundaries  of the Aliso  Water Management Agency are served with water
 imported  from the existing facilities of the Metropolitan Water District.
 The reason  for  this  importation is due to the fact that, with the exception
 of small areas  along Aliso Creek and in Laguna Canyon, the area is void of
 any major water bearing stratum that could be used for domestic purposes.

 However, there  is reported to be a potential  underground storage basin in
 the magnitude of 9,000 acre-feet within the Aliso Valley.  This fact is
 set forth  in  a  report prepared for the San Juan Capistrano Soil Conser-
 vation District in 1961  by Engineering Service and more recently confirmed
 by the Orange County Flood Control District ina report  dated June 1972.
 Through proper  management this limited underground storage basin can be
 utilized to the maximum benefit of the area.   The use of this potential
 storage basin has been discussed previously.

When  the early  settlers  came to the El  Toro area,  they were aware of the
 fact  that there was a limited amount of groundwater available.   The water
was of such quality and  quantity that some agricultural  and residential
development was permitted to take place.   However,  the availability of this
 supply was  limited and,  as a result,  development of the area was restricted.
 In addition to  the low volume of water available in the immediate area,
 the quality of  the water in some areas was poor.   The total  dissolved
solids of the water that was  stored in  the underground water basin was
high and even approached the  limits where the  water was  not suitable for
agricultural purposes.  Some  water of higher  quality was obtained from
springs  that were located on  side tributaries  to  Aliso Creek.   However,
although this water was  much  higher in  quality and  usable for domestic
purposes,  the supply was quite limited  and was only adequate to meet very
small  demands such as cattle facilities and a  few  residential  homes.

In the lower reaches  of  the Aliso Creek,  actual  artesian groundwater con-
ditions  exist.  In addition thereto,  the groundwater levels  in  the lower
reaches  of the Aliso  drainage basin are quite  shallow.   This  is probably
                                     2-56

-------
due to the geological conditions existing at the mouth of Aliso Creek
thus forcing the groundwater in the basin to surface at this point.  His-
torical information available relative to the water conditions in the Aliso
Canyon indicates that the water in the lower portion of the basin was not
fit for human consumption and, in many instances, even thelivestock would
not use this water for watering purposes. It should be noted that there
still exists numerous wells within the Aliso Basin while are used for
agricultural purposes when adequate water is available, however, the ex-
tensive agricultural demand is supplemented with imported water.

The underground water conditions in the San Diego Creek, into which a
portion of the El Toro and Los Alisos Water Districts drain, also has a
history of limited water supply in the upper reaches of the drainage basin
in the vicinity of the two districts.  Westerly and downstream from the two
districts, there is a known recharge area which provides storage facilities
for underground water.  The San Diego Creek then passes westerly through
the Irvine Ranch and discharges into the upper Newport Bay.   The underground
basin through which San Diego Creek passes within the Irvine Ranch Water
District provides a source for irrigation waters and the quality of this
water must be maintained.

Another underground basin exists beneath Laguna Canyon.  The size, config-
uration, and location of this basin has never been determined, although
historically underground water has been important to the community of
Laguna Beach.  Springs, and later wells, provided almost the entire supply
of water for over 50 years, until  1927.  At that time, the population num-
bered nearly 3,000 and the importation of water began.  Today, there are
at least three wells which are still  in use within Laguna Canyon.

At the present time, there is no evidence of any major underground water
supply in the coastal  areas within the Irvine Ranch Water District and the
South Laguna Sanitary District.   This area is served with imported water
and no production wells for domestic purposes are known to exist.

2.12.2.4  Wastewater Recharge Supply

None of the existing treatment plants in the AWMA area directly discharge
effluent for recharge back into the groundwater basins.  Rossmoor Sani-
tation, Inc., Los Alisos Water District and Moulton-Niguel  Water District
Improvement District No. 1A supply all  or part of their treated effluent for
irrigation and indirect recharge while the other member agencies of AWMA
utilize an ocean outfall as a method of final  disposal.

Rossmoor Sanitation, Inc. reclaims its entire capacity of treated  effluent.
Part of the 1.9 mgd of reclaimed water is stored in a reservoir located on
the Leisure World Golf Course while the Lion Country Safari  development
northwest of the treatment plant is furnished water for its  lakes.

The remaining amount of treated effluent is  pumped to several  large rain-
bird sprinklers on undeveloped lands  within  and outside of the district
for spray irrigation.   Rossmoor sanitation also leases 200 acres of agricul-
tural  lands from the Irvine Company where the reclaimed water  is  used  for
irrigation.
                                     2-57

-------
 The  1.062  mgd  of effluent treated by the Los Alisos Water District is
 settled out  in a secondary settling pond and then goes to the maturation
 ponds.  From the ponds, the reclaimed water passes through the chlorine con-
 tact chamber and is pumped to the Irvine Ranch property where it is utilized
 by the Irvine  Company for irrigation of agricultural lands.  In addition,
 the  district has a connection to one of the Irvine Company's irrigation
 pipelines  where the reclaimed water is conveyed to the Laguna Reservoir
 located along  Laguna Canyon Road approximately two miles south of the San
 Diego Freeway  and three miles directly west of the Los Alisos Water Dis-
 trict treatment plant.

 Improvement  District No. 1A of the Moulton-Niguel Water District is the
 only other agency which indirectly returns the treated effluent to the
 groundwater  basin.  The 0.35 mgd of effluent is conveyed to four oxidation
 ponds after  the activated sludge treatment process.   These ponds serve as
 holding reservoirs for the reclaimed water which ultimately is pumped to
 the  Laguna Miguel Golf Course and used for irrigation.

 2.12.2.5   Surface Water Supply

 Prior to the commencement of major development in the early 1960's in
 the  Moulton-Niguel, El Toro, and Los Alisos Water Districts, the Aliso
 Creek usually would dry up during the summer period withonly a small  amount
 of runoff  realized in the upper portion of the drainage basin near the
 community of El Toro.  This surface water was generally fed by springs in
 the  upper  drainage area and for some time was actually used for domestic
 pruposes.   In most cases, the water generally percolated underground during
 the  summer months prior to reaching the Moulton-Niguel Water District.

 However, since the major development activity has taken place within the
 three districts, runoff within the Aliso Creek is being experienced
 throughout the year.   This runoff condition has been created by the ur-
banization of some of the drainage area and has, in  turn,  resulted in
 greater runoff during the winter months.   During the dry summer months
 there is continued irrigation of the lawns and planted areas in the devel-
oped portions of the drainage basin, wh.ich, in turn, creates a continual
 runoff into Aliso Creek during the summer months.

2.13  POPULATION AND WASTEWATER FLOWS

The U.S.  Bureau of Census  estimated  that 1,410,386 people  lived in Orange
County in  1970.  The Population Research Unit of the California Department
of,,Finance estimated that as of January 1, 1974 Orange County's popula-
tion grew  to 1,646,314,  an increase  of 16% since 1970.

Annual rates of growth in  Orange County between 1950 and 1965 averaged
slightly more than 12%.   Since that'period of rapid  growth,  the average
annual rate of growth has  decreased  to slightly greater than 4%.

The pattern of growth in the past 20+.years originated in  the north
County.  After approximately 1965,  southward flow of development began to
be felt in the AWMA area.   As  a result, the population estimates of all  the
                                    2-58

-------
member agencies of AWMA are shown in Table 2-18 in relation to the corres-
ponding average wastewater and per capital flows.

2.14  INSTITUTIONAL FRAMEWORK AFFECTING THE ENVIRONMENT

Following is a brief description of the entities which entered into the
joint powers agreement forming the Aliso Water Management Agency.

2.14.1  Moulton-Niguel Water District

The Moulton-Niguel Water District was organized in November 1960 pursuant
to the California Water District Law (Section 34,000 etc., of the Water
Code, State of California).  The District serves nearly 24,000 acres, 21,345
of which are within the Aliso Water Management Agency.  The District is
governed by a Board of Directors consisting of seven members, each elected
at large by qualified voters in the district.  The General Manager is
appointed by the Board of Directors.

The District was formed to finance and construct joint water transmission
facilities connecting to the Metropolitan Water District.  The water
supplied by the Metropolitan Water District would meet the domestic re-
quirements of both the Moulton-Niguel Water District and other public
entities in the area.

As the area grew, the District recognized the necessity for developing a
good overall sewage system.  Subsequent modification of the California
Water District law permits the financing, construction, operation and
maintenance of sewage facilities by California water districts.  The Dis-
trict has constructed and is now operating a complete sewage system, with
the exception of an ocean outfall.

2.14.2  South Laguna Sanitary District

The South Laguna Sanitary District comprises some 2,700 acres lying adja-
cent to and south of the City of Laguna Beach.  The District is governed
by a five man Board of Directors elected at large and managed by a General
Manager who serves at the pleasure of the Board.

The South Laguna Sanitary District was formed on December 7, 1947 under
the Health and Safety Codes of the State of California Sanitary District
Act of 1923.  The sole purpose of the formation of the District was to
provide sanitary sewage facilities meeting the needs of the existing and
growing community.  As a result of the formation of the District, a success-
ful bond election was  held and the sewage facilities were built in 1953.  .

In recent years the Moulton-Niguel  Water District has entered into an  agree-
ment with the South Laguna Sanitary District for the joint construction and
use of sewage treatment and disposal  facilities of the South Laguna Sani-
tary District.
                                    2-59

-------
          TABLE 2-18
POPULATION AND WASTEWATER FLOWS
                       43
                                                           CM
                                                          O CD
        Agency

Los Alisos Water Dist.
El Toro Water District
Moulton Niguel Water Dist.
  1-A Plant
  2-A Plant
  South Laguna Plant
               Total
South Laguna San. Dist.
City of Laguna Beach
               TOTALS
                                                                  i  i
                                                                  
0. •—
2,500
19,130
(5,260)
(2,540)

7,800
4,870
15.7001
50,000
(U 5^-*
•POO
l/)i— CD
to LI- s:
*^p *^**
i.
. 01 0
CT-P r--
2> <0 o^
< 5-—
0.14
1.06
(0.07)
__
(1.07)
1.14
a. 49
1.72
4.55
00
o
i. a.
a* CD
o. *^^

0 S
^^ o
en •—
r-U-
56
55

-_
—
146
101
no
91
CL. i—
•o i
0)
•P C
to o
£ *r™
•r— 4^
•P (0
.CO i—
LU 3
9,700
33,900

--
—
12,700
10,300
22,000
88,600
CO
(O ^E
3 0

OJ U-
CT)
(O S— ^~^
S- tt) 0

> (O 21
< 5>-'
1.04
2.12
(0.13)
(0.05),
(1.14)3
1.32
.803
1.81
7.09
0 0
0
s. a.
QJ CD
CL "~*

«* 3
r^ o

i— U-
107
63

--
--
104
78
82
80
 Does not account for transient population.  City of Laguna Beach figures will
 include Emerald Bay Service District.
^Estimated by member agencies based upon occupied service connections:

LAWD
ETWD
MNWD
SLSD
Average
Pop/du
3.4
2.3
3.75
2.8
1/1/74
8,573
32,878
11,877 1
9,200
1/1/75
10,826
34,890
13,628
11,400
Average
9,700
33,900
12,700
10,300
The City of Laguna Beach estimates 18,000 people for 9 months and 35,000 people
for 3 months, for a yearly average of 22,000.
3Flows for the period 7/1/74 through 6/30/75.

-------
2.14.3  El Toro Water District

The  El Toro Water District was organized in September 1960 pursuant to
the  California Water District Law (Section 34,000 etc., of the Water Code
of the State of California).  It is governed by a Board of Directors con-
sisting of five members, each being elected at large by qualified voters
of the District.

The  District was formed to finance and construct joint water transmission
facilities from an existing Metropolitan Water District line to the District
and  adjacent districts.  The District is bounded by the Los Alisos Water
District on the north and the Moulton-Niguel  Water District on the south.

The  District was formed primarily to import water to supplement ground-
water supplies.

As growth took place within the District, it became necessary to construct
sewage collection, treatment and disposal facilities to keep in step with
the  rapid development in the area.  The District at that time elected not
to enter into the areas of sewage collection, treatment and disposal.   As
a result, a private company was formed to meet this need.   The formation of
this private company, Rossmoor Sanitation, Inc., was accomplished with the
approval of the Board of Directors of the El  Toro Water District.  While
existing sewage facilities are privately owned within the  District,  the .
District has, from time to time, particpated in major sewage studies carried
on by adjacent districts in order to be appraised of the regional planning
that was taking place.

As a result of these recent studies, the El  Toro Water District in 1971
took the necessary steps to exercise the sewering powers afforded them
under the California Water District Law.  In  early 1972, the Board auth-
orized thepreparation of an engineering report to include  facilities for
the treatment and disposal of municipal  and industrial  wastes.

On June 30, 1972, the District held a public  hearing and adopted a resolu-
tion authorizing the issuance of $10 million  dollars of general  obligation
bonds to finance major sewage facilities.  The Board of Directors elected
to join in the formation of the Aliso Water Management  Agency and have since
actively participated in the regional  planning of the Aliso Valley Water-
shed basin.

2.14.4  Los Alisos Water District

The Los Alisos Water District was organized  in October,  1960, under  pro-
visions of California Water District Law (Section 34,000 etc.,  of the  Water
Code of the State of California).   The  District is  governed by  a Board of
Directors  consisting of five members,  each being elected at large by quali-
fied voters in the District.   The General Manager is  responsible for the
overall supervision  and management of the district  and  is  appointed  by
and responsible to the  governing board.
                                    2-60

-------
 The District was  formed  primarily  for  the  purposes of financing and con-
 structing joint water  transmission facilities  from existing Metropolitan
 Water District lines to  the  District and adjacent agencies.

 Following the arrival  of water within  the  District, the Board of Directors
 recognized their  responsibility  to meet the  sewage needs of the developing
 area and elected  to proceed  with the financing, construction, maintenance
 and operation of  needed  sewage facilities.   These facilities were first
 constructed in 1964 and  have been  expanded and approved to meet the grow-
 ing needs of the  District.   In the past, the District has particpated in
 numerous studies  with  adjacent districts in  order to be appraised of
 regional  planning that is being  carried out  in the southerly portion of
 Orange County.  It was these reports,  the  first of which was prepared in
 August 1963 and the most recent  in September 1970, which suggested that a
 regional  agency should be formed to plan and construct joint facilities.
 Through the analysis of  these reports, the Board of Directors elected to
 actively particpate in the Aliso Water Management Agency.  The District
 has been  authorized to issue $16 million dollars in general obligation
 bonds  to  finance  their needed local and regional facilities.

 2.14.5  Irvine  Ranch Water District

 Irvine Ranch  Water District  was  formed in  January 1961 pursuant to the
 California  Water  District Law (Section 34,000  etc., of the Water Code of the
 State  of  California),  for the purpose of securing a supplemental water
 supply for  irrigation  and domestic  use from  Metropolitan Water District of
 Southern  California.   The total  area of the  Irvine Ranch Water District
 includes  approximately 67,850 acres.  However, only 8,560 acres lies with-
 in  the boundaries  of the Aliso Water Management Agency.   This acreage is
 basically that  portion of the District which drains southerly to the Pacific
 Ocean.  The  District is  governed by a five member Board of Directors, each
 of  whom must  be a  qualified  voter  in the District.  A general manager is
 appointed by  and  responsible to  the Board of Directors.   The Irvine Ranch
 Water  District  is  also acting under the California Water District law to
 provide sewage  facilities within the developed portions of the District.

 The area  of the District contained  within  the  boundaries of AWMA is pre-
 sently undeveloped.  However, inasmuch as  the  lands are a portion of the
 drainage  area of  the Aliso Watershed and areas logically related thereto,
 the Board of  Directors of the Irvine Ranch Water District elected to be
 a member  of AWMA  in order to participate in  the overall  planning of the
 regional  sewage facilities.

 2.14.6  City of Laguna Beach

 The City  of Laguna Beach is  the only incorporated area within the boundaries
'Of^the Aliso Water Management Agency.,  The City is governed by five city
 councilmen elected at  large  on an alternating two year basis.   A city mana-
 ger, is appointed by and responsible to the city council.

 Since  the initial   installation of sewage facilities in 1923, the financing,
 construction, operation and maintenance of the facilities have been assumed
                                     2-61

-------
 by  the  City of Laguna Beach.  The city council, recognizing the problems
 confronting the City of Laguna Beach and their sewage treatment and disposal
 facilities and recognizing the advantages of regional planning, have elected
 to  participate in the Aliso Water Management Agency.

 2.15  NOISE

 The AWMA area is subject primarily to vehicular noise along the circulation
 system  and to intermittent aircraft noise from operations at the El Toro
 Marine  Corps Air Station.  Noise contours or zones of influence are deter-
 mined relative to different sources of noise.  For the ground transporta-
 tion elements, criteria developed by the U.S Department of Housing and
 Urban Development are used to determine the distances from roadways and
 railways within which noise conflicts with residential use may occur.
 The contours of the Community Noise Equivalent Level (CNEL) are used to
 describe the aircraft noise environment around aircraft operations.  The
 El Toro MCAS is located adjacent to the northwesterly boundary of the AWMA
 area, but its aircraft overflights have an impact upon the AWMA area.

 These CNEL noise contours, then, describe the magnitude of the noise levels
 in the  AWMA area and are used to develop criteria and procedures to ensure
 land use compatibility for all future development in the AWMA area.

 For instance, the California Airport Noise Regulations restrict residential
 uses including single-family and multiple-family dwellings of standard
 construction within an airport noise impact boundary.  Although these
 regulations do not apply to military airports, the criteria developed
 therein can be used to evaluate land use in the vicinity of El  Toro MCAS
 relative to aircraft noise compatibility.

 Of importance to the AWMA area are the aircraft overflights along runways
 34R, 25R and 25L.  Runway 34R generates a noise corridor through the AWMA
 area that will  have the most significant impact upon future residential
 growth.  The ultimate effect of these continued aircraft operations at El
 Toro MCAS will  be as a constraint upon future urbanization.

 2.16  HISTORICAL RESOURCES

2.16.1   Historical  Background
 'i<-',
The AWMA area has experienced many human activities of historic signifi-
cance during the various periods that man has inhabited the region.  In
al^l of Orange County, no one area has recorded more historical  occurrences
than within the land area known as the Irvine Ranch.

Within the AWMA area, historical  background can be categorized  into four
 periods:  the prehistoric, the Spanish period comprising the mission and
 rancho periods,  the Anglo pioneer period after 1848, and the industrial
period  (ca.  1950 et. seg.).
                                     2-62

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TABLE 2-19
SUMMARY OF GOVERNMENTAL AUTHORITY

1 - Decisive or strong impact
2 - Significant impact
3 - Moderate or minor impact
* - Impact rating if outside
funding sources used












Environmental Protection Agency
U.S. Soil Conservation Svc.
Corps of Engineers
U.S. Fish & Wildlife Svcs.
Calif. Coastal Zone Conservation Comm.
State Water Resources Control Board
Department of Water Resources
Air Resources Board
State Dept. of Fish & Game
State Division of Highways
State Division of Beaches & Parks
State Department of Public Health
Calif. Dist's. Securities - Div. of
State Treas.
Regional Water Pollution Control Boards
South Coast Regional Coastal Comm.
S.C.A.G.
Orange County Transit District
O.C. Harbors, Beaches & Parks Dist.
O.C. Flood Control District
O.C. Air Pollution Control District
O.C. Board of Supervisors
O.C. Planning Commission/ Dept.
O.C. Road Department
O.C. Health Department
City of Laguna Beach
O.C. Building Department


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-------
Newport
Beach
                V-   i    ~f -X*   ' '  -  i\ .
                          Laguna BeacHw..
                                                           Dana Point i
Exhibit  2-9
                                                                SOURCE: BOLT BERANEK AND NEWMAN, INC JULY, 1972

-------
 Man's  presence  in  the area may go back to the late Pleistocene  (ca. 20,000
 B.C.)  or  earlier.   Further intensive  research is required to ascertain this
 possibility.

 However,  it  can  be surmised  that the  Native Americans occupied and utilized
 the  area  without interference until about 1770.  Aliso Creek was the terri-
 torial  boundary  between  the  Gabrielino Indians to the north and the Juaneno
 Indians to the  south.  Linguistically the two groups were quite diverse,
 but  culturally  they had  many basic  similarities.  Dwellings consisted of
 tule mats on  the pole frames.  Many villages had small earth-covered sweat
 houses.   The  subsistence base was comprised of marine resources, acorns,
 seeds  and small  mammals.  Many archaeologists estimate that between the years
 2500 B.C. and 1800 A.D.  over two hundred Indian camps were established on
 what was  to become known as  the Irvine Ranch.

 The  first Spanish  contact for the region began with Portola's expedition of
 July 1769.   It was at this time that the Spanish probably met the Juaneno
 at the various areas of  future Capistrano Mission, Trabuco Mesa, and Tomato
 Springs.

 Soon afterwards, "missionization" of the populations began to ensue, in-
 troducing European conditions into  the region.  Eventually, the Native
 American or Gabrielino Indian societies of what is now Orange County dis-
 integreated through forced removal   to the missions, introduced diseases and
 the  general  demoralization which accompanied the Spanish Conquest.   Those
 Indians who survived the mission period (ca. 1770-1834) became dependents
 of the Rancheros who proliferated during the Rancho period (1834-1848).
 Such dependents worked as vaqueros and domestics on the huge ranches.

 In the early  1830's and 1840's the Ranches had reached their highest
 development dependent upon cattle raising for the economic livelihood.
 It was during this period that early Californians like Jose Sepulveda
 (grantee of Rancho San Joaquin), Juan Avila (grantee of 'Rancho Niguel  and
 several other ranches), and  Jose Maria Acura and Isidor Oliveras,  who
 occupied "ungranted" land which stretched from Rancho Niguel  to the ocean,
 acquired ownership of the land in southern Orange County.   Rancho  San
 Joaquin later passed into the hands of James Irvine in 1868.

 Rancho Niguel, which was originally granted to Juan Avila  in  1842  by
 Governor Juan Alvarado, occupied an area  east of Laguna Canyon and  west
 of El Camino Real near El Toro.   In 1868,  the Rancho  was sold to C.B.
 Dawson and finally, in 1875,  to Lewis F.  Moulton.   Out of the purchase
of the Rancho and by adding  surrounding acreage,  L.F.  Moulton developed
 the  ranch into 26,000 acres.   It was situated between  Laguna  Canyon and
 Salt Creek,  south from El Camino Real  to  the ocean.   Laguna  Niguel  and
 Leisure World are a part of the old Moulton Ranch.

Several developments in the AWMA region mark what is  referred to as the
American Period (after 1848).  The  coming  of the stagecoach  line,  the  coming
of squatters  on the San Joaquin  ranch; the establishment of a school at
 the  intersection of Niguel  Road  and Laguna Canyon,  the bee industry,
                                     2-63

-------
 the hauling of water from the Laguna  Canyon,  and  homesteading  are  all
 examples  of activity during  the American  Period.

 2.16.2   Historical  Landmarks

 In  1969,  the Orange County Planning Department  published  a  Historical
 Landmarks  study as  part  of their county wide  General  Plan Program.   In
 addition  to this  document, a "Travelers Guide to  Historical  Sites  of the
 Irvine  Ranch (Northern Half)"  was  prepared  in 1919 and appeared  in The
 Rancho  San  Joaquin  Gazette.   In combination these two documents  provide
 a detailed  listing  of significant  historical  and  natural  landmarks of the
 AWMA region.   The Archaeological/Historical Resources Map provides the
 location of the following landmarks:

     *OCPD  Site  -      Portola's Trail crosses the northern  portion of the
                      Study  Area
      OCPD  Site  -  68  Moro Canyon  Indian  Site
      OCPD  Site  -  69  Home of  the  Pageant of  the Masters, Laguna Beach (1921)
      OCPD  Site  -  70  Laguna Beach Art Gallery  (1929)
      OCPD  Site  -  71   Laguna Stage Coach  Stop
      OCPD  Site  -  72   Arch Beach~Boom Town  (1886)
      OCPD Site  -  73  Goff Island  Indian  Site,  South Laguna Beach
    **IR Site    -  10   El  Toro  Cemetery (1884)
      IR Site    -  11   Canada de Los Alisos  (1842)
      OCPD Site  -  77   Jose Serrano Adobe  (1856)
      OCPD Site  -  78   St. Georges  Episcopal Mission (1890's)
      OCPD Site  -  79   Leisure World Marine Deposit
      OCPD Site  -  80   The Stage Coach Stop
      OCPD Site  -  81   Seacow Skull Discovery Site
* OCPD = Orange County Planning Department
**IR = Irvine Ranch
                                    2-64

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 3.0  WASTEWATER MANAGEMENT  ALTERNATIVES

 3.1  DESCRIPTION OF  PROPOSED  ALTERNATIVES

 Five viable project  alternatives  were  formulated  and  are  described  in  some
 detail  below.   A sixth  alternative,  although  unfeasible because  of  violation
 to public  health codes  and  SRWQCB regulations is  also described.  The  alterna-
 tive of "no action"  is  discussed  in  order  to  compare  the  effects of the  viable
 alternatives as they relate to  the operation  of the current wastewater system.

 Two modes  of communication  were devised  to facilitate comparison of the  various
 alternatives.   A topographic  map  with  schematic representation of facilities  is
 presented.   Then a schematic  diagram shows each alternative.  Estimated  1995
 flows and  sizes of all  proposed facilities and expansions are also  provided on
 the schematic.   A comparison  of the  schematic diagram with the topographic map
 schematic  demonstrates  the  relationship  between the existing facilities  and
 each proposed alternative.

 3.1.1   Alternative 1A -  Local Treatment, Regional Disposal

 This alternative represents an  extension of the current treatment practices
 and methods  combined with regional outfall  facilities  for cases  where  reclaimed
 wastewater  from inland  plants cannot be  successfully  discharged  to  the land.
 It maximizes the reclamation  potential of  the Los Alisos, El Toro and  Moulton-
 Niguel  Water Districts  treatment  plants.

 This  alternative requires the enlargement  of  local plants, construction of a
 regional effluent transmission  main and a  north coast  interceptor and ocean
 outfall.  The use of two existing  short, shallow ocean outfalls  and the
 Laguna  Beach treatment  plant would be  terminated and  the South Coast Interceptor
 would be replaced.   Capital cost of this alternative  is estimated to be $37.9
 mi 11i on.*

 3.1.1.1  Wastewater  Treatment Plants

 As  part of  the  overall  improvements to the Los Alisos Water District treatment
 plant,  the plant  is  currently being expanded  to a capacity of 4.0 mgd.  This
 expansion is included in as a part of alternative 1A.

 The  Rossmoor Sanitation, the treatment plant  serving the El  Toro  Water District,
 will be expanded  to  a capacity  of  6.5 mgd.

 The  Moulton-Niguel Water District No. 2A plant will  be expanded for a capacity
 of  .85 mgd.

 The Moulton-Niguel Water District No. 1A plant will  be expanded to a capacity
 of  2.5 mgd.
*Detailed cost analysis can be found in the 1974 Project Report prepared by
 Don Owen and Associates.


                                       3-1

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Newport
Beach
                                                                                 S8F
                                  w<
                             -^- :f-4 f' .
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                                                                           •:-A
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                                                            ' Vl^C- :->-,''L^V'     1  1  '  \ UM"?.        V
                                                            '. •  . .  j  f,  - j*~   '.'-I'-
Legend
.........  RAW SEWAGE INTERCEPTOR
o__  LAND OUTFALL
	  OCEAN OUTFALL
"	«  FORCE MAIN
  A    PUMP STATION
  (g)    ABANDONED TREATMENT PLANT
        SECONDARY TREATMENT PLANT
Dana Point
Exhibit  3-1

-------
Project Alternative 1A provides
maximum reclamation potential
of  secondary treated effluent
through expansion of the LAWD
ETWD, and MNWD treatment
plants and provides impoved treat-
ment and disposal from the IRWD,
EBSD, City of Laguna Beach and
SLSD by expansion of the existing
South  Laguna treatment plant
and construction of a new North
Coast Interceptor and deep ocean
outfall.  Unreclaimed effluent
generated during the rainy season
from the upper Aliso treatment
plants will pass down a land out-
fall through Aliso Valley to the
ocean outfall.
4.0
MGD
6.5
MGD
              NORTH COAST INTERCEPTOR
                           MNWD 4A
                           PLANT
                           1.8 MGD
                                                           1.3
                                                           MGD
                                                   18"
                                                            0.9
                                                            MGD
              IBIBIWIIII^
         SOUTH COAST INTERCEPTOR
 Exhibit  3-2a
                 ALTERNATIVE     1A

-------
 A new activated sludge (secondary)  treatment plant with a capacity of 1.8 mgd
 would be constructed in the Moulton-Niguel  Water District and would be known
 as Improvement District 4A.  This plant would be located at the northerly side
 of Aliso Valley at the westerly extension  of Aliso Creek Road.   This area to be
 served is now called the Moulton Ranch and is presently undeveloped.   There-
 fore, construction of the facilities would be deferred until  about 1978.

 Addition to the existing treatment  facilities of the  Aliso Creek plant of the
 South Laguna Sanitary District is also included  in this alternative plan.  The
 plant will  be expanded to a capacity,of 5  mgd.   In addition,  expansion of sludge
 facilities  would be required.   The  expansion would be adjacent and easterly of
 the existing site,  at an elevation  requiring a lift of about  40 feet.   The
 plant would serve South Laguna Sanitary District as well  as the North Coast
 Area.

 3.1.1.2   Outfalls

 The northern most reach of the outfall  system would connect the Los Alisos
 Water District plant to the Rossmoor Sanitation,  Inc.  plant.   This reach  would,
 in part,  follow the San Diego  Creek and cross under the San Diego  Freeway.

 Below the Rossmoor  Sanitation,  Inc.  plant  the next reach  would  include a  pumping
 station  and force main in Moulton Parkway  to convey the treatment  effluent from
 the two  plants over to the Aliso  Creek  drainage  area.   A  gravity flow portion of
 the pipe  then continues in Moulton  Parkway  to Aliso Creek.

 Where  Aliso Creek meets  the proposed extension of  Alicia  Parkway,  southerly of
 Moulton  Parkway,  the  outfall from the Moulton-Niguel  Water  District Plant  2A
 would  join  the Los  Alisos-El Toro.   Below  this point  of juncture,  the outfall
 would  follow the  general  alignment  of Aliso  Creek.

 The Upper Sulphur Creek  outfall would utilize an existing  interceptor owned by
 Moulton-Niguel  Water  District and would  convey water  to the Aliso  Creek plant
 for treatment.   Below the South Laguna  Sanitary District,  the outfall would
 extend from the Aliso treatment plant to the  Coast  Highway, following the  stream
 bed  alignment.  Construction of the  reach would be  limited  to summer  and dry
 periods and  the final  design should  incorporate flood protection facilities.

 The  ocean outfall would  extend from  the Coast Highway,  under the beach and off-
 shore  to  180  feet.  At  the  end of the outfall would be a diffuser  of  1,200 feet
 in  length.   Total estimated  length of the outfall and diffuser on  the ocean
 bottom would  be approximately 8,200  feet.  The outfall pipe diameter would be
 48  to  54  inches.  (See Section 4.3.4  for a discussion on Coastal Commission
 restrictions.)

 3.1.1.3   Interceptor  and  Pump Stations

The Salt Creek Pump Station No. 2 and force main would be constructed in 1975
 near the Coast Highway at Salt Creek.  The force main would extend up Salt Creek
 to the existing Arroyo Salada Pumping Station.

The Arroyo Salada Pumping Station and force main is an existing facility that
extends from the southerly boundary of the Moulton-Niguel Water District along
or adjacent to the Crown Valley Parkway, to the vicinity of Paseo del Niguel.


                                      3-2

-------
The South Crown Valley Trunk Sewer Unit No. 2 is an existing 12-inch pipe
extending from the end of the Arroyo Salada force main to Paseo del Ville near
Hillhurst Drive.  A parallel line would be needed to increase the capacity to
2.2 mgd.

The South Crown Valley Trunk Line Sewer Unit No. 1 is an existing pipe gravity
line extending from the terminus of Unit 2 to the vicinity of Niguel Road and
Crown Valley Parkway.  A parallel line will be needed to increase the capacity
along this portion.  From that point a portion of the line extends along
Sulphur Creek adjacent to and westerly of Crown Valley Parkway.  The line then
extends northerly to the Moulton-Niguel Water District 1A point.

The Salt Creek pump station No. 1 force main and gravity sewer are existing
facilities located in the Monarch Bay area.  The pump station is located near
the beach at Monarch Bay.  The force main and gravity sewer extends to Crown
Coast Drive to La Senda Place and through Three Arch Bay.  There is no addi-
tional capacity needed in this reach.

The South Coast Interceptor sewer and tunnel is a facility consisting of an
existing tunnel excavated in the bluff material about 75 to 100 feet from the
shoreline and extending from La Senda Place in Three Arch Bay to Aliso Creek.
The existing sewer in the tunnel has deteriorated and is being replaced.  A
portion of the interceptor extends from the tunnel portal at Aliso Creek to the
Aliso Creek pump station.  This line is in good condition and would not be
replaced.

Aliso Creek Pump Station and Force Main is an existing facility owned by the
South Laguna Sanitary District.  The pumping station is located on the west
side of Aliso Creek about 700 feet inland from the Pacific Coast Highway.   It
extends from the pumping station in an easement in a private road to the vicinity
of Ben Brown's Restaurant.   From there it crosses the Laguna Beach Country Club
Golf Course and continues adjacent to Aliso Creek to the Aliso Creek treatment
plant.

3.1.1.4  Alternative 1A Modified-Local  Treatment, Regional  Disposal

In Chapter 5 of the Draft EIS EPA made several  modifications to Alternative 1A
and proposed the alternative for additional consideration (Exhibits 3-2b and c).
Two modifications were made in Chapter 5.   First, expansion of Moulton-Niguel
plants 1A and 2A was not proposed because experience with the 'rapid bloc'  sys-
tem used in those plants indicated that expansion was not desirable.   Also,
the proposed Moulton-Niguel  Improvement District's 4A plant would be con-
structed to serve the entire Moulton-Niguel Water District.   Second,  construc-
tion of the Sulphur Creek interceptor and the Moulton-Niguel  4A plant would be
deferred until  needed.   All  other features of Alternative 1A modified are
identical  to those of Alternative 1A.

Subsequent to publication of the Draft  EIS, AWMA decided  to postpone construc-
tion of the Sulphur Creek interceptor,  regardless of the  final  alternative
selected.   In addition,  EPA's rejection of the  regional  plant site left the
entire issue of a treatment plant for the Moulton-Niguel  Water District
unresolved (see Chapter 5).   Therefore, Alternative 1A modified should merely
be viewed as a  slight modification of alternative 1A in order to avoid expand-
ing the inflexible 'rapid bloc'  plants  at Moulton-Niguel  Improvement District's
1A and 2A.
                                      3-3

-------
Newport
Beach
                   •  '\   i'V^-M- ''. v ,4
Legend
South Laguna\* *5
......... RAW SEWAGE INTERCEPTOR
^•^ LAND OUTFALL
	 OCEAN OUTFALL
       FORCE  MAIN
       PUMP STATION
       ABANDONED TREATMENT PLANT
       SECONDARY TREATMENT PLANT
           Dana Point —.V
Exhibit 3-2b

-------
As with Project Alternative 1A,
Alternative 1A-Modified provides
maximum  reclamation  potential
of secondary treated effluent in
the upper, middle, and lower
Aliso  Valley.  This alternative,
however, consolidates  reclama-
tion in the middle Aliso Valley
into one  sub-regional  MNWD
treatment plant and phases out
two smaller plants. This alterna-
tive also provides improved treat-
ment  and  disposal from the
IRWD,  EBSD, City of  Laguna
Beach and SLSD by expansion of
the existing South Laguna treat-
ment plant and construction of a
new North Coast Interceptor and
deep ocean outfall. Unreclaimed
effluent generated  during the
rainy  season  from the upper
Aliso treatment plants will pass
down a land outfall through Aliso
Valley to the ocean outfall.
                       LAWD PLANT
                       ROSSMOOR PLANT
                                                          MNWD 2A PLANT
                 8
SULPHUR CREEK
INTERCEPTOR
                                                               MNWD 1A PLANT
                                                             18"-24"
                                                             4.7 MGO
                                                           • 18"
                                                           • 2.2 MGD


                                                           I,
                                                           5 22 MGD
                                              5.0 MGD
                                        o
           CITY OF LAGUNA BEACH PLANT
 59        5.9
 MGD   24,,   MGD
              NORTH COAST INTERCEPTOR
                                                  JOINT
                                                  MNWD-SLSD PLANT
                                                    18"
                                                              0.9
                                                              MGD
                            IBIBIBlllll^

                       SOUTH COAST INTERCEPTOR
Exhibit 3-2c
ALTERNATIVE   1A
MODIFIED

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 3.1.2   Alternative  2E  -  Central Treatment.  Regional  Disposal

 Alternative  2E  represents a  concept of  central  treatment within  the AWMA area.
 None of the  individual existing inland  treatment  plants would  be operated
 except  for water  reclamation purposes.   Central treatment of the raw  sewage
 would occur  at  a  new central  sewage treatment plant  which would  be located
 approximately 1,800 feet north of  the existing  South Laguna Sanitary  District
 plant.   Capital costs  for this alternative  are  estimated to be $27.7  million.

 Raw sewage from the upper Aliso area would  flow towards Aliso  Creek where
 raw sewage from Moulton-Niguel Water District Improvement District 2A would
 join the conveyance system on its  course to the central treatment plant.  The
 existing treatment  plant at  M-NWD  1A would  be completely abandoned.   This
 pipeline would  follow  Aliso  Creek  on the east side to its junction with
 Sulphur Creek.

 In the  Salt  Creek service area, flows would be  pumped northward to the
 Sulphur Creek drainage area.  In order  to carry raw  wastewater from the
 Salt Creek service  area  to the Sulphur  Creek drainage area, existing  pipe-
 lines would  have to be paralleled  and new pumping facilities would have to
 be constructed.

 At the  confluence of Sulphur and Aliso  Creeks the raw sewage flows from
 Los Alisos Water District, Rossmoor Sanitation  Inc., Moulton-Niguel Water
 District Improvement District 2A would  be combined with the flows conveyed
 by the  Sulphur  Creek service area  and interceptor sewer and would be  conveyed
 down Aliso Creek to the  regional plant.

 The North Coast Interceptor would  convey wastewater  from Irvine Ranch Water
 District, Emerald Bay  Service District  and the  City  of Laguna to the  regional
 treatment plant.  Provisions would also be made to divert, when necessary, a
 portion  of the  flow to the existing South Laguna Sanitary District treatment
 facilities.  The interceptor will   begin at a pumping station located  in Morro
 Canyon  between  the  Pacific Coast Highway and the ocean.   From Aliso Creek and
 Pacific  Coast Highway, the North Coast  Interceptor will  turn up Aliso Creek
 following a  path parallel to the existing force main from the existing Aliso
 Creek pump station.  Flow will be  under pressure to  the regional  treatment
 facility.

 The South Laguna Sanitary District treatment facility operates using the
 activated sludge process and has a design capacity of 3.2 mgd.   The effective
 capacity of  this facility will be decreased to 2.6 mgd to meet the waste
 discharge requirements set by the State ocean standards  and the Coastal
 Commission's requirements for nitrification.  It is  planned to eliminate all
 sludge  treatment facilities at this facility and discharge sludge to that
 portion of the North Coastal  Interceptor which continues up to Aliso Canyon
 to the regional  plant inflow and pumping station.

The regional  treatment facility will  provide secondary treatment  using the
conventional  activated sludge process  or modifications thereof, such as
step feed and re-aeration.   The plant  will  have an initial  capacity of 16.0
mgd.   The outfall  will  originate at the regional treatment facility and  will
consist of three reaches, similar  to those for Alternative 1A.   Second stage
construction will  involve the expansion of the regional  treatment facility
                                      3-4

-------
Newport
Beach
                       -
                         •->•
Legend
...... RAW  SEWAGE INTERCEPTOR
—^ LAND OUTFALL
	 OCEAN OUTFALL
	'"'•«	««i FORCE MAIN
  A   PUMP STATION
  (g)   ABANDONED TREATMENT PLANT
  (J   SECONDARY TREATMENT PLANT
       REGIONAL SECONDARY
       TREATMENT PLANT
                                                 Dana Point
Exhibit  3-3

-------
 Project Alternative 2E provides
 consolidation of wastewatertreat-
 ment to a regional facility in lower
 Aliso  Valley. Existing  inland
 plants will continue to operate for
 reclamation during demands for
 irrigation water. Untreated sewage
 will bypass the LAWD, ETWD,
 and MNWD plants, through a rew
 sewage interceptors transporting
 the sewage to the regional plant.
 Effluent disposal will be accom-
 plished through a newly construc-
 ted ocean outfall.
                                        LAWD PLANT
                                            ROSSMOOR PLANT


                                           36"/9.2 MGD
                                       kUl
                                                         MNWD 2A PLANT
                                            SULPHUR CREEK
                                            INTERCEPTOR
                                                             MNWD 1A PLANT
                                                            21"-24"/2.5 MGD
                        REGIONAL  PLANT
                        19.5 MGD
           CITY OF LACUNA BEACH PLANT
1.3
MGD
16"   15" "i00 16"    18"
        IIIIHIBI
           NORTH COAST INTERCEPTOR
                                                      4
                                                      i
                                                            24"/2.5 MGD
 S • 54"-48719.5 MGD
      2.5 MGD        Al6"/1.17 MGD

   ^^   JOINT MNWD-SLSD PLANT

ks ^^^^


   Ik   i
                 18"/1.75 MGD
                                         SOUTH COAST INTERCEPTOR
 Exhibit  3-4
                  ALTERNATIVE    2E

-------
 from 16 mgd  to  24 mgd which, when combined with the South Laguna plant, will
 provide a  total treatment capacity of 26.6 million gallons per day.  The
 treatment  would take place at this location and discharge into the outfall
 system which is also sized for 26.6 mgd in the 1975 construction.

 Four alternative sites in the Alisq Valley (Exhibit 3-5) near the existing SLSD
 plant were considered.  The preferred site and the existing SLSD plant site are
 shown on Exhibit 3-6.  About 17 acres of land are required for the proposed
 16  mgd treatment plant.  This 17 acres would also provide space for expansion
 to  24 mgd  in most locations.

 Site 1 is  located immediately southeast of the existing SLSD plant.  The site
 is  in a small canyon with ground elevations ranging from about 60 feet above
 sea  level  at the SLSD plant to about 160 feet above sea level at the eastern
 edge of the  site.  The maximum area available without extensive earthwork is
 approximately 5 acres.

 Site 2 is  the preferred site located approximately 1500 feet north of the
 existing SLSD plant (Exhibit 3-6).  The proposed site is approximately 17 acres
 in  size.   Ground elevations range from about 50 feet above seal level to the
 southern end to about 75 feet above sea level on the eastern edge of the site.
 The  present  channel of Aliso Creek runs through the proposed site (Exhibits 3-7
 to  3-9).

 Site 3 is  located approximately 1.5 miles upstream of the existing SLSD plant
 and  about  0.25 miles south of the Wood Canyon confluence with Aliso Creek.  The
 site is located along the eastern edge of Aliso Creek with Ground Elevations
 of about 80  feet above sea level.

 Site 4 is  located about two miles upstream of the existing SLSD plant and
 0.25 miles upstream of the Wood Canyon confluence with Aliso Creek.  The site
 located on the north side of Aliso Creek with ground elevations of 100 to 150
 feet above sea level.

 3.1.3  Alternative 3C - Reclamation

 Alternative  3C represents a concept of broad scale wastewater reclamation
 within the Aliso Water Management Agency area.   The objective of this alterna-
 tive would be to eliminate dependence on ocean discharge and utilize the
 treated effluent for reclamation and irrigation purposes.   Whatever excess
 treated effluent could not be used for these purposes would be disposed of in-
 to the Aliso Creek thereby enabling the stream flow to convey the effluent to
 the  ocean.

To provide a high quality effluent, this alternative would utilize two
advanced wastewater treatment facilities and would introduce tertiary processes
 such as denitrification,  chemical  clarification,  carbon absorption and chlori-
nation.  Capital costs of this alternative are estimated to be $43.3 million.

The  collection system and plant site locations would be very similar to those
described in Alternative  2E.   Major variations would be the degree of treat-
ment, the need for an  ocean outfall,  and construction of an extensive network
of land outfalls and pump stations for reclamation in the  Upper Aliso Watershed.
                                      3-5

-------
                                                Dana Potat
Exhibit 3-5

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PAGE NOT
AVAILABLE
DIGITALLY

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 AREA NORTH OF PROPOSED PLANT SITE

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  AREA SOUTH OF PROPOSED PLANT SITE

-------
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 AREA NORTH OF PROPOSED PLANT SITE

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  AREA SOUTH OF PROPOSED PLANT SITE

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 AREA NORTH OF PROPOSE-D PLANT SITE

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  AREA SOUTH OF PROPOSED PLANT SITE

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 ALISO CREEK CHANNEL ADJACENT TO
 PROPOSED REGIONAL TREATMENT PLANT

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Newport
Beach


                                                                              l^^^Q^i!
                                                                            OY. .'„ -'ft '/fv" &»•
                                                                           iyic«


Legend
.i.mi.i. PAW  SEWAGE INTERCEPTOR
^••M LAND OUTFALL
	 OCEAN OUTRftLL
i	"	 FORCE MAIN
  A    PUMP STATION
  (g)   ABANDONED TREATMENT PLANT
       SECONDARY TREATMENT PLANT
       REGIONAL A.W.T. PLANT
Dana Point
Exhibit  3-10

-------
maximum reclamation potential
of tertiary treated effluent through
the construction of a new regional
advanced wastewater treatment
plant. The new plant to be located
in lower Aliso  Valley  would
enable the treated effluent to be
utilized  throughout the  Aliso
watershed for recharge to the
groundwater basin, discharge to
Aliso Creek with continued stream
flow to the ocean, discharge to
recreational lakes, and irrigation.
Excess effluent would be dis-
charged to Aliso Creek during the
dry season, and to the existing
SLSD ocean  outfall during the
rainy season. This system would
serve all of the agencies except
the  North Coastal area which
would utilize its own independent
.advanced wastewater treatment
for disposal through reclamation
and stream-flow within the Irvine
Ranch Water  District drainage
areas.
          REGIONAL
          A.W.T. PLANT
          16 MGD
                     LAWD PLANT
                   30"
ROSSMOOR PLANT
                           1878 MGD^ggl
                              Ml^
                                  MNWD2A PLANT
                 • SULPHUR CREEK
                 | INTERCEPTOR
                O—
                                                                   MNWD1A PLANT
                                                                  0.8
                                                                  MGD
                                                      JOINT MNWD-SLSD PLANT
                CITY OF             =
                LAGUNA BEACH PLANT = 18'/16.1 MGD
                  4.8
                  MGD
                               16.1
                               MGD
                                         18"
             24"/5.9 MGD
           II
                                      SOUTH COAST
                        INTERCEPTOR
 Exhibit  3-11
                   ALTERNATIVE    3C

-------
 The North Coast Interceptor would not be constructed under this alternative;
 instead a reclamation project would be located in the North Coast service area.
 Effluent from the North Coast service area would be treated at a new plant to
 be constructed near Morro Canyon.  The Morro Canyon plant would have an acti-
 vated sludge plant and then have the same tertiary processes described for
 the main plant in Aliso Valley.   This project, instead of requiring a pipeline
 from the regional plants down to the coast and then for ocean outfall, would
 rely upon the existing outfalls  of the South Laguna treatment plant and the
 Laguna treatment plant to discharge tertiary treated effluent during periods
 of time when the water could not be utilized.   There would be no new ocean
 outfall.

 3.1.4  Alternative 4A - Partial  Regional  System with Stream Discharge in
        Upper Aliso Creek Area

 Alternative 4A separates the AWMA area into essentially two service areas.  The
 Upper Aliso service area would be independent  of the lower All so and the coastal
 areas.   The concept would be similar to Alternative 1A except that the Los
 Alisos  and El  Toro Water Districts'  flows  would be combined into a tertiary
 treatment process with bio-stimulant removal and discharged into the San Diego
 Creek.

 This  alternative would enable the facilities in the lower  Aliso  and coastal
 areas to  be reduced in size and  capacity.   This would  also reduce the  size  of
 the ocean outfall  from 29 mgd to 17  mgd.

 The advanced wastewater reclamation  facilities  to  be constructed  for the Upper
 Aliso service  area  would be essentially the tertiary processes described in
 Alternative 3C.   Other aspects of the  North Coast  Interceptor and  South  Coast
 Interceptor would  remain the same as those  described in Alternative 1A.   Capital
 costs for this alternative  are estimated to be  $39.7 million.

 3.1.5 Alternative  2F  -  Regional  Treatment, Regional Disposal with  Upstream
       Reclamation

 Alternative 2F represents a  consolidation of treatment through the  construction
 of a  regional wastewater treatment plant.   Wastewater will  be collected  from
 the total  area and  treated  at.a  central plant using  an activated sludge  process.

 Alternative  2F is essentially the central treatment and outfall project  pro-
 posed as  Alternative 2E  except for the  addition of 4 mgd of wastewater recla-
 mation in  the Upper Aliso area to provide for irrigation of greenbelts through-
 out the Aliso Valley.  Capital costs for this alternative are estimated  to be
 $27.4 million.

 This alternative involves a trade-off of wastewater reclamation in the Upper
 Aliso reaches with the summer population flow of the coastal communities of
 Laguna and South Laguna.  During the summer months the summer population uses
 the central treatment facilities and the outfall facilities of the lower reach,
while wastewater reclamation for irrigation can be performed in the Upper
Aliso service area.  During the winter periods  (when rainfall creates a problem
with wastewater reclamation) the summer population of Laguna and South Laguna
 is not present and the facilities of central treatment and ocean discharge are
available for the Upper Aliso service area.
                                       3-6

-------
       jH- ,->'a'-\r-'--"-^u^ ^"^^C^Sc• ^ I-
                          NORTH COAST
                          INTERCEPTOR
                                         SOUTH COAST
                                         INTERCEPTOR
legend
I
      RAW SEWAGE INTERCEPTOR
      LAND OUTFALL
	  OCEAN OUTFALL
n	mini  FORCE MAIN
A    PUMP STATION
0    ABANDONED TREATMENT PLANT
3    SECONDARY TREATMENT PLANT
A    A.W.T. PLANT
   hibit  3-12

-------
 Project  Alternative 4A  would
 enable the upper Aliso area to
 provide  independent  disposal
 through the construction of an
 advanced wastewater  treatment
 plant and land outfall. Treated
 effluent would be utilized in the
 upper Aliso and Irvine Ranch area
 for man-made recreational lakes,
 irrigation and other miscellaneous
 urban uses throughout most of
 the year, with excess effluent to
 be discharged to San Diego Creek.
 Dislocation of the upper Aliso
 area, enables  the local and
 regional treatment facilities in the
 lower Aliso and coastal areas to
 be reduced in size and  capacity.
 Excess treated effluent from the
 SLSD and MNWD plants not used
 for irrigation would pass through
 a pipeline in lower Aliso Valley to
 the ocean outfall.
                                         LAWD PLANT
                                         ROSSMOOR PLANT
                          A.W.T. PLANT
                          10.0 MGD
                                                               MNWD2A PLANT
                                           1270.7 MGD
                                                               3.8 MGD
                            MNWD 4A
                            PLANT
                            10.0 MGD
            CITY OF LACUNA BEACH PLANT
1.3
MGD
 15J™16"
11 •MUM 11
                          5.9
I                             24"
                             Hill
                                 24"
             NORTH COAST  INTERCEPTOR
                                                                    MNWD1APlMN-|
                                                                  18"-24"/4.7 MGD
                                                                  18-/2.2 MGD
                                                                S 18"/2.2 MGD

                                                                  2.2
                                                                  MGD
                                                      JOINT MNWD-SLSD PLANT
                                    5.9
i IMIHN*
                                                          MGD
                                                               12"
                                0.9
                                MGD
    B 18"/1-5 muu   it  ^
• iVIBlHIBIBIIini^

SOUTH COAST INTERCEPTOR
 Exhibit  3-13
                    ALTERNATIVE    4A

-------
•tf-r-  )--^  j    */:3

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 I  /•  .,.  ,   V .—»       -'^ ••«' » ^ / ,-   X
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                                                               '  te&g
                                                                    - vrw
                                                              I
                                                              (4  .
                                        V-. . ,
                                                             I
                    NORTH COAST
                    INTERCEPTOR
legend
            ***_rSR ,
            IpLA^rl '
              ?l   '-        i    ""A
                           J v    V        '
South Lagun^K^fxJ J' ^>^" §/
         ^P>i'Kl '   #:rr 7    "J


                                                                      v/»



                                                             v

I
      RAW SEWAGE INTERCEPTOR

      LAND OUTFALL

      OCEAN OUTFALL

 	mi	 FORCE MAIN

  A   PUMP STATION

  g)   ABANDONED TREATMENT PLANT

  J   SECONDARY TREATMENT PLANT

      A.W.T. PLANT
                               SOUTH COAST
                               INTERCEPTOR
                                        -

                               /
                               '.       ', ]


                                    - W   ,'.
                                      Dana Point _....
                                             ' -
  [hibit 3-12
  JOOO 4000  1000
                                                   ~"  Capistrano
                                                      Beach'

-------
Project Alternative  4A  would
enable the upper Aliso area to
provide  independent disposal
through the construction of an
advanced wastewater treatment
plant and land outfall. Treated
effluent would be utilized in the
upper Aliso and Irvine Ranch area
for man-made recreational lakes,
irrigation and other miscellaneous
urban uses throughout most of
the year, with excess effluent to
be discharged to San Diego Creek.
Dislocation of  the upper Aliso
area,  enables  the  local and
regional treatment facilities in the
lower Aliso and coastal areas to
be reduced in size and capacity.
Excess treated effluent from the
SLSD and MNWD plants not used
for irrigation would pass through
a pipeline in lower Aliso Valley to
the ocean outfall.
                                                LAWD PLANT
                                                ROSSMOOR PLANT
                                A.W.T. PLANT
                                10.0 MGD
                                                             MNWD 2A PLANT
                                          1270.7 MGD
                                                             3.8 MGD
                           MNWD 4A
                           PLANT
                           10.0 MGD
1.3
MGD
     CITY OF LAGUNA BEACH PLANT
   15              5.9
  ..MGD        „ .X-^MGD
i lii^iiiiM i • i •^X)^HIIB i • i

      NORTH COAST  INTERCEPTOR
                                                                  MNWD1APMJN1
                                                                18"-2474.7 MGD
                                                                18"/2.2 MGD
                                                              S 18-/2.2 MGD
                                                                2.2
                                                                MGD
                                                     JOINT MNWD-SLSD PLANT
                                                              12"
                                                                 0.9
                                                                 MGD
                                                  B 18'71.5 MGD
                                                 mmlm\m\
                                              SOUTH COAST INTERCEPTOR
 Exhibit  3-13
                   ALTERNATIVE    4A

-------
IKl       ~-*v   ^v
TSU  •••     *\ 'V;-, ,

                I'
           Laguna Beach i
             NORTH COAST
             INTERCEPTOR
- K<5n>,
'-.  •
-.•»• •O-''.: I
                        .V. P, \. T    ' ~
                        \ ^ MWITJIA',
                        k \v'SLW Os
                                ^ .
                        &       /   i-w
                                  '^^

legend
   r^iP^rw!
   /-^BEUfl
South Laguna^ll
    RAW SEWAGE INTERCEPTOR
    LAND OUTFALL
 	 OCEAN OUTFALL
 	i FORCE MAIN
 A  PUMP STATION
 (g)  ABANDONED TREATMENT PLANT
 3  SECONDARY TREATMENT PLANT
 A  A.W.T. PLANT
SOUTH COAST
INTERCEPTOR
                     I
                           I
                         .  ~
                    /  "r 1Nt  "
                          -
                   V\
                    \      '


                       rJ • .



    Dana Point _.,-£^

 [hibit 3-12
                          iu

-------
 Project  Alternative 4A  would
 enable the upper Aliso area to
 provide  independent  disposal
 through  the construction of an
 advanced wastewater treatment
 plant and land outfall. Treated
 effluent would be utilized in the
 upper Aliso and Irvine Ranch area
 for man-made recreational lakes,
 irrigation and other miscellaneous
 urban uses throughout most of
 the year, with excess effluent to
 be discharged to San Diego Creek.
 Dislocation of the upper Aliso
 area, enables  the local  and
 regional treatment facilities in the
 lower Aliso and coastal areas to
 be reduced in size and  capacity.
 Excess treated effluent  from the
 SLSD and MNWD plants not used
 for irrigation would pass through
 a pipeline in lower Aliso Valley to
 the ocean outfall.
               LAWD PLANT
                ROSSMOOR PLANT
A.W.T. PLANT
10.0 MGD
                                                               MNWD 2A PLANT
                                           1270.7 MGD
                                                              3.8 MGD
                           MNWD 4A
                           PLANT
                           10.0 MGD
1.3
MGD

  CITY OF LACUNA BEACH PLANT

1.5               5.9         5.9
 ID

  HUB I

   NORTH COAST  INTERCEPTOR
                                                                    MNWD1AP
                                           All
                                                                  18"-24"/4.7 MGD
                                                                  18'7 2.2 MGD
                                                                mi 18"/2.2 MGD
                                                                  2.2
                                                                  MGD
                                                      JOINT MNWD-SLSD PLANT
                                 24" ^  18
                               • !•!
                                                        1.5 MGD   12"
                                  0.9
                                  MGO
                                               SOUTH COAST INTERCEPTOR
 Exhibit  3-13
                    ALTERNATIVE     4A

-------
                             •~v*r * ^'•f
                       Laguna Beach „,.,;„..
                            NORTH COAST
                            INTERCEPTOR
legend
 m.i.t.ii RAW SEWAGE INTERCEPTOR
I-— LAND OUTFALL
 	 OCEAN OUTFALL
l>	ii FORCE  MAIN
   A    PUMP  STATION
        ABANDONED TREATMENT PLANT
        SECONDARY TREATMENT PLANT
        A.W.T.  PLANT
  Ixhibit  3-12
   7000 4000 |   MOD
South Lagunai;

  SOUTH COAST
  INTERCEPTOR
                                                                                       *s
                                                                                       -•*,   -^1 • !.«.".! *

                                                                                    San ClementeV^BJ^^
                                                                                        •

-------
 Project  Alternative 4A  would
 enable the upper Aliso area to
 provide  independent  disposal
 through the construction of an
 advanced wastewater treatment
 plant and land outfall. Treated
 effluent would be utilized in the
 upper Aliso and Irvine Ranch area
 for man-made recreational lakes,
 irrigation and other miscellaneous
 urban uses throughout most of
 the year, with excess effluent to
 be discharged to San Diego Creek.
 Dislocation of the upper Aliso
 area, enables  the local  and
 regional treatment facilities in the
 lower Aliso and coastal areas to
 be reduced in size and  capacity.
 Excess treated effluent  from the
 SLSD and MNWD plants not used
 for irrigation would pass through
 a pipeline in lower Aliso Valley to
 the ocean outfall.
                                         LAWD PLANT
                                         ROSSMOOR PLANT
                          A.W.T. PLANT
                          10.0  MGD
                                                              MNWD 2A PLANT
                                           12-/0.7 MGD
                                                              3.8 MGD
                           MNWD 4A
                           PLANT
                           10.0 MGD
                                                                  18"-24"/4.7 MGD
                                                                  18"/2.2 MGD
                                                               S 18"/2.2 MGD
1.3
MGD
    16"
     CITY OF LAGUNA BEACH PLANT

   1.5              5-9

III^NlillHIB

      NORTH COAST INTERCEPTOR
24"   24"
IIIIBIHI
                                                                   MNWD1APLBN1
                                                                     I
                                                      JOINT MNWD-SLSD PLANT
                                               SOUTH COAST INTERCEPTOR
 Exhibit  3-13
                    ALTERNATIVE    4A

-------
f
 I  v'  x      "  ••       Y           '
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    I-;,  I    ) ••IX'J;.    k! ^
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      i™
                                    , LAWD
                                    ' PLANT

 K  m          vmMW&Sm**-
 I:iw^.|t^^fe'-     ?
 asfe,'..,, „... -"  7 v. '•-           "^ •  /  (* x- • 1  i   *'^.,JSi  ^^""sj\ ri--iiS^y-ck /" * $ -^ir\ J9

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                          J~
                       SEfci'l
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             Laguna Beach	,,,
               NORTH COAST
               INTERCEPTOR
                           :. •',
                                       MNWD2A(,«
                                       ftXtfT }-^
                       /     '-
              #'»-..<•     •


                           IVL.
                               -'^•'

                                  /

                                     , MNWD 1A
                                     PLANT
                                                  •• *«
                                             "'  \~Aif V'' 'f •

                                               ]
                                                 •
                                                      *

                                              J •"
                                                     *
                                             - \  -.^.-^

                                              1      I  -i
                                             jjrbm      {
legend
                               m
                                Wi
                                        •
I
  '•'• RAW SEWAGE INTERCEPTOR


    LAND OUTFALL


    OCEAN OUTFALL


 	mm FORCE MAIN


    PUMP STATION


    ABANDONED TREATMENT PLANT


    SECONDARY TREATMENT PLANT


    A.W.T. PLANT
                      South Laguna^
                        SOUTH COAST
                        INTERCEPTOR
                               4
                                       '

                               ^
                                                   .
                                                     .


                                                     '
                                   ^
                                   ,
                               &

                              *%   M$<
                                           r
  -*%}> •'
«•»*• —-x ff(f
                                  •-- " -  '""'' -'
                                       ~" Capistrano
                                        Beach" -,.
                                    •!•' •
                                        ill
 (hibit 3-12

-------
 Project  Alternative 4A would
 enable the upper Aliso area to
 provide  independent  disposal
 through the construction of an
 advanced wastewater treatment
 plant and land outfall. Treated
 effluent would be utilized in the
 upper Aliso and Irvine Ranch area
 for man-made recreational lakes,
 irrigation and other miscellaneous
 urban uses throughout most of
 the year, with excess effluent to
 be discharged to San Diego Creek.
 Dislocation of the upper Aliso
 area, enables  the local  and
 regional treatment facilities in the
 lower Aliso and coastal areas to
 be reduced in size and  capacity.
 Excess treated effluent  from the
 SLSD and MNWD plants not used
 for irrigation would pass through
 a pipeline in lower Aliso Valley to
 the ocean outfall.
               LAWD PLANT
               ROSSMOOR PLANT
A.W.T. PLANT
10.0 MGD
                                                              MNWD 2A PLANT
                                           1270.7 MGD
                                                              3.8 MGD
                           MNWD 4A
                           PLANT
                           10.0 MGD
                                                                 18"-24"/4.7 MGD
                                                                 18"/2.2 MGD
                                                               S 18"/2.2 MGD
M3GD
            CITY OF LAGUNA BEACH PLANT

                         S.9
            IIIIBIBI

             NORTH COAST INTERCEPTOR
                                                                   MNWD1APIWJT
                                                     JOINT MNWD-SLSD PLANT
              SOUTH COAST INTERCEPTOR
 Exhibit  3-13
                   ALTERNATIVE    4A

-------
s*


   Kffe^         :  r4  P
 f -V  ^          •  .  ^
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                                                                              -•

                                                                       :
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                                      -.V i
                                             ^







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                                           M%*^
                                       k \,./^uAflT,  ;
                                 ^Vr..™ .

                                 -•-3*^V ^
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                   Laguna Beach Ls,
                      NORTH COAST

                      INTERCEPTOR
                                                      . MNWD 1A

                                                      'PLANT
  i
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   i • j


 ., •

 i
                                                                   V          ^
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                                                                  f  -- V;.
                                                                 • |>- .-. •


                                                                m     S
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                                                   '
legend
I
 '•'•'• RAW SEWAGE INTERCEPTOR



     LAND OUTFALL



     OCEAN OUTFALL



ii	mm FORCE MAIN



     PUMP STATION



     ABANDONED TREATMENT PLANT



     SECONDARY TREATMENT PLANT



     A.W.T. PLANT
                               South Laguna;
                                   SOUTH COAST

                                   INTERCEPTOR
                                          Oft "41
                                          TJ» i

                                              (SB


           ?
                                                                 r
                                                                       " '• 3 s- "~.

                                                                         J4»'- ?"
                                                                         Ii.  ' ' '"«-

                                                  /--^:
                                                           €apistrano

                                                           Beach"'%
                                                                 **o,
m
.


       LU
I
xhibit 3-12


-------
Project Alternative  4A  would
enable the upper Aliso area to
provide  independent disposal
through the construction of  an
advanced wastewater treatment
plant  and land outfall. Treated
effluent would be utilized in the
upper Aliso and Irvine Ranch area
for man-made recreational lakes,
irrigation and other miscellaneous
urban uses throughout most of
the year, with excess effluent to
be discharged to San Diego Creek.
Dislocation of the upper  Aliso
area,  enables the  local  and
regional treatment facilities in the
lower Aliso and coastal areas to
be reduced in size and capacity.
Excess treated effluent from the
SLSD and MNWD plants not used
for irrigation would pass through
a pipeline in lower Aliso Valley to
the ocean outfall.
                                                LAWD PLANT
                                                ROSSMOOR PLANT
                                 A.W.T. PLANT
                                 10.0 MGD
                                                              MNWD 2A PLANT
                                           1270.7 MGD
                                                              3.8 MGD
                           MNWD 4A
                           PLANT
                           10.0 MGD
1.3
MGD
    ._.,
    16
       „,. MGD
       15 fe. 16
  CITY OF LACUNA BEACH PLANT

1.5               5.9         5.9
 ID

  HimI

   NORTH COAST  INTERCEPTOR
                            ma i • i
                                                 3.0 MGD         4V |

                                                      JOINT MNWD-SLSD PLANT
                                                                   MNWD1APUJN1
                                                                 18"-24"/4.7 MGO
                                                                 18"/2.2 MGO
                                                               S 1B"/2.2 MGD
                                                                 2.2
                                                                 MGD
 B 18"/1.5 MGD   12"
BIBlBIBI
                                                                   0.9
                                                                   MGD
                                               SOUTH COAST INTERCEPTOR
 Exhibit 3-13
                   ALTERNATIVE    4A

-------
                                                                                          -
                                                                                   '
                                                                                    ~  •'


                                                                             s>?fe^-.sr yK£r<
                                                                                  i tW *il
                                                            -^f  ' ^
                                                              I
                                                                                       • r-

                                                                                •-
                                                                                       ,

Legend
i.i.<...  RAW SEWAGE INTERCEPTOR
—^— LAND OUTFALL
	 OCEAN OUTFALL
	i	 FORCE MAIN
  A    PUMP STATION
  (g)   ABANDONED TREATMENT PLANT
  d_   SECONDARY TREATMENT PLANT
  %   A.W.T. PLANT
       REGIONAL' SECONDARY
       TREATMENT  PLANT
                                                 Dana Point r-.
Exhibit 3-14

-------
 Project Alternative 2F provides
 consolidation of waste water treat-
 ment to a regional facility in the
 lower Aliso Valley and advanced
 wastewater   reclamation  and
 ground water recharge in the uper
 Aliso area.  The existing  inland
 plants would continue reclama-
 tion of secondary treated waste-
 water for irrigation during periods
 of  demand.  Untreated sewage
 would pass down Aliso Valley by
 a raw sewage interceptor to the
 regional treatment plant and then
 to  the  ocean  outfall for  final
 disposal. This alternative enables
 the regional facility to be sized at
 a lower capacity because of the
 high summer reclamation  de-
 mands in the  upper Aliso area
 traded off with increased summer
 and wastewater generation in the
 coastal area.
                                    LAWD PLANT
            A.W.T. PLANT
            4.0 MGD
               16*/3.5 MGD
                            15V3.5 MGD
                                        ROSSMOOR PLANT
                                                              MNWD 2A PLANT
                                            '=§
                                           ?••
                                            • «s
                                           *• >•
                                           iu" •<•>
                                           Uj ™ <•>
                                           5! SULPHUR CREEK
                                              INTERCEPTOR
                         REGIONAL
                         TREATMENT PLANT
                         16 MGD
                                                 i
                                                              E 16
                                                                0.8
            CITY OF LAGUNA BEACH PLANT
1.3
MGD

 1.5
,. MGD
5.9
MGD
                      5.9
                      MGD
16"   18" jf^.    24"        Iff1   S
IIMI • I «(y) ^illiiHUi | B|M||||H I i

NORTH COAST INTERCEPTOR
                                                                  MNWD 1A PLANT
                                                    24"/2.5 MGD


                                                    2172.5 MGD

                                                  S 24V 2.5 MGD
                                                         1.5
                                                         MGD
                                                     JOINT MNWD-SLSD PLANT
                                                      II
                                                       18"/1.75 MGD
                                                  SOUTH COAST INTERCEPTOR
 Exhibit  3-15
                  ALTERNATIVE     2F

-------
 Project Alternative 4C provides
 independent disposal of secon-
 dary treated effluent in the upper
 Aliso area through the construc-
 tion of a land outfall to San Diego
 Creek. Reclamation for irrigation
 purposes would be maintained as
 long as the demand occurs. Dislo-
 cation of the upper Aliso area
 enables the local and regional
 treatment facilities in the lower
 Aliso  and coastal areas to  be
 reduced  in  size and capacity.
 Excess treated effluent from the
 SLSD and MNWD plants not used
 for irrigation would pass through
 a pipeline in lower Aliso Valley to
 the ocean outfall.
                                               LAWD PLANT
                                               ROSSMOOR PLANT
                                                           MNWD 2A PLANT
                                         1270.7 MGD
                                                           3.8 MGD
                          MNWD 4A
                          PLANT
                          10.0 MGD
            CITY OF LAGUNA BEACH PLANT
1.3
MGD
   ....
   16
         1.5
       „„ MGO ..
       15 fc. 16
                       5.9
            IIIIBIHIH X 1MIIIIHI

            NORTH COAST INTERCEPTOR
                                                                MNWD1APLA)
                                                              18"-24"/4.7 MGO
                                                              18V 2.2 MGO
                                                            35 18"/2.2 MGD


                                              3.0 MGD         A MOD

                                                   JOINT MNWD-SLSD PLANT
  5.9

24" «» 18
                                               = 1871.5 MGD   12"
                                              i m m i • i • i
                                            SOUTH COAST INTERCEPTOR
Exhibit 3-16
                 ALTERNATIVE    4C

-------
 During  the  second  stage  of construction  in  1985, a 4mgd advanced wastewater
 treatment plant would  begin  to  provide tertiary treatment  in the Upper Aliso
 area.   This tertiary treatment  facility  would  be essentially the same as
 described in Alternative 3C  and would involve  the operation of  the Los Alisos
 and  El  Toro Water  Districts'  plants.

 An additional  feature  of this alternative would allow the  effluent flows
 that were coming out of  the  tertiary plant  to  flow down Aliso Creek and be
 put  into groundwater storage in the Aliso Basin of approximately 9,000 acre-
 feet storage capacity.   This basin at the present time has more than 2,500
 ppm  TDS in  groundwater and is not useable for  even agricultural purposes.
 An objective of this alternative would be to remove the highly  saline water
 from the basin and replenish with secondary treated lower  TDS supplies from
 the  tertiary plant.  In  the  early stages of the project, three  pumps would
 be installed in the lower portion of the Aliso groundwater basin and approxi-
 mately  3 mgd of water  would  be  removed and discharged to the ocean through
 the  ocean outfall.  During this period of time, available  aquifer capacity
 can  be  obtained and the  Aliso groundwater basin would be overdrafted.  After
 the  basin had been drained for  approximately 3 years, either rainfall or
 tertiary treated effluent should be discharged into the basin for flushing.
 It is estimated that there are  about 50,000 tons of currently accumulated salt
 in the  basin.  This accumulation of salt would have to be reduced to something
 on the  order of 20,000 tons  before the water coming out of the groundwater
 basin would  be of sufficient quality for agricultural purposes.  Three wells
 and  a short  pipeline would be installed  to take these waters to the treatment
 plant so it  could be combined,  bypassing the treatment process, and put into
 the  outfall.  These have been included in part of the cost estimate of this
 project.  After the first ten years of operation, essentially when enough
 salt has been removed and the tertiary process is in operation, these same
 wells and distribution system would be incorporated into the greenbelt irriga-
 tion system  for the Aliso Greenbelt area.

 3.1.6  Alternative 4C -  Intermittent Streat Discharge from the Upper Aliso Area

 As with Alternative 4A, Alternative 4C represents a concept of separating
 the AWMA area into essentially two service areas.   The Upper Aliso service
 area would be independent of the lower Aliso and the coastal  areas.   Effluent
 from the two upper plants would be stored in existing facilities.   During
 winter months when demand for reclaimed water is at a minimum,  excess effluent
 would be intermittently discharged to San Diego Creek.   Discharge would coincide
 with maximum stream flows and dilution and would also coincide with  minimal
 public recreational use of the Creek.   This concept would enable the facilities
 in the lower Aliso and  Coastal areas to be reduced in size and capacity.
 This would also reduce  the size of the ocean outfall  from 29 mgd to  17  mgd.

 Exhibits 3-7 and 3-8 prepared for Alternative 4A may also be used  to describe
Alternative  4C.   The only variation occurs in the utilization of an  advance
wastewater treatment plant in the 4A alternative.   Other aspects of  the North
Coast Interceptor and  South Coast Interceptor would remain  the  same  as  those
described  in Alternative  1A.   No estimate was made of the cost  savings  of
 this  alternative compared to  Alternative  4A.
                                  3-7

-------
  Project Alternative 4C provides
  independent disposal of secon-
  dary treated effluent in the upper
  Aliso area through the construc-
  tion of a land outfall to San Diego
  Creek. Reclamation for irrigation
  purposes would be maintained as
  long as the demand occurs. Dislo-
  cation of the  upper Aliso area
  enables the local and regional
  treatment facilities in the lower
  Aliso and  coastal areas  to be
  reduced  in size  and capacity.
  Excess treated effluent from the
  SLSD and MNWD plants not used
  for irrigation would pass through
  a pipeline in lower Aliso Valley to
  the ocean outfall.
                                           LAWD PLANT
                                           ROSSMOOR PLANT
                                                           MNWD 2A PLANT
                                         1270.7 MGD
                                                           3.8 MGD
                          MNWD 4A
                          PLANT
                          10.0 MGD
1.3
....
16
         1.5
       ..„ MGO „.
       15 ^ 16
           HUM i
         CITY OF LAGUNA BEACH PLANT

                              5.9
            NORTH COAST  INTERCEPTOR
                                                                MNWDIAPLAf
                                                              18"-2474.7 MGO
                                                              18"/2.2 MGO
                                                            ~ 18"/2.2 MGD
                                                   JOINT MNWD-SLSD PLANT
 .
MGD
                                         SOUTH COAST INTERCEPTOR
 Exhibit 3-16
                  ALTERNATIVE    4C

-------
 During  the  second  stage of  construction  in  1985, a 4mgd advanced wastewater
 treatment plant would  begin to  provide tertiary treatment  in the Upper Aliso
 area.   This  tertiary treatment  facility  would  be essentially the same as
 described in Alternative  3C and would involve  the operation of the Los Alisos
 and  El  Toro  Water  Districts'  plants.

 An additional  feature  of  this alternative would allow the  effluent flows
 that were coming out of the tertiary plant  to  flow down Aliso Creek and be
 put  into groundwater storage in the Aliso Basin of approximately 9,000 acre-
 feet storage capacity.  This basin at the present time has more than 2,500
 ppm  TDS in groundwater and  is not useable for  even agricultural purposes.
 An objective of this alternative would be to remove the highly saline water
 from the basin and  replenish with secondary treated lower  TDS supplies from
 the  tertiary plant.  In the early stages of the project, three pumps would
 be installed in the lower portion of the Aliso groundwater basin and approxi-
 mately  3 mgd of water  would be  removed and discharged to the ocean through
 the  ocean outfall.  During  this period of time, available  aquifer capacity
 can  be  obtained and the Aliso groundwater basin would be overdrafted.  After
 the  basin had been drained  for  approximately 3 years, either rainfall or
 tertiary treated effluent should be discharged into the basin for flushing.
 It is estimated that there  are  about 50,000 tons of currently accumulated salt
 in the  basin.  This accumulation of salt would have to be  reduced to something
 on the  order of 20,000 tons  before the water coming out of the groundwater
 basin would  be of sufficient quality for agricultural purposes.  Three wells
 and  a short  pipeline would  be installed  to take these waters to the treatment
 plant so it  could be combined,  bypassing the treatment process, and put into
 the  outfall.  These have been included in part of the cost estimate of this
 project.  After the first ten years of operation, essentially when enough
 salt has been removed  and the tertiary process is in operation, these same
 wells and distribution system would be incorporated into the greenbelt irriga-
 tion system  for the Aliso Greenbelt area.

 3.1.6  Alternative 4C  - Intermittent Streat Discharge from the Upper Aliso Area

 As with Alternative 4A, Alternative 4C represents a concept of separating
 the AWMA area into essentially two service areas.   The Upper Aliso service
 area would be independent of the lower Aliso and the coastal  areas.   Effluent
 from the two upper plants would be stored in existing facilities.   During
 winter months when demand for reclaimed water is at a minimum,  excess effluent
 would be intermittently discharged to San Diego Creek.   Discharge would coincide
 with maximum stream flows and dilution and would also coincide  with  minimal
 public recreational use of the Creek.   This concept would enable the facilities
 in the lower Aliso and  Coastal areas  to be reduced in size and  capacity.
 This would also reduce  the size of the ocean outfall  from 29 mgd to  17  mgd.

 Exhibits 3-7 and 3-8 prepared for Alternative 4A may also be used  to describe
Alternative  4C.  The only variation occurs in the utilization  of an  advance
wastewater treatment plant in the 4A  alternative.   Other aspects of  the North
 Coast Interceptor and South Coast Interceptor would remain the  same  as  those
described  in Alternative 1A.  No estimate was made of the cost  savings  of
 this alternative compared to Alternative  4A.
                                  3-7

-------
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                   .        ,
                   Vv^
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                                                                -^,' '/.;..-• -:  •
                                              *£*<:•
                                              tit E
                                                      -  -  ±\-  "
                                                        i  (til: -
                                                           ''    ;  '
Legend
,. . . . RAW SEWAGE INTERCEPTOR

—i— LAND OUTFALL

	 OCEAN OUTFALL

iiiiiiiiiiiiiiiiiiin FORCE MAIN

  A   PUMP STATION

  0   ABANDONED TREATMENT PLANT

  (J   SECONDARY TREATMENT PLANT

  A   A.W.T. PLANT
                                  Dana Point >.-.~«
 3
REGIONAL SECONDARY
TREATMENT PLANT
Exhibit 3-17
                                                                          i

-------
Project Alternative 2G AWMA
Proposed Project  provides an
efficient system of raw sewage
transmission  from the  upper
Aliso area to the regional treat-
ment plant. Although the concept
of this alternative is virtually the
same as Project Alternative 2F, it
takes advantage of the natural
division between the Aliso and
San Diego Creeks drainage basins.
Double-pumping is eliminated,
thus conserving valuable energy
resources and increasing  the
reliability and efficiency of the
operating facilities.
                                                 247 4.1 MGD
                               LAWD PLANT
                       A.W.T. PLANT,
                       4.0 MGD
                         1673.5 MGD
                         15'/3.5 MGD
                                      ROSSMOOR

                                      PLANT
                                    '2.6
                                     MGD
                                   S 2073.4 MGD
                                     18"/3.4 MGD
                                          I $  27"/ 8.6 MGD
                                         il.
                                                         MNWD2A PLANT

                                        of SULPHUR  CREEK
                                          . INTERCEPTOR
                                        8ll
                                        3!
                       REGIONAL
                       TREATMENT PLANT
                       16 MGD
1.3
MGD

  1.5
... MGD
CITY OF LACUNA BEACH PLANT


16'^   18"
                       5.9
                       MGD
        k.  •"    10
       iapiiiiBiHi

           NORTH COAST INTERCEPTOR
                                                              MNWD1A PLANT
                                                             2472.5 MGD


                                                             2172.5 MOD

                                                             24V 2.5 MGD
   JOINT MNWD-SLSD PLANT




1...

 SOUTH COAST INTERCEPTOR
Exhibit 3-18
                ALTERNATIVE    2G

-------
3.1.7  Alternative 26 - Modified Alternative 2F

Alternative 2G modified Alternative 2F slightly to take advantage of natural
terrain.  After completion of the 1973-1974 project report, it was determined
that Alternative 2F could be modified slightly to avoid 'double pumping' of
wastes.

Both LAWD and ETWD serve lands which naturally drain to both Aliso and
San Diego Creeks.  Currently, flows from the Aliso Creek portion of the
service area are collected and then pumped over the ridge into the San Diego
Creek Basin.  It was determined that these flows could be collected directly,
rather than be pumped into San Diego Creek Basin and then pumped back into
Aliso Creek Basin.  This would save a substantial amount of 'double pumping'.

3.2  PRIMARY IMPACTS OF ALTERNATIVES

The following sections will describe the primary impacts of the foregoing
alternatives.  The discussion will focus on construction impacts, operational
impacts, and the reliability of each alternative.  Construction impacts will
be avoided when describing impacts common to several alternatives.

3.2.1  Alternative 1A - Local Treatment, Regional Disposal

3.2.1.1  Construction Impacts

3.2.1.1.1  Aliso Creek Interceptor

The pipeline components of the regional  wastewater system will create short-
term impacts due to construction.  Project construction will consist primarily
of the trenching, laying and back-filling of interceptors and outfalls, the
construction of pumping stations, and the construction of a regional  treat-
ment plant.

The Aliso Creek Interceptor extends approximately 51,600 feet from the regional
treatment plant to the Los Alisos treatment plant in Sec.  21, T65, R8W.  The
interceptor route goes up Aliso Creek canyon to the Moulton Parkway,  then
follows the parkway and streets to El  Toro and Los Alisos treatment plants.

In the lower reaches the interceptor will  be constructed in gradually sloping
bottom lands used for grazing and dry farmed cereal  grains.   Assuming a 24-foot
wide construction lane,  approximately 19,750 feet of grassland (10.9 acres)
will be destroyed.   There will  be a reach of 10,400 feet transversing agricultural
habitat.

The Aliso Creek Interceptor would be located adjacent to Aliso Creek and
would follow the creek from the regional  treatment plant to Moulton Parkway
where it would then follow the alignment of Moulton Parkway to the northwest
for approximately 13,400 feet where it would reach the intersection of El  Toro
Road.  The Interceptor would then follow El Toro Road northerly for approxi-
mately 1,400 feet to a point where the interceptor would leave the roadway
alignment and continue to the El  Toro Water District's treatment facilities.
                                   3-8

-------
 The traffic volumes along these major roadways currently range from S.,000
 (Moulton Parkway) to 16,000 (El  Toro Road).   With upcoming improvements and
 extensions of these roadways and the continued addition of people and vehicles,
 these roadways will generate increasingly higher traffic volumes.

 The -Aliso Creek Outfall  will be constructed  in a variety of terrain types and
 activity areas., each posing different problems.   Starting at the  regional
 treatment plant, the outfall will  cross  approximately 4,000 feet  of grassland
 type.   The lower section of Aliso  Creek  canyon is narrow and the  creek has
 been channelized.   The length of this reach  to the Pacific Coast  Highway is
 5,000 feet.   As a result of channelization,  the creek here is a relatively
 sterile  habitat.

 The construction of Aliso Creek  Interceptor  will  involve six stream crossings,
 two on San Diego Creek and four  on Aliso Creek.   Consequently,  the construction
 of Aliso Creek Interceptor would result  in a disruption of riparian habitats
 at these six locations.   The extent of the disruption,  either temporary or
 permanent, would depend  on the kind of construction that would occur at those
 particular locations.   Construction would also provide  the potential  for erosion
 and creek siltation.  A permit from the Department of Fish and Game is required
 for in-stream work.   Coordination  with the Department will  insure  mitigation
 of impacts.

 The lower section  of Aliso Creek is na'rrow and the creek has been  channelized.
 A  country club and golf  course occupy both sides  of the canyon floor.   The
 creek  will  be used as  the pipeline route along this portion  of the system.
 Excavation will  occur in the bed of the  stream channel.   The length of this
 reach  to the Pacific Coast Highway is approximately 4,000 feet.  As a result
 of channelization, the relatively  sterile creek  habitat will  not be affected
 as significantly as  in the upper reaches of  the Aliso Creek.
3.2.1.1.2  South Coast  Interceptor


The South Coast Interceptor is not under construction by the applicant.  This
interceptor is being constructed almost entirely in the Coast Highway.  The
traffic disruption that has been associated with this project should be
indicative of the inconvenience of construction to local residents.
3.2.1.1.3  Sulphur Creek Interceptor


The Sulphur Creek Interceptor will be constructed in roads and streets and
through a golf course, and will requine two pump stations.  There will also
.be one stream crossing, with attendant impacts on stream habitat.
                                   3-9

-------
3.2.1.1.4  North Coast  Interceptor


The North Coast Interceptor will be constructed along approximately 35,000 feet
of the Pacific Coast Highway from Morro Canyon to Aliso Creek where it will
then follow Aliso Creek to the regional treatment plant.  The existing traffic
flows along the portion of Pacific Coast Highway which will be affected by
construction activities range between 21,000 to 35,000 daily.  These volumes
of traffic will be impacted more significantly at certain locations than
others.  Since the precise alignment of the North Coast Interceptor along the
Pacific Coast Highway has not yet been determined, the disruptions of traffic
flows cannot be estimated or discussed in relation to their specific location
along the highway.


3.2.1.1.5  Land and Ocean Outfall
The outfall will be tunneled under Pacific Coast Highway and laid in a deep
trench across the beach to the ocean.  The outfall will be buried beneath the
ocean floor approximately 2,100 feet seaward from the beachline.  The buried
reach will be covered with large rocks which will protrude above the ocean
floor starting at the point where ocean depths reach 20 feet.

The final reach of the outfall will not be buried.  The pipe will be laid on
the ocean floor at a minimum depth of 50 feet increasing to 170 feet at the
terminal diffuser.

During construction of the outfall facilities, the Aliso Beach Staging Area will
require a fenced area of 150 feet wide by 700 feet long.  Construction
equipment will be located in the public parking area, thereby limiting the
public parking capacity for a period of approximately six months.  Construction
time would be scheduled during the months from October through May in order to
avoid, as much as possible, the majority of beach visitors.  Nevertheless,
construction of this stretch will interfere with public use of Aliso Beach
and the Aliso Beach public fishing pier.  The steepness of the beach (20 percent)
and the small width (50 yards) will compound the impacts.


The 8,700 foot alignment of the ocean outfall would be permanently committed
to use for disposal  purposes.  Large rocks covering the outfall  trench through
the ocean depths of 20 to 50 feet will  protrude above the ocean floor.   An
artifical reef approximately 1,600 feet long will be formed.   Construction of
the outfall would also introduce a permanent artificial  structure to the ocean
and an additional surface on which attached marine forms may grow.


Outfall  construction will  involve some dredging in order to establish the
trench for the outfall bed.   Backfill will also be required.   It is very
unlikely that the dredge spoil will involve any contaminants, since the sediments
are exclusively stream deposited sediments and there is no industry in the area.
                                  3-10

-------
 Construction  operations will,  however, cause  temporary  turbidity.   Further-
 more, marine  life will be  impacted.   Intertidal flora and fauna, as well as
 benthic  subtidal biota, within the construction area, will be destroyed
 directly by dredging.  Also, benthic  subtidal biota and fishes will be
 affected by construction noise, although these effects will probably be
 local, both in  time and place.  Whether the noises produced will attract or
 divert fishes is not  known.  Vibration perception among invertebrates is not
 fully understood, but the  patterns of sound appear  to be more important than
 either the intensities or  specific frequency  characteristics of sound.  This
 is  also  true  of fishes.  The turbidity of the water and the general disrup-
 tion of  the area will affect phytoplankton to an unknown degree.  Upon the
 completion of construction activities, it may be expected that the area will
 be  repopulated  by flora and fauna which were  not destroyed or disturbed
 within one year.  As  kelp is not present off  of the Aliso Beach, construction
 will have no  short-term effects.

 3.2.1.1.6 Treatment  Plants

 The South Laguna Sanitary District, Moulton Miguel Plants 1A, and 2A, the
 El Toro  plant and the Los Alisos plant will all need to be expanded under
 this alternative.  All construction will take place on existing sites, but
 wiTl involve  noise, traffic increases, dust,  and other normal construction
 impacts.

 3.2.1.2   Operational  Impacts

 3.2.1.2.1  Ocean Discharge Impacts

 The impact of the AWMA. ocean discharge depends ultimately upon the assimilative
 capacity  of the marine environment.  This assimilative capacity cannot be
 accurately determined, consequently it is difficult to predict fully the envi-
 ronmental impacts of  ocean discharge.  However, a discussion of the environ-
 mental impacts of primary treatment will be presented in comparison with
 secondary treatment.

 Pollutants of general  environmental concern resulting from the discharge of
 effluent  into the ocean are floatable arid settleable solids, toxic and per-
 sistent metals and organics, and pathogens.

 Floatable solids are  those solids, or clumps of solids such as grease, oils,
 gas and a variety of  particulates which are lighter than water.   These masses
 can be borne on shore by wind or current.   Since they are unsightly and often
 contain high  levels of bacteria and chlorinated hydrocarbons, they are a    ;
 potential health hazard as well as an aesthetic disturbance.  Floatable solids
will"be significantly reduced when treatment is upgraded from primary to
 secondary levels.

Toxic materials, most notably heavy metals and persistent chlorinated hydro-
carbons,  are of long-range concern.  Both of these materials can be concen-
 trated in the ocean, in the biological chain.   Data from the Southern California
Coastal  Water Research Project (SCCWRP)  indicates  that there are significant
depositions of particulates, heavy metals,  and chlorinated hydrocarbons  in the
vicinity of ocean outfalls—particularly if the sewer system serves a significant
                                      3-11

-------
 industrial area.  The solids themselves can be toxic if not well stabilized,
 hydrogen sulfide odors were pronounced in some areas.  However, solids are
 more generally seen as an indicator of other toxic materials.  Both heavy
 metals and toxic hydrocarbons tend to be absorbed onto sediments.  Thus they
 are relatively stabilized in the marine environment—although they can still
 be available to organisms.

 The SCWRRP study also showed that both hydrocarbons and heavy metals are
 concentrated in the marine food chain.  High concentrations of DDT were found
 in sand crabs, mussels, and the dover sole in the vicinity of the outfalls.
 To a lesser extent, lead concentrations were found in sand crabs.  The exact
 nature of concentration into the food chain and the overall marine significance
 is hard to predict, since larger ocean fish feed in much larger areas than
 benthic fauna or bottom fish such as the dover sole.  Thus, they may not con-
 sume species with high concentrations of metal or hydrocarbons in sufficient
 quantity to further concentrate the materials.  No reductions in game fish
 catches have been noticed in the Southern California Bight, indicating that
 all effects are sublethal, and do not affect reproduction.

 Diseases of marine vertebrates are noticeably higher in the vicinity of ocean
 outfalls.  Whether this is a result of pathogens in the sediments, or from
 reduced resistance, is hard to determine at this time.

 The previous discussion indicates that the discharge of primary effluent, at
 some level, results in significant harm to at least localized marine biological
 communities.  Insufficient research has been done to establish accurate and
 exact treatment parameters to prevent these effects—indeed considerable
 controversy exists on the subject.   However, it can be noted that most of the
 impacts are associated either directly or indirectly with the discharge of
 settleable solids.   Reductions in solids can be expected to reduce both heavy
 metals and hydrocarbons which usually absorb to solids or are heavy enough to
 settle out.  Secondary treatment increases removal  of settleable solids from
 roughly 50 to 60 percent to roughly 90 to 95 percent.  In the case of
 Laguna Beach, secondary treatment would reduce suspended solids from about
 150 milligrams per liter to 30 milligrams per liter or less.

 Most of the materials found in wastewater are also found in ocean water--
 though at greatly reduced concentrations.   This indicates that dilution may
 be a critical parameter in determining environmental  impact.  If so, the
 impact of the discharge can be mitigated considerably since the dilution and
 dispersion of the effluent can be regulated through design.

 The length of the diffuser (600 feet) enables the discharged effluent to achieve
 a high rate of dilution.   A computer analysis predicted that with 2.0-inch
 diameter diffuser ports,  spaced at  12-foot intervals, discharging at a velocity
 of 10 feet per second at a depth of 175 feet (the average depth of the pro-
 posed discharge), an initial  dilution of 290:1  would occur with the effluent
 field remaining submerged at a depth of approximately 85 feet for average sum-
mer conditions and  an initial  dilution of 620:1  with the effluent field remain-
 ing submerged at a  depth of approximately 20 feet for average winter conditions.

The computer analysis for "subsequent dilution"  predicted additional  dilution
after the effluent  field has  reached equilibrium with the surrounding sea water
                                      3-12

-------
                            TABLE 3-1
       PROJECTED MASS EMISSIONS  (POUNDS PER DAY) TO OCEAN

                                           PERIODS
Constituent

TDS
Hardness
Chlorides
Sulfates
Fluoride
Magnesium
Copper
Zinc
Iron
Calcium
Sodium
Potassium
Bicarbonate
Nitrate
Boron
Phosphate
Lead
Selenium
Chromi urn
Cadmium
Arsenic
ifercury
Nickel
Silver
Ammonia
1975-80
127,000
61 ,400
25,200
34,400
73
6,700
24
24
9.7
11,570
23,140
2,310
41 ,500
2,440
73
3,650
4.8
3.7
0.5
1.0
0.86
0.12
0.24
0.37
244
1980-85
140,000
67,400
27,600
38,100
95
8,720
31.7
31.7
12.7
15,060
25,376
3,012
54,076
3,170
95
4,760
6.3
4.8
0.63
1.27
1.1
0.16
0.32
0.47
317
1985-90
151,000
74,000
34,400
28,300
113
10,400
37.7
37.7
15.1
15,100
29,640
3,590
60,040
3,780
113.2
5,660
7.5
5.7
0.75
1.51
1.32
1.51
0.38
0.57
377
1990-95
175,200
85,800
39,900
32,800
131
12,040
43.8
43.8
17.5
17,500
34,400
4,160
69,600
4,380
131.3
6,570
8.8
6.6
0.88
1.75
1,53
1.75
0.44
0.66
438
                                    3-13

-------
 for  various  times and distances away from the point of discharge assuming a
 current  speed of 0.2 feet  per second.

 "Subsequent  dilution" values range from 1.0:1 to 30:1 for times after discharge
 of zero  to 10 hours respectively.  Total predicted reduction in coliform
 organisms for the same  times after discharge range from 620:1 to 6,060,000:1
 respectively; this reduction includes the initial dilution based on winter
 conditions of 620:1, subsequent dilutions indicated above and reduction in
 coliform organisms assuming a TgQ (rate of coliform bacteria disappearance) of
 4 hours.

 During the "current studies," no currents were detected moving directly onshore.
 However, assuming a direct onshore current could occur and an average speed of
 about 0.2 feet  per second, and assuming the effluent field might reach the
 water surface during a  period of isothermal conditions in the water column,
 it would take approximately 8 hours for the effluent field to reach a point
 1,000 feet from the shore.  At this point a subsequent dilution of approxi-
 mately 23 to 1  would be achieved with a total predicted reduction in coliform
 organisms of approximately 1,800,000 to 1.  Exhibit 3-19 shows calculated con-
 tours of subsequent dilution as a percent of initial dilution for the case of
 an onshore current.

 The  short term  impacts  would be minimized by the extreme initial dilution of
 290:1 and the "subsequent dilution" of the effluent on entering the sea.  On
 the  other hand, the long term and cumulative impact, especially the biological
 and  sedimentary impacts, cannot be assessed accurately at this time because:
 (1)  present  data are limited and monitoring programs in the vicinity of the
 disposal site are not available; and (2) experimental observations on the
 nature and kinetics of  very slow reactions at extreme dilution are lacking.

 In summary,  the initial dilution of waste water with sea water from the ocean
 outfall  would meet the  requirements of the State Water Quality Control Board
 and  the  State Plan for  the ocean waters of California.  These requirements
 establish a  dilution factor of 100:1 at least 50 percent of the time.  In
 effect the initial dilution rate of 290:1 provides a substantially higher ratio
 of dilution  relative to the existing requirements.

 3.2.1.2.2  Land Discharge

 Alternative  1A would involve reclamation of a sizeable amount of water in the
 Upper Aliso  Service Area.  In this option, the groundwater basins would be
 the  receiving waters.   When groundwater basins are charged sufficiently, the
 rising groundwater would cause streamflow, and thus the streams would be
 impacted as  wel  1.

 For  groundwater, nitrates, pathogens and trace organics are the pollutants of
 chief concern.   Heavy metals will absorb onto the soils where the wastewater
 is reclaimed.   Uptake of heavy metals into food crops is not a concern,
 although sufficient build-up of heavy metals can ruin a soils productivity.
 This is  not  likely to occur with domestic sewage.

Nitrates, unlike heavy  metals  and phosphates,  pass through  soils in  water.
Nitrates  can  accumulate in groundwater  and render it unfit  for drinking.
                                       3-14

-------
-o
>
O
 -n

 O
     -1200'
     Diffuser
 75*
 50%


 25%
                                ALISO
Exhibit 3-19

T
0     2090
                 DILUTION  CONTOURS

-------
                                          TABLE  3-2

               ANTICIPATED SUBSEQUENT DILUTION AND TOTAL  REDUCTION IN  COLIFORM

                         ORGANISMS  FOR THE ALISO CREEK OCEAN OUTFALL
Time After
Discharge
 (hours)
 Distance From
Discharge Point
     (feet)
   Width of
Effluent Field
    (feet)
 Subsequent
  Dilution
(ratio to 1)
Total Predicted
  Reduction3
 (ratio to 1)
-0-
0.1
0.2
0.3
0.5
0.7
1.0
2.0
3.0
5.0
7.0
10.0
-0-
72
144
216
360
504
720
1440
2160
3600
5040
7200
130
150
175
200
250
310
400
760
1180
2200
3400
5500
1.0
1.0
1.0
1.2
1.4
1.7
2.2
4.2
6.6
12
19
30
620
660
740
860
1 ,180
1,610
2,470
8,280
22,300
135,000
665,000
6,060,000
 Includes an initial  dilution of 620 to 1,  the subsequent
 dilution indicated and reduction in coliform organism
 assuming a TgQ of 4 hours

-------
 Nitrates can  be present  in  rising  groundwater  to  the  extent where they can
 cause eutrophication  of  streams  and  estuaries.  In  the  case of the AWMA
 agencies in the upper Aliso Creek  area,  the actual  impacts will depend on
 reclamation practices.   If  irrigation  practices are carefully controlled,
 most of the nitrates  can be taken  up and used  by  vegetation.  In any case,
 nitrates are  not a  critical  concern  in the upper  Aliso  area.  Groundwater
 basins are very small  and are  not  used for domestic supply.  Further, the
 contribution  of nitrates from  the  treatment plants  is much less than the
 contributions from  agricultural  practices and  urban runoff.  It cannot be
 said that wastewater  is  causing  eutrophication in Newport Bay.

 Pathogens are a potential problem  in reclamation.   Pathogens are bacteria and
 viruses that  cause  diseases  that can be  found  in  sewage effluent.  Pathogens
 of  concern include  hepatitis and polio viruses and  various bacteria which
 cause disease.   Pathogens are  reduced  through  treatment and disinfection
 and are reduced or  eliminated  by passage through  soils.  Pathogens are
 usually not a problem in the groundwater, but can be a  problem with uncon-
 trolled runoff from irrigated  areas.   Indeed, this  is the current water
 quality problem from  the Rossmoor  treatment plant.

 Trace organics  can  be  a  concern  with groundwater  recharge.  Trace organics
 refer  to complex organic chemicals  which can be  found  in sewage, although
 they are  more frequent in industrial waste than domestic sewage.  These
 complex compounds are  not broken down  by conventional waste treatment and can
 even be created  by  chlorinating  domestic sewage.   Some  of these compounds are
 known to  be carcinogenic and some  are  suspected mutagens.  Further, there is
 no  convenient or inexpensive method  of monitoring these compounds on a daily
 basis.  The State of California's  Department of Health  strongly discourages
 recycling  sewage through groundwater because of the danger of trace organics.
As  a  rule  of  thumb, they feel  that no more than five percent of the water in
a groundwater basin should be  sewage effluent if  the groundwater is to be
used  for  domestic supply.  Trace organics are probably  not a major problem with
reclamation in  the AWMA area as  long as virtually all domestic drinking water
 is  imported.

Reclamation of wastewater for either expanded agricultural purposes or green
belt  irrigation will cause substantial  changes in habitat.  These are not
beneficial or adverse effects unless they affect a rare habitat, rather they
are  changes.  Areas which are now natural chapparal  would be changed to either
irrigated agriculture, which does provide some wildlife habitat, or irrigated
greenbelt.  Irrigated green belt would be a wildlife habitat similar to that
found  in existing riparian areas.

3.2.1.2.2  Energy Consumption

Operation of this alternative is estimated to require 227 x 10  kilowatt-hours
over  the 20 year planning period.

3.2.1.3  Reliability

Any increase in the number of components  within a  system decreases  the
reliability of the total  system operating properly.   Conversely,  an increase
in the number  of components  within a system decreases the significance of the
                                        3-15

-------
failure of one component.  In the case of Alternative 1A, the number of treat-
ment plants would result in more frequent upsets than with a central treatment
plant.  Yet the water quality impact of the failure of one treatment plant
would be minimized by the dilution with other plants effluent.  The probability
of upset is greatest with this alternative, while the impact of upset is the
least.

3.2.1.4  Compatibility with Reclamation

Total reclamation for a year 2000 flow of 20 mgd would require over 10,000
acres of land plus facilities for water storage of over 5,000 acre feet of
water.  An ultimate flow of 30 mgd would require over 15S000 acres of land for
irrigation and over 10,000 acre feet of storage.  If flows are less than this,
land requirements would be reduced in direct proportion to flow reductions.

No detailed analysis has been made of potential users of reclaimed water or
market areas.  However, since both Los Alisos Water District and El Toro Water
District are now having trouble disposing of their effluent on a year-round
basis, it is extremely unlikely that a year-round market can be found for
these volumes of effluent.  Consequently, an ocean outfall to provide fail-safe,
year-round disposal would be an essential element of any reclamation project.

Although total reclamation is probably impossible, partial reclamation is pos-
sible and desirable, and each alternative will  be evaluated for compatibility
with future reclamation.

Reclamation depends upon distribution of water for reclamation to potential
customers, which in turn depends upon using available static head to distribute
with minimal pumping and a pipeline system separate from domestic water to get
effluent to potential  users.

Unless pumping is held to a minimum and some sort of distribution system exists,
reclaimed water will not be able to compete with potable water supplies, which
rely on an existing distribution system.

Alternative 1A would be very compatible with reclamation since the available
head of the upstream flows is retained through local treatment, and the use
of an effluent line provides the backbone of an effluent distribution system
for reuse.

On the other hand, i_f it is ultimately determine that substantial deminerali-
zation or advanced treatment to remove viruses and/or trace organics is essential
to reclamation, Alternative 1A would sacrifice economies of scale and make such
treatment more expensive.  Alternative 1A, the basic water supply for the area
could be demineralized.  Under this option, economies of scale would be obtained
and head would not be  lost.

3.2.2  Alternative 2E  - Central  Treatment, Regional  Disposal

3.2.2.1   Construction  Impacts

3.2.2.1.1   Interceptors
                                         3-16

-------
All  interceptors  for this alternative would be the same as for Alternative 1A
except  that  they  would convey raw sewage rather than treated sewage.  The con-
struction  impacts would be virtually identical.

3.2.2.1.2  Treatment Plant

This alternative  would require a new treatment plant to be constructed.  Four
sites have been considered, by AWMA  (Exhibit 3-5) and Site 2 is proposed as be-
ing  the most suitable location (Exhibit 3-6).  The cost of constructing inter-
ceptors, outfalls, sludge pipelines, and sewer pipelines as well as the cost
of power to  pump  the wastewater to  the treatment plant, was computed to com-
pare the alternative sites (Table 3-3).  This comparison indicates that
alternative  Site  2 is the least costly for pipelines and pumping.  Other
factors were also considered, these included:  the extent of site prepara-
tion, plant  operation, future plant expansion, flood control and proposed
land use (Table 3-4).

Site 1 would require costly cut and fill and could only accommodate a 10 mgd
plant.  It has the advantage of a relatively secluded location, thus limiting
the overall  visual impact from within and surrounding the Aliso Creek Open
Space and Conservation Corridor.   However, when the site is in view, the
impact will  be severe.  The relatively location, large fill slopes and
cut scars on the  canyon walls will accentuate the presence of the plant.

Sites 3 and  4 are located deeper within Aliso Canyon.  Because of the broad
and gentle curving nature of the canyon, these sites are highly visible.  They
may disrupt  the continuity of recreational or open space uses within the Aliso
Creek corridor, impacting the corridor visually and functionally.  Further-
more, these  sites place the regional treatment plant too far away from the
SLSD plant for combined operations to be possible, as compared to sites 1  and
2 which facilitate combined operations.
                                 TABLE 3-3

                      COMPARISON OF ALTERNATIVE SITES

                                                RELATIVE COSTS - $1000's
                                                    ALTERNATIVE SITE
Cost of Pipelines

     Aliso Creek Interceptor
     North Coast Interceptor
     Land Outfall
     Sludge Line - SLSD Plant
     Raw Sewage Line - SLSD Plant

Cost of Pumping (20 years)
                         TOTALS

                 RELATIVE COSTS
$1045
$ 760
$ 380
$ 163
          $ 915
          $1931
                                          3-17

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                                                       TABLE  3-4

                         ALTERNATIVE  SITE INFORMATION AWMA REGIONAL  WASTEWATER TREATMENT PLANT
          Site Preparation


          Plant Operation



          Future Plant Expansion



          Flood Control
CO
I

00
          Proposed Land Use*
                                           1
Extensive cut
and fill req'd

Combined opera-
tion with SLSD
plant

Not sufficient
area for pro-
posed plant

Site above
flood plain
Category 4.2
Quasi-Open
Space
                              ALTERNATIVE SITE

                                            3
Fill req'd
minimal cut

Combined opera-
tion with SLSD
plant

Sufficient area
for expansion
to 24 mgd

Required chan-
nelization of
Aliso Creek &
Protective
Work

Category 5.4
Open Space
Fill req'd
minimal cut

Separate opera-
tion with SLSD
plant

Sufficient area
for expansion
to 24 mgd

Require pro-
tective works
for design
storm
Category 5.3
Recreation Use
Fill req'd
minimal cut

Separate opera-
tion with SLSD
plant

Sufficient area
for expansion
to 24 mgd

Require pro-
tective works
for design
storm
Category 5.3
Recreation Use
Proposed school
site
          *County of Orange, Land Use Element, Amendment 3-74

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 The site which  AWMA  has  selected,  site  2, would  result  in environmental trade-
 offs.   The visual  impact would  be  less  than  that of  sites 3 and 4, and possibly
 site 1, owning  to  its  location  in  the narrow portion of the canyon which re-
 stricts views  (Exhibits  3-20  and 3-21).   In  response to concerns expressed
 regarding future hiking, riding, and bicycle trails  along Aliso Creek, AWMA
 has directed  its engineers  to provide an  equestrian  trail and a hiking-bikeway
 trail  system  along the western  edge of  the 2-G plant site.  This 50 to 65 foot
 wide trail  system, which would  replace  the plant service road originally planned
 for this area,  would cover  three of the site's 17 acres.  The trail system
 could  include the  ranch  road  along the  western edge of  Aliso Creek.  The
 proximity of  the SLSD  treatment plant will consolidate  the over-all intrusion
 of  these facilities  into the  Aliso Creek  Corridor.  This is also true of site 1,
 but site 2 will be on  the canyon floor  and will  not require the extensive grad-
 ing involved with  the  development of site 1.

 The principal adverse  impacts of this site are the channelization of a portion
 of  Aliso Creek  and the destruction of an archaeological  site.  A meander of
 the creek exists on the  northern third  of the site and  a diversion channel is
 proposed to cut off this meander.  The  channel must commence off site and will
 continue along  the present  creek bed through the site.   Buried rip-rap is to be
 used and the new water course would be  able  to carry a  Standard Project Flood,
 thus protecting the treatment plant from this hazard.*  An archaeological site,
 Ora 397,  is recorded within the boundaries of the proposed plant site.  It is
 adjacent to Aliso  Creek  about half way  through the project site.  This one-
 third  acre  site appears  to  have been a  temporary encampment and further investi-
 gation  will be  necessary to determine its significance.  Construction activities
 could  destroy the  site and any  artifacts contained within it; however, AWMA has
 indicated  that  they will attempt to preserve as  much of the archaeological site
 as  is  possible  and that  they will coordinate construction with a qualified
 archaeologist who will  be aided in any  salvaging which  is necessary.

 If  a regional  treatment  plant capable of serving the projected AWMA area popula-
 tion is  to be constructed in Aliso Canyon, then  site 2 appears to be the best
 location, both  environmentally  and cost/benefit wise.   Impacts such as noise,
 dust,  increased erosion and increased traffic normally associated with construc-
 tion can  be expected irrespective of the treatment plant location.   Because of
 the remoteness  of these sites,  relatively few people would be inconvenienced.

 3.2.2.1.3  Treatment Plant Access Road

 The construction and operation of the regional treatment plant will  require the
 construction of an access road.   Because of topological  and land use constraints,
 access alternatives have focused on northerly or southerly approaches along
 Aliso Creek.
*Also, AWMA will acquire another 11  acres subject to inundation during a
 Standard Project Flood of 22,000 cubic feet per second flow.   AWMA is
 willing to make this area available for greenbelt corridor uses.
                                         3-19

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                                                      TABLE 3-4

                         ALTERNATIVE  SITE  INFORMATION AWMA REGIONAL WASTEWATER TREATMENT PLANT
                                                                  ALTERNATIVE SITE
                                           1
          Site Preparation


          Plant Operation



          Future Plant Expansion



          Flood Control
00
          Proposed Land Use*
Extensive cut
and fill req'd

Combined opera-
tion with SLSD
plant

Not sufficient
area for pro-
posed plant

Site above
flood plain
Category 4.2
Quasi-Open
Space
Fill req'd
minimal cut

Combined opera-
tion with SLSD
plant

Sufficient area
for expansion
to 24 mgd

Required chan-
nelization of
Aliso Creek &
Protective
Work

Category 5.4
Open Space
Fill req'd
minimal cut

Separate opera-
tion with SLSD
plant

Sufficient area
for expansion
to 24 mgd

Require pro-
tective works
for design
storm
Category 5.3
Recreation Use
Fill req'd
minimal cut

Separate opera-
tion with SLSD
plant

Sufficient area
for expansion
to 24 mgd

Require pro-
tective works
for design
storm
Category 5.3
Recreation Use
Proposed school
site
          *County of Orange, Land Use Element,  Amendment 3-74

-------
 The  site  which AWMA  has  selected, site 2, would result in environmental trade-
 offs.   The  visual  impact would  be less than that of sites 3 and 4, and possibly
 site 1, owning to  its  location  in the narrow portion of the canyon which re-
 stricts views  (Exhibits  3-20 and 3-21).   In response to concerns expressed
 regarding future hiking, riding, and bicycle trails along Aliso Creek, AWMA
 has  directed its engineers to provide an  equestrian trail and a hiking-bikeway
 trail  system along the western  edge of the 2-G plant site.  This 50 to 65 foot
 wide trail  system, which would  replace the plant service road originally planned
 for  this  area, would cover three of the site's 17 acres.  The trail system
 could  include the  ranch  road along the western edge of Aliso Creek.  The
 proximity of the SLSD  treatment plant will consolidate the over-all intrusion
 of these  facilities  into the Aliso Creek  Corridor.  This is also true of site 1,
 but  site  2  will be on  the canyon floor and will not require the extensive grad-
 ing  involved with  the  development of site 1.

 The  principal adverse  impacts of this site are the channelization of a portion
 of Aliso  Creek and the destruction of an archaeological site.  A meander of
 the  creek exists on the  northern third of the site and a.diversion channel is
 proposed  to cut off this meander.  The channel must commence off site and will
 continue  along the present creek bed through the site.  Buried rip-rap is to be
 used and  the new water course would be able to carry a Standard Project Flood,
 thus protecting the treatment plant from this hazard.*  An archaeological  site,
 Ora  397,  is recorded within the boundaries of the proposed plant site.  It is
 adjacent  to Aliso  Creek about half way through the project site.  This one-
 third acre  site appears to have been a temporary encampment and further investi-
 gation  will  be necessary to determine its significance.  Construction activities
 could destroy the  site and any artifacts contained within it; however, AWMA has
 indicated that they will attempt to preserve as much of the archaeological site
 as is possible and that they will coordinate construction with a qualified
 archaeologist who will  be aided in any salvaging which is necessary.

 If a regional  treatment plant capable of serving the projected AWMA area popula-
 tion is to  be constructed in Aliso Canyon, then site 2 appears to be the best
 location, both environmentally and cost/benefit wise.   Impacts such as noise,
 dust, increased erosion and increased traffic normally associated with construc-
 tion can  be expected irrespective of the treatment plant location.   Because of
 the remoteness of these sites, relatively few people would be inconvenienced.

 3.2.2.1.3  Treatment Plant Access Road

The construction and operation of the regional  treatment plant will  require the
construction of an access road.   Because of topological and land use constraints,
access alternatives have focused on  northerly or southerly approaches along
Aliso Creek.
*Also, AWMA will  acquire another 11  acres subject to inundation during a
 Standard Project Flood of 22,000 cubic feet per second flow.   AWMA is
 willing to make  this area available for greenbelt corridor uses.
                                         3-19

-------
 REGIONAL TREATMENT PLANT



View from West Side of Aliso Creek



     150 Feet Above Site
Exhibit  3-20

-------
REGIONAL TREATMENT PLANT



  View from East Side of Aliso



  Creek 150 Feet Above Site
    Exhibit   3-21

-------
 3.2.2.1.3.1  Northern Alternative

 There are three variations of this alternative.  One alignment would coincide
 with the proposed Aliso Creek Road between Alicia Parkway and Aliso Creek Beach
 as  shown on the Orange County Master Plan of Arterial Highways (MPAH).  Another
 alignment would be on the eastern and southern side of Aliso Creek (Exhibit 3-22),
 along the present interceptor route.  In either case, the road would be of all
 weather design -- a 20-foot paved surface in a 50-foot right-of-way.  A third
 alternative, currently proposed by AWMA, is to re-grade the existing dirt road
 which traverses the western side of the canyon along an alignment almost
 identical to the MPAH route.  However, the surface would only be oiled to con-
 trol dust.  Aliso Creek would be crossed twice by temporary earth fill bridges.
 At  the completion of construction this road would be abandoned and the bridges
 removed.  When the plant is built, access will be from Pacific Coast Highway via
 a private 20 foot wide, 1,500 foot long paved road through the Laguna Beach
 Golf Course.  A permanent easement and approximately 20 foot wide right-of-way
 was acquired by the Moulton-Miguel Water District on July 19, 1971.

 3.2.2.1.3.1.1  Environmental Considerations

 The environmental variables in the area of the northern alternative have been
 thoroughly researched and mapped during the development of the Master Plan for
 Moulton Ranch.  Analysis of these variables for both variations indicates that
 the eastern route would result in the least disruption of biological resources
 and natural processes; however, the AWMA proposed route and construction tech-
 niques will greatly reduce the impacts of a permanent road.

 3.2.2.1.3.1.2  Economic Considerations

 Analyzing economic factors also leads to a conclusion that the eastern route
 is the better selection.  Since the route already contains AWMA facilities, a
 right-of-way would not have to be purchased as it would for the western route--
 a substantial savings.  Construction costs would also be substantially less
 for the eastern route because a bridge would have to be built across Aliso Creek
 from the western route to provide entry into the treatment plant.

 3.2.2.1.3.1.3  Cultural/Scientific Considerations

 The western route would encroach on more acres identified in the Moulton Ranch
 General  Plan (MRGP) as having a potential  for scientific resources particularly
 of archaeologic interest.

 3.2.2.1.3.1.4  Planning Considerations

 The western route, the proposed extension  of Aliso Creek Road, has been desig-
 nated as a major arterial  highway in the Orange County Master Plan of Arterial
 Highways (MPAH), as amended March 1973,  but it should be noted that there is a
 growing concern in favor of abandoning the segment of the proposed extension
 between the foot of Sheep Hills and Aliso  Creek Beach.   Also, the Moulton Ranch
General  Plan (MRGP) recognized a need to provide linkages between communities
while retaining the environmental  integrity of the area or providing an interest-
 ing aesthetic experience and proposed a  circulation element called a scenic loop.
The segment of the Aliso Creek Road extension between Alicia Parkway and the
 foot of Sheep Hills is identified as a part of the scenic loop circulation sys-
 tem in the MRGP.
                                 3-20

-------
 Northern Alternative
 -Western Alignment

         W.
            Northern Alternative
            -Eastern Alignment
             Regional Treatment Plant
                                                 ROADWAY RIGHT OF WAY
                                     Northern
                                     alignment
                                     (Western)
Southern Alternative
          *
                                     Northern
                                     alignment
                                     (Eastern)
                                                 ROADWAY RIGHT OF WAY
                                                     Exhibit 3-22
SERVICE ROAD ALTERNATIVE  ALIGNMENTS

-------
3.2.2.1.3.2  Southern Alternative

The southern alternative would also be coincidental with the proposed Aliso
Creek Road extension to Aliso Creek Beach.  A narrow access road to the
existing treatment plant already exists in this alternative alignment and it
would have to be widened to accommodate the needs of this project.

3.2.2.1.3.2.1  Environmental Considerations

The widening will cause little disruption to the natural environment but would
have a significant impact on the man-made environment.  The existing road
passes through a golf course and is adjacent to tourist facilities and a hotel.
The construction of the road and the treatment plant would not pose significant
long-term environmental threats to the users of these facilities, but they would
be a source of irritation, degraded air quality, and noise during the construc-
tion stage.

3.2.2.1.3.2.2  Economic Considerations

The existing access road is very narrow and additional right-of-way would have
to be purchased.  The total construction costs would be much less—the route
is shorter.

3.2.2.1.3.2.3  Planning Considerations

As previously noted, this alternative is coincident with the planned arterial
highway alignment shown in the MPAH, but in all liklihood this segment will  never
be built because of the growing concern over its location in an environmentally
sensitive area.

An overview of various factors involved leads to the conclusion that the eastern
alignment of the northern alternative would be the best solution for access  to
the regional treatment plant.

3.2.2.1.4  Land and Ocean Outfall

Construction impacts for this portion of Alternative 2E would be identical  to
the impacts of Alternative 1A.

3.2.2.2  Operational Impact

3.2.2.2.1  Discharge Impacts

Since all effluent would be discharged to the ocean, the impacts would be the
same as for Alternative 1A except that there will  be no impacts from land
discharge.

3.2.2.2.2  Energy Consumption

Operation of this alternative is estimated to require 203.3 x 10  kilowatt-hours
over the 20 year planning period.
                                3-21

-------
 3.2.2.3  Reliability

 Alternative 2E would  involve  only  one  treatment  plant.   Further,  the size of
 the treatment plant would  give  it  some ability to  resist treatment  upsets.
 Thus,  Alternative  2E  would have the  fewest number  of  plant  upsets of any
 alternative.   However,  the impact  of any  one  upset would be greater than the
 impact of any upset with Alternative 1A.

 3.2.2.4  Compatability  with Reclamation

 Alternative 2E envisions abandoning  upstream  plants in favor of central treat-
 ment.   Head would  be  lost  in  draining  effluent to  a central  treatment plant.
 Reclamation would  still be possible  by using  upstream plants on a "stripping"
 basis  where they only treat enough water  to supply reclamation demands.
 Moulton  Miguel  Water  District's  Plants  1A and 2A currently  operate  on this
 basis.

 Alternative 2E is  less  compatible with  reclamation than  1A  because  it lacks
 a  treated line to  provide  distribution  of treated  effluent.  Unless advance
 treatment and distribution  similar to  Alternative  3C  is  instituted, recla-
 mation would  probably be limited to  the existing reclamation areas  currently
 served  by Moulton  Miguel,  Los Alisos and  El Toro Water Districts.

 3.2.3  Alternative  3C - Reclamation

 3.2.3.1   Construction Impacts

 3.2.3.1.1   Interceptors

 In Alternative  3C  the Aliso Creek, Sulphur Creek and  South  Coast Interceptors
 will be  identical  to  Alternative 1A.   The North Coast Interceptor will go in
 the opposite  direction to a new plant  site, but will  involve virtually the
 same construction  impacts.

 There will  be  two new interceptors with Alternative 3C, both to convey treated
 effluent.   The  major  outfall would parallel the Aliso Creek Interceptor up-
 stream to  the  Los Alisos Plant, and then would continue up  El Toro  Road to a
 disposal  area.  A  treated line would also be constructed in the Irvine Ranch
 area to dispose of wastes from Irvine Ranch and Laguna Beach.  No route was
 selected  for  this alternative, but it would probably follow a natural  drainage
 course.  Thus  its construction impacts would be those of construction along
 an ephemeral  stream.

 3.2.3.1.2   Land and Ocean Outfall

 No new facilities would be constructed.  The existing Laguna Beach and South
 Laguna Beach outfalls would be used to dispose of desalinization brines and
 flows which could not be reclaimed.

 3.2.3.1.3  Treatment  Plants

An advanced wastewater treatment plant would be constructed in  the same site
as foir Alternative 2E.  Although the size would be reduced,  the additional  •
                                 3-22

-------
treatment units would result in a plant area and construction impacts about
the same as for Alternative 2E.  In addition, a new treatment plant would be
built in the Irvine Ranch area.  No site has been proposed for this alternative,
but all sites would be essentially undeveloped or agricultural lands.

3.2.3.1.4  Access Roads

The access road described for Alternative 2E would be required for this
alternative.

3.2.3.2  Operational Impacts

3.2.3.2.1  Discharge Impacts

All effluent will be discharged to the land.  The impacts will be similar to
those detailed for Alternative 1A except that the effluent will  receive a
higher level of treatment.  This should substantially reduce the problems
from pathogens and nutrients when the treatment plants are operating properly.
Advance waste treatment does not remove trace organics.

3.2.3.2.2  Energy Consumption

Operation of this alternative is estimated to require 1,520 x 10  kilowatt-
hours over the twenty year planning period.   Increased power consumption is
related to advanced treatment and greatly increased pumping.

3.2.3.3  Reliability

Although there are more units within each plant, there are only two treatment
plants.  The total number of units thus is about the same as with Alternative
1A, and the frequency of failure is expected to be about the same.   However,
the impact of each failure would be greatest in this alternative.  Alternative
3C does not provide access to an ocean outfall  for periods of plant upsets, and
the land environment is far more sensitive to the discharge of inadequately
treated effluent than is the ocean.  Land discharge of inadequately treated
effluent would result in a hazard to the public health from pathogens.

3.2.3.4  Compatability with Reclamation

Alternative 3C is expressly designed for reclamation and has access to  the
largest number of potential  reclamation sites.   Demineralization of effluent
would make reclamation a virtual certainty since reclaimed effluent would be
a valuable commodity.   The loss of head involved in draining upper Aliso
Creek flows to the coast and then pumping flows back inland involves costs
which somewhat lessen the advantage of this  alternative, nevertheless,  this
alternative is the most compatible with long-term reclamation.

3.2.4  Alternative 4A - Partial Regional System with Stream Discharge in
       Upper Aliso Creek Area

3.2.4.1  Construction Impacts
                                   3-23

-------
 3.2.4.1.1   Interceptors

 All  interceptors would be similar to  those proposed for Alternative 1A except
 for  the  Aliso  Creek  Interceptor, which would be somewhat shorter.

 3.2.4.1.2   Land and  Ocean Outfall

 The  land and ocean outfall  for Alternative 4A would be similar to those proposed
 for  Alternative 1A except that they would be slightly smaller, since capacity
 for  the  Upper  Aliso  area would not be provided.  This would reduce the con-
 struction  impacts slightly.

 3.2.4.1.3   Treatment Plants

 A  regional  treatment plant to serve the lower Aliso area would be constructed,
 just as  in  Alternative 1A.  The upper treatment plants would also be expanded
 as in Alternative 1A, except that a new tertiary treatment facility would be
 needed.  This  could  be constructed on a new site, or adjacent to the Rossmoor
 plant.

 3.2.4.1.4   Access Road

 No new access  road would be required with this alternative.

 3.2.4.2  Operational Impacts

 3.2.4.2.1   Discharge Impacts
                                        t
 3.2.4.2.1.1  Ocean Discharge

 The  impacts of ocean discharge would be similar to those described for
 Alternative 1A except the volume of discharge would be reduced.

 3.2.4.2.1.2  Stream  Discharge

 Stream discharge from the Upper Aliso area would be practiced when there was
 no demand for reclaimed water.   Advanced treatment would remove nutrients and
 pathogens, but not trace organics.   This stream discharge would not represent
 a significant contribution to any known water supplies at present, but could
 represent a potential problem.

 3.2.4.2.2  Energy Consumption

Operation of this  alternative is  estimated to require  3.2 x 10"  kilowatt-
hours over the twenty year planning period.
                                        !
3.2.4.3  Reliability

The number of units  in this  alternative is nearly at a maximum,  thus  the
probability of unit  failure  is  high.   The  water quality impact of a  failure
is low in the lower  area,  relatively high  in  the upper area.
                                3-24

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3.2.4.4  Compatability with  Reclamation

Alternative 4A would encourage, virtually force reclamation in the upper Aliso
Creek area.  A demineralized effluent would be a valuable product and would
almost certainly be used by agricultural users.

Reclamation in the lower Aliso area would be possible using the effluent from
Moulton-Miguel Water District Plant's 1A and 4A and the treated line outfall.
Thus Alternative 4A is as compatible as Alternative 1A in the lower Aliso
Creek area and more compatible in the upper Aliso Creek area.

3.2.5  Alternative 4C - Intermittent Stream Discharge from the Upper Aliso Area

This alternative is identical to Alternative 4A except that storage is proposed
to minimize stream discharge, and only secondary treatment would be used.
Storage would limit stream discharge to periods when there is running water
in the stream to provide dilution of waste flows.  The impacts of this alterna-
tive are identical to Alternative 4A except in two respects.

3.2.5.1  Streat Discharge

There would be a discharge of nutrients and pathogens with Alternative 4C.  This
discharge would be timed to avoid recreational users.  The impact of this
occasional discharge of nutrients would not have a significant impact on water
quality, but the occasional discharge of pathogens would be a potential  health
hazard.

3.2.5.2  Reliability

Again, the reliability of this alternative would be similar to that for
Alternative 4A except that the impact of failure would be even more pronounced.

3.2.5.3  Compatability with Reclamation

Alternative 4C is similar to Alternative 4A except that in order to reduce
costs, no advanced waste treatment is included.  This reduces the market-
ability of effluent considerably.  Other than this factor, Alternative 4C is
the same as Alternative 4A.  The reduced marketability of the effluent means
that Alternative 4C is probably only slightly better than Alternative 1A in
terms of compatibility with future reclamation.

3.2.6  Alternatives 2F and 2G - Regional Treatment, Regional  Disposal with
       Upstream Reclamation

These alternatives are almost identical  to Alternative 2E except for provisions
for upstream reclamation during summer months.  This would allow a reduction in
the size of the downstream plant and a net reduction in overall  costs.   The
impacts of this alternative are virtually identical to those  of Alternative 2E
except for a slight increase in power consumption from 203.3  x 10& to 237.7 x
due to advanced waste treatment in the upper area at a later  date.

Alternative 2G is idential to Alternative 2F except for a slight decrease in
power costs.
                                    3-25

-------
3.2.6.1  Compatability with Reclamation

Alternatives 2F and 2G are virtually the same as Alternative 2E except that
2 mgd of summer reclamation on a "skimming" basis is planned as part of the
project.

3.2.7  No Project Alternative

If no project is constructed, the problems detailed in Chapter 1  would not be
solved.  Less than satisfactory treatment would continue at Laguna Beach and
South Laguna Beach; poorly diluted effluent would be discharged in relatively
shallow water; and the systems in the Upper Aliso area would remain unreliable.

Since the chief primary impacts associated with project construction are those
of construction, which are short term; and those of ocean discharge; the no
project alternative is not felt to be appropriate.  The no project alternative
would continue the discharge of greater quantitites of pollutants at lesser
dilution than any of the alternatives considered.
                                3-26

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4.0  SECONDARY IMPACTS OF PROJECT ELEMENTS

4.1  INTRODUCTION—THE RELATIONSHIP BETWEEN PUBLIC UTILITIES AND DEVELOPMENT

The major issue in this project is whether or not the project, by stimulating
or accommodating urban development creates more environmental problems than
it solves.  Answering this question is fairly complex, because although
public utilities play a role in urban development, that role is not always
or chiefly causative.  It is possible that utilities cause urbanization in
a direct sense.  But they can also encourage development, drawing it more to
one area than another.  Public utilities might also facilitate development,
making it easier, or merely accommodate urbanization that is caused by other
factors.  The lack of public utilities can deter development, making initial
costs higher or decreasing densities.  Finally, the lack of public utilities
can prevent development, if certain utilities are absolutely necessary.  It
will be one of the tasks of this chapter to determine where on this continuum
between cause and prevent that the Aliso project lies.

The availability of some public utilities plays a major role in determining
whether or not urbanization occurs.   The lack of transportation access is an
absolute barrier to development, while overload transportation facilities
represent a partial barrier.   Water supply and sometimes sewers can also
deter development, especially if there is insufficient (or poor quality)
groundwater, or if septic tanks will  not work.  In all of these cases, the
lack of facilities prevents or deters urban growth.

It is far more difficult to establish whether or not public utilities have a
causative role in urban development.   Many examples  exist including the
coastal areas of Aliso where an adequate supply of utilities existed and
development did not take place.  One of the few ways that utilities can play
a causative role is in their impact on assessed values.   Anything that in-
creases assessed values, like public  utility construction, increases taxes.
Any increase in taxes makeslow intensity agriculture like cattle grazing less
profitable, and thus makes urban development an attractive alternative.

In this chapter the issue of development and public  utilities will  be
examined in some detail.  The historical  causes of growth in the project
area will be determined.  Then the factors affecting future land use patterns
and population growth will be examined.

The role of sewer and other public utilities in these growth patterns will
be an important area of investigation.  After the past dynamics of  growth
and the future prospects are determined,  the environmental impacts  of the
land use patterns and population growth,  and potential methods to mitigate
those impacts will  be evaluated.   This information will  help guide  local  and
EPA decision making, both on  this project and on future  activities.

4.2  DYNAMICS OF GROWTH

4.2.1   County Dynamics

For the past twenty years, Orange County  has experienced rapid population
growth.   From a population of approximately 700,000  in 1960,  the County
                                   4-1

-------
has grown to 1,656,300 in 1974, an increase of approximately 70,000 persons
per year.  Since 1970 the population has increased by an additional 273,360,
a slightly slower annual increase of about 55,000.  Table 4-1 shows these
annual increases.

Initially population growth in Orange County was a 'spill over1 from
Los Angeles County.  But the development of freeways and'the increasing
population allowed establishment of local employment, by 1960 the employ-
ment base was 165,000 jobs and by 1965 it reached 293,000.

The original 'spill over1 effect, the extensive freeway network, and the
policies of the Irvine Company established the character of Orange County.
The initial growth of Orange County as 'bedroom communities' necessitated
an expansive freeway network to get these people to their jobs.  Both of
these factors encouraged competition by cities for commercial and residential
development.  As a result, no single city dominated the economic and com-
mercial development of the County.  Meanwhile, during the 1950's the Irvine
Company's policy was to retain their land in agriculture and only develop
those ranch lands immediately adjacent to existing urbanization.  The effect
of this policy was to put a halt to 'leapfrog1 development, and confine
development to the northern part of the County.

It took a major event to alter this pattern of development—but this major
event occurred when the San Diego Freeway was completed in 1959.  The
freeway improved access through the Irvine Ranch to such an extent that
commuting became a possibility and the development of Southern Orange
County began.   The new community of Laguna Niguel  was approved by the County
in 1960, and was quickly followed by Rossmoor Leisure World, Mission Viejo,
and other developments.   Southern Orange County continued to grow, and
began to account for a relatively large share of the County's growth, as
shown by this chart! of new residential  units:
                  1968
                     1969
                     1970
     1971
  Southern
  Orange
  County:

  Rest:
  Southern
  Orange
  County:

  Rest:
10179 (42.1%)   10828 (32.5%)    6133 (26.2%)   10949 (35.0%)
13546 (57.1%)

     1972

14537 (35.0%)
21966 (66.9%)   17275 (73.8%)

     1973            1974

11002 (38.9%)   7709 (48.5%)
20299 (65.0%)
21127 (65.0%)   17269 (61.1%)   8158 (51.5%)
1
 Construction Summary,  Security Pacific Bank.   Southern Orange County is  con-
 sidered that area southwest of the Newport Freeway,  including the cities of
 Costa Mesa, Irvine,  Laguna Beach,  Newport Beach,  San Clemente, San Juan
 Capistrano, and Tustin.
                                   4-2

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    1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
                                                            T^9
                                                             1    ••^-••»
                                                                                          i increase due to
                                                                                          increase in  popu
                                                                                  Authorize^  building  permits



                                                                             ™"" Populatio
5.00

-------
1950
 Population
  216,224
1960
 Population
  703,925
8
HI
O
1968
 Population
 1,300,000
1973
 Population
 1,646,314

Exhibit 4-1
                                              s
                                              DC
UJ

t
O

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 Economic factors have played a major role in this development.  As shown
 by Tables 4-1 and 4-2, population increases due to migration are related
 almost directly to job formation, which in turn is sensitive to general
 economic conditions.  The line showing job formation reflects the defense
 and aerospace cutbacks in 1964-66 and 1970-71.  The decreasing rate of
 population growth also reflects this economic impact, although the economic
 effect does not entirely account for the drop.  This migration decrease
 probably reflects the overall decrease in migration to California.  The
 population did increase following the economic surge of 1972-73, indicating
 that there is a relation between economic conditions and population growth;
 however, the relation can be overriden by larger demographic trends.

 Construction of housing, measured by building permits issued, has generally
 followed job formation—at least until 1973.  As can be expected in a
 traditionally volatile economic sector, general economic fluctuations are
 magnified in their impact on housing.  The fluctuation in housing also re-
 flects over-and under-building. The impact of over-building can be seen
 in the 1964-68 building.  Despite these fluctuations, the general trend
 of housing construction following job formation can be discerned—except
 when general  economic conditions interfere.  This trend can be seen in the
 fluctuations since 1970, which reflects the overwhelming force of the
 effective interest rate.  The climb in interest rate and consequent fall
 in housing since 1973 is a national  trend, although in terms of job
 formation, Orange County has not been hit hard by the current recession.

 The preceeding discussion illustrates the significance of economic con-
 ditions.  Unfortunately, general  economic trends, and the attendant demo-
 graphic projections were examined, which project, on a County-wide basis,
 what population will occur if certain assumptions are made regarding birth
 rate and State-wide immigration.   Implicit in all of these projections are
 rough order assumptions about economics; areas with a stable employment base
 are expected to absorb most of the population increases.   All projections
 indicate that Orange County's population will continue to grow.   However,
 where this new population locates within Orange County depends on a variety
 of localized physical and economic conditions (as we have seen with the
 case of the San Diego Freeway).  Geography (topography and climate),  and
 the availability of public utilities—especially roads and water, the lack
 of which can  prevent development—both help determine the location of popu-
 lation.   Similarly, land must be available and relatively cheap.   It  is
 these physical  and economic factors  that will be examined next.

 4.2.2  Aliso  and Growth Dynamics

Table 4-1  establishes the baseline population growth for the entire County,
while Table 4-3 relates this to population growth in the AWMA area.

 Exhibit  4-2 and Table 4-3 indicate that within AWMA, growth has  occurred in
two geographic  areas—the coast and  the inland valley.   Growth in the
 inland valley has  been very rapid recently,  while coastal  growth has  been
relatively  slow.

 In the Irvine Ranch area along the coast there has been  practically no
growth in  the last ten years.   It can be assumed that this is a  result of
                                     4-3

-------
 PAGE NOT
AVAILABLE
DIGITALLY

-------
 / f
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                                  TABLE 4-3

                       POPULATION GROWTH WITHIN AWMA

                     COASTAL SECTOR
                           1
               City of
             Laguna Beach
     South Laguna
     Laguna Niguel
1960
1968
1970
1973
Increase
over 1960:
9,288
Not available
14,550
14,851
13,410
2,000
3,357
5,696
9,847

Percentage
of Increase:
     INLAND SECTOR


El  Toro       Laguna Hills
                                                   1,722

                                               Not available

                                                   4,357

                                                   6,196
1 1 Q '
I I O.i
                                                          23,516
       1058.3%
                                         500 Est.

                                           8,517

                                          12,078

                                          19,542
1
 1960 Census, 1970 Census,  O.C.  Progress Report,  1968 Special  Census-Orange County,
 1973 State of the County Report,  Orange County Forecast  and Analysis  Center.
  the Irvine Company's policy about gradual  development of their  land,  maintain-
  ing agricultural  productivity for as  long  as  possible.   Virtually all  of  this
  area is in an agricultural  preserve,  although preserve status has  been cancelled
  on part of the area.

  The City of Laguna Beach  has also experienced moderate growth,  from 9,288  in
  1960 to 14,550 in 1970 and  14,991  in  1974.   In general,  the  rate of develop-
  ment along the coastal  area of AWMA has  been  much  slower than in the  rest  of  the
  County.

  Growth  along the  San Diego  Freeway in the  El  Toro  area  has been significant in
  the last 15 years.   New communities emerged fairly rapidly after the  initial
  construction of the San Diego Freeway.

  4.2.3  Growth Rate Analysis

  To account for these baseline patterns,  freeway construction, water supply
  changes, sewerage facilities, assessed value and recreational trends as well as
  social  attitudes  were examined to  try to determine the  complex of  factors
  determining the overall growth rate.
                                      4-4

-------
                                                 \
Legend
         Single Family Residential
         Multi-Family Residential
         Commercial
      I  Industrial
         Public
       I  Open Space
Exhibit  4-3

-------
                                                   \
                                                    \
 Legend



          Agricultural
          Planned Community



          Single Family Residential
      1   Multi-Family Residential



          Commerical
       I   Industrial
Exhibit 4-4

-------
 4.2.3.1   Circulation

 Freeway  access,  is  very  important  in  that development  is impossible if there
 is  no  access;   development   is   unlikely  if access is not convenient and
 timely.   The  latter point 'can be  illustrated by envisioning a  'commuting
 radius1  around  an  individual's home.  This reflects the amount of time an
 individual  is willing to spend commuting.  This 'commute radius' depends
 upon freeway  access because a commuter can travel further by freeway than
 by  normal  roads  in any  given  length  of time.  Thus, the initial construction
 and subsequent widening of the San Diego Freeway meant that many more people
 could  live  in the AWMA  area and have an acceptable  'commuting radius1 than
 before the  freeway. ,

 The freeway, constructed in 1959  and expanded in 1969, has been very important
 in  the growth of AWMA in the  El Toro area—indeed we  can say that it played
 a facilitative role (although  its effect on land values probably can be said
 to  be  causative).  On the other hand, transportation  to the coastal area has
 been less than convenient. Pacific Coast Highway is fairly congested and has
 many stops  along its route.   The  proposed coastal  freeway has been dropped
 from serious consideration.   Through roads, such as Laguna Canyon Road, have
 only limited capacity.  Access is available so it cannot be said that growth
 is  prevented; however,  it is  clear that the existing  roads deter development
 in  Coastal  AWMA.

 Freeways  (and all,public improvements) also stimulate growth through their
 effect on land values.  Freeways  increase the value of land, both adjoining
 and surrounding  the freeway.  Motorists and their demand for services impact
 adjoining areas  heavily and stimulate service oriented development.  But
 improved access  also raises the value of surrounding  land.   These changes
 begin  when  a freeway route is adopted and lands take on a more favorable
 long-term value,  increased land value increases taxes, making it harder for
 landowners  to profit from land-intensive ventures  like agriculture.  This
 economic effect  increases development pressures over and above those created
 by  improved access.

 4.2.3.2  Assessed Value

 Assessed values, shown  in Exhibit 4-5, provides a  good illustration of this
 economic effect.  However,  any sort of physical  improvement increases the
 development pressure and the entire process is  circular.   An upward trend in
 land values can already be seen in the Aliso area,  particularly near freeway
 interchanges where development pressures are most  intense.   The assessed
 value  for the developed land north of the AWMA  area  is not indicative of
 assessed value trends, but rather of potential  profits.

 4.2.3.3  Water Supply

Water supply was investigated  because the lack  of  sufficient water can
 prevent development,  especially when groundwater is  of poor quality as  it
 is in the AWMA area.   Exhibit  4-6 shows  the water  supply  lines  serving  the
AWMA area.  With the exception of the Irvine Ranch and the  steeper slopes
 in central Aliso, the  entire AWMA area has  water.  Tri-Cities  Transmission Main was
                                    4-5

-------
LAND VALUES
AREA
1
2
3
4
ACRES
157.92
262.09
418.73
53.27
Exhibit 4-5
0 MOO 4000 I HX» I BOOO KOOOft
ASSESSED V.
PER AC.
$ 3,668.56
$ 1,100.00
$ 4,541 .38
$67,920.00
MARKET V.
PER AC.
$ 14,674.00
$ 4,400.00
$ 18,165.52
$271 ,683.00
©

-------
 4.2.3;1   Circulation

 Freeway  access,  is  very  important  in  that development  is impossible if there
 is  no  access;   development   is   unlikely  if access is hot convenient and
 timely.   The  latter point  can be  illustrated by envisioning a  'commuting
 radius'  aroilhd  ah  individual's home.  This  reflects the amount of time an
 individual  is willing to spend commuting.   This 'commute radius' depends
 upon freeway  access because a commuter can  travel further by freeway than
 by  normal  roads  in any  given  length  of time.  Thus, the initial construction
 and subsequent widening of the San Diego Freeway meant that many more people
 could  live  in the AWMA  area and have an acceptable  'commuting radius' than
 before the  freeway. .

 The freeway,  constructed in 1959  and expanded in 1969, has been very important
 in  the growth of AWMA in the  El Toro area—indeed we  can say that it played
 a facilitative role (although its effect on land values probably can be said
 to  be  causative).  On the  other hand, transportation  to the coastal area has
 been less than convenient. Pacific Coast Highway is fairly congested and has
 many stops  along its route.   The  proposed coastal  freeway has been dropped
 from serious  consideration.   Through roads, such as Laguna Canyon Road, have
 only limited  capacity.  Access is available so it cannot be said that growth
 is  prevented; however,  it  is  clear that the existing  roads deter development
 in  Coastal  AWMA.

 Freeways  (and all.public improvements) also stimulate growth through their
 effect on land values.  Freeways  increase the value of land, both adjoining
 and surrounding  the freeway.   Motorists and their demand for services impact
 adjoining areas  heavily and stimulate service oriented development.  But
 improved access  also raises the value of surrounding  land.   These changes
 begin  when  a  freeway route is adopted and lands take on a more favorable
 long-term value,  increased land value increases taxes, making it harder for
 landowners  to profit from land-intensive ventures  like agriculture.  This
 economic effect  increases development pressures over and above those created
 by  improved access.

 4.2.3.2  Assessed Value

 Assessed values, shown  in Exhibit 4-5, provides a  good illustration of this
 economic effect.  However,  any sort of physical  improvement increases the
 development pressure and the  entire process is  circular.   An upward trend in
 land values can already be seen in the Aliso area,  particularly near freeway
 interchanges where development pressures are most  intense.   The assessed
 value  for the developed land  north of the AWMA  area  is not  indicative of
 assessed value trends, but rather of potential  profits.

 4.2.3.3  Water Supply

 Water  supply was investigated  because the lack  of  sufficient water can
 prevent development,  especially when groundwater is  of poor quality as  it
 is in  the AWMA area.   Exhibit  4-6 shows  the water  supply  lines  serving  the
AWMA area.  With the exception of the Irvine Ranch and the  steeper slopes
 in central Aliso, the  entire AWMA area has  water.  Tri-Cities  Transmission Main was
                                    4-5

-------
LAND VALUES
AREA
1
2
3
4
ACRES
157.92
262.09
418.73
53.27
Exhibit 4-5
0 1000 4000 | 8OOO | DODO MOOOH
ASSESSED V.
PER AC.
$ 3,668.56
$ 1,100.00
$ 4,541 .38
$67,920.00
MARKET V.
PER AC.
$ 14,674.00
$ 4,400.00
$ 18,165.52
$271 ,683.00
®

-------
    •ff
Hi
       East Orange County
       Feeder No.2
m
T; IftaV'S... f |

®fe
       *
   li
I,/
Newport
Beach
Legend
    o



    •
 Exhibit 4-6
         Transmission Main-Major


         Transmission Main-Minor


         Filtration Plant


         Pumping Station


         Reservoir
                                            Dana Point',.,-,

-------
 constructed  in  1962 while the Eastern Main was constructed in 1963-64 by
 Moulton-Niguel  Water District.  The Aufdenkamp Main was constructed in 1971
 and  the  Santiago Aqueduct in 1963.  The Eastern Orange County Feeder No. 2
 was  constructed in 1964.  It can  be seen that the first water projects
 followed  the  first developments (which presumably used groundwater) and
 facilitated  the following developments.

 4.2.3.4   Sewerage Facilities

 Sewerage  service in the AWMA area has generally followed initial housing
 construction, although it has generally anticipated long-term growth (shown
 in Exhibit 4-7).  Thus the initial sewerage service accommodated already
 existing  growth, and facilitated  continuation of those growth patterns.  The
 initial  system  for the City of Laguna Beach was constructed in 1923, the
 system for South Laguna Beach in  1968-69.  Moulton-Niguel's plant 1A was
 constructed  in  1963-64, the 2A plant in 1965.  The Rossmoor Facility was
 constructed  by  the developer of Leisure World in 1963-64 while the Los Alisos
 facility  was  constructed in 1964.   In 1968 the first effort at regionaliza-
 tion was  made,  tying the Moulton-Niguel plants to the South Laguna Branch
 plant and outfall.  This project  also included an interceptor along Aliso
 Creek which  is not yet at or near capacity, although it is too small to
 accommodate  flows from Los Alisos and Rossmoor.  This project has not re-
 sulted in rapid growth, although  individual trunks have facilitated growth.

 4.2.3.5   Social Factors

 Ultimately, residential growth in an area is caused by an economic condition
 which creates a demand for housing, physical conditions which allow an area
 to absorb that demand, and economic pressures or social attitudes that
 render an area acceptable or desirable to live in.   The economic and physical
 conditions have been discussed above, and it seems appropriate to determine
 whether it is economic pressures or social  attitudes that predominate in
 making the AWMA area acceptable or desirable.

 Economic pressures occur when the cost of housing near communities exceeds
 the cost of housing in more remote areas.   However, it appears that this is
 not the case  in the AWMA area.   The average cost of housing is as high or
 higher in the AWMA area, and since the area is remote, transportation costs
 are significantly higher.   It may be surmised that social attitudes play a
 key role in the development in the AWMA area.

 To begin with, Table 4-4 establishes the social  characteristics of the exist-
 ing population as of 1970.   It can be seen  that the new communities differ
 considerably from the established  communities and are remarkably homogeneous
 in nature.  With the exception of  Rossmoor  Leisure World, the new communities
 are occupied by fairly young, affluent people with families.   They are
 relatively well  educated,  and the  number that make over $15,000 per year
 greatly exceeds the number below the poverty line.   They are predominately
white,  as is the entire County.

 In attempting to analyze the existing social  make-up of the community to
determine the motivating factors behi;nd the influx  of people, one is
 hampered by the scarcity of data.
                                    4-6

-------
 Newport
 Beach
Legend
  	   Gravity  Sewers


  	   Force Mains


   •      Pump Stations


   D     Wastewater Treatment Plant
Dana Point
                                                                     \. •   San Clements

                                                                       V- ^
                                                                          '" ^
Exhibit 4-7
            i

-------
                                       TABLE 4-4
                               ORANGE COUNTY 1970 CENSUS
                                                  =»*=
Capistrano
Dana Point
Laguna Beach
Laguna Hills
Laguna Niguel
Mission Viejo
San Clemente
San Juan Capistrano  4.5
South Laguna
Orange County
Anaheim-Santa Ana
z
o
3
1
^
3-
^«
<~t*
fD




3.0
2.0
1.8
0.2
0.7
1.1
2.9
4.5
1.1
2.7
2.7
3
CL
fD
-s

__l
00







32.2
33.6
20.6
7.5
35.0
44.1
27.2
32.9
17.9
36.8
36.8
oo
c+
o

o^
^"s.







52.0
57.5
61.3
24.7
57.9
54.1
55.4
54.8
60.4
56.2
56.2
*•
QJ
3
Q.

O
<
fD
-s




15.8
8.9
18.0
67.8
7.1
1.8
17.5
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-------
Very little analysis of migration within Orange County has been done, although
some good data on movements between counties exists.  Information in this
chapter is gathered from Orange County Progress Reports as well as contacts
with the staffs of Orange County's Planning and Transit Departments, and con-
tacts with several of the developers in the area.  The most detailed source
used is the survey work done by developers in Mission Viejo, the City of
Irvine, and Laguna Niguel.  These surveys were designed to determine why new
homeowners had moved to the area.  A general study by the Southern California
Association of Governments, census data, and observations by those who have
worked on general migration and transportation studies were also used.

Despite the variety of sources used, a consensus on motives emerges.  It seems
that people have been moving to Southern Orange County because it is an
attractive area, rather than moving away from another area which is unattrac-
tive. Orange County does not contain any cities which people are fleeing to
avoid crime, center city decay, or racial tensions.  Both Orange County as a
whole and Southern Orange County have few non-whites; thus racial tension is
not a significant factor.  However, more than 75% are opposed to low or middle
income housing for less affluent whites or non-whitesJ   From the observed
data, it appears that the following factors are the social factors involved
in Southern Orange County's growth, in order of their importance:

     1.  Exclusiveness and amenities of the developments.

         Many of the developments in Southern Orange County are planned and
         executed on a large scale.  They include many recreational  and social
         amenities such as green belts, swimming pools,  local  shopping centers,
         and local schools.   Respondents have said they  liked the 'country club1
         atmosphere; others cite the 'overall  planning of community'  as major
         reasons for their move.

     2.  Environmental  amenities of the area.

         Chief among the environmental  amenities were open space and proximity
         to the ocean.   The desire to live near the ocean  is a trend discerned
         by SCAG in their more general  study.   A feature that also attracts
         people is the ocean's tempering effect on the climate.   Summers in
         the AWMA area are cooler and winters are warmer,  than in the inland
         portions of Orange and Los Angeles Counties.  The topography of the
         area is also appreciated, since the terrain of  rolling hills provides
         a contrast to the vast plains  that have been developed.   Although
         mentioned less frequently than others, better air quality was also
         cited as an important environmental  amenity.
 Community Profile of Irvine,  Calif.,  University  of  North Carolina, Center
 for Urban and  Regional  Studies,  1974.
                                    4-7

-------
      3.  More  single family  housing available.

         This  was mentioned  as a factor,  but  is more a perceived phenomenon
         than  a  reality.  There is more housing available elsewhere  in the
         County, but the rest of the County is considerably larger.  There is
         a  good  supply of housing available in a small area in AWMA.  What is
         probably more significant is that there is a greater variety of hous-
         ing available.  Much of northern Orange County was developed with
         small tract homes,  built in one or very few styles.  Housing in the
         Southern County, because it is more  expensive, has provided house-
         hunters with a wider variety of choices within a development.  This
         has led to a 'buy up' phenomenon in  Mission Viejo, where a  sub-
         stantial number of  houses are sold to existing residents who desire
         a  nicer home.

      4.  Some  people move to be near their friends.

         This  is a phenomenon that has been observed before in American
         migrations.  This is reflected in the AWMA area by people actually
         locating near friends, also in locating in a community of peers.
         This, and economic exclusivity, helps account for the cultural
         homogeneity of the newer communities.

4.2.3.6  Conclusion

The overall economic health of the County, freeway access, and the 'exclusiveness'
of the area have been the major factors in past growth in the AWMA area.   The
initial construction and subsequent widening  of the San Diego Freeway are the
key events opening up Southern Orange County  to absorb development pressures.

4.3   FUTURE DEVELOPMENT PROSPECTS

Establishing what has happened in the past -- and why -- can be done much more
accurately than the future can be projected.   To estimate what will happen in the
future for our purposes of evaluation, the existing dynami.cs will be used as a
base  pattern.  Factors which may affect this  pattern, including current land use
planning,  availability of utilities, and various regulatory activities will  be
examined.  Various population projections will also be presented and analyzed.

4.3.1  Population Projections

As the last section showed, there is a general pattern of migration from  .
Los Angeles County to Orange County.   By virtually all  accounts this pattern
wiljl;'  continue and may even accelerate.   Various population projections will  be
presented (Exhibits 4-8, 9, 10), first on a County-wide basis and then in the
AWMA;.area.   On a County-wide basis it is felt that the E-0 and D-100 projec-
tions establish the 'most likely to occur' range unless significant economic
and governmental  policy changes take place.   These projections are developed
by the Department of Finance and are used by the State and EPA for planning
purposes.  However, when these population projections are broken down from
County level to district level, considerably more uncertainty is introduced,
as can be seen in the larger spread in the AWMA projections.   Thus, we feel
                                    4-8

-------
                    ORANGE   COUNTY  ALTERNATIVE  POPULATION  FORECASTS
                                        ,580,000)
                                    ,420,000)
                    (655,000)
      (216,000)
  1950
1960
1970 73
1980
1990
2000
         D/E 2A  (SCAG)
                          1,914,000
                          2,240,000
                          2,560,000
 	 D-100   (DOF)
                          1,970,500
                          2,465,000
                          2,811,000
 	E-0     (DOF)
                          1,900,500
                          2,195,000
                          2,378,000
         1970-73 STRAIGHT LINE
         (COUNTY ESTIMATE)
                          1,953,000
                          2,487,000
Exhibit 4-8

-------
 YEAR1970
1975
1980
1985
1990
1995
2000
         PROJECTED POPULATION BY AWMA MEMBER AGENCIES
                E-O
                       Modified Orange County
Agency
Los Alisos W.D.
EIToroW.D.
Moulton-Niguel
South LagunaSan
City of Laguna 2
Irvine Ranch W.D.
  TOTALS    50,000 120,400  157,900 174,000
1. These figures are based upon State Water Resources Control
 Board data, but they have been proportially increased to reflect
 the State Department of Finance projected E-O totals.

2. Includes Emerald Bay Service District.
Exhibit 4-9
1970
2,500
19,100
7,800
4,900
15,700
^MM^HB
1985
12,546
49,833
18,060
13,918
26,043
^-^•™-—
1995
16,453
65,355
23,685
18,253
34,154
^™^™^^"
2000
18,131
72,019
26,100
20,114
37,636
m^fnni^^m
1985
40,000
40,000
41 ,300
17,300
19,100
6,000
1995
53,000
51 ,000
64,000
25,400
20,400
11,000
2000
58,700
58,000
72,800
30,000
21 ,000
14,500
                     163,700 224,800 255,000
      AWMA    ALTERNATIVE
      POPULATION    FORECAST

-------
   30
   25
   20
 £15
   10
      1970

      YEAR
     Flow Rate
 1975
1980
1985
1990
1995
2000
              PROJECTED WASTEWATER FLOWS
                 (Average Daily Flow-MGD)
   E-O Population
Agency gal/cap/day 1970 1985 1995  2000
          Modified Orange County
          1985  1995 2000
LAWD
ETWD
MJSIWD
SLSD*
CLB*
IRWD* .
100
84
87
87
87
87
0.25
1.61
0.68
0.42
1.37
—
1.18
3.94
1.48
1.15
2.14
—
1.55
5.12
1.96
1.51
2.82
—
1.71
5.71
2.15
1.67
3.10
—
4.00
3.36
3.59
1.51
1.66
0.52
5.30
4.28
5.57
2.21
1.77
0.96
5.87
4.87
6.33
2.61
1.83
1.26
   TOTALS
4.33 9.89 12.96  14.34
         14.64 20.09 22.77
*Does not include summer population flows
PROJECTED
WASTEWATER   FLOWS
                          Exhibit 4-10

-------
 more  comfortable with  the county-level projections, realizing that the level
 of growth  in AWMA  depends on  localized factors, and not entirely on the
 County's growth.   We will turn our attention to factors in the AWMA area
 impacting  on population  location.

 4.3.2  Formal  Land Use Planning

 One of  the factors affecting  population location is formal land use planning.
 Exhibit 4-11,  compiled from County, City, and landowner general plans illu-
 strates formally adopted land use elements to the Orange County General Plan
 in the  AWMA area.  Barring action to retard development by regulatory agencies,
 areas within this  developable region will continue to develop to the limits
 of their zoning (or more), guided chiefly by housing economics and access-
 ability.   It should be noted  that zoning has not restricted development in the
 AWMA  area  in the past.  Although state legislation requires that zoning now
 be consistent  with land use plans, land use plans may be amended three times
 each  year.  It is  probable that developing plans, rather than zoning, will
 guide and  control  development.

 Local governments  ultimately  have 'complete' control of land use decisions.
 The general plans  noted in Exhibit 4-12, Proposed Land Use, should provide
 the technical  basis for these decisions.  The planning map represents a com-
 posite  of  three different plans:  Orange County's The 1983 Land Use Element
 which governs  most of  the AWMA area, the City of Laguna Beach's General Plan,
 and the Irvine Company's Coastal Community Plan.  The Irvine Plan is a pre-
 liminary indication of how this land will develop, although it must be
 developed  under the direction of the County which has land use planning
 authority  over the area.

 These land  use plans are not absolute, however, nor should they necessarily
 be absolute.   The Orange County Land Use Element, is ".  .  . designed to
 provide a  policy framework within which decisions, both private and public,
 can be made concerning the physical  development of the County."  The plan is
 designed with  flexibility in mind; partly because there is no County-wide
 consensus  on growth and development, and partly because effective planning
 must  be a  dynamic process.   Flexibility is provided by using policy direction,
 rather  than inflexible maps, and by allowing up to three amendments to the
 plan  each year.  In the AWMA area, where large landowners  predominate and
 intend  to  phase development of their land, the general  plan does not repre-
 sent  a barrier to growth, but rather a tool  to guide growth.   (It should  be
 noted that air quality does not receive major emphasis  in  land use planning,
 although other physical and environmental  constraints do.   There are no air
 quality elements  in California land  use plans.)

An example in the AWMA area of the intended  flexibility  of land use planning
 in Orange County can be seen in the  designation of Planning Reserves and
 Preserves.   Planning Reserves are areas where no formal  plan is presented as
a part of the County land use element.   Rather,  these are  areas where planning
 is currently underway,  and  such planning  is  accomplished through coopera-
 tion  between private land owners and county  planning staff.   As shown on
 Exhibit 4-13,  there are three planning Reserves in  the Aliso area,  the Laguna-
Aliso, South Coast, and Northern El  Toro  Planning Reserves.   In 1974,  Orange
                                    4-9

-------
                                                  \
                                                   \
Legend
                                                     \
                                                       -
                                                                -'   jff Ti _
                                                          \
         Single Family Residential



         Multi - Family Residential



         Commercial



         Industrial



         Public



         Open Space
Exhibit 4-11

-------
                                                \
                                                    \
                                                        \
Legend
         Single Family Residential


         Mult! - Family Residential


         Commercial


         Industrial
                                                                                    LU
                                                                                    0)
                                                                                    Q
                                                                                    LU
Exhibit 4-12

-------
 County amended its Land Use Element to include planning that had been com-
 pleted for these areas.  The South Coast Planning Reserve (also known as
 Bear Brand Ranch) was approved for a density of 2.09 dwelling units per acre
 and an ultimate population of 6256.  The Northern El Toro Planning Reserve
 was approved for a density of 3.3 d.u./acre and an ultimate population of
 22,892.  Laguna-Aliso was approved for a density of 4.6 persons per acre,
 with a projected population of 46,664.

 The 1983 Land Use Element also includes areas designated as Planning Preserves.
 These areas are identified as essentially open space,  and are areas "...
 where development is not expected nor encouraged to. occur during the next ten
 years."  An 11,677 acre area of the Irvine Ranch within.the AWMA area has been
 designated as a planning preserve.   However,  it is not the intent of the Irvine
 Company to keep this area in open space or agriculture permanently.   They
 have already cancelled the preserve status on part of  their land,  although they
 cannot develop this land for about 8 and 1/2  years unless they pay a sub-
 stantial  tax penalty.   It will  require  final  approval  to  the County before
 any land  use plan for the area  is adopted, but the Irvine Company has prepared
 a  plan that is undergoing review internally and with a review group which in-
 cludes members of the responsible governments as well  as  citizens  groups with
 an interest in land use.   This  draft plan has been included in Exhibit  4-12,
 but may be altered considerably before  implementation.   In  any case,  imple-
 mentation   is at least four or  five years away,  and  probably eight to ten years
 away.   The plan proposes  a  fairly low density,  with  an  ultimate population  of
 55,350.

 The City  of Laguna Beach  has  also prepared a  General Plan with a  Land Use
 Element that  anticipates  an ultimate population  of 20,000.   The City  is  very
 interested  in maintaining  its  'village1  character  and  expanding  its  tourist
 industry.   It has  oriented  its  plan to  controlling residential  development
 and maintaining and  expanding tourist-oriented  commercial areas,  expecially
 along  the  Coast Highway.

 4.3.3   Availability  of Utilities

 4.3.3.1  Transportation

 The last section showed that the  San Diego  Freeway has dominated development
 trends  in the AWMA area.  It is expected  that this trend will continue,
 expecially  if the  proposed mass transit corridor, which parallels the freeway,
 is  adopted.  Within AWMA, arterial  roads will play an important role, and the
 existing and  projected arterials  are shown  in Exhibit 4-14.  The construction
 of  several of these roads represent  key events in the future growth of AWMA.
 The growth of Upper Aliso. (Northern El Toro) will be stimulated by the com-
 pletion of El Toro Road widening, now under construction.  The poor condition
 of  El Toro Road has been acting as a deterrent to development.  The rate of
 growth in the upper El Toro area will also depend on construction of local
 arterials and the extension of Canada Road; however, these can be constructed
 by developers and do not represent a significant deterrent.

Development in central AWMA (Moulton Ranch) depends to  some extent on road
construction.  In order to develop the western part of  the ranch, it will be
necessary to extend Oso and Alica Parkways.  Aliso Creek Road would facilitate
development, but the lack of this road alone would surely not deter development.

                                     4-10

-------
m
x
w
            PLANNING RESERVE AREAS
            1. Bolsa Chica
            2. Laguna-Aliso
            3. South Coast
            4. Northern El Toro
URBAN AREAS
PRESERVE AREAS
      BASIC  PLANNING CATEGORIES - 1983 LAND USE

-------
Legend

Major
Primary
Secondary
Commuter
Existing   Proposed   Proposed
     a   For Development
         Thru 1979
         eeeeec   	
         eeeeee
         eeeeeee
         eeeeeeee
Exhibit 4-14
            0000   MpOOfl
                3n*

-------
..^....^  ^  ^,.  ,  ,   v,'   ... %
/:. ' ' -S>sNiW^/ •/' • ,"-yx:::.-•,,••.•• /'
 j>i'm,-  v«  .v-v •/^.^••.•
 :^/:-y^^---'-^-:. .^ •_  .;•.''•: ",•. X, •.-••-    .,<
fefe5^-.;?>y'•: x^i-:^,


           w^^^p^^PW
                                     Dana
Exhibit 4-15

-------
Local arterials, including Wood Canyon Road and Alta Laguna Boulevard will also
be needed to facilitate development in the western part of Moulton Ranch.  If
this road network is not built, or is delayed, development in the area will be
prevented and development in the eastern part of the ranch will probably
increase.

The possible upgrading of Laguna Canyon Road to freeway status would be a very
important event in the future development of coastal AWMA.  As noted previously,
poor transportation has acted as a deterrent to urbanization in coastal  AWMA,
and construction of freeway access would facilitate development.

Future development of the Irvine Ranch depends very heavily on road construc-
tion.  If no arterials are constructed, development would be prevented every-
where except in the immediate vicinity of the Coast Highway.   No road construc-
tion in the Irvine Ranch is proposed for the next five years.

4.3.3.2  Water

The existing water system can be seen in Exhibit 4-6.   It is evident that water
is available to virtually all areas except Irvine Ranch, Bear Brand Ranch,
and the very northernmost parts of AWMA.  The existing facilities have adequate
capacity to maintain short term growth.  In addition,  there are two projects in
the active planning stage.  There is a possibility of paralleling the upper
part of the Eastern Transmission Main with the 16 cfs line to serve Moulton-
Niguel Water District.   There is also a possible project to parallel  the
Santiago Aqueduct to serve Moulton-Miguel Water District, and the Santa
Margarita Water District in nearby SERRA.

4.3.3.3  Sewers

The existing sewer lines can be seen on Exhibit 4-7.  Almost all facilities are
now adequate, but are approaching capacity.  Interceptor sewers are more
important than treatment plants in determining urbanization patterns, especial-
ly where an ocean outfall  or adequate storage exists.   When a  treatment  plant
with storage or an ocean outfall is overloaded, it does not represent a  serious
public health hazard, and consequently, building bans  are rarely instituted and
growth is not impacted.   When a sewer interceptor is overloaded it represents
a serious health hazard, and can deter growth almost immediately.

The existing system for Moulton-Niguel and South Laguna is not now deterring
development, but is approaching capacity and may deter urban  growth in the
near future.  The South Laguna Treatment Plant can treat 2.5  mgd of sewage and
achieve a nitrified effluent, or it can treat 3.2 mgd  and achieve secondary
standards.   The interceptor leading into the treatment plant  can accommodate
3.9 mgd of flow.  Current flow at the treatment plant  is about 2.2 mgd,  flow
in the interceptor line is about 1.3 mgd.

In the upper AWMA area,  both El Toro and Los Alisos Water District have  adequate
capacity in their treatment plants for some time to come.   El  Toro's  current
flows average 2.7 mgd,  Los Alisos flows average 1.062  mgd.   Both treatment
plants are rated at 4.0 mgd.   However, both districts  have been having trouble
disposing of their effluent without it reaching the local  creeks.   Rossmoor
Sanitation District,  which serves the El  Toro Water District,  is currently
under a cease and desist order for discharge into San  Diego Creek.  They feel
                                    4-11

-------
 that they have solved  their  problems,  but  if  the  problems continue,  it  is
 possible that a building  ban would  be  instituted  which would  stop development
 immediately.   This discharge does not  represent as  serious a  health  hazard
 as an overflowing interceptor,  but  does  represent a potential health hazard.
 Los Alisos doesn't have any  immediate  problems which might lead to a building
 ban, but unless some major effort is made,  or development slows, both treat-
 ment plants will  be overloaded  and  development will be deterred within  the
 next three to five years.

 The existing  treatment plant for the City of  Laguna Beach is  periodically
 overloaded due to fluctuations  in flow.  This has not acted as a deterrent to
 growth except in  the immediate  vicinity  of  the treatment plant.

 4.3.3.4  Other Utilities

 Other utilities,  such  as  schools, fire protection,  police protection and so
 forth are affected by  urbanization.  However, these utilities customarily do
 not stimulate or  deter development, so no detailed  examination of trends was
 made.

 4.3.4  Regulatory Programs

 Regulatory programs, especially those developed under the Clean Air Act and
 those developed under  the Coastal Conservation Act, will affect development in
 the AWMA area.  Obviously, construction  permitted by the cities and  the County
 as  part of their  general  planning function will have a large effect on AWMA's
 urban growth.   Review  of  indirect sources of air  pollution and certain elements
 of  the Transportation  Control Plan, developed under the Clean Air Act Amend-
 ments of 1970 (Section 110), will affect urbanization in the AWMA area.   This
 Act,  and why  a  Transportation Control Plan was needed are described  in Section
 4-5.   Under regulations to review indirect sources of air pollution, permits
 are required  to construct projects which generate mobile source activity to
 insure that such  projects do not interfere with the attainment of air quality
 standards.  The Transportation Control  Plan, designed to reduce automobile
 traffic  throughout the Basin, may act to direct development away from newly
 developing areas  and back towards filling the existing urbanized areas.   It is
 not possible  to quantify the net impact, but it does appear that these pro-
 grams  will deter  sprawling development in fringe areas such as Aliso.

 The'Coastal Conservation Commission has planning authority over a large  portion
 of  the AWMA area  and permit authority over a smaller area, including this
 project.  The Commission's planning effort is in its final stages,  as indicated
 on  the publication of  their Preliminary Control  Plan in early 1975.   It  is
 anticipated that  the eventual plan will require that the immediate  shoreline
 be  kept  in open space,  that new traffic generators will  be discouraged -- at
 least until such  time as the existing traffic problems are resolved, and that
 development on hillsides and valley's near the coast be carefully planned to
 prevent  environmental  damage and maintain scenic views.   If the State Legis-
 lature creates an agency to implement the plan,  this plan could have a major
 effect on the location  and density of future growth in a large portion of the
AWMA area.  It has already had a noticeable effect in  deterring Coastal
development within the  AWMA.
                                     4-12

-------
On June 20, 1973, the California Coastal Zone Conservation Commission granted
the Aliso Water Management Agency a permit to construct and operate an ocean
outfall.  Two of the conditions of the permit related to the maximum capacity
and the utilization of the outfall capacity by the AWMA member agencies.  These
permit conditions are as follows:

     1.  The facilities shall be constructed with only the capacity reasonably
         necessary to satisfy appropriate engineering standards, and in no
         event shall such capacity be greater than that reasonably necessary
         to serve a permanent population derived from an E-0 population pro-
         jection to the year 2000 plus commercial and industrial needs for
         the area, seasonal population increases, infiltration, and peak flows
         as determined by the State Water Resources Control Board.

     2.  The maximum portion of the total capacity of the facilities that can
         be used by any of the member agencies of AWMA shall be determined
         by that proportion of total  capacity assigned to that member agency
         in Table 4-5 with appropriate adjustments among the member agencies
         for the capacity necessary to service the respective seasonal  popu-
         lations, commercial and industrial  needs, infiltration, and peak
         flows as determined by the SWRCB pursuant to Condition No. 1.

On April 30, 1975, the Executive Officer of the State Water Resources Control
Board, in response to the permit condition requirement, recommended that the
Aliso Creek outfall be designed for a minimum peak daily flow of 42.1 mgd to
accommodate an E-0 population projection to the year 2000 and 50-year pro-
jected needs for commercial, industrial, and seasonal population.   The
Executive Officer further stated that if the outfall is to be designed to also
limit commercial, industrial, and seasonal  population flows to the projected
year 2000 levels rather than the 50-year outfall  life, then a minimum peak
design capacity of 36.7 mgd is indicated.
                                   TABLE  4-5
               Agency

  Santa Ana Mts.  County  Water  Dist.
  Los Allsos Water District

  El  Toro  Water District
  Moulton-Niguel  Water District
  South Laguna  Sanitary  District
  City of  Laguna  Beach
  Emerald  Bay Service District

  Irvine Ranch  Water  District
                                TOTAL
     Capacity
Average Flow (mgd)
(Proposed by AWMA)

        1.0

        5.5
        5.5
       12.9
        3.2
        4.4

        0.2
        3.0

       35.7
Proportion
 of Total
 Capacity

   .028
   .154
   .154

   .361
   .090
   .123

   .006
   .084

  1.000
                                    4-13

-------
 The  staff  of  the California Coastal Zone Conservation Commission notified the
 Aliso  Water Management Agency on May 30, 1975 that the lower flow of 36.7 mgd,
 indicated  in  the State Water Resources Control Board's letter, represented the
 intent of  the Coastal Commission permit and that the allocation of the capacity
 among  the  AWMA member agencies would be in accordance with the capacity pro-
 portions contained  in Condition No. 1 of the permit.  The member agency
 capacities as determined by the Coastal Commission are as shown in Table 4-6.


                                   TABLE 4-6
                        MEMBER AGENCY OUTFALL CAPACITY
              CALIFORNIA COASTAL ZONE CONSERVATION COMMISSION

               Agency                   Average Flow (mgd)  Peak Flow (mgd)

  Santa Ana Mts. County Water District          .59               1.03
  Los  Allsos  Water  District                    3.23               5.56
  El Toro  Water District                       3.23               5.56
  Moulton-Niguel Water District                7.56              13.25
  South Laguna Sanitary District               1.89               3.30
  City of  Laguna Beach                         2.58               4.51
  Emerald  Bay Service District                  .13                .22
  Irvine Ranch Water District                  1.76               3.08
The member agencies of the Aliso Water Management Agency have expressed
concern that the outfall capacity as indicated by the Coastal Zone Conservation
Commission, is less than what is expected and AWMA is considering appealing to
the California Coastal Zone Conservation Commission for reconsideration of
the outfall size limitations.  AWMA is presently making a determination of the
minimum outfall capacity necessary by each member agency to accomplish the
water quality objectives of the regional wastewater system and to protect   .
against the possible need to construct, in the near future, a costly second
ocean outfall system.  The current Coastal Commission permit requires that con-
struction on the Aliso Creek Outfall must be initiated by October 18, 1975.
To nTe~et this construction date, the Aliso Water Management Agency is proceeding
on .t'He following schedule:  advertise for construction bids on August 22, 1975;
open'bids on September 25, 1975; award construction contracts on September 30,
1975; and, initiation of construction contract on October 14, 1975.
                                     4-14

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4.3.5  External Stimuli

As noted earlier, regional economics play a profound role in growth within
AWMA and the entire County.  There are several developments of regional
import within and near the AWMA area (Exhibit 4-16).  First, there is the
Irvine Regional Center, a financial center development near the San Diego
Freeway just north of AWMA.  This Center has already been established, and
is currently growing.  The rate of growth of this center obviously depends
on complex economic factors beyond the scope of this report, but the center
will represent a potential place of employment for people now living in
AWMA as well as an employment center which will draw people to the AWMA area.
Second, there is a proposal to construct the East Irvine Industrial Complex
adjacent to the Irvine Center.  This development would also be a center of
new employment, but because of the high cost of local housing and the
'exclusivity1 of the communities, it is unlikely that a substantial number
of these employees would live in AWMA.

4.3.6  Social Attitudes

The last section demonstrated that social attitudes are of critical importance
in determining the rate at which AWMA grows.  Some recent trends indicate that
those social factors which affect the growth of Southern Orange County may be
in flux.  First, there is an increase in multi-unit construction County-wide.
This may be  in part an economic response to inflation in housing costs, or may
reveal a trend to smaller families, and more families without children.
Second, there is a national trend of rising suburban crime which may slow the
flight of people seeking a safer community.  Third, the noticeable worsening
of air quality in the Southern County area, may degrade its attractiveness.
However, the above discussion indicated that most of the attraction will retain
its exclusiveness for some time yet.  It appears likely that people will still
want to move to Southern Orange County, the major question is how many people
will be able to afford to.

4.3.7  Conclusion

Unless substantial changes in governmental policies occur, the AWMA area will
continue to absorb a significant amount of Orange County's population growth.
At the County level, the actual  level of population growth depends on general
economic conditions, which cannot be predicted.  The areas within AWMA, which
absorb population, the amount of population absorbed, and the manner in which
population is absorbed, depends on governmental policies and actions.   In
particular, land use planning and regulation,  and extension of public utilities,
including sewer trunks, water trunks and roads, will all play a critical role
in determining the urban form as AWMA develops.

4.4  ROLE OF THE PROJECT

4.4.1   Introduction

As stated in the introduction, one of the goals of this chapter is to determine
where along the continuum between cause and deter that the Aliso project lies.
We have seen in previous discussions that utilities have,  and will  continue
to have an effect on the location and magnitude of urbanization within a sub-
region.   Sewerage is not now playing a  major role in the location of develop-
ment because sewers are not now a deterrent to development.   However,  should


                                     4-15

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this project not be built, sewers will become a deterrent in various areas
in AWMA within the next two to five years.

A particular problem in evaluating the exact role of sewers in development
is that there are alternatives to public sewers.  An area can be developed
at densities suitable to the use of septic tanks, or developers can con-
struct private systems for apartment buildings or entire tracts.  Although
septic tank use can be observed in the nearby Santa Margarita Water District,
septic tanks are not a real alternative in AWMA because of opposition by the
Regional Water Quality Control Board and the County.  Should septic tank use
be allowed, the net population of AWMA would not be reduced much.  (There
are 40,000 acres undeveloped in AWMA.  Assuming half the area is suitable for
septic tanks, and developed on half acre lots, you could have 20,000 houses,
or about 80,000 more people for a total of about 175,000.)  Privately
developed systems can be observed in AWMA at Rossmoor Leisure World and also
in Coastal Malibu.  Private systems require higher costs for developers, and
thus houses.  It is not anticipated that this cost would ever exceed $2,500,
which is about 5-10% of the cost of housing in the AWMA area.   This would
have some deterrent effect, but since housing is already expensive, and the
attraction of the area is its exclusiveness, it is not anticipated that there
would be a significant effect.

In the absence of Federal funding for the project, it is likely that the AWMA
member agencies would construct the project on their own, although probably
without the City of Laguna Beach.  This might increase costs as much as
$800 per unit, again a relatively small cost to affect housing economics.

However sewerage service is provided, it will add to the assessed values of the
AWMA properties, and thus will directly increase developmental pressures.  How-
ever, the earlier discussion of assessed values showed that the potential gains
from development were much higher than the costs in increased assessed value
to install the basic improvements which make development possible.   It is felt
that these potential gains are behind development as the driving force and the
role of assessed value increases on taxation is relatively small.

Conclusion

The AWMA regionalization project is causative of urban growth to a  very slight
degree through its effect on assessed values.  If constructed as proposed, it
will facilitate development within the AWMA area, although not to the same
extent as provision of roads.   Finally, if no regional  project is built,
sewerage will  become a partial deterrent to urbanization within five years.

4.4.2  Variation by Alternative

There is no distinction in secondary impacts associated with the sizing of
elements since AWMA intends to construct all  alternatives with the  same
capacities.   However,  alternatives will vary in role to some extent,  depend-
ing on whether the upper Aliso Creek area is drained by a treated line inter-
ceptor or by a raw sewage interceptor.   Provision of service by raw sewage
interceptor opens up a corridor along the interceptor for urbanization.   With-
in this corridor, residences and subdivisions can connect directly  to the
                                    4-16

-------
 interceptor at minimal  capital  cost,  namely, that of constructing lines and
 a connection fee to  cover a  share of  capital costs for treatment and transport.
 Provision  of service by a treated effluent  line would require users to treat
 wastes,  prior to connection, or transport wastes to an existing treatment
 system;  as well  as pay  a connection fee.  Either of the latter options would
 involve  significantly more initial capital  cost for a developer.  Consequently,
 a raw sewage interceptor gives  a greater economic impetus to urbanization than'
 does  a treated effluent interceptor.

 4.4.2.1  Alternative 1A

 Alternative 1A would involve treated  effluent lines, consequently, its secondary
 impacts  would be less than those of a raw sewage line.  All existing trunk
 sewers would provide a  margin for increased urbanization within Los Alisos
 Water District,  El Toro Water District, Moulton-Niguel Water District Improve-
 ment  Districts No. 1A and 2A, Laguna  Beach, Emerald Bay Service District, and
 South Laguna Sanitary District.  Urbanization within the Irvine Ranch Water
 District,  most of the Moulton Ranch,  Glenn  Ranch, Whiting Ranch and Rancho
 de  Los Alisos would  require construction of new interceptor facilities.

 4.4.4.2  Modified Alternative 1A

 The secondary impacts of modified Alternative 1A would be virtually identical to
 those of Alternative 1A.

 4.4.2.3  Alternative 2E

 Alternative  2E would involve the construction of a new raw sewage interceptor
 along the  length  of  Aliso Creek.  As previously discussed, such a line would
 have  greater  secondary  impacts  than a treated line and would essentially provide
 a backbone  facility  for the development of the Moulton Ranch.  All  existing trunk
 sewers would  provide  a margin for increased urbanization, as with Alternative 1A.
 New facilities would  still  be needed for Irvine Ranch Water District, Glenn
 Ranch, Whiting Ranch, and Rancho de Los Alisos.

 4.4.2.4  Alternative  3C

 Since Alternative 3C would also provide a new raw sewage interceptor along
Aliso Creek,  its  secondary impacts would be virtually identical  to  those of
Alternative 2E.   The  increase in costs associated with this alternative would
 also  increase  the tax burden on undeveloped lands and further increase develop-
ment  pressures.

4.4.2.5  Alternative 4A

Alternative 4A would provide a new raw sewage interceptor along  only part of
Aliso Creek, but  the interceptor would be long  enough to serve  the  Moulton
Ranch.  Consequently, the secondary impacts of  Alternative 4A are virtually
 identical to those of Alternative 2E.
                                     4-17

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4.4.2.6  Alternative 4C

The secondary impacts of Alternative 4C are virtually the same as those of
Alternative 4A.  Because Alternative 4C is slightly less expensive, it would
have a slightly less tax-related effect on developmental pressures.

4.4.2.7  Alternative 2F

The secondary impacts of Alternative 2F are virtually identical  to the secondary
impacts of Alternative 2E.

4.4.2.8  Alternative 26

The secondary impacts of Alternative 2G are similar to the secondary impacts of
Alternative 2E with one exception.  Alternative 2G would provide a new inter-
ceptor sewer in the upper Aliso Creek area to avoid pumping sewage into the
San Diego Creek Basin and then back into the Aliso Creek Basin.   This would
provide for urbanization, possibly in the Glenn Ranch/Whiting Ranch/Rancho de
Los Alisos area.

4.4.2.9  No Project

Unless AWMA built the project without Federal assistance, the no project
alternative would begin to retard development in 3 to 5 years.

4.5  IMPACT OF DEVELOPMENT

4.5.1  Air Quality

The impact on air quality is the secondary impact which has received the most
attention on this and other sewer projects in Southern California.  A discussion
of the impact on air quality should be prefaced by some background information.

Documentation of a harmful relationship existing between air pollution and the
health of the public has been generally unobtainable except during periods of
intense pollution such as occurred in London in 1952 and on several  other
occasions and in Donora, Pa., in 1948.   One reason that little hard data is
available is that air pollution levels have increased gradually  and consequently
the impact on mortality has been impossible to measure adequately.*

Because of the importance of determining the minimal levels of pollution which
may create or aggravate health problems of the public, many studies relating
to specific elements of air pollution are being conducted.
*"Cardiovascular Deaths and Air Pollution in Charleston,  S.C."   Cecil  F.
 Jacobs, M.D., MPH, and Bettye Anne Langdoc, AB,  Health Services Report,
 September 1972.
                                    4-18

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 A study conducted  by  the  Department of  Physiology, McGill University, Montreal
 exposed normal  subjects,  smokers  and  nonsmokers, to 0.37 or 0.75 ppm of ozone
 for  two hours  in an environmental chamber.  Two hours of intermittent exercise
 in such atmosphers of ozone  produced  major changes in the lung function tests.
 The  total  lung  capacity was  not significantly affected, but the residual volume
 increased.  This increase indicates an  early effect in the small airways.*

 Other  studies  indicate that  excess delayed death and/or chronic diseases are
 related to air  pollutants.   In cities where the N0(2) level is high, there
 are  more deaths from  emphysema.  Adverse bronchitis reactions seem to be
 related to S0(4) and  S0(2).  Coronary artery diseases have some relationship
 to oxides of nitrogen and carbon monoxide.

 The  mounting evidence of  the effects of exposure to air pollution led to the
 Clean  Air Act Amendment of 1970, which  established a national program for clean,
 healthful air across  the  United States.  Pursuant  to this law, EPA promulgated
 the  National Ambient  Air  Quality Standards (NAAQS) for those pollutants of major
 national health significance.  Primary  standards were established to protect
 human  health from  long-term exposure, and significant harm levels were estab-
 lished to protect  people  from short-term exposure.

 In order to achieve these  standards, States were required to submit implemen-
 tation plans that  would provide for the attainment of these standards by 1975,
 or by  1977 if specific justification for the longer period was accepted by EPA.
 For  strategic purposes in  developing implementation plans, the law instructed
 states  to divide their territory into Air Quality Control  Regions.   These
 regions  were established  in areas where meterological  and topographic conditions
 made the emissions of  pollutants in any one area of region-wide significance.

 The State of California did not submit a totally approvable State Implementation
 Plan for the Los Angeles  Intrastate Air Quality Control  Region (LAAQCR).
 Because  of this failure, and litigation, the EPA promulgated a Transportation
 Control  Plan (TCP) for the State of California (November 12, 1973)  which
 included a specific strategy for the LAAQCR in order to correct certain defi-
 ciencies in the California State Implementation Plan.
   2"-
 In the Metropolitan Los Angeles Intrastate Air Quality Control Region, the best
 known and most severe air pollution problem is 'smog,1  which consists primarily
of photochemical oxidants.

This pollution problem results from a chemical reaction between reactive hydro-
carbons  (RHC) and nitrogen oxides (NOX), which occurs  in the presence of sun-
 light.    The control strategy for oxidants in the LAAQCR is focused  on reducing
*"Pulmonary Function in Man After Short-Term Exposure to Ozone," Milan
 Hazucha, M.D.,  et al,  Arch Environ Health, Vol.  27, September 1973.
                                    4-19

-------
reactive hydrocarbons, since NOX control alone would not provide sufficient
reductions of oxidants.  This is due to the regenerative role of NOX in the
reaction, as well as production of NOX during normal biological processes.

Under the adverse meteorological conditions which are necessary to produce
high oxidant concentrations, the LAAQCR is virtually a closed basin.  Hydro-
carbon emissions are nearly directly proportional to oxidant concentrations
under these conditions.  Consequently, the air quality control strategy
developed for the area was 'basinwide' in scope.

The technical basis for EPA's basinwide strategy can be found in "The Tech-
nical Support Document for the Metropolitan Los Angeles Air Quality Control
Region Transportation Control Plan Final Promulgation," available for review
in EPA's Los Angeles office.  This document begins with observances of the
nature of the air quality problem, and relates the problem to emissions of
reactive hydrocarbons.  The strategy uses a 'worst case' situation, which is
an effort to eliminate meteorology as a variable by using an oxidant concentra-
tion observed during severely adverse meteorological conditions.  The strategy
then presents an inventory of emissions, including both stationary and mobile
sources.  Based on the 'worst case' determination and its relationship to the
emissions inventory, a determination of the allowable emissions was made.
This, in turn, allowed the determination of the emissions reductions neces-
sary in order to meet the standard, using the proportional technigue referred
to as 'rollback.1  The stationary RHC emissions in the base year (1970) are
estimated to be 255 tons/day, and the mobile RHC emissions are estimated to
be 1346 tons/day.  Allowable emissions have been calculated to be 112 tons/day
of RHC; this is the maximum average emission rate consistent with attainment
of the oxidant standard.   Various stationary source controls and emission
controls upon mobile sources will reduce the emission to an average of
558 tons/day--which still must be reduced by 446 tons/day to assure attainment
of standards.  Given the current and projected status of mobile source emis-
sion control strategy, it appears that the only method available to achieve
the required emission reductions that are necessary involves controlling
vehicle usage, measured in terms of vehicle miles travelled (VMT).

The TCP for the LAAQCR sets forth a strategy to achieve these additional
emission reductions necessary for the attainment of primary air quality
standards by 1977 if all  proposed measures are enforced.   The source type
controls include catalytic converter retrofit on older light duty vehicles,
a mandatory inspection and maintenance program, organic solvent controls  and
vapor recovery systems on fuel  storage and transfer operations.   Exclusive
bus lanes, a carpool program, and a parking management program are included
as transportation-type controls, and are expected to provide a 14-31%
reduction in VMT.  As a final control  step, gasoline rationing is provided
which would provide the final reductions in emissions necessary to attain the
standards.

The preceding discussion  revealed that in the short-term,  air quality standards
in the LAAQCR can only be met by controlling vehicular usage, measured  by VMT.
Thus, the following discussion  will use VMT as the basic parameter to evaluate
the effects of the project.   But in addition to short-term solutions, long-term
                                    4-20

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 solutions are needed.   Long-term solutions will  probably require mass transit
 development and local  land  use  planning  that  recognizes air quality as a
 valid planning constraint.   Such a  planning effort, commonly referred to as
 Air Quality Maintenance Planning (AQMP),  is now  in the conceptual stage. EPA
 has published guidelines for the States  to develop plans to insure the mainte-
 nance of air quality  standards,  and to prevent serious air quality degradation.
 The State of California is  considering institutional mechanisms to implement
 these plans, and it is  likely that  they will  become a reality within the next
 year or so.   We will  give a brief discussion  of  the urban form of the AWMA
 area, and how this form will  affect AQMP.

 4.5.1.1   VMT Increases
                   i
                   i
 The Aliso area is an  automobile  dependent area,  as indicated by Exhibit 4-17,
 and will  in all  likelihood  remain so.  Any increases in population in such an
 area will  also increase VMT.  Preliminary VMT estimates were made for develop-
 ment in  the AWMA area using 3.82  vehicle trips per day per capita and 7.98
 miles per trip as the average.   These estimates  were then verified using
 Orange County Rapid Transit District's raw data  from their upcoming South
 County Study.   These  estimates indicate that  current VMT in the AWMA area is
 about 2,620,000 miles per day.   Using the Orange County modified growth rate,
 a  1985 population of  163,700  will travel 4,990,000 miles per day, an increase
 of 2,370,000 miles per  day.   (Approximately 200,000 additional gallons of
 gasoline  per day will be required by this VMT increase.)  A 1985 E-0 popula-
 tion of  120,400 would travel  3,670,000 miles  per day, an increase of 1,050,000
 miles per  day.

 Even assuming  that all  of these new people are currently residents of the
 LAAQCR, there  will still  be a net increase in VMT.  The South County Study,
 and  other  raw  data developed  by OCTD, indicates  that people in the AWMA area
 travel about  30% further  per week than people elsewhere in the County.   (260
 miles  per  week on the mean, compared to 200 miles per week on the mean for the
 entire County.)  Thus we  can conclude that there will  be a substantial  traffic
 increase that  accompanies growth  in the AWMA area, an increase that would not
 occur  if that  growth occurred elsewhere in the County where automobiles are
 used  less.

 4.5.1.2  Urban  Form

The  secondary  impacts of this growth on urban form can only be discussed in
 general terms  at this time.   Yet our earlier discussion of future growth
 prospects  indicated that the AWMA area would continue to grow in a 'leapfrog'
manner unless  there are changes in governmental  policies.   As shown by the
recent study,  "The Costs of Sprawl," urban sprawl is  fairly costly in
environmental  and energy terms, although it clearly provides social  amenities
which most homeowners desire.  Energy costs for transportation in the AWMA
area are particularly high because the commute distance is greater than the
County average, and because with the exception of the El  Toro area,  the lack
of a well-balanced supply of shopping areas leads to  longer shopping trips.
Unless some mitigation steps are taken,  this trend will  continue, and densities
 in the area does not appear consistent with the long  range changes in urban
form that are needed to attain and maintain air quality standards.
                                    4-21

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  K
      (   ,
 ""•I    I
Legend
 8,000 j   Represents vehicles per 24 hours
                                              Dana Point  J *«-*-,/*_ ^,
Exhibit 4-17
                  i™

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4.5.2  Water

4.5.2.1  Quantity

Development of an area usually involves an increase in impervious surfaces,
which  in turn increases the quantity of runoff.  Studies of urbanized areas
indicate that stormflow can increase by 1.2 to 5 times from urbanization.
No detailed study of the AWMA area has been made to determine the overall
impact of urbanization on storm flow, but it is not felt that the increases
will be significant.  About 82% of the soils in the AWMA area are fairly
impervious, with slow to very slow infiltration rates.  Thus, urbanization
will not substantially increase impervious surfaces.  The County's ambitious
open space plan for the area also indicates that the net increases in storm
flows will not be significant.  If warranted on a smaller scale, individual
developments could be planned to maximize retention of pervious surfaces,
but it is not felt that this is necessary on an area-wide basis.

4.5.2.2  Quality

Urbanization also increases the pollutants such as biological oxygen demand
(BOD), nitrogen and phosphorous which are found in storm runoff.  Streets and
curbs in urbanized areas collect runoff and pollutants like detritus, lead
from auto emissions, and oils and grease.   An estimate of mass emissions
(Comprehensive Water Quality Central  Plan for the San Diego Basin, SWQCB,
1974) from urbanization can be seen in Table 3-1.   Table 4-7 indicates the
pollution generation characteristics  of various land uses.   While natural open
space produces as much Total  Dissolved Solids (TDS) as industrial  and com-
mercial uses --  and more than residential  --  the quantities of Biological
Oxygen Demand (BOD), nitrogen and phosphorous are significantly lower.  Agri-
cultural  uses are roughly comparable  to recreational uses in this respect.
In order to provide a reasonably accurate estimation of the amount of these
pollutants which will result from the existing, adopted,  and projected land
uses, the land uses presented in Section 2.11  and  summarized in Table 2-14
were re-distributed into categories of similar pollution  production.

                                   TABLE 4-7

                    SURFACE RUNOFF POLLUTION  COEFFICIENTS*

            Land Use              TDS      BOD       Total  N      Total  P

    Residential                    400      30         12             2.0
    Commercial,  Including          rnn      /,n         19             -,  n
      Nonwater Service            5UU      ^u         '^             l
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                               TABLE 4-8
                            LAND USE ACREAGE
             Land Use                 Existing    Adopted      Proposed
Residential1                           6,396      21,977       26,439
Commercial, Including Nonwater           77Q2      ,  ,n73       ,  ^.3
   Service                               //y       '>4U/        ljb^
Industrial                               2594      1,6845       1.6845
Public Recreation and Similar Uses       5806      1,4687       2,0008
Dry Farming                           17.1169      3,48210          0
Citrus and Truck Farming               2.44511         0            0
Natural Open Space                    21,330      18,887       17,258
                   TOTAL              48,905      48,905       48,905
 Includes single- and multi-family.
y
 Includes 75 acres of Public (institutions).
Includes 230 acres of PUblic (institutions).
 Includes 145 acres of Public (sewerage facilities).
 Includes 165 acres of Public (sewerage facilities).
 Includes 3 golf courses (380 acres)  and 2.5 acres of Parks/1000  p-p.,
 population based upon 2.5 occupants/du and 5 du/acre.
 Includes 3 additional golf courses  (400 acres)  and Parks  calculated  as
 above.
Q
 Includes another 3 golf courses  (300 acres)  and Parks  calculated as
 above.
Q
 Based upon 35% of total  AWMA acreage which contains  Class  III  and  IV soils.
 Based upon 40% of the IRWD area  being in  this use.
 Based upon 5% of the total  AWMA  area which contains  Class  I and  II soils
 and which has not been urbanized.

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                             TABLE  4-9
        SURFACE RUNOFF POLUTION FROM ADOPTED LAND USES*
Land Use
Residential
Commercial,
Include Non-
Water Service
Industrial
Public Recreation
and Similar Uses
Dry Farming
Citrus and Truck Farming
Natural Open Space
*in tons per year

TDS
1,279.2
194.8
71.23
72.5
2,139.5
305.62
5,865.75

TABLE 4-10
SURFACE RUNOFF POLLUTION FROM ADOPTED
land Use
Residential
Commercial ,
Include Non-
Water Service
Industrial
Public 'Recreation
and Similar Uses
Dry Farming
TDS
4,395.4
351 .75
•463.1
183.5
435.25
BOD
95.94
15.58
3.89
5.22
171.16
36.68
63.99


LAND USES
BOD
329.66
28.14
25.26
13.21
34.82
Total N
38.38
4.67
1.55
4.35
85.58
36.68
21.33


*
Total N
131.86
8.44
10.10
11.01
17.41
Total P
6.4
0.39
0.16
0.15
6.85
1.83
3.2



Total P
2,1.98
0.70
1 ,01
0.37
1.39
Citrus and Truck Farming          -            -
Natural Open Space              5,193.93      56.66      18.89      2.83
*in tons per year

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                               • TABLE 4-11
              SURFACE  RUNOFF  POLLUTION FROM PROPOSED LAND USES*


          Land Use                     TDS         BOD     Total N     Total P

      Residential                     5,287.8      396.59      158.63     26.48

      Commercial
        Including Non
        Water  Service                   381         30.48        9.14      0.76

      Industrial                        463.1       25.26      10.10      1.01

      Public Recreation
        and Similar Uses                250         18         15         0.5

      Dry Farming                       -            -

      Citrus and Truck Farming          -            -

      Natural  Open Space              4,745.95      51.77      17.26      2.59

     *in tons per year
Table 4-12 provides a summary of the amount of runoff pollutants which have
been projected for the AWMA region.   The total increase from existing land uses
to proposed land uses is 13%.  This  figure is largely a reflection of the
quantity of TDS in the runoff and does not indicate the significant increases
in phosphorous and BOD which will accompany urbanization.   Phosphorous in run-
off will increase approximately 49%  with the implementation of adopted land use
plans and another 11% if proposed plans are approved.   The total increase from
existing to proposed land uses is 64%.  Similarly,  BOD will increase the most
by 24% with the realization of adopted land uses.   An increase in BOD 33% is
projected with development of all adopted and proposed land uses (Exhibits
4-11 and 4-12).
                                 TABLE 4-12

                   SUMMARY OF SURFACE RUNOFF POLLUTION*
Land Use
Existing
Adopted
Proposed
TDS
9,928.6
10,587.7
11,127.9
BOD
392.5
487.8
522.1
Total N
192.5
197.64
210.1
Total P
19
22.3
31.3
Grand
Total
10,532.6
11,282.6
11,891.4
     *in tons per year

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 It  does  appear  somewhat  incongruous  that  the coefficients for total dissolved
 solids are  higher  for  open  space  than  for agriculture,  since agriculture is
 responsible for many of  the salinity problems  in southern California.   It  is
 assumed  that the different  coefficients obtained are related to the relative
 permeability of soil and resulting velocity at which water runs off.  Most of
 the salts added by agriculture are leached into the groundwater or drain off
 underground and consequently are  not reflected in runoff coefficients.
 Further, there  is  considerable variation  in the data, particularly for IDS
 and the  figures shown  are clearly estimates, subject to refinement when better
 information is  available.

 4.5.3  Land

 Development in  the AWMA  area will devote  40-50% of the remaining open space to
 urbanized land.  This  represents  a commitment of a land resource, as well as
 a long-term reduction  in wildlife habitat.  Review of recent County planning
 efforts  indicates  that the  more valuable  wildlife areas will receive priority
 consideration for  open space, but a  net loss of habitat is anticipated and
 cannot be avoided.

 Presently,  undeveloped lands within  AWMA  are almost entirely privately owned.
 As  lands become developed,  public ownership of property will increase through
 road and park dedications increasing access and recreational areas available
 to  the public.  This may be viewed as a public benefit resulting from develop-
 ment.  However, the beneficial aesthetic  and psychological  effects of open
 space are also  important.  The balance between these two divergent open space
 functions is not quantifiable and the significance attached to these functions
 is  based upon value judgments.  There will be a loss in wildlife habitat.

 AWMA is responding to a  situation which has been created by local  governments.
 There are the agencies with control   over  land uses and which have authorized
 urban uses  for much of AWMA.  It  is  the realization of such policies which
 will reduce open space and alter  the environment.   The major portion of AWMA
 for which no urban uses  have been designated belongs to The Irvine Company.
 The future of this large coastal  area will be the subject of the Second
Amendment,  1975, to the Orange County General  Plan Land Use Element as well
 as the Coastal Commission's Development Plan.   At that time, it will  be
determined  if urbanization will  take place and, if it does,  where and in what
 form.  It will be at that time that the value judgments will  be made about
 the remaining open space.  In the past, the rate of growth  has been much
 slower along the coast than it has been in the rest of Orange County.   This
 is due to inflated land values and limited access  along the Pacific Coast
 Highway.

4.6  POTENTIAL MITIGATION MEASURES

Since the secondary impact on air quality is  the most significant  impact,  most
of the following measures will  be aimed at mitigating this  impact.   Measures
evaluated by the applicant will  be presented  as well  as those evalued  by the
EPA.  The question of mitigation,  and especially the eventual  implementation
of any proposed measures  is more  a question of policy than  technical  analysis.
Therefore,  the following  discussion  will  be in fairly general  terms.
                                     4-23

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4.6.1  Summary of Mitigation Measures Evaluated by the Applicant

1.  High density cluster residential development with neighborhood shopping
    centers rather than low density development with regional shopping centers.
    This option could reduce VMT in three ways:  (a)  shorter trips, (b) in-
    creased utilization of transit, and (c) shopping by bicycle or walking.
    It is estimated that this could reduce VMT by 311,000 miles per day.  This
    option could not be implemented by the applicant, but would take action by
    local general purpose governments.

2.  Encourage Commuter car pooling.  Some carpooling is now done in the AWMA
    area (about 5% travel in carpools).  It is estimated that commuter car
    pooling could provide for 25% of all commute trips, resulting in a VMT
    reduction of 394,000 miles per day.

3.  Encourage use of buses.  The Orange County Transit District feels that as
    many as 7% of the trips in the AWMA area could be diverted to buses.  It
    is estimated that this would result in a VMT reduction of 201,000 trips
    per day.  This would have to be done by the general purpose governments
    and the OCTD, and will probably be done as a part of EPA's Transportation
    Control Plan.

4.  Construct a new town around the GSA facility.   If a town, oriented towards
    serving the GSA facility and towards reducing automobile traffic were
    constructed, the applicant estimates that it could reduce VMT by 574,000
    miles per day or more.  This would require a coordinated effort by land-
    owners, local and Federal governments, as well  as a change in the attitude
    of the local population which is opposed to low or medium cost housing.

5.  Park and ride for beach users.   The applicant estimates that this would
    result in a VMT reduction of 32,000 miles per day during the summer.
    This would have to be implemented by general purpose governments or a
    transit district.

6.  Park and ride for the Laguna Beach Art Festival.   A limited version of this
    option is now operated by the City of Laguna Beach.  The applicant esti-
    mates that this would result in a VMT reduction of 9,400 miles per day
    during the Festival.

4.6.2  Additional Measures

EPA's Transportation Control  Plan contained several  measures aimed at reducing
traffic (VMT).  Parking supply management, either  directly,  or through sur-
charges on parking is one of these  methods.  (EPA  does not require parking
surcharges, but it is an option available to local  governments in the AWMA area.)
Parking management is required to relate parking supply to areawide VMT.   Com-
puter carppoling, and mass transit  encouragements,  discussed above, are also
part of the TCP.

One of the transportation controls  which will  be implemented as part of the
TCP, carpooling appears to have the most effectiveness in  the AWMA area.
However, this option was  listed low in the South County Study's poll  of mode
                                     4-24

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 preference  and  has  been abandoned  by most of those who have tried it.  Other
 than  the  applicant's  estimates of  the possible VMT reductions from car pool-
 ing,  no attempt was made  to quantify VMT reductions, although these measures
 are estimated to  achieve  a VMT reduction of 14-31% basin-wide.

 Since utilities do  play an important role in development, controlling utility
 extension is presented here as an  additional option for consideration. Control
 of water  and sewer  extensions could be accomplished by the member agencies of
 AWMA,  so  institutional problems are minimal.  This could be very important
 in controlling  growth in  areas without critical utilities, but relatively
 ineffective in  areas which now have utilities.  One method of controlling
 'sprawl'  within areas that have utilities could be to institute a density re-
 quirement prior to  extension of service, even if that extension does not require
 a major new trunk sewer.

 Control of  arterial highway construction is another method of utility extension
 control,  but cannot be done by the applicant.  To implement this strategy, the
 local  general purpose government--the County—would have to agree to this option.
 This  would  be very effective in Northern El Toro, Bear Brand Ranch, Ivine Ranch
 and western Moulton Ranch, but ineffective elsewhere.

 A related benefit of any  form of utility extension control would be to increase
 density in  already developed areas.  This in turn would increase the potential
 for mass  transit, car pooling, and other measures which need density to work
 well.

 The development of work centers within and near AWMA represent both an
 opportunity and a potential threat to the environment in and near AWMA.   The
 Irvine Industrial Center and the full utilization of the GSA facility could
 provide jobs for  AWMA residents and reduce the overall  travelling distances
 for commuters.   If carefully structured, the AWMA communities and the new
 centers could be  easily linked by buses or shuttle buses, further reducing
 VMT.   However,   this would require innovative local  planning to insure that a
 substantial  number of future employees of these facilities reside within AWMA,
 and in a  form conducive to reduced commute travel  by automobile.   At present
 there is  no indication that this will  be done, and there is massive resistance
within the AWMA communities to housing policies which would make this possible.
 This remains an option for local  government, possibly through the Air Quality
Maintenance Planning effort,  but prospects at this time are not good.

The above options for mitigating the air quality impacts of development  with-
 in AWMA are presented in general  terms in order to solicit public comment on
 the measures.   We are extremely interested in public opinion on the accept-
ability or desirability of these measures.

4.6.3  Economic Impact of Potential Mitigation Measures

The Orange County Transit District is conducting a  number of studies and pro-
grams aimed at  meeting the needs  and demands for public transportation.   The
major studies are:  (1)  Alternate Rapid  Transit Corridor Study concentrating
on regional  needs; (2) Special  Bus Needs Study to  determine immediate and
short-term transit needs;  (3)  Park and Ride Freeway Bus System Study has been
                                     4-25

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completed and operations will commence in June, 1975; (4) Dial-a-Ride
Expansion Study; (5) market studies to monitor the transit needs and attitudes
of Orange County residents.  Buses cost about $64,000 each to acquire and
about $70,000 annually to operate and maintain.

Park and Ride systems, while they can make a substantial contribution to
mitigating air quality impacts and conserving energy, have substantial  capital
operating and maintenance costs.  Acquisition of large parking areas is required
if facilities do not exist or cannot be utilized.   A rule of thumb is one acre
of land for each 110 cars.  This provides sufficient space for shelters, bus
loading and bus layover areas, as well as car parking areas.   After the
parking sites are obtained, bus-related costs include purchase of buses, fuel,
oil, driver wages, insurance and taxes besides other maintenance costs.   The
Orange County Transit District projects a County-wide need of 163 buses by
1980 which would result in vehicle costs of over $6 million.   Only a portion
of this total, on the order of 10%, could be attributed to serving the  needs
of the AWMA region.  Annual operating costs are forecast by the OCTD to be
$1.10 per vehicle mile by the end of this year with a 10% annual escalation
thereafter if the inflationary trend continues.  This implies a rate of $1.77
per vehicle mile in 1980.   For the entire County,  OCTD forecasts a $10  million
operating cost in 1980.  Therefore, under the previous assumption, AWMA would
account for about $1 million of this total.  Under the present fare concepts
(average fare of $.75 in 1980), the fare box revenues would pay only about 22%
of the annual operating costs.

A significant opportunity to reduce the costs and  some of the impacts of
urbanization is in changing the pattern of residential development from sprawl
type configurations to cluster type designs.   Two  obvious sources of air pol-
lution in the residential  sector are residential  heating and  automobiles.   High
density cluster developments require less energy for heating, and, if well
planned, stimulate more efficient automobile use.   Compared with low density
sprawl communities, cluster developments generate  about 45% less air pollution.
In terms of total  investment costs, clusters cost  44% less than the typical
low density sprawl  pattern of development.   The largest portion of these
savings is attributable to reduced costs for roads and utilities, which  cost
about 55% less in high density communities.  Also, lower total  costs are
likely to be incurred by local governments  due to  economics of scale.

Furthermore, a low-density sprawl is the most expensive community to create
and operate.  Total capital costs (exclusive of land and financing charges)
average approximately 80% higher than hioh  density housing ($58,502 per
housing unit compared to $27,025).  Approximately  74% of the  difference, or
$16,000, are construction costs, with another $4,000 for utilities and  $1,500
for roads.  Construction costs are extremely important, because they account
for approximately 64% of the total capital  costs in each community, and these
costs vary as much as 100% among communities   (The Real  Estate Corporation,
Costs of Sprawl).

School costs are generally the second largest cost component  in a neighbor-
hood, but these do not vary appreciably among communities.  Utility costs  are
next in magnitude and generally show the greatest   variation  between community
types.  For high-density cluster designs, the utility costs are about 8% of
the total compared with 13% for low-density sprawl designs.   Transportation
                                      4-26

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 costs are next in scale,  but road  costs are less sensitive than utility costs
 to variations  in  development patterns.  Open  space and public facilities
 costs are a  small  component of  total costs (4-7%) and, in any case, vary only
 moderately among  community types.   Long-term  operating and maintenance costs
 are approximately 12.7% higher  for sprawl type communities than for cluster
 •designs    (The Real  Estate Corporation, Costs of Sprawl).

 'As stated at the  outset,  the goal  of the mitigation strategies is the improved
 air quality.   It  is  apparent that  mobile emission controls, even catalytic
 converters,  will  not reduce total  emissions sufficiently to satisfy the ul-
 timate standards  of  the Clean Air  Act, particularly if motor vehicle usage
 continues the  rate of growth experienced during the past ten years.  The
 goal  then must be accomplishd primarily through VMT reduction plans.

 To reduce VMT  on  an  emergency basis, rationing is probably the most effec-
 tive  technique, but  may be politically unacceptable.  The measure most widely
 discussed at present is the gasoline tax increase.  In opposition to this
 measure,  it  is  frequently argued that it would be too regressive, imposing
 the greatest hardship  on the poor  and those who need the automobile as a
 means  of  transportation to and  from work through higher costs for gas.

 An additional  driving  disincentive would be a tax, or an increase, in parking
 rates.  This type  of measure was actually included in the EPA Implementation
 plan  for  Los Angeles.  The reductions in VMT which would accompany parking
 rate  increases  have  been studied in San Francisco.  During the 1970-71 fis-
 cal year,  a 25% tax  was imposed on all  parking operations in downtown San
 Francisco.  Although many parking  lot operators, trying to gain a competitive
 edge,  did  not  pass on  the tax increase to their customers, and although many
 drivers shifted their  parking patterns, parking further from their destinations
 and walking to  save  the parking rate increase, analysis of the data after two
years  of operation still indicated a strong decline in parking utilization
with  increase  in price.  The price elasticity of demand for parking space
 varied between  -.5 and -1.5.*

 This  relatively large elasticity suggests a draconian measure to reduce
available  parking  space altogether.  A parking strike in Pittsburgh in 1972
closed about 90% of  the downtown parking facilities.   However, the absentee
 rate of those employed downtown remained essentially constant.  This indi-
cates an  increased usage of alternate modes such as public transit and car-
pooling.   During this time,  theatres experienced a 60-70% decline in patronage
which suggests that people are willing to use alternate modes for work com-
muting, if necessary, but not for recreational purposes.

Carpools represent a promising technique for VMT reduction.   They require
virtually no capital  expenditure,  and they provide more convenience than
scheduled bus service.  Since the  energy crisis  of 1973-74,  some governmental
agencies have explored this  alternative,  and some computerized data bases
have been established to locate partners  with similar origins and destina-
tions.  Some employers in  downtown areas  have provided subsidized parking as
an incentive for carpools.   Reserved lanes  on freeways for carpools have been
discussed, but to  date they  have been implemented only on an  emergency basis.
These costs are highly variable and not absolutely necessary,  but should be
more than offset by the savings  in energy,  parking,  and the  maintenance of
individual cars.
*Note:  A -1 elasticity means that as price increases (say 20%), use decreases
        in exactly the same porpdrtion (20%); a -1.5 means if price is up 20%,
        use is down 30%.              4.37

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4.7  OPTIONS AVAILABLE TO EPA

4.7.1  Fund the Project as Proposed by the Applicant

In this option we would assign higher priority to the water quality problem
and limit our actions on secondary impacts to the economic disincentive of
the SWRCB's funding limitation.  The outcome of this alternative would be
an improvement in surface and ocean waters, and an increase in VMT.

4.7.2  Fund the Project as Proposed by the Applicant if the Applicant
       Agrees to Implement Mitigation Measures Within their Legal  Authority

The probable mitigation measures within the applicant's legal  authority are
nonextension of water and sewer services to new areas until an AQMP indicates
that this would be consistent with the strategy to achieve air quality stan-
dards.  This alternative would solve water quality problems, and would limit
to some extent the increases in VMT.  It would also encourage higher density
in existing urban areas.

4.7.3  Construct a Regional  System. Treat the Upper Aliso Area's Wastes
       Locally, Require Mitigation

This option is oriented towards eliminating the interceptor down Aliso Creek
which facilitates development.  The upper areas of AWMA could be served by
either increasing their storage capacity, or by constructing a treated
water line to the new ocean  outfall.  The Regional  Boards would object to
this option unless the treatment plants had access to an ocean outfall.
Both of these alternatives would increase costs by $5-10 million.   They
would have the benefits of eliminating the need for a new site and a new,
possibly growth inducing road.  They would also be superior alternatives for
achieving reclamation in the future, sincenohead would be lost in draining
effluent down into Aliso Valley.

4.7.4  Don't Participate in  the Project Since it will  Facilitate Growth Which
       Will  in Turn Have a Significant Air Quality Impact

If there is no EPA participation, it likely that applicants will  construct a
regional  system with their own money, probably without the City of Laguna Beach
if all necessary permits can be obtained.  The system that will  probably be
somewhat smaller and the increased costs may deter development slightly.   But
the water quality problems from Laguna Beach's discharge would not be solved,
and there would not be any mitigation of the air quality impact.   In this
option, air quality and water quality impacts would be maximized;  therefore
this course of action is not recommended unless the applicants refuse to im-
plement mitigation measures, the Coastal Commission may revoke their permit.

4.7.5  Construct a Regional  System with a Smaller Outfall
      (or other portions)

This option would be aimed at using sizing as a growth constraint,  and in
effect this has been done by the Coastal Commission.   However,  this option
                                     4-28

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would have no effect on growth until the facilities are near capacity, and
even then the applicants could construct small  land disposal systems on
their own.  This option is more of a policy statement about who should pay
for growth than an option which would mitigate the effects of growth.  It
could have the beneficial effect of forcing reclamation once facilities
•are near capacity.
                                    4-29

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5.0   SELECTED ALTERNATIVE


5.1   PROPOSALS IN THE DRAFT EIS

The draft EIS for the AWMA project deferred selection of a proposed project
and proposed two alternatives for further consideration; Modified Alter-
native 1A which embraced a satellite treatment concept with regional dis-
posal, and Alternative 2G (also referred to as Alternative 2F modified)
which featured regional treatment and disposal.

Modified Alternative 1A proposed to continue operation of the upstream
treatment plants at Los Alisos and Rossmoor, disposing of their effluent
through a treated line.  Flows from Moulton-Niguel would be treated at the
existing South Laguna Treatment plant until the flows justified construct-
ing a new treatment plant.  Laguna Beach's treatment plant would be abandoned
and a new treatment plant would be constructed on the site of the South
Laguna treatment plant.  Excess effluent would be disposed of in a new
ocean outfall.

Alternative 2G would involve abandoning upstream treatment plants except
for minor reclamation during summer months, construction of a raw sewage
interceptor along Aliso Creek, a new regional treatment plant on a site
in Aliso Canyon, and ocean disposal through a new outfall.  Laguna Beach's
treatment plant would be abandoned and Laguna's waste would be transported
to the new regional  plant by interceptor as in Alternative 1A.

The draft EIS also listed a number of mitigation proposals without specific-
ally proposing or committing to any of them.  The purpose of deferring
alternative selection and mitigation proposal selection was to allow the
public and interested local, state and federal  agencies to affect the
decision making by providing new information and analysis of the public
acceptability and policy implications of the alternatives.

5.2   PUBLIC REVIEW AND THE SELECTION PROCESS

5.2.1   Alternative Selection and Plant Site Location

The review process indicated that there were serious problems with the
treatment plant site under Alternative 2G.   In  addition, the review pro-
cess indicated that there was strong support for reclamation, and that
even if total reclamation was not possible, the alternative most consistent
with future reclamation should be given serious consideration.

Comments at the public hearing held by EPA on the AWMA project indicated
very strong opposition to the regional  treatment plant site because of
aesthetic disruption of a valuable open space and recreational corridor.
Because of public concern over dwindling open space, the County of Orange
has designated the Aliso Creek corridor a high  priority area  for retention
as natural  and recreational  open space.  AWMA was willing to  donate ease-
ments through the plant site for equestrian, bicycle and hiking trails,
as well  as  landscape the plant site to provide  continuity with the creek
                                     5-1

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 atmosphere.   However,  the  public  and  the  County Planning Commission were
 still  concerned  about  the  aesthetic disruption of the area by a 30 acre
 treatment  plant  and  channelized stream  bed  in a narrow part of All so
 Creek  Canyon.

 Comments by  the  public and co-ordination  with the Department of Interior,.
 the  National  Historic  Advisory Council  and  the State Historic Preservation
 Officer revealed that  there were  valuable archaeological resources in the
 Aliso  Creek  area,  potentially qualifying  the area for inclusion in the
 National Register  of Historic Places.   Further analysis revealed that the
 Aliso  Creek  interceptor could probably  avoid all archaeological sites, but
 the  treatment  plant  for Alternative 2G  would directly affect one of the'
 archaeological sites.   The public, local  archaeologists, and the State
 Historic Preservation  Officer's staff all expressed concern over this
 potential  impact and stressed the need  for  analysis of additional treatment
 plant  sites.

 Review of  the  EIS  also revealed that  the  regional treatment plant site would
 involve encroachment into  the flood plain of Aliso Creek.  Extensive
 grading of the plant site  area and realignment and channelization of
 Aliso  Creek  would  be necessary to utilize the site.  Even with these
 modifications, the plant site would be  exposed to some flood hazard.
 Executive  Order  11296  requires federal  leadership in avoiding the develop-
 ment of flood  plains.   Consequently,  additional analysis of plant sites
 not  in the flood plain area would be  necessary prior to approval of the
 regional plant site.

 Because of these three problems,  EPA  informed the Aliso Water Management
 Agency on  May 6, 1975  that the plant  site for Alternative 2G was unaccept-
 able.  This  action virtually eliminated Alternative 2G from further consid-
 eration.

 5.2.2   Mitigation Measures

 There  were fewer comments  dealing with  the  various mitigation measures
 than with  the plant  site.  Agencies responsible for air quality uniformly
 supported  the concept  of mitigation,  but not necessarily specific measures.
 Most commenters  realized the institutional  problems involved in encouraging
AWMA ~ which does not  have general  purpose governmental  authority -- to
 provide for mitigation.  Most of  the measures discussed were clearly      •
 beyond the legal  authority of AWMA.   According to AWMA's counsel, even the'
 nonrextension of interceptors « which  had  initially appeared to be within
AWMA's legal  authority  — would be difficult or impossible to accomplish.

The County of Orange is the general  purpose government with authority over
 land use and transportation decisions within most of the AWMA area.   The
County appeared  to be  somewhat interested in the concept of mitigation.
and meetings were begun with the County and landowners by AWMA.   To date,
however,, these meetings have not resulted in any firm commitments for any
sJiort- or  long-term vehicle use reduction measures.
                                     5-2

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5.3   PROPOSED PROJECT

5.3.1   Introduction

Through the review process EPA discovered that there were plant site
problems with Alternative 2G and effectiveness problems with Alternative
1A (refer to comment letters by AWMA and the Moulton-Niguel Water District).
As a result, neither of the two favored alternatives was completely accept-
able.

The rejection of Alternatives 1A and 2G left the project with a need for
more engineering and cost-effectiveness analysis.  EPA determined that
trying to accomplish this analysis within the framework of an EIS was not
desireable.

Selection of appropriate mitigation measures resulted in a very time con-
suming process which did not fit easily within the time constraints of
an EIS.  Further, the effectiveness of all  of the mitigation measures
depends in large part on the degree of support the measures have with local
regulatory agencies which will be responsible for their implementation.
In other words, the procedure for implementation of mitigation measures
could be counterproductive to the goal of reducing automobile reliance.

Nevertheless, it was clear that an initial  project which combined the
acceptable portions common to both Alternatives 1A and 2G could and should
be built.  A phased project along this line was suggested by AWMA and
is proposed here.

5.3.2   Phase I
With consideration given to the urgency of the existing problem at Laguna
Beach and the time constraints involved in outfall  construction, EPA
supports a Phase I AWMA project which will provide for a regional  ocean
outfall, and an expansion at the South Laguna treatment plant to allow
abandoning the Laguna Beach treatment plant; solving the two immediate
problems.  Phase I consists of:

     1.   The Aliso Creek Outfall, Ocean Portion; from the Pacific Coast
          Highway extending approximately 7,500 feet offshore.

     2.   The Aliso Creek Outfall-Onshore Portion extending from the Pacific
          Coast Highway to the existing South Laguna Treatment Plant.

     3.   The North Coast Interceptor would be constructed to serve the
          City of Laguna Beach and Emerald Bay Service District.   An exist-
          ing 8-inch diameter gravity main would be utilized to transport
          wastewater from the Emerald Bay pump station to the Laguna Beach
          pump station.  From the Laguna Beach pump station to the Coastal
          Treatment Plant, capacity would be provided for future use by the
          Irvine Ranch Water District.
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      4.    A Coastal  Treatment  Plant  constructed  adjacent  to  the  existing
           South Laguna  Treatment  Plant.   Designed  for  an  initial  liquid
           capacity of 4.2  mgd  and an ultimate  capacity of 7.6 mgd.

      5.    Modifications to the Existing  South  Laguna Treatment plant which
           will  increase the flexibility  and  effectiveness of the treat-
           ment  plant but will  not increase the capacity of the treatment
           plant.

 Other than the  phasing  of  the  project and the  initiation  of  planning efforts
 aimed at  producing mitigation,  no mitigation measures  are included as part
 of  Phase  I.   Phase I involved  no  actual  increases  in treatment capacity
 at  the SLSD Plant  (which also  serves MNWD 1A and 2A, see  Section  1.2.2).
 Phase I also only  gives a  minor capacity increase  to the  City of  Laguna
 Beach.  This capacity will  also serve the Emerald  Bay  Service District.
 Mitigation measures  would  be required prior  to use of  the outfall by any
 other of  the AWMA  member agencies as a condition on the grant offer.


 5.3.3  Phase II
 Phase  II of  the project will consist of sludge facilities for the expanded
 South  Laguna treatment plant.  Determination of appropriate facilities will
 be made as part of the facilities plan addendum, but construction of
 sludge facilities can proceed prior to final resolution of the mitigation
 measures.

 5.3.4   Phase III
Since the treatment concept and treatment plant site(s) for the upper
Aliso Creek area are unresolved at this time, Phase III will consist of the
necessary facilities  planning studies and construction of facilities
for the upper Aliso Creek area, as well as implementation of mitigation
measures necessary to minimize the impacts of urbanization in the upper
Aliso Creek area.

A facilities plan addendum will be prepared for the upper Aliso Creek area,
co-ordinated through the State Water Resources Control Board to determine
the most cost-effective solution for the area.  A supplemental EIR dealing
wi.th environmental impacts will be part of this addendum, and the project
will be subject to environmental review by EPA under the National Environ-
mental Policy Act.  If this environmental review indicates that there are
significant, unmitigated impacts, the Phase III project will involve an
addendum to this EIS.

The facilities plan addendum will also deal  with the eventual method of
sludge disposal for the entire AWMA area, including the existing South
Laguna Treatment plant's sludge.  Final determination of sludge disposal
is not possible at this time due to unresolved siting issues.  The analysis
of sludge treatment and disposal will necessarily involve consideration of
energy recovery and composting, as suggested in comments on the draft EIS.
                                    5-4

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Mitigation measures will be required in order to obtain EPA grant funds for
the Phase III project.  Prior to approval of the Phase III project, commit-
ments to implement mitigation measures must be obtained from those entities
with authority to implement such measures.  At the time of any grant offer
on Phase III, limitations on use of the ocean outfall established under the
Phase I grant contract can be modified as appropriate.

5.4   UNRESOLVED ISSUES AND PROCEDURES FOR RESOLUTION

5.4.1   Treatment Concept

It has not yet been decided whether to serve the upper Aliso Creek area
through a satellite concept using existing treatment plants with disposal
through a treated effluent line, or through a system involving a treatment
plant serving the entire upper Aliso Creek area.  It is proposed to use the
facilities planning addendum process, including an EIR supplement, to resolve
this issue.  As noted in Chapter IV, if a semi-regional concept is adopted
involving new raw sewage interceptors, such a concept would have greater
secondary impacts than would a concept involving treated effluent interceptors.
Accordingly, additional mitigation measures would be expected with such a
concept.  The variation in secondary impacts according to concept should
affect decision making in the facilities plan supplement.

5.4.2   Treatment Plant Site

Rejection of the regional plant site has left the location of any alternative
sites an unresolved issue.   Again, it is anticipated that the facilities
plan addendum proposed would provide the mechanism for resolving this issue.
The Aliso Water Management Agency will be expected to use a careful  site
screening process to avoid selecting a site with serious environmental
problems.

5.4'.3   Mitigation Measures

AWMA and most of its member agencies have passed a resolution encouraging
those with implementation authority to undertake mitigation measures
(See Appendix B).  AWMA also intends to take a more active role in planning
to insure mitigation and careful co-ordination between water quality and
air quality decisions.  In addition, AWMA has begun to meet with the County
of Orange and landowners within the district to try to insure eventual
adoption of mitigation measures.  Such activities are not in themselves
adequate mitigation, but do appear to establish a program which will  event-
ually arrive at mitigation.

It is anticipated that the facilities plan addendum,  and EIR,  and continuing
meetings by AWMA with the County and landowners within AWMA will  be  the
mechanism by which mitigation measures will  eventually be implemented.
In the interim, use of the outfall  will  be restricted by grant condition to
the existing South Laguna treatment plant and its Phase I  expansion  until
satisfactory mitigation measures are implemented or scheduled.
                                    5-5

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 5.4.4    Sludge Treatment and Disposal

 Elimination of the regional treatment plant site has left the ultimate
 nature of sludge disposal as an unresolved issue.  The South Laguna treat-
 ment plant site is a fairly poor site for sludge treatment and;drying be-
 cause of the  recreational corridor and the restricted road through' the
 golf course.  However, an alternate site cannot be selected without further
 study.

 It is anticipated that the Facilities Plan Addendum prepared for the upper
 Aliso Creek area will resolve the issue of sludge treatment and disposal
 method as well as the proper site for treatment and disposal.  Consider-
 ation will be given to energy recovery and composting for agricultural
 reuse, as suggested in comments received on the EIS.

 5.4.5    California Coastal Zone Conservation Commission Permit

 AWMA has received a construction permit from the Coastal Commission,
 however, AWMA is dissatisfied with some of the conditions attached to the
 permit.  The permit included limitations on discharge of ammonia and on
 the overall size of the outfall.  AWMA intends to seek modification of the
 permit on both grounds.

 AWMA has already been scheduled for hearing on amendment of the ammonia
 requirement.   Meeting of the 2 mg/1 ammonia requirement requires additional
 air.   Air is provided by electric blowers, and thus the ammonia requirement
 involves additional  capital  costs and energy consumption.  AWMA questions
whether the benefits to the environment of a lower ammonia discharge
 outweigh the environmental costs of increased power consumption.  This issue
will  be resolved before the State Coastal  Commission in a hearing process.

As discussed in Chapter 4, AWMA is also dissatisfied with the capacity
 limitations in the ocean outfall.   AWMA has not yet scheduled a  hearing
date before the Commission.   This issue will  either be resolved  through a
 hearing before the Coastal Commission, or  by AWMA accepting the  existing
permit and beginning construction on the ocean outfall.   The time schedule
for this decision is discussed in Chapter  4.
                                     5-6

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6.0  UNAVOIDABLE ADVERSE IMPACTS OF THE PROPOSED PROJECT

The beneficial and adverse impacts of the proposed project are both short-
and long-term in duration and effect.  The long-term adverse impacts are
mostly indirect.  Primary impacts of the proposed project result from con-
struction and operation of the facilities.  The primary unavoidable impact
of the proposed project is the commitment of land to the placement of facil-
ities.  Of primary significance will be the need for approximately 12 acres
on which to locate the regional treatment plant.  These primary impacts are
described in greater detail  in Chapter 3.

The construction activities will cause short-term unavoidable impacts by
creating noise, air and dust pollution from mechanical  construction equip-
ment, obstructing traffic, disrupting the marine environment, disturbance
of archaeological  sites, changing the landscape, interfering with business
and recreational activities, and posing safety, fire, flood and erosion hazards.

The operational processes of the proposed project will  result in long-term
unavoidable impacts which for the most part, are beneficial  since they will
improve upon existing conditions or prevent future adverse impacts which could
result from the continued utilization of the existing methods of wastewater
treatment.

Operational  impacts include  an increased utilization of water through the
direct use of the water supply, an increased consumption of energy, ground-
water recharge by treated effluent, the dilution and dispersion of wastewater
effluent entering the marine environment, and the production of waste sludges.

Aside from those unavoidable impacts associated with the proposed project as
a whole, there are those unavoidable impacts which can  be defined in somewhat
more specific terms as they  apply to the major components of the system.
The following impacts are unavoidable,  but temporary and will  be mitigated by
time or be reduced to a very low level  of significance.

Aliso Creek Interceptor:

    -Temporary destruction of surface vegetation in 10.9 acres of grassland,
     5.7 acres of agricultural and 0.05 acres of riparian and cover types.

Aliso Creek Outfall:

    -Temporary destruction of approximately 2 acres of  grassland type  surface
     vegetation.
    -Interruption  of country club activities.
    -Scenic degradation.
    -Risks of flooding, erosion and siltation.
    -Reduction of beach recreation capacity.
    -Temporary destruction of approximately 1  acre of marine habitat and
     its organisms.
                                   6-1

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Sulphur Creek Interceptor:

    -Temporary destruction of grasslands.
    -Interruption of traffic.
    -Appearance and noise of pumps.

North Coast Interceptor:

    -Interference with traffic and roadside businesses.
    -Scenic degradation.

Regional  Treatment Plant:

    -Destruction of vegetation.
    -Soil compaction and  dust from construction of roads,
    -Flood and erosion hazards.
    -Fire hazard.
                                   6-2

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7.0  RELATIONSHIP BETWEEN LOCAL SHORT-TERM USES OF THE ENVIRONMENT AND
     MAINTENANCE AND ENHANCEMENT OF LONG-TERM PRODUCTIVITY

7.1  INTRODUCTION

The proposed wastewater treatment project has been designed with long-term
productivity in mind.  Consequently, several adverse impacts which are un-
avoidable, yet temporary in duration, emanate from the construction and opera-
tion of the project facilities.  These impacts produce secondary and indirect
effects which are long-term.  In a sense, the impacts resulting from the con-
struction and operation of the proposed project are trade-offs for the long-
term productivity of the AWMA area.  These long-term indirect effects can be
categorized according to their source - construction and operation processes.

7.1.1  Construction

The project will accommodate and encourage land use changes in the agricultural
open space areas of the region.  There will  be a reduction of open space due to
direct and indirect project impacts.  The regional treatment plant will occupy
approximately 12 acres of land.  The change of agricultural land to residential
or industrial use will cause a major reduction in open space.  Wildlife will
decrease in numbers and some species requiring large areas of continuous open
space will disappear.

The short-term impact due to the construction of the project's facilities will
improve the quality of wastewater effluent,  thereby maintaining the highest
possible quality of groundwater and marine water.

Coliform concentrations which have previously violated the acceptable stan-
dards of the Orange County Health Department will  be corrected through the
construction of the new outfall facility.

The existing primary treatment process at the City of Laguna Beach's treat-
ment plant is not capable of meeting the Water Quality Control  Plan for the
ocean waters of California.   The age and condition of the plant and the diffi-
culty of obtaining replacement parts for much of the equipment raises severe
questions on its ability to remain in effective service.   The replacement of
this facility by the proposed regional ocean outfall  will  insure the mainte-
nance of the marine environment and eliminate the possibility of physical
failure and pollution of the ocean and beaches.

The long-term impact of ocean outfall  discharge cannot be assessed accurately
because present data are limited and monitoring programs  in the vicinity of
the outfall are not available.  In addition, experimental  observations on
the nature and kinetics of very slow reactions at extreme dilution are
lacking.

The long-term productivity of the individual  treatment plants within AWMA
will not be efficient.  For example, without any improvements to the Rossmoor
treatment facilities to advanced wastewater  treatment or  completion of the
proposed project in 1977, land disposal  of effluent from  this plant will  become
over-taxed in the late 1970's.
                                     7-1

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 The  commitment of water  to  the operation of the project facilities will 'be an
 unavoidable  impact.  However, the construction of the upper Aliso tertiary
 treatment  plant  in  Phase II  (1985) of the proposed project will enhance the
 long-term  productivity of a  high quality treated water to be made available
 for  reclamation  and  groundwater recharge.

 7.1.2   Operation

 The  continued maintenance and operation of the proposed regional facilities
 will require the consumption of energy (237 x 10(6) kilowatt-hours) in order
 to meet the wastewater reclamation requirements of the Regional Water Quality
 Control Boards.  This commitment of energy consumption is a tradeoff for the
 long-term  maintenance of growth in the area.

 The  effect of the construction of the tertiary treatment plant in the Upper
 Aliso area in 1985 will  not  only be to reclaim and recharge wastewater but the
 central treatment plant  and  ocean outfalls would be reduced in capacity by
 5 MGD.  This would reduce the amount of effluent discharged into the ocean which
 would have to be diluted  and dispersed.

 This treatment plant would remove the highly saline water in the Upper Aliso
 basin and  replenish  it with  secondary treated lower TDS supplies that would come
 out of  the tertiary plant.   It is estimated that this process would take 10
 years of groundwater recharge in order to eliminate enough salt from the
 basin to enable the recharged groundwater to be utilized for agricultural
 purposes.

 The generation of population into the region will  occur at an unforeseen
 rate, but  it can generally be forecast at certain periods throughout the
 next 25 years.   The project's capacity can be expanded to accept a popula-
 tion greater than the E-0 projections, but not greater than the modified
 Orange  County projections.  The operational  flexibility of the proposed
 project can meet the requirements for wastewater treatment whereas the
 existing treatment facilities cannot easily be expanded to meet the same
 requirements.

 7.2  INFLUENCES OF THE PROPOSED PROJECT UPON GROWTH IN THE AWMA AREA

 As discussed in Section 4.2, there  are several  land uses,  land use policies,
 economic trends and other factors which influence  growth.   The proposed pro-
 ject can be considered a factor which, in conjunction with the policies,  the
existing environment and the multitude of other factors,  would further in-
 duce and introduce population and economic growth  into the AWMA area.

 The pattern of urbanization usually moves outward  from the border between  the
 urban and rural  landscape where  it  becomes economically advantageous to con-
 tinue development.   The proposed regional  wastewater treatment plant will  not
only improve the level  of wastewater treatment for the existing population,
 but it will establish the framework for defining the areas within AWMA
available for future development.  The wastewater treatment system then be-
comes another criterion for determining population growth.   In recent years,
 regulatory  and  planning agencies  have been exerting a greater influence in
                                    7-2

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controlling growth by relating such matters as air pollution and open space
to land use plans.  While this trend,will remain, efforts are also being made
to control land use through limitations of capacity permitted to be provided
by utilities such as water and sewage.

Since it was realized that the introduction of the proposed wastewater treat-
ment facilities would generate a regional increase in population over a long
period of time, population projections were forecast in order to determine the
extent of treatment facilities that will ultimately be needed by the population
that will exist within the AWMA area.   However, the proposed project will  not,
by itself, be the final determinant of the ultimate regional population.  Many
other factors will have an impact upon the AWMA region and final approval  of
land use development plans will come from the proper governmental  and/or
regulatory agency.

In fact, pressures outside of the AWMA area will  have an effect upon the
development of the AWMA area.  The Irvine Industrial Complex-East and the
Irvine Regional Center will  have tremendous growth inducement upon the AWMA
area.  Decisions made outside the influence of the AWMA area are creating
growth pressures which can only be reacted to and not necessarily modified or
altered by the AWMA members.

The AWMA region offers relatively vacant land that can be used to provide  a
new living environment better than already existing areas of the county.

Through the development of planning reserve areas (e.g., Laguna-Aliso, South
Coast and Northern El Toro Planning Reserves), a  more efficient utilization
of resources such as energy systems and modes of transportation is realized.
The proposed project will  encourage development to take place within these
planning reserve areas since the wastewater system will be made available
prior to development.  The project's facilities will strengthen the Planned
Community zoning regulation of the areas within AWMA by insuring the long-term
commitment and productivity of the proposed land uses.

The indirect effect of the proposed project is its generation of population.
By generating population the proposed  project creates impacts upon air quality
and the other environmental  and urban  systems.  The encouragement  of develop-
ment due to the regional wastewater system will  cause further commute dis-
tances, thereby producing air quality  and transportation problems.

Based upon both the Orange County's Modified Growth Rate and the SCAG E-0
series of population projections the standards for hydrocarbons and oxides
of nitrogen will be far exceeded in 1985.  Unless the mitigation measures
related to air quality in Chapter 4 are implemented, the ambient air quality
will  be the only major long-term adverse effect produced by the short-term
uses of the environment.

7.2.1   Impacts on Land Value

The proposed project will  create impacts on land  values throughout the region
in much the same way that transportation corridors  do.   Land values fluctuate
                                    7-3

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with proximity to freeways.  Growth in this portion of the County has typically
followed the San Diego Freeway because it provides economic benefits in terms
of reduced travel times, due to easy access.

Access to the regional wastewater facilities will be a major factor for
locating development since the costs of connecting with the wastewater system
would be less expensive closer to a tie-up point in the system.  Consequently,
land values will appreciate throughout the region.

The coastline property of the Irvine iCompany has experienced no growth in
the last 10 years.  In general, the rate of growth has been much slower along
the coast than it has in the rest of Orange County.  This is due to an in-
flated rate of land values which will make any future development along the
coastline high priced.  Since no regional sewage treatment interceptors or
plants currently exist north of the City of Laguna Beach, the proposed North
Coast Interceptor will provide the backbone to service development within
the Irvine Ranch Water District.   Therefore, the land values in this area
will  increase.

The areas along the Aliso Creek which are primarily vacant now will  increase
in value although planning policies will  maintain the Aliso Canyon as a
regional greenbelt corridor.

The City of Laguna Beach will  not be affected by the proposed project in
terms of either induced population growth or the relative increase in land
values.   Laguna Beach has placed a population limit of 20,000 residents and
therefore will only need an upgraded wastewater system to meet the health
standards.

Overall, escalated land values will  render future acquisition of parks and
recreation  lands, as described in Section 2.8.2 more difficult to achieve.
Recreation  demands for the area will  increase as development proceeds, how-
ever, lands suited for these needs will  diminish.
                                    7-4

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Is)

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 8.0   IRREVERSIBLE AND  IRRETRIEVABLE COMMITMENTS OF RESOURCES

 8.1   LAND  USE  COMMITMENTS

 The environmental changes produced by the implementation of the proposed
 project occur  as a result of alterations to the physical environment in the
 form  of a  commitment of land.  The regional treatment plant will occupy 12
 acres, permanently changing open space to an industrial land use.  If the
 proposed project is implemented the indirect effects of the project will not
 become committed due to the existence of wastewater infrastructure.  The
 governmental and regulatory agencies will determine the patterns of develop-
 ment.  This means thalt there wouldn't necessarily be a reduction of open space
 or a  change of agricultural land to residential or industrial uses.

 The major  irreversible environmental changes will be indirect.  The urbani-
 zation of  the  AWMA area will be an irreversible environmental change that
 will  insure a  long-term comrnitment to planned communities such as the South
 Coast, Laguna-Aliso and Northern El Toro Planning Reserve Areas.

 8.2   ENERGY REQUIREMENTS

 The energy requirements of the proposed project will  reduce the available
 energy supply.  Each proposed wastewater treatment alternative will irretrie-
 vably reduce this energy supply.  The primary effect of the proposed project
 on energy  supplies will center on electrical  energy required to pump waste-
 water from sources to the wastewater treatment plant.   Comparatively, some
 alternatives will utilize more energy than others, but this irretrievable
 commitment of  resources must be considered as an unavoidable impact that
will enhance the long-term productivity of the region.   The following table
 shows the energy requirement for each alternative.

                                                    ENERGY
                ALTERNATIVE                       REQUIREMENTS
                                                (kilowatt-hours)

                    1A                            227  x 10(6)
                    2E                            203.3 x 10(6)
                    2G                            230.39 x 10(6)
                    3C                            1,520 x 10(6)
                    4A                            205.2 x 10(6)
                    4C                                 N/A
                    2F                            237.7 x 10(6)


Since one of the primary commitments  of the  proposed project is  the irre-
trievable use of energy,  the amount of energy  expended  by each  alternative
for pumping raw sewage through  the  system is  an important consideration  in
evaluating the relative impacts of  the laternatives.  The following tables
 (Tables 8-1 through  8-5)  provide  a  quantitative energy  expenditure  break-
down for pumping raw sewage  upgrade at each pump station.
                                    8-1

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TABLE 8-1 Energy expenditure for pumping raw sewage up grade as designated in Project Alternative 1A.
   PUMP STATIONS
PRESSURE HEAD^feet)
                         PERIODS (KW-HR/YRx 106)
Static Friction
Salt Creek - to Aliso PS
- to Arroyo Salada PS
Arroyo Salada - with Salt Creek
- without Salt Creek
Aliso Creek - with Salt Creek
- without Salt Creek
Rossmoor - location as in Alt. 2F
Morro Canyon
Emerald Bay
Broadway
Bluebird
TOTAL
125
60
150
150
65
65
120
150
90
30
100

20
20
15
15
10
10
20
6
4
10
15

Total
145
80
155
155
75
75
145
156
94
40
115

1975-8O
0.24
O.13
O.40
0.15
0.31
0.19
2.53
0.11
0.13
0.47
1 .36

1981-85
0.33
0.18
0.66
0.25
0.41
0.24
3.35
O.26
0.21
0.52
1 .51

1 986-90
0.43
0.23
0.86
O.40
0.53
0.31
3.93
O.40
0.30
0.57
1 .65

1991-95
0.51
0.28
1 .11
0.56
O.65
0.39
4.49
O.55
0.40
O.63
1 .80

   with Salt Crk PS to Aliso PS
  830
100
930
5.30
6.84
8.21
9.59
   with Salt Crk PS to Arroyo
      Salada PS
  765
100
865
5.32
6.93
8.25
9.65

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8.0   IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES

8.1   LAND USE COMMITMENTS

The environmental changes produced by the implementation of the proposed
project occur as a result of alterations to the physical environment in the
form  of a commitment of land.  The regional treatment plant will occupy 12
acres, permanently changing open space to an industrial land use.  If the
proposed project is implemented the indirect effects of the project will not
become committed due to the existence of wastewater infrastructure.  The
governmental and regulatory agencies will determine the patterns of develop-
ment.  This means that there wouldn't necessarily be a reduction of open space
or a  change of agricultural land to residential or industrial  uses.

The major irreversible environmental changes will  be indirect.  The urbani-
zation of the AWMA area will be an irreversible environmental  change that
will  insure a long-term commitment to planned communities such as the South
Coast, Laguna-Aliso and Northern El Toro Planning Reserve Areas.

8.2   ENERGY REQUIREMENTS

The energy requirements of the proposed project will  reduce the available
energy supply.  Each proposed wastewater treatment alternative will irretrie-
vably reduce this energy supply.  The primary effect of the proposed project
on energy supplies will  center on electrical energy required to pump waste-
water from sources to the wastewater treatment plant.   Comparatively, some
alternatives will utilize more energy than others, but this irretrievable
commitment of resources must be considered as an unavoidable impact that
will enhance the long-term productivity of the region.   The following table
shows the energy requirement for each alternative.

                                                    ENERGY
                ALTERNATIVE                       REQUIREMENTS
                                                (kilowatt-hours)

                    1A                            227  x 10(6)
                    2E                            203.3 x 10(6)
                    2G                            230.39 x 10(6)
                    3C                            1,520 x 10(6)
                    4A                            205.2 x 10(6)
                    4C                                 N/A
                    2F                            237.7 x 10(6)


Since one of the primary commitments of the proposed  project is the irre-
trievable use of energy,  the amount of energy expended  by each alternative
for pumping raw sewage through the system is an important consideration  in
evaluating the relative  impacts of the laternatives.   The following tables
(Tables 8-1  through  8-5)  provide a quantitative energy  expenditure  break-
down for pumping raw sewage upgrade at each pump station.
                                    8-1

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TABLE 8-1 Energy expenditure for pumping raw sewage up grade as designated in Project Alternative 1A.
   PUMP STATIONS
PRESSURE HEAD_(feet)
                PERIODS (KW-HR/YRx 106)
Static Friction
Salt Creek - to Aliso PS
- to Arroyo Salada PS
Arroyo Salada - with Salt Creek
- without Salt Creek
Aliso Creek - with Salt Creek
- without Salt Creek
Rossmoor - location as in Alt. 2F
Morro Canyon
Emerald Bay
Broadway
Bluebird
TOTAL
125
60
150
150
65
65
120
150
90
30
100

20
20
15
15
10
10
20
6
4
10
15

Total
145
80
155
155
75
75
145
156
94
40
115

1975-80
0.24
0.13
0.40
0.15
0.31
0.19
2.53
0.11
0.13
0.47
1 .36

1981-85
0.33
0.18
0.66
0.25
0.41
0.24
3.35
0.26
0.21
0.52
1 .51

1 986-90
0.43
0.23
0.86
0.40
0.53
0.31
3.93
0 . 40
0.3O
0.57
1 .65

1991-95
0.51
0.28
1.11
0.56
O.65
0.39
4.49
O.55
0.4O
0.63
1 .80

   with Salt Crk PS to Aliso PS
  830     1OO
930
5.30
6.84
8.21
9.59
   with Salt Crk PS to Arroyo
       Salada PS
  765     100
865
5.32
6.93
8.25
9.65

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TABLE 8-2 Energy expenditure for pumping raw sewage up grade as designated in Project Alternative 2G.
    PUMP STATIONS
PRESSURE HEAD (feet)
                         PERIODS (KW-HR/YR x 106)
Static Friction
Salt Creek - to Aliso PS
- to Arroyo Salada PS
Arroyo Salada - with Salt Creek
- without Salt Creek
Aliso Creek - with Salt Creek
- without Salt Creek
Morro Canyon
Emerald Bay
Broadway
Bluebird
LAWD PS
ETWD PS
TOTAL
125
60
150
15O
65
65
150
90
30
100
105
120

20
20
15
15
10
10
6
4
10
15
15
20

Total
145
80
155
155
75
75
156
94
40
115
120
140

1 975-80
0.24
0.13
0.40
0.15
0.31
0.19
0.11
0.13
0.47
1 .36
0.63
0.99

1981-85
0.33
0.18
0.66
0.25
0.41
0.24
0.26
0.21
0.52
1 .51
1 .06
1 .09

1 986-90
0.43
0.23
0.86
0.40
0.53
0.31
0.40
0.30
0.57
1 .65
1 .27
1 .25

1991-95
0.51
O.28
1.11
O.56
0.65
0.39
O.55
0.40
0.63
1 .80
1 .46
1 .42

    with Salt Crk PS to Aliso PS

    with Salt Crk PS to Arroyo
       Salada PS
   935
   870
115
115
1050
 985
4.39
4.37
5.64
5.73
6.80
6 .%
8.00
                                                                                                8.06

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TABLE 8-3 Energy expenditure for pumping raw sewage up grade as designated in Project Alternative 4A.
    PUMP STATIONS
PRESSURE HEAD (feet)
                        PERIODS (KW-HR/YR x 1
Static Friction
Salt Creek - to Aliso PS
- to Arroyo Salada PS
Arroyo Salada •>• with Salt Creek
•* without Salt Creek
Aliso Creek - with Salt Creek
- without Salt Creek
Morro Canyon
Emerald Bay .
Broadway
Bluebird
MNWD-4A Plant -. Influent
125
60
150
150
65
65
150
90
30
1OO
50
20
20
15
15
10
10
6
4
10
15
10
Total
145
8O
155
155
75
75
156
94
40
115
50
1975-80
0.24
0.13
0.40
0.15
O.31
O.19
0.11
0.13
0.47
1 .36
0.52
1981-85
0.33
0.18
0.66
0.25
0.41
0.24
0,26
0.21
0.52
1 .51
O.81
1986-90
0.43
0.23
O.86
O.40
0.53
O.31
0.40
0.30
O.57
1 .65
1 .05
1991-95
0.51
0.28
1.11
0.56
0.65
0.39
0.55
0.40
0.63
1 .80
1 ,30
TOTAL
    with Salt Crk PS to Aliso PS
   760
90
850
3.29
4.30
5.33
6.40
    with Salt Crk PS to Arroyo
       Salada PS
   695
90
785
3.27
4,39
5?37
6,46

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TABLE 8-4  Energy expenditure for pumping raw sewage up grade as designated in Project Alternative 2E & 2F,
   PUMP STATIONS
PRESSURE HEAD (feet)
                         PERIODS (KW HR/YR x 106)
Static Friction
Salt Creek - to Aliso PS
- to Arroyo Salada PS
Arroyo Salada - with Salt Creek
- without Salt Creek
Aliso Creek - with Salt Creek
- without Salt Creek
Rossmoor - location as in Alt. 2F
Morro Canyon
Emerald Bay
Broadway
Bluebird
TOTAL
125
60
150
150
65
65
12O
150
90
30
100

20
20
15
15
10
10
20
6
4
10
15

Total
145
80
155
155
75
75
145
156
94
40
115

1975-80
0.24
0.13
0.40
0.15
0.31
0.19
2.92
0.11
0.13
0.47
1 .36

1981-85
0.33
0.18
0.66
0.25
0.41
0.24
3.87
0.26
0.21
0.52
1 .51

1 986-90
0.43
0.23
0.86
0.40
0.53
0.31
4.53
0.40
0.30
0.57
1 .65

1991-95
0.51
0.28
1 .11
0.56
O.65
0.39
5.18
0.55
0.40
0.63
1 .80

   with Salt Crk PS to Aliso PS

   with Salt Crk PS to Arroyo
       Salada PS
   830
   765
100
100
930
                                                      865
5.69
            5.67
7.36
          7.45
                                                   8.81
                                                   8.85
                                                  10.28
                                                  10.34

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TABLE 8-5 Energy expenditure for pumping raw sewage up grade as designated-in Project Alternative 3C.
    PUMP STATIONS
Salt Creek - to Aliso PS
  •*• to Arroyo Salada PS

Arroyo Salada - with Salt Creek
            - without Salt Creek

Aliso Creek - with Salt Creek
          - without Salt Creek

Rbssmobr - location as in Alt.  2F

Morro Canyon

Emerald Bay

Broadway

Bluebird
Regional Plant - Influent

RECLAMATION PUMPING

    Aliso drainage
   North Coastal drainage

TOTAL
PRESSURE HEAD (feet)
                         PERIODS (KW-HR/VR x 1 Q6)
    with Salt Crk PS to Aliso PS

    with Salt Crk PS to Arroyo
        Salada PS
Static
125
60
150
150
65
65
120
150
90
30
100
50

Friction
20
20
15
15
10
10
20
6
4
10
15
10

Total
145
80
155
155
75
75
145
156
94
40
115
60
1100
600
1975-80
0.24
0.13
-Q.40
0.15
O.31
O.19
2.92
0.11
O.13
0.47
1 .36
1 .97
18.5
5.68
1981-85
0.33
0.18
0.66
0.25
0.41
0.24
9.87
0.26
0.21
0.52
1 .51
2.74
32.1
6.15
1 986-90
0.43
0.23
O.86
O.40
0.53
0.31
4.53
0.40
O.30
0.57
1 .64
3. 01
40.1
6.55
1991-95
O.51
0.28
1 .11
0.56
0.65
0.39
5.18
0.55
0.40
0.63
1 .80
3.96
50.9
6.94
   880
   815
110
110
269O
2625
31 .84
31 .82
48.35
48.44
58.47
58.51
72.08
72.14

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 It  is  important to note a few different aspects of these tables to compare
 the impact of different components of the alternatives.  First, the total
 energy expenditure of each alternative utilizing the Salt Creek Pump Station
 as  it pumps sewage to the Aliso Creek Pump Station would be lower, but almost
 equivalent if the alternatives were to be constructed with the Salt Creek
 Pump Station pumping sewage to the Arroyo Salada Pump Station.

 Although the energy expenditures will be approximately equivalent, the dif-
 ference in pressure heads is substantial.  If the Salt Creek pump station
 was constructed to pump to the Aliso pump station the pressure head would be
 145 feet as opposed to 80 feet for the Arroyo Salada pressure head.

 Secondly, Alternatives 2F and 2E were combined in one table because the re-
 quirements were approximately the same for the pumping facilities.  The
 energy expenditure for the advanced wastewater treatment portion of Alter-
 native 2F is coincidental with the energy requirement expenditure of land
 reclamation in Alternative 2E.

 From the standpoint of energy expenditure, Alternative 2G, compared to
 Alternatives 2E and 2F, would be the most cost effective.  Alternative
 2G  eliminates double-pumping in the Upper Aliso area.  Alternative 2G would
 therefore conserve valuable energy resources and increase the reliability
 and efficiency of the operation of the facilities.   From the standpoint of
 pumping alone, Alternative 2G would, by 1995, save  approximately 3,898,000
 kilowatt-hours.

 Population growth in an automobile dependent area will  result in an increase
 in  Vehicle Miles Travelled (VMT).   Population growth made possible by com-
 pletion of the proposed project may result in 2,370,000 miles per day of
 additional  automobile travel, and  200,000 gallons per day of additional
 gasoline consumption.

 8.3 WATER RESOURCES

 The function of the wastewater system is  to produce an  environmentally com-
 patible wastewater that can be reclaimed  or discharged  into the land and
 marine environment.  The commitment of constructing the wastewater facilities
 results in an irreversible use of  the marine environment for dilution and
 dispersion of effluent and the use of the land for  irrigation and groundwater
 recharge.  This commitment results in an  irreversible impact upon the exist-
 ing marine water and groundwater systems.   However, the advanced technology
 of  the proposed project will  produce an effluent that will  be highly compatible
with the natural ground and ocean  waters.   As an example, the water discharged
 into the Upper Aliso basin will  improve the quality of  the highly saline
 groundwater,  thereby retrieving the groundwater as  a usable future resource.
                                    8-2

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 8.4   SCIENTIFIC  RESOURCES

 8.4.1   Paleontological  Resources

 The Aliso  Creek  Watershed and the geographic area it affects, contains one of
 the most important paleontological regions in the United States.  To list and
 describe every known fossil site in the Aliso drainage system would be in-
 adequate because the entire area contains fossils in varying degrees of abun-
 dance and  many sites will be discovered during grading.  It is inevitable that
 sites will be uncovered during the construction of the project; consequently
 there are  certain recommendations that will reduce the impact, when possible,
 and provide a plan for  the preservation and salvage of fossils in danger of
destruction.  The paleontologists make the following recommendations:

 1.   A  qualified paleontologist must be given the opportunity to survey the
     area  to be  graded or developed as far as possible in advance of the
     grading date.

     a.    A qualified paleontologist should be a scientist who has completed
           at least his B.S. in paleontology and has commenced advanced work in
           paleontology, has worked in the county and is familiar with the
           regional fossils and geologic formations, and who is acknowledged
           by other paleontologists in Southern California.

           This statement has been added to emphasize the necessity of having
           a skilled paleontologist on the site.   In the past, unqualified
           consultants such as archaeologists and soil  engineers have made
           decisions which have led to the destruction of great fossil accu-
           mulations.   Similarly, a paleontologist who is present during
           grading must have had broad field experience in surveying and
           salvaging fossils.

2.   Because of  the abundance of fossils within  the Aliso drainage area,  a
     paleontologist must be given the opportunity to be present during all
     grading and excavation.  The paleontolgist  should be permitted to remove
     any fossils, using proper recovery techniques,  and using a paleontolo-
     gical  salvage team, if necessary.

     At all times developers and grading crews must respect the scientific
     significance of  the paleontologist's work and cooperate with the paleon-
     tologist and salvage teams  to recover maximum scientific information
     about the prehistory of the area.

3.   Paleontological  specimens and data must be  placed in a public institution
     such as the Natural History Museum of Los Angeles County,  Geology De-
     partment of UCLA,  Geology Department of Chapman College, or Geology
     Department of UCR.    These  specimens and data must be  available to
     anyone who wishes  to research and study them.

4.   When possible,  fossil  sites should be preserved.   Often greenbelts or
     parks  can be developed upon fossil  sites thus preserving them,  and in
     some cases,  actually incorporating a display of the fossils "in situ"
                                    8-3

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     for school children to observe.  If large bone beds are discovered, con-
     sideration should be given to establishing a wind-sun shelter under
     which an on-going dig could be made by scientists and college students
     in the county.  This would have great appeal to tourists as well as
     students.  Several such parks have been established in the United States
     that utilize fossil sites and on-going digs, notably Dinosaur National
     Monument, Agate Springs, La Brea Tar Pits, and Dinosaur State Park
     (Connecticut).

5.   If any fossils are found in this area, a paleontologist must immediately
     be notified.  Dr. Lawrence G. Barnes, Natural History Museum of Los
     Angeles County (213) 746-0410; Mr.  Jack Mount, Geology Department,
     University of California at Riverside (714) 787-3440; and Carol  J.
     Stadum, Huntington Beach High School (714) 536-2514, will be able to
     provide assistance.

8.4.2  Archaeological Resources

Given the distribution of known archaeological  sites and the probable loca-
tion of those yet to be recorded, it is  very likely that construction can
adversely affect archaeological resources.  Surveys on the Moulton Ranch
indicate numerous sites in areas likely to exhibit middens representing
long-term occupations.  These substantial deposits present greater mitigation
problems than other types of sites.

While the AWMA project may not be the causal  element of population increases
within this district, it is an important component of urban growth.   Indirect
or secondary effects of increased development will be far-reaching.   The San
Joaquin Hills are a unique feature of Orange County; the archaeological com-
plexes here and in the northern El  Toro  district are also unique.   The site
density for most areas of AWMA exceeds that of other areas of Orange  County
with the exception of the coastline and  areas about marshes.   Increased
disturbance of archaeological  remains by development is inevitable in all  areas
of AWMA excepting the eastern margin.  In this  region the few sites,  several
of which are very important,  may be more easily incorporated  into  residential
planning than the other regions where sites are numerous.

In order to reduce the possibility of archaeological  resources becoming irre-
trievable,  archaeological  reconnaissance should be undertaken to mitigate
possible adverse impacts of proposed construction.  Once specific  locations
or specific alternatives have been established  a systematic survey should  be
made to assess the impact of construction.   Field reconnaissance is necessary
since not all  areas have been thoroughly investigated,  particularly with  re-
gard to buried deposits.   Indirect effects may  be partially mitigated by
long range  planning for the district as  a whole.   With  regards to  archaeolo-
gical resources, high density development should be focused in those  parts
of El Toro, Laguna Hills,  Moulton Ranch, Laguna Niguel, Bear  Brand, and
Colinas that exhibit low site density.   Programs of archaeological salvage
and protection should be instituted for  the remainder of lands within AWMA.
A great many archaeological  sites are located in steep  or rough  terrain, areas
best suited for open space.   Sites  in other areas  should be incorporated into
plans with  as  little disturbance of the  deposits as  possible.  Considering
                                     8-4

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the number of sites being destroyed in Orange County and elsewhere in Southern
California, archaeologists would prefer that sites be protected in open space
or covered over, leaving the remains intact for possible future study.  Des-
pite previous development, lands within AWMA still exhibit a wide range of
archaeological resources, sites that are uniquely important to an under-
standing of Orange County prehistory.

8.4.3  Biological Resources

The San Joaquin Hills, which comprise almost 60% of the AWMA area, are com-
prised of several unique and/or endangered habitat types occurring in the
Southern California coastal  zone.  In addition to displaying a diverse flora,
the coastal hills'  environment provides suitable habitat for many rare and
threatened faunal species or populations.   The AWMA project itself will  have
negligible primary impacts upon these terrestrial biological resources.
Secondary impacts,  however,  created by population growth and housing devel-
opments will have significant effects on these resources.  A detailed field
analysis should preceed any development and a complete biological  resource
survey should be included as part of the planning process.

Several endangered habitat types occurring in the AWMA area have already
been identified and are listed in the Coastal Land Environment prepared  by
the California Coastal Zone Conservation Commission (1974).fn the past,
loss of habitat has been the prime cause for the decline in numbers of
species to endangered status.  Preservation of sensitive habitat types in-
corporated with proper conservation measures provides protection of potentially
endangered species.   Therefore, unique and/or endangered habitat types should
be recognized and conserved  early in the planning process before additional
growth in the AWMA area occurs.
                                    8-5

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l_l

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9.0  PUBLIC INPUT

9.1  COMMENTS RECEIVED ON THE DRAFT EIS

A public hearing on the draft EIS for this project was held on March 25,
1975, in Laguna Niguel.  As expected, concern was expressed over potential
growth inducement and many people supported reclamation concepts.  In
addition, the plant site emerged as an item of great public concern.  This
concern prompted the EPA to reject the Aliso Canyon plant site location.

In this chapter, all comments received on the EIS will be presented, fol-
lowed by EPA's responses to each comment.  First, a chronology of public
participation will be presented.  Then comments dealing strictly with the
plant site issue will be summarized.  A section summarizing comments re-
ceived at the public hearing will follow.  Finally, all written comments
received on the EIS will be reproduced, followed by summaries of the com-
ments and EPA's responses.

9.2  CHRONOLOGY

The Final Environmental Impact Report for the Aliso Water Management Agency
Project prepared under the guidelines established by the California Environ-
mental  Quality Act of 1970 (Chapter 1433, Statutes of 1970, Public Resources
Code, Section 2100-21150) had considerable public and governmental  input.
The following chronology of events and written comments outlines the public
hearing process of the AWMA Project.

                            CHRONOLOGY OF EVENTS

Mar  1, 72     Aliso Water Management Agency Established

Sep  1, 72     Completion of the AWMA Project Report prepared by Boyle
               Engineering

Sep  1, 72     Completion of the AWMA Environmental Impact Study prepared
               by Jones and Stokes Associates, Inc.

Apr 23, 73     Permit approval for the construction of the AWMA ocean out-
               fall  by the California Coastal  Zone Conservation Commission,
               South Coast Region

Jun 20, 73     Permit approval for the construction of the AWMA ocean out-
               fall  by the California Coastal  Zone Conservation Commission.

Dec 27, 73     Environmental  Opportunities Workshop on the AWMA Draft EIR
               held at the South Laguna Sanitary District Offices

Feb 22, 74     Completion of AWMA Project Report prepared by Don Owen and
               Associates

Mar 26, 74     Public hearing for the AWMA Draft EIR in the City of Laguna
               Beach Council  Chambers
                                    9-1

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Apr  23, 74     Continued public hearing for the AWMA Draft EIR at the
               Irvine Ranch Water District

May  2, 74     Meeting with the Environmental Protection Agency and State
               Water Resources Control Board to receive comments on the AWMA
               Draft EIR and Project Report

May  7, 74     Final Public Hearing for the AWMA Draft EIR at the City of
               Irvine City Council Chambers

May  28, 74     Public Hearing for the AWMA Draft EIR by the Orange County
               Planning Commission

Jun  7, 74     Orange County Board of Supervisors passes Air Quality Reso-
               lution

Jun  12, 74     City of Laguna Beach passes Air Quality Resolution

Jun  26, 74     Completion of the AWMA Final EIR

Nov  4, 74     NPDES (Waste Discharge Requirements) Permit for AWMA approved
               by the California Regional  Water Quality Control  Board, San
               Diego Region

Feb     75     Completion of the EPA Draft EIS for the AWMA Project

Feb     75     Completion of the AWMA Draft EIR prepared by Clean Water
               Consultants

Mar 25, 75     Public Hearing for the EPA Draft EIS held at the  GSA facil-
               ity on the Moulton Ranch

Apr     75     The State Water Resources Control  Board, in compliance with
               the Coastal Commission permit conditions, recommended
               outfall  design capacities for the AWMA Project

Apr  3, 75     Public Hearing for the AWMA Draft EIR held at the Orange
               County Planning Commission  Chambers

May  6, 75     EPA finds the Alternative 2-G regional  treatment  plant site
               is unacceptable and determines that EPA grant funds will be
               made to AWMA only if measures are developed or prepared to
               resolve the proposed level  of development and the inconsis-
               tency with the Clean Air Act

Jun 16, 75     Completion of AWMA Final  EIR as prepared by Clean Water
               Consultants
                                    9-2

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Several issues surfaced either during public hearings or by written communi-
cation on the ElR between December 1973 and November 1974.  These include:

 I.  Growth Inducing Impacts

     A.   Air Quality
     B.   Water Quality
          1.   Surface water
          2.   Ground water basins
          3.   The marine environment
     C.   Loss of Open Space (in particular the Aliso-Laguna Greenbelt area)
     D.   Loss of Archaeological and Paleontological Resources

II.  Cost/Benefits of each Alternative, particular emphasis on reclamation.

III. Description of marine habitat and wildlife along the ocean outfall
     alignment.

IV.  Monitoring and maintenance of raw sewage interceptors and pump stations
     in unpopulated areas.

To the extent possible, these issues have received additional  consideration
in this EIS.

9.3  COMMENTS ON THE PLANT SITE AND ALTERNATIVES

The following individuals and organizations supported Alternative IA,  for
the most part, on the plant site issue:

Michael Lynd; California Coastal Zone Conservation Commission; Don Ferguson;
William Suddaby; U.S. Department of the Interior, Fish and Wildlife Service,
River Basins Office; Santiago Heights Property Owners Association; the Laguna
Greenbelt Inc. (James Oil ley, Harry Jeffrey, Elinor Davis and  Betty Heckel  as
members); Roberta Thayer and Linda Harrington, American Association of Uni-
versity Women, Laguna Beach; City of Laguna Beach (Roy Holm, Mayor; Carl
Johnson, vice mayor; Charlton Boyd, Jon Brand, and Phyllis Sweeney, Council-
members); Chas Dunway; Sierra Club, Orange County Group; E.  Hoffman; David
Baker; H. M. Anderson; Helen Gregory; Margaret Baggs, Mrs.  R.  H.  Bain; Mr.
and Mrs. Richard Brandwine; Desomount Club; Bill Sues, Mary Sues, Jim
Mamer, Candice Mamer; Debbie Neumann, Dee Dee Challis, Lisa Hartley, James
Searby, Brent Lowe, Mike Briggs, Alex Warrick, Randy Landon, Dwight Miller,
Mary Ann Ottmer, Carey Conklin; Kurt Westguard, Beth Reilly, Matt Muiphine,
Melody Berryhill, Marcia Daley, Candee Cullen, Carol Moffat, Patty Rodriguez,
Darrell Faccio,  Garry Dometriotes, Norman Clark, Sherry Garcia, Karen  Krause,
Marina Van Gores, Gary Suffin,  Susan Vincent, Nona Arman, Steve Modiano,
Pat Joseph O'Hara, Richard Fireberg, Paul Kohut, Jennifer Moskowitz, Bridget
Hoff, Cherrell Digframe, Steve  Tat, Tom Van Luchene, Heidi  Burkhardt,  Fre
Hollister, Alan  Gilbly, and Fary Langenheim, Laguna Beach High School;
Carol Thompson;  Helen Brockmeier; Henry Weber of California  Garden Clubs;
W.  H. Vernor, Citizens Town Planning Association; Dorothy Woods;  Lloyd Johnson,
Ray Moose; Elsie Moose; Ralph Netzley; Edna Netzley; E.  E.  Ayrns; Virginia
Gray; La Vina Vos; D. Bresnahan; John N.  Daniel, Sherry Stephens  of Laguna
                                     9-3

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 Beach  Junior Women's Club; Carmen Perry and Bill Ives of Irvine Teachers
 Association; Joan  Petty of Orange County League of Women Voters; Alvin
 Wienie;  John Daniel; G. H. Kirkpatrick, Laguna Citizens Town Planning
 Association; Tom Alexander and Ron Chi 1 cote, Temple Hills Community Associa-
 tion  (or 92 individuals and 15 organizations).

 Foothill Communities Association, Inc., and Ron Yeo objected to a site in
 Aliso  Canyon, although they did not specify an alternative site.

 The Orange County  Planning Commission had serious problems with the site for
 Alternative 2G and tended to favor Alternative 1A, but they desired more
 analysis.

 The State Department of Parks and Recreation's State Historic Preservation
 Officer, the Department of the Interior, the Advisory Council on Historic
 Preservation, Marian Parks and Roberta Greenwood all objected to plant loca-
 tions which would  directly affect any of the valuable archaeological sites in
 Aliso  Valley.  Alternative 2G would have been located on an archaeological
 site, and the site would have needed to be at least partially excavated.

 William  Leak of Village Laguna favored an interim A solution, using the con-
 cept of  Alternative 1A, but delaying construction of treatment plant capa-
 city to  the maximum extent possible.

 Lorell Long of the South Laguna Civic Association favored Alternative 3C
 for reclamation reasons.  (Several of those who favored Alternative 1A
 also favored Alternative 3C).

 Roscoe Poland of the San Diego Audubon Society and Margaret Carl berg, Chuck
 Greening, Gerald Podolak, Harry Jeffrey and Dale Secord of the Environmental
 Coalition opposed any Federal  funding for the project without drastic revi-
 sions.

 The following individuals and organizations favored Alternative 2G:

 The California Regional Water Quality Control  Board, San Diego Region;
 the Orange County Chamber of Commerce; H.  L.  Remmers, Moulton-Miguel
 Water District; the Aliso Water Management Agency; the Saddleback Area Coor-
 dinating Council; Robert Price of Leisure World Community;  Assemblyman Robert
Badham; State Senator Dennis  Carpenter; Robert Moore of the Santa Ana Water-
 shed Planning Agency, Bob Miller; V.  P. Baker, Los Alisos Water District;
Warren Wilson,  Rancho Mission Viejo;  Hugh Walker, El Toro Water District;
 G. W.  Ferguson of Orange County Council  for Environment of Excellence,
 Full  Employment and a Strong  Economy  through  Planned Development (CEEED);
 D.L.  Langton,  Santa Ana College;  Clark McDermed, South Laguna Sanitation
 District; Ralph Kiser,  Orange County  Coast Association; Clay Mitchell,
 South Laguna Sanitation District; Jeff Lodder, Mission Viejo Company; William
Thrash, Presley Corporation;  and  Thomas Swanson, Emerald Bay Service Dis-
trict (or 23 individuals and  17 agencies  and  organizations.
                                    9-4

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 9.4   COMMENTS RECEIVED AT'THE  PUBLIC  HEARING  REQUIRING A  RESPONSE -••

      California  Garden Clubs,  Inc., Dr.  Henry M. Weber    -   -
      Laguna  Greenbelt, Inc., Dr.  Harry  P.  Jeffrey
      Los  Alisos  Water  District, Mr. V.  P.  Baker
      State Water Quality Control  Board,  Mr. Ladin  H.  Delaney
      CEEED,  Mr.  G. W.  Ferguson
      Orange  County Coast Association, Mr.  Ralph  C.  Kiser
      Mr.  Alvin Wiehle                                 - .
      South Laguna Sanitary  District,  Mr. Clay N. Mitchell
      Ms. Abigail  H. Alderman
      City of Laguna Beach,  Mr. Roy W. Holm, Mayor;  Ms. Phyllis Sweeney,
          Council woman
     'San  Clemente Citizens, Ms. Dorothy  Fuller
      The  Environmental  Coalition, Inc.,  Mr. Dale A. Secord
      Laguna  Greenbelt,  Inc., Mr.  Michael A. Schley
                              SUMMARY COMMENTS

                             Dr. Henry M. Weber
                        California Garden Clubs, Inc.

1.   This project is a first step in the destruction of thousands of acres
of potential agricultural land.  Therefore, with a food crisis already a
reality, no action should be taken until Assembly Bill 15 has had adequate
consideration by the State Assembly.

R-l.  Approximately 13% of the AWMA'area, or 6,358 acres, contains prime
agricultural soils.  These soils are almost exclusively located on valley
and'-canyon floors and many areas, such as Laguna Canyon, have already been
urbanized.  For a more complete discussion, see Section 2.4.4, Agricultural
Soils and Chapter 4.0, 'Secondary Impacts of the Project in the Final EIS.
                          Dr. Harry P. Jeffrey
                            Laguna Greenbelt

1.   Although AWMA argues that this project will not induce growth because
other modes of sewage treatment, such as septic tanks, could be used,
it is absurd to expect a large population to utilize these methods without
drastic effects upon the environment.  Also, the State Department of
Health has strict regulations governing the issuance of permits for septic
tanks' and only-a few permits are granted annually.

R-l.  On the contrary, many permits for septic' tanks are issued.  As
for the other alternative methods of sewage disposal and their impacts
upon the environment, please' refer to Section 4.4 of the EIS.
       * '  -  	  •        --' '   * \  ' ' •
2.   Population growth -is t'he: criteria on which AWMA is based.  If it
weren't for population growth, this project would probably not be con-
si dered.
                                    9-5

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 R-2.   Problems currently exist which need to be solved.  The scope of
 the  solution  depends  upon projected population growth.

 3.    The projected population size and the proposed treatment capacity
 in the EIS are unclear.

 R-3.   This information in the EIS has been clarified in Section 4.3.4 of
 the  Final EIS..

 4.    SCAG, the Orange County Planning Commission, and the California
 Coastal Zone  Conservation Commission have all proposed lower densities.

 R-4.   Only the Coastal Commission has made such a proposal and only for
 the  portion of AWMA over which it has authority.  The County of Orange
 has  adopted an LUE which would locate more people within AWMA than pro-
 jections serve.  Refer,to Exhibits 4-8, 4-9, and 4-10 in the Final EIS.

 5.    The stationary emissions from the AWMA sewage treatment plant in-
 cinerator will contribute significantly to air pollution.

 R-5.   Particulate emissions are not the air quality problem.  Particulate
 emissions are controllable with devices currently available.
                 .                V. P. Baker
                          Los Alisos Water District

1.   In 1968, the Los Alisos Water District held an election and a bond
for 15 or 16 million dollars which was approved by 99.76% of the voters.
The people in this district favor the AWMA project.

R-l.  The Los Alisos Water District is a California Water District.  Water
districts of this type restrict voting to land owners, irregardless of
residency and the number of votes each land owner has is based upon the
assessed value of his property.  Therefore, the election does not neces-
sarily indicate the desires of the people who reside within the district.

                              Ladin H. Delaney
                            State of California
               California Regional  Water Quality Control Board
                    .  .         San Diego Region

In the interest of regionalization, the regional board supports Alternative
2-G, not only for reasons of economy, but also for the reliability of opera-
tion.  The board feels that the system which is adopted should be adequately
sized in order to minimize the direct economic costs and environmental dis-
ruptions involved with construction.

R-l.  Please refer to .the EIS for a discussion of the comparative reliability
of the alternatives.   The maximum capacity of the project has been dictated
by the Coastal  Commission (Section  4.3.4 of the Final  EIS).
                                     9-6

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                               G. W. Ferguson
                                    CEEED

2.   The growth of Orange County has continued unabated at 60 to 70,000
people per year.  This is a fact of life.  These people are not coming from
outside of the state, but are our own children.  They are the result of a
national population increase.  As children become adults, they will need
houses, water, sewage service, and roads in order to lead their own lives.

R-l.  Population growth within Orange County is actually about 50,000 people
per year.  Of this total, 30,000 to 40,000 people are migrating into the
County, mostly from other areas of the state.

                               Ralph C. Kiser
                      Orange County Coastal Association

1.   It is not factual to say that growth can be reduced by eliminating
regional wastewater treatment systems.  Smaller private systems may be
built and the result would be an ultimate increased cost to the residents
and taxpayers.

R-l.  These higher costs are a partial deterrent to development.


                                Alvin Wiehle
                                 South Laguna

2.   Today there are many unsold homes available in the county.   Further-
more, the old growth rate and development pattern may change in the future
and projections cannot be relied upon.  My question is why is either alter-
native 2G or 1A needed?

R-l.  The existing problems described in Chapter 4 of the EIS need to be
solved.  The scope of the project is affected by population projections,
not the need for the project.


                              Clay N. Mitchell
                  President, South Laguna Sanitary District

1.   The regional plant proposed in Alternative 2G can be completely con-
cealed from view within the canyon by heavy landscaping.   We have been
discussing the use of California Holly, Toyans, Sycamores and Torrey Pines -
all native plants - for landscaping.  Also, adequate room for bicycle and
riding trails, etc., will be provided.

R-l.  This indicates the willingness of the applicant to  try to  make the
project consistent with the recreational  use of Aliso Creek.
                                     9-7

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                             Abigail H. Alderman

1, We can attempt to .improve a situation, but may discover that the solution
has caused even greater problems than we ever envisioned.  There was a case
in Japan where methyl mercury was discharged with the sewage effluent.  It
was absorbed into  the food chain and eventually crippled people.

R-l.   It has been  our goal throughout this in-depth study to consider all
eventualities.  Using the knowledge and tools we now have available, and
taking into consideration the area involved, we feel confident that there
will not be any future problems of any consequence.  The cited example in
Japan was, indeed, serious.  However, with the knowledge that there are no
heavy metals in this case, and with other safeguards taken, such a dilemma
will not occur here.
                                 Roy L. Holm
                            Major of Laguna Beach

1.   The City of Laguna Beach favors alternative 1A if modified so that
the proposed treatment plant is located not in Woods Canyon, but in a
more environmentally acceptable area.

R-l.  Alternative 1-A has been modified.  The treatment plant 'is now
proposed to be located adjacent to the GSA facility at Moulton Miguel
1A site as one of the alternatives.

2.   We would have expected a more complete evaluation of the process
of reclamation.

R-2.  The discussion of reclamation has been expanded (see Section 3.2.1.4),

3.   We would also like to suggest a more complete treatment of the
question of air quality.

R-3.  The EIS discusses current air quality and the impacts  of urbaniza-
tion in terms of traffic generation and consistency with the State Imple-
mentation Plan (SIP).  No verifiable model is available to actually
predict future air quality.  So discussion necessarily is limited to
compatibility with SIP control  strategy.                      ,
                                                              !
4.   We've been repeatedly told by 4 members of AWMA that they\will build
the 2G alternative in any event.  If this is the case, what  happens then
to Laguna's sewage problem if these agencies go their own way?

R-4.  If AWMA goes against EPA's recommendations, there will  be no federal
grant.   This will  unfortunately affect Laguna Beach.  The City;will still
be required to meet NPDES requirements.
                                     9-8

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                               Phyllis Sweeney
                          Laguna Beach City Council

1.   The City of Laguna Beach is opposed to and views with great concern
any plan that would wipe out the Aliso Creek Corridor.  The dollar loss
of the destruction of Aliso Creek is not considered or addressed in the
EIS in relationship to Alternative 2-G.

R-l.  The existence of a regional treatment plant in Aliso Canyon would
not prevent recreation within the corridor; instead, it would change the
character of the recreational experience.  We do not feel  it is possible
to quantify this in monetary terms.


                               Dorothy Fuller
                            San Clemente Citizens

1.   The AWMA EIS does not adequately discuss the SERRA project.  Accord-
ing to Federal regulations, both these projects should be considered con-
currently, as the primary and secondary impacts of one project affect the
other one.

R-l.  The EIS has been modified to discuss the relationship of the AWMA
and SERRA projects and the reasons for separating the projects into two
EISs.

The intent of these regulations is clearly to insure that impacts are not
considered piecemeal  when the overall impacts are significant.  However,
the secondary impacts of each project are significant and  has caused the
EPA to prepare impact statements and seek methods to  minimize those
impacts.  This is the desired course of action and would not be made more
effective by considering the projects in one document.


                               Dale A.  Secord

1.   J would suggest that the scope of the project itself be limited.
Each alternative serves basically the same purpose.  Each  is the same
size.  The EIS should consider reducing the size of facilities and cutting
segments of interceptors.

R-l.  Section 4.3.3.3 describes the relative effects of various sewerage
facilities.  EPA feels that the original  size of facilities  is relatively
unimportant in determining development patterns.  On the other hand,
the location of facilities, particularly interceptors,  does  affect urban-
ization patterns.  This is a valuable comment on segmenting  interceptors
and was taken into consideration in the determination of final  mitigation
measures.

2.   Another possible alternative is the staged construction of facilities.
For example, you could have a phased development over the  next 10 years,
adding sections on a pre-arranged schedule.
                                    9-9

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 R-2.   This  is  basically what 1-A  (modified) proposes to do.

 3.    I think that  the Federal government should not grant any money to
 this  project since some members of AWMA are California Water Districts.
 Voting in these districts, for the board of directors or for bonds, is
 not by popular vote.  This situation can be changed and AWMA certainly
 has the power  to try to implement a revision of the voting pattern.

 R-3.   This  concept would certainly improve the long-term accountability
 of California  Water Districts.  However, it shows little promise as a
 mitigation  for the short and medium term impacts of urbanization.  Further,
 the water district is a creation of the State of California and State
 action would be required to change the system.

 4.    AWMA cannot really implement the mitigation measures proposed in
 the EIS, only  general purpose governments can.  However, in June of 1974,
 both  the Orange County Supervisors and the Laguna Beach City Council
 passed resolutions recognizing that attempts by AWMA to solve water
 quality problems would or could cause air quality problems which might
 have  to be  alleviated by land-use controls.  This is your opportunity
 to work with these governments to implement the suggested alternatives
 or mitigation  measures put forth in the EIS.

 R-4.   Chapter  5.0 of the Final  EIS describes the selected wastewater manage-
 ment  alternative for AWMA.  As noted in this chapter, the Final Mitigation
 Plan  for AWMA will  be addressed at the Phase III level  of the total project.
 Sections 5.2.2 and 5.3.3 discuss this subject in detail.

 5.    I suggest that additional mitigations are needed,  that the County
 of Orange be required to have an air quality element to the General
 Plan.

 R-5.   The Air  Quality Maintenance Plan to be formulated for the South
 Coast  Air Basin will  provide the necessary mitigation measures and serve
 as the  air  quality element for the General  Plan.

 6.   I  think that if the EPA wants to be forceful,  they should require
 the County of Orange to adopt a growth policy for at least the southeast
 county, AWMA and SERRA.   Such a policy has been discussed for about
 two years, but nothing has been done.  I also think that lower income
 housing should be provided in the AWMA area as a condition of grant appro-
 val, especially since the Federal government is to become a major employer
of low to moderate income workers.

 R-6.   Refer to R-4.

                            Michael  A.  Schley
                            Laguna  Greenbelt

1.   We are concerned about the validity of AWMA decisions, they may
be in violation of the California Political Reform Act, particularly
Chapter 7, Article  1, entitled "Conflict of Interests."

 R-l.  Administration  of the California Political  Reform Act is the respon-
 sibility of the State of California  and is  beyond the authority of the EPA.
You should address  your comments  on  this matter to  the  Attorney General  of
the State of California.
                                     9-10

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 9.5  COMMENTS RECEIVED DURING THE DRAFT EIR REVIEW PERIOD REQUIRING A
      RESPONSE

United States Federal Agencies

      Department of the Interior, Fish and Wildlife Service - March 31, 1975
      Department of the Interior, Office of the Secretary - April 23, 1975
      Federal Energy Administration - March 13, 1975'
      Federal Energy Administration - March 16, 1975
      General Services Administration - March 25, 1975

State of California Agencies

      Assemblyman, 74th District, Robert E. Badham - March 25, 1975
      California Coastal Zone Conservation Commission - April  14, 1975
      Resources Agency of California - June 9, 1975
      State Water Resources Control Board - April 17, 1975

County of Orange Agencies

      Orange County Environmental Management Agency - March 28, 1975
      Orange County Health Department - March 31, 1975
      Orange County Planning Commission - March 25, 1975

City of Laguna Beach

      City of Laguna Beach, City Council  - April  9, 1975

Quasi-Public Agencies

      Aliso Water Management Agency - April  10, 1975
      Moulton Niguel Water District - March 25, 1975
      Moulton Niguel Water District - April  10, 1975

Private Interest Groups

      The Environmental Coalition, Inc.  - March 19, 1975
      Foothill  Communities Association -  April  2, 1975
      Laguna Beach Taxpayers'  Association - March 14,  1975
      Laguna Beach Taxpayers'  Association - March 25,  1975
      Laguna Greenbelt, Inc.  - March 3,  1975
      Laguna Greenbelt, Inc.  - March 25,  1975
      League of Women Voters  of Orange County - March  25,  1975
      Santiago Heights Property Owners' Association -  March  26,  1975
      Sierra Club, Los Angeles Chapter -  April  15, 1975
      Society for California  Archaeology  - April  16,  1975
      South Laguna Civic Association - March 25,  1975
      Village Laguna - March  25,  1975

Private  Individuals

      Mr.  & Mrs.  Richard A.  Brandwine - March  21,  1975
      Ms.  Marian  Parks - April  11, 1975
      Mr.  Ron Yeo -  March  7,  1975
                                        9-11

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                           UNITED STATES
                 DEPARTMENT OF THE  INTERIOR                  #3 $
                     FISH AND WILDLIFE SERVICE
                         River B.-r,in ''l!"1-:-:;
                         24000 Avi'.-. !  •-'!
                         U^uiia  NLuci, C.; 92577
                                              March 31,  1975
 Regional Administrator
 Environmental Protection Agency
 Region IX
 100 California Street
 San Francisco, CA  94111

 Dear Sir:

 As a result of the March 25th public hearing held at the Laguna
 Miguel Federal Building on the Regional Wastewater Treatment System,
 Aliso Water Management Agency, we now submit the following  comments
 on the proposed project.

 The aforementioned meeting, held to clarify areas of confusion and to
 receive public input, compared favored project  alternatives 1A and 2G
 (2F modified).  Both alternatives will engender serious  harm to the
 biologic resources of Aliso Creek and its tributary area.   This will
 be due primarily to construction of plant site(s)  and alignment(s) of
 interceptor and land outfall pipelines along the creek channel.

We agree with your assessment that alternative  1A will have less serious
 secondary impacts on the biologic resources of  the area.  Clearly, alter-
native 2G is highly growth inducing and development oriented which will
be much more damaging to this fragile environment.   On this basis, we
recommend alternative 1A be the selected plan.

However,  we wish to point out that losses of wildlife habitat will occur
with either alternative.  Losses under alternation 1A are much less in
scope.   Continued coordination during the remaining planning process on
issues such as pipeline location,  creek crossings,  plant siting and other
site specific measures is needed to implement necessary wildlife mitiga-
tion measures.

Should alternative 2G be selected,  a wildlife mitigation plan designed
to replace both primary and secondary losses  incurred should be adopted
as an integral part of the project.
                                  9-12

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                                  - 2 -
We appreciate this opportunity to comment on this project.   Please
advise us of significant planning changes.

                                       Sincerely,
                                       M.  S.  Zschomler
                                       Field Supervisor

MSZrgr

cc: R, 0., RBS, Portland,  OR
                                   9-13

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                              SUMMARY COMMENTS

                          Fish and Wildlife Service
                         Department of the Interior
2.   Losses of wildlife habitat will  be less under Alternative  1A  than
under Alternative 2G.  Specific measures relating to proper site are
necessary to implement wildlife mitigation measures.

R-l.  These are addressed in the specific EIR for the  construction phase
of the project authored by CWC, February 1975.
                                    9-14

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         United States Department of the Interior        ,:^      /j  6 7

                     OFFICE OF THE SECRETARY                     -1^
                      WASHINGTON, D.C.  20240        . ....  •     "'*••'

ER-75/154                                   flpp o •  .••  -c

                                                      REGIONAL inJARiNG CLE»
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 high potential  for  unrecorded  sites  to  exist  also.   Consequently,
 the  project  area  should be  surveyed  by  a  competent,  professional
 archaeologist as  soon  as possible.   The final statement  should  either
 document  that such  a survey has been conducted or contain  definite
 commitments  to  have such an investigation conducted.   Such a  commit-
 ment could be made  by  changing the word "should" to  "will" in the
 first,  second,  fifth,  sixth, and  eighth sentences in the second
 paragraph on page 8-5.

 Since the project area contains a wide  range  of archaeological
 resources uniquely  important to an understanding of  Orange County
 prehistory,  as  stated  in the draft statement,  a detailed set  of
 guidelines and  procedures should  be  developed and instituted  to
 identify, preserve,  and protect as many of these resources as possible.
 All  aspects  of  all  alternatives entailing land modification should
 be surveyed  by  a  professional  archaeologist.   Any significant cultural
 resources which are identified should be  described and evaluated for
 their National  Register of  Historic  Places potential.  If  any sites
 meet the  criteria for  nomination, as set  forth in title  36 CFR  800.10,
 they should  be  nominated to the National  Register, and compliance
 with title 36 CFR 800.4 should be documented.

 The  surveys  and evaluations should be made early in  the  planning
 stages  of the project  so that  the results of  the evaluation and,
 thus, the potential impacts of the various alternatives  upon  signi-
 ficant  cultural resources can  be  incorporated into the decisionmaking
 process for  selecting  the best alternative and for developing final
 designs for  the project.  Other aspects being  equal, we  recommend
 the  alternative that will have the least  impact on cultural resources
 be selected.

 Measures  that will  be  implemented to mitigate  the adverse  effects of
 the  project  on  cultural resources should be fully described in  the
 appropriate  section of the  final  statement.  These measures should
 be designed  to  preserve the greatest amount of information and material
 from the  archaeological resource base.  Therefore, if sites with
 National  Register potential are found to exist in the development
 areas,  there should be mechanisms for deciding whether or  not a
 redesign  or  relocation of the  development might be more  appropriate
 than  salvage excavation.  There should be serious consideration given
 to preservation of  such resources as  opposed to merely salvage.

 Copies of any archaeological reports  obtained should be made available
 to the Arizona Archaeological Center, National Park Service, P.O.
Box 49008, Tucson, Arizona  85717, in accordance with section 3(a)  of
Public Law 93.-291.
                                   9-16

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The draft statement is fairly comprehensive, presenting six alternative
plans for collection, treatment, and disposal of sewage within the
AWMA area.  It is obvious that all of the alternatives would preclude
mineral development in the immediate vicinity of the 15 to 20 miles
of new sewer lines and the 12 or more acres that will be occupied by
a new treatment plant.  However, it appears that mineral resources
in the area have been adequately assessed and would not be adversely
affected by any of the alternatives.  The effects of slope instability
and fault-related earthquakes are also discussed (pages 2-11 to 2-13),
but no estimation of possible damage to new facilities is presented.
An attempt should be made to do this.

Several impacts regarding potential recreation ramifications should be
discussed in greater detail in the final EIS, particularly regarding
the growth-facilitating impacts of the proposed project.

The EIS notes that both construction and operation will adversely
affect recreation activities, but the degree to which these activities
will be affected is never made clear.  We suggest that the final EIS
quantitatively reflect the impact of facilitated growth on existing
recreation facilities, particularly accessible public beach areas.

Specific Comments

Description of Existing Environment—The geology section contains many
technical inaccuracies.  A good reference for geologic formation names
is in the Geological Survey bulletin 1200.  Suggested word changes are:

          P. 2-7. 1st par., line 6, "is" for "would be"
                  last par., line 1, "is" for "would be"

          P. 2-8, 2d par., line 9, should be "welded-tuff"
                  3d par., line 2, should be "Breccia"
                           line 11, should be "glaucophane
                             schists"  (no capitals)
                           line 12, "In some areas" should be
                             substituted for "At times"

          P. 2-9. 1st par., line 5, should be "pectins"
                           line 4, "in some localities" should
                             be substituted for "at times"
                  last par., line 3, should be "terrace"

          P. 2-10, 1st par., line 1, should be "marine terrace"
                               (same in line 12)
                  6th par., line 1, should be "marine terrace
                             deposition"
                                  9-17

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 Geologic time and formation name corrections  on pages  2-7 to 2-10 should
 be:                     ,

      Paleocene Epoch,  Sespe-Vaqueros  Formations,  Topanga Formation,
      Lower Miocene Epoch,  San Orofre  Breccia,  glaucophane schists,
      Monterey Shale, Upper Miocene  Epoch,  Capistrano and Niquel
      Formations,  Oso Member,  terrace,  and  marine terrace.

 Minor discrepancies exist  between geologic ages,  given on pages 2-7  to
 2-10  and on pages 2-54 to  2-56.   For  example,  the oldest formation in
 the area is given as the Paleocene  Silverado  formation on page  2-7,
 but as the Cretaceous  Williams formation on page 2-54.   The  Topanga
 formation is given as  Lower Miocene on page 2-8 (paragraph 2),  whereas
 it is given as Middle  Miocene on page 2-55 (paragraph  2).  The  Monterey
 Shale is given as Upper Miocene on  page 2-9 (line 13),  but is identified
 with  Middle Miocene on page 2-55 (lines 8-10  from bottom).
                                   i
 The sum of the areas covered by the 9  or 10 formations described in
 section 2.3.3 is  165 percent,  indicating that  one or more of the
 figures may be in error.   Possibly  the area occupied by the  Sespe-
 Vaqueros formations was intended to be given  as 7 percent instead of
 72 percent (page  2-7).
                                    j
 The term "Neogene," used on page 2-52  (paragraph 2), was not used
 previously in the discussions  of stratigraphy;  it would be helpful
 to identify the term as equivalent  to  Miocene  and later.

 Wastewater Management  Alternatives-—The proposed  ocean outfall  off
 South Laguna,  as  shown on  the  maps  (for example,  exhibit 3-1 for
 alternative 1A),  is depicted as  approximately  4,000 feet long,  whereas
 the text gives  its  length  as 8,700  feet (page  3-12, paragraph 2).

 Page  3-9,  Section 3.2.1^ Alternative 1A, -  Local Treatment, Regional
 Disposal—Last  paragraph on page 3-10  indicates that the lower  Aliso
 Creek section is  channelized,  and the  resultant relatively sterile
 habitat  will  not  be affected as  significantly  as  the upper stream
 reaches.   Without proper planning,  construction methods, and plant
 operation,  the  possibility exists that  the entire creek could become
 a sterile  ecosystem.  The  statement' should thoroughly discuss specific
 impacts  alternative 1A would have on fish  and wildlife  resources  and
 habitat  in the  upper reaches of Aliso  Creek.

 Unavoidable Impacts.of  the  Proposed Project—Page  6-1,   section  6.0,
 acknowledges  temporary destruction of vegetation.  It is asserted that
mitigative measures would  reduce  impacts to a very low  level.   However,
no mention is made  of how  these  impacts would be  reduced, except by
                                  9-18

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passage of time.  We conclude that there is no contemplated positive
loss-reduction plan for surface vegetation destroyed.  Further,
vegetation loss is not correlated with wildlife habitat values affected.
The statement should discuss whether these areas will be revegetated
and what loss-reduction measures will be implemented.

Relationship Between Local 'Short-Term Uses of the Environment and
Maintenance and Enhancement of Long-Term Productivity—As section 7.2.1
of the EIS indicates, the proposed project will cause land values to
increase throughout the region, a situation which renders future
acquisition of park and recreation lands such as those described in
section 2.8.2 more difficult to achieve, yet all the more necessary
to accommodate the recreation demands of the increased population.
This indirect and unavoidable impact should be recognized in the
final EIS.

Alternative Mitigation Plans to Reduce Potential Adverse Air Quality
Impacts in the AWMA Area—Appendix B-21, mitigation plan 5, discusses
a park-and-ride transit system to recreation beaches.  The implementa-
tion of such a plan might increase beach use, as well as that of
tidepool areas.  Since existing marine life reserves often suffer
overuse and misuse as a function of visitation above the ecosystem's
carrying capacity, and since enforcement of "no collecting" rules is
usually lax, the potential addition of a greater number of users
could pose a hazard to the integrity of the ecosystem.  This mitigation
plan, although reducing atmospheric emissions, does pose other problems
which should be recognized in the final EIS.

                                 Sincerely yours,
              Deputy li—i- ;       Secretary of the Interior
                                 9-19

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                           SUMMARY COMMENTS

                        Office of the Secretary
               United States Department of the Interior
 1.   We suggest  that a more detailed study of the effluent impacts on
 marine life from all ocean outfalls be presented.  With regard to your
 project plans, both the short-term and the long-term impacts of effluents
 upon marine life within and about the marine life refuges and the more
 general coastal  area should be noted.  Although you have presented a
 plan that improves existing conditions, we feel it is important to note
 that there will  be continuing effects upon every level of marine organisms
 in  the outfall areas.

 R-l.  As noted in Section 3.2.1.2.1 of the Draft EIS, there is a limited
 amount of information which will allow exact prediction of effluent
 impacts.  Research work is continuing and may result in future limitations
 on  discharge.  Consequently, compatability with reclamation is being
 stressed.  An ongoing monitoring program is part of the AWMA Project, see
 the NPDES Permit in Appendix C of the Final EIS.

 2.   There should be detailed elaboration on the "temporary destruction
 of  approximately one acre of marine habitat and its organisms" from
 the Aliso Creek  outfall, including possible repercussions from this
 consequence.  Exhibit 2-7 could have been more clearly detailed and
 could have recognized principal currents in the outfall area.

 R-2.  The Draft  EIR prepared by Clean Water Consultants in February
 1975 for the applicant directed itself toward the primary construction
 impacts of the AWMA Project.  We have amended the Draft EIS,  Sections
 2.7.3 and 3.2.1.1.5, however, in response to the above comments.

 3.   There appears tc have been no archaeological survey or investigation
 directly associated with this project.   As pointed out in the Draft
 EIS, the project area is very rich archaeologically and historically.
 The Final EIS should either document that such a survey has been conducted
 or contain definite commitments to have such an investigation conducted.
Any significant, cultural resources which may be identified should
be described and evaluated for their National Register of Historic
Places potential.

 The surveys and evaluations should be made early in the planning stages
of  the project so that the results of the evaluation and, thus,  the
potential impacts of the various alternatives upon significant cultural
resources can be incorporated into the  decision making process for
selecting the best alternative and for  developing final designs  for
 the project.   Other aspects being equal,  we recommend the alternative
 that will have the least impact on cultural resources be selected.

Measures that will be implemented to mitigate the adverse effects of
 the project on cultural  resources should be fully described in the
                                   9-20

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 appropriate  section  of the  final  statement.   These measures  should
 be  designed  to preserve the greatest  amount of  information and  material
 from the  archaeological resource  base.   There should be  serious con-
 sideration given  to  preservation  of such resources as opposed to merely
 salvage.

 R-3.   A field  reconnaissance has  been conducted and coordinated with
 representatives of the State Historic Preservation Office.   The results
 appear in the  Draft  EIR (February 1975)  prepared by Clean Water Con-
 sultants  for the  construction aspects of the  AWMA Project.   EPA rejected
 the treatment  plant  site in Aliso Canyon,  partly because of  archaeolo-
 gical  impact.   EPA will  continue  to coordinate  with the  SHPO.

 As  AWMA develops  new alternative  plans for facilities, on-site  archaeo-
 logical investigations will  be conducted previous to any finalization
 of  those  plans.   Mitigation measure programs  will be coordinated with
 representatives of the Arizona Archaeological Center, National  Parks
 Service,  and the  Archaeological Research Unit of the University of
 California,  Riverside.

 4.    There has been  no attempt in the Draft EIS to describe  the effects
 of  slope  instability and fault-related earthquakes on possible  damage
 to  the new facilities.

 R-4.   Thorough on-site geological  and soils engineering  investigations
 have  been made for Alternative 2G and presented in the Draft EIR (February
 1975)  prepared by Clean Water Consultants.  Construction will comply
 with  all  minimum  standards  set forth  in  Chapter 70 of the Uniform Building
 Code  as new  alternative plans for facilities  develop.  The applicant
 will  consider  all geologic  and soils  constraints  and will comply with
 all local, state  and Federal  requirements.

 5.   Several impacts regarding potential recreation ramifications
 should be discussed in greater detail in the final EIS,  particularly
 regarding the growth-fad litating impacts of the proposed project.

 R-5.  A full, in detail discussion of recreation and the impact  of  future
 populations on recreational  facilities did not appear to be  a significant
 issue in the total perspective of the AWMA Project.   Therefore,  this
 topic was omitted for the sake of brevity.  A complete and thorough
 analysis  of the recreation potential and limitation of the region are
 presented in the Recreation  Element and Preliminary Coastal  Plan prepared
 by the California Coastal Zone Conservation Commission.

 6.   The EIS should thoroughly discuss specific  impacts  Alternative
1A would have on fish and wildlife resources  and habitat in  the  Upper
Reaches of Aliso Creek.

R-6.  There will be  very little direct impact.  The  construction phases
of the project will  be coordinated with  the California  Department of
 Fish and  Game.   A more thorough discussion is  presented  in the Draft
                                 9-21

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 EIR (February 1975)  prepared by Clean  Water Consultants  for  the  construc-
 tion phase of the AWMA project.   Secondary  impacts will  depend on  the
 level  of retention of open space,  which  is  a County  responsibility.

 7.    There is no contemplated positive loss-reduction plan for surface
 vegetation destroyed.  Further,  vegetation  loss is not correlated  with
 habitat values affected.   The EIS should discuss whether these areas
 will be revegetated  and what loss-reduction measures will be implemented.

 R-7.  AWMA intends to coordinate all construction plans  with the California
 Department of Fish and Game.  Measures will  be taken to  revegetate
 all  areas disturbed  and to avoid,  wherever  possible, significant habitat
 and/or plant species.

 8.   As section 7.2  of the EIS indicates, the proposed project will
 cause  land values to increase throughout  the region, a situation which
 renders future acquisition of park and recreation lands  such as those
 described in Section 2.8.2 more  difficult to achieve, yet all the  more
 necessary to accommodate the  recreation demands of the increased popula-
 tion.   This indirect and unavoidable impact  should be recognized in
 the  final EIS.

 R-8.   So noted in the Final  EIS  in Section 7.2.1.

 9.   Appendix B-21,  mitigation plan 5, discusses a park-and-ride transit
 system to recreation beaches.  The implementation of such a  plan might
 increase beach use,  as  well as that of tidepool areas.  Since existing
 marine life reserves often suffer overuse and misuse as a function  of
 visitation above  the ecosystem's carrying capacity, and since enforcement
 of "no collecting" rules is usually lax, the  potential addition of
 a greater number  of  users could pose a hazard to the integrity of the
 ecosystem.   This  mitigation plan,  although  reducing atmospheric emis-
 sions,  does pose  other  problems  which should  be recognized in the  final
 EIS.

 R-9.   As  in  R-5,  a thorough analysis of the  recreation and its potential
 impacts  on  natural resources was presented in the Recreation and Coastal
 Land Elements  and the Preliminary Coastal Plan prepared by the California
 Coastal  Zone  Conservation Commission.  Also,  the intertidal and beach
 habitats  between  San  Clemente and Emerald Bay were surveyed by Dr.  Peter
 S. Dixon  in May and  June of 1972.  He concludes that the  minimal  algal
 flora  and  associated  animal life occurs in those areas subject to maximum
 human  use.  The situation between Goff Island near Laguna Beach and
 Laguna  Lido/Laguna Royale near South Laguna demonstrates  this most clearly.
The total  biomassatthe two ends of the range, furthest away from the
 parking area at Aliso Beach, is  far greater both in quantity and diversity
 than it  is on the two reefs in close proximity to the parking area.
 In view of the impacts of the mass curiosity regarding the subtidal
and intertidal, "one can only be thankful that the peak low tides  in
this area occur during the night or very early morning during the summer
months when there is  likely to be greatest interest in the marine environ-
ment.  Peak tides occur during the day only in the winter  months when
pressure is likely to be minimal  for climatic reasons."
                               9-22

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Due to the physical ownership, inaccessibility or lack of adequate parking
facilities near the shoreline, much of the intertidal zones of the AWMA
region are flourishing.  Most of the inaccessible areas will  remain in good
condition, however, the areas already damaged are already experiencing
heavy recreational use.  Those areas that are now accessible, but are re-
ceiving little use because of parking limitations, would experience heavier
use by implementing a Park-and-Ride transit system.

Only continued protection of the intertidal zone will increase its chances
for survival.  Besides designating areas as marine life refuges as described
in Chapter 2.8 of the EIS, the California Superintendent of Public In-
struction and the Department of Fish and Game have developed  guidelines
to conserve tide-pool resources.  Today, state legislation requires a
permit from the Department of Fish and Game to take tide-pool organisms.
Only those county education offices which adopt plans to conserve tide
pool life and which employ a staff biologist to conduct the program can
qualify.  Uninformed adults and tourists remain the major enforcement
problem.
                               9-23

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                                                                              /t  1
     Ernest E.  Sligh,  Director, ;Einrir0Wjntal Ipact         .March 13,  1975
     Division,  FEA,  Washlngtoa,-,^             "

     Eugene W.  Standley,  Director,
     Development Programs Dovfelon,

     Review of  Draft Errvirotioental Impact Statement  for Aliso
     Water Management  Agency, dated February 14,  1975


 This is in response to your February 24, 1975 request for comments on EPA's
 Aliso Hater Management Agency's Draft Environmental Impact Statement.

 From tiie viewpoint  of energy consumption, the major concern is the secondary
 effect  of projected Vehicle Miles Traveled  (VMT) Increases, resulting from
 population growth in  an  automobile dependent area.  As noted in the statement,
 completion of  the proposed  project may result in 2,370,000 miles per day of
 additional automobile travel in the  area.  This would amount to approximately
 200,000 gallons per day  of  additional gasoline useage.

 Although the mitigative measures indicated in the Statement for reducing VMT
 may be  important for  the conservation of fuel, further analysis of the economic
 impacts should be done.   In particular further explanation of Sections 4.6.1.1
 and 4.6.1.3 should be given.             .     .      .

 A description  of alternative sources of power in the event of interruption
 should  be included in the Statement.  A description of possible ecological
 and economic damage caused  by prolonged power curtailment should also be given.

 As  indicated in the statement the primary effect, of .the proposed project on
 energy  supplies will  center on.electrical energy required to. punp waste water
 from sources to ocean outfalls.    	

 In  addition to fuel consumed, the statement should indicate that this generation
 of  power will result  in approximately 109^.000 Ibs of particulates,, 1,065,000 Ibs
 of  SO  (with 0.57. S oil), 27,240 Ibs of hydrocarbons, and 1,426,000 Ibs of N02
 to  berreleased  into the air over the life of  the project.
                                         Eugene W. Standley
Copy furnished:
EPA, Region IX, Mr. F. Covingtqn
100 California St.
San Francisco, CA  94111
                                        9-24

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                           SUMMARY COMMENTS

                     Federal Energy Administration
                             March 13, 1975

I.   The secondary effect of projected Vehicle Miles Travelled (VMT)
is a major concern relative to energy consumption.  Additional gasoline
usage will amount to 200,000 gallons per day of additional gasoline
usage.

R-l.  So noted in the Final EIS.

2.   Alternate sources of power should be described.  A description
of possible economic and ecological damage caused by prolonged power
curtailment should be included.

R-2.  The State of California Water Resources Control Board requires
standby power to all treatment plants and pump station facilities.
AWMA fully intends to comply with this requirement.   In many cases  several
alternative electrical  substations may be utilized and in others  local
generators powered by gasoline or kerosene will  be available.

Potential impacts due to power failures depend on the source of the
failure and the facility in question.  If both sources of power fail
at the treatment plant level, the worst case situation would be disposal
of primary treated sewage (without disinfection) into the outfall.
If all sources of power failed at an interceptor pump station, raw  sewage
would be discharged into the stream water drainage system or natural
drainage course.  A potential health hazard could be created and  short-
term impacts on the biota of the drainage course would also result.

3.   The primary effect of the proposed project  on energy supplies  will
be the electrical energy required to pump wastewater from sources to
ocean outfalls.

R-3.  So noted in the Final EIS.

4.   This generation of power will result in approximately 109,000  Ibs
of particulates, 1,065,000 Ibs of SO(2)  (with 0.5% S oil), 27,240 Ibs
of hydrocarbons, and 1,426,000 Ibs of NO(2)  to be released into the
air over the life of the project.

R-4.  So noted in the Final EIS, but these figures will  vary as power
usage varies with the alternatives.
                                   9-25

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               FEDERAL ENERGY ADMINISTRATION        ApR - fi

                         WASHINGTON, D.C. 20461

                                                              REGION DC
                             APR  i 6 1^/5        OFFICE OF THE ASSISTANT ADMINISTKAWK
 FEA. 75-55
 Mr. Paul De Falco, Jr.
 Regional Administrator
 Environmental Protection Agency
 100 California Street
 San Francisco, California  94111

 Dear Mr. De Falco:

 This is in  response to your request for review and comment on the
 draft environmental impact statement for the Aliso Water Management
 Agency Regional Wastewater Treatment System, Orange County, California.

 Our comments are presented according to subject.

 Energy Consumption

 The major concern is the secondary effect of projected Vehicle Miles
 Traveled (VMT) increase resulting from population growth in an auto-
 mobile dependent area.  As noted in the statement, completion of the
 proposed project may result in 2,370,000 miles per day of additional
 automobile  travel in the area.  This would amount to approximately
 200,000 gallons per day of additional gasoline usage.  Although the
 mitigative measures indicated in the statement for reducing VMT may
 be important for the conservation of fuel, further analysis of the
 economic impacts should be done.  This additional explanation could
 be incorporated in sections 4.6.1.1 and 4.6.1.3 which discuss miti-
 gating measures associated with transportation.

 The primary effect of the proposed project on energy supplies will
 center on electrical energy required to pump wastewater from sources
 to ocean outfall.

 Alternative

A description of alternative sources of power in the event of inter-
 ruption should be included.  A description of possible ecological
 and economic damage caused by prolonged power curtailment should be
given.           :
                                 9-26

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                                  -2-
We hope these comments will be helpful in the preparation of the final
environmental statement and in your further consideration of this
project.
                                  Sincerely
                                    jer W. Sant
                                  Assistant Administrator
                                  Energy Conservation and Environment
cc:  Eugene W. Standley
     EEA, Region IX
                                  9-27

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                         SUMMARY COMMENTS

                   Federal Energy Administration
                          April 16, 1975
1.   Further analysis is needed of economic impacts of the mitigation
measures which have been suggested to reduce VMT.

R-l.  Refer to Section 4.6.3 in the Final EIS.

2.   Alternate emergency sources of power should be discussed.   A des-
cription of possible ecological and economic damage caused by prolonged
power curtailment should be included.

R-2.  See R-2 in a letter received from the FEA on March 13,  1975.
                               9-28

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                      UNITED STATES OF AMERICA
               GENERAL SERVICES ADMINISTRATION

                                          Public Buildings Service
                                           Washington, DC   20405



                                               REGIONAL"I.IJ.A;u.:.-, c:^;nK

MAR 9 5 1975                                        APR C   1975

                                                      REGION IX
Mr. Paul De  Falco, Jr.
Regional Administrator
Environmental Protection Agency
100 California Street
San Francisco, California  94111

Dear Mr. De  Falco:

We have reviewed the draft environmental  impact  statement dated
February 14, 1975, for the Aliso Water Management Agency  Regional
Wastewater Treatment System.  The following comments are  offered
for your consideration in the preparation of the final environmental
impact statement for this action.

     1.  Discussion of the fourth mitigation measure, proposed
         construction of a new town around the Federal Building
         at  Laguna Miguel (p. 4-23  and Appendix  B-rl5 to B-21),
         contains some dangerous generalizations and misstatements,
         in  addition to the obvious errors of calling GSA the
         "Government Services Administration" and omitting the
         footnote to which the asterisk on page  B-15 refers.
         The Regional Office of GSA was not contacted for input
         to  this statement, nor for updating of  information
         contained in our own final impact statement on occupancy
         of  the Federal Building, which was published in April  1974.
         Neither GSA nor EPA can say at this time whether or not
         most of the employees who  will be working in the Federal
         Building in the future are now working  in the Los Angeles
         area.  As regards housing, GSA with the cooperation  of
         the Department of Housing  and Urban Development certainly
         does plan to develop the necessary housing  at the
         appropriate cost level and within a reasonable commute area,
         The housing situation even today is not so  unfavorable
         that any employees in our  building are  forced to commute
         50 miles to work.
              Keep Freedom in Tour Future With U.S. Savings Bonds

                                    9-29

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          2.  You have oversimplified the social and economic implications
              of your proposed planned community and have apparently
              ignored the good faith proposals made by GSA regarding
              mitigation of possible adverse impacts connected with
              occupancy of the Federal Building.

     If you would like additional information, please contact Arthur 0. Barton,
     Regional Commissioner, Public Buildings Service, GSA at (415)556-0882.
     Sincerely,
r
 y*  Director
     Environmental Affairs
                                        9-30

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                         SUMMARY COMMENTS

                  General Services Administration
1.   Information on page 4-23 and Appendix B-15 to B-21 needs to be
updated to reflect the April 1974 final impact statement on occupancy
of the Federal Building.

R-l. The information on the GSA facility appearing on page 4-23 has been
deleted and added to an updated and expanded discussion in Appendix B,
pages 12 and 13.

2.   The social and economic impacts of the proposed planned community
have not been fully addressed.  This proposal does not take into account
the GSA's proposals for mitigating adverse impacts connected with the
occupancy of the Federal Building.

R-2. The new community plan was an option presented by the applicant.
EPA does not endorse this concept; however, we have updated the dis-
cussion in the Final EIS.
                                9-31

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 STATEMENT 3Y ASSEMBLYMAN ROBERT E. BADHAM
 To be delivered March 25,  1975


      As the 'Assemblyman representing the Aliso Water Management

 Agency,  which lies completely within the 74th Assembly District,

 and because of my previous work with the Assembly Water Committee,

 I  am acutely aware of the  three-year planning process of the

 Agency's Regional Wastewater Treatment system,  as well as the

 rapidly escalating costs.   The Environmental Protection Agency

 states  that sewage facilities do not control growth.   These

 facilities  are to provide  service for the approved land use

 within  the  AWMA area.   The delays in construction are costing

 the  taxpayers approximately one-half million dollars  each month

 in  terms of increasing construction  costs.

      The proposal by  the Aliso Water Management  Agency to

 construct Plan 2-G has the lowest total  cost and the  lowest

 operation and  maintenance  cost which will be borne by the Orange

 County taxpayers.   Fu^^feher,  the proposed  project is in compliance

with  the  State  of  California  Basin Plan.

      The overwhelming  majority of residents  have expressed their

will, both  in  obligating themselves  financially  through the

authorization  of  general obligation  bonds and by public community

endorsement.
                              J.-J  i'j /?>H. y(v\ c.;-;- i7:tt.'t
      The people have spoken.   The Aliso Water Management  Agency's

Regional Wastewater Treatment  Facilities  should  be  constructed

now, without further delay.

                               #####
                                 9-32

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                           SUMMARY COMMENTS

                     Assemblyman Robert E. Badham
I.   The majority of residents, by authorizing general obligation bonds
and by public community endorsement, have expressed support for the AWMA
regional wastewater treatment system.

R-l.  Several of the bonds went by property holder vote, not popular vote.
Members of AWMA are one of two types of water districts:  county munici-
pal, or California.

County or municipal water districts:  only residents may vote and each
resident has one vote.  Laguna Beach, South Laguna Sanitary District,
and the Emerald Bay Service District are all of this type.

California water districts:  only landowners may vote, residency is not
a prerequisite, and the numbers of votes each landowner has is based
upon the assessed value of his property.  The Moulton-Niguel Water Dis-
trict, Los Aliso Water District, El Toro Water District, and Irvine Ranch
Water District are so organized.
                                  9-33

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STATE OF CALIFORNIA	•	EDMUND G. BROWN JR., Governor

CALIFORNIA  COASTAL ZONE CONSERVATION  COMMISSION
1340 MARKET STREET, 2nd FLOOR
SAN FRANCISCO, CALIFORNIA 94102
PHONE: (413) 337-1001
                                           April 14, 1975
             Mr. Paul De Falco
             Regional Administrator
             Environmental Protection Agency
             100 California Street
             San Francisco, California  94111

             Gentlemen:

                  We are responding to your letter of February 14,  1975,  requesting
             comments on the draft Environmental Impact Statement for the Aliso
             Water Management Agency, Regional Wastewater Treatment System.
             Detailed comments on the EIS are enclosed.  It should  be emphasized
             that the following comments are from the staff and have not  been
             formally acted upon by the Commission; but although these reflect
             only the views of the staff, the comments result from  a comparison
             with adopted Commission plan policies and previous permit actions of
             the Commission*

                  Because of our concern over the rate and distribution of rapid
             population growth in Southern Orange County and its impact on the
             resources of the coastal zone, the Coastal Commission  limited the size
             of the Aliso Ocean Outfall when we gave it a construction permit in
             Junef 1973.  We remain concerned about the potential for rapid popula-
             tion growth in the AWMA service area; at least encouraged or accomo-
             dated by and to some extent stimulated by the regional project.  EPA
             has begun to come to terms with this problem and proposes measures to
             mitigate the impacts.  The Coastal Commission supports measures to
             mitigate the entire impact of the Aliso project, and feels that the
             mitigation measures should be clearly indicated in the final EIS.

                  The Coastal Commission prefers the modified Alternative 1A to
             Alternative 2G because it avoids further commitment of open  space in
             Aliso Canyon and because it does not include any new sewer interceptors•
             The South Coast Regional Commission has identified Aliso Canyon and the
             surrounding area that remains undeveloped as an important wildlife habi-
             tat and open space resource of the coastal zone.  As such it deserves
             protection.

                  However, before this alternative is implemented,  a firm commitment
             to mitigate all air quality impacts is needed.  No Federal funds should
             be expended to subsidize urban expansion unless firm commitments are
             obtained from local governments to at least mitigate,  if not eliminate,
             the environmental impacts of such urban expansion on coastal resources.
             In terms of how mitigation measures should be enforced,  the  Commission
                                            9-34

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Mr* Paul De Falco
Apri],  14,  1975
page two
 staff has found that a continuing degree of control is necessary to
 provide for unforeseen changes in circumstances.  This is particularly
 true in an area impacted by so many different governmental agencies and
 under such development pressure as the AWMA service area*  The staff
 would suggest that no new hookups to the sewer system be permitted
 until the mitigation measures have been specifically approved and all
 of the affected governmental agencies have formally agreed to them.
 The authority to stop further hookups in the event that the agreed to
 mitigation measures are not implemented may also be necessary.
Detailed Comments on the Aliso ECS

     1,  Maintenance of Aliso Creek and Aliso Canyon as coastal open
space,^watershed, and wildlife habitat is a high priority of the Coastal
Commission's Regional Plan for the AWMA area.  Therefore, we feel that
the alternative selected should not require any additional treatment
plant sites within Aliso Canyon,  Similarly, any alternative should not
require road construction in the Canyon,

     2,  We remain concerned about the size of the project because of
the impact on coastal resources such as air quality, wildlife habitats,
agricultural lands, scenic areas and coastal recreation areas and access
to them from major population increases in Southern Orange County,
Methods are tentatively proposed to mitigate the air quality impacts of
the project, but the sizing of the various elements is never made clear,
A graphic representation of the total treatment, interceptor, and out-
fall capacity of the various alternatives would make it possible to
compare the secondary impacts of the alternatives on coastal resources—
as well as demonstrate consistency with the Coastal Commission8s
restriction on the sizing of the Ocean Outfall,  At the present time,
the EES does not make it clear the terms of the Commission permit will
be complied with.  Since the project will increase VMT in an area
where decreases in VMT are needed to prevent the degradation of coastal
air quality as well as energy conservation goals adopted by the Coastal
Commission, the alternative with the least VMT increases should be
selected.  In addition, mitigation measures to reduce VMT increases
should be required.  This would be an important first step in developing
an Air Quality Maintenance Plan that should be required as a condition
to grant approval.

     We are particularly interested in the concept of non-extension of
trunk sewers.  Additional analysis of this measure is needed.  Speci-
fically, the wildlife, recreational, and most importantly, the
agricultural potential of various areas where development is planned
should be assessed as well as additional pressures on coastal access
routes and beaches.  Extension of sewers, water supplies and roads into
these areas would not be consistent with Coastal Commission planning
and with the urgent need to achieve air quality standards.  Non-extension
                             9-35

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Mr. Paul De Falco
April114? 1975
page three
could also prevent the snowballing effect of improvements, discussed
in the impact statement.  Initial improvements tend to financially
force development of an area—particularly if funded by improvement
districts.  Avoiding this could prevent committing resource areas to
urbanization and preservation of the remaining coastal resources of
the area.

                                  Sincerelyf
                                  E.tfACK SCHOOP,  AIP
                                  Chief Planner
                             9-36

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                         SUMMARY COMMENTS

          California Coastal Zone Conservation Commission

1.   The sizing of the various elements of each alternative should
be made clear.  This would aid in comparing the secondary impacts
of the alternatives upon coastal resources, as well as compliance
with the terms of the Coastal Commission permit.

R-l.  Refer to expanded discussion on consistency with conditions
in Chapter 3 and 4 of the Final EIS.

2.   We are particularly interested in the concept of non-extension
of trunk sewers.  Additional analysis of this measure is needed.

R-2.  An expanded discussion on the secondary impacts of each alter-
native has been added to Chapter 4.0 of the Final EIS.
                               9-37

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CL*'-IRE T.  DEDRICi:
     HXKXXDEUB
      SECRETARY
Depa iment of Conservation
Depa tmenl of Fiih and Gam*
Depa tmenl of Navigation and
 Ocean Development
Oepo iment of Porks end Recreation
Depo tmenl of Water Resources
EDMUND G. J3SOWN JR.
     XIQffiDSlCXKEJSSJSMX
       GOVERNOR OF
        CALIFORNIA
A 68
                          THE RESOURCES AGENCY OF CALIFORNIA
                                      SACRAMENTO, CALIFORNIA
       OFFICE OF THISECRETARY
         RESOURCES BUlOJmO
          1416 NINTH STREET
              95814
                                           Air Retourcet Board
                                           Colorado Rlv«r Board        ,
                                           Son Francisco Bay Conservation and]
                                           Development Commission
                                           Stot« Lands Commission
                                           State Reclamation Boor4
                                           Stal* Water Resources Control. Board
                                           Regional Water Quality Control Board|
                                          JUN  91975
     Mr. Paul  De Falco, Jr.
     Regional  Administrator
     U. S.  Environmental Protection Agency                                         r     .
     100 California Street                                                          -     -
     San Francisco, California   94111                                              _^~    ~.:

     Dear Mr.  De Falco:

     The State of California has reviewed the "Draft Environmental  Impact Statement:
     Regional  Waste Water Treatment System, Allso Water Management  Agency", which was
     submitted to the Office of Planning and Research (State Clearinghouse) in the
     Governor's Office In accordance with Part II of the U. S. Office  of Management
     and Budget Circular A-95 and the National Environmental Policy Act of 1969.

     The State's review was coordinated with the Departments of Commerce, Conservation,
     Pish and  Game, Pood and Agriculture, Health, Navigation and Ocean Development,
     Parks  and Recreation, Transportation, and Water Resources; the Air Resources Board;
     the Coastal Zone Conservation Commission; the  Colorado River Board of California;
     the Solid Waste Management Board;  and the State Water Resources Control Board.

     The State's general comment is presented below, and specific comments as they
     relate to the various areas of concern are attached.

     In general, the report needs more  information  on various areas of concern such as
     description and impacts, air resources, solid  waste, planned facilities, geology,
     cultural  resources, and fish and wildlife.  The attachment will elaborate on some
     of these  areas of concern.

                                                    Sincerely,

                                                    CLAIRE T. DEDRICK
                                                    Secretary for Resources
     Attachment
     cc:  Director of Management Systems
          State Clearinghouse
          Office of  Planning and Research
          lUOO Tenth Street
          Sacramento,  California  9581^
            (SCH Ho.  T5030U8)
                                               9-38

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                         Specific Comments on the
                   Draft Environmental Impact Statement
                   Regional Waste Water Treatment System
                        Aliso Water Management Agency
These comments on the specific areas of concern are an integral part of the
State's comments.

Description and Impacts

The description of the existing waste water treatment facilities of the Los
Alisos Water District is not up to date.  The District is now bypassing the
activated sludge units and is using a series of three oxidation ponds for
treatment of the sewage.  Because these ponds provide better treatment, the
District does not plan to use the activated sludge process again soon.

The impact of Alternative 3C on the ground water basin is not similar to
that of Alternative 1A, since there will be more reclamation and discharge
to Aliso Creek in the dry season.  The impacts of Alternatives 2F and 2G are
not at all similar to Alternative 2E.  Alternative 2E would have limited
reclamation and Alternatives 2F and 2G would have extensive reclamation proj-
ects.  In the last two alternatives, the ground water basin would be recharged
with reclaimed sewage effluent, which would be coupled with ground water
extraction in the lower portion of the Aliso ground water basin.

In general, the impact of waste water disposal on the ground water in all
the alternatives is not adequately described.

Cultural Resources

The Draft Environmental Impact Statement (EIS) fails to adequately identify
and evaluate the cultural resources within the area of the undertaking's
potential impact, as is required by the National Historic Preservation Act of
1966 and Executive Order 11593.

Because an assessment of the cultural resources must be provided prior to
Federal Agency decision concerning an undertaking, we endorse the statement
on page 8-5 of the EIS that a "field reconnaissance is necessary since not
all areas have been thoroughly investigated, particularly with regard to
buried deposits.  Once specific locations or specific alternatives have been
established, a systematic survey should be made to assess the impact of
construction.  Therefore, indirect effects may be partially mitigated by long-
range planning for the District as a whole".

Survey reports prepared by qualified archeologists, architects, and historians
providing information and recommendations regarding cultural resources in the
project area should be coordinated with Parks and Recreation.  Consultation  •
with the State Historic Preservation Officer is recommended, in accordance
with the Advisory Council Procedures pursuant to 36 CFR Part 800.
                                    9-39

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Fish and Wildlife

The EIS is inadequate in its presentation of three major areas in regard to
fish and wildlife.

In the first Instance, the BIS is inadequate in its discussions of both the
project Impacts on fish and wildlife resources and public use disruption
resulting from restricted parking near the Wildlife Conservation Board's pier
at Alloo Reach during construction.  Tb be considered adequate, each project
alternative should include a more thorough discussion of impacts relative to
acreage disturbed, habitat type, and dependent wildlife.  The EIS should also
better describe the percentage of area presently used for parking at Aliso
Beach that will be needed for equipment parking during project construction.

Second, the EIS fails to discuss, for all alternatives, mitigation of project
impacts to fish and wildlife from pipeline crossings of Aliso Creek and from
construction of the Regional Treatment Plant within the flood plain of Aliso
Creek.  Mitigation measures such as the following should be discussed for all
alternatives:

     1.  Disposal of project effluent through watersheds and streams for
         maintenance and enhancement of existing riparian vegetation.

     2.  Disposal of project effluent through watersheds and creeks for
         reestablishment (Aliso Creek mouth) or enhancement (Upper Newport
         Bay) of coastal wetlands.

Cost information should be included where it affects feasibility of implementation.

Last, the EIS fails to give complete consideration to an alternative that we
believe would be beneficial to fish and wildlife yet still economical and prac-
tical for the project sponsor, the separation of the Aliso Water Management
Agency (AWMA) into two service areas.  The upper, or easterly, service area,
would Include Los Alisos and El Toro Water Districts.  Their combined effluent,
if adequately treated, could be introduced into San Diego Creek.  This would
benefit fish and wildlife through the enhancement of stream end riparian habi-
tat.  Another positive benefit would be the potential for enhancement of
estuarine habitat within Upper Newport Bay.  In addition, part of the effluent
could be introduced into Aliso Creek, thereby enhancing riparian vegetation in
its upper reaches.

The lower, or westerly, service area would include the Moulton-Niguel Water
District and South Laguna Sanitary District and the City of Laguna Beach.
Moulton-Niguel's effluent could be introduced into Aliso Creek near each plant.
The City of Laguna Beach and South Laguna Sanitary District could pump their
effluent directly into the middle reaches of Aliso Creek or to a regional
treatment plant, thence to Aliso Creek.  Such use of adequately treated
effluent, rather than piped conveyance to the ocean, would provide benefits
to fish and wildlife by enhancement of stream and riparian habitat as well
as development of an coastal wetland at the mouth of Aliso Creek.

Air Resources

The Air quality impact of the proposed project was extensively discussed in
the EIS.  The present air quality in the AWMA area is among the worst in the
State, has a high potential for adverse conditions, and is a serious problem.
                                      9-40

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The EIS points out that "... the solution seems to lie in reducing the total
vehicle miles traveled (VMT) within AWMA."  The Air Resources Board (ARE)
agrees with this conclusion.  However, this would necessitate land use plan-
ning and development of alternative transportation models, which are not
within the power of AWMA to implement.  AWMA has some power, however, to par-
ticipate in enforcing implementation strategies.

The EIS presents six mitigation measures and associated implementation strat-
egies, which, if implemented, would reduce projected VMT.  These measures are
promising proposals and need to be developed and appropriately implemented so
that the proposed regional waste water treatment and disposal system will not
adversely affect air quality.

The project needs to comply with all environmental laws.  40 CFR 35.925-14
(published 2/11/74) states that sewage collection systems "... will comply
with all pertinent requirements of the Clean Air Act and other applicable
Federal, State, and local environmental laws and regulations."  This may be
done through the implementation of the previously mentioned mitigation mea-
sures.

In the next two years the ARE, in cooperation with local government, will
participate in the development of an air quality maintenance plan for those
areas in which growth and development are projected to prevent either the
attainment or, if attained, the maintenance of the national, ambient air qual-
ity standards in the next ten years.  The air quality impact of the Allso
project on the jurisdictions in the AWMA needs to be mitigated.  Air quality
considerations, such as the proposed mitigating measures, must be integrated
with the local land use and regional transportation planning to demonstrate
that attainment and maintenance of the standards will not be interfered with
by the proposed project.  To limit detrimental air quality to the area, this
project needs to be conditioned along the lines of the clean water grant con-
ditions now being worked out among the State Water Resources Control Board,
EPA, and ARB.  This is necessary if government is to carry out its responsi-
bility in protecting the public health from the continued effects of polluted
air as well as polluted water.

Solid Waste                                  ^

No mention is made of the method of disposal of sludge that will be produced
by this project.  The quantity of sludge and the impacts related to sludge
disposal should be assessed, and such action should be coordinated with the
local agency responsible for solid waste management.

The disposal of solid wastes generated during the construction phases of
this project should also be discussed.  We recommend that all such wastes be
disposed of properly within the project area or in an approved solid waste
disposal site.
                                    -3-

                                    9-41

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Planned Facilities

The lilS contains all information required by the State Water Resources Control
Board Environmental Impact Report and Public Participation Guidelines of July
1973.  However, several points in the report are unclear.  These relate primar-
ily to planned facilities and resulting secondary impacts.  Specific comments
and questions are set forth below:
                    ii
     1.  The recommended Alternative 2G envisions the construction oC a new
         regional plant Just north of the existing South Laguna Sanitary
         District plant.  To avoid disturbing the land along Aliso Creek, the
         applicant is urged to evaluate Alternative 1A (modified), which calls
         for expanding the existing facilities to handle 10.2 MGD.

     2.  Page 3-18, Service road — Is it necessary to construct a service road
         with a 50-foot right of way along Aliso Creek between the proposed
         regional treatment plant and the Alicia Parkway?  The possible second-
         ary impacts, such as land development, along the proposed road should
         be discussed.

     3.  The recommended Alternative 2G (Exhibit 3-13) shows a raw sewage
         interceptor, sized at 20 MGD, extending down Aliso Creek to the pro-
         posed regional treatment plant, designed for 16 MGD.  The secondary
         impacts produced by such an oversized interceptor traversing unde-
         veloped land should have been directly addressed.

     4.  Energy Conservation — The amount of energy required by each alterna-
         tive has been adequately covered.  However, no mitigation measures
         to reduce energy consumption have been put forth pursuant to Amend-
         ments to the State Guidelines, Appendix F, dated December 26, 1974.
         For example, if the sludge is to be digested anaerobically, consid-
         eration should be given ,to using the gas that is generated for heat-
         ing the digester and providing energy for pumps.
                    , ji
As a funding agency, the State Water Resources Control Board reserves the right
to make further comments on the EIS prior to granting an approval, pursuant
to the Clean Water Grant regulations.

Geology             '

The general geologic, seismic, and soils information given may be adequate for
the regional environmental impact statement.  However, construction should not
be allowed until a thorough on-site geological soils engineering investigation
of the site is made.

We recommend that:  complete detailed geologic and soils feasibility of speci-
fic sites be demonstrated.  Construction should comply with the minimum stan-
dards set forth in Chapter 70 of the Uniform Building Code.

It is also recommended that the geologist and engineer making the investiga-
tion clearly identify his work and attach his signature and state registration
or certificate number.
                                     -4-
                                      9-42

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                          SUMMARY COMMENTS

                The  Resources Agency of California

 1.    The  description of the existing waste water treatment facilities
 of  the  Los Alisos Water District is not up to date.  The District is
 now bypassing the activated sludge units and is using a series of three
 oxidation ponds for  treatment of the sewage.  Because these ponds provide
 better  treatment, the District does not plan to use the activated sludge
 process in the near  future.

 R-l.  So  noted and incorporated into Chapter 1.2.3 of the Final EIS.

 2.    The  discussion  of comparative water valuation potentials of each
 project alternative  is unclear.  Also, the impacts of ground water
 quality by recharge  with  sewage effluent in all alternatives is not
 adequately described.

 R-2.  The discussion on water reclamation has been expanded in the
 Final EIS in Section 3.2.1.4.

 Predicting the precise impact of reclamation on groundwater is extremely
 complex and depends  upon  accurate knowledge of groundwater quality,
 hydrology, and the various sources of pollutants and salts.  Existing
 information on the various sources of salts was not sufficient to
 allow accurate prediction of the effects of reclamation.  Estimates
 could be  made  of the amounts of various salts introduced into the
 groundwater by the various alternatives, but unless overall salt loads
 are known, resultant groundwater quality cannot be predicted.  The
 groundwater basins are fairly small and already contain high levels
 of  salt from past irrigation.  Because of this, and the lack of present
 or  potential domestic use of groundwater, detailed assessments of
groundwater quality impacts are not felt to be necessary.

 3.    The  Draft Environmental Impact Statement (EIS) fails to adequately
 identify  and evaluate the cultural resources within the area of the
 undertaking's  potential impact as is required by the National Historic
 Preservation Act of  1966  and Executive Order 11593.

 Because an assessment of  the cultural resources must be provided prior
 to  Federal Agency decision concerning an undertaking, we endorse the
 statement on page 8-5 of  the EIS that a "field reconnaissance is necessary
 since not all  areas  have  been thoroughly investigated, particularly
 with  regard to buried deposits.  Once specific locations or specific
 alternatives have been established, a systematic survey should be made
 to  assess the  impact of construction.  Therefore, indirect effects
 may be  partially mitigated by long-range planning for the District
 as  a  whole."

 Survey  reports prepared by qualified archaeologists, architects, and
 historians providing information and recommendations regarding cultural
 resources in the project  area should be coordinated with Parks and
 Recreation.  Consultation with the State Historic Preservation Officer
 is  recommended, in accordance with the Advisory Council Procedures
 pursuant  to 36 CFR Part 800.
                                 9-43

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 R-3.  A field reconnaissance has been conducted and  coordinated  with
 representatives of the State Historic Preservation Office.   The  results
 appear in the Draft EIR (February 1975)  prepared by  Clean Water  Con-
 sultants for the construction aspects of the AWMA Project.   EPA  rejected
 the treatment plant site in Aliso Canyon, partly because of archaeologi-
 cal impact.   EPA will  continue to coordinate with the  SHPO.

 4.   The EIS is inadequate in its discussions of the specific impacts
 of each alternative on the fish and wildlife resources and  public  use
 disruption at Aliso Beach Pier during construction.

 R-4.  The EPA EIS deals primarily with the secondary impacts of  the
 AWMA Project.  Since the construction of the ocean outfall  is common
 to all  the alternatives, the specific impacts are discussed in the
 Draft EIS (February 1975) prepared by Clean Water Consultants for  the
 construction of the regional  treatment facilities.

 5.   The BIS fails to  discuss,  for all alternatives, mitigation  of
 project impacts to fish and wildlife from pipeline crossings of  Aliso
 Creek and from construction of the Regional  Treatment  Plant  within
 the flood plain of Aliso Creek.   Mitigation  measures such as the following
 should be discussed for all alternatives:

 1.   Disposal of project effluent through watersheds and streams for
      maintenance and enhancement  of existing riparian  vegetation.

 2.   Disposal of project effluent through watersheds and creeks  for
      reestablishment (Aliso Creek mouth)  or  enhancement (Upper Newport
      Bay)  of coastal wetlands.

 R-5.  Alternative 3C did consider reclamation and would have  involved
 stream  discharge which  would  have benefited  riparian habitat.  Stream
 discharge is  opposed by the  San Diego  Regional Water Quality  Coastal
 Board unless  nutrients  are  removed.  Nutrient removal  increases  treatment
 costs from about $200-300 per million  gallons to $600  or more per million
 gallons;  well  over  the  cost of potable water  in the area.   Such  increases
 can  only  be justified where significant wildlife habitat depends on
 discharge.   Future  habitat  in Aliso  Creek  depends largely on  imple-
 mentation  of  the  County's open space plan.

 6.    The  EIS  fails  to give complete  consideration to an alternative
 that  we believe would be beneficial  to fish and wildlife yet still
 economical and practical for  the project sponsor, the separation of
 the Aliso  Water Management Agency  (AWMA)  into two service areas.   The
 upper, or  easterly, service area, would include Los Alisos  and El Toro
 Water Districts.  Their combined effluent if adequately treated,  could
 be introduced into San Diego Creek.  This would benefit fish and wildlife
 through the enhancement of stream and riparian habitat.  Another positive
 benefit would be  the potential for enhancement -of estuarine  habitat
 within Upper Newport Bay.  In addition, part of the effluent could
be introduced into Aliso Creek, thereby enhancing riparian  vegetation
 in its upper reaches.
                                9-44

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The lower, or westerly, service area would include the Moulton-Niguel
Water District and South Laguna Sanitary District and the City of Laguna
Beach.  Moulton-Niguel's effluent could be introduced into Aliso Creek
near each plant.  The City of Laguna Beach and South Laguna Sanitary
District could pump their effluent directly into the middle reaches of
Aliso Creek or to a regional treatment plant, thence to Aliso Creek.  Such
use of adequately treated effluent, rather than piped conveyance to the
ocean, would provide benefits to fish and wildlife by enhancement of
stream and riparian habitat as well as development of a coastal wetland
at the mouth of Aliso Creek.

R-6.  EPA agrees.  This alternative was considered in Alternatives 4A
and 4C; however, such a practice was opposed by the Santa Ana Regional
Water Quality Control Board.  See number 5, above.

7.   No mention is made of the method of disposal of sludge that will be
produced by this project.  The quantity of sludge and the impacts related
to sludge disposal should be'assessed, and such action should be coordinated
with the local agency responsible for solid waste management.

R-7.  Final sludge treatment and disposal methods have not been determined
because of the siting problem.  Refer to Chapter 5 of the Final EIS
for further discussion.

8.   The disposal of solid wastes generated during the construction
phases of this project should also be discussed.  We recommend that
all such wastes be disposed of properly within the project area or in
an approved solid waste disposal site.

R-8.  Environmental  impacts of the construction phases of the AWMA
Project are discussed in a Draft EIS (February 1975) prepared by Clean
Water Consultants.

9.   The recommended Alternative 2G envisions the construction of a
new regional plant just north of the existing South Laguna Sanitary
District plant.  To avoid disturbing the land along Aliso Creek, the
applicant is urged to evaluate Alternative 1A (modified), which calls
for expanding the existing facilities to handle 10.2 mgd.

R-9.  Alternative 2G has been rejected by the EPA and a facilities plan
addendum is proposed to determine the appropriate solutions for inland
AWMA (See Chapter 5.0 of the Final EIS).

10.  Is it necessary to. construct a service road with a 50-foot right
of way along Aliso Creek between the proposed regional treatment plant
and the Alicia Parkway?  The possible secondary impacts,  such as land
development, along the proposed road should be discussed.

R-10.  Since the regional treatment plant site in Aliso Valley was re-
jected by EPA, the service road proposed has been deleted from the
project.
                                    9-45

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 II.   The recommended Alternative  2G  (Exhibit 3-13) shows a raw sewage
 interceptor,  sized at  20 mgd,  extending down Aliso Creek to the proposed
 regional treatment plant, designed for  16 mgd.  The secondary impacts
 produced by such an oversized  interceptor traversing undeveloped land
 should have been directly addressed.

 R-ll.   Although  Alternative 2G has already been rejected by EPA, this
 interceptor was  sized  to provide  for servicing the AWMA area to 1995.
 The  regional  treatment plant site was to be expanded to a capacity of
 2.4  mgd in  1985.   The  secondary impacts for this sizing is discussed
 in Chapter  4.0.

 12.   The amount  of energy required by each alternative has been adequately
 covered.  However,  no  mitigation  measures to reduce energy consumption
 have been put forth pursuant to Amendments to the State Guidelines,
 Appendix F, dated December 26, 1974.  For example, if the sludge is
 to be digested anaerobically,  consideration should be given to using
 the  gas that  is  generated for  heating the digester and providing energy
 for  pumps.

 R-12.   Final  sludge treatment  and disposal methods have not been determined
 because of  the siting  problem.  Refer to Chapter 5 of the Final EIS
 for  further discussion.

 13.   The  general  geologic, seismic, and soils information given may
 be adequate for  the regional environmental impact statement.  However,
 construction  should not be allowed until a thorough on-site geological
 soils  engineering investigation of the site is made.

 We recommend  that:   complete detailed geologic and soils feasibility
 of specific sites be demonstrated.  Construction should comply with
 the  minimum standards set forth in Chapter 70 of the Uniform Building
 Code.

.It is  also recommended that the geologist and engineer making the inves-
 tigation clearly identify his work and attach his signature and state
 registration or certificate number.

 R-13.   So noted.   These investigations have already been carried out
 and  are discussed in the Draft EIR (February 1975) prepared by Clean
 Water  Consultants for the construction aspects of the AWMA project.
 AWMA will continue  to comply with all  the above requirements.
                                   9-46

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STATE OV^CALIFORNIA—THE RESOURCES AGENCY
                              /I
        EDMUND G. BROWN JR.
                  RBffiQCDCKESSSS, Governor
STATE WATER RESOURCES CONTROL BOARD

DIVISION OF WATER QUALITY CONTROL
ROOM 1015, RESOURCES BUILDING
1416 NINTH STREET •  SACRAMENTO 95814
     APR 171975


     Mr. William F. Wolfson
     Aliso Water Management Agency
     27281 Aliso Creek Road
     Laguna Niguel, CA 92677

     Dear Mr. Wolfson:
ID)  l c EI X1
     APR 1 8 1975
1
    ALISO WATER
 MANAGEMENT AGENCY
     Enclosed are additional  comments  that lately were received on the
     draft Environmental  Impact Statement  (EIS)  on the Aliso Water
     Management Agency Regional Wastewater Treatment System.  These
     comments should be addressed  in the amendment to the draft EIS
     pursuant to the State and Federal Guidelines.

     We hope these comments are helpful to you in finalizing the EIS.

     The following comments relate only to that  portion of the draft
     EIS that deals with  water quality.

     Options Available to EPA

     Any one of the funding options (4.7.1, 4.7.2,. 4.7.3) are acceptable.
     However, implementation  of option 4.7.3  (treat Los Alisos1  and El
     Toro's wastes locally) will require modification of Los Alisos1
     facility.  This is because its aerated lagoons now under construction
     will not produce an  effluent  that meets  secondary treatment standards.

     Sewers (4.3.3.3)

     We disagree with the statement that overloading of a treatment.piant
     with storage or an ocean outfall  "does not  represent a serious public
     health hazard."  Overloading  of a plant  may cause uncontrolled
     discharge of raw sewage  from  manholes.   Chronic violations  of waste
     discharge requirements can result in  sewage connection prohibitions.

     El Toro Water District

     The description of the problems associated  with the Rossmoor facility
     (Sec. 1.3.3) needs some minor clarification.   Rossmoor has  had
     difficulty disposing of its effluent  without  violating waste discharge
     requirements,  even during the  dry season.   The improperly controlled
     wastewater disposal to San Diego  during  last  year's dry season led
     this board to  adopt a cease and desist order.   Disposal and storage
     problems at Rossmoor are expected to  increase  as waste flows increase.
                                     9-47
                           GD
                          RECYCLED PAPER

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Mr. William F. Wolfson       - 2 -
This Board generally  agrees with the  statement regarding the effect
of Kossmoor's discharge to San Diego  Creek.

Rossmoor does not meet the sulfate and boron incremental limitations
which are required to protect the groundwater.  Ocean disposal
eliminates the need for dissolved mineral limitations.

Los Alisos Water District

The statement (1.3-4-) that the dissolved mineral requirements do
"not take.effect until 1977" is not strictly correct.  Dissolved
mineral incremental limitations became effective on March 1, 1975>
and the discharger is now in violation of chloride and sulfate.

Blended Water Supply (2-61)

The date cited for the arrival of 50/50 blend water must be considered
tentative.  This blend will produce a better quality of reclaimed
wastewater.
Sincerely,
Farouk T. Ismail, Ph.D.
Environmental Specialist
                                 9-48

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                              SUMMARY COMMENTS

                     State Water Resources Control Board
                      Division of Water Quality Control
                               April 17, 1975
1.   Option 4.7.3 (treat Los Alisos and El Toro's wastes locally)  will
require modification of Los Alisos' aerated lagoons as they will not pro-
duce an effluent which meets secondary treatment standsrds.

R-l.  If blending with other effluent does not allow the ocean discharge
to meet secondary requirements, the Los Alisos treatment plant will  be
modified.

2.   Treatment plant storage overloads may cause uncontrolled discharge
of raw sewage from manholes.  Chronic violations of waste discharge re-
quirements can result in sewage connecting prohibitions.

R-2.  Where adequate storage capacity exists, sewage does not discharge
from manholes.  EPA is not aware of any ocean discharges which chronically
violate discharge requirements where connection prohibitions have  been .
instituted.  The City of San Diego is an example of a chronically  over-
loaded plant with no connection prohibition.

3.   Rossmoor has difficulty dispersing effluent without violating waste
discharge requirements, even during the dry season.  A cease and desist
order was issued during last year's dry season because of improperly con-
trolled wastewater disposal to San Diego Creek.  Rossmoor's disposal and
storage problems are expected to increase as waste flows increase.  Ross-
moor currently is in violation of the sulfate and boron incremental  limi-
tation specified in the NPDES permit.

R-3.  Note changes in Section 1.3.3.

4.   Dissolved mineral incremental limitations became effective March 1,
1975 for the Los Alisos Water District.  The District is now in violation
of chloride and sulfate incremental limitations.

R-4.  Note changes in Section 1.3.4.

5.   The date of arrival of 50/50 blend water is tentative.  The blend
will produce a better quality of reclaimed water.

R-5.  Agree.
                                    9-49

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                   UIMXV  OF
 H. G. OSBORNE
   DIRECTOR

MURRAY STORM
ASSISTANT DIRECTOR
  REGULATION
ENVIRONMENTAL MANAGEMENT AGENCY

        REGULATION DIVISION

     400 CIVIC CENTER DRIVE WEST
        SANTA ANA, CA. 92701
TELEPHONE: 834-2626
  AREA CODE 714


  MAILING ADDRESS
   P.O. BOX 418
SANTA ANA, CA. 92702
                               March 28, 1975
         U.  S.  Environmental Protection Agency,
              Region IX
         100 California Street
         San Francisco, CA 94111

         Subject:   Draft EIS for the AWMA regional wastewater  treatment
                    system.

         Dear Mr. De Falco,

         Thank  you  for the  opportunity to review the Draft EIS for  the Aliso
         Water  Management Agency (AWMA) regional wastewater treatment  system.

         There  are  two inaccuracies in the EIS with regard to air quality that
         need to be pointed  out:
              1.  On page 2-28 the EIS says "...the proposed project is located
                  in an area of the County where the current peak concentrations
                  of oxidants are about 50% of those in the northwestern portion
                  of Orange  County."

                  The AWMA area is quite varied in topography and meteorology,
                  resulting  in differences in air quality throughout AWMA.
                  While Laguna Beach experienced low levels of oxidant  in 1974,
                  the El Toro air monitoring station (also in AWMA) recorded
                  the second highest oxidant levels out of the seven stations
                  operating  in Orange County in 1974.  The maximum hourly
                  average at El Toro was .48 ppm, while the highest level in
                  Orange County was only slightly higher at .54 ppm.

              2.  In  Appendix B of the EIS a crude model was used to calculate
                  the so called "worst case" concentrations resulting  from
                  automobile emissions in 1985.

                  The model  used is extremely limited and unrealistic.   Further-
                  more,  a quick check of the calculation shows that the  results
                                          9-50

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         are on the order of 25 to 50 times too high, depending on
         the selection of emission factors.

         Even if the model does not predict problems with air quality
         in 1985, the air quality data collected at El Toro indicate
         that an air quality problem already exists!  Air quality
         standards for oxidant, nitrogen dioxide, hydrocarbons, and
         lead were all exceeded.

I agree with the EIS's conclusion that the developing urban form in
the AWMA area is inconsistant with the attainment and maintenance
of air quality standards.  For this reason, all feasible measures
that will mitigate the air quality impacts of development should be
implemented.

                                 Sincerely yours,

                                 M. STORM, ASSISTANT DIRECTOR
                                 Environmental Management Agency
                                 Regulations Division


                                 By;  / ' UUMA  A 6UA/	
                                    Martin Kay0
                                    Air Pollution Control Engineer
                                9-51

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                              SUMMARY COMMENTS

                Orange County Environmental Management Agency
                             Regulation Division
I.   On page 2-28, the EIS says "... the proposed project is located in
an area of the County where the current peak concentrations of oxidants are
about 50% of those in the northwestern portion of Orange County."  This is
inaccurate.  The AWMA area is quite varied in topography and meteorology,
resulting in differences in air quality through AWMA.

R-l.  The text has been corrected in Chapter 2.0 of the Final EIS.

2.   The model used in Appendix B is extremely limited and unrealistic.
Furthermore, a quick check of the calculation shows that the results are
on the order of 25 to 50 times too high, depending on the selection of
emission factors.

R-2.  The model has been deleted from Appendix B.
                                    9-52

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          UPSITY" OF
                A IMG I
                                                       IX
                                              .'QsniiH'75
                           HEALTH DEPARTMENT
JOHN R. PHILP, M.D.
HEALTH OFFICER

SANTA ANA OFFICE
645 NORTH ROSS STREET
SANTA ANA, CALIFORNIA 92702
TELEPHONE: 634-3131
Mailing Addro**t P. 0. Bo* 355
Santo Ana, California 92702

ANAHEIM OFFICE
1011 SOUTH EAST STREET
ANAHEIM, CALIFORNIA
TELEPHONE: 776-5551
Mai liny Addn**: P. 0. Bo* 355
Santa Ana, California 92702
March 31, 1975
U.S. Environmental  Protection Agency
Pacific Southwest Region IX
100 California Street
San Francisco, CA   94111

Attention:  Mr. Paul De  Falco,  Jr.
            Regional Administrator

Subject:  Draft Environmental Impact Statement D-EPA-24011-CA,
          Aliso Water Management Agency

Dear Sir:

As requested this Department  has reviewed the subject draft document and
offers the following comments for your consideration in the preparation
of the final report.

  1.  While this Department recognized that under adverse hydrologic
      conditions the outfalls at Aliso Beach and Main Beach Laguna
      may constitute a potential threat to the health of bathers,
      Health Department  monitoring  which has been performed on a weekly
      basis during  the past 4 years does not reveal contamination in
      the water contact  areas of either of these beaches that might be
      attributed to the  ocean outfalls.   Violations of California Ocean
      Water Contact Sports  Standards have occurred at these beaches but
      have been closely  associated  with surface water runoff, occurring
      during and after rainstorms.

  2.  On page 1-2 the report  refers to the Moulton Niguel Water District
      Improvement District  3A facility.   As the 3A facility is inter-
      connected to  the Moulton Niguel Water District 1A and South Laguna
      Sanitary District  facilities,  which are AWMA members, it is
      recommended that more information be included in the report re-
      garding the relationship of the 3A plant to this project.

  3.  It should be  noted that Rossmoor Sanitation Inc. is not presently
      providing treated  effluent to the Lion Country Safari Development
      as stated on  page  1-6.
                                   9-53

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 4.  The report  states on page 1-2 that the sludge generated at the
     Moulton Niguel Water District 1A facility is dried in a series
     of drying beds at the plant site.  It is this Department's
     understanding that this process is accomplished only at the
     South Laguna Sanitation District facility.

 5.  According to the U.S. Geological Survey Map, San Juan Capistrano
     Quadrangle, the elevation of Niguel Hill is 936 feet and not 800
     feet as stated in the report.

 6.  It is unclear, based on the information provided on page 2-66
     and 2-67 how the population within the AWMA area was determined
     as depicted in Table 2-19.

 7.  The report  states on page 2-71 and 2-72 that CNEL contours are
     used to describe the magnitude of noise levels in the AWMA area
     attributable to aircraft from the El Toro Marine Corp Air Station.
     Yet, Exhibit 2-9 which is based on a Composite Noise Rating study
     (CNR) is included in the report.  As a noise study has been
     recently conducted establishing CNEL contours (Bolt, Beranek &
     Newman, Inc., CNEL Contours for MCAS El Toro, July, 1972), it is
     recommended that it be substituted in the report as Exhibit 2-9.

     It should also be noted on page 2-72 that overflights along
     Runway 07R&L are also of importance to the AWMA area.

 8.  The statement on page 3-16 that "It cannot be said that wastewater
     is causing eutrophication in Newport Bay." does not appear to be
     relevant in this discussion nor has it been established that
     wastewater is not causing eutrophication in Newport Bay.

 9.  It is recommended that under IMPACTS OF DEVELOPMENT, Air Quality,
     that the report list not only the amounts of pollutants projected
     to be emitted,  but also the health effects of these pollutants if
     they cannot be reduced to the levels specified in the report to
     meet air quality standards.

10.  In the environmental impact statement summary it is stated that
     mitigating measures will be implemented to lessen air quality
     impacts.   However in the report the only mitigating measure offered
     which can be controlled by the applicant is to limit the extension
     of services to undeveloped areas.   It is therefore recommended
     that more information be submitted regarding the practicality and
     method of implementing such a measure.

11.  The report states on page 4-25 and 4-26.that the water quality
     problems  from Laguna Beach's discharge  would not be solved and
     there would be  no mitigation of  air quality impacts if the
     Environmental Protection Agency  does  not -participate in the project.

     This statement  appears to be an  assumption that local and  state
     authorities would have no control  over  the applicants proposal and
     therefore does  not appear to be  valid.
                                  9-54

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  12.  In Appendix B page B-22 it is suggested that Route I become a
       toll road and the income collected could be used to subsidize
       buses.

       This strategy does not appear to be practical as Route I is a
       major transportation corridor between beach cities.  Further
       this idea would be in conflict with the South Coast Regional
       Planning Commission's concern of maximizing access to the coastal
       areas for the people of Southern California.

This Department appreciates the opportunity to review this report.  If there
are any questions regarding these comments please feel free to contact me at
(714) 834-5532.

Very truly yours,
Environmental Health Engineering Specialist
Division of Environmental Health

HGS/ED/se
                                   9-55

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                         SUMMARY COMMENTS

                  Orange County Health Department

 1.    Violations of California's Ocean Water Sports Standards at Aliso
 Beach and Main Beach during the past 4 years have been caused by surface
 water runoff during and after rainstorms.

 R-l.   We  agree, however, this is not within the scope of the EIS.

 2.    What is the relationship of the Moulton Niguel Improvement District
 3A plant  to  the MN District 1A and South Laguna Sanctuary District
 facilities?

 R-2.   This interconnection is explained in Section 1.2.1.3 of the Final
 EIS.

 3.    Rossmoor Sanitation does not presently provide treated effluent
 to Lion Country Safari.

 R-3.   So  noted in the Final EIS, Section 1.2.4.

 4.    Sludge  drying beds are used only at the South Laguna Sanitation
 District  facility, not at the Moulton Niguel 1A facility.

 R-4.   This has been rechecked and Facility 1A does have and uses sludge
 drying beds.

 5.   According to the U.S. Geological Survey Map, San Juan Capistrano
 Quadrangle,  the elevation of Niguel Hill is 936 feet, not 800 feet as
 stated.

 R-5.   So  noted.

 6.   How  was the population within the AWMA area, as depicted in Table
 2-19 determined?

 R-6.   This has been noted in Table 2-18 (formerly 2-19 of the Draft
 EIS) of the  Final  EIS.

 7.   Information from the Bolt,  Beranek S Newman, Inc., July 1972 study
should be substituted for the Composite Noise Rating study used to de-
 termine in CNEL contours in Exhibit 2-9.

 R-7.  A new exhibit is  provided  as 2-9 in the Final  EIS.

8.   It has not been established that wastewater is  not causing eutro-
phication in Newport Bay.

R-8.  EPA has reviewed  available information in eutrophication in Newport
Bay.  Since the treatment plants are tributary to San Diego Creek this
is a valid concern.   The statement (on page 3-16) is correct.
                                    9-56

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9.   The Air Quality impact section should discuss the heath effects
of pollutants which cannot be reduced sufficiently to meet air quality
standards.

R-9.  See Section 4.5.1 for an expanded discussion of health effects
of air pollution.

10.  Please discuss the practicality and methods of implementing air
quality mitigation measures.

R-10.  Chapter 5.0 of the Final EIS describes the selected wastewater
management alternative for AWMA.  As noted in this chapter, the Final
Mitigation Plan for AWMA will be addressed at the Phase III level  of
the total project.  Sections 5.2.2 and 5.3.3 discusses this subject
in detail.

11.  Pages 4-25 and 4-26 appear to assume that local and state authorities
have no control over AWMA's proposal.

R-ll.  This statement assumed that all permits had been obtained.  Text
has been changed to indicate this.

12.  Transforming Route I into a toll road is not practical, and would
conflict with the South Coast Regional Planning Commission's goal  of
maximizing public access to the coastal areas.

R-12.  We agree.
                                    9-57

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           UIMTY OF
                                                        TELEPHONE: 834-20SO

                                                            AREA CODE 714


                                                           B 0. BOX 4108

                                                   400 CIVIC CENT.ER DRIVE WEST

                                                   SANTA ANA, CALIFORNIA 92701
                         PLANNING COMMISSION
March 25, 1975
United States Environmental
 Protection Agency
Region IX
100 California Street
San Francisco, CA  94111
Attention:
Gentlemen:
Mr.  Paul DeFalco, Jr.
Regional Administrator
SUBJECT: Draft Environmental Impact Statement  for  the Aliso
         Water Management Agency Regional Wastewater Treatment
         System

The following comments represent the response  of the Orange  County
Environmental Management Agency (EMA) and the  Orange County  Planning
Commission to the Draft EIS on the above project.

1.  Alternatives 1A and 2G should be assessed  and  compared in rela-
    tion to their effects on current and future development  of  the
    AWMA area.  Would Alternative 1A serve to  satisfy the Regional
    Water Quality Control Board directive to improve the quality
    of sewer effluent?  Does Alternative 2G go beyond what is required
    and thus result in facilitating earlier development of the
    •Moulton Ranch?  It is not clear what population capacities  are
    to be served by the various alternatives, an inadequacy  which
    needs clarification.   What would be the impact of these
    Alternatives on land use policies of the County of Orange?

2.  The report fails to address directly the existing and projected
    quality of the streams, groundwater, and nearshore waters under
    present and planned alternative waste treatment and disposal
    practices.  This perceived deficiency in the EIS might be
    described as a failure to assess fully the total water quality
    situation at present, alongside the anticipated positive
    environmental impacts of each of the .AWMA alternatives.  Order
    No.  74-72 from the San Diego Regional Water Quality Control
    Board,  which outlines 'Water Discharge Requirements for .AWMA
    Ocean Outfall" should be included in the EIS.
                                9-58

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March 25, 1975
Page Two


3.  There exists possible severe conflicts between the location of
    the facilities necessary for this project and the Open Space and
    Conservation Element and the Land Use Element of the Orange County
    General Plan, specifically with regard to Aliso Creek, which has
    been designated as one of the top two open space priority areas
    in the County.  The Aliso Creek corridor has received a great deal
    of attention by both the Environmental Management Agency, the
    Planning Commission and  the Board of Supervisors and through
    adoption b$ the latter of the "Forest to the Sea" report as an
    interim guide for development of Aliso Creek as an open space/
    greenbelt corridor.

    The outstanding scenic, scientific and educational values of Aliso
    Canyon (particularly, the north-facing slope vegetation) has re-
    cently been recognized as being of State-wide importance.  In
    its Landscape Preservation Study for the Southwest Mountain and
    Valley Province, the California Department of Parks and Recreation
    identified that site (delineated on the attached) as Priority
    Area Number 18 of some 45 sites of the Province warranting
    acquisition and preservation by that Agency.  This fact should
    also be pointed out in the EIS.

    AWMA intends to prepare Environmental Impact Reports for specific
    facilities in accordance with the California Environmental
    Quality Act as it pertains to discretionary authorizations for
    these facilities from the County of Orange.  Nevertheless, as
    this overall EIS and project constrains the locations of specific
    facilities to the degree identified in the Draft EIS, we believe
    that this EIS must be expanded upon significantly to evaluate
    the environmental impacts and alternatives of the location of
    the facilities.  As proposed, all alternatives will have signi-
    ficant adverse environmental effects upon Aliso Creek.   We
    question why all alternatives are based on development of
    facilities in the creek.  We recommend, therefore, that the EIS
    be expanded upon to evaluate alternative sites for the AWMA
    facilities in Laguna Canyon, Salt Creek or any other locations
    within the AWMA area.  We strongly believe that each alternative
    presented should be also evaluated for its viability in an
    alternate location.

    Further, these alternative locations, as well as all the Aliso
    Creek locations noted in the Draft EIS, must be far more
    thoroughly evaluated as to their environmental impacts and
    mitigation measures.  The Draft EIS is inadequate in this regard.

    In addition, the impact of treatment plant location in any of
    the designated greenbelts or open space corridors (i.e.  Woods
    Canyon,Aliso Creek), should be assessed with regard to their
    long-range impacts on the recreation corridor.

    In addition, in narrow portions of Aliso Creek such as the area
    designated for location of the Regional Treatment Plant, con-
    struction of the plant, the road and :the necessary flood pro-
                                9-59

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 March 25,  1975
 Page Three


     tection works  may not  be  physically practical.   We  suggest that
     consideration  be  given to this  problem in weighing  Aliso Creek
     against alternate locations  for the AWMA project facilities.

 4.   The  impact  of  vehicular roadway along  the creek alignment should
     be assessed.   Is  it  required?   Are  stream crossings necessary?

 5.   How  would the  quality  of  surface waters flowing into Aliso Creek
     be affected by the alternatives?

 6.   The  Air Quality Mitigation Plans presented in the Draft  EIS
     could  have  significant ramifications for land use planning in
     Orange County.  This point should be expanded upon  to reveal more
     clearly to  all concerned  parties that  if required by the
     Environmental  Protection  Agency, there would be severe impli-
     cations and possible  resistance in Orange County.   The  impacts
     of these mitigation  measures needs  to  be spelled out.  What are
     the  costs of the  new buses recommended?  What are the costs and
     operating requirements of "Park and Ride"  parking areas?  What
     is the impact  on  area  population projections and the effect on
     land prices if a  new low  income type community  were developed
     near the Federal  GSA buildings?  What  are  the-impacts of these
     measures on Orange County's development policies, standards,
   „ land use planning and  current land  use?  Tremendous impacts on
     transportation systems are possible, and we believe these should
     be identified  and evaluated by  the  EPA and the  County prior to
     a  commitment to approve this project.
                                                    /
 7.   Justification  for using the figure  "115 gallons, of  sewerage per
     person per  day" should be provided.

 8.   An assessment  of  the original investment in the two (2)  plants
     to be  abandoned if Alternative  2G is selected should be  included
     in the cost figures  in order to determine  a true  cost comparison
     with Alternative  1A.   Under Alternative 1A no plants would be
     abandoned and  thus the money expended  to date for these  plants
     would  be utilized in continuing use  of the plants -- this  would
     appear to be a more  efficient use of expended funds  as opposed
     to abandoning  the plants  which  have  already been  paid for.

To the extent that the listed  alternativesha^fe been  evaluated,  we
concur with  the statements in  the EIS that  Alternative  1A as  slightly
modified has "fewer secondary  impacts",  is  "superior  for achieving
reclamation  in  the future", is "the  most cost  effective  in terms of
energy expenditure",  and "maximizes  the  reclamation  potential  of the
Los Alisos,  El  Toro and Moulton Niguel Water Districts  Treatment
Plants".    However, we believe  that  additional  factors should   be
evaluated  as they relate to Alternatives 1A (modified)  and 2G  (2F
modified)  as outlined in the  itemized statements above,  supplemented
with consideration and evaluation of alternative project  locations
within the AWMA area.
                               9-60

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March 25, 1975
Page Four
Thank you for providing the County with the opportunity  for  review-
ing the Draft EIS on this very important project.

Sincerely, .
Shirley L. Grindie, Chairman
Orange County Planning Commission

SLGrth

Attachment
                                9-61

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         SOUTHWEST MOUNTAIN AND VALLEY PRESERVATION STUDY
.  £>^,'«. :, ^VrP ••;£•' • v'"~   •''
-&fe-i%A vfe^fe J -7. .4

 fe§g2^-^:\^i|:^.;/i/
   SOUTHWEST MOUNTAIN AND VALLEY LANDSCAPE PRESERVATION STUDY
                                   Figure 2


                                       9-62

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                         SUMMARY COMMENTS

                 Orange County Planning Commission

2.   Alternatives 1A and 2G should be assessed and compared in relation
to their effects on current and future development of the AWMA area.
It is not clear what population capacities are to be served by the
various alternatives.

R-l.  Sizing has been clarified in Chapter 3.  An expanded section
has been added to Chapter 4 regarding alternatives and their secondary
impacts.

2.   The report fails to address directly the existing and projected
quality of the streams, groundwater, and near shore waters under
present and planned alternative waste treatment and disposal practices.
Order No. 74-72 from the San Diego Regional Water Quality Control
Board, which outlines "Water Discharge Requirements for AWMA Ocean
Outfall" should be included in the EIS.

R-2.  Order No* 74-72 has been included as an appendix in the Final
EIS.  It is extremely difficult to predict the actual quality of
streams, groundwater and near shore waters because of the varied
sources of pollutants.  Agricultural and urban runoff contribute
significantly to problems in streams, groundwater and near shore
waters.  An analysis of the impact of runoff from various rural  and
urban land uses has been added to Section 4.5.2.2 of the Final EIS.
The San Diego comprehensive basin plan includes estimates of relative
contributions from these sources.

3.   The EIS should be expanded to evaluate alternative sites for
the AWMA facilities in Laguna Canyon, Salt Creek or any other locations
within the AWMA area.  As proposed, all alternatives will have signifi-
cant adverse environmental effects upon Aliso Creek.

R-3. 1.   The initial commitment of the original treatment plant
          site will involve adverse effects (creek realignment and
          scenic disruption).  This treatment plant site has been
          eliminated from consideration.

    . 2.   To the extent physically practical, alternate sites have
          been considered.  The recreational, scenic, and wildlife
          values of Aliso Creek have been given major consideration.
          Refer to amended Chapter 3.

4.   The impact of vehicular roadway along the creek alignment should
be assessed.

R-4.  Discussion of roadways expanded in Chapter 3.
                               9-63

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 5.   How would the quality of surface  waters  flowing into Aliso Creek
 be affected by the alternatives?

 R-5.   There would be  virtually no  effect  on Aliso  Creek.  The effect
 on San Diego Creek would be a reduction in flow and nutrients.

 6.   The Air Quality  Mitigation Plans  presented in the Draft EIS
 could have significant ramifications for  land use planning in Orange
 County.   This point should be expanded upon to reveal more clearly
 to all concerned parties the nature of these  possible implications.

 R-6.   The conceptual  mitigation plans  proposed in this EIS are attempts
 to minimize the air quality impacts which will result from the urban-
 ization  of the AWMA region in accordance  with the  land use patterns
 currently approved by Orange County government.  The purpose of the
 AWMA  project is to enable present  sewerage to be properly treated and
 to provide sufficient treatment capacity  to meet the demands which
 will  occur as adopted County land  use  plans are implemented.  The
 principal  ramification of these mitigation plans upon Orange County
 land  use planning is  to highlight  the  fact that adequate consideration
 of air quality impacts was  not given when the present General Plan
 was adopted and that  now specific  direction must be given to the form
 which developments  take if air quality standards are to be achieved
 and maintained as  required  by law.

 The primary impact  which will  result from such mitigation measures
 is  a  reduction in the  amount  of air pollution generated within the
 AWMA  region.   Secondary impacts are diverse and no attempt can be made
 within this  EIS to  deal comprehensively with  them.  However, some economic
 impacts  can  be  discussed further and Section  4.6.3 has been added to
 the EIS.

 The intent  of the proposed  "new town" around  the GSA facility is not
 to  provide  low income  housing,  but to create  lower income housing than
 is  currently  being  planned.  This would enable more of the people who
 will  be working  in  the  GSA offices to live in the area.   This would
 also  result  in  a more  balanced community,  rather than an upper income
 suburb.

Any plan which will reduce air pollution by reducing the VMT may result
 in  the overbuilding of arterial highways.   However, this situation
 is  largely avoidable since many of the roads  eventually  needed in AWMA
 have yet to be built.   Therefore,  those roads  can be re-evaluated
before being constructed to reflect any changes  necessary.

High density cluster residential development  with neighborhood shopping
centers is consistent with the goals of the Land Use Element of the
Orange County General  Plan and land use planning practices  in various
urbanized sections of the County.   This type  of  residential  development
is typically seen in the County's  more urban  locales  in  close proximity
to commercial, educational, cultural  and institutional land  uses  and
major transportation corridors.
                               9-64

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According to the Orange County Planning Department, duplexes, triplexes,
apartments, condominiums and townhouses are to predominate within high
density areas.  High density dwelling units may range from 6.5 to 18
units per gross acre with an area per unit standard of 2,400 to 5,000
square feet.  Furthermore, these residential densities are flexible
to the extent that the maximum number of permitted dwelling units need
not be evenly distributed over the entire development area.  The County
Land Use Element, in fact, encourages cluster housing and planned unit
development when it is found that this type of development will better
preserve the natural terrain and the open character 'of the County.
Even so, a detailed analysis should be undertaken for each development
site to ensure its compatibility with existing and proposed land uses
within both the AWMA region and the County as a whole.

7.   Justification for using the figure "115 gallons of sewerage per
person per day" should be provided.

R-7.  Figures have been recomputed in accordance with CC criteria using
existing  per  day per capita for residential use.

8.   An assessment of the original investment in the two (2) plants
to be abandoned if Alternative 2G is selected should be included in
the cost figures in order to determine a true cost comparison with
Alternative 1A.

R-8.  We agree.  More work is needed on the upper Aliso area.  The
plants are not abandoned, however, but retained for development of
summer reclamation potential.
                               9-65

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                                                                                      4
      ':."  ,,,-K,TFR                xf\>Gl/#X
  cov
                                                        April 9, 1975


 U.S.  Environmental Protection Agency
 Pacific South West Region IX
 100 California Street
 San Francisco, California  94111

 Attention:  Paul DeFalco, Jr.

 Dear Mr.  DeFalco:

 We are pleased to submit for your consideration several comments regarding
 the draft EIS #D-EPA-24011-CA - Aliso Water Management Agency.   We wish to
 summarize our oral presentation and present additional information in this
 letter.

 We concur with the EPA staff that the information regarding Alternative 1A
 as modified,  is weak and should be given far more study and consideration.

 At this time  we favor Alternative 1A modified which provides for an expansion
 of the South  Laguna plant and we oppose any plant site in the Wood Canyon area.
 We recommend  that any future plant expansion be located in the  vicinity of the
 G.S.A.  (Ziggeraut)  facility.   Studies made by our consultant since the March 25
 hearing show  that contrary to statements made by Don Owens (AVWA consultant),
 differences in capital costs to the City of Laguna Beach between Alternatives
 1A and 2G are insignificant.

 In our opinion,  Alternative 2G will destroy the central portion of one of the
 last  remaining undeveloped canyons in this area.   The Aliso Creek Corridor has
 been  designated  by the Orange County Board of Supervisors as an area "to be
 preserved."   It  was pointed out at the hearing by those who favor Alternative
 2G that this  corridor has already been "blocked."  We would suggest that the
 golf  course development which exists is compatible with the natural undeveloped
 canyon, whereas  the proposed treatment plant is very incompatible and more
 suitable  in an industrial area.

 The sludge disposal from a large regional plant as proposed in  Alternative 2G
 will  be .a major  problem.   At  the AVMA hearing on the EIR for the construction
 details of the project which  was held on April 3,  it was revealed that the
 access road from the proposed regional plant in Aliso Creek to  the North was
 deleted.   It was also revealed that  no land costs  for the regional plant were
 included  in the  cost estimates for the plant.   The result of this is that if
Alternative 2G is constructed,  approximately 60 cubic yards per day of sludge
 will  be required to be trucked through the golf course to Pacific Coast Highway
 for disposal.  In our opinion,  it would be far better to construct Alternative
 1A since  the sludge disposal  requirements will be much less.
                                    9-66
     505 FOREST AVE.   •   LAGUNA  BEACH, CAL. 92651   •   TEL.  (714)  494-1124. 546-4856

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U. S. Environmei  1 Protection Agency            ^        April 9, 1975
Attention: ,,Paul DeFalco, Jr.                              Page 2


The Aliso Creek Interceptor is a major element of the AIWA project.  Under
Alternative 1A, it will be carrying treated effluent rather than raw sewage as
in Alternative 2G.  If Alternative 2G is constructed and an earthquake ruptures
the interceptor, a potential environmental threat from raw sewage would occur.
As pointed out in the EIS, the interceptor line proposed in Alternative 2G
would act as a collector sewer, thus spurring development along Aliso Canyon.
It is claimed that the project should be cost effective and that Alternative 2G
is the most cost effective of the two.  We wish to strongly point out that this
claim is in our opinion greatly in error since no monetary value has been
designated for the destruction of the central portion of Aliso Canyon and the
rerouting of Aliso Creek.  The recreational value of Aliso Creek has not been
considered.  The creek has a definite monetary value which will greatly increase
during the next 25 years.

There are several general comments regarding the AVMA project which concern us.
One of these is the cummulative effect of the AIWA project, the SERRA project,
and the Irvine Ranch Water District Rattlesnake Creek project.  These three
projects when considered together will provide for a population of more than
three times the existing population in the South part of Orange County and this
will greatly affect the air quality in this area.  The EIS has several mitigation
plans.  Unfortunately, neither AIWA nor any agencies in AIWA is in a position to
enforce any of the mitigation measures.  We would, therefore, recommend that the
mitigation measures be discounted and that the project be scaled down and/or
modified to reduce the impact rather than depending on the mitigation plans to
reduce the impact.

Thank you very much for the opportunity to comment on this important project.
We feel that this proposed project, which will be the largest public works
project in Southern Orange County, will have a great significance in our lives
and we are very appreciative of your concerns in trying to reduce the adverse
environmental impacts of these changes.

Very truly yours,
ROY W. HOLM, Mayor                            CARL E. JOHNSON, Vice Mayo:
CHARLTON BOYD, Ccfaicilman                X'xdQN S. BRANDT Councilman   /
                                              PHYLLIS SWEENEY, Councilwoi
                                   9-67

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                              SUMMARY COMMENTS

                            City of Laguna Beach
I.   The City of Laguna Beach will similar capital costs for either
Alternative 1A or 2G.

R-l.  We agree.  The costs are similar, however, the annual  operating
costs are higher in Alternative TA.

2.   Alternative 2G will have major sludge disposal problems.

R-2.  Final sludge treatment and disposal methods have not been determined
because of the siting problem.  Refer to Chapter 5 of the Final EIS for
further discussion.

3.   No monetary value has been placed on the present and future recreation
value of Aliso Creek.  Because of this omission, we believe  that it is a
great error to claim that Alternative 2G is more cost effective than Al-
ternative 1A.

R-3.  Existence of a regional treatment plant would not prevent recreation;
instead it would change the character of the recreational experience.  We
do not feel it is possible to quantify this in monetary terms.

4.   Since the proposed mitigation measures are not enforceable, the pro-
ject should be scaled down or modified to reduce the impacts.

R-4.  Chapter 5.0 of the Final EIS describes the selected wastewater manage-
ment alternative for AWMA.  As noted in this chapter, the Final Mitigation
Plan for AWMA will  be addressed at the Phase III level  of the total project.
Sections 5.2.2 and 5.3.3 discuss this subject in detail.
                                   9-68

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I
ALISO WATER
MANAGEMENT
   AGENCY
          ^t 92677

      744-834-2500
                                                                                               fiSl
                   April  10,  1975
      U.S.  Environmental  Protection Agency
      Region IX
      100 California Street
      San Francisco, California 94111
      Attention:
      Gentlemen:
              Mr. Paul DeFalco, Jr.
              Regional Administrator
                  Subject:   Draft Environmental Impact Statement for the
                            Aliso Water Management Agency, Regional Waste-
                            water Treatment System

                  The Board of Directors of the Aliso Water Management Agency urge the
      Environmental  Protection Agency to take an affirmative position in the selection
      of alternative Concept 2-G as the most cost-effective regional wastewater treat-
      ment system which would result in desirable environmental impact effects to the
      extent practicable on the area basis.

                  The AWMA  Board of Directors further urge the EPA to bring a halt to
      the three year planning treadmill and approve the grant offer for the Aliso Water
      Management Agency project on the basis of alternative Concept 2-G.  AWMA finds
      the description of Alternative 1-A soallusive and fluid that it has been impossible
      to properly evaluate  the impacts of the concept.  In the opinion of AWMA, the
      physical  feasibility  and environmental acceptability of Concept 1-A has not been
      demonstrated by the Environmental Protection Agency.

                  The following comments are directed to specific areas of comparison
      between the two concepts under consideration by EPA.

      1 .   Planned Population

                  The AWMA  project is being designed with a maximum ocean outfall  size
      to  serve  a permanent  population derived from an E-0 population projection to the
      Year 2000.   The maximum design size is being established by the State Water
                                                   & $00 Waft)
                           tM Siay y'fMMte&lutiict • tftvinr Zitanr/i Walet Qu/ur/
                              ,Mo,,aoH-J\fy,iff°)talet SVilW • SToutA SKaguita Sam/a >y


                                                9-69

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 U.S.  Environmental  Protection Agency
 Region IX
 April  10,  1975
 Page  Two
 Resources  Control Board and  is a  limitation on the AWMA outfall pursuant to the
 permit  issued by the Coastal Zone Conservation Commission.  Since both alterna-
 tive  Concepts 1-A and  2-G have the same ocean outfall size and capacity limita-
 tion, there would appear to  be no difference between growth inducing character-
 istics  of  the alternative projects.

            The contention that the raw sewer interceptor along Aliso Creek
 proposed in Concept 2-G would be more growth inducing than the treated outfall
 line  proposed in Concept 1-A has not been substantiated.  AWMA notes that an
 18-inch diameter interceptor sewer line in the Aliso Creek area has existed
 since 1968, with no evidence of induced growth.  Expansion of wastewater treat-
 ment  facilities by the year  1985 is contemplated in both concepts.  Whether the
 expansion  is made at a regional treatment plant (Concept 2-G) or at several
 separate plants (Concept 1-A) would make little difference.  The difficulties
 of obtaining permits, EIR approvals, funding, etc., would be the same under
 either  concept.

            Concept 2-G is responsive to growth and not growth inducing and
 should  be accepted by the Environmental Protection Agency.

 2.  Cost-Effectiveness

            Studies conducted by AWMA and EPA indicate that Concept 2-G has a
 lower construction cost than Concept 1-A and would have significantly lower
 operating costs than Concept 1-A.   At a time when power consumption is receiving
 so much attention, AWMA is astonished to find EPA suggesting a concept which
would require 12,000,000 to 24,000,000 kilowatt hours more power over the next
 twenty years than would Concept 2-G.   The additional  power consumption in Con-
 cept 1-A would require 27,000 to 54,000 additional barrels of oil  for power
 generation and at present rate schedules would cost the AWMA agencies $300,000
 to $600,000 more in operating costs.   AWMA notes that in the evaluation of
annual cost, no escalation of power costs were used.   Concept 1-A, as estimated
 by EPA, would have operating costs 20 to 30 percent higher than Concept 2-G.
 If EPA had projected the anticipated escalation in power costs, then the addi-
 tional operating costs of Concept 1-A would exceed projected operating costs of
Concept 2-G by an even greater percentage.   Concept 2-G is the most cost-effective
concept and is more responsive to the national  program for energy  conservation.

3.  Concept 2-G Treatment Plant Site

            AWMA is  concerned about the environmental  impacts  of the proposed
regional plant site in Concept 2-G and has  been working very hard  to mitigate
adverse impacts  from the construction of the treatment facilities.   Several
comments have been submitted to EPA recommending Concept 1-A because it would
                                           9-70

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U.S. Environmental Protection Agency
Region IX
April 10, 1975
Page Three
involve the construction of a 10 mgd regional plant in the canyon above the
existing South Laguna plant and therefore would not disturb the land along
Aliso Creek.  The South Laguna site had long been AWMA's preferred plant site
and the Moulton-Miguel Water District had purchased the site in anticipation
of constructing a treatment facility.  Soils investigations of the South Laguna
plant site, however, have identified extensive landslide areas which present a
construction limitation of the ultimate plant size of about a 10 to 12 mgd
capacity.  This size plant would not accommodate the anticipated 1985 flows,
and additional treatment plant capacity would have to be constructed at other
locations.  An additional concern of the South Laguna site is the cost of pump-
ing wastewater up to the plant.  Plant layouts indicate that a 12 mgd plant
would have to be stairstepped up the canyon and the intake works would be at
about elevation 160, or 100 feet higher elevation than the plant site proposed
in Concept 2-G.  A plant layout of a 12 mgd regional wastewater treatment plant
at the South Laguna site is presented in Attachment A.

            The EPA-EIS suggests that a future plant could be constructed in
the Moulton-Niguel 4-A service area along Aliso Creek adjacent to the General
Services Administration Building.  EPA has made no attempt to evaluate the
environmental impacts of this future plant site.  It is the opinion of AWMA
that this plant site would have more adverse impacts than the Concept 2-G pro-
posed site.  The 4-A site would be further into the proposed greenbelt recrea-
tion development area.  The operation of this remote treatment plant, with the
problems of sludge handling and cost to pump the wastewater to the plant, would
complicate the operation of wastewater treatment facilities and add an additional
wastewater treatment facility in the Aliso Creek greenbelt area.

            The County of Orange has suggested that AWMA consider a plant site
along Aliso Creek located immediately north of the proposed plant site.  The
County contends that the northerly site would not require the channelization of
Aliso Creek and would remove the plant from the narrow canyon area of Aliso Creek.
AWMA has not proposed the northerly site for two reasons.  One, it would separate
the proposed regional plant site from the existing South Laguna plant by approxi-
mately 0.7 miles which would complicate the operation of the plants as a single
regional plant.  Secondly, it would locate the regional plant in the Horseshoe
Bend area which is proposed as a major recreation nodal area.  AWMA believes that
the impacts of the treatment plants require that the new plant and the existing
South Laguna plant be located as close together as physically possible.  Shown
on Attachment B is the plant site proposed by the County and the AWMA proposed
plant site.  Concept 2-G attempts to minimize the impacts of the existing South
Laguna and new regional  treatment plants in the Aliso Creek area.
                                           9-71

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 U.S.  Environmental  Protection Agency
 Region IX
 April 10, 1975
 Page  Four
 4.   Recreational  Corridor

             Concern has  been  expressed  that  the  proposed  regional  plant  site  in
 Concept 2-G would destroy the integrity of the hiking  and equestrian  trails and
 bikeways proposed as a future greenbelt corridor along Aliso Creek.   AWMA  has
 directed the engineers to redesign  the  regional  treatment plant  to provide for
 an  equestrian trail  and  a hiking-bikeway trail system  along the  western  edge  of
 the plant site.   This trail system  would be  50 to 65 feet in width and would
 utilize about three acres of  the  17 acres proposed for the plant site and  would
 eliminate the plant service road  along  the western edge of the plant  site.  In
 addition to the  three acres in the  plant site, the trail  system  could also
 utilize the ranch road along  the  western edge of Aliso Creek.  AWMA will acquire
 property rights  to about 11 acres adjacent to the plant site which would be
 inundated under  a standard project  flood condition of  22,000 cubic feet  per
 second  flow in Aliso Creek past the plant site.   AWMA  has expressed a willingness
 to  make this area available for greenbelt corridor uses.  A copy of the  land-
 scaping plan which shows the  proposed trail  system is  presented  in Attachment C.
 A cross-section  of a typical  trail  system is presented in Attachment  D.  Concept
 2-G does provide  for the proposed recreational corridor.

 5.   Access  Road
            Substantial misunderstanding and confusion has been asserted to exist
over whether  there will be an access road to the regional plant in Concept 2-G
and whether or  not the road would be growth inducing.  First, AWMA is not pro-
posing  to construct a permanent access road through the three mile reach of Aliso
Creek from the  General Services Administration Building to the regional plant.
AWMA is  proposing that the contractor constructing the treatment plant use the
existing ranch  road located along the westerly side of Aliso Creek for access
during  construction.  This would require the contractor to install two temporary
crossings over  Aliso Creek.  The ranch road would be used only by the contractor
and would not be open to public access.  After completion of the plant construc-
tion, the contractor would remove the creek crossings and restore the creek area
to its  original condition.  Thereafter, access to the plant would be from the
Pacific  Coast Highway by means of a private access previously acquired by the
Moulton-Miguel  Water District.  AWMA is proposing to construct a permanent road
between  the South Laguna plant and the new regional plant.  The road-would have
a 20 foot paved section and would be 1500 feet in length.  The road would be used
by the AWMA plant operating personnel.

            Between the Pacific Coast Highway and the South Laguna plant, access
would be through the Laguna Beach Golf Course development.  A permanent easement
and right-of-way approximately 20 feet in width was acquired from Mr. and Mrs.
Brown .by the  Moulton-Niguel Water District on July 19, 1971.  The access was
                                           9-72

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U.S. Environmental Protection Agency
Region IX
April 10, 1975
Page Five
acquired for the purposes of access to a sewage treatment plant and the road
would not be open to public access.  Adequate access to the treatment plants
in Concept 2-G has been provided and private landowners have been compensated
for any impacts of the road access.

6.  Wastewater Reclamation

            Support for Concept 1-A has been suggested by some interests in the
belief that the concept would be more compatible for future wastewater reclama-
tion development.  AWMA does not agree with this contention.  The AWMA member
agencies have been operating wastewater reclamation programs for a number of
years and plan to continue these programs at existing plants and through the
implementation of the regional wastewater treatment facilities proposed in
Concept 2-G.   The ocean outfall is the same size under both alternatives (size
limited by Coastal Zone Conservation Commission); therefore the pressures to
expand wastewater reclamation programs will be the same under both alternative
concepts.

            Reclamation and conjunctive use of water supplies will be continued
by AWMA under Concept 2-G.

Summary

            The Aliso Water Management Agency wishes to express their apprecia-
tion to the Environmental Protection Agency for the professional manner in which
the Environmental Impact Statement (Draft)  was accomplished and for this opportunity
to make comments on the alternative concepts under consideration.  AWMA urges EPA
to approve Concept 2-G as the most cost-effective and environmentally responsive
alternative.   We know you are aware of the  tremendous impact the delay of project
approval has had upon the costs of the project.  Escalation of construction costs
during the three year planning program has  resulted in an almost two-fold increase
in the estimated costs of the regional  treatment facilities.  Further delays in
project approval is not warranted.

            The Aliso Water Management Agency Board of Directors request the
Environmental  Protection Agency to conclude these proceedings and thereupon act
affirmatively with the State Water Resources Control Board on the funding of the
project on the basis of alternative Concept 2-G.

Very truly yours,
                 firman
              Cors
      WATER MANAGEMENT AGENCY
                                           9-73

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                              SUMMARY COMMENTS

                        Aliso Water Management Agency
 1.   Since both Alternative Concepts 1-A and 2-G have the same ocean out-
 fall, and therefore the same capacity limitation, there is no difference
 in the growth-inducing characteristics of these two alternatives.  2-G's
 raw sewer interceptor along Aliso Creek is not more growth-inducing than
 1-A's treated outfall line.  An 18-inch interceptor line has been in the
 Aliso Creek area since 1968 and has not induced growth.

 R-l.  EPA does not contend that interceptors induce growth, however, they
 do facilitate urbanization by making subdivision less expensive.   The
 existing interceptor did not result in urbanization because of adverse
 economic conditions and a lack of roads.

 2.   Concept 2-G is the most cost-effective alternative.  In comparison
 to concept 1-A, it has lower construction costs, significantly lower opera-
 ting costs, and would require 12 to 24 million kilowatt hours less over a
 12 year period.  Concept 1-A would have operating costs 20 to 30% higher
 (or more, if power costs increase) and would require that 27,000  to 54,000
 additional barrels of oil be consumed to generate the greater power needs
 of this concept.

 R-2.  Concept 2-G is the most cost-effective alternative under AWMA's
 assumptions.  However, these assumptions do not quantify environmental
 costs, lost opportunities, and flexibility.  If the assumptions made in
 formulation of the AWMA proposal  are not accurate,  the most flexible pro-
 ject will be the most cost effective.

 3.   The 4-A site suggested in the EIS would have more adverse environmental
 impacts than the 2-G site.  The 4-A site would be further into the proposed
 greenbelt recreation area.  The site's remoteness would cause problems of
sludge handling and increase the cost  of pumping wastewater to the plant.

 R-3.   The 4-A site has already been disturbed by the GSA building.   There
 is no problem with archaeological  sites and the site benefits in  terms  of
 static head for future reclamation.

 4.   AWMA has not proposed a site immediately north of the proposed plant
 site because the 0.7 mile distance between this northerly site and the
existing South Laguna plant would complicate consolidation of operations
of the two plants.  The northerly site suggested by the County of Orange
is in the Horseshoe Bend area, which is proposed as a major recreation
node.

 R-4.   EPA does not endorse a treatment plant in Horseshoe Bend, but has
 included the site in an expanded  discussion of sites.   Refer to Section
 3.1.2 in the Final EIS.
                                     9-74

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5.  In response to concerns expressed regarding future hiking, riding,
and bicycle trails along Aliso Creek, AWMA has directed its engineers
to provide an equestrian trail and a hiking-bikeway trail system along
the western edge of the 2-G plant site.  This 50 to 65 foot wide trail
system, which would replace the plant service road originally planned
for this area, would cover three of the site's 17 acres.  The trail
system could include the ranch road along the western edge of Aliso
Creek.

AWMA will acquire 11 acres subject to inundation during a Standard
Project flood of 22,000 cubic feet per second flow in this area.
AWMA is willing to make this area available for greenbelt corridor
uses.

R-5.  The EIS has been amended to reflect these changes.  Refer to
Section 3.2.2.1.

6.  During plant construction, the contractor will use the existing
private ranch road from the GSA Building along the westerly side of
Aliso Creek. Two temporary creek crossings will be installed.  These
will be removed and the creek restored to its original condition fol-
lowing completion of construction.

When the plant is built, access will be from Pacific Coast Highway
via a private 20 foot wide, 1,500 foot long paved road through the
Laguna Beach Golf Course development.  A permanent easement and approximately
20 foot wide right-of-way was acquired by the Moulton-Niguel Water
District on July 19, 1971.

R-6.  The EIS has been amended to reflect these changes.  Refer to
Section 3.2.2.1.3.1.

7.  AWMA plans to continue its wastewater reclamation programs at
existing plants and at the facilities proposed in Concept 2-G.  Since
the ocean outfall will be the same size for Concepts 2-G and 1-A,
both alternatives would experience the same pressures for expansion
of wastewater reclamation programs.

R-7.  The static head, physical location, usefulness of treated line
for partial distribution in Alternative 1A appear to offer more com-
patibility to continual future reclamation.
                                  9-75

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 March  25,  1975
                                                         Moulton Miguel
                                                         27500 La Paz Road, Laguna Miguel
                                                         California 92677, Phone 831-250'
1
 Mr.  Paul  De  Falco, Jr.
 U.  S.  Environmental  Protection Agency
 Pacific Southwest Region  IX
 100 California  Street
 San Francisco,  California 94111

 Attention:   Mr. James McGrath

 Gentlemen:

 For the record  my name is Les Remmers, Vice-President of the Moulton
 Miguel Water District.  This agency, as well as other member agencies
 within the Aliso Water Management Agency, has embarked upon a program
 of  providing long-range water and sewerage facilities at the lowest
 possible  cost.  In order to accomplish this goal the Board of Directors
 held a general  obligation bond election in June 1968.  The total amount
 of  authorization was $26.7 million.  The qualified voters, mostly
 homeowners within Laguna Miguel, Mission Viejo and Laguna Hills,
 overwhelmingly  approved the issue by 76.8 percent.  Through the years
 these residents and  taxpayers have continued to support, both by
 endorsements  and through their tax dollars, programs that are vitally
 needed to upgrade water and sewerage service.

 The Aliso Water Management Agency's proposed wastewater treatment Plan 2-G
 represents the most economical and environmentally acceptable of all the
 alternatives  suggested by the Environmental Protection Agency, as well as
 the Aliso Water Management Agency.

 Through the  economics of regionalization brought about by incremental
 cost savings  and federal and state assistance the local taxpayers can,
 through their local  elected officials, implement the State Basin Plan
which will improve the environmental quality in our area.

On behalf of  the Board of Directors of the Moulton Miguel Water District
and their residents  and taxpayers, may I respectfully request your
approval  of the All so Water Management Agency's Plan 2-G.

Sincerely,

MOULTON MIGUEL WATER DISTRICT
      /
     /
H. Les Remmers
Vice-President

CJK:slh
                /
                                  9-76

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                         SUMMARY COMMENTS

                   Moulton Miguel  Water District
                          March 25, 1975

1.   The qualified voters in the Moulton Niguel Water District over-
whelmingly approved a June 1968 general obligation bond election
authorizing the MNWD to issue $26.7 million in bonds to provide long-
range water and sewerage facilities.

R-l.  The issue of "qualified voters" was raised at the public hearing
on this project.  In California water districts, "qualified  voters"
are determined by land ownership,  in direct proportion to ownership.
Thus, approval of bonds by qualified voters does not necessarily denote
popular support.  Within AWMA, in  the Moulton Niguel  Water District,
the majority of the land is undeveloped.  The bond election  in 1968
did receive popular support.
                               9-77

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 April  10,  1975
                                                  27500 La Paz Road, Laguna Miguel
                                                  California 92677,  Phone 831-2500.
 United States
 Environmental Protection Agency
 Pacific Southwest Region IX
 100 California Street
 San Francisco, California 94111
 Attention:
 Regarding:
Mr. Paul De Falco, Jr.
Regional Administrator

Draft Environmental Impact Statement
Regional Wastewater Treatment System
Aliso Water Management Agency
Mr. James McGrath, Project Evaluator
 Gentlemen:
The Moulton-Niguel Water  District would  like  to offer  the  following  comments  in
response  to  the draft  Environmental  Impact  Statement  (EIS)  for  the ATI so Water
Management Agency  (AWMA)  project.

One of  the basic concepts  in  implementing the regional AWMA project  and the
incentive to the Moulton-Niguel Water District and other member agencies to
participate was the premise that the costs  to any agency for participation
in the  project would be less  than the costs of the agency  proceeding on its
own.

In order  to justify the Moulton-Niguel Water  District's participation  in the
regional wastewater treatment plant, the District finds it  essential to have
a site  where at least  eight million gallons per day (mgd) of treatment plant
capacity can be constructed for the Moulton-Niguel Water District in con-
junction with a regional facility for joint operations.  Otherwise,  it is not
economically feasible  for  the District as to  either capital costs or operation
and maintenance costs.

Based upon the detailed wastewater treatment  plant estimate by  VTN,  dated
March 20, 1975, of $10,806,340 for a 12 mgd plant, and $12,280,770 for a 16 mgd
plant;  a 4 mgd share of a  16 mgd plant is $3,070,000, and a 4 mgd share of a
12 mgd  plant is $3,602,000.

The water reclamation  feasibility study prepared by Brown and Caldwell for the
Moulton-Niguel  Water District in July of 1973, in response  to the Environmen-
tal Protection Agency's (EPA) concern relative to expansion of  the Improvement  ,
District No.  1-A and Improvement District No.   2-A's water treatment  plants,
                                     9-78

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United  States
Environmental  Protection Agency
April 10,  1975
Page Two


estimated  the  cost  (ENR-2250) for a 4 mgd plant to be $5,591,000, with annual
operating  costs of  $370 per million gallons of water treated.  Brown and
Caldwell's estimate for a  16 mgd plant was $11,841,000, compared to VTN's
estimate of $12,280,770, and the estimated annual operating costs for an
18.6 mgd plant of $97 per  million gallons of water treated.

The site back  of the existing plant, beside being geologically hazardous, with
half the surrounding slopes being designated as landslide  areas (see attached
map), cannot accommodate the capacity of the City of Laguna Beach, the Irvine
Ranch Water District, and the South Laguna Sanitary District, plus Improvement
District No. 1-A of the Moulton-Niguel Water District.  Therefore, a 4 mgd
additional plant would be  required for Improvement District No. 1-A and a
4 mgd plant required for Improvement District No. 4-A, the most suitable site
would be where all  plant operations could be consolidated, which is the pro-
posed regional plant site.  To gravity from Improvement District No. 1-A, a
joint plant with Improvement District No. 4-A would have to be either at the
horseshoe  bend area (environmentally undesirable) or at the proposed regional
plant site of  Alternative  No. 2-G, or two separate 4 mgd plants.

In addition, the restricted alternative No.  1-A site varies in elevation from
160 feet at the top of the usable ground to 40 feet at the bottom of the usable
area.  The plan developed  for the site in March 29, 1973, and attached hereto,
still had to utilize lands within the Aliso Valley on both sides of the existing
South Laguna/Moulton-Niguel plant in order to meet the capacity requirements for
the prior project which had envisioned the expansion of Moulton-Niguel  Water
District's Nos. 1-A and 2-A plants at their existing site.  This alternative
subsequently was determined to be undesirable due to the type of treatment method
utilized at those locations.

With the proposed Alternative No. 1-A treatment works spread over a 100 foot
variation in elevation, additional pumping will be required to reach the head
works for all  participants.

Due to the landslide areas, no cuts can be made in the toe of the slopes and
drainage from  further up the canyon will  have to be accommodated through the
proposed plant site.

Environmentally, people utilizing a trail system or facilities in the floor
of the Aliso Valley would view and face a 100 foot vertical  scarring and
observe the treatment works terraced down over a 120 foot vertical  line, plus the
disruption of the valley;  compared to Alternative No.  2-G's  site with an average
width plant site of 400 feet horizontally transversing the valley,  which can
be shielded effectively by use of trees and  the triple buffer adjacent  to and
within the area to be set aside  for the mountains to the sea's trail  system.
                                      9-79

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 United States
 Environmental Protection Agency
 April 10, 1975
 Page Three


 The cost of two 4 mgd plants  at $5,591,000 each  totals  $11,182,000.  As  this
 cost includes items  for expansion,  the costs could  possibly  be  reduced  by
 $1,000,000 each by elimination  of the provisions for expansion to $4,591,000
 per plant for a total  of $9,182,000, compared  to the cost of two 4 mgd
 increments of a plant of 16 mgd capacity  totaling  $6,140,000,  or a total
 additional  cost to the Moulton-Niguel Water District of $3,042,000 to
 $5,042,000, compared to its potential grant for treatment capacity of approxi-
 mately $716,000.

 Minimum site development costs  per  treatment plant site would  range between
 $650,000 and $1,000,000 for each additional  plant  site.

 To  meet the restrictive sizing  of the ocean outfall, the Moulton-Niguel  Water
 District will  need to  develop a total capacity for reclamation  or other  dis-
 posal  of approximately 4 mgd.   This 4 mgd  capacity plus the total capacity of
 Los  Allsos  Water  District and El  Toro Water District in the summer, will
 provide a total ultimate reclamation potential of  15 mgd which  at a use  of
 3 acre feet per acre per year is  adequate  to supply between 3,000 and 3,500
 acres  of fully irrigated parks  and greenbelts.

 Therefore,  the regional  site, to  be economically viable under alternative
 No.  1-A must have  a  minimum size  of 18.8 mgd including  the present plant rated
 at  2.6 mgd.   This  includes 4.4  mgd for the  City of Laguna Beach, 3.0 mgd for
 the  Irvine Ranch Water  District,  0.2 mgd for  the Emerald  Bay Services District,
 3.2 mgd  for  the South  Laguna Sanitary District, and 8.0  mgd for the Moulton-
 Niguel  Water District.

 In further  response  to my comments made at  the EPA  public hearing, relative
 to the approval of the Moulton-Niguel Water District's  bond issues in 1968,
 I would  like  to advise you that on an assessed value basis, the bond issues
 carried  by a  98.4  percent.

At that  time, developed  homes represented approximately  30 percent of the
 total  assessed value of  the sewer improvement districts.  Assuming the total
 1.6 percent  no vote  represented the 30 percent of the homeowners, the total
homeowner vote equates to 94.7 percent in favor of the project.  Based upon
the assessed values of the land for the homeowners, only 84 homeowners out
of 2,930 voted against the bond issue.   The District must conclude from these
figures  that the homeowner populace of the District stands fully behind the
proposed bond issues for the District's sewer projects.

In conclusion, although some variations of Alternative No.  1-A may be
feasible, the alternative of utilizing the limited  area  available as  the
                                      9-80

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 United  States
 Environmental  Protection Agency
 April 10,  1975
 Page  Four


 wastewater plant site back of the existing plant seems completely unfeasible
 both  economically and environmentally, as it precludes establishment of
 the most cost  effective treatment system unless both sites are ultimately
 developed.

 Alternative No. 2-G still provides for utilization of the existing Los Alisos
 and El  Toro Water Districts' capacity throughout the Aliso Valley to the extent
 of the  capacity of these present plants totaling approximately 7 mgd.  This is
 adequate to develop approximately 1,500 to 2,000 acres of irrigated parks and
 greenbelts.  Development of this demand for use should take over 10 years, and
 covers  more than the initial planning period for this phase of treatment works.

 The selection  of Alternative No. 2-G with the treatment plant at the proposed
 regional plant site can be compatibly incorporated into the environmental
 element of the lower Aliso Valley, particularly when this represents 17 acres
 out of  a total of 6,000 acres of greenbelts, parks, and open space, and
 continue to provide flexibility to accommodate future decisions relative to
 the maximum reclamation potential and treatment plant capacity.  Further,
 and extremely  important to maintaining the viability of a regional  project,
 is retention of a project with the minimum cost impact to the agencies which
 will be contributing approximately 80 percent of their share of the cost of
 the facilities from local taxpayers'funds.

 Again,  this agency must emphasize the urgency of moving ahead immediately,
 to prevent further delays,  which have already resulted in cost increases of
 approximately $8,000,000 (eight million) for the Ocean Outfall, Regional
 Plant,  and Aliso Creek Interceptor.

 Sincerely,

MOULTON-NIGUEL WATER
H. Les Remmers
Vice President
Board of Directors

WFW/HLR:rfh

Enclosure
                                     9-81

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                           SUMMARY COMMENTS

                     Moulton Miguel Water District
                            April 10, 1975

 1.    Participation in a regional wastewater treatment plant with capacity
 of  less  than eight million gallons per day (mgd) could not be justified
 by  the Moulton-Niguel Water District as it would be economically unfeasi-
 ble.

 R-l.  The current flow from MNWD is 1.4 mgd.  Rate of growth cannot
 be  accurately predicted.  Thus, cost effectiveness depends on having
 facilities which are appropriately sized.  Where the rate of growth
 cannot be accurately predicted, flexibility is highly desirable.

 2.    The site behind the existing SLSD plant is geologically hazardous,
 and is too small to accommodate a plant large enough to serve the City
 of  Laguna Beach, the Irvine Ranch Water District, the South Laguna Sanitary
 District, and Moulton-Niguel Water District Improvement District No.
 1-A.

 In  order to permit gravity flow from both Improvement Districts No.
 1-A and 4-A, a regional plant would have to be located at either Horseshoe
 Bend  or the Concept 2-G site.  The alternative is for each Improvement
 District to have its own 4 mgd plant.

 R-2.  True, it cannot accommodate all flows, but it can accommodate
 all flows until MNWD flows develop to where they need a treatment plant.
 This  flexibility is viewed as highly desirable.

 3.    The site behind the existing SLSD plant was determined to be un-
 desirable because of the site's topographic constraints.  The planned
 expansion of the existing South Laguna/Moulton-Niguel plant was based
 on plans to expand the existing Moulton-Niguel Water District's Nos.
 1-A and 2-A plants.  This alternative was discarded because of the type
or  treatment used at the latter plants.
  r
 R-3.  EPA envisions treating all M-NWD flows upstream when and if the
 undeveloped areas do develop to a sufficient degree.   The eventual  solution
 for the MNWD depends upon the outcome of the Facilities Plan addendum
 (See Chapter 5.0 of the Final  EIS).

4.   Because the Alternative 1-A treatment plant is spread over a 100-
foot variation in elevation,  additional  pumping will  be required for
all  participants to reach the head works.

R-4.  True,  but this would be comparable to  pumping back upstream for
future reclamation.

5.   Concept 2-G's plant site would be more  aesthetically pleasing,
as it could be shielded by landscaping.  Alternative  1-A would disrupt
the valley and be more visually intrusive.
                                   9-82

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R-5.  It is a value judgment as to which is more disruptive.  The
comments received on the project are more concerned about use of
the valley bottom in Aliso Canyon.

6.   Because of the restrictive sizing of the ocean outfall, the
Moulton-Niguel Water District will need to develop a 4 mgd capacity
for reclamation or other disposal.'  In order to be economically
viable, the regional plant in Alternative 1-A must have a minimum
size of 18.8 mgd.

R-6.  EPA anticipates treating all MNWD upstream, reducing the regional
site under Alternative 1-A to 10.8 mgd.  Capacity for flows from
IRWD are not needed at this time and may never be needed.  It is
true that it would be cheaper for MNWD to treat 8 mgd in a 18.8
mgd treatment plant than in an 8 mgd treatment plant.  This must
be balanced against head loss for future reclamation purposes and
adverse primary and secondary impacts  (See R-3).

7.   The Moulton-Niguel Water District's 1968 bond issue was opposed
by only 84 homeowners out of 2,930 homeowners voting.  On an assessed
value basis, the bond issues carried by 98.4%.

R-7.  It appears that the bond issue met with popular support.
                               9-83

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                                                                /0
ENVIRONMENTAL COALITION OF ORANGE COUNTY, INC.
2OB W. 4TH ST..SUITE31B, SANTA ANA, CALIFORNIA 927O1
March 19, 1975
U.S. Environmental Protection Agency
Attn: Hearings Office,  HE 118
Region IX
100 California Street
San Francisco,  Ca  94111
RE:  The Aliso Water Management Agency Project  Federal  EIS
Gentlemen:

This transmittal letter is to acknowledge  that  Dale A  Secord
ha a been given authority by the  Board  of Directors of  the
Environmental Coalition of Orange County,  Inc.  to speak  on
behalf of the organization.

The Environmental Coalition has  made its position on this
issue rather clear in previous written and oral  comments.
Please consider the attached written comments and our  repre-
sentative's (Dale A Secord) oral comments  at  the March 25,
1975 public hearing in your deliberations.
Sincerely,
Environmental Coalition
Board of Directors
Herb Baasch
                                    (absent)
1st District :

2nd District :  Margaret Carl berg  'Tlla/a/tit

3rd District :  Chuck Greening

4th District :  Gerald Podolak

5th District :  Harry Jeffrey
                           9-84

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ENVIRONMENTAL COALITION OF ORANGE COUNTY, INC.
2O6 W. 4TH ST..SUITE31B, SANTA ANA, CALIFORNIA 927O1
March 24, 1975


U.S. Environmental Protection Agency
Attn: Hearing Office,  HE 118
Region IX
100 California Street
San Francisco, Ca   94111


RE: D-EPA-24011-CA Draft EIS on Aliso Water Management Agency


Hearing Officers:

Please consider the attached critique and evaluation of the
draft Environmental Impact Statement for the Aliso Water
Management Agency project.

The Environmental Coalition will submit additional materials
at a latter date.


Sincerely,
Dale A Secord
Executive Director
Environmental  Coalition
                            9-85

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ENVIRONMENTAL COALBTION OF ORANGE COUNTY, INC.
2O6 W. 4TH ST..SUITE316, SANTA ANA, CALIFORNIA 927O1


March 24,  1975
Paul DeFalco, Jr.
Regional Administrator
U.S. Environmental Protection Agency
Region IX
100 California Street
San Francisco, Ca   94111


RE: Draft Environmental Impact Statement  D-EPA-24011-CA
    Aliso Water Management Agency


Dear Mr. DeFalcb:

The Environmental Coalition of Orange County, Inc. requests the
Environmental Protection Agency (EPA) deny the Clean Water Grant
requested by the'Alison-Water Management Agency (AWMA).  We urge
the EPA to consider all environmental and social impacts in
their determinations - too often considerations are limited to
economics.

The EPA should be commended in its attempt to surface and assess
the significant environmental effects which would result from
the Federal government's action (i.e., possible financial
support).  The decision by the Regional EPA Administrator can
only be as good as the information provided to him upon which
to. oase that Judgemental decision.  Unfortunately, tne Federal
draft Environmental Impact Statement (EIS) for the AWMA regional
wastewater treatment system is inadequate and insufficient in
many respects.

PROCEDURES

Because of the complexity and importance of this proposed
project the Environmental Coalition urges that the public
hearing scheduled for March 25, 1975 in Laguna Niguel be con-
tinued to allow greater public participation in the planning
process.  Section 6.40 of the Environmental Protection Agency's
Interim Regulations for the preparation of environmental impact
statements (Federal Register, Vol 38, No 11) suggests that the
Agency actively solicit comments.from all concerned and affected
groups and individuals.  Because of the size of AWMA (approxi-
mately 48,905 acres) we would suggest that additional hearings
be held in Laguna Beach and El Toro.
 "*A>
The Enviconment&l Coalition would like to request that the
record remain open after the close of the public hearings so
that additional written comments may be obtained.  We would
suggest a JO day time period for additional written comments.
                            9-86

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AWMA EIS
CONTENT OF THE DRAFT SIS

The body or content of the draft EIS is incomplete.  Section
6.32(g) of the EIS Guidelines requires a discussion of problems
and objections raised by other Federal, State and local agencies
and by interested persons.  In the draft EIS this previous
public imput is summarized in a page and a. half.  This section
of the draft EIS does not adequately summarize the comment!? and
suggestions made during the review process of AWMA environmental
impact report prepared under the guidelines established by the
California Environmental Quality Act of 1970.  The review and
actions of other responsible agencies  (i.e., public agencies
involved in carrying out or approving  the project) are not
discussed.  It is hoped that the Final EIS will address some
of these previous comments, reviews and actions as well as
describing the disposition of the Issues surfaced (e.g., revision?.
to the proposed project to mitigate anticipated impacts or
objections).

Although, the Federal EIS Guidelines do not require a section
on cumulative effects, Section 6.20(a)(3) does discuss this
aspect of significant environmental effects for determining
when to prepare an impact statement.   The Guidelines state,
"The total expected environmental impact of precedent-setting
actions and individually small but cumulatively large actions
shall be identified and considered fully.  If the Agency is
taking a number of minor, environmentally insignificant actions
that are similar in execution and purpose, especially when
they are taken during a limited time span and in the same
general geographic area, the cumulative environmental impact of
all of these actions, may be significant."

In addition, Section 6.32(a) of the Guidelines requires a
statement of other relative planning.  According to the section
the'EIS is to "Describe the recommended or proposed action,
its purpose, where it is located, its  time setting, and its
interrelationship with other projects  or proposals." (emphasis
added)."To prevent piecemeal decisionraaking, the project
shall be described in as broad a context as possible.  The
relationship to other projects and proposals shall be discussed,
including: not only other Agency activities, but also those of
other Governmental and private organizations."

The EPA has already approved Federal Clean Water Grants for
Irvine Ranch >vater District's  (IRY/D) Rattlesnake outfall a^ci
is prsently considering  a grant application for the Southeast
Regional Reclamation  Authority (SERRA).  The cumulative
adverse impact of the secondary affects of the three projects
has never been addressed or considered.
                             9-87

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 PAGE  3
 AWMA  EIS
 In addition,  the draft EIS does not address the relationship
 of this proposed action to other Governmental agencies and
 private organizations.  There is little discussion of the
 relationship  of the proposed AWMA project with the permit
 application granted by the Regional and State Coastal Zone
 Conservation  Commission of California.

 The EIS does  not contain any statement of other relative plan-
 ning by other governmental agencies.  There is no discussion of
 the relationship of this proposed project with the relative
 planning of the County of Orange (General Plans and South East
 Orange County Transportation Study, Laguna Greenbelt Study
 and the Aliso Creek Study), of the City of Laguna Beach and
 of the California Coastal Zone Conservation Plan.

 The impact of construction is not adequately covered by this
 Federal draft EIS.  We are aware that AWMA has prepared their
 own "Construction Impact draft SIR under CEQA Guidelines but
 we consider that draft EIR inadequate.  Section 6.57 of the
 EIS Guidelines describes the extent or the contents necessary
 for wastewater treatment facilities.

 The Environmental Coalition considers this Federal draft EIS
 and jflTWMA's draft "Construction Impacts" report inadequate for
 the Corp of Engineers approval of activities under Section 103
 of the Marine Protection, Research and Sanctuaries Act (PL 92-
 532) and Section 404 of the Federal Water Pollution Control
 Act (PL 92-500).

 DISTRIBUTION  LIST

 1 . The AWMA draf-t-EIS distribution list incorrectly lists
   agencies,  organizations and individuals under improper
   categories.

 2. After comparing Table 2-20 (Summary of Governmental Author-
   ity) with  the distribution list it is significant that
   several important agencies were apparently not sent a copy
   of the draft EIS for review.  These agencies include: U.S.
   Fish & Wildlife Services, SCAG, Orange County Transit
   District,  O.C. Flood Control District, O.C. Air Pollution
   Control District, O.C. Board of Supervisors, and O.C.
   Road Department.  Section 6.23 of the EIS Guidelines
   requires the draft EIS to be sent to all appropriate State
   and local  agencies.

 CLARIFICATION OR ELABORATION OF INFORMATION

 There are numerous areas within the draft EIS that require
 an elaboration or clarification.

1. pp.  2-67,  Table  2-19:   Date  of  data  should  be  provided  and
   total .AWMA  per  capita  flows  should  be  shown.
                            9-88

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PAGE 4
AWMA EI3


2. pp. 2-68, Section 2.14.1
   pp. 2-69, Section 2,. 14.3
   pp. 2-70, Section 2.14.4
   pp. 2-71, Section 2.14.5
The term "qualified voters" should be clarified.  It should
be pointed out that voting for the Board of Directors and for
authorization of bonds is done by an assessed valuation of
land and not by popular vote.

3. Exibits 3-2, 3-4, 3-6, 3-8, 3-10, 3-11, 3-13
The schematic diagrams for the alternatives shows the 1995 flows
and sizes for the proposed facilities.  The ultimate or maximum
flows or capacity should also be provided.  Also, it is not
clsar whether the flows are average or peak flows.

4. pp. 4-8: The statement that "more than 75$ are opposed to
low or middle".income housing for less affluent whites or non
whites" should be documented.

5. Exibit 4.8:  It would be helpful if a second graph and table
showing alternative population forcasts for the AWMA .area was
included.

6. Exhibit 4-9:  It is not clear whether the wastewater flows
are average or peak flow.  Also, it is not clear what the nota-
tion "Ultimate Population Reflected on Adopted General Plans"
is suppose to designate.  The entire graph should be redone
using a daily per capita flow of 100 gpd.

7. pp. 4-15: The April 16, 1973 date refers to the South Coast
Regional Coastal Zone Conservation Commission approval.  That
decision was appealed and the State Coastal Commission on June
20, 1973 after accepting the appeal modified the Regional permit
to subject AWMA to capacity limitations.

8.  pp. 4-15:  The Irvine Regional Center is discussed in Section
4.3.5 and shown on Exhibit 4-14.  This has not been established
nor is it currently growing.  The City of Irvine has approved
pre-annexation zoning only.

9. pp. 4-19:  It is not clear whether the  emissions of 558
tons/day of RHC for various stationary source controls and
emission controls upon mobile sources takes into account the
latest delays in implementing exhaust standards by EPA.

10. pp. 8-1: The data on energy requirements should indicate
the time period considered, (i.e., ten years or 20 years);


QUESTIONABLE ASSUMPTIONS

1. pp. 4-20 and Appendix B:  The analysis of vehicle miles
travelled (VMT) Increases is based on some highly questionable
assumptions.
                            9-89

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 PAGE 5
 AWMA EIS
 The  factor of  7.98  miles  per  trip  is apparently  Incorrect.

                              B
 .(H-^G)       5.76:; miles    6.92 miles    8.36 miles    10.99 miles
 (0-0)       4.82          5.54          6.44          8.5?
 (0-W)       7.24          8.33          9.69          12.15
 (H-W)       9.12         10.49          12.21          15.31
 (H-S)       3.09          3.50          4.08          5.j1
 Average     b.24 miles    7.2 miles     8.15 miles    10.43 miles

 A =  1967  data, LARTS Study
 B =  Gal Trans, 1971
 C =  Straight line  projections  to 1985 assuming Col  B currently
     used  in 1975
 D =  Straight line  projections  to 1985 assuming Col  B as 1971
     data  only

 Thus instead of 7.98 miles per trip  the calculation should use
 either 8.15 or 10.43 miles per trip.  Using the 3.82 trips per
 capita and  the three average trip allocations of 7.98, 8.15 and
 10.43 miles the daily per capita VMT would be 30.5. 31.3 and
 39.9 miles. The means  of the  commuter mileage for  the AWMA
 area as indicated  in Table 4.4 would also support the higher VMT.

 The  traffic generation  factors generated in Appendix B are not
 applicable  for the AWMA  area.   These are regional approximations.
 As pointed  out on pp. 4.21 of  the draft EIS, "The South County
 Study, and  other raw data developed by OCTD, indicates that
 people in the AWMA area  travel  about 30$ further per week than
 people elsewhere in the  county."

 This questionable principal assumption of miles per trip clouds
 the  accuracy of all the  VMT and air quality calculations.

 2. pp. 5-1:  There have  been no cost-effective analysis done
 to support  the statement that  Alternative 2F is the most cost-
 effective alternative over a 20-year period.

 3. Exhibit  4-9:  The Aliso WMA  has consistently attempted to
 obtain greater capacity  by exagerating population forcasts,
 commercial  and industrial needs for the area, seasonal popula-
 tion increases, infiltration and peak flow.  The facilities
 shotiiid be constructed with a capacity reasonably  necessary to
 satisfy appropriate engineering standards.

 Infiltration;   A'WMA apparently  is requesting a 15 gallon per
 person per  day for infiltration.  This is absurd!    The 1972
AWMA £reject Report stated,  "Since the pipe Joints  in use today
are water tight,  infiltration  should be minimal at  joints;
however,  some  amount of  Infiltration is experienced at manholes,
not only from  groundwater but also from surface water period-
ically in areas where manhole  covers are in streets." (pp.  53).
                            9-90

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PAGE 6
AWMA EIS


The question of the amount of infiltration experienced at the
manholes is addressed in the Project Report for SERRA  (pp IV -
41, 42).  That report stated there was no correlation  between
precipitation and maximum daily flows during 1970 and  during
1968-69, a wet year when precipitation totalled 159.2$ of the
mean, only 3 days of peak sewage flow coincided with rainstorms.

Industrial/Commercial;  It is understood that AWMA is  requesting;
additional capacity for industrial and commercial wastewater
flows.  Only a few industrial plants are presently located
within, or are planned for, the AWMA area.;  None of these
plants fall into the category of wet-process industry, using
and discharging large volumes of water.  The principle contri-
bution of the few industrial plants connected to the participa-
ting agency sewer systems is sanitary sewage.  Volumes of liquid
industrial wastes discharged to the sewer system are minor,
amounting to only a fraction of the sanitary sewage flow gener-
ated within the same buildings.  Industrial and commercial waste
discharges have virtually no effect upon the quantity  and flow
patterns of the total sewage flow within the AWMA area.

Seasonal; Exhibit 4-9 indicates that there would be a .constant
seasonal wastewater flow of about 3 mgd.  The State WRCB staff
recommended certain seasonal flows for two segments of AWMA's
service area.  In the area of South Laguna, the staff had used
seasonal flows of 0.33 mgd by 1985 and 0.41 mgd by 1995.  In
the area of the City of Laguna Beach, the staff had allowed
seasonal flows of 1.63 mgd by 1985 and 2.16 mgd.by 1995.  AWMA
petitioned the State WRCB for a Review of the staff determina-
tions.  Subsequently the Laguna Beach seasonal allowances were
increased to 2.15 ragd and 2.76 mgd, respectively.

Domestic;  AWMA is apparently requesting a domestic (excluding
commercial and industrial) flow of 100 gallons/day/dapita.
Table 2-19 of the draft EIS shows population and wastewater
flows.  The per capita flow for the entire AWMA area is 91.5
gpcd for the resident population and 93 gpcd with transient
population Included.  These per capita flows include infiltra-
tion and commercial/industrial flows and are not strictly
domestic wastewater flows.  These flows are supported by prev-
ious data within the 1972 Project Report.  According to page
28 or the 1972 report a flow rate of 92 gpcd was experienced
in 1972 (population, 66,150 and average dry weather flow of
6.10 mgd).  Domestic wastewater flows without industrial,
commercial and infiltration should be about 60-70 gpcd.
The State WRCB has allowed a per capita flow of 87.4 gpd (this
apparently includes domestic,  commercial, industrial and infil-
tration flows).

The Final EIS should address these factors of wastewater flows.
Also, EPA should eliminate funding for capacity in excess of
that reasonably necessary to satisfy appropriate  engineering
standards.
                            9-91

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PAGE 7
AWMA EIS
ALTERNATIVES

1 .   It would be helpful if:.there was a table cross referencing
alternative designations  in  the Federal draft EIS, previous  1972
AWMA  Project Report..and EIR  and 1974 AWMA Project Report and EIR.

2.   According  to  Section  6.32(d) of the Federal EIS Guidelines
the  draft  EIS  must,  "Develop, describe, and objectively weigh
alternatives to any  proposed action which involves significant
tradeoffs  among the  uses  of  available environmental resources.
The  analysis shall be structured in a manner which allows
comparisons of: (1)  Environmental and financial cost differences
among equally  effective alternatives, or (2) differences in
effectiveness  among  equally  costly alternatives.  Where practi-
cable, benefits and  costs should be quantified or described
qualitatively  in  a way which will aid in a more objective
judgement  of  their  value.   Where such an analysis is prepared,
it shall be appended to the  statement."

There is no analysis of the  benefits and costs of the environ-
mental and financial differences of the suggested alternatives.
Thus  the reviewer cannot  easily Judge the relative desirability
of the alternatives.  It  is hoped that'this deficiency will be
remedied in the Final EIS.

3. The EIS Guidelines also require "The analysis of different
courses of action shall include alternatives capable of substan-
tially reducing or eliminating; any adverse impacts, even at the
expense of reduced project objectives." (Emphasis added).

It appears that all  the alternatives are based on a design
population range  of  170,000  to 250,000.  The prima facie evidence
of secondary effects on air quality indicates that no alternatives
have  been considered to substantially reduce or eliminate the
adverse impacts.  We would urge that additional alternatives
which have facilities with reduced capacities or elimination of
extensions of  some of the interceptors be evaluated.

4. The EIS Guidelines also requires the specific alternative of
taking no action  be evaluated.  The extent of such an evaluation
is limited to  a short paragraph (pp. 4-25) under the Chapter
titled "Options Available to EPA".

5. The wastewater reclamation alternative 3C is incomplete and
inadequate.  Maintaining existing beneficial uses of water and
the limited supply available for importation at a rising cost
requires the reclamation or reuse of water instead of simply
treating and disposing of water after a simple use.  Reclaimed.
wastewater presently has a variety of benefical uses.  Reclaimed
uses have expanded from mainly crop irrigation to include parks,
greenbelts, golf  course irrigation,  industrial processes and
cooling, recharging groundwaters and recreational water supply.

The Federal Water Pollution Control  Act Amendments of 1972
encourage wastewater management which results in construction of
revenue-producing facilities for wastewater reclamation.  The


                              9-92

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PAGE 8
AWMA EIS                        j                  "
                                v


Porter-Cologne Water Quality Control Act states that it is the
intention of  the California Legislature that the State undertake
all possible  steps to encourage development of water reclamation
facilities so that reclaimed water may be made available to help
meet the growing requirements of the State, and directs the State.
Water Resources Control Board to give added consideration to
grant applications for wastwater treatment facilities which will
provide water reclamation reuse.

There is support for wastewater reclamation from those who oppose
pollution and those who view water as a limited resource in terms
of economic value.  The attitude of the public on use of reclaimed
water is rapidly changing.  A recent opinion survey in the Marin
Municipal V/ater District (Ref: California SWRCB News & Views,
Vol VI, No 1) showed that approximately 65 percent of the people
said that they would have no concern using reclaimed wastewater
for nonconsumptive uses and that a suprising 25 percent of the
people stated that they would have no problem accepting reclaimed
water for domestic and drinking purposes.

Other wastewater reclamation alternatives were not evaluated.
The draft EIS alternative 3C is based on utilizing two advanced
wastewater treatment facilities with tertiary processes such as
denitrification, chemical clarification, carbon absorption and
chlorination.

We would urge that other schemes involving wastewater reclamation
to serve existing developed areas be evaluated.  These alterna-
tives should  strive to meet the project objectives (eliminating
water pollution and improving water quality) while substantially
reducing or eliminating the adverse secondary impacts (increased
VMT and degradation of air quality).  Pressure pipe treatment
(e.g., IRWD Rattlesnake outfall) or land treatment methods (see
attachment) should be addressed for each of the five service
areas (north  coast, lower aliso creek, salt creek, middle aliso
creek and upper aliso creek).

Each alternative should be discussed in relationship to the long
range goals of the 1972 Amendments to the Federal Water Pollution
Control Act.
    1977 Goal: minimum of secondary treatment
    1983 Goal: achieve "best practicable waste treatment tech-
         nology" and body contact water quality
    1985 Goal: zero discharge of pollutants

MITIGATION

One of the problems with most of the mitigation measures suggested
in the draft EIS is their enforceability.  All the potential
mitigation measures evaluated by the applicant are lofty.
Unfortunately, they require implementation by general purpose
governments,  a transit distirct and voluntary efforts of residents.

The applicant has control over several potential mitigation
measures including but not limited to the following:


              -              9-93

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PAGE 9
AWMA EIS
1. Original size of facilities (outfall, interceptors and treat-
   ment plant).

2. Location of interceptors.

3. Staged construction of proposed facilities.

4. Future extension of both water and sewer trunks and mains.

5. Immediate revision of method of voting procedure for the
   Board of Directors for the four California Water Districts
   to assure a popular vote.

Potential mitigation measures suggested by the applicant could
possibly be facilitated by requiring as a condition of approval
that the general purpose government within six months of approval
complete the following:

1. Prepare an Air Quality element for their General Plan.

2. Limit construction of arterial highways within AWMA to reduce
   VMT.  All arterlals now shown on the Master Plan of Arterial
   Highways be removed.

3. Alter the land use element of the General Plan to provide
   high density cluster residential development with neighborhood
   shopping centers rather than low density development with
   regional shopping centers.

4. Prepare a parking management plan for the GSA facility and
   all other facilities within AWMA which would have over 1000
   parking spaces.

5. Adopt a growth policy for the AWMA area consistent with the
   E-0 projections.

6. Subsidize low and moderate income housing in the AWMA area.

APPENDIX B

The air quality analysis is inadequate.  As mentioned earlier
in this paper the validity of the average trip length of 7.98
miles is questionable.  Air quality data should be generated for
both 1985 and 1990.  The emission calculations should be revised
to reflect recent EPA delays in implementing exhaust emission
standards.

SUMMARY

1. The public hearing should be continued at other locations
   within the AWMA area and the record should be kept open for
   a 30 day period after the close of the public hearings.

2. The EIS should address and evaluate cumulative effects of
   this and other similar proposals in the general area.
                           9-94

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 PAGE 10
 AtfKA EIS
 3. The draft £13 should be sent, immediately, to all appropriate
    State and local agencies.

 4. Revise the analysis of VMT and air quality to incorporate a
    more accurate estimate of average trip distance.

 5. Address the factors of domestic, industrial, commercial,
    seasonal and infiltration factors of wastewater flows.

 6. Analyze benefits and costs of the environmental and financial
    differences of the suggested alternatives.

 7. Evaluate alternatives capable of substantially reducing or
    eliminating any adverse impacts.

 8. Explore other wastewater reclamation alternatives.

 9. Demand implementation of mitigation measures within the
    authority of the agency.

10. Push for other mitigation measures to be implemented by a
    general purpose government.

11. Correct and expand the air quality analysis.
1. The Environmental Coalition recommends that EPA immediately
   adopt a mandatory policy of denying federal clean water grants
   where secondary effects would contravene federal or state
   environmental standards.  Prior to issuance of clean water
   grants the applicant would have to revise the project or
   implement mitigation measures to substantially eliminate the
   adverse secondary effects.

2. The Environmental Coalition recommends that the geographical
   area within the Jurisdiction of the Southeast Regional•Recla-
   mation Authority (SERRA), the Aliso Water Management Agency
   (AWMA) and the Irvine Ranch Water District (IRWD) be designa-
   ted for 208 planning.

3. The Environmental Coalition requests the EPA deny the Aliso
   Water Management Agency clean water grant application.


Sincerely,


Dale A Secord
Executive Director
•Lnvironmental Coalition
End.
                              9-95

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                         SUMMARY COMMENTS

            Environmental Coalition of Orange County, Inc.

 2.    The  record  should remain open 30 days after the close of the public
 hearings  so that additional written comments may be obtained.

 R-l.   The record remained opened well into June.  Sufficient hearings have
 been  held over the  life of the project to establish the nature of public
 concerns.

 2.    The  EPA has already approved Federal Clean Water Grants for Irvine
 Ranch Water District's (IRWD) Rattlesnake outfall and is presently con-
 sidering  a grant application for the Southeast Regional Reclamation Authority
 (SERRA).   The cumulative adverse impact of the secondary effects of the
 three projects has  never been addressed or considered.

 R-2.   A section  on  the relationship 'of the AWMA project to other projects
 has been  added.  The impacts of the AWMA project by itself are significant,
 and the EPA has  tried to establish mitigation measures accordingly.

 3.    There is little discussion of the relationship of the proposed
 AWMA  project with the permit application granted by the Regional and State
 Coastal Zone Conservation Commission of California.

 R-3.   Chapter 4  has been amended for'clarification of permit application
 guidelines  and the  CCZCC permit has been placed in the Appendix.

 4.    The EIS does not contain any statement of other relative planning by
 other  governmental agencies.

 R-4.   See  4.3.4  and 4.3.2.

 5.    The Environmental Coalition considers this Federal draft EIS and AWMA's
 draft  "Construction Impacts" report inadequate for the Corps of Engineers
 approval of activities under Section 103 of the Marine Protection,  Research
 and Sanctuaries Act (PL 92-532)  and Section 404 of the Federal Water
 Pollution Control Act (PL 92-500).

 R-5.   Possible discussion of construction impacts was edited in the interest
of brevity as the secondary impacts have been the chief concern.   Discussion
 of regional  treatment plant location and construction of the ocean  outfall
 has been expanded in Chapter 3.0 of the Final EIS in response to public concern.
 A detailed  Draft EIR on the construction impacts of the AWMA Project was..pre-
 pared  in February 1975 by Clean Water Consultants.   The report was  later,,
 finalized  in.time.                                                       ?

&.:   The AWMA draft EIS distribution list incorrectly lists agencies,
organizations and individuals under improper categories.   Several important
agencies were apparently  not sent a copy of the draft EIS for review.
 These agencies include:  U.S.  Fish S Wildlife Services, SCAG, Orange County
 Transit District, O.C.  Flood Control District,  O.C.  Air Pollution Control  •
District,  O.C.  Board of Supervisors, and the O.C. Road Department.
                                    9-96

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 R-6.      U.S. Fish and Wildlife Services received through the Depart-
          ment of the  Interior.

          SCAG - see pages ii-13

          OCTD - overlooked

          OCFCD - overlooked

          OCRD - overlooked

          APCD - see pages 11-10

          Supervisor Riley received a copy.

 7.   Pages 2-67, Table 2-19:  Date of data should be provided and
 total AWMA per capita flows should be shown.

 R-7.  So noted in the Final EIS.

 8.   The schematic diagrams for the alternatives shows the 1995 flows
 and sizes for the proposed facilities.  The ultimate or maximum flows
 or capacity should also be provided.  Also, it is not clear whether
 the flows are average or peak flows.

 R-8.  All flows are average.  "Ultimate" flows are impossible to
 determine.

 9.   The statement that "more than 75% are opposed to low or middle
 income housing for less affluent whites or non-whites" should be
 documented.

 R-9.  The statement is from a survey conducted in the spring of 1973
 by the Center for Urban and Regional Studies of the University of
 North Carolina.  Both the cities of Irvine and Fountain Valley were
 included in the survey.

 10.  It is not clear whether the wastewater flows are average or
peak flows on Exhibit 4-9.  Also, it is not clear what the notation
 "Ultimate Population Reflected on Adopted General Plans" is supposed
 to designate.  The entire graph should be redone using a daily per
capita flow of 100 gpd.  It would be helpful if a second graph and
 table showing alternative population forecasts for the AWMA area
was included.

R-10.  All flows  appearing in Exhibit 4-9 are average flows.   Exhibit
4-9 has been modified using 90 gallons per person per day.   A new
Exhibit, patterned after Exhibit 4-8 in the Draft EIS shows alternative
population forecasts for AWMA and its member agencies.
                               9-97

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 21.   On page  4-29:   It  is not clear whether the emissions of 558 tons/day
 of RHC for various  stationary source controls and emission controls upon
 mobile sources  takes into account the latest delays in implementing exhaust
 standards by  the  EPA.

 R-ll.   The emission figures  do assume reductions.  The direction of controls
 is still  appropriate.

 12.   The data on  energy requirements should indicate the time period con-
 sidered (i.e.,  ten  years or  twenty years).

 R-12.   20 years.

 23.   Page 4-20  and  Appendix  B:  The analysis of vehicle miles travelled
 (VMT)  increase  is based on some highly questionable assumptions.

 The  factor of 7.98  miles per trip is apparently incorrect.

 Instead of 7.98 miles per trip the calculation should use either 8.15
 or 10.43 miles  per  trip.  Using the 3.82 trips per capita and the three
 average trip  allocations of  7.98, 8.15 and 10.43 miles the daily capita
 VMT  would be  30.5,  31.3 and  39.9 miles.  The means of the commuter mileage
 for  the AWMA  area as indicated in Table 4.4 would also support the higher
 VMT.

 The  traffic generation  factors generated in Appendix B are not applicable
 for  the AWMA  area.   These are regional approximations.  People in the
 AWMA area  travel about  30% further per week than people elsewhere in- the
 county."

 This questionable principal assumption of miles per trip clouds the accuracy
 of .all  the VMT and air quality calculations.
   <
  > , .
 R-13.   We  believe that  the use of 7.98 miles/trip is justified in present
 VMT  calculations.  Use of 7.98 miles/trip and 3.83 trips/capita give a
 weekly  per capita VMT of 213.5.   The South County Study arrived at 260
 mile/week/vehicle which is a VMT per capita of about 130.   Thus, we have
 used a  high VMT estimate.

 Projections of  future VMT based on assumed increases in miles/trip are
 highly  speculative.  Cost of fuel  and EPA's own TCP may alter current
 trends.  The  significant factor is still  the fact that South County travels
 30% more.

 14.  There have been no cost-effective analysis done to support the state-
ment that Alternative 2F is the most cost-effective alternative over a
 20-year period.

 R-14.  This analysis was done in project  report.   Subsequent analysis
was presented at public hearing on March  25, 1975.
                                    9-98

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25.  The facilities should be constructed with a capacity reasonably
necessary to satisfy appropriate engineering standards, rather than exag-
gerated needs.

R-15.  See Table 4-9 and 4-10 which has been modified to reflect the CCZCC
permit requirements.

16.  Infiltration:  AWMA apparently is requesting a 15 gallon per person
per day for infiltration.  This is absurd'.

R-16.  No infiltration allowances are needed or recommended by EPA.

17.  The final EIS should address Industrial/Commercial, Seasonal and
Domestic factors of wastewater flows.  Capacity in excess of that reasonably
necessary to satisfy appropriate engineering standards should not be funded.

R-17.  Flows in excess of E-0 projections will  not be funded.  See discussion
of CCZCC permit for Maximum Flow in Chapter 4 of the Final  EIS.

18.  There is no analysis of the benefits and costs of the environmental
and financial differences of the suggested alternatives.

R-18.  Cost effectiveness analysis was presented and was in the  project
report, not repeated for brevity.

19.  Additional alternatives which have facilities with reduced  capacities
or elimination of extensions of some of the interceptors should  be eval-
uated.

R-19.  This was the purpose of introducing modified Alternative  1A.

20.  The EIS Guidelines require that the specific alternative of taking
no action be evaluated.

R-20.  The No Project Alternative  was discussed in the Draft EIS in
Section 3.2.7.  A no project alternative would  result in declining quality
of effluent and continued pollution of the near shore waters.

21.  The air quality analysis is inadequate.   The validity  of the average
trip length of 7.98 miles is questionable.  Air quality data should  be
generated for both 1985 and 1990.  The emission calculations should  be
revised to reflect recent EPA delays in implementing exhaust emission
standards.

R-21.  Note that analysis has been dropped.   No reliable model fo esti-
mating  air quality exists.   Therefore, EPA used VMT which provides an
analysis of consistency with control  strategy.
                                     9-99

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22.  Each alternative should be discussed in relationship to the long
range goals of the 1972 amendments to the Federal Water Pollution Control
Act.

R-22.  A discussion of reclamation consistency with this Act has been
added to the Final EIS (See Section 3.2.1.4).
                                    9-100

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                                                                                     h 4 5
                                                                      P. 0. BOX 261
FOOTHILL COMMUNITIES ASSOCIATION, INC.                       TUSTIN, CALIFORNIA 92680


                                                    April 2, 1975             ---:
                                                                              —J
       U.S. Environmental Protection Agency                                   ^>   \-^
       Hearings Office, HE 118                                             '   ^, .5
       Region IX                                                             • ts=  z
       100 California St.
       San Francisco, Ca. 94111                                               <-"   x


       Gentlemen:

       Our association is aware of the far reaching impacts of the Aliso Water
       Management Agency's proposed waste treatment system.  Although the members
       of our organization reside outside of the AWMA boundaries, the facilities
       nonetheless will have secondary impacts on our area, particularly in terms
       of facilitating population increase in southern Orange County with resultant
       increase in traffic which in turn will degrade air quality in the already
       overburdened South Coast Air Basin and may necessitate additional freeways
       which would impact our area.

       We are aware of the necessity of some wastewater treatment facility improvement
       due to the problems with the Aliso Beach and Laguna Beach ocean outfalls and
       the outdated Laguna Beach treatment plant.  We hope that whatever alternative
       the EPA choses to fund for AWMA will solve these problems but also meet the
       following criteria:

            1) it will have the least secondary impacts of all the alternatives,
               especially in relation to its ability to indirectly affect popula-
               tion growth;

            2) no major construction (ie. a waste treatment plant) would be allowed
               in a greenbelt corridor such as the Aliso Creek or Laguna Greenbelts,
               including Woods Canyon, but would be required to be located outside
               these areas which are such valuable recreational and scenic natural
               resources for Southern California;

            3) stringent measures be required of AWMA, the County of Orange and any
               other regulatory agencies involved to mitigate the secondary impacts
               of the proposal.  Those of particular value appear to.be mentioned in
               the EPA's very excellent EIS: clustering of residential development
               with neighborhood shopping centers to reduce VMT, and strong emphasis
               put on development arid use of regional transit systems.  The former
               would require policy changes on the part of the Orange County Board of
               Supervisors, and we would urge the EPA to impress upon the Board the
               necessity of making such changes and encouraging this type of development,
                                          9-101

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Ve thank you for the opportunity to comment  on this project and hope you will
carefully consider our suggestions.
                                            Yours truly,
                                                        yZ*J(r*-"
                                              iomas Lenhart
                                             President

P.S. Foothill Communities Association is  an organization with a membership
of approximately 1000 families in the north Tustin area of Orange County.
                                   9-102

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                              SUMMARY COMMENTS

                    Foothill Communities Association, Inc.
1.   No major construction should be permitted in greenbelt corridors such
as Aliso Creek or Laguna Greenbelt, including Woods Canyon, as these areas
are valuable recreational and scenic natural resources.

R-l.  Sections 3.1.2 and 3.2.2.1.2 in the EIS have been  amended to reflect
these comments.

2.   AWMA, County of Ornage, and other involved regulatory agencies should
be required to mitigate secondary impacts.   EPA should urge the Orange
County Board of Supervisors to make necessary policy changes in order to
encourage clustering of residential and neighborhood commercial development.

R-2.  Chapter 5.0 of the Final EIS describes the selected wastewater manage-
ment alternative for AWMA.  As noted in this chapter, the Final Mitigation
Plan for AWMA will be addressed at the Phase III level of the total  project.
Sections 5.2.2 and 5.3.3 discusses this subject in detail.
                                     9-103

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Organized November 1947, to co-operate in bringing about the greatest possible economist, eoniistent with efficiency, in expenditure! of Public Fundi.

                LAGUNA BEACH TAXPAYERS' ASSOCIATION,  INC.
                P. O. BOX 404           LAGUNA BEACH, CALIFORNIA 92652
       Mr.  Paul  De  Palco                              March 14,  1975
       Director,  and
       Mr..  Covington
       U.S. Environmental Protection Agency, IX
       100  California Street
       San  Francisco,  Calif. 9*4-111

       Gentlemen:

       Enclosed  please find the response concerning the  Federal
       Environmental Impact Statement for the AWMA, Aliso  Water
       Management Agency of Orange County, Cal.

       While we were not selected on the distribution of these
       E.I.S reports,  we feel that we should have beenl  The
       Laguna Beach  Taxpayers'  Assoc. Inc. is one of  the oldest
       established organizations in Orange County, since 19^7 «
       We noted several organizations on the distribution  list
       received two  copies, and many are not incorporated  also
       mentioned on  this list.

       We have requested time to present our public prepared
       statement at  the scheduled EPA public hearing  on  March 25 »
       1975 to be held at the Federal GSA Building 2*100  Avila Rd.
       Laguna Niguel,  Cal.  from Dr.  Mack Wesner, Clean Water
       Consultant, 2232 S.E.  Bristol St. Suite 210, Santa  Ana,
       Calif. 92702.   We 'have also sent Dr.  Wesner our response
       as he was listed as  a consultant for this project.

       If necessary, we wish to also make this request from you
       in order that the L.B.T.A.  will be given time  to  make the
       prepared statement concerning this report at the  above
       scheduled meeting.

       Thank you,
       Sincerely,
       JAMES C. YANCEY
       President                                    JY/mwm
                                      9-104

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            PAGE  1.
10
s
           FORWARD,
           THIS REPORT FROM THE LACUNA BEACH TAXPAYERS' ASSOCIATION, INC. IS A RESPONSE TO
           THE DRAFT ENVIRONMENTAL IMPACT STATEMENT  PREPARED FOR THE REGIONAL WASTEWATER
           TREATMENT SYSTEM OF THE ALISO WATER  MANAGEMENT AGENCY KNOWN ASi A W M A.
           IT IS INTERESTING TO NOTE THAT ONE HUNDRED AND FIFTY-SIX VARIOUS GROUPS WERE
           SELECTED FOR THE DISTRIBUTION OF THIS  E.I.S., MANY  OF WHICH ARE NOT WELL
           ORGANIZED OR INCORPORATED?  HOWEVER,  THE LAGUNA BEACH TAXPAYERS' ASSOC. INC.
           SINCE 19^7 AND BEING ONE OF THE OLDEST ESTABLISHED  ORGANIZATIONS IN ORANGE
           COUNTY WAS NOT SELECTED TO RECEIVE THIS NOTIFICATION AND COMPILATION OF
           ENVTRNOMENTAL IMPACT STATEMENTSI   WE WISH TO KNOW WHY?  	 	
BECAUSE THE L.B.T.A.,  THE LAGUNA BEACH TAXPAYERS' ASSOCIATION, INC. WAS FORMED
IN 19^7 TO COOPERATE IN BRINGING ABOUT THE GREATEST POSSIBLE ECONOMIES, CONSIS-
TENT WITH EFFICIENCY IN EXPENDITURES OF PUBLIC FUNDS, WE ARE CERTAINLY CONCERNED
NOW WITH THIS INTENSIVE AWMA-EPA-HUD FEDERAL PROJECT WHICH WILL COST THE ENTIRE
TAXPAYING PEOPLES OF ORANGE COUNTY AS WELL AS PEOPLE FROM ALL OVER AMERICAl
THE TAXPAYERS WANT TO KNOW WHY SUDDENLY, WE ARE SUBJECTED TO FEDERAL £ STATE
SUPER AGENCIES SUCH AS AWMA-EPA-HUD?  QUITE SOMETIME AGO, THE CITY'OF LAGUNA
BEACH & ITS CITIZENS VOTED FOR A SEWER BOND OF $500,000. WHICH WOULD ACCOMMODATE
A POPULATION OF APPROXIMATELY 30,000 POPULATION FOR ADEQUATE SEWERAGE"DISPOSAL
SYSTEMS.  THIS BOND HAS NOT BEEN RETIRED. ... .WE ARE STILL PAYING TAXES FOR THISI
LAST YEAR, THE CITY OF LAGUNA BEACH DOWNZONED ALL R-3t R-2, AND C-l L>k)S
DISCRIMINATELY FOR THE SOLE PURPOSES TO PRESERVE THE VILLAGE ATMOSPHERE, THE
AESTHETIC QUALITIES OF LIFE HERE, AND UNDER GOVERNMENT CODE 65858 FOR THE BENEFITS
OF PUBLIC HEALTH,  SAFETY AND WELFARE.  AT THE SAME TIME, THIS CITY APPROVED OF THE
AWMA-EPA-HUD PROGRAMS  TO INCREASE THE POPULATION, POLLUTION OF AIR & WATER QUALITIES
WHICH THE L.B.T.A.  FEELS IS A DEFINITELY ADVERSE ENVIRONMENTAL IMPACT TO THE FUTURE
OF OUR BEAUTIFUL CITY  OF LAGUNA BEACHl  IT REPRESENTS ALSO A CONFLICT OF INTERESTI

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           ON NOVEMBER 15, 197^,  THE CITY OP LACUNA BEACH PUBLISHED A NOTICE TO INTERESTED CITIZENS
           THE CITY'S PROPOSED GENERAL PLANo  IT STATED THAT AT THE PRESENT TIME STATS LAW REQUIRES
           EACH CITY TO ADOPT A MINIMUM OF NINE ELEMENTS OF A GENERAL PLAN»  THESE NINE ELEMENTS
           MUST CONSIST OF A TEXT AND DIAGRAMS WHICH TOGETHER COMPRISE AN OFFICIAL STATEMENT CF THE
           CITY POLICY REGARDING-. FUTURE-CHARACTER AND QUALITY OF DEVELOPMENT IN THE PLANNING AREAS.
           THE NINE ELEMENTS ARE LISTED AS FOLLOWS?
           1«  LAND USE ELEMENT TEXT, ADOPTED FEBRUARY 16, 1972.  NO STATEMENTS CONCERNING JUST
               COMPENSATION FOR DOWNZONING, RSZONING, OR THE TAKING OF PRIVATE PROPERTY RIGHTS
               FOR SUCH PUBLIC PURPOSES.   REFERs U.S. CONSTITUTIONAL ARTTCLES V AND XIV.
           2o  TRANSPORTATION AND CIRCULATION ELEMENT,. ADOPTED APRIL, 197^»  ALL FIVE MEMBERS OF THIS
               COMPREHENSIVE CITY-APPOINTED COMMITTEE FOR THESE FLANS WERE NOT QUALIFIED ENGINEERS8

           3.  HOUSING ELEMENTo ADOPTED OCTOBER 20 197^. ALL MEMBERS OF THIS CITY-APPOINTED COMMITTEE
               WERE PROPONENTS OF THE HUD PROGRAMS!  NO OPPOSITION WAS PERMITTED,  AND THE LoB.T.A.
               EoI.Ro RESPONSE WAS NEVER RESPONDED BY THIS CITY THROUGH AN ADDENDUM REGARDING THIS!

           b.  CONSERVATION ELEMENT„  ADOPTED OCTOBER 20 197^o   THE L.BoT.A, RESPONDED TO THIS REPORT
               ON SAID DATE BY PRESENTING A 25 MINUTE FACTUAL REPORT AND 22 COLORED-SLIDES OF THE  .
               BLIGHTED HUD REPOSSESSED HOMES IN THE LoA» AREAS AS ADVERTISED BY HUD IN THE SUNDAY
               LoAo TIMESp SEPTEMBER 26„  197^8  LATER AT A SUBSEQUENT PUBLIC HEARING THE L.BoT.A.
               INQUIRED IF THE CITY COUNCIL HAD ORDERED AN ANALYSIS OF OUR FACTUAL DOCUMENTATIONS.
               THE CITY COUNCIL ADMITTED THEY HAD NOT REQUESTED SUCH AN ANALYSIS & RESPONSE!

£         5o  OPEN .SPACE ELEMENT„ ADOPTED NOV. 210 1973,- AMENDED JUNE 12, 197^o ALL FIVE MEMBERS OF
•g             THIS CITY-APPOINTED COMMITTEE WERE PROPONENTS OF THE OPEN SPACE CONCEPTS.  ONE MEMBER
               MR. HARRY WILMTS,  OWNER OF THE RIVIERA HOTEL COMPLEX AT 825 So COAST HOTo LAGUNA BEACH.
               GAINED A ZONING VARIANCE A A CONSTRUCTION PERMIT WITHOUT THE REQUIRED ENVIRONMENTAL
               IMPACT REPORT AFTER SUCH EoIoR. WAS REQUIRED0 AND CONSTRUCTED FIVE ADDITIONAL HOTEL
               UNITS WITHIN 10000 YARDS OF THE BEACH FRONT 1   HE OPPOSED ALL OWNERS CF OPEN SPACE LANDS
               WITHIN THE LAGUNA  GREEN BELT FROM USING THEIR LANDS TO IMPROVE THEIR INVESTMENTS!  THE
               L.BoT.A, REPORTED  THIS INCIDENT TO THE CAL. COASTAL ZONE COMMISSION DIRECTLY,  AND THEY
               DID NOTHING TO RECTIFY THE DISCREPENCIES IN THIS INSTANCE.   THIS WAS A DEFINITE CONFLICT
               OF INTEREST.  THE  CITY ISSUED THE PERMITS WITHOUT AN E.I.R. TO MR.  HARRY WILLATS!

           60  NOISE ELEMENT, ADOPTED OCT. l60 197^.   NO ENGINEERS WERE CONCERNED  WITH THIS DOCUMENT!

           7°  SCENIC HIGHWAYS ELEMENT,   IN PREPARATION.
           80  SEISMIC SAFETY ELEMENT.  IN PREPARATION.
           9.  PUBLIC SAFETY ELEMENT, IN  PREPARATION,,

           ADDITIONAL SOCIAL NEEDS ELEMENT PROGRAMS ARE BEING  CONSIDERED,  AND THE  ECONOMIC ELEMENTS,
           PARKS AND RECREATION ELEMENT,  AND HISTORIC PRESERVATION ELEMENTS ARE INCLUDED FOR THE FUTURE.

           THE L.B.T.Ao ASKS? "HOW CAN LOCAL OFFICIALS IGNORE  THE FACTUAL STATEMENTS  PRESENTED WHICH
•'•           SHOW THAT SOME OF THESE ELEMENTS OF THEIR GENERAL PLAN ARE A DEFINITE THREAT TO THE
           ENVIRONMENT?  IS IT LEGAL  FOR  THIS CITY TO ADOPT  SUCH MEASURES  UNDER ADVERSE E.I.R.  RESPONSES?

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PAGE i-li ITEM 2.  THE PURPOSES OF THE ALISO WATER MANAGEMENT AGENCY, AWMA PROJECT IS TO
IMPLEMENT A LOCAL OR REGIONAL WASTEWATER TREATMENT AND DISPOSAL SYSTEM TO ELIMINATE THE
EXISTING WATER QUALITY PROBLEMS IN THE VARIOUS SYSTEMS & PREVENT FUTURE PROBLEMS. ETC.
THE APPLICANT HAS PROPOSED CONSTRUCTION OF MODIFIED ALTERNATIVE 2F, A REGIONAL SYSTEM WITH
CENTRAL TREATMENT AND OCEAN DISPOSAL OF MOST WASTES, ALTHOUGH THERE WOULD BE SOME RECLAMATION
DURING THE SUMMER.  EVALUATION OF SECONDARY IMPACTS INDICATES THAT ALTERNATIVE LA, A REGIONAL
DISPOSAL SYSTEM WITH LOCAL TREATMENT MAY BE PREFERABLE, ALTHOUGH MORE EXPENSIVE. ETC.

L.3.T.A. RESPONSES!
THE PRESENT SEWERAGE TREATMENT SYSTEMS ARE UNDER AN UNRETIRED BOND WHICH WAS TO ADEQUATELY
PROVIDE FOR A POPULATION GROWTH TO APPROXIMATELY 30,000.  THE PRESENT POPULATION IS APPROX-
IMATELY 15,000 PEOPLE, SUMMER APPROXIMATELY 20,000 IN LACUNA BEACH.  THE L.B.T.A. FEELS THAT
AN EXPANDED SEWER-WATER TREATMENT SYSTEM UNDER AWMA WOULD NOT ALLEVIATE PROBLEMS, BUT CREATE
NEW ONES.  THE AWMA SYSTEMS WOULD PROVIDE FOR A TREMENDOUS POPULATION EXPANSION IN THIS AREA
WHICH IS ALREADY CONSIDERED ONE OF THIS NATION'S GREATEST SMOG AREAS.  ALSO THE WATERSHED
GREENBELTS WOULD BE THREATENED WITH THIS EXPANDED PROGRAM BY AWMAI   LACUNA BEACH HAS ALREADY
ADOPTED A "NO-GROWTH" POLICY BY DOWNZONING, AND RESTRICTING NEW DEVELOPMENTS.  THEIR ENVIRON-
MENTALIST CONSTITUENTS INCLUDING VILLAGE LACUNA (mentioned as a recipient of this E.I.S. is,
adamantly opposed to increasing the population facilities). THIS ENTIRE AWMA POPULATION-INCRSA
FACILITATION WOULD CERTAINLY BE IN CONFLICT WITH THIS CITY'S GENERAL PLAN APPROVALSl

ITEM 3.  ALL PROJECTS WILL INVOLVE CONSTRUCTION AND ITS ASSOCIATED ENVIRONMENTAL IMPACTS.
CONSTRUCTION WILL TAKE PLACE AT TREATMENT PLANT SITES, ALONG ROADS AND STREAMS, AND FOR
OCEAN DISPOSAL ALTERNATIVES, ON THE BEACH AND THE OCEAN FLOOR OFF ALISO CREEK. ETC.

L.B.T.A. RESPONSES:
ALL CF THESE ADMISSIONS WITHIN THIS PHRASE ARE CERTAIN ADVERSE ENVIRONMENTAL HAZARDS TO THIS
LOCALS, TO THE ROADS, STREAMS, AND THE OCEAN FLOOR OFF ALISO CREEK.
DUE TO THE ORIGINAL INTENTIONS OF THE GENERAL PLAN CONCEPTS FOR LACUNA BEACH, AS REQUIRED BY
THIS STATE, IT IS INCONCEIVABLE THAT SEWERAGE, WASTE WATER OR OTHER POLLUTANTS AS WILL PREVAIL
THROUGH CONTINUED AND INCREASING CONSTRUCTION WOULD BE PLANNED WITHIN THIS AWMA PROJECT I  THE
ADVERSE ENVIRONMENTAL IMPACTS UPON OUR BEAUTIFUL ALISO GREENBELTS & ALISO CREEK AND ALISC BEAC
WILL BE PERMANENTLY ERODED UNDER SUCH PLANNING.  AS A LIFE TIME RESIDENT OF LACUNA BEACH AND
NATIVE OF ORANGE COUNTY,  I CAN CERTAINLY JUSTIFY THIS PREDICTION.

PAGE 1-1.  BACKGROUND.  THE ALISO WATER MANAGEMENT AGENCY AWMA,  WAS ESTABLISHED ON MARCH 1, 19
BY THE EXECUTION OF A JOINT POWERS AGREEI'ZNT IN ACCORDANCE WITH ART. 1,  CHAPTER V, DIV.ll,
TITLE 1 OF THE GOVERNKENT CODE,  STATE OF CAL.  THE AGENCY HAS SEVEN MEMBERS:   THE MOULTON-
NIGUEL WATER DISTRICT, THE S. LACUNA SANITARY DIST., THE IRVINE RANCH WATER DIST., THE EL TORC
WATER DIST., THE LOS ALISOS WATER DIST., THE CITY OF LACUNA BEACH.  & THE EMERALD BAY SER. DIST.
AWMA IS A LEGAL ENTITY CREATED,  OPERATING,  AND FUNCTIONING IN RESPONSE TO THE NEEDS FOR A
REGIONAL BODY TO PLAN, CONSTRUCT AND OPERATE FACILITIES FOR A WATER MANAGEMENT PROGRAM WITHIN
THE ALISO VALLEY WATERSHED BASIN AND RELATED CONTIGUOUS AREAS.  INCLUDED IN THE MANAGEMENT
PROGRAMS ARE T'-'E COLLECTION, TRANSMISSION,  TREATMENT AND DISPOSAL OF WASTE WATER; THE RECLA-
MATION OF WASTEWATERi & THE USE OF RECLAIMED WASTEWATER FOR BENEFICIAL PURPOSED.

L.B.T.A. RESPONSE:  (INCLUDING MAPS.  COUNTY LOCATION MAP & REGIONAL LOCATION MAP.)

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PAGE ^0

L.B.ToAo RESPONSES CONTINUEDg(PAGE 1-1.  BACKGROUND, )
PLEASE REFER TO U.S. CONSTITUTIONAL ARTICLE IV.  SECTION 3s  "NSW STATES MAY BE ADMITTED BY THE
CONGRESS INTO THIS UNION?  BUT  NO NEW STATE?  NOR  ANY STATE BE FORMED BY THE JUNCTION OF TWO
OR MORE STATES, OR PARTS,.OP.STATES, WITHOUT THE  CONSENT OF THE LEGISLATURES OF THE STATES
CONCERNED AS TOLL AS OP-THErGONG«ESS."
U.S. CONSTITUTIONAL ARTICLE VI STATESs  "THIS CONSTITUTION,,  AND THE LAWS OF THE UoS, WHICH
SHALL BE MADE IN PURSUANCE THEREOF? AND  ALL TREATIES  MADE,  OR WHICH SHALL BE MADE, UNDER THE
AUTHORITY OF THE UNITED STATES, SHALL BE THE SUPREME  LAW OF THE LAND?  AND THE JUDGES IN EVERY
STATE SHALL BE BOUND THEREBY,,  ANY THING  IN THE CONSTITUTION OR LAW'S OF ANY STATE TO THE
CONTRARY NOTHWITHSTANDING." ETC."
YOUR MAP CONCERNING REGIONAL LOCATIONS UNDER EPA FEDERAL REGIONAL COUNCIL IX, AND THE FRC IX,
THE AWMA ARE QUESTIONABLE  CONSTITUTIONAL STATES  WHICH HAVE BEEN FORMING WITHIN THE STATES8
THE L.BoToA. WISHES FULL DOCUMENTATIONS  CONCERNING THE ORIGINATION OF SUCH FEDERAL REGIONAL
COUNCILS, ALL TEN OF THEM  WHICH ARE STATES FORMED WITHIN ALL 50 STATES NOW!  THESE F.R.C.'s
ARE DICTATING ABSOLUTE CONTROLS OVER LOCAL,  COUNTY AND OTHER.LESSER GOVERNMENTAL BODIES
UNDER SUCH PROGRAMS SUCH AS THE ENVIRONMENTAL PROTECTION AGENCY MAY FORM FOR SUCH PROGRAMS!
THE STATE ATTORNEY GENERAL HAS STATED PREVIOUSLY BY LETTER TO THE L.B.T.A. THAT NO GOVERNMENTAL.
AGENCY CAN DICTATE OR CONTROL  OTHER GOVERNMENTAL AGENCIES.   AWMA-3PA-HUD AND THIS STATES
ENVIRONMENTAL AGENCIES ARE IN  CONFLICT WITH THAT RULING NOW!   THE LEGALITIES AS ARE STATED
WITHIN THIS EoloSo ARE NOT SUBSTANTIATED,  AND THEIR EXACT RULES ARE NOT REPORTED AS TO THE
EXTENT OF THEIR AUTHORITIES„ WHICH APPARENTLY VIOLATE THE U0S.  CONSTITUTIONAL ARTICLES IV & VI8
WHILE THE CITY OF LAGUNA BEACH FLOUNDERS WITH THE GENERAL PLAN CONCEPTS, MOST OF WHICH ARE
INCONSISTENT AND HAVE NOT  CONFORMED TO THE DUE PROCESS OF" LAW PROCEDURES, AND AWMA HAS BEEN
FORMED TO SUBROGATE LOCAL  POWERS, THE PEOPLE OF  THIS  STATE VOTED RECENTLY TO RETAIN THE POWER
TO VOTE UPON FEDERAL LOW-INCOME HOUSING  PROJECTS & RELATED PROGRAMS WHEN THE MONIES FOR SUCH
PROJECTS ARE FROM GENERAL  TAXES!!   HAS THIS REFERENDUM BEEN CONSIDERED  CONCERNING AWMA PROGRAMS?

REFERg TABLE 1-1i   CITY OF LAGUNA BEACH. OPERATIONAL  PERFORMANCE & CONDITIONS UNSATISFACTORY
NOWB OUTDATED, INADEQUATE  TREATMENT FACILITIES,  PRIMARY TREATMENT ONLY, POOR QUALITY EFFLUENT.

L.BoT.A. RESPONSES  REFERRING  AGAIN TO THE BONDED INDEBTEDNESS OF $500,000,, WHICH HAS NOT
BEEN RETIRED UNTIL 1984, AND WHICH IMPROVEMENTS  OF LOCAL SEWERAGE SYSTEMS WAS TO PROVIDE
ADEQUATELY FOR A POPULATION OF 30,000, IT  IS NOT CONSISTENT TO THE AWMA REPORTS AS MENTIONED.
IT IS ALSO STATED WITHIN THIS  REPORT THAT  THE SEWERAGE SYSTEMS WILL CONTINUE TO BE EMPTIED
INTO THE OCEAN AT ALISO CREEK  TRIBUTARY  TO THE SEA.   WITH ADDITIONAL POPULATION PROVISIONS
AS ARE PLANNED, THERE CERTAINLY IS NO CONSISTENCY TO  INCREASING ADVERSE ENVIRONMENTAL
IMPACT THROUGH" OCEAN DISPOSAL  SYSTEMS SUCH AS ARE PROPOSED BY AWMA UNDER THIS NEW SYSTEM.
THE LoB.ToA, BELIEVES THAT IF  INLAND CITIES  MUST DEPEND ON ALTERNATIVES FOR THEIR SEWERAGE
DISPOSALS, THERE IS NO CONSTRUCTIVE REASON WHY COASTAL CITIES SHOULD BE PERMITTED TO USE
THE OCEAN FOR SEWERAGE DISPOSALS.  THIS  CONTENTION HAS A LOGICAL CONCLUSION THAT ADDED SEWERAGE
DISPOSAL INTO, THE ••OCEAN,-ADDED POPULATION  FACILITIES  THROUGH AWMA WASTEWATER TREATMENT
SYSTEMS WILL ONLY CREATE MORE  BURDENSOME PROBLEMS UPON LOCAL CONDITIONS AS PREVAIL ACCORDING
TO THE REFERENCE GIVEN ON  TABLE 1-1.   TH2RE WILL BE NO APPRECIABLE ADVANTAGES WHATSOEVER      QN
TO INCREASE SEWERAGE-WATER TREATMENT FACILITIES  FOR INCREASED POPULATION PROGRAMS IN THIb REGION,
THIS REFERENCE ENCOMPASSS3 PAG3 l-li SECTIONS 1.2 THROUGH PAGE 1-11.

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      PAGE 5.

      PAGE 2-1 THROUGH 2-25«  DESCRIPTION OF EXISTING ENVIRONMENT. TOPOGRAPHY. GSOLOGY.

      L.B.T.A. RESPONSES»
      IT CAN BE SAFELY STATED IN THESE CATAGORIES THAT THE WATERSHED AREAS ARE AN INTEGRAL FACTOR
      TO BE CONSIDERED WHEN PROPOSING TO DISPOSE VASTS AMOUNTS OF SEWERAGE AND WA5TEWATERS INTO
   '   THESE COASTAL AND INLAND AREAS AS INDICATED THROUGHOUT THESE REPORTS IN THIS E.I.S.
      PRIOR TO THE SEWERAGE TREATMENT SYSTEMS IN LACUNA BEACH AND THE SOUTH LACUNA AREAS, WHEN
      THE POPULATION WAS LESS, WE HAD CEPTIC TANKS, AND CESSPOOLS.  WHILE THIS SYSTEM WAS NOT
      INADEQUATE IN MOST CASES, IT PRESENTED.PROBLEMS TO SOME DEGREE FOR THE TAXPAYERS HERE
      WHO WERE OP THE MEDIUM AND LOW-INCOME BRACKETS WHEN THE GENERAL SEWERAGE TREATMENT PLANS
      WERE CONSUMMATED FOR THIS CITY.  MANY PROPERTY OWNERS WERE INDEBTED 32YOND THEIR ABILITIES
      TO PAY FOR THE CITY'S NEW SEWERAGE SYSTEMSj HOWEVER, IT WAS COMPULSORY AND REGARDLESS OF
      THESE FINANCIAL ADVERSE IMPACTS, EACH OWNER PAID THEIR FAIR SHARE OF THESE COSTS.  WHEN
      OUR PROPERTY TAXES WERE AT LEAST J$% LESS, UNTIL 1972, OUR SEWERAGE SERVICES WERE PROVIDED
      THROUGH OUR PROPERTY TAXES.  THIS WAS EQUITABLE DUE THE FACT THAT EVERYONE HAD ALREADY PAID!
      WHEN THIS CITY WAS ABOUT TO ADOPT. THE FEDERAL HOUSING & URBAN DEVELOPMENT PROGRAM CN MARCH 1,
      1972, THEY INSTITUTED SEPARATELY SEWER SERVICE TAXES.  THIS HAS BEEN INCREASED PROGRESSIVELY
      AND NOW THIS CITY PROPOSES -TO MORE THAN DOUBLE THESE EXORBITANT SEWER SERVICE CHARGES AT THIS
«P     DATEI
£     LAST FALL, AWMA's CARL KYMLA ISSUED AN ULTIMATUM TO THE CITY OF LAGUNA BSACH, EITHER JOIN
«>     AWMA OR PAY THE $200,000 •.THICK WAS GRANTED THIS CITY THROUGH AWMA, & FACE A 32,000 DAILY FINSl
      MR. KYMLA ISSUED A COST ANALYSIS TO THE L.B.T.A. WHICH SHOWS THAT THE TAXPAYERS -','CULD FAY
      $10.80 ANNUALLY UNDER A MAXIMUM FEDERAL-STATE GRANT,.FOR THEIR SEWERAGE SERVICES THROUGH AWKA,
      OTHERWISE THE CITIZENS OF THIS CITY WOULD PAY $111.00 ANNUALLY PER UNIT.  AT THE PRESENT TIME,
      WITHOUT ANY IMPROVEMENTS FROM AWMA, AND WHILE-THIS CITY HAS JOINED AWMA, THIS CITY IS ASKING
      THE PROPERTY OWNERS  FOR AN INCREASE OF $6.33 PER MONTH PER UNITI  THE L.B.T.A. FEELS THAT
      THERE IS NO JUSTIFICATION FOR THESE SUR-TAXES FOR OUR SEWERAGE SERVICES WHEN OUR PROPERTY
      TAXES HAVE BEEN INCREASED AT LEAST 35# AND IN SOME CASES UP TO 150?$ OF THE ASSESSED VALUATIONS.
      WE HAVE NOT BEEN PERMITTED DUE PROCESS OF LAW' PUBLIC HEARINGS, OR RESPONSES TO CUR STATEMENTS
      THROUGH LETTERS REGARDING THE S3WER & TRASH SERVICE EXORBITANT INCREASES.  WE HAVE NCT BEEN
      GRANTED A REFERENDUM BY THE A'WMA AS REQUIRED BY CALIF. LAWS NOW WHEN FEDERAL PROJECTS AS
      ARE NOW PLANNED BY AWMA-EPA-HUD WITHIN OUR AREA FOR THE LOW-INCOME FEDERALLY SUBSIDIZED PEOPLE1
      FURTHERMORE, OUR FINE WATERSHED AREAS WILL BE RUINED IF CLUSTER-HUD-LCW-INCCME-HIGH-DSNSITY
      CONSTRUCTION IS PERMITTED WITHIN THESE FLOOD PLAIN ZONES AS SO DESIGNATED ALREADY BY THE ORANGE
      COUNTY BOARD OF ENGINEERS, SANTA ANA, CA.   NO PHYSICAL CONDITIONS ARE RELATED WITHIN THE ABOVE
      REFERENCES AS TO THE NEGATIVE ENVIRONMENTAL IMPACTS UPON TH2SS WATERSHED AREAS, FLOOD PLAIN
      ZONES, AND OPEN SPACE LANDS.  THE L.B.T.A. BELIEVES. THAT THE CITY OF LACUNA BEACH MUST REMAIN
      CONSISTENT TO THEIR  AVOWED OPEN SPACE, NO-GROWTH,  GREEN BELT, LOW PROFILE LAND DEVELOPMENT
      CONCEPTS,  AND THEIR  APPROVED POPULATION LIMITATION FOR 20,000 MAXIMUM WITHIN THESE AREAS NOW!

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        PAGE 60

        L.B.ToAo  RESPONSE TO E.I.So  FOR AWMA CONTINUSDs
        THE L.B.T.A.  HAS PRESENTED VOLUMES  OF  LETTERS SHOWING  THAT  OUR COSTS ARE THE HIGHEST I.N THIS
        STATE WITH  THE  EXCEPTION OF  THE CITY OF SAN  FRANCISCO  WHICH ACCOUNTS BOTH CITY & COUNTY RECORDS.
        THE L.B.ToA.  SENT EAWCfF THE  26 CITIES THE  ENCLOSED REFERENCE FOR RESPONSE CONCERNING .EACH
        CITY'S REVENUES IN  ORANGE' COUNTY.   SVERY CITY IN  ORANGE COUNTY RESPONDED TO THESE QUESTIONNAIRES
        EXCEPT THE  CITY OF  LA HABRA, FULLERTON AND PECULIARLY  LAGUNA 3SACH8  '
        Tl?l LoB.T.Ao  MADE A ViiHY CUWnF^fEflEWSTYErAlS«.LY5IS "FROM THIS CITY'S  LIST OF PROPERTY OWNERS, OF
        THE INCOMES FROM SEWER SERVICES AND TRASH. THIS WAS AS FOLLOWS WHICH DOES NOT INCLUDE COKMERCIAL
        ACCOUNTS  AND 96 UNITS WHICH  WERE NOT CODED8  (1973 REPORT)   THESE SERVICES HAVE BEEN INCREASED AGl
        SEWER SERVICE MONTHLY INCOME?  $370857.?5      REFUSE  MONTHLY INCOMEi    $15,050,, 25
        ANNUAL SEWER SERVICE INCOME*   $1*5^»293•00      ANNBAL  REFUSE INCOME*    $1300603oOO

        THE COMBINED INCOMES FROM REFUSE &  SEWER SERVICES ARE  A VERY LOW  ESTIMATES  $64-3,896.00 ANNUALLYJ

        ENCLOSED  FOR YOUR INSPECTION IS THE ANNUAL STATEMENT WHICH  ACCOMPANIES OUR PROPERTY TAX BILLS8
        PLEASE NOTE?  REFUSE DISPOSAL,, SEWAGE  COLLECTION  & TREATMENT.  AND WATER DISTRIBUTION SYSTEMS
        ARE COMBINED IN THE COST ANALYSIS FROM THE ORANGE COUNTY-.TAX COLLECTOR'S COMPILATION & REPORTS!
        30  ACTUALLY,  WE ARE PAYING DOUBLE TAXATION NOW SINCE JANUARY 1, 1972 FOR REFUSE & SEWER SERVICES!
        AWMA WILL CERTAINLY CREATE ADDITIONAL  TAXATIONS UPON LOCAL  GOVERNMENTS WITH THEIR SEWER AND
        •tfASTEWATSR  PROGRAMS WHICH ARE  PLANNED  TO ACCOMMODATE AT LEAST AN  ADDITIONAL 230,000 BY THE
        YEAR 2000 IN THIS AREAS
«P       THE L.BoT.A.  QUESTIONS THE PROBLEM  SOLVING ASPECTS OF  THIS  ENTIRE PROGRAM BY AWMA AT THIS TIMS?
=;       ESPECIALLY,  WITH REGARD TO CONTINUING  THE SEWERAGE DISPOSAL SYSTEMS  INTO ALISO-OCEAN TRIBUTARY?
0       WE  ALSO QUESTION THE ENTIRE  PLANNING FOR CONTINUED POPULATION EXPANSION ON A LARGE SCALE, WHILE
        URBAN SPRAWL HAS BEEN THE.PRIMSCONDITION WHICH IS STRONGLY OPPOSED  BY SUCH^ENVIRONMENT PRCTECTIO)
        AGENCIES?  ALSO URBAN~SPK£WL,  AIR AND  WATETTlSUATirY^POLLUTION,,  AND HIGH~UETSf3TYY DEVELOPMENT HAS
        JOIL_BJ1N ..STRQNCnGY~lJPl?USED~BY~THB CITY~DF"'LAGUNA~^BSACH  AND~ALL OF  THE CONSTITUENTS LISTED AS
       ^gECIPpNTS"'OF THIS  E.I.S.I   WHAT ISi THE ABSOLUTE  ENVIRONMENTAL BENEPITr~NDW^mEN~^'llEjLTZ3_™^
       ~     OF THESE AGENCIES AND THEIR SUPPORTERS  HAS REV5RST5D"~TH2IR ENVIRONMENTAL PROTECTlUITTDSrnj&NS'
      '  V7HAT GUARANTEES ARE THERE UNDER THESE REVERSALS  FOR  FUTURE  PROPOSALS,  AND ASSURANCES THAT CUR
        AIR & WATER AND LAND-USE ENVIRONMENTS WILL ACTUALLY  NOT  SUFFER  UNDETERMINABLE ENVIRONMENTAL
        IMPACT REVERSES?  WE NEED ABSOLUTE ANSWERS TO THESE  VERY IMPORTANT QUESTIONS NOW!

        PAGE 2-128 2»3o6 STRUCTURE REFERENCE IS GIVEN TO GEOLOGIC STRESSES &  STRAINS IN THIS REGION.

        L.B.T.A.  RESPONSE!                                                                   . .   . .
        3VSN THE  IMMINENT DOCTOR RICHTER OF GAL TECH LABORATORIES OF PASADENA DOES NOT HAVE ALL THE
        REASONS,  ANALYSIS, CAUSES AND DETERMINATIONS CONCERNING  SEISMIC QUAKES AND PERTINENT DATA.
        IT IS THEREFORE UNREASONABLE WE FEEL TO GIVE ANY GREAT CREDITS  TO  SPECULATIVE ANALYSIS IN
        THIS FIELD OF SCIENCES!  IT CAN BE SAFELY SAID,  HOWEVER,  THAT SINCE SOUTHERN CALIF. IS
        VULNERABLE TO SEISMIC TREMORS FREQUENTLY, THAT CONSTRUCTION HAS TAKEN ISSUE TO THESE CONDITIONS
      '  ESPECIALLY IN THE L.A7'-AREAS "'WHERE HIGH-RISE BUILDINGS HAVE SEEN CONSTRUCTED WITH SUCH SAFETY
        PRECAUTIONS IN MIND,  CERTAINLY, SUCH WOULD BE THE CASE  WITHIN  THE AWMA REGIONAL PLANNINGI
        INCLUSIVE COMMENTS COVER MAPS AND CHARTS & SOIL  ANALYSIS THROUGH PAGES 2=26'.

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PAGE 7.      L.B.T.A.  RESPONSES TO S.I.3.  AWMA DRAFT ENVIRONMENT IMPACT STATEMENT.

PAGE 2-26 THROUGH PAGE 2-72.   INCLUSIVE OF METEOROLOGY,  OCEANOGRAPHY,  TERRESTRIAL BIOLOGY .
MARINE LI?E REFUGES.  PALSONTOLOGICAL RESOURCES .  LAND USE.   WATER QUALITY. POPULATION AND
WISTEWATER FLOWSVSUMMARIES OF GOVERNMENTAL AUTHORITY.  PERCEIVED NOISE LEVEL CONTOURS FOR
EL TORO FOR FLIGHT OPERATIONS.

L.B.T.A. RESPONSES!  CLIMATIC CONDITIONS CONCERN EVERYONE IN SOUTHERN CALIF.  THE AIR
QUALITY IS CONDITIONAL PRIMARILY DUE TO HYDROGEN BOMB TESTING IN THE NEVADA PROVING GROUNDS I
THIS FACT WAS REVEAL QUITE SOMETIME AGO BY A NOTED PROFESSOR OF  NUCLEAR PHYSICS.  HE REVEALED
THAT INTENSIVE NUCLEAR TESTING OF THE VARIOUS ATMOSPHERIC & UNDERGROUND MISSL23 HAVE CREATED
A HEAVY BELT AROUND OUR EARTH.  IN BASINS SUCH AS IN SOUTHERN CALIF. WHERE CLIMATIC CONDITIONS
ARE MILD AND WINDS DO NOT DISSIPATE THESE NUCLEAR RADIATION PARTICLES QUICKLY, THE SECONDARY
PROBLEMS OF CAR EMMISSIONS POSES A THREAT TO OUR AIR AND WATER QUALITIES.  THE L.B.T.A. HAS
STUDIED THIS THEORY.PERIODICALLY AND WE BELIEVE THIS CONDITION IS ABSOLUTELY TRUE,  AFTER A
NUCLEAR TEST EITHER AT U.S. AF BASS AT VANDENBURG OR IN  NEVADA, ESPECIALLY WHEN OUR AIR IS
STILL, WE CAN DEPEND UPON SEVERAL DAYS OF INTENSIVE SMOG AND AIR POLLUTION CONDITIONS.  THIS
FACT WILL CONTINUE AND BE INCREASED IF AWMA-EPA-HUD PERSIST UPON BRINGING MORE POPULATION TO
ORANGE COUNTY.  ADDITIONAL AUTOMOBILES,  SEWERAGE INCREASES, REFUSE INCREASES, SCHOOL INCREASES,
GENERAL RELATIVE COLLATION OF ALL FACTORS INVOLVED WITH  SUCH ENVIRONMENTAL CHANGES, WILL SURELY
NOT ALLEVIATE THE PRESENT ADVERSED ENVIRONMENTAL AIR AND WATER CONDITIONS PREVAILING.

WITH RESPECT TO SEISMIC PROBLEMS IN THE FUTURE, IT CAN BE DETERMINED FROM PREVIOUS EARTHQUAKES
THAT IT WOULD BE DANGEROUS TO GROUP LARGE POPULACE IN HIGH-DENSITY-HIGH-RISE STRUCTURES WITHIN
THIS VULNERABLE AWMA AREA ANYTIME IN THE FUTURE.   THE LOW-INCOME STRUCTURES HAVE IN THE PApg'W
BEEN CONSTRUCTED UNDER LESSER STANDARDS DUE TO INCREASED COSTS CONNECTED WITH CONSTRUCTION^"*
DUE TO DELAYS CAUSED BY CITIES. COUNTIES,  THE STATE AND  FEDERAL GOVERNMENTS FOR ADDITIONAL "   "
STUDIES, E.I.R.'S ETC., THIS PROBLEM WILL PREVAIL EXTENSIVELY IN THE FUTURE IN ORDER TO KEEP
COSTS AT A MINIMUM IN ORDER TO PROVIDE HOUSING FOR THE LOWER INCOME PEOPLE COMING INTO ORANGE
COUNTY.  IT IS LOGICAL NOT TO EXPECT LUXURIES IN THE HOUSING CONSTRUCTION INDUSTRIES NOW, WITH
LAYERS OF GOVERNMENT REDUCING THE POTENTIALS OF LOW-COST CONSTRUCTION FOR SUCH PERSONS WHICH
AWMA-EPA-HUD HOPE TO PROVIDE ADEQUATE HOUSING NEEDS FOR  THESE PERSONS IN THE FUTURE!
THEREFORE, HOW CAN IT BE CONCLUDED NOW THAT THE AIR A:JD  *AT£R QUALITIES AND THE CONSTRUCTION
COSTS BE SATISFIED WITH THESE ANALYSIS AS PROVIDED WITHIN THESE PAGES OF THIS E.I.S.?
HOW CAN IT BE DETERMINED THAT BY INCREASING FACILITIES FOR AWMA PROJECTS IN THE FUTURE THAT
ALL THESE PROBLEMS WILL NOT BE INCREASED,  RATHER THAN BE SOLVED UNDER THE TERMS GIVEN IN THIS
ENVIRONMENTAL IMPACT STUDY?
IT HAS BEEN DETERMINED BY SCIENCE THAT A CERTAIN AMOUNT  OF VEGETATION IS MANDATORY TO THE
SURVIVAL OF MANKIND.   WITH THE PLANNED INCREASES OF SEWERAGE DISPOSALS, WASTEWATER DISPOSALS,
ENCROACHMENTS UPON PRIMS FARMING LANDS 'WITHIN THE WATERSHED AREAS, PLUS ALLEVIATION OF THE
CERTAIN VITAL VEGETATION CHARACTERISTICS WITHIN THESE LANDS, HOW CAN AWMA MAINTAIN A POSITION
THAT THEIR SUPER-AGENCY CAN SOLVE OUR SURVIVAL?
WITH INCREASING COSTS OF WATER, AND OTHER VITAL UTILITIES,  TAXPAYERS WILL DISREGARD THE USES
WHICH ARE VITAL TO PUBLIC HEALTH, SAFETY AND WELFARE. WATER IS ESSENTIAL NOT ONLY FOR THE
PRESERVATION OF CUR EARTH AND DOMESTIC USES, LAWNS, WATERING WILD ANIMALS & INSECTS WHICH ARE
A PART OF OUR ECOLOGICAL SYSTEMS, BUT WITH INCREASED COSTS TO THOSE TAXPAYERS, WATER WILL BE
USED SPARINGLY.  OTHER UTILITIES PROVIDE HEALTHFUL ESSENTIALS TO MANKIND, BUT GOVERNMENTAL

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PAGE 8.

INVOLVEMENTS INTO LOCAL, COUNTY AND SUBSIDIARY CONTROLS WILL PRICE THESE ESSENTIAL COMMODITIES
BEYOND THE FINANCIAL CAPACITIES OF EVEN WEALTHIER USERS.  IT GOES WITHOUT FURTHER ANALYSIS
WHAT UNHEALTHY CONDITIONS WILL PREVAIL FOR EVERYONE IF THIS TRAGEDY CONTINUES.  ALREADY PEOPLE
ARE WITHOUT JOBS.  OUR SOCIAL SECURITY SYSTEMS ARE ALMOST BANKRUPT.  OUR YOUNG MARRIEDS CANNOT
AFFORD HOUSING, OR MEDICAL CARE, *OR THE BARE ESSENTIALS.  HOW CAN AWMA SOPHISTICATED SEWERAGE
DISPOSALS SYSTEMS, WITH POPULATION EXPANSION PROGRAMS AIM TO REDUCE THESE PROBLEMS IN THIS E.I.3.?
THE FLORA AND FAUNA WILL DRY UP1  THE WILD ANIMALS, SQUIRRELS, RACOONS, 3EAVERS, DEER, CPPOSSUMS,
SKUNKS, AND THE AMPHIBIANS WILL DISSAPPEAR EVENTUALLY IP THE FEDERAL & STATE GOVERNMENTS DO NOT
ALLOW LOCAL CITIES TO CONTINUE THEIR TRIED AND PROVEN DEMOCRATIC PLANNING FOR THESE CREATURES
OF OUR EARTH.  THE 13^ PAGE COMPREHENSIVE STUDY JUST RELEASED BY THE COUNCIL FOR THE ENVIRONMENT,
ECONOMY, EDUCATION DEVELOPMENT IN ORANGE COUNTY HAS PROVEN THESE FACTS TO THE ORANGE COUNTY
BOARD OF SUPERVISORS.
THE ENDANGERED HABITAT TYPES AS ANALYZED FROM PAGE 2-^2 CHART WILL CERTAINLY SUFFER PERMANENT
DAMAGES UNDER PRESENT PLANNING BY AWMA.
THE MARINE BIOLOGY ALREADY HAS DECREASED DUE TO POLLUTION IN OUR LOCAL OCEAN WATERS.  FISH ARE
CONTAMINATED AND UNFIT TO EAT NOW.  WHAT WILL HAPPEN BY THE YEAR 2000^ WITH MORE POPULATION?

THE LAND USE PLANNING PAGE 2-57 ILLUSTRATES CORRECTLY THE INTENSITY OF AGRICULTURE IN ORANGE
COUNTY.  ALREADY MUCH OF THIS VALUABLE FARMING LAND HAS BEEN INNUNDATED BY DEVELOPMENT.  IT
IS INCONCEIVABLE TO THE MEMBERS OF THE LAGUNA BEACH TAXPAYERS' ASSOC. INC. WHY THE CITY OF
LACUNA BEACH RESTRICTS CERTAIN LAND DEVELOPMENT ON OTHERWISE NON-FARMING LANDS KNOWN AS THE
SYCAMORE HILLS IN THE LAGUNA CANYON NOW, AND WITH APHORISM, IT QUICKLY APPROVES OF THE AWMA
CONCEPTS TO" PROVIDE A GREAT POPULATION INCREASE AND CONSTRUCTION & DEVELOPMENT ON PRIME FARMING
LANDS WITHIN THIS SPHERE OF INFLUENCE I   ON ONE HAND THIS ENTIRE PLAN PRETENDS TO PROVIDE FOR
THE FUTURE & ALLEVIATE PENDING PROBLEMS, MILE ON THE OTHER HAND, AND WITHIN PAGES 2-5? THRU
PAGE 2-?2 RELATES TO PLANS TO USE PRIME FARMING LANDS FOR PUBLIC PURPOSES IN THE FUTUREl

PAGE 2-72i HISTORICAL BACKGROUND.   THE AWMA AREA HAS EXPERIENCED MANY HUMAN ACTIVITIES OF
HISTORIC SIGNIFICANCE DURING THE VARIOUS PERIODS THAT MAN HAS INHABITED THE REGION.  IN ALL OF
ORANGE COUNTY, NO ONE AREA HAS RECORDED MORE HISTORICAL OCCURRENCES THAN WITHIN THE LAND AREA
KNOWN AS THE IRVINE RANCH.

L.B.T.A. RESPONSE!
TO PUT THE R-SCORDS. STRAIGHT, REFER TO-PAGE. 1-11   AWMA WAS ESTABLISHED ON MARCH 1, 1972 SO IT
CAN 3E STATED THAT AWMA WAS NOT IN THIS AREA OR HAS EXPERIENCED MANY HUMAN CHANGES OF SIGN-
IFCANCE FOR- SUCH DURATIONS AS THIS STATEMENT DOES IMPLY I   IT ALSO CAN BE SAFELY STATED THAT
NOT ONLY THIS SOUTHERN CALIF,  AREA HAS RICH HISTORICAL SIGNIFICANCE, BUT THE ENTIRE U.S.A.
SHOULD 3E INCLUDEDI   THE SPANIARDS,  THE CHINESE^,  THE MEXICANS, THE AZETC INDIANS, AND THE
MANY MIXES OF NATIONALITIES PROVIDE THE HISTORICAL BACKGROUNDS OF THIS AREA, NOT AWMAl
CERTAINLY AWMA PROVISIONS FOR INCREASED POPULATIONS PLUS FACILITIES FOR SAME WILL NOT ENHANCE
THESE HISTORICAL PRESERVATIONS I

PAGE 3-1.1 ALTERNATIVE LA-LOCAL TREATMENT.  REGIONAL DISPOSAL:;   THIS ALTERNATIVE REQUIRES THE
SNLARG2M2NT~OF~LOCAL PLANTS, CONSTRUCTION OP A REGIONAL 2FFLUENT TRANSMISSION MAIN AND A NORTH
COAST INTERCEPTOR AND OCEAN OUTFALL.   THE USE OF TWO EXISTING SHORT, SHALLOW OCEAN OUTFALLS

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       PAGE 9.

       PAGE 3-1 CONTINUED! (INCLUSIVE OP PAGES 3-1 THRU PAGE 4-2.)
       A^ THE LACUNA BEACH TREATMENT PLANT WOULD BE TERMINATED AND THE SOUTH COAST INTERCEPTOR WOULD
       BE REPLACED.  CAPITAL COST OF THIS ALTERNATIVE IS ESTIMATED  TO 3E $37-9 MILLION.

       L.B.T.A. RESPONSEi
       NO MENTION HAS BEEN MADE REGARDING THE PRESENT $500,000. SEWER BONDS WHICH ARE NOT RETIREDl
       ALSO WHAT WOULD THE ALTERNATIVE PROGRAM HAVE BEEN CONCERNING THE CITY OF LAGUNA BEACH HAD THEY
       NOT ELECTED TO JOIN AWMA SEWER-WASTEWATER SYSTEMS IN 1972?
       ALSO WHY SHOULD LOCAL TAXPAYERS, ALREADY BURDENED WITH COSTLY ACQUISITIONS SUCH AS MAIN BEACH
       WHICH COULD EXCEED $16 MILLION DOLLARS FOR PUBLIC USE, AND THE RECENTLY ACQUIRED CRESCENT BAY
       LOTS FOR $550,000. WITH BOTH PERPETUAL MAINTENANCE PROBLEMS  FOR ONLY 6,000 PROPERTY TAXPAYERS
       OF LAGUNA BEACH, BE SUBJECTED NOW TO PROVIDE EVER INCREASING POPULACE EXPANSION SYSTEMS THRU
       AWMA-EPA-HUD WITH INCREASING TAXES & SUR-TAXES FOR NO PROVEN ADVANTAGES FINANCIALLY OR
       PHYSICALLY OR ECOLOGICALLY OR ENVIRONMENTALLY TO THIS ENTIRE REGION?
       THIS REPORT HAS ELIMINATED THESE VERY COSTLY FACTORS WHICH CONCERN LOCAL TAXPAYERS NOW AND
       IN THE FUTURE.  WE ARE A MINORITY ALREADY FACED WITH EXORBITANT TAXATION PROBLEMS.  AWMA PROJECTS
       HAVE NOT PROVIDED SUBSTANTIAL EVIDENCE WITHIN THIS ENTIRE E.I.S. TO SHOW CAUSE THAT THEIR FLANS
       ARE WORKABLE OR WILL ALLEVIATE THE PROBLEMS THEY HAVE POSED»
       WHY SHOULD LOCAL PROPERTY OWNERS PROVIDE FOR PUBLIC FACILITIES WHICH WILL ULTIMATELY COST US OUR
       LIFE'S INVESTMENTS IN LAND AND FINANCES?
._      WHY SHOULD THE CITY OF LAGUNA BEACH DOWNZONE OUR PROPERTIES  DISCRIMINATCRILY NOW, WHILE APPROVING
^      OF AWMA-EPA-HUD PROGRAMS INCONSISTENT TO LOCAL APPROVAL?  THIS E.I.S. DOES NOT RESPOND TC THESE
-      AND SO MANY OTHER PERTINENT QUESTIONS?  IS SIMPLY HAS GENERALIZED DESCRIPTIVELY THE REQUIRED
    . .  E.I.S. ELEMENTS.  AS TAXPAYERS LOCALLY & NATIONALLY WE DESERVE AN IN-DEPTH ANALYSIS OF THESE
       BASIC COSTSI

       NOTE*  IT IS DIFFICULT TO FOLLOW SUCH PAGING WITHIN THIS E.I.S. MANUAL! WE REFERRED TO 2-72,NOWi

       PAGE 4-2  DYNAMICS OF GROWTHt  FOR THE PAST TWENTY YEARS, ORANGE COUNTY HAS EXPERIENCED RAPID
       POPULATION GROWTH".FROM A POPULATION OF APPROXIMATELY 700,000 IN I960, THE COUNTY HAS GROWN
       TO 1,656,300 IN 1974, AN INCREASE OF APPROXIMATELY 70,000 PERSONS PER YEAR.  SINCE 1970 THE
       POPULATION HAS INCREASED BY AN ADDITIONAL 273.360, A SLIGHTLY SLOWER ANNUAL INCREASE OF ABOUT
       55,000. ETC.
       INITIALLY POPULATION GROWTH IN ORANGE COUNTY WAS A 'SPILL OVER' FROM L.A. COUNTY.  BUT THE
       DEVELOPMENT OF FREEWAYS AND THE INCREASING POPULATION ALLOWED ESTABLISHMENT. OF LOCAL EMPLOYMENT,
       BY I960 THE EMPLOYMENT BASE WAS 165,000 JOBS AND BY 1965 IT  REACHED 293,000.
       PAGE 4-5 CIRCULATION! FREEWAY ACCESS IS VERY IMPORTANT IN THAT DEVELOPMENT IS IMPOSSIBLE IF THERE
       IS NO ACCESS, AND DEVELOPMENT IS UNLIKELY IF ACCESS IS NOT CONVENIENT AND TIMELY.

       L.B.T.A. RESPONSES!
       THE RECENT NO-GROWTH POLICIES APPARENTLY ARE INTERMITTENT TO THE AWMA-EPA-HUD PROJECTS TO COME.
       WITH SUCH DELAYS FOR PLANNING PURPOSES, CONSTRUCTION COSTS ARE PRICING THE AVERAGE BUYER OUT OF
       ORANGE COUNTYl  BECAUSE OF THE ADVERSE ENVIRONMENTAL IMPACTS OF THE FEDERAL HUD SECTION 23
       REPOSSESSED PRIVATE HOMES IN THE L.A. AREAS NOW, PEOPLE ARE  GROWING EVER CONCERNED THAT THIS
       IRREPLEVIA3LS CONDITION WILL SOON PREVAIL HERE UNDER THE AWMA-EPA-HUD PROJECTIONS WITHIN THIS E.I.S

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PAGE 10 o

IT CAN BE AGREED THAT PRESENT PROPOSALS CONCERNING  GAS & OIL SHORTAGES AND CONCURRENT TAXATION
TO CURTAIL SUCH USEAGES,  WILL ALLEVIATE THE NEED FOR ADDITIONAL CORRIDORS,, FREEWAYS, SURFACE
STREETS,,  EVEN BIKE TRAILS .   PEOPLE HAVE TO  WORK.  THIS ENVIRONMENTAL ISSUE HAS CAUSED MANY
PEOPLE TO MOVE AWAY FROM CONGESTED AREAS IN SEARCH  OF EMPLOYMENT.   WHILE AWMA-EPA-HUD KAY
INTEND TO PRO VIDE ••GOVERNMENT EMPLOYMENT , AND SUBSIDIES FOR WELFARE AND HOUSING ,  THERE IS A
CERTAIN CONSIDERATION WHICH MUST BE ACCOUNTABLE AND THAT IS THAT SUCH SUBSIDIES ARE PROVIDED
ULTIMATELY THROUGH INCREASED TAXATION.   WHEN LOCAL  PEOPLE ARE OVER-TAXED ,  WITHOUT EMPLOYMENT,
WITHOUT BARE NECESSITIES,, & GOVERNMENT  CONTINUES ITS COSTLY INCREASES FOR MORE SUBSIDY PROGRAMS,
THE ENVTRONEMTAL ISSUES WILL BE SECONDARY TO THE PREDICTABLE ECONOMIC BANKRUPTCY IN ORANGE       •!
COUNTY, AND PERHAPS NATIONALLY!   HUNGRY PEOPLE ARE  DANGEROUS AND DESPERATE, '  WHEN ETHNIC GROUPS
ARE DISPLACED B WHEN THE LESS INTELLECTUALS  ARE RESTLESS DUE TO JOBLESSNESS , THE PUBLIC POLICE,
JUVEKILS FACILITIES, THE GENERAL BUSINESS CONDITIONS WILL SUFFER ADVERSELY.  WHY HASN'T THIS
E.I.S. TAKEN THESE VERY VITAL CONSIDERATIONS INTO ACCOUNT?
•CROWDING AND INTEGRATION WILL CERTAINLY CREATE MORE PROBLEMS THAN AWMA HAS PREDICTED IT CAN SOLVES

PAGE b~6, SEC. ^.2. 3° 2 ASSESSED VALUE 8   THE ASSESSED VALUE FOR THE DEVELOPED LAND NORTH OF THE
AWMA AREA IS NOT INDICATIVE OF ASSESSED VALUE TRENDS, BUT RATHER OF POTENTIAL PROFITS.

L.3.T.A.  RESPONSES
BECAUSE THIS IS A VITAL ISSUE WITH LOCAL TAXPAYERS, ESPECIALLY THOSE WHOSE PROPERTIES HAVE BEEN
INDISCRIMINATELY DOWNZONED LAST YEAR IN LACUNA BEACH, THIS IS A VERY INADEQUATE ASSESSMENT OF
PROPERTY VALUES WITHIN THIS AWMA DISTRICTS   ASSESSED VALUATIONS HAVE TAKEN A DIP DUE TO THE
ECONOMIC TRENDS?  HIGHER INTEREST & COLLATERAL REQUIREMENTS BY LENDING INSTITUTIONS, QUESTIONABLE
UNCONSTITUTIONAL DOWNZONING, AND LAND-USE RESTRICTIONS WITHOUT DUE PROCESS OF LAW, OR JUST
COMPENSATION FOR THE TAKING OF PRIVATE  PROPERTY RIGHTS NOW FOR PUBLIC PURPOSES,  WHAT HAPPENS IN
CASES WHERE OWNERS ARE STILL PAYING MORTGAGES & THEIR DOWNZONED MULTI-UNITS ARE DESTROYED BY
FIRE, OR OTHER NATURAL CAUSES?  WHAT ABOUT  THE INSURANCE LIABILITIES INVOLVED IN DEVALUED DOWN-  -•
ZONED AREAS?  WHO IS LIABLE WHEN DISASTERS  STRIKE CONDOMINIUM APARTMENT COMPLEXES?  WHO GETS TO
REBUILD THEIR UNITS, WHO DO NOT?  THESE AND MANY OTHER FACTORS, PLUS THE DENIAL BY THIS CITY TO
OWNERS TO DEVELOP,  WHILE PROPERTY TAXES CONTINUE TO RISE DURING MORATORIUMS? ETC. ETC,
THIS PHASE OF THIS E.I.S. HAS SADLY SKIPPED MANY IMPORTANT FACTORS CONCERNED WITH LOCAL PROPERTY
VALUATIONS 8

PAGE ^=6 4.2.30^0 SEWERAGE FACILITIES 8   SEWERAGE SERVICE IN THE AWMA AREA HAS GENERALLY FOLLOWED
INITIAL HOUSING CONSTRUCTION, ALTHOUGH  IT HAS GENERALLY ANTICIPATED LONG-TERM GROWTH. ETC.
THE INITIAL SYSTEM FOR THE CITY OF LACUNA BEACH WAS CONSTRUCTED IN 1923, ETC.

L.3.T.A.  RESPONSES
NOTHING HAS BEEN MENTIONED CONCERNING THE UPDATING  OF OUR SEWER FACILITIES THROUGH THE $500,000
BOND WHICH IS TO RETIRE 198^8  THIS WOULD SERVE A POPULATION OF APPROXIMATELY 30 „ 000 IN LAGUNA
BEACH,  WHILE AWMA SEEMS TO INDICATE THROUGHOUT, THAT LACUNA'S SEWER SYSTEMS ARE INADEQUATE,
THE LAGUNA BEACH TAXPAYERS0 ASSOC . INC. BELIEVES THIS IS MERELY AN ASSUMPTION TO FORCE THIS CITY
THIS IS CERTAINLY A CONSPIRACY IF WE MUST CONTINUE TO BELIEVE THAT THE CITY WANTS NO-GROWTH

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      PAGE 11.

      L.B.T.A. RESPONSES CONTINUEDi
      AND AT THE SAME INCREASES OUR  SEWER SERVICES  SUR-TAXES  OVER  100% NOW,  ALSO REQUIRES THAT WE
      CONTINUE TO PAY FOR A SEWERAGE BOND UNTIL 1984- WHICH WAS  TO  HAVE ADEQUATELY PROVIDED FOR A
      POPULATION OF DOUBLE THE EXISTING  POPULACEl   PLEASE ANSWER THESE QUESTIONS & PROVIDE A LEGAL
      POSITION AND OPINION FOR THESE CONTROVERSIAL  FACTORS.

      PAGE 4-7, 4.2.3.5, SOCIAL FACTORS!  ECONOMIC PRESSURES OCCUR  WHEN THE COST OF HOUSING NEAR
      COMMUNITIES EXCEEDS THE COST OF HOUSING IN MORE REMOTE  AREAS.   HOWEVER,  IT APPEARS THAT THIS IS
      NOT THE CASE IN THE AWMA AREA.  THE AVERAGE COST OF HOUSING  IS  AS HIGH  OR HIGHER IN THE AWMA
      AREA, AND SINCE THE AREA IS REMOTE,  TRANSPORTATION COSTS  ARE SIGNIFICANTLY HIGHER.  IT MAY BE
      SURMISED THAT SOCIAL ATTITUDES PLAY A KEY ROLE IN THE DEVELOPMENT IN THE AWMA AREA.

      L.B.T.A. RESPONSEi
      THE ECONOMIC PRESSURES ARE CERTAINLY SIGNIFICANT WITHIN THIS AWMA AREA AS ANYWHERE IN THE U.S.A.
      AT THIS TIME.  MANY PEOPLE ARE WITHOUT JOBS.   IT CAN HARDLY  BE  CONSIDERED THAT AWMA IS A REMOTE
      AREA EITHERI  REMOTE TO WHAT?   WE HAVE ALL FACILITIES WHICH  LARGE CITIES HAVE!   AND PERHAPS OUR
      ETA'S TO AIRPORTS & SHOPPING AREAS  ARE EQUAL  TO LARGER  COMMUNITIES!  THE FACILITIES ARE HERE,
      BUT THE INTERUPTIONS OF PLANNING FOR FUTURE HUD CITIES  IS SOMETHING  OF A CHOATIC NATURE, WHEN
      PRACTICAL FACTORS ARE SUMMED TOGETHERI   DEVELOPMENT IN  ORANGE COUNTY HAS HALTED BECAUSE OF
      SUCH IMPROVISED PLANS BY FEDERAL GOVERNMENT FOR THE ULTIMATE PURPOSES  OF INTEGRATING OUR
      PEACEFUL LOCALE.  PLANS TO MOVE VAST NUMBERS  OF NON-ORANGE COUNTY RESIDENTS INTO OUR AREAS ARE
Y»     THE INGREDIENTS FOR A VERY NEGATIVE ENVIRONMENTAL IMPACT  HERE IN THE FUTUREI   EVEN THE ETHNICS
H     DO NOT WANT TO BE FORCED TO INTEGRATE.   THEY  ARE PROUD  PEOPLE AS ANY OTHER PEOPLE.  THEY DO
01     NOT DESERVE TO BE EXPLOITED ANYMORE THAN WE DESERVE TO  BE EXPLOITED  TO PAY FOR THIS CONSPIRACYl
      THE L.B.T.A. PREFERS STRAIGHT  LANGUAGE FOR TH1 IPITOME  OF BETTER UNDERSTANDING I   WE ARE NOW
      COMPELLED TO PAY FOR AWMA SCHEMING,  LET'S HAVE THE FULL RAW  FACTS WITH FULL DETAILS NOW!!!
      IT CAN BE ASSUMED HOWEVER,  FROM THE CHART 4-4 THAT THE  UNEMPLOYMENT  RATE PREVAILS WITH THE
      ETHNIC GROUPS.  THEY ALSO HAVE A HIGHER ADA IN LOCAL SCHOOL  SYSTEMS  BECAUSE THEY HAVE LARGER
      FAMILIES, ISN'T THIS A FACT?
      THE POVERTY RATE IS ALSO THE HIGHEST APPARENTLY IN THESE  CATAGORIES  IS IT NOT?
      SO WITH THESE FACTS EXPOSED NOW, CAN AWMA-EPA-HUD SAFELY  PREDICT THAT  THESE PROBLEMS WILL BE
      SOLVED BY PROVIDING MORE FACILITIES  WITHIN THIS AREA AND  CROWDING PEOPLE ALREADY UNEMPLOYED,
      AWAY FROM ORANGE COUNTY,  AND CAUSING OUR TAX  RATES  TO SOAR IN ORDER  TO PROVIDE GREATER PUBLIC
      POLICE, FIRE, JUVENILE HOMES,  PROBLEM CENTERS,  FOR THE  LESS  EDUCATED & SUBSIDIZED GROUPS?
      WHAT PROBLEMS AS SUCH CAN THIS AWMA-EPA-HUD PROGRAM SOLVE UNDER THE  TERMS LISTED WITHIN THIS S.I.R?

      PAGE 4-9, 4.2.3.6. CONCLUSIONt   THE OVERALL ECONOMIC HEALTH  OF  THE COUNTY,  FREEWAY ACCESS,  AND
      THE 'EXCLUSIVENESS' OF THE AREA HAVE BEEN THE MAJOR FACTORS  IN  PAST  GROWTH IN THE AWMA AREA.  THE
      INITIAL CONSTRUCTION AND SUBSEQUENT  WIDENING  OF THE SAN DIEGO FREEWAY  ARE THE KEY EVENTS OPENING
      UP SOUTHERN 0?J^NGE COUNTY TO ABSORB  DEVELOPMENT PRESSURES.
      PAGE 4-9, 4.3 FUTURE DEVELOPMENT PROSPECTS i   ESTABLISHING WHAT  HAS HAPPENED IN THE PAST, AND WHY,
      CAN BE DONE MUCH MORE ACCURATELY THAN THE FUTURE CAN 3E PROJECTED.

      T  ~Q *p A  RFSPONS**11
      THE'CONCLUSION is NOT SPECIFIC!  MANY QUESTIONS ARE POSSIBLE WITH SUCH A BROAD STATEMENT.  IF

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PAGE 12 o

LoB.ToAo  RESPONSES CONTINUEDt
SUCH A COSTLY FEDERAL PROGRAM  IS  TO  ABSORB  OUR  VERY  ECONOMIC  BALANCE WITHIN ORANGE COUNTY
DUE TO SUCH REMOTE PLANNING, THERE MUST ESSENTIALLY  BE A GOAL,  AN ABSOLUTE & ULTIMATE GOAL,
IN ORDER  TO BASE THE FEASIBILITIES OF SUCH  TAX  EXPENDITURES  IN  THIS AWMA AREA IN THE FUTURE!
THESE STATEMENTS AS FUTURE DEVELOPMENT PROSPECTS ARE INADEQUATE IN THAT THEY ARE GENERALIZED,
NOT SPECIFIC!  THE TOTAL NATIONAL ECONOMIC  PICTURE HAS NOT BEEN CONSIDERED AT THIS TIKE CR
IN THE FUTURE, AND WHILE THIS  IS  MERELY SPECULATIVE,,  A CERTAIN  TREND THROUGH ANALYSIS OF SUCH
COMPARABLE PROJECTS OVER THE U.S.Ao  IN THE  PAST A3 PRECEDENTS SHOULD BE USED IN THIS STUDYt
ON JUNE 230 2b0 1972, A SPECIAL SYMPOSIUM ON  NEW TOWNS WAS HELD AT U.C.I.  I WAS INVITED TO
ATTEND THESE INFORMATIVE SESSIONS I  IT WAS  INVALUABLE INFORMATION, ALTHOUGH IRRELATIVE TO
THOSE DAYS TO LEARN THAT THESE EASTERN NEW  TOWNS WHICH WERE  FEDERAL HUD PROJECTS WERE NOT
WORKING!   EACH PHASE OF THESE  PROGRAMS WAS  AIRED DURING THESE INFORMATIVE SESSIONS.   WHILE
A GREAT EXPRESSION WAS VOICED  THAT THE LOW-INCOMES NEEDED HOUSING, IT WAS STRESSED THAT THIS
WAS NOT THE WORKABLE SOLUTION  TO  SUCH NEEDSJ
AT THIS TIME, THE PICTURE BECOMES COMPREHENSIVEI  AWMA PLANS  SUCH A FEDERALLY SUBSIDIZED NSW
TOWN APPARENTLY UPON THE PRIME FARMING LANDS  WITHIN  THE AWKA-GSA AREAS SOONo  AWMA SHOULD
RSSSARCH THE NSW TOWNS & THEIR UNWORKABLE PROGRAMS CONCERNING8  RESTON, VIRGINIA AND JONATHAN,
MINNESOTA BEFORE WE GO BANKRUPT WITH TAXATION WHILE  EXPERIMENTATIONS CONTINUE UNDER AWMA HEREI

PAGE 4°10s FORMAL LAND USE PLANNINGA   BARRING ACTION TO RETARD  DEVELOPMENT BY REGULATORY AGENCIES,
AREAS WITHIN THIS DEVELOPABLE  REGION WILL CONTINUE TO DEVELOP TO THE LIMITS OF THEIR ZONING
(OR MORE), GUIDED CHIEFLY BY HOUSING ECONOMICS  AND ACCESSABILITYo  IT SHOULD BE NOTED THAT
ZONING HAS NOT•RESTRICTED DEVELOPMENT IN THE  AWMA AREA IN THE PAST.  ALTHOUGH STATE LEGISLATION
REQUIRES  THAT ZONING NOW BE CONSISTENT WITH LAND USE PLANS,  LAND USE PLANS MAY BE AMENDED THREE
TIMES EACH YEARo  IT IS PROBABLE  THAT DEVELOPING PLANS,  RATHER  THAN ZONING, WILL GUIDE AND
CONTROL DEVELOPMENTo

L.B.T.Ao  RESPONSES
THIS ENTIRE STATEMENT IS INADEQUATE  AND INACCURATE AND INCONSISTENT WITH THE LOCAL ZONING
AND DOWNZONING PRACTICES OF LACUNA BEACH WHICH  IS WITHIN TH3  AWMA AREA!   THE SYCAMORE HILLS,
RANCHOS PALOS VERDES ESTATES HAS  BEEN COMPLETELY STOPPED FROM THEIR LAND USE RIGHTS WITHOUT
A SUSPENSION OF THEIR PROPERTY TAXES0 BUT INCREASING DAILY COSTS DUE TO THESE RESTRICTIONS!
THE PROPERTY OWNERS 0? MACCHU  PICHU  LANDS WITHIN THE CITY LIMITS, THE OWNERS OF MANY OTHER
MAJOR PROPERTI3S IN LAG-UNA,  PLUS  ALL OWNERS OF  PROPERTIES OF R-3P R-2 AND C-l ZONED LANDS
HAVE BEEN STOPPED FROM USING THEIR PROPERTIES AS ZONED!   NO  PROPERTY OWNER, HOWEVER, HAS
HAD DUE PROCESS OF LAW IN COURT,  OR  JUST COMPENSATION OFFERED FOR THE TAKING OF HIS PRIVATE
PROPERTY  RIGHTS FOR THESE PUBLIC  PURPOSESI
ALSO NOT  MENTIONED WITHIN THIS FORMAL LAND  USE  PLANNING ARE  THE CONSTITUTIONAL PROVISIONS
WHICH ULTIMATELY COULD COST THE TAXPAYERS EXORBITANT CLAIMS  WHEN THE COURTS MUST AWARD THESE
RESTRICTED AND DEFAULTED PROPERTY OWNERS THEIR  JUST  COMPENSATIONS FOR THEIR LAND USE RIGHTS!  '

TO CONTINUE RESPONSE THAT LOCAL GOVERNMENT  ULTIMATELY HAVE 'COMPLETE' CONTROL OF LAND USE
DECISIONS IS ALSO ERRONEOUS!  THE SCAG AND  CALIF» COASTAL ZONE  COMMISSION, THE 0,C. SUPERVISORS,
THE LAFC, THE FEDERAL AND STATE GOVERNMENTS NOW HAVE FINAL CONTROLS OVER OUR LAND USE DECISIONS!
30 THIS STATEMENT IS ENTIRELY  FALSE  AND A THOROUGH REPORT CORRECTING THESE STATEMENTS SHOULD

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PAGE 13.

L.S'.T.A, RESPONSE CONTINUED!
ACCOMPANY THE ADDENDUM ON THIS CATAGORYl
THE 1983 LAND USE ELEMENT WHICH GOVERNS MOST OF THE AWMA AREA, THE CITY OF LAGUNA BEACH'S       :t
GENERAL PLAN, ETC. IS TOO BRIEF FOR COMPREHENSION!  THE CITY OF LAGUNA BEACH HAS NOT COMPLETED
ITS GENERAL PLAN, ALSO THE PRESENTED PROPOSALS AS ADOPTED VARIOUS DATES SINCE 1972 ARE  NOT
FEASIBLE IN THAT NON-PROFESSIONALS HAVE COLLATED THESE'DOCUMENTS FOR THE CITY OF LAGUNA BSACHl
ALSO SEVERAL OF THESE E.I.R.'S HAVE BEEN OPPOSED AND THE CITY NEVER RESPONDED OR CCRRSCTED
"THEIR STATEMENTS FOR FUTURE CONSIDERATION AND LEGAL PURPOSES 1  THEREFORE, SUCH  PROJECTIONS
CONCERNING THE LAND USE ELEMENTS ARE INCONSISTENT AND INACCURATE.
THE L.B.T.A. WOULD APPRECIATE INFORMATION CONCERNING THE OWNERSHIPS OF THE LANDS WHICH  THE
AWMA HAS PLANNED FOR INTENSIVE FUTURE DEVELOPMENTS WITHIN THESE WATERSHEDS.  WILL THE OWNERS
BE FORCED TO SELL TO PUBLIC AGENCIES FOR THE PURPOSES OF PROVIDING HUD CITIES FOR THE LOW-
INCOME SUBSIDIZED PEOPLE?
ARE THESE LANDS CURRENTLY UNDER THE WILLIAMSON ACT, AND AGRICULTURAL PRESERVE PROGRAMS?
HAVE THE OWNERS OF THESE LANDS BEEN PROPERLY NOTIFIED OF THE FUTURE POTENTIALS  WHICH THEIR
LANDS HAVE BEEN DESIGNATED UNDER THESE LAND USE PROGRAMS BY AWMA-EPA-HUD?
WHILE SOME IRVINE COMPANY LANDS ARE UNDER AGRI-PRESERVE STATUS, THE AWMA PROPOSED WATERSHED
LANDS WITHIN ALISO VALLEY HAVE NOT BEEN MENTIONED WITHIN THIS E.I.S.  WHAT ARE  THESE STATUS1?

PAGE 13, SEWERSt  THE EXISTING SEWER LINES CAN BE SEEN ON EXHIBIT 4.?. ALMOST ALL FACILITIES
ARE NOW ADEQUATE, BUT ARE APPROACHING CAPACITY.  ETC.

L.B.T.A. RESPONSE!
THIS STATEMENT CONTRADICTS TABLE 1-1 WHICH MENTIONS THAT THE LAGUNA BEACH SEWERAGE DISPOSAL
SYSTEMS ARE INADEQUATE, OUTDATED FACILITIES WITH POOR QUALITY SFFLUSNTl
PLEASE CORRECT THE CONTRADICTORY STATEMENTS.  'WHICH IS CORRECT & HOW WAS THE FACT DETERMINED?

PAGE 4-lAi 4.3.3.4- OTHER UTILITIES!  OTHER UTILITIES, SUCH AS SCHOOLS, FIRS PROTECTION, POLICE
PROTECTION & SO FORTH ARE AFFECTED BY URBANIZATION.  HOWEVER, THESE UTILITIES CUSTOMARILY DO  NOT
STIMULATE OR DETER DSVELOPftENT, SO NO DETAILED EXAMINATION OF TRENDS WAS MADE.

L.B.T.A. RESPONSEt
THESE ARE VERY COSTLY UTILITIES, ACTUAL PUBLIC FACILITIES TO ALL AREA PROPERTY  OWNERS!   THE
TRENDS ARE THAT DEVELOPMENT MUST PROVIDE ADEQUATELY FOR THESE NEW FACILITIES, THEREFORE, MORE
CONSIDERATION IN THIS E.I.S. SHOULD HAVE BEEN GIVEN TO THESE AREAS OF ENVIRONMENTAL IMPACT
UPON THE AREAS WITHIN AWMA PLANNING HERE.  ARE DEVELOPERS IN THE FUTURE REQUIRED TO PROVIDE
CERTAIN LANDS FOR THESE FACILITIES PRIOR TO CONSTRUCTING HOMES?  HOW MUCH OF THESE BURDENSOME
COSTS FOR SUCH PUBLIC FACILITIES GOING TO BE A PART OF THAT AREAS COSTS?  WILL  THESE COSTS BE
ANOTHER GENERAL TAXATION FOR ALL ORANGE COUNTY PROPERTY TAXPAYERS TO SUPPORT THESE FACILITIES?
LOW-INCOME, WELFARE FAMILIES AS PROPOSED IN THE AWMA PROJECT WILL CERTAINLY NOT BE FINANCIALLY
SOLVENT TO ABSORB SUCH MAJOR UTILITY COSTS IN THE FUTURE.  HAS ANY COST ANALYSIS BEEN DETERMINED
APPROXIMATELY HOW MUCH ADDITIONAL TAX REVENUES GENERALLY WILL BE NEEDED TO OFFS2T THESE FACILITIES?
WHILE TRENDS NEITHER STIMULATE OR DETER SUCH FACILITY rtEQUIKSMSNTS, THESE ARE CERTAINLY A MAJOR
FACTOR TOWARD PLANNING WITHIN AN UNDEVELOPED PRIME FARMING AREA SUCH AS AWMA PROPOSES NEAR THE

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00
 PAGE 1*4-.

 L.B.T.A.  RESPONSES CONTINUED...
 0.3, A.,  ZIGARRAT FEDERAL GOVERNMENT  FACILITY  WITHIN THE LAGUNA-NIGUEL AREAI

 PAGE 4-14,  4.3.4.  REGULATORY PROGRAMS i   REGULATORY PROGRAMS ,  ESPECIALLY THOSE DEVELOPED UNDER
 THE. CLEAN AIR ACT AND THOSE: DEVELOPED  UNDER THE COASTAL CONSERVATION ACT, WILL AFFECT DEVELOPMENT
 IN THE AWMA AREA.   OBVIOUSLY,  CONSTRUCTION PERMITTED BY THE CITIES AND THE COUNTY AS PART OF THSIF
 GENERAL PLANNING FUNCTION WILL HAVE  A  LARGE EFFECT ON AWMA's  URBAN GROWTH.

 L.B.T.A.  RESPONSE!
..ON PAGE 4-10,- 4.3.2.  FORMAL USE  PLANNING .ON LAND .DEVELOPMENT  STATES THAT LOCAL GOVERNMENTS
 ULTIMATELY  HAVE 'COMPLETE' CONTROL OF  LAND USE DECISIONS.   THIS STATEMENT CONTRADICTS THE ABOVE
 -STATEMENT MADE UNDER  REGULATORY- PROGRAMS, AND MY STATEMENT PREVIOUSLY THAT SCAG , THE COASTAL
 ZONE COMMISSION, LAFC,  THE ORANGE COUNTY BOARD OF SUPERVISORS,  ETC. ALL HAVE ABSOLUTE CONTROLS
 OVER LOCAL  PLANNING AND CONSTRUCTIONl   PLEASE CLARIFY YOUR STATEMENTS REGARDING PAGE 4-14 ,4. J. 4 . ?

 PAGE 4-16,  4.3.7 CONCLUSIONt  UNLESS  SUBSTANTIAL CHANGES IN GOVERNMENTAL POLICIES OCCUR, THE
 AWMA AREA WILL CONTINUE TO ABSORB A  SIGNIFICANT AMOUNT OF ORANGE COUNTY'S POPULATION GROWTH.
 AT THE COUNTY LEVEL,  THE ACTUAL  LEVEL  OF POPULATION GROWTH DEPENDS ON GENERAL ECONOMIC CONDITIONS
 WHICH CANNOT BE PREDICTED.  THE  AREAS  WITHIN  AWMA, 'WHICH A BSORB POPULATION, THE AMOUNT OF
 POPULATION  ABSORBED,  AND THE MANNER  IN '//HIGH  POPULATION IS ABSORBED, DEPENDS ON GOVERNMENTAL
 POLICIES AND ACTIONS.  IN PARTICULAR,  LAND USE PLANNING & REGULATION, AND EXTENSION OF PUBLIC
 UTILITIES,  INCLUDING  SEWER TRUNKS, WATER TRUNKS AND ROADS, WILL ALL PLAY A CRITICAL ROLE  IN
 DETERMINING THE URBAN FORM AS  AWMA DEVELOPS.

 L.B.T.A.  RESPONSE:
 THIS ENTIRE STATEMENT IS QUITS FACTUAL IN ESSENCE, HOWEVER. THE BASIC MYSTERIES CONCERNING WHY
 THE CITY OF LACUNA BEACH IS PREPARING  FOR POPULATION EXPANSION, CHARGING EXORBITANTLY FOR OUR
 SEWER SERVICES WHEN THEY ARE ALREADY PAID THROUGH PROPERTY TAXES, AND THEIR NO-GROWTH, DOWNZONING
 AESTHETIC -VILLAGE LACUNA STORIES,  CERTAINLY CONTRADICT THE FUTURE PROGRAMMING BY AWMA IN THIS  SIS!
 THE REAL PROBLEMS ARISE WEN OVER TAXATION OF ESTABLISHED COMMUNITIES OF LESSER TAX BASES, -.NO
 GROWTH,  AND SMALL POPULACE ARE REQUIRED TO SUBSTANTIALLY SUBSIDIZE A FUTURE POPULATION PROGRAM
 WHICH DOES  NOT SHOW AN ABSOLUTE  POSITIVE POTENTIAL.  EXAMPLES!   THE NEW CITIES OF RESTON, VA . ,
 AND JONATHAN, MINN. WERE ABSOLUTELY  COSTLY FLOPS.   THESE HAVE COST AREA TAXPAYERS SMALL FORTUNES
• FOR NO" ADVANTAGEOUS" PUR POSES I  'WHY CAN'T SUCH PROJECTS AS PRECEDENTED THERE SERVE AS FUTURE
 PLANNING EXAMPLES FOR THIS AWMA  PROGRAM HERS?  WHY MUST ALL PROPERTY TAXPAYERS SUBSIDIZE
 EXPERIMENTAL" PROGRAMS SUCH AS  THIS" A'.VMA PROJECT, SIM'PLY TO PROVIDE FEDERAL & STATS 'GRANTS TC
 BE SQUANDERED OVER MORE OF THE SAME  UNWORKABLE NEW HUD EXPLOITATIONS?
 WHY MUST THE LOW-INCOME PEOPLE,  THE  ELDERLY,  THE LESS EDUCATED PEOPLE, THE ETHNICS * THE  POOR
 VULNERABLE  TAXPAYERS  BE EXPLOITED CONTINUOUSLY FOR SOCIALISTIC PROGRAMS 'WHICH HAVE NCT PROVEN
 EQUAL VALUE FINANCIALLY OR ..PHYSICALLY?
 WHY MUST OUR ECOLOGICAL BALANCES OF  NATURE BE SUBMITTED PERMANENTLY NOW THROUGH AWMA PROJECTS
 FOR THESE UNWORKABLE  SOCIALISTIC SCHEMES WHICH BRING MORE PROBLEMS & PEOPLE INTO THIS AREA
 WHICH IS ALREADY SUFFERING FROM  ECONOMIC DEPRESSION, SMOG PROBLEMS, OCEAN POLLUTION & AIR
 PROBI FMS*'
 IT IS ABSOLUTELY STATED ABOVE THAT NEW SEWERS, WATER TRUNKS & ROADS WILL BE A FART OF THIS

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      PAGE 15.

      L.B.T.A.  RESPONSES}  CONTINUED  PAGE 4-16 4.3.?.i
      AWMA PROJECT I   THESE ARE CRITICAL FACTORS WEN  CONSIDERING  THAT THIS AREA  IS  PRIME FARMING
      LANDS.   WHY NOT BUILD HUD COMMUNITIES  ON NON-FARMING  LANDS  AND PRESERVE OUR PRECIOUS FARMING
      LANDS THROUGH YOUR ENVIRONMENTAL PROTECTION  LEGISLATION?
      THE REASON WHY LEVEL LANDS ARE BENEFICIAL IS THAT  IT  IS LESS  COSTLY TO  DEVELOP THE LOW-INCOME
      HIGH-DENSITY-COMMUNAL APARTMENTS ON  LEVEL GROUND ISN'T THAT THE BASIC REASON  WITH AWMA PROJECTS?
      BUT PRESENT COSTS FOR DEVELOPMENT AREN'T ANY LONGER CHEAPI  30 NOT ONLY IS PUBLIC LAND LOST
      FROM THE TAX ROLLS,  BUT  THE  TAXPAYERS  ARE BURDENED ADDITIONALLY TO SUBSIDIZE  COSTLY HOUSING
      FOR THE LOW-INCOMES  SUBSIDIZED ON WELFARE &  GOVERNMENT PAYROLLS!  IS THIS  THE WAY TO RESPECT
      THE INDIVIDUALS SUPPORTING THE ECONOMIES?  HOW  LONG CAN A SMALL GROUP OF LAGUNA BEACH PROPERTY
    .  TAXPAYERS CONTINUE TO PAY FOR  THESE  EXORBITANT  PUBLIC FACILITIES  IN THE FUTURE?  THIS E.I.S.
      DOES NOT ATTEMPT TO  EXPLAIN  THESE VERY VITAL ISSUES DOSS IT?  WHY?  THERE  ARE MANY PROPERTY
      OWNERS, ELDERLY AND  WITH LOW-INCOMES TOO IN  LACUNA BSACHI   ARE THESE PEOPLE GOING TO LOSS
      THEIR HOMES OVER THIS PROGRAM  THROUGH  AWMA & THIS  CITY'S TAXATION PROGRAMS?  WE DESERVE ANSWERS 1

      PAGE 4-17,  4.4 PARAGRAPH TWO IN PARTi  ALTHOUGH SEPTIC TANK USE CAN BE  OBSERVED IN THE NEARBY
      SANTA MARGARITA WATER DIST., SEPTIC  TANKS ARE NOT  A REAL ALTERNATIVE IN AWMA.  BECAUSE OF OPPOSITION
      BY THE REGIONAL WATER QUALITY  CONTROL  BOARD  AND THE COUNTY.   SHOULD SEPTIC TANK USE BE ALLOWED,
      THE NET POPULATION OF AWMA WOULD NOT BE REDUCED MUCH. (THERE  ARE  40,000 ACRES UNDEVELOPED IN
      AWMA.  ASSUMING HALF THE AREA  IS SUITABLE FOR SEPTIC  TANKS, AND DEVELOPED  ON  HALF ACRE LOTS,
^     YOU COULD HAVE 20,000 HOUSES,  OR ABOUT 80,000 MORE PEOPLE FOR A TOTAL OF 250,000.) etc.

^     L.B.T.A.  RESPONSE:
      THE CITY OF LACUNA BEACH HAS SAID NOTHING OF THEIR APPROVAL OF THIS POPULATION EXPANSION WITHIN
      THEIR APPROVED AWMA  DISTRICTI   SEPTIC  TANKS  WERE ALWAYS USED  PRIOR TO THE  SEWER TREATMENT
      PROJECT IN LACUNA BEACH.   THE  OCEAN  WAS NEVER POLLUTED, ANT) FISH  WERE EDIBLE  THEN!  THE L.B.T.A.
      FEELS THAT UNLESS ALTERNATIVES TO TREAT SEWERAGE FROM THIS  ANTICIPATED  POPULATION OF 250,000
      PEOPLE WITHIN THE AWMA DISTRICT OTHER  THAN OCEAN OUTFALL SYSTEMS, WE CAN SURELY PREDICT AN
      ABSOLUTE ADVERSE ENVIRONMENTAL IMPACT  IN CUR COASTAL  WATERS.  THE WATERSHED DETERRANTS FRCfc
      ADDITIONAL ROADS, PAVED  SHOPPING CENTERS, FREEWAYS, SIDEWALKS, ETC. WILL IN THEMSELVES FC5E A
      MAJOR HAZARD TO THE OCEAN'S  ENVIRONMENTAL BALANCE  AT  ALISO  CREEK  TRIBUTARY INTO THE SSA WITH
      AWMA'S  NEW CITY BY THE GSA,  ZIGARRAT BUILDING.  WHY HAVEN'T THESE VERY  IMPORTANT ITEMS BEEN
      INCLUDED IN THIS E.I.S.?  THEY.ARE CERTAINLY INEVITABLE BECAUSE THE DRAINAGE  CHANNEL IS NOT
      COMPLETED BELOW THE  ZIGARRAT,  AND THE  NATURAL WATERSHED CANALS ARE ALREADY TERRIBLY ERODEDl.
      ALISO BEACH IS ONE OUR MOST  LOVELY BEACHES AND  VIEWING POINTS IN  LACUNA BEACHl  "WHY THIS AREA
      BE THREATENED NOW WITH THIS  COSTLY,  UNWORKABLE  NSW CITY PROJECT UNDER AWMA-EPA-HUD?

      PAGE 4-1? THRU PAGE  4-22i  4.5.2.2.  QUALITYi  URBANIZATION  ALSO INCREASES  THE POLLUTANTS FOUND
      IN STORM RUNOFF.  STREETS &  CURBS IN URBANIZED  AREAS  COLLECT  RUNOFF AND POLLUTANTS LIKE
      DETRITUS, LEAD FROM  AUTO EMISSIONS, &  OILS AND  GREASE.  ETC.  THESE STATEMENTS CONFIRM MY
      PREVIOUS  RESPONSES CONCERNING  AWMA'S PROJECT E.I.S.
      4.5.3.  LAND«   DEVELOPMENT IN THE AWMA  AREA WILL DEVOTE 40-50# OF  THE REMAINING OPEN SPACE TO
      URBANIZED LAND.  ETC.
      L.B.T.A.  RESPONSE!
      THIS STATEMENT ALSO  CONFIRMS MY QUESTIONS PREVIOUSLY, WHY SHOULD  PRIME  FARMING LANDS BE

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         PAGE 16.                                                                   •

         L.B.T.A.  RESPONSEESi
         UTILIZED  FOR  URBANIZATION WHEN OTHERWISE NON-FARMING, HILLY TERRAINS ARE DENIED  DEVELOPMENT
         BECAUSE OF THEIR AESTHETIC OPEN SPACE QUALITIES, OR THE SQUIRRELS. TARRANTULERS,  RODENTS,
         BIRDS & BEES,  FLORA & FAUNA ARE DISTURBEDl  THIS REASONING IS RIDICULOUSl  WHAT  ABOUT THE
         FUTURE FOOD SUPPLYING AREAS?  WITH MORE PEOPLE IN ORANGE COUNTY, MORE FOOD MUST  BE PROVIDED
         FROM THE  FIELDS I  INSTEAD OF TAXING FARMERS INTO DEVELOPMENT OF THEIR LANDS,  WHY NOT  PROVIDE
         TAX RELIEF IN ORDER TO ALLOW THEM TO PRODUCE FOR THE PUBLIC'S HEALTH, SAFETY  AND WELFARE?
         NOTHING WAS MENTIONED TO PRESERVE SUCH PRIME LANDS FOR FARMING, INSTEAD OF AWMA  USING NON-
         FARMING LANDS FOR URBANIZATIONI

         PAGE 4-22,  4.6.1i  SUMMARY OF MITIGATION MEASURES EVALUATED BY THE APPLICANT!  HIGH DENSITY
         CLUSTER RESIDENTIAL DEVELOPMENT WITH NEIGHBORHOOD SHOPPING CENTERS RATHER THAN LOW DENSITY
         DEVELOPMENT WITH REGIONAL SHOPPING CENTERS.  THIS OPTION COULD REDUCE VMT IN  THREE WAYS«
         (A) SHORTER TRIPS, (B) INCREASED UTILIZATION OF TRANSIT, AND (C) SHOPPING BY  BICYCLE  OR
         WALKING.   IT  IS ESTIMATED THAT THIS COULD REDUCE VMT BY 311,000 MILES PER DAY.   THIS  OPTION
         COULD NOT BE  IMPLEMENTED BY THE APPLICANT, BUT WOULD TAKE ACTIONJBY LOCAL GENERAL PURPOSE
         GOVERNMENTS.

         L.B.T.A.  RESPONSES!
         WHO EVER  DID  THEIR SHOPPING AT SUPER MARKETS ON BICYCLES?  I WOULD SUGGEST THAT  ANY MEMBER
         OF THIS AWMA  TEAM TRY THIS RIDICULOUS MODE OF LIFE STYLE FIRST BEFORE SUGGESTING THAT OTHERS
f        DO IT ON  A PERMANENT BASIS I
£        HIGH DENSITY  CLUSTER RESIDENTIAL DEVELOPMENT IS A VERY INCOMPATIBLE METHOD CF LIVING  HAPPILY
0        ON A PERMANENT BASIS I  PSYCHOLOGISTS HAVE THEIR MOST COMPLEX BAStS WHERE SUCH PROBLEMS ARE
         BROUGHT TO THEM BY PERSONS WHO ARE LIVING OR HAVE LIVED WITHIN SUCH TIGHT QUARTERS WITH ALL
         ETHNIC GROUPS COMPACTED TOGETHER.  DIVORCES ARE AT THEIR HIGHEST LEVELS IN SUCH  QUARTERS.
         JUVENILE  DELINQUENCY AS PARENT DELINQUENCY IS THE HIGHEST LEVELS WITHIN SUCH  TIGHT LIVING
         COMPLEXES.  THE TRANSFER & MOVING RATES ARE THE HIGHEST IN SUCH HIGH DENSITY  QUARTERS.  WHY
         ADD TO THESE  MAJOR ADVERSITIES SIMPLY TO ACCOMMODATE THE CROWDS WISHING TO LIVE  BY OR NEAR
         THE SEA?   IT  IS TIME THAT PEOPLE WERE GIVEN THEIR CONSTITUTIONAL RIGHTS AGAIN, THEIR  FREEDOMS
         TO SELECT PLACES WHERE THEY ARE HAPPIEST, WHERE THEY ARE SATISFIED, RATHER THAN  FORCE PEOPLE
         INTO COMMUNAL LIVING COMPOUNDS!  IS THIS THE SIGNIFICANCE OF GOVERNMENT CODEi  65858?
         PEOPLE TEND TO ESCAPE SUCH ENVIRONMENTS, WHICH-ARE PSYCHOLOGICALLY CRAMPING TO THEIR  STYLES,
       .  AND. THEY  .TAKE TO-THE ROADS. IN GREATER NUMBERS SIMPLY TO EXPEND THEIR EMOTIONS! ..THEY  DRINK
         ALCOHOLIC DRINKS MORE PREVALENTLY, THEY CREATE NUISANCES TO BRING ATTENTION TO THEIR  PLIGHTS,
         .THEY ARE  GENERALLY MISFIT PEOPLE IN A SOCIETY AROUND THEM WHICH IS COMFORTABLE SUCH AS MOST
         PEOPLE ARE IN SINGLE FAMILY DWELLINGS WITH THE AFFRANCHISEMENTS OF PROPER LIVING CONDITIONS.
         THEREFORE,  THE ESTIMATION CF REDUCED VMT'S BY 311,000 M.P.DAY IS ASSUMPTIOUSI
         A NSW TOWN NEAR THE GSA, ZIGARRAT AS PROPOSED UNDER SUBSEQUENT PLANS LISTED IN THE AWMA
         PLAN BOOK B-15 THRU B-17 WOULD BE A VERY EXPENSIVE SPECULATIVE SCHEME TO APPEASE THE  LOW-
         INCOME PEOPLE'WHO-WOULD BE EMPLOYED BY THAT FACILITY.  IT WOULD HARDLY WARRANT CONSTRUCTION
         CF A NEW  CITY, WITH ITS COSTLY AMENITIES UNDER SUCH LOOSELY PROGRAMMED AWMA REPORTS.
         THE SAME  REFERENCES ARE GIVEN AS FOLLOWSi
         PAGE ^-23.  ITEM  b.   CONSTRUCT A  NSW  TOWN AROUND  THE GSA  FACILITY.   IF A-ICMK*~GHIENTED
         SERVING THE G$A  FACILITY AND TOWARDS REDUCING AUTOMOBILE TRAFFIC  WERE CONSTRUCTED,  THE
TOWARDS

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       PAGE 17.

       L.3.T.A. RSSPONSESs CONTINUED FROM PAGE ^-2J, ITEM ^i
       APPLICANT ESTIMATES THAT IT COULD REDUCE VMT BY 57^,000 MILES PER DAY OR MORE.  THIS WOULD
       REQUIRE A COORDINATED EFFORT BY LANDOWNERS, LOCAL AND FEDERAL GOVERNMENTS, A3 WELL AS A
       CHANGE IN THE ATTITUDE OF THE LOCAL POPULATION WHICH IS OPPOSED TO LOW OR MEDIUM COST HOUSING,

       L.B.T.A. RESPONSESi
       THE FACT THAT AWMA PROPOSES A NEW TOWN AROUND THE GSA,  ZIGARRAT FACILITY AT AN EXORBITANT
       TAXATION ALREADY TO LOCAL PROPERTY TAXPAYERS, WITHOUT THE DETAILED ITEMIZATION OF THE VERY
       COSTLY AMENITIES, SCHOOLS, FIRS & POLICE PROTECTION SERVICES, PUBLIC FACILITIES FOR HEALTH,
       BIKE ROUTES, JUVENILE AUTHORITIES, RECREATIONAL FACILITIES, ETC. PLUS THE COSTLY GENERAL PLAN
       CONCEPTS!  THE TRANSPORTATION ELEMENTS, THE PUBLIC UTILITIES, GAS, WATER ELECTRICITY, SEWERS,
       REFUSE COLLECTION & DISPOSAL AREAS, THE ADVERSE ENVIRONMENTAL IMPACTS UPON THE GREEN BELTS,
       THE OPEN SPACES, THE FLOOD PLAIN ZONES & ERODED CANALS & NEEDS FOR MORE FLOOD CONTROL CHANNELS,
       THE AIR, SOIL AND WATER POLLUTION PROBLEMS AND THE ULTIMATE POLLUTION TO ALISO CREEK TRIBUTARIES
       TO THE SEA ARE NOT THOROUGHLY EXPLAINED OR ITEMIZED THROUGHOUT THIS S.I,3.1                     {
       THE ENTIRE PRIME FARMING LANDS AROUND THE ZIGARRAT, THE GSA FACILITY WILL BE TOTALLY INNUNDATED.
       FOR ROADWAYS, FREEWAYS, BIKE ROUTES, PAVED SIDEWALKS ETC.
       WHEN THE CITIZENS & TAXPAYERS ARE SUBJECTED TO THESE COSTLY ITEMS FOR THE BETTER WAY OF LIFE,
       WE HARDLY CAN BE CATALOGUED AS OPPOSED TO LOW OR MEDIUM COST HOUSING 1  THAT STATEMENT IS FAR
       FROM THE TRUTH IN THE AWMA AREA... WE WOULD APPRECIATE KNOWING WHERE YOU OBTAINED THIS INFORM-
       ATION TO MAKE SUCH A GENERALIZED STATEMENT?  WE ARE NOT OPPOSED TO HOUSING THE POOR, OR MED I UK  '
«>      INCOME PEOPLE IF THIS MIGHT BE ASSUMEDl  WE FEEL THAT THERE ARE MANY PROPERTY OWNERS WITHIN    :
-      THIS LOW AND MEDIUM CATSGORYl  PEOPLE SHOULD BE ALLOWED TO SELECT THEIR OWN MODE OF LIVING-,
-      THEIR OWN FINANCIAL ARRANGEMENTS FOR HOUSING, AND NOT BE PROVIDED WITH GOVERNMENT WELFARE
       & HOUSING SUBSIDIES AT THE EXPENSE OF OTHER PROPERTY TAXPAYERS I   PROUD,- PEOPLE ARE FOUND ONLY
       WHERE PEOPLE ARE FREE TO CHOOSE, LIVE WHERE THEY WISH,  WORK WHERE THEY WISH, AND EARN THEIR
       OWN LIVINGS.  WELFARE ONLY BREEDS MORE CONTEMPT AGAINST THE ESTABLISHMENT WHICH SUPPORT THEM I
       A FINE REFERENCE TO THIS STATEMENT CAN BE FOUND ON PAGES 79 THRU Q3 IN THE MARCH 1975 ISSUE
       OF THE READER'S DIGEST.  THIS REVEALING DOCUMENTATION CONCERNING FIDEL CASTRO'S CONTROLS OF
       CUBA IS ENTITLED!  "CUBA'S NEW LOOK", BY TED MORGAN, A PRIZE WINNING REPORTER!  WHILE AMERICAN
       STANDARDS WOULD PROBABLY NEVER REACH SUCH A SUB-STANDARD LEVEL AS CUBA, THERE IS MERIT TO THE
       WORK PROGRAMS IMPLEMENTED NOW IN CUBA.  THERE IS NO UNEMPLOYMENT THERE, AND INDUSTRIALIZATION
       HAS REACHED A ZENITH AGAIN.  OUR WELFARE, GIVEAWAY PROGRAMS ARE CREATING THE NATIONAL DEFICITS
       WHICH COULD ULTIMATELY BE OUR END.  MORE SUBSIDIZED PROGRAMS WILL CERTAINLY NOT ELIMINATE THE
       POVERTY LEVELS IN AMERICA, BUT CREATE ADDITIONAL ONES IN THE FUTURE.
       MENTAL HOSPITALS WILL BE NECESSARY FOR MANY FRUSTRATING, HELPLESS INDIVIDUALS IF THE ECONOMIC
       CONDITIONS WORSEN.  SOCIALIZED MEDICINE, WITHOUT MALPRACTICE INSURANCE CERTAINLY PRESENTS A
       BLEAK PICTURE FOR EVERYONEI

       PAGE J*-23 AND 4-24, ^.6.2, ADDITIONAL MEASURES; A RELATED BENEFIT OF ANY FORM OF UTILITY
       EXTENSION CONTROL WOULD BE TO INCREASE DENSITY IN ALREADY DEVELOPED AREAS.  THIS IN TURN WOULD
       INCREASE THE POTENTIAL FOR MASS TRASIT, CAR POOLING, AND OTHER MEASURES WHICH NEED DENSITY TO
       WORK WELL.  THE DEVELOPMENT OF WORK CENTERS WITHIN AND NEAR AWMA REPRESENT BOTH AN OPPORTUNITY
       & A POTENTIAL THREAT TO THE ENVIRONMENT IN AND NEAR AWMA.

       L.B.T.A. RESPONSES!

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 PAGE 18.

 RESPONSES CONTINUEDs
 INCREASED DENSITY IS OPPOSED BY THE CITY OF LACUNA BEACH, YET THEY HAVE APPROVED OF THE AWMA,
 THE L.B.T.A. WOULD APPRECIATE LEARNING WHY THE CITY OF LACUNA BEACH OPPOSES DENSITY &  POPULATION
 INCREASES IN LACUNA BEACH, YET HAS APPROVED OF THESE HIGH DENSITY STANDARDS SET BY THE AWMA
 IN THE OPEN SPACES, GREEN BE~LT AREAS, FLOOD PLAIN ZONES & ON PRIME FARMING LANDS WITHIN THIS
 SPHERE OF INFLUENCE?  OVER CROWDING PEOPLE IN COMMUNES WON'T SOLVE PROBLEMS, BUT GREAT?NEW ONES8

 PAGE ^-25. ^o?0^0 DON'T PARTICIPATE IN THE PROJECT SINCE IT WILL FACILITATE GROWTH WHICH  WILL  IN
 TURN HAVE A SIGNIFICANT AIR QUALITY IMPACT;  IF THERE IS NO EPA PARTICIPATION, THE APPLICANTS
 WILL CONSTRUCT A REGIONAL SYSTEM WITH THEIR OWN MONEY, PROBABLY WITHOUT THE CITY OF LACUNA BEACH.

 L,B.T.Ao RESPONSES?
 TO THIS MEASURE, WE WOULD FINALIZE OUR OPINIONS THAT THERE WOULD BE LITTLE NEED FOR AN INDEPENT-
 ENT SEWER-WASTEWATER FACILITY TO BE CONSTRUCTED BY THE AWMA, BECAUSE LOCAL SEWER SYSTEMS
 FACILITIES WOULD CONTINUE TO PROVIDE LOCAL PROPERTIES8  AS HAS BEEN STATED WITHIN THIS E.I.S...
 THE INCREASING OF UTILITIES WOULD NECESSITATE THE CREATION OF NEW POPULACE REQUIREMENTS,  OTHERWISE,
 THERE WOULD BE VERY LITTLE NEED TO CHANGE PRESENT SEWER TREATMENT FACILITIES IN ORDER  TO  RETAIN
 THE CITY OF LACUNA BEACH'S AGREED POPULATION MINIMAL GOALS!  AWMA-EPA-HUD PROGRAMS HAVE BEEN
 UNPOPULAR BECAUSE THEY INTEND TO ENCOURAGE A MASSIVE POPULATION EXPANSION PROGRAM WITHIN  THIS
 AREA FOR NO APPARENT ADVANTAGES EITHER TO LOCAL ECONOMY, OR THE ENVIRONMENTAL  PROGRAMS" RETINUE!

 PAGE 5-1 p 5.0, 5-1 THRU 6=28  ALTERNATIVE 2FL  DOWNSTREAM CENTRAL TREATMENT WITH MINOR
 RECLAMATION UPSTREAM.  IT HAS BEEN DETERMINED THAT THIS ALTERNATIVE IS THE MOST COST-EFFECTIVE
 ALTERNATIVE OVER A 20 YR. PERIOD AT THE DESIGN POPULATION RANGE OF 1?00000 TO  250„000,
 PAGE 5-2, ALTERNATIVE lAs COSTS FOR EXPANDING LOS ALISOS' & EL TORO°S TREATMENT PLANTS HAVE BEEN
 ELIMINATED SINCE THESE TREATMENT PLANTS HAVE ALREADY BEEN EXPANDED,  THESE CORRECTIONS REDUCE
 THE ESTIMATED COST OF ALTERNATIVE 1A BY ABOUT $8 MILLION.

 L,B.T,A, RESPONSES
 IF THESE ALTERNATIVES HAVE REDUCED THE AWMA COSTS $8 MILLION, HOW MUCH IS THE  TOTAL BILL?
 THE L,3.T.A0 WOULD ALSO APPRECIATE LEARNING WHY THE CITY OF LACUNA BEEN HA3 RECENTLY ASSESSED
 EACH PROPERTY TAXPAYER OVER 200# OF THEIR EXORBITANT SEWER SERVICE CHARGES IF  SUCH ALTERNATIVES
 ARE SO ECONOMICAL FOR THE AWMA?  ALSO WHY DID CARL XYMLA LAST FALL CALCULATE THAT BY THIS CITY'S
 JOINING THEN WITH AWMA THAT EACH INDIVIDUAL PROPERTY TAXPAYER W©ULD PAY ONLY $10080 ANNUALLY?
 THE L.B.T.A. REITERATES ITS OPINIONS THAT THE SEWERAGE OUTFALL AS PROPOSED BY  AWMA WILL SURELY
 CREATE MORE IRREVERSIBLE PROBLEMS BY THEIR OCEAN OUTFALL AFTER THE POPULATION  EXPANSION REACHES
 FULL CAPACITIES HERE.  WE ALSO FEEL THAT DUE TO THIS CITY'S ESTABLISHED OPPOSITION TO  POPULATION
 EXPANSION WITHIN LACUNA BEACH AND ITS SPHERE OF INFLUENCE, THAT THE AWMA JOINT POWERS
 AGREEMENTS ARE A CONFLICT OF INTEREST WITH THEIR PREVIOUS ENVIRONMENTAL PROGRAMS & GENERAL PLANS.

. PAGE .6-1. . UNA'VOlDX-BgE_'IlWCIfS;'pF THE PROPOSED PROJECTi   OPERATIONAL IMPACTS INCLUDE AN INCREASED
 UTILIZATION OF'WATER THROUGH "THE DIRECT USE OF THE .VATER SUPPLY, 
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      L.3.T.A.  RSSPONSESi  PAGE  6-li
      THIS STATEMENT  IS ABSOLUTELY TRUEl  THE  UNAVOIDABLE EFFLUENTS  & POLLUTANTS ENTERING THE 3SA,
      SERENELY  REFERRED AS THE  MARINE  ENVIRONMENT,  WILL  ELIMINATE THE UNDER SEA PLANT LIFE AS WELL
      AS THE ECOLOGY  BALANCES,  FISH, AND  WATER  PURIFICATION  REGENERATION  NATURALLY.   CONTINUOUS
      MAJOR DISCHARGES CAN POLLUTE MILES  OF OUR OCEAN  CURRENTS,  THEREBY CREATING IRREVERSIBLE DAMAGE
      ULTIMATELY TO OUR COASTAL WATERS.   DRAINAGE FROM THE VALUABLE WATERSHED WHICH WILL 3S COVERED
      WITH PAVEMENT SOON,  WILL  PRESENT A  SECONDARY PROBLEM ON THE SURFACE TO THE FLOOD CHANNELS
      THROUGH THE ALISO VALLEY.   OIL,  GREASE  &  OTHER COMMON  WASTES  PERTINENT TO TRAFFIC i VEHICLES
      WILL SOON POLLUTE THE ENTIRE ALISC  VALLEY.   RECLAMATION OF SUCH WATER WOULD BE USELESS AND
      THEREBY INCREASE A SECONDARY PURIFICATION PROGRAM  OF GREATER  MAGNITUDE EVENTUALLY TO AVOID
      THESE DISASTERS.

      PAGE 7-1  CONSTRUCTIONi- THE PROJECT WILL  ACCOMMODATE & ENCOURAGE LAND USE CHANGES IN THE
      AGRICULTURAL OPEN SPACE AREAS  OF THE REGION.  THERE WILL BE A REDUCTION OF OPEN SPACE AREAS OF
      THE REGION.  THERE WILL BE  A REDUCTION  OF OPEN SPACE DUE TO DIRECT  & INDIRECT PROJECT IM^fcCTS.
      THE REGIONAL TREATMENT PLANT WILL OCCUPY  APPROXIMATELY 12 ACRES OF  LAND.  _THS CHANGE OF AGRI-
      CULTURAL  LAND TO RESIDENTIAL OR  INDUSTRIAL USE WILL CAUSE A MAJOR REDUCTION IN OPEN SPACE.
      1/ILDLIFS  WILL DSGRSASS IN NUMBERS & SOME  SPECIES REQUIRING LARGE AREAS OF CONTINUOUS OPEN SPACE
      WILL DISAPPEAR.

      L.3.T.A.  RESPONSES!
vo     THIS STATEMENT  IS ABSOLUTELY TRUEl   WE  ASK AWMA. THE SPA.  AND HUD NOW;  IS THIS ENTIRE PROJECT
L     V-/ORTH THESE g3SMAN5NT NfiCATI VS! 5N VI AONfcS'NT'AL IMPACTS TO THIS  BEAUTIFUL ALISC VALLEY?  ARE THE""
w    "^ESTIMATED LOSSES OF  WILDLIFE FOR THIS PROJECT WORTH THE RISKS INVOLVED?  THE L.B.T.A. HARDLY
      AGREES WITH SUCH PHILOSOPHY WHICH IS ESTIMATED COULD OBLITERATE THE NATURAL RESOURCES CF ALI3~C
     "VALLEY FOREVER.  MUCH OF  THIS  OPEN  SPACE  HAS ALREADY BEEN CONSUMED. THE WILD ANIMALS HAVE BEEN
      DRIVEN FROM THEIR GROUNDS BY MAJOR  DEVELOPMENT IN  THE SADDLEBACK VALLEY AREAS ALREADY.  THSRS
      /ARE MANY  HIGH-DENSITY DEVELOPMENTS  ALREADY WITHIN  THIS AREA NOT'RENTED!  WHY NUJSTTHIS NATURAL
      ^BEAUTY BE DESTROYED  NUW BY  TMSSa UtN^KSUEJJENTED PROGRAMS FOR THE SAKS OF GAINING FEDERAL & STTTS^
      IP RANTS?                         ~~"'

      PAGB 7-2  OPERATIONi   THE  CONTINUED  MAINTENANCE & OPERATION OF THE PROPOSED REGIONAL FACILITIES
      WILL REQUIRE THE ."CONSUMPTION OF  ENERGY  9237 x 106  KILOWATT HOURS) IN ORDER TO MEET THE WA3TE-
      WATER RECLAMATION REQUIREMENTS OF THE REGIONAL WATER QUALITY  CONTROL BOARDS.  THIS COMMITTMENT
      OF ENERGY CONSUMPTION IS  A  TRADEOFF FOR THE LONG TERM  MAINTENANCE OF GROWTH IN THE AREA.

      L.B.T.A.  RESPONSES!
      BECAUSE THERE IS SUCH A CRITICAL ENERGY SHORTAGE NOW & PREDICTED TO REMAIN, THERE IS HARDLY ANY
      JUSTIFICATION TO ADD TO THESE  SHORTAGES THROUGH  THIS QUESTIONABLE,  SPECULATIVE ADVENTURE BY
      AWMA TO PROVIDE A NEW HUD CITY AROUND THE GSA FACILITY SIMPLY FOR EXPERIMENTATION PURPOSES 1

      PAGE 7-3,  INFLUENCES OF THE PROPOSED PROJECT UPON  GROWTH IN THE AWMA AREAi  THE PATTERN OF
      URBANIZATION USUALLY MOVES  OUTWARD  FROM THE BORDER BETWEEN TH3 URSIN AND RURAL LANDSCAPE WHERE
      IT BECOMES ECONOMICALLY ADVANTAGEOUS TO CONTINUE DEVELOPMENT. ETC.
      L.B.T.A.  RESPONSES!

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PAGE 20.

L.B.T.A.  RESPONSES CONTINUEDi
THE CITY OF LAGUNA BEACH HAS OPPOSED URBAN  SPRAWL AS  INDICATIVE BY THEIR NO-GROWTH POLICIES.
THE L.B.T.A. WOULD APPRECIATE A REPORT SHOWING  WHEN THIS  CITY APPROVED OF THESE URBAN SPRAWL
PLANS THROUGH AWMA?

PAGE 7-4, 7-5» IMPACTS ON LAND VALUE THE PROPOSED PROJECT WILL CREATE IMPACTS ON LAND VALUES
THROUGHOUT THE REGION IN MUCH THE SAME WAY  THAT TRANSPORTATION CORRIDORS DO.
THE CITY OF LAGUNA WILL £fi NOT BE AFFECTED  BY THE PROPOSED PROJECT IN TERMS OF EITHER INDUCED
POPULATION GROWTH OR THE RELATIVE INCREASE  IN LAND VALUES.  LAGUNA BEACH HAS  PLACED A POPULATION
LIMIT OF 20,000 RESIDENTS AND THEREFORE WILL ONLY NEED AN UPGRADED WASTEWATER SYSTEM TO MEET
THE HEALTH STANDARDS.

L.B.T.A.  RESPONSES!
THE IMPACTS CONCERNING THE PROPERTY OWNERS  OF LAGUNA  BEACH ARE THE EXORBITANT, UNREALISTIC
SEWER SERVICE SUR-TAXES PLACED UPON EACH OF THE APPROXIMATELY 6,000 PROPERTY OWNERS.  THIS
SEWER TAX WILL ULTIMATE LOWER THE VALUES OF PROPERTIES ALONG THIS COASTAL REGIONAL AND WITH
INCREASED TAXATION COULD BANKRUPT EACH PROPERTY OWNER WITHIN THE LOW AND MEDIUM INCOME BRACKETS!
IS THIS THE PROPOSED GOAL DESIGNED BY THE AWMA-EPA-HUD SEWERAGE TREATMENT PROGRAM?

PAGE 8-1 IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCESt THE MAJOR IRREVERSIBLE
ENVIRONMENTAL CHANGES WILL BE INDIRECT.  THE URBANIZATION OF THE AWMA AREA WILL BE AN IRREVER-
SIBLS ENVIRONMENTAL CHANGE THAT WILL INSURE A LONG TERM COMMITMENT TO PLANNED COMMUNITIES SUCH
AS THE SOUTH COAST, LAGUNA-ALISO AND NORTHERN EL TORO PLANNING RESERVE AREAS.

L.B.T.A.  RESPONSES!
THIS IS AN UNDERSTATEMENT IN VIEW OF PRECEEDING FACTS PRESENTED THROUGHOUT THIS E.I.S.I
THE ENERGY COMMITMENTS OF SUCH A PROPOSED PROJECT ARE IRRETRIEVABLE USEAGE OF THESE VITAL
RESOURCES PLUS THE LAND INNUNDATION WHICH SHOULD BE PRESERVED FOR FUTURE FOOD NEEDS FOR THE
PEOPLE.

PAGE 8-2  WATER RESOURCESi THE COMMITMENT OF CONSTRUCTING THE WASTEWATER FACILITIES RESULTS IN
AN IRREVERSIBLE USE OF THE MARINE ENVIRONMENT FOR DILUTION & DISPERSION OF EFFLUENT & THE USE
OF THE LAND FOR IRRIGATION & GROUNDWATER RECHARGE. THIS  COMMITMENT RESULTS IN AN IRREVERSIBLE
IMPACT UPON THE EXISTING MARINE WATER AND GROUNDWAT2R SYSTEMS.

PAGES 8-3 THRU 9-1, SCIENTIFIC RESOURCES TO PUBLIC INPUTt UNIQUE AND/OR ENDANGERED HABITAT
TYPES SHOULD BE RECOGNIZED & CONSERVED EARLY IN THE PLANNING PROCESS BEFORE ADDITIONAL GROWTH
IN THE AWMA AREA OCCURS.
CHRONOLOGY OF EVENTS LISTED»

L.B.T.A.  RESPONSESt
WITH THESE FINAL ARGUMENTS WHY SUCH A SERIOUS WASTEWATER-SSWSRAGE TREATMENT FACILITY SHOULD BE-
REGARDED, PLUS PUBLIC INPUT, OF WHICH THE L.B.T.A. HAS PARTICIPATED, WE CONCLUDE OUR EXAMINATION
OF THIS LENGTHY ENVIRONMENTAL IMPACT STATEMENT  FOR THE AWMA. WITH THE SUMMARY STATEMENTS!
1.  THE CITY OF LAGUNA^BEACH HAS MAINTAINED A NO-GROWTH POLICY NOT ONLY WITHIN THESE CITY LIMITS

                              II«Y"••!,'•»?!•• OJWTEW TfttfTS

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        PAGE  21.

        CONCLUSIONSt

        THE TAXPAYERS ARE ASKING AWMA, SPA AND HUD THESE QUESTIONS:

        1.  HOW MUCH FEDERAL AND STATE MONEY HAS THE CITY OF LAGUNA 3EACH RECEIVED TO DATE?

        2.  HOW MUCH FEDERAL AND STATE MONEY WILL THE CITY OF LAGUNA 3EACH RECEIVE ANNUALLY?

        3,  HOW MUCH FEDERAL AND STATS MONEY WILL THE CITY OF LAGUNA 3EACH RECEIVE FOR 3SWSR  SYSTEMS?

        ^.  HOW MUCH FEDERAL AND STATE MONEY HAS THE CITY OF LAGUNA BEACH RECEIVED FOR SEWER  SYSTEMS?

        5.  HOW MUCH MONEY DOES THE FEDERAL/AND OR/ STATE REQUIRE THE CITY OF LAGUNA 3SACH TO PAY
           TOWARD THE AWMA SEWER SYSTEMS?  ANNUALLY?

        6.  HOW MUCH MONEY DOES THE FEDERAL/AND OR/STATE REQUIRE THE CITY OF LAGUNA 3SACH TO  CHARGE
           EACH HOUSEHOLD FOR THEIR SEWER SERVICES?

        7.  WHAT IS THE PERCENTAGE WHICH THE CITY OF LAGUNA BEACH IS REQUIRED TO PAY FOR SEWER SYSTEMS
           AS SUPPLIED NOW BY THE ALISO WATER MANAGEMENT AGENCY?
vo
£       THE LAGUNA BEACH TAXPAYERS' ASSOC. INC. WISHES TO REQUEST A DIRECT REPLY WITHIN 30 DAYS TO
01       THE QUESTIONS ABOVE STATED TO THE AWMA.

        THIS  ASSOCIATION FURTHER WISHES TO THANK YOU FOR THE CONCISE ENVIRONMENTAL I.VIPACT STATEMENTS
        WHICH HAVE BEEN COMPILED FOR PUBLIC RESPONSES.  WE TRUST THAT OUR RESPONSES WILL BE BENEFICIAL
        ALSO  THAT OUR QUESTIONS WILL IN TURN BE ANSWERED THROUGH AN ADDENDUM FROM THE AWMA.

        THIS  REPORT WAS COMPILED AND THE RESPONSES HAVE BEEN SUPPLIED BY SEVERAL PROFESSIONALS
        AND MEMBERS OF THE LAGUNA BEACH TAXPAYERS' ASSOC. INC. IN ORDER THAT THE L.3.T.A. EXECUTIVE
        SECRETARY, MARIE WARE MAYER COULD COMPILE AN ADEQUATE RESPONSE TO THIS SPA, FEDERAL
        ENVIRONMENTAL IMPACT STATEMENT COMPILATION.
       L.3.T.A. EXECUTIVE SECR S^RY^/RESPONDENT

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                         SUMMARY COMMENTS

                 Laguna  Beach Taxpayer's Association
                          March 14, 1975

 1.    There  is a  joint action by AWMA-EPA-HUD to construct a new com-
 munity within this City's sphere of influence.

 R-l.  At  this time there is no firm plan by AWMA, EPA or HUD to con-
 struct a  new community  in the AWMA area.  Refer to Moulton Ranch
 Plan  approved by the County which was financed privately.  HUD is
 considering in general  terms some sort of low cost housing (objection
 should be directed to HUD).  This new community concept was given
 consideration in the EIS as a method to mitigate the air quality
 impact.

 2.    The  Laguna  Beach Taxpayer's Association, Inc., was not selected
 to receive  this  notification and compilation of environmental impact
 statements.  We  wish to know why.

 R-2.  Attempts were made to make the EIS distribution list as compre-
 hensive as  possible.  Some organizations were inadvertently missed.

 3.   A sewer bond of $500,000 which would accommodate a population
 of approximately 30,000 population for adequate sewerage disposal
 systems,  has not yet been retired.

 R-3.  The City of Laguna Beach's treatment plant is a substandard
 treatment plant  and must be upgraded or the City will be subject
 to expensive fines (See Table 1-2 for comparison of treatment plant
 performance with requirements).

 4.   Is it legal for this City to adopt general plan elements if
 they have adverse environmental impacts?

 R-4.  The resolution of this issue rests with the local  government.

 5.  An expanded sewer-water treatment system would not alleviate
problems, but create new ones.   Air and watershed problems would
result.

 R-5.  See Response 3.   The EPA has attempted to integrate the air
and water problems by proposing mitigation  measures.

6.   The adverse environmental  impacts upon our beautiful Aliso green-
belts and Aliso Creek and Aliso Beach will  permanently be eroded
under such planning.

R-6.  Soil erosion and runoff will  be controlled through such programs
as re-seeding.
                                9-126

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 7.   Your map concerning regional locations under EPA Federal Regional
 Council IX, and the FRC IX, the AWMA are questionable constitutional
 states which have been forming within the states.

 R-7.  These are not states but administrative agencies subject to
 the authority of the State of California.

 8.   Added sewerage disposal into the ocean, added population facil-
 ities through the AWMA wastewater treatment systems, will only create
 more burdensome problems upon local conditions as prevail according
 to the reference given in Table 1-1.  There will be no appreciable
 advantages whatsoever to increase sewerage-water treatment facilities
 for increased population programs in this region.

 R-8.  Section 3.2.1.2.1, Ocean Discharge Impacts, discusses the rami-
 fications of ocean disposal of liquid wastes produced within the
 AWMA region.  Table 3-1 and 3-2 and Exhibit 3-14 describe the projected
 mass emission and dilution characteristics of ocean discharge.  These
 factors not only meet but exceed the existing requirements set by
 the State Water Quality Control Board and the State Plan for the
 ocean waters of California.  Thus the characteristic pollution problems
 related to the existing ocean disposal of primary or low grade secondary
 treated effluent will be reduced substantially.

 9.   At the present time, without any improvements from AWMA, and
 while this city has joined AWMA, this city is asking the property
 owners for an increase of $6.33 per month per unit.  The LBTA feels
 that there is no justification for these sur-taxes for our sewerage
 services when our property taxes have increased at least 35% and
 in some cases up to 150% of the assessed valuations.  We have not
 been permitted due process of law, public hearings, or responses
 to our statements through letters regarding the sewer and trash service
 exorbitant increases.

 R-9.  The Federal Water Pollution Act Amendment of 1972 required
 that users of sewer systems pay for services rendered.  Property
 taxes are not allowable to pay for these user charges although they
 can be used for initial capital costs.  Federal and State grants
 will defray about 80% of these costs.  The past increases in property
 taxes remain a local issue.

 If AWMA does not develop a solution to waste water management problems
 of the region, the City of Laguna Beach will be required to provide
 a solution to their local water problems, at even a greater capital
 cost to the residents.   In addition, many public hearings were held
 to discuss these issues.

 20.  The LBTA believes  that the City of Laguna Beach must remain
 consistent to their avowed open space, no-growth, greenbelt, low
profile land development concepts, and their approved population
 limitation for 20,000 maximum within these areas now.   Property
                               9-127

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 devaluations have occurred now with  this city's downzoning ordinances;
 however no property  taxes  have been  reduced.  Instead, property taxes
 and utilities,  sewer and trash charges have all been increased due
 to the proposed land-use schemes pending with AWMA-EPA-HUD.

 R-10.   See Response  #1.  Congress  has determined  (PL 92-500) that
 protection of water  resources  warrants additional tax revenues.

 11.  AWMA will  certainly create additional taxations upon local govern-
 ments.

 R-ll.   Bringing Laguna Beach's sewerage system up to the required
 levels  of performance will involve substantial increases in costs.
 Regionalization of services within AWMA will keep these increases
 to a minimum.

 12.  We question the planning  for  continued population expansion
 on a large scale,  while  urban  sprawl has been the prime condition
 which is strongly  opposed  by such  environment protection agencies.

 R-12.   See Chapter 4 in  the Draft  EIS.  Controlling development is
 the  responsibility of the  local government; however, the EPA will
 attempt to mitigate  impacts which  arise from development.

 15.  Even the imminent Doctor Richter of Cal Tech Laboratories of
 Pasadena does not  have all the reasons, analysis, causes and deter-
 minations concerning seismic quakes and pertinent data.  It is therefore
 unreasonable we  feel  to  give any great credits to speculative analysis
 in this field of sciences.

 R-13.   Section  2.3.6  outlines the  geologic structure within the AWMA
 area and the major Southern California fault zones which affect it.

 14.  Climatic conditions concern everyone in Southern California.
 The air quality is conditional primarily due to hydrogen bomb testing
 in the  Nevada proving grounds.  In basins such as in Southern California,
 where climatic conditions are mild and winds do not dissipate these
 nuclear radiation particles quickly,  the secondary problems of car
 emissions poses a  threat to our air and water qualities.   After nuclear
 test either at U.S. AF Base at Vandenburg or in Nevada,  especially
 when our air is still, we can depend upon several days of intensive
 smog and air pollution conditions.

 R-14.   There is no known relationship between nuclear testing and
 smog in Southern California.   The effects of these testings are not
within  the scope of the EIS and are not applicable to the primary
 or secondary impacts of the project being considered.

 15.  Additional automobiles,  sewerage increases,  refuse  increases,
school increases, general relative  collation of all  factors involved
with such environmental changes,  will surely not  alleviate the  present
adversed environmental air and water  conditions prevailing.
                                9-128

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 R-15.  See Response #12.

 16.  How can it be determined that by increasing facilities for AWMA
 projects in the future that seismic safety  (air and water quality)
 problems will not be increased, rather than be solved under the terms
 given in this environmental impact study?

 R-16.  Air quality will suffer from developments, but water quality
 will benefit from project - refer to mass emissions in the EIS.

 17.  It has been determined by science that a certain amount of vege-
 tation is mandatory to the survival of mankind.  With the planned
 increases of sewerage disposals, wastewater disposals, encroachments
 upon prime farming lands within the watershed areas, plus alleviation
 of the certain vital vegetation characteristics within these lands,
 how can AWMA maintain a position that their super-agency can solve
 our survival?

 R-17.  The bulk of the state remains vegetated and large open space
 areas will be retained within AWMA.  The AWMA project is intended
 only to resolve water quality problems.

 18.  The endangered habitat types analyzed from page 2-42 chart will
 certainly suffer permanent damages under present planning by AWMA.

 R-18.  The AWMA project itself will have negligible primary impacts
 upon terrestrial biological resources.  Population growth and housing
 developments will significantly affect these resources.   See Section
 8.4.3 for suggestions for minimizing impact.       ^

 19.  The marine biology already has decreased due to pollution in our
     local waters.  Fish are contaminated and unfit to eat now.  What
     will happen by the year 2000 with more population.

 19.  Refer to R-8.

 20.  Why should local property owners provide for public facilities
 which will ultimately cost us our life's investments in  land and
 finances?
                                                                   \
 R-20.  Refer to R-3, R-9, and R-10.

 21.  Why should the City of Laguna Beach downzone our properties
 discriminately now, while approving of AWMA-EPA-HUD programs incon-
 sistent to local approval?

 R-21.  This topic is not within the scope of this EIS.

 22.  There is a very inadequate assessment of property values and
 assessment value trends within Laguna Beach.  This section of the
EIS has sadly skipped many important factors concerned with local
property valuations.
                               9-129

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 R-22.   Laguna  Beach  is  not expected to develop rapidly because of
 the City's  land  use  and growth policies; however, the remainder of
 AWMA is projected  for rapid  growth.  The orientation of the invest-
 igation of  assessed  values centered on the causes and secondary impacts
 of growth,  primarily in the  Aliso Valley.

 23.  AWMA seems  to indicate  that Laguna' s sewer systems are inadequate.
 The Laguna  Beach Taxpayers'  Association Inc. believes this is merely
 an assumption  to force  this  city into this federal program in order
 to pay for  increases in the  proposals for populace in the future.

 R-23.   Refer to  R-3, R-9, and R-10.

 24.  The citizens  of Laguna  Beach are currently paying for a tax
 bond which  will  expire  in 1984.  This land was supposed to have ade-
 quately provided for a  population of double the existing. populace.
 Why do we need additional sewer services over and above these.

 R-24.   Refer to  R^-3.  Congress requires that those who benefit pay
 for the sewerage service.

 25.  Plans  to  move vast numbers of non-Orange County residents into
 our area are the ingredients for a very negative environmental impact
 in the future.   Even the ethnics do not want to be forced to integrate.
 They are a  proud people as any other people.  They do not deserve
 to be  exploited  anymore than we deserve to be exploited to pay for
 this.

 R-25.   The  relative  number of "ethnic" groups are so small as to
 not play a  significant  role  in the County or AWMA.

 26.  The conclusions related to the courses of growth on page 4-
 9  are not specific.  Many questions are possible with such a broad
 statement.  The  total national economic picture has not been considered
 at  this  time or  in the  future.

 R-26.  Only generalized statements are possible.   It is not possible
 to  predict economic  trends in Orange County and the U.S.
27.  To continue response that local government ultimately have
plete' control of land use decisions is also erroneous.  The SCAG
and California Coastal Zone Commission, the O.C. Supervisors, the
LAFC, the federal and state governments now have final controls over
our land use decisions.

R-27.  Local government includes SCAG and the Coastal  Zone Commission.
Only counties and cities can approve development plans, state and
federal governments have no veto authority.

28.  What portion of the privately owned Aliso Valley  are lands currently
under the Williamson Act and agricultural preserve programs?  While
some Irvine Company lands are under agri-preserve status, the AWMA
                                9-130

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proposed watershed lands within Aliso Valley have not been mentioned
within this EIS.  What is their status?

R-28.  Within the Aliso Creek watershed, there are only 114.35 acres
in agricultural preserve status.  Notice of non-renewal was filed
in 1971 for 32.57 acres.  A request for cancellation is also on file
for this acreage.
                                                           «
29.  The statement on page 13 contradicts Table 1-1 which mentions
that the Laguna Beach Sewerage Disposal system are inadequate, outdated
facilities with poor quality effluent.  Which is correct?

R-29.  These statements refer to sewerlines as opposed to treatment
plants.  Examine Section 4.7 and this becomes clear.

30.  Since development must provide adequately for new utilities
and public facilities more consideration should have been given to
the environmental impact in the EIS.

R-30.  Planning is a local responsibility.  EPA's responsibility is
to review and determine the role of a sewerage project.

31.  Formal use planning or land development states that local govern-
ments ultimately have 'complete' control of land use decisions.
This statement contradicts the above statement made under regulatory
programs, and my statement previously that SCAG, the Coastal Zone
Commission, LAFC, the Orange County Board of Supervisors, etc., all
have absolute controls over local planning and construction.

R-31.  All of these agencies have some effect on land use.  Local
governments, (including the Coastal Zone Commission) have the most
direct effect.

32.  Why must all property taxpayers subsidize experimental programs
such as this AWMA project, simply to provide federal and state grants
to be squandered over more of the same unworkable new HUD exploitations?

R-32.  Refer to R-l.

33.  Septic tanks were always used prior to the sewer treatment project
in Laguna Beach.  The ocean was never polluted, and fish were edible
then. The watershed deterrants from additional roads, paved shopping
centers, freeways, sidewalks, etc., will in themselves pose a major
hazard to the ocean's environmental balance at Aliso Creek.

R-33.  Refer to secondary water impacts in Section 4.5.2 and  the
general discussion of septic tanks in Section 4.4.

34.  Instead of taxing farmers into development of their lands, why
not provide tax relief in order to allow them to produce for  the
public's health, safety and welfare?
                               9-131

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 R-34.   The Williamson  Act,  also  known as  the California Land Conserva-
 tion Act of 1965,  is a method  of preserving agricultural land.  The
 Act enables the  County Board of  Supervisors to stabilize taxes on
 agricultural  lands in  return for an owner's guarantee to keep his
 land in agricultural use  for an  agreed-upon length of time.  The
 landowner's participation in this tax relief program is on a voluntary
 basis.

 35.  High density  cluster residential development as proposed in
 the EIS is a  very  incompatible method of  living happily on a permanent
 basis.   Psychologists   have their most complex cases in persons who
 are living or have lived  within  such tight quarters, with many ethnic
 groups  compacted together.

 R-35.   In July,  1974,  the Center for Urban and Regional Studies,
 University of North Carolina,  published the results of a nationwide
 new community survey.   Residents of these new towns, which contain
 a wide  variety of  housing types  and densities, were asked to rate
 their homes,  neighborhoods and quality of life.  Their responses
 were compared to the responses of residents from a less planned,
 "typical"  southern California  residential community.  When asked
 "overall  -  is this a very good place to live?" the survey results
 were:
All Residents
Single-Family Home Residents
Townhouse/rowhouse residents
Apartment residents
Control
Community

  48.3
  56.1
  50.0
  16.7
13 New
Communities

   59.0
   61.3
   60.0
   49.2
36.  When the citizens and taxpayers are subjected to costly items
for the "better way of life," we hardly can be catalogued as opposed
to low or medium cost housing.  That statement is far from the truth
in the AWMA area ... we would appreciate knowing where you obtained
this information to make such a generalized statement?

R-36.  The "generalized statement" is from a survey conducted in
the spring of 1973 by the Center for Urban and Regional Studies of
the University of North Carolina.  Residents of Irvine and Fountain
Valley were asked whether homes for each type of family listed below
would greatly improve, improve, not affect, harm, or greatly harm
their neighborhood.  The following table indicates the proportions
of respondents who said that housing for such families would "greatly
improve," "improve" or "not affect" their neighborhoods:
                                9-132

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                                                            Fountain
                                             Irvine         Valley

Low income  (under $5000/yr) white families   17.5           27.8
Low income  (under $5000/yr) black families   14.9           20.7

Moderate income ($5000-10,000/yr)
                            white families   52.4           54.7
                            black families   45.0           45.2

Low and moderate income families require low and moderate priced
housing.  If the local population is opposed to such housing, they
are, at the very least, indicating that they don't want it in or
near their neighborhoods.

37.  The existing sewerage facilities would continue to provide for
the populace of Laguna Beach.  The expansion of utilities would neces-
sitate the creation of new population demands on local government
and community services.

R-37.  Refer to R-3.

38.  If Alternative 1A and 2F have reduced the AWMA costs $8 million,
how much is the total bill?

R-38.  Refer to the updated discussion in Chapter 3.

39.  Oil, grease, and other common wastes pertinent to traffic and
vehicles will soon pollute the entire Aliso Valley.  Reclamation
of such water would be useless and thereby increase a secondary purifi-
cation program of greater magnitude eventually to avoid these disasters.

R-39.  Refer to Section 4.5.2.  Increased traffic is not expected
to have a significant impact on water quality.

40.  Why must natural beauty be destroyed now by these unprecedented
programs for the sake of gaining federal and state grants?

R-40.  AWMA's purpose is not to obtain federal  and state grants.
AWMA's purpose is to implement a treatment and disposal system which
will eliminate water quality problems and prevent future water quality
problems.  Federal and state grants will ease the burden on local
taxpayers.

41.  There is hardly any justification to add to these energy shortages
by the construction of a regional wastewater management system.

R-41.  The expenses of energy consumption in order to protect water
quality is warranted.
                                9-133

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 42.   When did Laguna Beach approve of plans  for urban sprawl  through
 AffMA?

 R-42.  Urbanization is  occurring  outside  of  Laguna  Beach,  but within
 AWMA.

 43.   The impacts concerning the property  owners of  Laguna  Beach are
 the  exorbitant,  unrealistic sewer service sur-taxes placed upon each
 of the approximately 6,000 property owners.   This sewer  tax will
 ultimately lower the values of properties along this  coastal  region
 and  with increased taxation could bankrupt each property owner within
 the  low and medium income  brackets.   Is this the proposed  goal designed
 by the AWMA-EPA-HUD sewerage program?

 R-43.  The purpose of the  AWMA project is to implement a wastewater
 treatment system and disposal  system which will  eliminate  the existing
 water quality problems  in  the  various systems and prevent  future
 problems.   The cost necessary  to  achieve  this are thought  to  be justi-
 fiable.

 44.   How much federal and  state money has the City  of Laguna  Beach
 received to date?

 R-44.   The "Annual  Report  of Financial Transactions for  Cities of
 California"  from the State Controller's Office  records that during
 the  past seven years, the  City of Laguna  Beach  has  received federal
 and  state grants,  including  revenue  sharing, as  follows:

      Fiscal  Year              Federal                   State







45.
1973-74
1972-73
1971-72
1970-71
1969-70
1968-69
1967-68
How much federal
$205,530
185,438
57,547




and state money will
$510,572
34,545
71,039
190
53,000
63,078
48,959
the City of Laguna Beach
receive annually?
R-45.  Because federal and state revenue programs are highly dynamic,
it is impossible to predict future revenue available to the City
of Laguna Beach from these sources.

46.  How much federal and state money will the City of Laguna Beach
receive for sewer systems?

R-46.  Preliminary figures suggest that the City of Laguna Beach
may contribute $1,150,000 to AWMA and receive $4,130,000 in federal
and state funds.
                               9-134

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47.  How much federal and state money has the City of Laguna Beach
received for sewer systems?

R-47.  According to available figures, since 1971, the City has received
$302,000 in federal and state funds for local sewer facilities.

48.  How much money does the federal and/or state require the City
of Laguna Beach to pay toward the AWMA sewer systems?  Annually?

R-48.  The City's dollar requirement for participation in AWMA has
not yet been finalized.  Preliminary figures indicate that the City's
total share will be approximately $5,280,000.  However, the City
will only finance about 20% ($1,150,000).  Federal and state funds
will be used to finance about 80% of the City's total share.

49.  How much money does the federal and/or state require the City
of Laguna Beach to charge each household for their sewer services?

R-49.  Charges for sewer service are determined by the local agency,
and authorized by the Public Utilities Commission.  Charges are based
on water consumption.

50.  What is the percentage which the City of Laguna Beach is required
to pay for sewer systems as supplied now by the Alisq Water Management
Agency?

R-50.  There are no services presently being supplied to the City
by AWMA.
                               9-135

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Organized Novombor 1947, to eo-oporato in bringing about tho greatest po-5'ble economies, consistent with efficiency, in crapondituros o{ Public Funds.



                P. O. BOX 404          LAGUNA BEACH, CALIFORNIA 92652
                                           March 25„  1975
                                               ToAo PUBLIC STATEMENT
Federal Environmental Impact Statement,,  EIS  issued by the EoP0A
for the AWMA6 Aliso Water Management Ageneys  Sewer & Planned
Community Development in thj/s Aliso Valley»
 Federal  EoPoA0
 Federal  Building„  The  Ziggurat
 2^00 Avila Road
 Laguna   Niguelp  California
 SUBJECT s
 QUESTIONS
          -^ ~ -

 Has the Federal Environmental Protection Agency cdhsidQred the negative
 environmental impact  implications  in this entire E0IoS0 that this planned
 community development0  and  the increases for sewer services0 schools„ public
 utilitieso homes0 polic© &  fire protection facilities0 on these prime farm°
 ing lands will ultimately cause additional air and water pollution and
 contaminate the ocean which is below this valuable watershed area?

 Has the State Attorney  General responded to the EPA for the Laguna Beach
 Taxpayers" Assoc<> Inc0  requests of Feb0  l^p 1975 under the State°s authority
 of Government Codess  12600  through 12612 to investigate this entire EPA
 planned community development and  to protect the valuable environmental :.
 qualities of this prime farming land & the flood plain zone & watershed areas?

 The State Califo Coastal Zone Commission has just released its initial reports
 concerning the General  Plans  for this State and the land-use proposals„
 One of these CoCoZoCo proposals embraces protection of prime farming lands„
 also the prevention of  further "Urban Sprawl0  such as this EPA proJQCt  ,
 proposes0 And to use  existing community  facilities„ severs„ utilities„ etc»
 rather than extend the  population  into urbanization
 Has the Califo Coastal  Zone Commission presented the  Federal Environmental
 Protection Agency and the AWMA with this proposed State Land~Us<§ General Plan?

 Isn't it a California law that a referendum must be presented to the voters
 when such a Federal & State low=income housing community development project
 is planned and to be financed by public  tax funds?

 What is the actual chronological legal history of the Federal Envirnomental
 Protection Agency?
 Doesn't the EoPoAo actually usurp  the authority of other governmental agencies
 such as City.Planning Commissions„  City  Councils„  County planning Commiesions
 and The Board of Supervisors  &  their local responsibilities?

 We will appreciate your prompt  reply to  all of these  questions I
 Thank you
 Sincerely
 MARlE WARE MAYER
 Executive Secretary
 Respondent to this EIS
                                      9-1,36

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                         SUMMARY COMMENTS

                Laguna Beach Taxpayer's Association
                          March 25, 1975

1.   The planned community development will place increased demands
on community services, and will cause loss of prime farming lands,
and create additional air and water pollution.

R-l.  See response #1 to EIS comments to LBTA, March 14, 1975.

2.   Has the State Attorney General contacted the EPA relative  to
the Laguna Beach Taxpayers' Association's request that the Attorney
General investigate the planned community development?

R-2.  NO.

3.   Has the California Coastal Zone Commission presented EPA and
AWMA with the proposed State Land Use General Plan, which seeks to
protect prime farm lands and prevent urban sprawl?

R-3.  The draft EIS was coordinated with the State CCZC.  See Chapter 4
of the EIS.

4.   Does California law require that a referendum be presented to
the voters when a publicly financed low-income housing project  is
planned?

R-4.  Comments regarding California law should be directed to the
Attorney General.

5.   What is EPA's chronological legal history?  Does EPA usurp the
authority of local agencies.

R-5.  EPA was formed by Reorganization Plan #3 of 1970, effective
December 2, 1970.  EPA was formed as a new independent agency from
several functional groups in the Department of the Interior and
other agencies.  EPA's authority extends only to the regulation of
air pollution, water pollution, noise, solid wastes, pesticides,
and radiation.  EPA cooperates with local agencies in regulating
these areas.
                                 9-137

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                                                                 COWM. CrIMTER

THE LAGUNA GREENBELT. INC.                              H.4R  7  jlj  l»6 -'iH 75
               a non-profit corporation Box 1611, Laguna Beach, California, 92652
                                                             March  3,  1975
                 Mr. Frank M. Coviagtaa
                 US 3PA
                 100 California St.
                 Saa Francises, Calif.   94111
Re: Draft EIS •« the Alias
 Water Management Project
                 Dear Mr. Coviagtoa,

                      Our Board is workiag ea aa analysis for yaur hearing  on March  25.
                 We will have a formal Board statement for the hearing.

                      However, at this time, I would like to call your attention to
                 a possible factual error on p. 2-65 regarding the uadergrouad supply
                 ia the Laguaa Caayoa Watershed. Contrary to your statement which
                 allows no underground water supply, I v/ould note the following f acts;
                              1) the wells ia the area supplied the Sown «f Laguna
                                 Beach for fifty (50) years with its water  - uatil
                                 the population approached 3,000 ( around 1925). So,
                                 •ae can claim that there is a basic supply for 3000
                                 people, if flushed and reclaimed.
                              2) there are operating wells in the area now. Harry
                                 Hodges has had two wells on his property in the
                                 Canyon and his neighbor has one.
                 I do not think the local water board, which took over from the old
                 Skidmore Company areund 1926 has been sufficiently regardful of the
                 basic supply in the area. If thay h*d, they v/ould have bought up the
                 entire watershed at thtt t-inz -.Then the laad could have been had for u.
                 vary nominal price.

                      I am enclosing some data in confirmation of the above rr
                                                              fc
                                                           Sinter3ly yours,
                                                                President
                  end: MKLOTutflDUii OF vrATb!R RlSOURCE DATA RiiLHIVAST TO LAGUIIA CAiTCN
                        •VATTiiRSffcJD PR3SSRVATIOX (Dec. 9, 1972)
                                             9-138

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                           SUMMARY COMMENTS

                     Laguna Greenbelt Incorporated
2.   The wells in the area supplied the town of Laguna Beach for fifty
(50) years with its- water - until the population approached  3,000 (around
1925).  There is a basic supply for 3,000 people, if flushed and reclaimed.
There are 3 operating wells in the area now.

R-l.  Section 2.12.2.3  of EIS modified to reflect this comment.  This
doesn't alter the basic conclusion of the EIS since imported water must
still be relied on in the area.
                                  9-139

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 Statement of Jam*a W. Dilley, President of The Laguna Gr'eenbelt
 Fort EPA Hearing, Laguna Miguel, March 25, 1975
                        ;                                             ' '
 From the very inception of this project, we have proceeded on the simple assumption
 that a water project should be for water. YJe have steadily appraised the Aliso Water
 Management Agency's Project in light of this simple assumption.

 1. True Water Conseration, as mandated by the State Law for this Project, necessitates
    the saving of the residual water supply in the two watersheds, the Aliso and Laguna,
    that are encomoassed by this Project. This residual supply supported Laguna Beach
    for fifty years, until 1927 when the population reached 3,000 persons. And yet AYtMA
    has elaborately contrived a project that is based on the destruction of these
    watersheds.

 2»%Full Tiastewater Reclamation, as mandated by the State Law for this Project, neoesaita-
    the best of tertiary systems,! a natural terticry system above and beyond the chemical
    tertiary process*  And yet AKMA has stopped short with a secondary treatment systea
    and we have, been told that a fully tertiary system would necessitate "too much land"
    that would have to be purchased or leased  or coned for the project.

 3. The Laguna Greenbelt,  consisting essentially of these two watersheds,  the Aliso and
    the L&guna,  is absolutely vital for a valid  water project under the  State guidelines.
    The greenbelts around  the European cities  developed as a result of local water boards
    saving their local and  immediate watersheds.  And  yet AY01A has  consistently ignored
    The Laguna Greenbelt and this  simple logic of a water board undertaking to save its
    immediate watersheds with their immediate  water resources  and  water  possibilities.

 4. In fact,  A?'MA has  gone  to great lengths to accomplish the  destruction  of its  local
    watersheds.  The  enormous and grotesque  sewage treatment plant  on  vital  flood  plain
    and. water recharge'land,  the growth inducing  raw  sewage interceptors,  the growth
    inducing  roads,  and  the  whole  overlaid  by  an  enormous  structure of mumbo-jumbo,  are
    all  elaborate and  grotesque  contrivances that can only result  in  the destruction of
    its  own immediate  water  lands.

 5.  More flagrantly yet, ATOIA has  consistently used the Moulton Development  Plan  Map as
    the  Land  Use  Map for the project  and they have  consistently cited the Chapman,  Brandt,
    Phillips,  Reddick  Study  for  the Moulton Ranch  in  their bibliographies. In their
    hearings  of  1973 and 1974, this flagrancy was  steadily called  to  their attention.
    And  yet they  persisted,  even after  official plans' had  been adopted by the county and
    the  city  recognising the Greenbelt.

 6*  As previously pointed out, in our Memorandum of June 10, 1974, they  have not  fulfilled
    theirs committments that kr. Kymla made  for them in behalf of the  feasibility  and
    adequacy  of the project, the definition of watershed planning areas  and  the saving  of
    those- from price escalations. In fact, they have opposed us as we undertook to  save
    the lands in  the interim by toning holes and have appeared against us in county
    toning hearings. (Re: Greenbelt Resolution on A741A, November 6, 1972).

We  appreciate this EPA Report. It has come ailong way in correcting the gross destructionM
 of water resources and '.vater possibilities inherent in the AT11A project. We would hope  •
 that when the final project is matured under' the wise guidance of EPA and for th« benefit
 of the people that the final project would mandate the preservation of  these two vital
watersheds of the Laguna Greenbelt. A water prolect should be for water.
                                          9-140

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                         SUMMARY COMMENTS

                The Laguna Greenbelt, Incorporated

1.   The AWMA project will destroy the residual water supply in the
two watersheds, the Aliso and Laguna, that are encompassed by the
project.  State law mandates the protection of such residual supplies.

R-l.  The project will not destroy the residual water supply, rather
urban growth facilitated by the project will effect runoff quality
and quantity and recharge patterns.  (See amended Section 4.5.2).
It is not felt that these changes are significant.  The EIS has been
amended to include additional information on the ground water of Aliso
and Laguna Canyons.

2.   Tertiary treatment, for full wastewater reclamation, is mandated
by State law.  AWMA proposes only a secondary treatment system.

R-2.  Tertiary treatment is not necessary; in addition, there are problems
with reclaimed water distribution at this time.
                                 9-141

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League of WDmenXfoters of Orange County
          Statement to  EPA rei federal EIS  for Aliso Water Management
          Agency (AWMA)  proposed regional wastewater project,  Mar. 25i
          1975. "by Joan Petty, Planning Chairman

               The League of Women Voters has been active for  some time
          in the field  of water quality.  We are very concerned  by the
          violation of  public health codes  and water quality board regu-
          lations by the South Laguna Sanitary District and Laguna Beach
          ocean outfalls and the potential  nutrient flow from  the Ross-
          moor Sanitation Plant into Newport Bay and seek a remedy for
          these conditions.  The proposed Aliso Water Management Agency's
          regional waste disposal plant does, however,  raise the following
          concerns:

               1.  We are concerned that  AWMA's proposal locates a region-
          al plant in a recreation and open space conservation area.
          Aliso Creek has been designated as a recreational corridor
          stretching from the mountains to  the sea.  Our members have
          been active in the Aliso Creek Study Teams and we are concerned
          that the integrity of this corridor be maintained.   The partiic-
          ular portion  of the corridor chosen for the site is  a rather
          narrow canyon  with steep walls.   It seems doubtful that there
          is adequate width at that location to accommodate the plant
          and the hiking and equestrian trails and bikeways that are
          planned.   The  prospect of an access road to serve the plant
          complicates the problem further.  Are there not other site
          alternatives?
                   EPA's recommended alternative,  1-A,  which does not
          necessitate construction of a regional plant,  would  seem
          preferable.

               2.   Our  second area of concern is that intensification of
          uses in the AWMA area will impact the air quality of the south-
          eastern portion of Orange County.  The secondary impacts of
          deteriorating  air quality which will be  brought about by in-
          creased vehicle miles traveled  are described  well in the EIS.
          We question the workability,  however,  of several of  the pro-
          posed mitigation measures,  especially on a voluntary basis.
          For instance,  the increased bus service  represents a substan-
          tial capital outlay.
                   Administrative means must be found to ensure that
          adequate  and effective mitigation measures are implemented.
          EPA must  impose requirements  upon the local agencies involved
          and set  up  review processes  whereby progress  can be  assessed.

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igueof WDmen\t)ters of Orange
     Statement to EPA re AWMA EIS,  March 25, 1975,  page 2
             A basin-wide air quality maintenance plan and traffic
     control plan must be formulated in order to ensure that no
     further deterioration of air quality is brought  about as a
     result of proposed development.  Development plans should be
     carefully studied for their efforts in reducing  the rate of
     growth of vehicle miles traveled.
             Until such a plan has  been adopted, water and sewer
     service should not be extended  to new areas and  highway con-
     struction in the undeveloped areas should not be permitted.
     Low- and moderate-income housing and mass transit must be
     provided, and cluster residential development should be
     encouraged.

         We are considering, today,  the use of federal funds for
     the relief of a serious violation of state and federal water
     quality standards.  Under no circumstances should the use of
     these funds  be allowed to contribute, directly or indirectly,
     to a problem and subsequent violation of similar air quality
     standards.   We recommend, then,  that the EPA grant funds to
     AWMA only after adequate mechanisms have been set up to re-
     quire local  agencies involved to implement mitigation meas-
     ures as prescribed by EPA.

         Thank you for this opportunity to comment upon this
     proposal.
                              9-143

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                              SUMMARY COMMENTS

                   League of Women Voters of Orange County
1.   Any proposed plan should remedy the potential nutrient flow from Ross-
moor Sanitation Plant into Newport Bay, and the violation of public health
codes and water quality board regulations by the South Laguna Sanitary Dis-
trict and Laguna Beach ocean outfalls.

R-l.  The potential nutrient flow from Rossmoor is not a significant con-
cern.  Refer to page 3-16 of the Draft EIS.

2.   AWMA's proposed regional treatment plant location in a narrow, steep
sided portion of the Aliso Creek recreation corridor would seem to pre-
clude room for planned hiking, equestrian, and biking trails.  Other sites
should be explored.

R-2.  Refer to expanded discussion of sites in Section 3.1.2 and 3.2.2.1.2
of the Draft EIS.

3.   Many of the proposed air quality mitigation measures are based on
voluntary actions, and therefore have questionable workability.  Adminis-
trative means must be found to ensure that air quality mitigation measures
are adequate and effective.

R-3.  Chapter 5.0 of the Final  EIS describes the selected wastewater manage-
ment alternative for AWMA.   As noted in this chapter, the Final Mitigation
Plan for AWMA will be addressed at the  Phase III level  of the total  project.
Sections 5.2.2 and 5.3.3 discusses this subject in detail.
                                     9-144

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     ANT1AGO
                                                                                /I 3
                         EIGHTS
                Property  Owners   Association
                                                       26 March 1975
U. S. Environmental Protection Agency
100 California Street
San Francisco,  California  9U111

    Attn:   Jim McGrath, Environmental Specialist

Dear Mr. McGrath:

    We were unable to attend the public hearing on EIS D-EPA-2U011-CA  for the AWMA
Regional Wastewater Treatment System which was held on 25 March.  We have, however,
had an opportunity to completely read this Draft EIS and wish to  register our com-
ments on this project at this time.   First, we would like to compliment the authors
of this EIS for an excellent job --  having read the EIR prepared  on this project
last year under the direction of AWMA,  there  is no question but what the entire
subject has been more thoroughly evaluated and fairly discussed without the built-in
bias apparent in the first EIR.

    After evaluating the alternatives presented, it is our opinion  that if a Regional
Wastewater Treatment System is needed at this point-in-time, that Alternative 1A slightly
modified,  best meets the desires of  all interested and concerned  entities.  Except
for the location of the proposed Moulton Niguel Treatment Plant ^A  in  the Woods Canyon
area, Alt.  1A seems to be the least  damaging  from an environmental  standpoint, yet
satisfies the requirements to meet the San Diego Regional Water Quality Control Board's
sewage effluent quality requirements.

    We would therefore recommend that EPA consider funding Alternative 1A with reloca-
tion of the MN hA treatment plant (preferably upstream towards the  GSA building)_.
Further, inasmuch as both the City of Laguna Beach and the County Board of Supervisors
have adopted resolutions which indicate their acceptance of instituting land use con-
trols to mitigate air pollution and  achieve air quality standards,  we  would strongly
encourage EPA's influence and advice towards enacting the mitigation measures proposed
in your EIS.   We would encourage representation on this matter at the  Board of Supervi-
sors so that they may realize the seriousness of the situation and  take appropriate action
to achieve adequate land use controls.
                                                 Sincerely,
                                            c_     / /
                                                      ^ <.*<
P.S.
                                           Howard A. Faul
                                           President
Santiago Heights Property Owners Association is comprised of approximately 150
members residing in the East Orange (City of Orange) area in county territory.
We have been actively involved through Supervisor Clark's offAce in countywide
issues and are most interested in the growth of the Moulton Ranch area of Orange
County.
                                       9-145

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                         SUMMARY COMMENTS

           Santiago Heights Property Owners Association

2.   The proposed Wood Canyon treatment plant site as outlined in Alter-
native 1A unmodified is incompatible with the natural environmental
conditions of Aliso Canyon.

R-l.  Alternative 1A has been modified.  The treatment plant is now
proposed to be located adjacent to the GSA facility or at the existing
Moulton Niguel 1A site.
                               9-146

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                                                                                /I 61
                             SIERRA CLUB
                       OFFICE OF THE SOUTHERN CALIFORNIA         ' '     "'•''.'lift
                             COASTAL COORDINATOR
                           2410 Beverly Boulevard, Suite 2         rTf?/)       •  ''/"i
                            Los Angeles, California 90057               '      J    ' J
                                (213)382-5793
                              April  15,  1975
Mr.  Paul  De  Falco,  Jr.
Regional  Administrator
U.S.  ENVIRONMENTAL  PROTECTION AGENCY
Pacific Southwest Region  IX
100  California Street
San  Francisco, California  94111

      RE:  Aliso Water Management Agency,  Regional  Wastewater
          Treatment System;  File No.  D-EPA-24011-CA	

Dear  Mr.  De  Falco:

This  letter  represents the comments of  the Sierra  Club  staff  on  the  Draft
Environmental Impact Statement for the  Aliso Water Management Agency's
Clean Water  grant application, and our  recommendations  as  to  the ultimate
project which should be approved for  Federal funding.

As noted  in  the EIS the AWMA project  area contains important  natural  and
open  space resources that are threatened  by the current population trends
for southern Orange County.  Exhibit  4-1  and 4-10  show  in  graphic form
the trend of suburban sprawl.  Air quality data show the relationship be-
tween development patterns and air pollution.  Auto dependent suburban
development  is rightly singled out as a major contributor  to  air quality
deterioration through the increase in vehicle miles traveled  (VMT).   Al-
ready some health related standards are being exceeded  within the project
area, but the pollution is vastly smaller than the heavily developed  north
western section of Orange County.  We suggest the  primary  reason for  this
healthy air  is the  predominance of low  intensity agriculture  and the  coastal
location with consequent favorable meteorological  conditions.

Given the population distribution and projected increases  in  southern
Orange County, only regulatory action will prevent the  gradual filling-in
between the emerging developments on  former Irvine Ranch properties to
the northwest of AWMA, the El Toro area, and the San Juan  Capistrano  and
San Clemente developments.   Key to this "fill-in"  process  is  the land in
the AWMA and how it is developed, and a key to the development process  is
sewage facility improvement  and the role of the Environmental  Protection
Agency in influencing the regulatory action of other agencies.   Exhibit
4-10  (which we found a useful compilation of various development proposals)
describes "proposed land use" for the AWMA project area.   With the excep-
tion of the beach strip and  two canyons proposed for state acquisition  in
the Irvine Coastal  Project,  the proposed land use  pattern  shows  a full
build-out along the coastline, significant build-out in the Moulton-
Niguel area, and a continuation of the rather intense development of  El Toro.
Public parks, steep slopes,  and generally inferior building sites on  rug-
ged terrain will  be all  that remains of a once significant open  space and
                                  9-147

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 MR.  PAUL DE FALCO, JR
 April  15, 1975                                                 Page Two
 recreational  resource.   Although the EIS does a  reasonable job of asses-
 sing the contribution of sewerage facilities to  growth  and development,
 the consequences,  in  terms  of air quality,  land  use,  recreational  areas
 lost, and loss of  open  space, are only to be inferred from the various ex-
 hibits in section  4.   Notwithstanding the failure  to  make such impacts ex-
 plicit,  the implication is  clear—unless checked Orange County, and  the
 region,  will  lose  most  of its significant coastal  related open space.  !_/

 We view  this  situation  as a tragic,  and unnecessary,  loss.   Not only will
 such development destroy much of the ambience sought  by residents, but it
 will  lead to  more  traffic problems,  which in turn  must  be solved by  free-
 ways (rapid transit  is  generally not feasible to serve  less  dense  suburban
 areas) which  will  in  themselves  bring further pressure,  either for second
 generation higher  intensity development,  or  for  further "fill-in"  of re-
 maining  parcels.   Projecting public  recreation areas  vs.  expected  population
 one finds a dirth  in  park land by Orange  County's  own standard in  the south
 Orange County region, and this does  not take into  account the  loss to in-
 land  residents who may  wish to enjoy the  coastal values  for  which  the Laguna
 Beach area is famed.

 We do not believe  the Environmental  Protection Agency has the  option to
 watch as  a disinterested  observer as the  environment  is  thus degraded.
 Reading the policy of Congress in the National Environmental Policy  Act  of
 1969  directing all agencies  to "utilize a systematic, interdisciplinary
 approach  which will insure  the integrated use of the  natural and social
 sciences  and  the environmental design  arts in planning  and in  decision-
 making which  may have an  impact  on man's  environment" in  conjunction with
 the  policy of the  Federal Water  Pollution Control  Act Amendments of  1972
 that:  "it is  the  national  policy that  areawide  waste treatment manage-
 ment  planning  processes be  developed  and  implemented  to  assure  adequate
 control of sources of pollutants  in  each  State"  it is clear  that Congress
 intended  the  EPA to administer its Clean  Water grant  program consistent  with
 the environmental  goals of  NEPA  and  other statutes.

 An even more  immediate  concern to  the  Environmental Protection Agency should
 be the eventual impact  of the  AWMA project area  developments upon the at-
 tainment  of health related  air quality  standards in the  South Coast Air  Basin.
 The EIS concludes  that  traffic increases, with consequent increases  in air
 pollution, will occur with  the expected growth in  the AWMA area that would
 not occur  if  that  growth occurred elsewhere where automobiles are used less.
 Indeed, the conclusion of the  EIS  is  that ambient air quality will degraded
 so as to  constitute a "major long-term  adverse effect"  (p. 7-4).
     ]_/  We find the treatment of open space resources, recreation, and the
aesthetic qualities of the region cavalier in the extreem.  To say that with
40-50 percent of open space permanently removed from this region as a result
of AWMA area development (4-22), and then to conclude that the only long-term
adverse impact is air pollution (7-4) seems to equate all land uses as of
equal environmental and ecological value, a premise that is patently unsupport-
able, and for which the only justification in the EIS is a conclusionary phrase
on page 7-4 that the additional population will live in a relatively better


                                   9-148

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MR. PAUL DE FALCO, JR
April  15, 1975                                                 Page Three
Combining the Environmental Protection Agency's obligations under NEPA,
the Clean Air Amendments of 1972, and the Federal Water Pollution Control
Act Amendments of 1972, we believe significant changes must be made to
the recommended project alternative, in fact, neither of the two recom-
mended alternatives is adequate.

We support the development of a regional wastewater management system that
emphasizes reclamation of wastewater, sized for a population total in the
AWMA area that will be distributed in such a manner as not to violate the
health related standards for air quality, and consistent with the adopted
"Intensity of Development" policies of the South Coast Regional Commission
(the agency created by the California Coastal Zone Conservation Act of 1972
to formulate regional coastal zone.(i.e., five miles inland or to the
highest point of the nearest coastal mountain range) planning policies).

None of the alternatives exactly addresses these concerns.  The Reclamation
option, Alternative 3C, is still sized for a population between 170,000 and
250,000.  Based upon the Southern California Association of Governments
series E-0 projections, which were adopted as an interim guide by the South
Coast Regional Commission, the year 2000 wastewater flow would be about 20
MGD rather than the 29 MGD total sized capacity for Alternative 2E.  This
lower capacity figure is much more in keeping with the subregional recom-
mendations of the South Coast Regional Commission (Irvine and Laguna Area
subregions 11 and 12, see South Coast Regional Commission, Intensity of
Development Element,  pp. 49-51, adopted January 6, 1975).

Even if the capacity is scaled down, as we recommend to a maximum of 20
MGD, and the reclamation option is chosen, there will still remain the
question of controlling development, that will under series E-0 levels
by 1985 exceed health related standards for hydrocarbons and oxides of
nitrogen (p. 7-4).  Therefore, the EPA should implement option 4.7.2,
modified both as to reclamation and ultimate size as recommended above,
so that any grant would be expressly conditioned upon an agreement by
the applicant to implement mitigation measures within their legal  authority.
Nonextension of water and sewer services until the Air Quality Management
Plan indicates that this would be consistent with the strategy to achieve
health related air quality standards should be required of the applicant,
with a continuing review by the EPA so as to ensure compliance with such
an agreement.  In effect what is suggested is the implementation of both
options 4.7.2 (modified for size and reclamation) and option 4.7.2 which
is aimed at using sizing as the only growth restraint.
                                                           *
This recommended option would have a marginal  increase in energy usage,
although this is mitigated by the beneficial  aspects of concentrating
development and thus partially offsetting the energy usage.  It would also
have a higher capital  cost than other options.  The combined benefits of
reclamation, controlled growth, and reduced air pollution, we believe clearly
offsets the additional  cost.   Considering that the development proposed will


environment, which is what was said about the initial  Orange County suburban
development.
                                    9-149

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MR. PAUL DE FALCO, JR
April 15, 1975                                                Page Four
aim at the relatively affluent who are drawn by "the  'exclusiveness1 of
the area" (p. 4-9) the additional cost factor is not as important as it
would be if low income developments were proposed.  One of the serious
problems with this EIS is the failure to fully cost out the benefits from
controlled population growth and reclamation, thus it could be that on
balance, even from a cost effectiveness standpoint our recommendations
should be implemented.  But we do not understand the EPA's mandate to be
concerned strictly with the lowest cost options to the exclusion of con-
sideration for EPA's other regulatory functions, i.e., its obligations
under the Clean Air Amendments of 1972.  Begining with the consideration
of the AWMA project, the Agency should implement a policy of denying
Federal clean water grants were secondary effects (such as air pollution,
traffic generation, etc.) would conflict with Federal or State environ-
mental standards.  Prior to the issuance of clean water grants the
applicants should be made to revise their projects or implement mitigation
measures to substantially eliminate the adverse secondary impacts.
                                    Si
                                    JOSEPH TASKER EDMISTON
                                    Southern California
                                    Coastal Coordinator
                                    Sierra Club
cc:  Army Corps of Engineers
     Calif. Coastal Zone Conservation
       Commission
     Calif. State Water Resources
       Control Board
     Environmental Coalition of
       Orange County, Inc.
     Environmental Defense Fund
     Natural Resources Defense Council
     Sierra Club Legal Defense Fund
     South Coast Regional  Commission ;
                                  9-150

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                              SUMMARY COMMENTS

                                 Sierra Club
2.   The secondary impacts on air quality, land use, loss of recreational
areas and open space need to be more fully assessed.  Greater emphasis
should be placed on the loss of significant coastal related open space.

R-l.  Section 4.5.3 of the EIS has been amended to more fully assess these
impacts.

2.   Noen of the alternatives exactly addresses reclamation of wastewater,
sized for a maximum population in AWMA that will be distributed so as to
not violate health standard for air quality and which is consistent with the
adopted policies of the South Coast Regional Commission

R-2.  Please refer to amended Section 4.3.4 in the Final EIS.

3.   The question of controlling development still remains.  We suggest  the
implementation of Option 4.7.2 in Chapter 4.9 of the Draft EIS (modified
for size and reclamation) and using sizing to restrain growth.

R-3.  Please refer to Chapter 5 of the Final EIS.

4.   "A cost/benefit alalization of controlled population growth and recla-
mation should be included in the EIS."

R-4.  Controlled population growth in the South County area would probably
increase population densities in the North County, reduce sewerage costs in
the South County, and reduce air pollution from automobiles to some degree.
Accurate analyses of the exact changes would be extremely difficult, and
the costs would be almost impossible to quantify.

The costs of reclamation raise the cost of the reclaimed water above the
existing potable supplies.   To compete with potable water,  reclaimed water
would need subsidy price support.   To be sure, the cost of existing supplies
is artificially low because of State and Federal  subsidies.   But subsidizing
reclaimed water would simply encourage further inefficient use of water
supplies.

Since about 85% of California's water supply is used for agricultural  use,
conservation practices in agricultural areas hold  more promise than recla-
mation.  Conservation can be encouraged by eliminating or reducing subsidies,
but an overall  analysis of this option is beyond the scope  of this EIS.
                                   9-151

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                            725 Jacon Way
                            Pacific Palisades, California 90272
                            April 16, 1975
Mr. James McGrath
Environmental Protection Agency
100 California Street
San Francisco, California
Dear Mr. McGrath:
     I wish to register certain comments, opinions, and sug-
gestions regarding D/EIS D-EPA-2U011-CA, Aliso Water Management
Agency, Regional Wastewater Treatment System. These statements
are addressed solely to the archaeological element in this report.

     Section 2.9 is inadequate, basically, for lack of a systematic
survey of the area to be affected by the proposed construction.  It
does not fulfill the various requirements for inventorying cultural
resources; see pp. 9-12 of Appendix I of the SCA publication en-
closed.

     Section 3.1*. 2 also fails for lack of recommendations on the
mitigation of anticipated adverse impacts.  This is inevitable, to
some degree, because the survey and inventory have not been com-
pleted; without an adequate data base on which to make environmental
assessment, such conclusions are not possible.  Specific alternatives
which should be addressed in this section include the preservation of
sites, where possible, by the realignment or adjustment of facilities,
or the fully funded excavation of jeopardized sites according to
accepted standards of professional practise.

     Mr. Nelson Leonard, who has performed some preliminary recon-
naissance of certain areas within the AWMA project area, informs me
that there are most assuredly site complexes which are eligible for
the National Register of Historic Places.  They are among the most
important and significant localities remaining extant in Orange
County, and encompass the full range of archaeological resources, both
chronologically and culturally.  I would advise that you obtain a
consultation in accordance with the Advisory Council Procedures set
forth under 36 CFR 800.  You might also want to investigate the ap-
plicability of the Moss-Bennett Bill (Public Law 93-291, 5/21*/7i*),
towards the funding of any required excavations.
Sin
                               cerely
                            Mrs. Roberta 3. Greenwood
                            Chairman, Environmental Policy Committee
                          9-152

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                         SUMMARY COMMENTS

                Society for California Archaeology

1.   A systematic archaeological survey and cultural resource inventory
has not been conducted in the area to be affected by construction.

R-l.  This survey has been conducted and is included in the EIR prepared
specifically for the construction aspects of the AWMA project.

2.   An adequate archaeological data base is needed in order to fully
explore specific alternatives which could preserve or excavate pits.

R-2.  EPA will mitigate by avoidance, or if not possible,  by excavating.
Will arrive at memo of agreement with Advisory Council to  that end.
EPA will continue to coordinate archaeological impacts with the advisory
counsel and will eventually arrive at a memorandum of agreement to
that end.  EPA has rejected the Aliso Creek Canyon Plant site in part
because of archaeological impacts.  All future sites will  carefully
consider and try to avoid archaeological- sites.
                                9-153

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                                                                .  17
    NON-PROFIT ORGANIZATION • BOX 668
    SOUTH LAGUNA, CALIFORNIA 92677


                                                  March 25, 1975

 Environmental  Protection
 Agency
 Region  IX
 100 California Street
 San Francisco, CA  94111

 Attn:   Paul deFalco

 Dear Sirs:

 The Board of Directors of the South Laguna Civic Association has
 reviewed and analyzed the EIR for the AWMA facility for the soujfthern
 Orange  County  region.  While we support the concept of regional
 management of wastewater, we do not feel that this approach should
 necessarily adversely affect our existing resources.

 We cannot support  the construction of a facility within the Aliso
 corridor.  With existing facilities that could more efficiently be
 utilized if upgraded, there is no need to introduce a new faciltiy
 within  a bioligically sensitive area.  The Aliso Creek corridor
 has been recognized by both the County of Orange and the State Coastal
 Commission as  an environmentally significant area.  We find this
 project inconsistent with their planning policies, and therefore
 feel that alternative III-C is a more acceptable proposal.

 We are well aware  that southern Orange County falls within the: critical
 air basin established by the ARE; we are also aware that partially
 due to  this designation the population figures for granting criteria
 for the AWMA project have been revised downward to comply with an
 E-0 projection for this basin.  We agree with this approach.  The
 State Coastal Commission has also conditioned the size of the
 outfall in AWMA's permit to comply with this standard, as well as
 stipulating that population limitations among participants in AWMA
would not be transferable.

We now understand that A'WMA has petitioned SWRCB to revise the
projections upward and to transfer limitations among member districts.
We feel thattno approval should be granted to this project unless
 and until it is definitely determined that it is in full compliance
with all conditions imposed upon it by other agencies.  Specifically,
we believe that this project must comply with the conditions set by
 the State Coastal Commission.
                             9-154

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Along the same line, we would suggest as a policy, that the EPA
granting administrator should not approve a project if the secondary
impacts of that project conflict with federal or state environmental
standards, unless those impacts have been significantly mitigated.

Finally, it seems to us a sad commentary on our ability to utilize
advanced technology that so much is being spent on a system which
is far from innovative and wasteful of our water resources as well
as our energy resources.  We should not have to simply choose
between mediocre alternatives; and as a community that will
probably be most affected by this project (since the outfall and
the treatment plant are within our area) we would hope that a more
serious consideration could be given to a tertiary treatment/reclama-
tion system.
              oard of Directors
                              9-155

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                         SUMMARY COMMENTS

                  South Laguna Civic Association

1.   AWMA should not be permitted to revise its population projections
upward, or to transfer limitations among member districts, nor receive
project approval until it is determined that the project is in full
compliance with all conditions imposed on it by other agencies, es-
pecially the State Coastal Commission.

R-l.  Reference discussion in Chapter IV on size of facilities/Coastal
Commission consistency.

2.   A tertiary treatment/reclamation system should be considered.

R-2.  The draft EIS indicated that there are unresolved public health
questions with reclamation at this time.  This  discussion has  been
revised to indicate relative consistency with future reclamation.
                                9-156

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PUBLIC HEARING - MARCH 25, 1975 - ENVIRONMENTAL PROTECTION AGENCY
ENVIRONMENTAL IMPACT STATEMENT FOR AH SO WATER MANAGEMENT AGENCY PROJECT

Environmental Protection Agency 	there's no need to ask what that means.
Virtually every citizen in the country knows it's ->n agency for the protection
of  the environment.  We believe most citizens also think the EPA is charged
with fostering decisions which reflect the greater concern for the long-range
effects of recommended actions rather than the short-term.

With this in mind, VILLAGE LAGUNA suggests that perhaps there is another alter-
native which has not been considered.  We'll call it "Interim A".  The Laguna
Beach treatment plant is the one plant in the agency which has been declared
inadequate and incapable of being made so.  If this be the case, the Laguna
Beach plant could continue treatment as now, pumping the effluent to 3' South
Liguna plant which was expanded to give the additional treatment necessary to
bring the combined effluent of the two jurisdictions up to current ocean dis-
charge standards.

We suggest sn interim project so that adequate planning can.be realized.  Why
provide for waste treatment for the open range land of the Irvine Ranch Water
District between Lagun'i Beach and Newport Beach before the land use of that
area has been determined?  Why plan for- the construction and expansion of a
pl-int of present day technology in the most sensitive, constricted neck of
Aliso Canyon?  Why not, instead, use "Interim A" so that the land uses may
become known rather than guessed at;  so that the plant sites may be located
so ss not to destroy the terminus of the Aliso Creek Corridor:  so that time
r.ay be bought to accomodate the technology which would allow the "Interim A"
effluent and the effluent from all the other plants in the agency to go to an
eventual new plant for tertiary treatment?

Such a  plant could be located much further inland.  This would mean pumping
some partially treated wat.er inland but this would be no more costly than
pumping fully treated water inland to gain the greatest benefit from agri-
cultural irrigation.  If it is cost-effective to punp water from the Colorado
river and from Northern California it should be reasonable to pump it from
any point in the county to any other point.

Finally, we urge that whatever alternative or modified alternative or com-
bination of alternatives .the EPA recommends for funding, a condition be attach-
ed requiring composting of all sludge, whether at scattered sites or at a
central facility.  Methodology is tried and proven, equipment is available and
it  can be a profit-making venture.   We are sure the EPA realizes that the re-
source, sludge,  is too valuable to be squandered in land-fills or incinerated,
that composting removes any objections to sludge use and that it should be re-
turned to its source, the land.  It's time society  stopped burying its  mess  like
a cat or diluting it in the ocean nnd started cleaning it up instead.
If proper planning is realized the area encompassed by this agency can stay
relatively free of those industries  producing heavy metal pollutants, use of
the wrong kind of water softerers can be controlled and the area can remain   -
an ideal one for tertiary treatment  and sludge recovery.
                                              Wm.  W. Leak, Vice-Chairman
                                              500  Broadway
                                              Laguna Beach, Ca.  92651
                                        9-157

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                          SUMMARY COMMENTS

                           Village Laguna

 1.    EPA should consider the  alternative  of continuing -treatment
 at  the Laguna  Beach plant and pumping effluent  to an  expanded :Sout!h
 Laguna Plant for additional treatment or  bring  effluent  up to ocean
 discharge standards.

 R-l.   In standard secondary treatment,  the  settled sewage  solids
 play  an important role  in .providing  food  and micro-organisms  in -a
 process which  biologically breaks down  pollutants.  'Removal of 5sse!titTle-
 able  solids at the .existing Laguna Beach  STP would prevent efficient
 operation of this process. Further,  this alternative would not 'reiliueve
 the disposal problems at the  upstream treatment plants.

 2.   -An interim project  would allow  time  for adequate planning of
 undeveloped land.   Technological  advances in treatment methods maj
 occur in the meantime.

 R-2.   Extensive planning 'in the AWMA  area has been -done.   Whether
 or  not this is "adequate"  is  ultimately a consideration  for locall
 government.

 3.    If an interim plant were located farther inland,  partially ^treated
 water would need to be pumped inland, but this  would  be  no more •cosfciy
 than pumping fully-treated water  inland.

 R-3.   Correct.   See expanded  discussion on  reclamation in  final OS..

 4.   EPA should condition  the project to  require  composting of add
 sludge.

 R-4.   Final sludge treatment and disposal  methods 'have not been 'deter-
mined because of the siting problem.   Refer to  Chapter 5-of the finra'd
EIS for further discussion.
                                9-158

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                   _
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                ^~J-^-
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                                         KBGION.IX
       j&f-
                              ^
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         -f^—t*

            /
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                       9-159

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                                                        .oZ
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                                                /=^e-JLfO




                                                ,  ,   /
9-160

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                         SUMMARY COMMENTS

                      Mr. and Mrs. Brandwine

1.   The huge plant capacity will encourage extremely dense development,
which cannot be accomodated because of seasonal tourism.

R-l.  The member agencies of AWMA comprise an area of Orange County
encompassing approximately 48,905 acres, extending from the coast 15
miles inland to the foothills of the Santa Ana Mountains.   Seasonal
tourism primarily affects the coastal areas.  Whether or not such
seasonally-affected areas can accomodate additional  development, and
to what degree, is a determination of local government.  AWMA's planned
capacity reflects current land use plans, rather than causing them.

2.   Aliso Canyon should be preserved as a scenic area.

R-2.  Factors which influence the final selection of treatment plant
sites included capital and maintenance costs, efficiency considerations,
future expansion room, and land use plans.  The treatment  plant and
facilities as proposed in Alternative 2G would be near any trail system
that might be constructed along Aliso Creek.  An expanded  discussion
on the impacts and mitigative measures of this plant is presented in
Section 3.1.5 and 3.2.2.1.2.

3.   No ocean discharge should be permitted, as the  nutrients cause
sea urchins to increase, and in turn, kill kelp beds which serve as
fish breeding grounds.

R-3.  The advanced technology of the proposed project will  produce
an effluent that will  be compatible with the natural ground and ocean
waters.  Refer to Section 3.2.1.2 of the EIS.  It has been theorized
that there is a relationship between wastewater effluent and prolifera-
tion of sea urchins, but a firm link has never been  established.  The
nutrient contribution  of wastewater to the ocean is  relatively minor
compared to direct inputs from atmospheric nitrogen, land  runoff, and
bottom upwelling.  Nutrients may become of concern in localized areas,
consequently, discharge sites should avoid areas of  rich productivity
like Dana Point.  In addition, reclamation is encouraged as a beneficial
use of nutrients, and  treatment levels will be increased and dilution
improved to reduce the effects of nutrients on the marine  environment.
                                 9-161

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                               MARIAN PARKS            ,  „ ,',". .'  .. _'  ^
                           233 MORNING CANYON         '-' ' -' ' v ' fv '   '"' : ' ; ' ~ *
                    CORONA DEL MAR, CALIFORNIA 92625
                                                      A en  ill   "! •-- ^4 '
                                                      II \\  ;4    y I'o iiii
                                                       ^-
                                           
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                         SUMMARY COMMENTS

                           Marion Parks

2.   You have on file my references and comments regarding the Aliso
Water Management Agency project, addressed to Ms. Judy Gimler, November 4,
1974.

I protest the allocation of public money in the form of a grant to
this project until complete survey and test excavation for archaeology
heritage are performed.

R-l.  The documents referenced refer to an earlier EIR prepared by
Jones and Stokes for the applicant.  Our updated EIR prepared by Clean
Water Consultants was circulated in February, 1975, and dealt much
more specifically with the direct impacts on archaeological  resources.
Refer to R-l, and 2 of Summary Comments, Society for California Archaeo-
logy.
                                9-163

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RO*i
             March 1, 1975
             Paul De Falco, Jr.  Regional Administrator
             United States Environmental Protection Agency
             Region IX
             100 California St.
             San Francisco, CA.  94111

             Re:  Aliso Water Management Agency
                  Regional Wastewater Treatment System

             Dear Mr. De Falco:

             After reviewing the Draft EIR, I recommend that it be
             considered inadequate until the following items are
             addressed:

                    1.  Planning Considerations
                        a.Include a map indicating the general plan
                            designation.
                        b.   Discuss conflict of uses within conser-
                            vation and open space catagories.
                        c.   Include discussion of impact upon  master
                            plan of scenic highways.
                        d.   Discuss conflicts with open space, re-
                            creational activities, and goals of
                            "Aliso Creek- Forest to Sea" Report,
                            and the open  space element of the  general
                            plan.

                    II.  Physical Considerations
                        aTDiscuss the problems of physically ac-
                            comodating a  regional facility, access
                            road,  bike trail, horse trail, natural
                            creeK  flood plane, within a very narrow
                            valley.  Sections graphically illustrat-
                            ing the impact on change of land form
                            and creek modification is necessary.
                        b.   The physical  constraints of Wood Canyon
                            should also be addressed.
                        c.   Dual use or underground facilities.

                    III.Access  Road
                                      9-164

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Mr. De Falco
March 1, 1975
Page 2
           a.  Discuss the number of bridges required
               along the creek.
           b.  Discuss conflict with recreational
               activities.

       IV. View Analysis
           a.  Discuss the conflicts and proposed
               mitigation of irreversable loss of
               scenic qualities within a conservation
               corridor as viewed from vista points
               above.

Without these discussions it is difficult to assess
the ability of maintaining any integrity within one
of Orange Counties most valuable and critical scenic
and recreational corridors.
Very truly yo
AIA Architect
Member, Orange County Planning Commission

RY/jg
                          9-165

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                            SUMMARY COMMENTS

                              Ron Yeo,  AIA


 1.    A map indicating the general plan designation  is needed.

 R-l.   Exhibit 4-10 has been modified to show adopted General Plan:   Plans
 for Irvine Ranch are  shown separately.

 2.    The proposed uses conflict  with conservation and open space elements,
 and with the goals of "Aliso Creek-Forest to Sea" report.

 R-2.   The locating of a treatment plant in Aliso Canyon would appear to
 be  in conflict with some of the  goals  and policies  of these documents.
 However, such a use would appear to be consistent with the existing  zoning
 and the Land Use Element.   It was the  intent of the L.U.E  to incorporate
 the Open Space and Conservation  Element's goals and policies into its
 pattern of land use designations.   The proposed regional treatment plant
 site  is situated within 5.3 and  5.41 Open Space designations.  Utilities
 are a compatible use  within the  5.3 category and also in 5.41 when "... Ab-
 solutely required for public safety, health and welfare." (Orange County
 General  Plan L.U.E.,  March,  1975,  page  24.).  Therefore, it is felt  that
 only  the Orange County Planning  Commission and Board of Supervisors  can make
 a determination as to whether or not a  conflict exists between these
 elements and if there is  a  conflict, provide a definite resolution.

 3.    How will  the proposed project  affect the Scenic Highway element?

 R-3.   The  AWMA project should affect the  Scenic Highways Element only if
 two circumstances occur.   First,  a  regional  treatment plant as proposed in
 Alternative  2G would  have to be  constructed.  Second, the Aliso Creek
 Scenic Highway would  have to be  built.  At  this time, there is some ques-
 tion  as  to the desirability  of such a primary arterial located in Aliso
 Canyon.   Nevertheless,  if it were constructed, the treatment plant would
 force the  highway to  be constructed through  this narrow portion of the
 qanyon at  potentially great  environmental  or monetary costs.   The con-
 struction  could be  accomplished  by  (1) cutting into the west canyon wall,
 which  would  result  in  extensive  cut slopes;  (2) filling the canyon bottom
 to  raise the level  to  the road to where the  canyon would be wider, but
 this  may expose  the treatment plant to  flood hazards; (3) a combination of
 cutting  and  filling;  or  (4)  modifying the  proposed location of the
 treatment  plant  in  order to  leave moreroom  for the highway.   The impacts
 upon  Aliso Creek  caused by this  proposed  scenic highway are greater than
 the impacts of the  treatment  plant.

 4.   Please discuss the problems of physically accomodating a regional
 treatment plant and all proposed recreational facilities in a narrow
 valley.  Cross-sections showing proposed creek modification and terrain
alteration are necessary.

 R-4.  An expanded discussion of these implications of the regional  treat-
ment plant site has been added to Section 3.1.2 and 3.2.2.1.2 of the EIR.
                                 9-166

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5.   Please discuss physical constraints of Wood Canyon.

R-5.  So noted.  Site 4A has been moved to the GSA Facility or the MNWD
1A site.

6.   Please discuss dual use of the recreational corridor or the possi-
bility of underground facilities.

R-6.  See comment 5 by AWMA.  Most utilities will be underground.

7.   How many bridges will be required along the creek?

R-7.  No permanent bridges will be required.  See comment #6 by AWMA.

8.   Please discuss the impacts and mitigations of loss of scenic
qualities of the creek when viewed from vista points above.

R-8.  Refer to R-4.
                                9-167

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9.6  COMMENTS RECEIVED DURING THE DRAFT EIR REVIEW PERIOD
     NOT REQUIRING A RESPONSE
UNITED STATES FEDERAL AGENCIES

              Department of Transportation, Federal Highway
                   Administration - March 28, 1975

STATE OF CALIFORNIA AGENCIES

              Air Resources Board - April 11, 1975
              California Regional Water Quality Control Board
                   San Diego Region - April 1, 1975
              Department of Transportation - February 21, 1975
              State Lands Division - March 7, 1975
              State Water Resources Control Board,
                   Division of Water Quality - March 28, 1975
              State Water Resources Control Board,
                   Division of Water Quality - April 3, 1975

COUNTY OF ORANGE AGENCIES

              Orange County Chamber of Commerce - March 28, 1975

CITY OF LAGUNA BEACH

              City of Laguna Beach, City Manager - April 21, 1975

QUASI-PUBLIC AGENCIES

              El Toro Water District - no date
              Laguna Beach High School, Natural  History/
                   Coastal Class - March 19, 1975
              Laguna Beach High School, Natural  History/
                   Coastal Class - March 20, 1975
              Laguna Beach High School, Natural  History/
                   Coastal Class - March 20, 1975.
              Orange Coast County Coast Association - March 25,  1975
              Santa Ana Watershed Project Authority - March 25,  1975

PRIVATE INTEREST GROUPS

              American Association of University Women -
                   May 1, 1975
              Bricklayers Local  No.  22 of California - no date
              California Garden Clubs, Inc. - March 16, 1975
              Citizens'  Town Planning Association - March 19,  1975
              Desomount Club - March 22, 1975
              Guard -  March 25, 1975
              Irvine Teachers'  Association - March 24, 1975
                                       9-168

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PRIVATE INTEREST GROUPS, CONTINUED
              Junior Woman's Club - March 18, 1975
              Laguna Beach Taxpayers' Association, Inc. -
                   March 14, 1975
              Professional Community Management, Inc.  -
                   March 18, 1975
              Saddleback Area Coordinating Council - March 19, 1975
              San Diego Audubon Society, Inc. - April  12, 1975
              Sierra Club, Angeles Chapter, Orange County Group-
                   April 8, 1975
              Temple Hills Community Association - March 23, 1975
              The Laguna Greenbelt, Inc. - March 19, 1975
PRIVATE INDIVIDUALS
              Mrs.  H.  M.  Anderson - April  14,  1975
              Mrs.  P.  H.  Braun - March 31, 1975
              Mrs.  Margaret Baggs - April  12,  1975
              Mr.  David W.  Baker - April  18,  1975
              Mr.  Helen F.  Brockmeier - March  21, 1975
              Mr.  John N.  Daniel  - March 16,  1975
              Mr.  Chas. J.  Durway - April  9,  1975
              Mr.  Don  Ferguson - April  4,  1975
              Mrs.  Helen  P. Gregory - March 26, 1975
              Mrs.  Betty  Heckel  - March 19, 1975
              Mrs.  Betty  Heckel  - April 3, 1975
              Mrs.  Betty  Heckel  - April 5, 1975
              Mr.  Michael  Lynd - March 31, 1975
              Mr.  & Mrs.  Bill  Ines - March 25, 1975
              Mr.  & Mrs.  Jim Marner - March 25, 1975
              Mr.  Lloyd A.  Johnson - March 13, 1975
              Dr.  Ray  M.  Moose - March 16, 1975
              Mr.  William Robert Suddaby - April  1,  1975
              Mrs.  R.  M.  Thompson - March  24,  1975
              Mrs.  Gerald A.  Woods - March 17, 1975
                                      9-169

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                                                     ARIZONA
                                                     CALirOKMIA
                                                     NEVADA
               U.S. DEPARTMENT OF TRANSPORTATION        I*»»<*«A((
                  FEDERAL HIGHWAY ADMINISTRATION            A-M.CAH •*«<«.
                         REGION NINE                               *n F
             450 Golden Gate Avenue, Box 36096                  ft3 5
              San Francisco, California  94102

                       March 28,  1975
                           .                          IH REPLY REFER TO
                                                     9ED

Mr. Paul  De  Falco,  Jr.
Regional  Administrator
Environmental  Protection Agency
100 California Street
San Francisco,  California  94111

Dear Mr.  De  Falco:

We have reviewed the Draft Environmental Impact Statement
for the Aliso  Water Management Agency Regional Wastewater
Treatment System and find the discussion of  transportation
to be adequate.  Also,  Exhibit 4-13 reflects  the California
Department of  Transportation's current plans  for new or
revised freeway interchanges in the area.  Therefore, we
have no comments to offer.

We appreciate  this  opportunity to review the  subject Draft
EIS.

                             Sincerely yours,
                                E.  Hawley
                             Regional Administrator
                               9-170

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StntS of California                                                  The Resources Agency
                                                                           /g Cj o
Memorandum                                                  •  .  " ° °


To   :   Honorable Ronald Robie, Director           Date '  April 11, 1975
       Department of .-Water Resources               • _
       1416 Ninth Street    ....                  Subject:  Regional Wastewater
     •  Sacramento, CA  95814                       Treatment System-.   ..
                                                   Aliso Water Mangmt Ag
       Attention:  Mr. Ken Fellows                 San Diego/Los Angeles/
                                    .               San Bernardino Counties
                           . ..  ..:. , ..   .:            SCH. No. 75030448   .
From :  Air Resources Board       "    •'•••»    /v***^  It
    '   William C-. Lockett, Chief |..\.(v  \3 .1^? , -. .        .          .
     ., Evaluation and Planning  .-"':•'' '•• - .'^*•"•"• ^^    . ""
       The proposed Aliso Water Management Agency (AWMA) project consists
       of the implementation of.a regional wastewater. treatment and dis-
      .posal system designed to eliminated existing water quality problems
       and prevent future problems in the Agency's jurisdictional bound-
       aries.   AWMA is responsible for the planning, construction, and
       operation of facilities for a water management program within the
      .Aliso Valley Watershed Basin and related contiguous areas.  The
       AWMA ^encompasses approximately 48,905 acres of Orange County. ,

       The environmental impact statement (EIS) evaluates several alter-
       natives relative to environmental effects.  The applicant favors
       a regional system with central treatment and ocean disposal of most
      wastes.   The proposed project, if not built,  would act as a deter-
       rent to the development and urbanization of various areas within
       the AWMA.   The  option of no alternative or controlling utility
       extensions are  choices which need to be considered following the
       comment portion of the EIS process.

      The air quality impact of  the proposed project was extensively
      discussed  in the EIS.   The present air quality in the AWMA area
      is  among the worst in the  State,  has a high potential for adverse
      conditions,  and is a serious problem.  The EIS points out that
       "...  the solution seems to lie in reducing the total vehicle miles
      traveled (VMT)  within AWMA."  The Air Resources Board (ARE)  agrees
      with this  conclusion.   However,  this would necessitate land use
      planning and the development of alternative transportation models
      which are  not within the power of AWMA to implement.  AWMA has
      some power,  however,  to participate in enforcing implementation
      strategies.

      The  EIS  presents  six mitigation measures and  associated implementa-
      tion strategies  which,  if  implemented, would  reduce projected VMT.
      These measures  are  promising proposals and need to be developed
      and  appropriately  implemented so  the  proposed regional wastewater
      treatment  and disposal  system will not adversely affect air quality.

      The  project  needs  to  comply  with  all  environmental laws.   40 CFR
      35.925-14  (published  2/11/74)  states  that sewage collection systems
                                       9-171

-------
Mr. Robie                      ;'-2-              April 11, .1975
"... will comply with all pertinent requirements of the Clean Air
Act and other applicable Federal, State, and local environmental
laws and regulations."  This may be done through the implementation
of the previously mentioned mitigation measures.

In the next two years the ARB, in cooperation with local government,
will participate in the development of an air quality maintenance
plan (AQMP) for those areas in which growth and development are pro-
jected to prevent either the attainment or if attained the maintenance
of the national ambient air quality standards in the next ten years.
The air quality impact of the Aliso project on the jurisdictions
in the AWMA needs to be mitigated.  Air quality considerations,
such as the proposed mitigating measures, must be integrated with
the local land use and regional transportation planning to demon-
strate that attainment and maintenance of the standards will not be
interfered with by the proposed project.  In order to limit detri-
mental air quality to the area,"this project needs to be conditioned
along the lines of'the clean water grant conditions now being worked
out between the State Water Resources Control Board, EPA, and ARB.
This is necessary if government is 'to carry out its responsibility
in protecting the public health from the continued effects of
polluted air as well as polluted water.

cc:  J. McGraph, EPA
     F. Broadhead, Coastal Commission
     R. Walsh,  SWRCB
                                 9-172

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                   ,                                 ..                                    /; 4 a
Jftemoranclu'sii                      -rCHIVED                     ...   , .   -.
                                                A  REGION .IX   ;        •    ,  .    i-'-v,.>.-•:••.
To   :     MR. LARRY WALKER                  .    ,.  „ ., .u .#"*   APR'L  1' 19?5
          STATE WATER RESOURCES CONTROL BOA^D"  H  II Ul HP
          SACRAMENTO
From  :  California Regional Water Quality Control Board
                    San Diego Region
       6154 Mijsion Gerga Road —Suite 205, San Diego, Calif. 92120
Subject:    REVIEW OF ENVIRONMENTAL IMPACT STATEMENT,
         SCH No.  753CM8 FOR ALISO WATER MANAGEMENT
         AGENCY,  REGIONAL WASTEWATER TREATMENT SYSTEM,
         I.D. No. 7^-o8if1, F.Y. 1974-75
                     STAFF OF THIS REGIONAL BOARD DOES NOT CONCUR WITH
                     COMMENT No. 1 IN YOUR MARCH 28, 1975 MEMO ON THIS
                     SUBJECT.  As A MATTER OF FACT, STAFF SUPPORTED THE
                     2G ALTERNATIVE AT THE PUBLIC HEARING ON THE.EIS ON
                     MARCH 25, 1975-
                                             LADIN H. DELANEY
                                             SENIOR WATER QUALITY CONTROL ENGINEER
         LHD:LVR
         cc:   MR.  ROBERT H. LEWIS,  CHIEF
              DIVISION OF PLANNING  AND RESEARCH

              EPA,  REGION IX
              ATTN:   MR. JIMMCGRATH

              CRWQCB, SANTA ANA REGION (8)
              ATTN:   MR. MIKE COONEY

              Anso  WATER MANAGEMENT AGENCY
              ATTN:   MR. WILLIAM F.  WOLFSON

              STATE  COASTAL COMMISSION
              ATTN:   MR. FRANK BROADHEAD
                                            9-173

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STATE OF CALIFORNIA—BUSINESS. AfD. TRANSPORTATION AGENCY
Edmund G. Brown Jr.,
DEPARTMENT OF TRANSPORTATION
DISTRICT 7, P.O. BOX 2304, LOS ANGELES 90054
             Mr. Paul De Falco, Jr.
             United States Environmental
               Protection Agency
             Region IX
             100 California Street
             San Francisco, CA  94111
                                                     February 21, 1975

                                                     07-Ora-General
                                                     07102 - 910002
             Dear Mr. De Falco:

             We have reviewed the Draft Environmental Impact Statement  for
             the Aliso Water Management Agency Regional Wastewater Treatment
             System.  We find that the proposal has no slanlfleant Impact  on
             State Transportation plans or on the State Highway System.
                             f
             Sewer line crossings of State Highways will be reviewed at the
             time applications  for permits are submitted by the Water Manage-
             ment Agency.

             Very truly yours,
                   Programs  &  Budgets  Branch
                                                                                 C3   O

                                                                                 -=o   r- .;;
                                                                                 O
                                                                                 OJ
                                                                                c_n
                                                                                     rn '-
                                            9-174

-------
  STATE L/NDS Division
   3007 - }£;h ST-irfT                                                                         ,;  .
SACRAMENTO, CALIF. S5514                                                                     /f  3
                                                 March 7,  1975

                                                           File Ref.i   8D-75-2-11*
                Aliso Water Management Agency
                27281 Aliso Creek Road
                Laguna Miguel, CA 92667
                     .-   •  .
                Gentlemen:

                          SUBJBCTt  :BB Ho.: ;
                                    Regional Waatewater Treatment System
                                    Aliso Water Management Agency

                          This Division has reviewed the subject Draft BIS and has
                determined that a portion of  the area underlying the proposed project
                is presently under  lease to South Laguna Sanitary District,  P.R.C.
                Ho. 899.9, dated March 1, 195^.

                          If will be-necessary for you to make application to the
                State Lands Commission for a lease to cover additional occupancy of
                State land.  Application Form 52.1 is enclosed for your  convenience.

                          Your cooperation and. early response will be appreciated.

                                                Very truly yours,
                                                C. R. KIRKS
                                                Supervisor,
                                                Land Transactions

                /cap

                End. i . Form 52.1

                txf:  United States Environmental Protection Agency
                     Region IX
                     100 California Street
                     San Francisco, CA 9^111
                     Attention!  Mr. Paul De Falco, Jr.
                                 Regional Administrator

                bcc:  P.R.C. 899=9

                      Alan C. Scott
                                              9-175

-------
 Memorandum
To
 From
                                             iX
       Robert H.  Lewis,  Chief       COMM. CENTER
       Division of Planning and Research        ' _
                                   APR  ? i222PH'75
                                                  Dot*
                                                   Subject;
      Larry F.  Walker
      Division of Water Quality
       3 1975
Review of Environmental
Impact Report, SCH
No. 74031822 for Aliso
Water Management Agency.
Regional Wastewater TreM-
raent System, I.D. No.   w
74-0841, F.Y. 1974-75
       This office has reviewed the draft Environmental Impact Report (EIR)
       of subject project dated March 20, 1975.   The Division of Water
       Quality with concurrence of the California Regional Water Quality
       Control Boards, Santa Ana Region and San  Diego Region, hereby
       presents preliminary comments on the draft EIR.

              This draft  EIR contains  all information required by
              the State Water Resources Control  Board Environmental
              Impact Report  and Public Participation Guidelines of
              July, 1973.  However,  several shortcomings  were discovered
              that'relate to planned facilities  and  resulting secondary
              impacts.  These are  as follows:
              Comment;  The proposed project  envisions  the  construction
              of  a new  regional  plant  just north of  the  existing South
              Laguna Sanitary  District plant.   To avoid  disturbing the
              land along  Aliso Creek,  the applicant  is urged to  evaluate
              an  alternative that  calls  for  expanding  the  existing
              facilities  to handle 10.2  MOD.

              Comment;  Location  map -  Is it  necessary  to construct a
              service road with  a  50-foot right of way along Aliso
              Creek between the  proposed regional treatment  plant
              and the Alicia Parkway?  The possible  secondary impacts,
              such as land development,  along  the proposed road  should
              be  discussed.

      As a funding agency the State Water Resources Control Board reserves
      the right  to make  further comments on subject report  prior to granting
      and EIR approval pursuant to the  Clean  Water  Grant  regulations.

      Should  you have  any questions regarding this  review,  please contact
      Wayne Brown at (916) 322-4940.
   SURNAME

RC8 I29Q (8-09»
                                        9-176

-------
Robert H.  Lewis
Page 2
2.c:  : EPA,  Region IX
     Attn:  Jim McGrath

     CRWQCB, Santa Ana Region (8)
     Attn:  Mike Cooney

     CRWQCB, San Diego Region (9)
     Attn:  Ladin Delany

     Aliso Water Management Agency
     Attn:  William F. Wolfson
                                  9-177

-------
  Sfato ot California

  Memoran
                                          REGION !X
To   ,  Robert H. Lewis, Chief      HflR 3 j  |Q 48 fiH '?5
      Division of Planning and Research
                                                   State Water Resources Control Board
                                                         MAR 2 8 -97S
       Larry F.  Walker
  From  : Division of Water Quality
                                                  Subject: Re view of Environmental
                                                       Impact Statement, SCH
                                                       No. 7530448 for Aliso
                                                       Water Management Agency,•
                                                       Regional Wastewater Tred»-
                                                       ment System, I.D. No.
                                                       74-0841, F.Y. 1974-75 .
       This  office  has  reviewed the  draft Environmental Impact Statement
        (EIS)  of  subject project dated March 12,  1975.   The Division of
       Water Quality  with  concurrence of the California Regional Water
       Quality Control  Boards,  Santa Ana Region  and San Diego Region,
       hereby presents  preliminary comments on the draft EIS.

              This draft Environmental Impact Statement  (EIS) contains
              all information required by the State Water Resources
              Control  Board Environmental Impact Report  and Public
              Participation Guidelines of July, 1973.  However, several
              points in the report are unclear.  These relate primarily
              to  planned facilities and resulting secondary impacts.
              Specific comments and questions are set forth below:
             Comment; The recommended  alternative  2G envisions the
             construction of  a new regional  plant  just north of the
             existing South Laguna Sanitary  District plant.   To avoid
             disturbing the land  along Aliso Creek the applicant is
             urged to evaluate Alternative 1A (modified)  that calls
             for expanding the existing  facilities to handle 10.2 MGD.

             Comment: Pg. 3-18, Service  road -  Is  it necessary to
             construct a service  road  with a 50-foot right of way
             along Aliso Creek between the proposed regional treatment
             plant and the Alicia Parkway?   The possible  secondary
             impacts, such as land development, along the proposed
             road should be discussed.

             Comment; The recommended  alternative  2G (Exhibit 3-13)
             shows a raw sewage interceptor,  maximally sized at 20 MGD,
             extending down Aliso Creek  to the proposed regional
             treatment plant, designed for 16 MGD.   The secondary
             impacts produced by  such  an oversized interceptor traversing
             undeveloped land should have been directly addressed.
   SURNAME

•ACS 129Q <«•«»>
                                        9-178

-------
Robert H. Lewis
Page 2
        Comment: Energy conservation - The amount^ of energy
        required by each alternative has been adequately
        covered.  However, no mitigation measures to reduce
        energy comsumption have been put forth pursuant to
        Amendments to the State Guidelines, Appendix F, dated
        December 26, 1974.  For example, if the sludge is to
        be digested anerobically, consideration should be given
        to using the gas that is generated for heating the
        digester and providing energy for pumps.

As a funding agency the State Water Resources Control Board reserves
the right to make further comments on subject report prior to
granting an EIS approval pursuant to the Clean Water Grant regulations,

Should you have any questions regarding this review, please contact
Wayne Brown at (916) 322-4940.

cc:  EPA, Region IX
     Attn:  Jim McGrath

     CRWQCB, Santa Ana Region (8)
     Attn:  Mike Cooney

     CRWQCB, San Diego Region (9)
     Attn:  Ladin Delany

     Aliso Water Management Agency
     Attn:  William F.  Wolfson

     State Coastal Commission
     Attn:  Frank Broadhead
                                   9-179

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               OFFICERS

        Chairman of the Board
              Gordon Olson
Knobbe, Martens, Olson, Hubbard & Bear

    President & General Manager
            Lucien D. Truhitl

            Vice Chairman
              Fred Cahtrell
     Alpha Beta Acme Markets, Inc.

            Vice Chairman
            Richard J. Smith
        Hunt-Wesson Foods, Inc.
              Treasurer
            Eugene V. Kadow
        Fountain Valley Land .Co,

   Chairman. Executive Committee • -
            Robert W.Clifford
        • • " *. "'  A*! California,,

              DIRECTORS

             Sandy Berwick
            Real.'Estate Broker
              Stan Botelho
            General Telephone
              Fred Cantrpll
     Alpha Beta Acme Markets. Inc.
             J. Wylie Carlvle
       County of Orange Recorder

            Robert W. Clifford
              Air California

            James W. Decker
    Southern California Gas Company

            Ron Dommguez
            Disneyland Park

              Werner Escher
            South Coast Plaza

            Charles Ferguson
         Avco Financial Services
               Mike Gallic
       M-G Disposal Systems, Inc.
            Kenneth E. Hag an
            Attorney at Law
            Robert E. Hanson
       Arthur Young & Company
              Richatd Hart
        Richard Hart & Associates

            Clyde M. Haugan
         Delco-Remy Div. CMC

            Richard Holmcjren
           Holmgien & Sawyer
            Fpnton E. Jones
  West Orange Countv Municipal Court

              Gotdon Jones
           Tlw livme Company

            Eugene V. Kadow
        Fountain Valliy Land Co.

              Carl Kiiichet
         C

    -------
                     RESOLUTION IN RESPONSE TO FEDERAL EPA
                   ENVIRONMENTAL IMPACT STATEMENT REGARDING
                        ALISO WATER MANAGEMENT AGENCY
                   REGIONAL WASTEWATER TREATMENT FACILITIES
         WHEREAS/ it is the policy of the Orange County Chamber of
    Commerce to review planning, economic and environmental issues
    which have a significant effect on Orange County, and
    
         WHEREAS, there exists a need for a regional wastewater treat-
    ment system to serve the existing and future populations of
    southern Orange County within the Aliso Water Management Agency
    service area, and
    
         WHEREAS, the City of Laguna Beach, the Moulton-Niguel Water
    District, the Los Alisos Water District and the El Toro Water District
    are currently mandated by the State Water Resources Control Board
    to improve the treatment processes at existing sewage treatment
    facilities, and
    
         WHEREAS, the Aliso Water Management Agency's Regional Waste-
    water Treatment project has been three years in the planning stages,
    and
    
         WHEREAS, the concept of the Aliso Water Management Agency's
    Regional Wastewater Treatment system has received the approval of
    the Southern California Association of Governments, the Orange
    County Planning Commission, the County of Orange Board of Supervisors,
    the San Diego and the Santa Ana Regions of the California Water
    Quality Control Board, and the Regional and State of California
    Coastal Zone Conservation Commissions, and
    
         WHEREAS, the economy of Orange County can be positively stimu-
    lated by increased employment, and
    
         WHEREAS, the implementation of the Aliso Water Management Agency
    project will provide overall environmental benefits as well as needed
    employment, and
    
         WHEREAS, there is a continuing escalation of construction costs
    at the rate of one and one-half percent per month for wastewater
    treatment facilities, and
    
         WHEREAS, Aliso Water Management Agency Plan 2-G appears to be
    the most practical and most effective method to accomplish waste-
    water treatment both in consideration of costs and environmental
    impacts of all of the alternatives,
    
         THEREFORE, BE IT RESOLVED, that the Orange County Chamber of
    Commerce supports the construction of the Aliso Water Management
    Agency's regional wastewater treatment facilities known as Plan 2-G
    and urges the Environmental Protection Agency and the State Water
    Resources Control Board to commence construction of facilities at
    the earliest possible time.
    Adopted by:  Orange County Chamber of Commerce/ Attested
                 Board of Directors                 Lucien D. Truhill
                 March 27, 1975                     President & Gen. Mgr
    
                                     9-181
    

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                                                                                  A'
     April 21, 1975
     U.  S.  Environmental Protection Agency
     Region "DC
     100 California Street
     San Francisco, California  94111
    
     Attention:   Mr.  Paul DeFalco, Jr.
                 Regional Administrator
    
     Gentlemen:
    
                 Subject:  Draft Environmental Impact Statement for the
                           Aliso Water Management Agency (AWMA), Regional
                           Wastewater Treatment System
    
     A letter  dated April 10,  1975 was addressed to your office by Carl J. Kymla,
     Chairman  of Aliso Water Management Agency, indicating that the Board of
     Directors of AWMA were urging the Environmental Protection Agency to take •
     an  affirmative position in the selection of Alternative Concept 2-G as the
     most cost-effective regional wastewater treatment system which would result
     in  desirable environmental impact effects to the extent practicable on the
     area basis.
    
     At  the AWMA Board of Director's meeting on April 16th, this letter was dis-
     cussed after the fact.   The Board was asked to approve the letter which was
     done by five affirmative  votes, one abstention and one negative vote.  A
     motion was  made  by the Laguna Beach Director to notify EPA of the results
     of  the vote.   This motion was defeated on a six to one vote.   It was the
     opinion of  the Laguna Beach City Council that EPA should be aware of the
     facts  regarding  the letter and the results of the votes on the two motions.
    
     Very truly  yours,
    ALFRED R. THEAL
    City Manager
    
    ART:as
                                        9-182
        505 FOREST AVE.  •   LAGUNA BEACH,  CAL.  92651    •   TEL. (714) 494-1124,  546-4856
    

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                                                                    / <-'
         The Board of Directors of the El Toro Water District
    
    
    
    has approved the Aliso Water Management Agency Plan 2G and
    
    
    
    has adopted a plan of works incorporating this regional plan.
    
    
    
         Based or. studies made by the District's Engineer, the
    
    
    
    Board has found that Plan 2G provides the most cost effective
    
    
    
    method of handling the District's waste water.  There will
    
    
    
    be a substantial saving to the District for future pumping
    
    
    
    costs, sludge disposal and treatment with the regional plant.
    
    
    
         In addition, Plan 2G enables the District to reclaim a
    
    
    
    significant amount of waste water which will be put to
    
    
    
    beneficial uses in the area.
    
    
    
         During periods when reclaimed waste water cannot be
    
    
    
    beneficially used, the plan affords the District an economi-
    
    
    
    cal and efficient method of disposing of its waste water.
                                9-183
    

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    LAGUNA  BEAChTHIGH  SCHOOL
    625 PARK AVENUE, LAGUNA BEACH, CALIFORNIA 92651 (714)494-8546
    21
                                                                   DONALD G. HAUGHT. Principal
                                                                   THOMAS LaVERN DUGGER. Asst. Principal
                                                                   RICHARD D. HOLUSTER, Asst. Principal
               March 19,  1975                                          !';-;cio>. i:-;
    
    
               EPA,  Hearings Office                  •                           •
               HE  118,  Region IX
               100 California Street
               San Francisco, California 9^111
    
               Dear  Sirs:
    
               Please enter this letter in the Hearing  Record.
    
               After studying natural history of the coastal region we have come to
               the realization of the great importance  that the open space around
               Laguna Beach plays in the environment of the coast.  We fail to see
               the value  of a gigantic sewage treatment plant in Aliso Canyon.  The
               toll  of  natural destruction would be enormous in this area.  Vie feel
               the proposed money would be better spent if it were used to update
               the present  sewage treatment plants, bringing them up to standards
               comparable to today's technology.
    
              We  need  to preserve more of our natural  resources, not only for our
               personal pleasure and existence, but for the future generations who
              will  have the same understanding, likes, and dislikes which we have.
              For this reason we lend support for the  EPA proposal that can assure
               smaller  and  dispersed plants, and which  emphasizes agricultural ir-
              rigation and a clear stream system flowing to the ocean.
    
              Sincerely,   the undersigned members of the Natural History /Coastal
                           class,  Laguna Beach High School
                                                9-184
    

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    AGUNA  BEAChTHIGH  SCHOOL
    25 PARK AVENUE. LACUNA BEACH, CALIFORNIA 92651 (714)494-8546
                         /I24
                                                                 DONALD G. HAUGHT. Principal
                                                                 THOMAS LaVERN DUGGER. Asst. Principal
                                                                 RICHARD D. HOLUSTER. Asst. Principal
             March 20, 1975
    MAR 2 5 1975
    
      REGION IX
             EPA, Hearings Office
             HE 118, Region IX.
             100 California Street
             San Francisco, California
    
             Dear Sirs:
    
             Please enter this letter in the Hearing Record.
    
             It was,, brought to our attention recently that a plan to build an
             enormous sewage plant in Aliso Canyon, a plan to be presented at
             a public hearing on Tuesday, March 25.
    
             We are appalled that such a monstrosity is even considered.  Such
             a plant could only encourage increased development in the coastal
             area which is already heavily populated. We support the Laguna Green-
             belt and the ideals of conservation which allows an area to be set
             apart in its natural state.
    
             If it is essential that we plan expansion of sewage treatment plants,
             then the EPA proposal for scattered, smaller plants is preferable.
             The decision might best be made directed by our conscience, not our
             bankbooks.
    
             Sincerely,  the undersigned members of the Natural History/Coastal
                         class, period 2, Laguna Beach High School
                                              9-185
    

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    LAGUNA  BEAChTHIGH  SCHOOL
    625 PARK AVENUE. LAGUNA BEACH, CALIFORNIA 92651 (714)494-8546
    i
                                                                   DONALD G. NAUGHT. Principal
                                                                   THOMAS LaVERN DUGGER. A3St. Principal
                                                                   RICHARD D. HOLLISTER. Asst. Principal
              March 20,  1975
              EPA, Hearings Office
              HE 118, Region IX
              100 California Street
              San Francisco, California
    
              Dear Sirs:
              Please enter this letter  in the Hearing Record.
    
              We would like to express  bur view on the enormous water  treatment
              plant planned for Aliso Canyon.  This would be an excessive waste
              of money and misuse of land because smaller, more efficient dis-
              posal plants could do the same work at a smaller cost  and without
              the waste of this valuable land.
    
              We are only a part of a group, students, citizens and  others, who
              feel as we do and who have the intelligence to see the importance
              of saving this beautiful canyon bottom from total destruction.
    
              Haven't we done enough damage already? •.
    
              Sincerely,  the undersigned members of the Natural Hi story /Coastal
                          class, period 1, Laguna Beach High School
                                                                        (XA.,C,v£
                                                9-186
    

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                                                                                     PHONE  962-6661
                                                    Gotutfy  GoadJ
                                                            18582  BEACH BOULEVARD    .     SUITE 224
                                                            HUNTINGTON  BEACH, CALIFORNIA  .   92648
                                              March 25, 1975
     OFFICERS
     Edwin "Ted" Finster  .     President
     William Webb     First Vice President
     Jack Feehan    Second Vice President
     Willard Jordan           Treasurer
     Ralph C. Kiser           Secretary
             STATEMENT BEFORE ALISO WATER MANAGEMENT AGENCY
     DIRECTORS
     Dr. Daniel G. Aldrich, Jr.
     Robert Badham
     Hancock "Bill" Banning, III
     Jack Barneh • ':  ^ .^rj>o
     Ted Bartlett
     Cap Blackburn
     Don Byrnes
     J. Wyllie Cartyle
     Robert Clifford-- -, -  - Q-
     Wimam Coulter" "'" '.' 't " .
     James-W.'Decker'-   V
     Jack Feehan < '-" -:"  .
     Edwin Finster ;.>--;     '
     William Foster	
     Judge Selim S. "Bud" Franklin
     Jack Hammett     -' •
     E. F. Hlrth
     Roy Holm
     Willard T. Jordan
     Edward Just
     Ralph C. Kiser     .
     Carl Kymla
     William  Lusk
     Randy McCardle
     George McCracken
     Robert McCurdy
     Donald Mclnnis
     John Macnab
     Doreen Marshall
     Stephen Michalec
     Lorna Mills  :,.-,• •   •  .-.r
     0. W. "Pete" Moore
     R. I. "Cuba" Morris
     Hugh Mynatt
     Paul Presley
     H. L. Remmers
     0. W. "Dick" Richard
     Theo Robins, Sr.
     Kenneth Sampson
     Robert SheHon
     Dr. Donald D. Shipley
    Thomas Stadlinger
    J. Leslie Steffensen
     Richard  Stevens
    John Vibert
    Raymond Watson
    William "Bill" Webb
    Robert N. Weed
    C. E. "Bill" Woods
    Nick Ziener
         The Orange  County Coast Association represents all of the coastal
     communities from Seal  Beach to San Clemente in Orange  County and has
     dedicated itself to'the  economics and environment of our coastline for
     over sixty years.
    
         The association supports the regional wastewater treatment facilities
     as. proposed by the Aliso Water Management Agency.
    
         It is-not a  factual  statement in our opinion, to say that growth for an
     area can be reduced by eliminating regional wastewater treatment  systems.
    
         Limited expansion of treatment facilities does not represent a deter-
     rent to development because smaller individual private systems may  still
     be built.  The result would be an ultimate increased cost to the local
     residents and taxpayers along the coastline.
    
         The Coast  Association feels that the regional system with its  deep
     ocean outfall and high level of treatment will have no detrimental  effect
     on the ocean environment.
    
    -  -   The Orange County.Coast Association hereby  endorses  regionalization
     of  sewerage facilities  as proposed by the Aliso Water Management Agency
     and supports the most  economical and cost effective plan.
     For Executive Committee
     Orange  County  Coast Association,
    Ralph C;
    Secretary
                           RCK/hg
                                                   9.187
    

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    SANTA^ANA WATERSHED
      PROJECT A LSTHQRITY
    COMMISSION FOR THE PROJECT AUTHORITY
    
    CARL B. MASINGALE. CHAIRMAN. AND RAY W. FERGUSON (CBMWD)
    ROBERT L. CLARK AND AUGUST F. LENAIN (OCWD)
    JACK A. BEAVER AND LLOYD D. YOUNT (SBVMWD) .
    HOWARD A. HICKS AND JOHN M. MYLNE. JR.  (WMWD).
                                       MANAGER
    
                                       ROBERT E. MOORE
                   TREASURER
    
                   MARILYN A. THOMPSON
           March 25, 1975
           Environmental Protection Agency
           100 California Street
           San Francisco, California 94111
    
           Attention:  Hearing Officer; Aliso Water Management Agency Project
    
           Gentlemen:
    
           In Santa Ana Watershed Planning Agency's role as basin contractor
           for Basin 8, we became familiar with and followed the development
           of the programs and plans of the Aliso Water Management Agency.
           These plans involved both basin 8 and 9 water supplies, waste
           collection, treatment and disposal, as well as regionalization
           across this boundary.  Their interface with the water quantity
           and quality aspects were of prime concern to SAWPA as we developed
           the Santa Ana plan.
    
           With respect to the environmental soundness and consistency with
           Title III planning, the following points should be made with
           respect to the AWMA recommended plan:
    
                1.  The AWMA concept of water resource utilization is
                    consistent with the basin plans insofar as quantity
                    and quality considerations are concerned.
    
                2.  The AWMA concept of regionalization of water resource
                    facilities is consistent with State and Federal
                    planning guidelines.
    
                3.  To the extent that these cpncepts and considerations
                    can incorporate environmental concerns and show
                    intent to mitigate environmental compromises we
                    believe the AWMA recommended plan to be environmentally
                    sound.
                  Total Water Quality Management — SAWPA's Commitment to the Community
    
                                        9-188
    

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    Environmental Protection     -2-          March 25, 1975
      Agency
    Taken as a whole we believe the AWMA plan to be compatible
    with and complimentary to the clean water programs of the
    Southern California area.
    
    Within the context of amplifying and executing the basin plans,
    then, we believe the Environmental Impact Statement under
    consideration at this hearing is accurate and complete.
    
    Very truly yours,
    !».'..•'       •         •         '• '                       .
    SANTA ANA WATERSHED PROJECT AUTHORITY
    Robert E. Moore
    Manager
    
    REM:map
                                 9-189;
    

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                                                 ?.R May  1,
    U.S. Environmental Protection  Agency
    San Francisco, California
    Dear Sirs;      ...
    
         Our Land Use Study Group would  like  to  offer  some  comments
    
    on.the proposed Aliso-Water Management Agency  project.
    
         We are concerned that tne project is planning for  too  much
    
    growth and should be scaled down to  a more reasonable population
    
    density for this area.  The area of  land  within  this district
    
    should be designated for 208.Planning.
    
         We would like to see many of the elements of  plan  1A
    
    adopted, rather than 2G, as we feel  that  more  of the waters tied.
    
    in Aliso Canyon would be preserved.  Instead of  the lar^e treatmeitt
    
    plant facility  in iliso Canyon we would favor  expansion of  the
    
    existing facilities in the areas Bast of  Laguna  Beach.  Although
    
    we realise tuere is little room for  expansion  of the Laguna
    
    Plant in Laguna Canyon, the facility snould.be improved, parti-
    
    cularly lengthening the sewage discharge  pipe  into  the  ocean.
    
         One of the  secondary effects we fear in tiie treatment  plant
    
    in Aliso Canyon is the possibility of sludge over-flow  during
    
    the rainy season.  Another is the tremendous amount of  water
    
    which would bave to be re-piped back to other  areas.  We would
    
    also lii'.e to see more possible wastewater reclamation alternatives.
    
    The mitigation  measures are good but we question whether .ttie.y can
    
    be enforced.
    
                                  Sincerely yours,
                            9-190
    

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               •flflKMERS   LOCAL  1  22  Of  CALMIA—
               (714) 531-3132      •      1605 NORTH HARPER STREET      .     SANTA ANA, CALIFORNIA 92703
    WILLIAM H.-MEIER
    FINANCIAL SECRETARY
     ft BUSINESS AQENT
                     ENVIRONMENTAL PROTECTION AGENCY
    
    
                      ALISO WATER MANAGEMENT AGENCY
    
                             .SEWAGE FACILITY
    
    
       To t'he members of the board I want  to thank you  for this opportunity
       to speak to you.
    
       One of my greatest concerns, is the  unemployment  problem with the
       construction workers in  Orange County.  We have  been delt some very
       hard blows due to Prop9sition 20.   We have been  put in a position
       by 'the Federal Government  to create more employment with the minorities
       and this takes money to  train them  for the productivity that they
       must give their employers  and now we  have a situation where we
       cannot build.in Orange County.
    
       .Thev people that you are  denying employment to are not people that
       are coming from other states but you  are talking about people who
       are. native Californians  and born right  here in Orange County.  We
       have educated  them.  .Their parents, many have been transients, but
       they have paid taxes in  Orange County and now you are denying these
       people the right  to live in Orange  County and the right to work in
       Orange County.        '
    
       I  .know it has  been said  numerous times  that skilled tradesmen in
       Orange County  are  highly paid.  We  are  highly paid because we are
       seasonal workers.   We are  at the mercy  of the economy, EPA, weather
      .conditions,  poor  conditions  of the  jobs, interest rates, etc. The
       construction worker that has  health,  welfare and pension, they are
      .only covered when  they are  working.
    
       The cut  in construction  caused  by Proposition 20 has left a scare
       on the construction worker  for  the  next 20 years because the hours
       that a skilled  transman  worksstoday are the pensions that he will
       get 2.0 years from  now.   There will  be a decline in those hours which
       will  once  again put  the  senior  citizen on a fixed income with a
                   / position versus  the economy and )
                                  9-191
    

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                     CALIFORNIA GARDEN CLUBS, I
    
                        Official Publication: "GOLDEN GARDENS"
                                                                      ri zt
                                                           : *v
                          C
                       Laguna
                          92653
                                                             ..
                                                      REGIONAL HEARING CLERK
    
                                                           MAR 2 0 1975
                                                             i
                                                             I REGION IX
     For Hearing scheduled at Federal Bldg0fl 2l(.000 Avila Rdoj
          Laguna Miguel- Galo  on Tuesday March 25 0 19?5o
    
     SUBJECT;   Alis© Wastewater Management Projecto
    
     Gentlemeng
    
     The massive program as proposed by the Aliso Wastewater
     Project is not realistic in relation to th® problems of
     the following subjeets in minds
                                                             today0 with
    l°This  project  is a first step leading to the destru@tion of many
    thousand  ©f  acres of potential agricultural ©rop landsp an item
    d©serving of top priority0 with a food crisis already a r®ality0
    A moratorium should be declared on any a©ti©n that entails loss of
    such land until  the proposed legislation by Assemblyman) Charles
    Warren  (AB #15>)  has had adequate consider at ion0
    
    2°The ©reaping pollution ©f th© air in spite of all thej elaborate
    and ineffieient  remedies^ sk©uld be ©au&e to delay asssy !su@h
    as thisp  sisa©® the next step will be large real ootat® c
    
    3° Near saturation of the prases^, highways with traff i© and the
    comitaat  nois® and ©onfusion0
    
    4° Exp®ri®saee shows that su©h developments incr©as© the: already
    excessive taxes  of those persons already lining her®0  ;
    
    5° He®dHess  ©spenditur® ©f energy and m aterials that had better
    be directed  else^3her©0
    
    6- Jobs and  use  ©f materials that this operation w@uld produce' had
    far better be expended in the already assisting slBas and blighted
    areas of  the incorporated communities t$i©r© streets^ schools^ firo»
    fighting  facilities,,  hospitals^,  s®^e2?s0  wat®r0 ad infiraitura now
    ar© available in l©cati©M wher© treansp@rtation to ^©ifkp et©0$ is
    a minor p5?@blemo                                        |
                                                            i
    7° The  losg  ©f the  Aliso and Lagmsa watershed with the :sceni@
    values  n©w re©ognized by such gr@ups as  the  Laguna Greenbelt
    should  receive adequate ©onaideration0 Many ©omraunities in th©
    parts of  country where  thes® values have be©n lost are TOW finding
    it neesssiiry to  spesad millions of dollars to recreate^ ;if possible^
    just su©h natural  amenities0
    Signed= Henry M
    
    bmw
                               Chairman  Environment Preservatioa0
                        _
        Interested partie¥
                               9-192
    

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                        post office box 1132,  laguna  beach,  California
                                                    REGIONAL HIOAR1NG CLERIC
    
                                                         MAR 2 0 1975
    
                                                           REGION DC
    
    
                                                     19 March 1975
    U.S. Environmental Protection Agency
    Attn:  Hearings Office,   HE 118
    Region IX
    100 California Street
    San Francisco, Ca  94111
    
    Gentlemen:
    
    We have reviewed the Draft ElS on the Aliso Water Management
    Agency Proposal for a Regional Wastewater Treatment System
    and submit the following Comments:
    
    
    Our Organization supports EPA1a  Alternates 1 - A and 3-C,
    in view of their far greater sympathy for the environment.
    We strongly approve of the Mitigation Measures called for
    by EPA in corollary to any proposed system.
    
    We recognize the need for improvement and upgrading of our
    local wastewater.management system, but we feel that the pro-
    posed AWMA plan is conducive to encouraging development and
    with it .the consequent further deterioration of our local
    Air Quality.  Little-concern is shown by AWMA in preservation
    of Open Space, which is another vital factor in maintaining
    air quality.
    
    Appreciation to.EPA for their,fine efforts in bringing to
    the public awareness of concerns in connection with the pro-
    posed. AWMA Project.
    Sincerely,
    
    
    BOARD OF DIRECTORS
    
    CITIZEN'S TOWN PLANNING ASSOCIATION
    W. H. Vernor, Jr.
          President
                                   9-193
    

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                                                                                        MAR 21.  19/5
                                                                                           REGION IX
             Naiuie
     PRESIDENT
       James G»lliver
       1223 S. Palm Ave.
       San Gabriel, Ca. 91776
    
     VICE PRESIDENT fc MEMBERSHIP
       George Peters          rmiv
       120 E. Rose           EPA
       La Habra, Ca. 90631
                                        1260 Cliff Dr., Laguna Beach, Ca. 92651
                                        March 22, 1975
         , Hearings Office
    HE 118.  Region DC
    100 California St.
     SECRETARY
       Dorothy Millunchick
       11722 Darlington Ave., Apt. 2San Francisco,  Ca.  94111
       Los Angeles. Ca. 90049
     TREASURER
       Eugene Brand
       81 W. Calaveraa St.
       Altadena, Ca. 91001
    
     MEMBER-AT-LARGE
       Frances Cramer
       766 Obispo Ave.
       Long Beach,  Ca. 90804
    
     OUTDOOR CHAIRMEN
       Yvonne Ash
       6956 Goodland Ave.
       No. Hollywood, Ca. 91605
    
       Ray & Frances Comport
       104 Spindrift  Dr.
       Portuguese Bend, Ca. 90274
    
     INDOOR CHAIRMAN
       Lorayne French
       8715 E. Hermosa Dr.
       San Gabriel,  Ca. 91775
    Concerned Officer
       Desomount Club urges that the sewage treatment plant on Aliso
    Creek be limited to site  ] (with modifications ) and site 3.
    
       These two areas would :
            1. Minimize the usurpation of land designed for the Aliso
               and Laguna Greenbelts  important to
                   a. recreation
                   b. wildlife
                   c. open space
                   d. geological and archaeological values.
    EDUCATION DIRECTOR, HONORARY
       Roland C. Ross
       388 Dearborn St.
       Pasadena, Ca. 91104
                                  2. Preserve
                                the Aliso and Laguna watersheds.
                                                       tertiary treatment
    CONSERVATION CHAIRMAN
       Evelyn Cayman
       1260 Cliff Dr.
       Laguna Beach, Ca. 92651
    
    PARLIAMENTARIAN
       Jason Walker
       19511 Sunken Trail
       Topanga, Ca. 90290
    
    HISTORIAN
       Kenneth Fitt
       1105 S. 4th St.
       Alhambra, Ca. 91801
    
    PUBLICATION CHAIRMAN
       Toni Steele
       5114 W. 133rd St.
       Hawthorne, Ca. 90250
    
    EDITOR DUSTINGS
       Dorothy Levy
       22246 Victory Blvd., F-323
       Woodland Hills, Ca. 91364
    
    CO-EDITOR DUSTINGS
       Ruth Kempton
       841 Hauseman St.
       La Canada, Ca. 91011
       We  ''support as the only acceptable method
    which would :
            1>  Conserve the water enabling the recharging of aquifers
                and the recharging of aquifers
            2.  Provide a clear stream flow to the ocean.
    
       Xhe 17 acre-site 3 in providing  for projected growth is  encourag-
    ing a density of development which already is  responsible for a
    deteriorating air quality.
    
       We  oppose channelization as seriously disrupting wildlife and -
    plant habitats and destroying natural scenic landscapes.
    
       This decision will affect the quality of life  for thousands of
    citizens  in this coastal area.
    
                                          Respectfully yours,
                                                                Evelyn Cayman,  Conservation Chairman
                                                       9-194
    

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                                                     REfiSGWAl, HKARINCJ GLERIt
    
                                                          MAR 2 5 1975
     United States Environmental Protection Agency
     Paul DeiPalco, Jr. Regional Administrator
     -100 California Street^
     San Francisco, California
    
    
     Dear °fficials:
    
    
    .Thank you for the opportunity to comment on the
     draft environmental impact statement for the
     proposed regional wastewater treatment system
     of the Aliso Water Management Agency of Orange
     County.
    
     GUARD supports proposals for establishment of
     regional reclamation systems for recycling of
     wastewa.ters.
    
     The GUARD committee which reviewed the draft
     statement offers  the following comments.
    
     Section  3.2.1.2.1 is.to us a disappointingly
     inadequate assessment of ocean discharge  impacts.
     Consideration must be given to cumrnulative effects ,
     not ;.only of these proposed discharge lines but of
     thosa  of  adjacent areas, because of the tremendous
    predeicted:growth of this southern California
    megalopolous from San Diego to Los Angeles, the
    fastest  population growth area of-the nation.
    
    Especially,  assessment  should  be considered of
    the Southeast Regional  Reclamation Authority plans.
    
    Our experience has been that installation of ocean
    outfall lines encourages later enlargement  of those
    lines, and also leads to contract arrangements with
    inland areas for  discharge  of  inland sewage,  in
    a  spiral  of  environmental degradation which is
    difficult  to  halt,  once it  has begun.
    
    The pollution of  theGreat Lakes,  major rivers,
    the Mediterranean  Sea,  and  uncontrollable  sludge
    threatening  New York's  coast,  are foundation
    enough for  our request  that tertiary reclamation
    is  the only  environmentally ^acceptable system for
    southern California's preciaus coastal area.
    GUARD applauds the vision of the  people of  San  Clermte
    in providing  tertiary treatment  and use of  recycled
    wastewater,  and asks that all  future  regional
    reclamation systems follow  that  lead,  and meet  quality
    standards of  the Coastal  Conservation  Commission.The
    impact statement should at least  assass theproposals1
    efficiency ija, adhering  to /tho^e  standards.
    Sincerely
                      Lyn
                                    lairma
                                    JARD
                                        9^195
    

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    President
    Carmen Perry
    
    First Vice President
    Judy McCoy
    
    Second Vice President
    Errol Allan
    
    Seeyeitflry
    Julia Chaussee
    
    Treasurer
    Deloris Roberts
                          Irvine   Teachers   Association
         March 24,  1975
    EPA Hearing Office
    HE 118, Region IX
    100 California Street   „
    San Francisco , California
    
    Dear Sir:
                                   94111
         The Irvine Teachers 'Association supports  the Laguna Greenbelt's goal
         to preserve vital Laguna and Aliso watersheds.  The Aliso Wastewater
         Management Project Proposal to build  a  large disposal plant with
         considerable outfall would mar this natural watershed.  As educators
         we realize the importance of an environment suitable for the future
         of our  children.  Consequently, we are  committed to the Greenbelt's
         goals of preserving natural watershed areas with an accent on agri-
         cultural irrigation and clear streams flowing to the ocean.  We urge
         that existing disposal stations be utilized and if necessary expanded
         rather  than see new ones built in  what  is now scenic open space.
         Sincerely,
          armen Perry, President
         IRVINE TEACHERS ASSOCIATION
         CP rsbi
                      190! East 17th Street, Santa Ana, 'California  92T01  (714) 542-3292
                     	           9-196
    

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                       ...  _____________            A 7
                    JUNIOR WOMAN'S CLUB
                     Laguna Beach, California
    March 15,  1975                                 ^  :r, T
                                                   en  > m
    Environmental  Protection Agency
    Hearings  Office            "               •
    HE  118
    Region  IX    .
    1 00 California. Street
    San Francisco,  California 94111
    
                            Re: ALISO WASTE WATER
                               MANA&EIJENT PROJECT
    
    Gentlemen:
    
            We eqncur with  The .Lacuna Greenbelt, Inc8  in
    supporting the alternative proposal which your agency
    has worked out for  this project.
    
            We reject the proposal  of 1  enormous,  ugly
    treatment plant and favor the  smaller, dispersed  plants,
    accent  on agricultural irrigation and a clear stream  •
    system' flowing to the  ocean.   In summary,  we  feel this
    project should be compatible with the Greenbelt and
    preserve  its natural environment.
                           Very  Truly  Yours,
                               '
                                                  /••••
                                   ~  "
                            (Mrs.) JSheTTy  Stephens
                            Chairperson,
                            Conservation Committee
                            Laguna  Beach Junior  Woman's  Club
    AW: aw
                             9-197
    

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    Organized November 1947, to co-operah^, bringing about the greatest possible eeonomiei, coK_*ent with efficiency, in eipendituret of Public Funds.
    
                    IAGUNA BEACH TAXPAYERS' ASSOCIATION, INC.           /f 5
    
                    P. O. BOX 404           LAGUNA BEACH, CALIFORNIA 92652
           Mr. Paul De  Falco                              March  1^,  1975
           Director, and
           Mr. Covington
           U.S. Environmental  Protection Agency, IX
           100 California Street
           San Francisco, Calif.  9^111
    
           Gentlemen:
    
           Enclosed please  find the  response concerning the Federal
           Environmental Impact Statement for the AWMA, Aliso Water
           Management Agency of Orange County, Cal.
    
           While we were not selected  on the distribution of these
           E.I.S reports, we feel that we should have beenl  The
           Laguna Beach Taxpayers' Assoc. Inc. is one of the oldest
           established  organizations in Orange County, since 19^7-
           We noted several organizations on the distribution list
           received tv/o copies, and  many are not incorporated also
           mentioned on this list.
    
           We have requested time to present our public prepared
           statement at the scheduled  EPA public hearing on March 25,
           1975 to be held at  the Federal GSA Building 2^00 Avila Rd.
           Laguna Niguel, Cal. from  Dr.  Mack Wesner, Clean Water
           Consultant, 2232 S.E.  Bristol St.  Suite 210, Santa Ana,
           Calif.  92702.  We have also sent Dr.  Wesner our response
           as he was listed as a  consultant for this project.
    
           If necessary, we wish  to  also make this request from you
           in order that the L.B.T.A.  will be given time to make the
           prepared statement  concerning this report at the above
           scheduled meeting.
    
           Thank you,
           Sincerely,
           JAMES C.  YANCEY
           President                                    JY/mwm
                                          9-198
    

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                                                           A13-'-'--'-'  '•'••''W
                                                                "'w,-, ~n  -,   .s.'i f
                      LEISURE WORLD - LACUNA HILLS                   REGIONAL^^NG CLERK
                                                                     MAR 2 0 1975
                                                                       REGION IX
                                               March 18, 1975
                                               Ref: Admin. #75-59d
     U. S. Environmental Protection Agency (3)
     Attn:  Hearings Office HE-118
     Region IX
     100  California Street
     San  Francisco, California 94111
                        Subject: Draft Environmental Impact Statement
                                 D-E. P. A. - 24011-CA
                                 Aliso Water Management Agency
                                 Regional Wastewater Treatment System
    Gentlemen:
    The official Leisure World Community comprised of approximately 18,000
    adults has supported the concept of a regional treatment system to serve
    the Saddleback area in support of A.W.M.A. since it was  initiated by the
    California Regional Water Quality Control Board, San Diego Region, back
    in early 1972.  Most recently the community's official representatives
    supported by its  technical staff and a knowledgeable committee of competent
    engineers who are also residents of the community, have  reviewed the Draft
    Environmental Impact Statement prepared by U.S.  E. P. A.
    
    All parties involved in the preparation of this document are to be congratulated
    on its completeness, particularly with reference to  the associated environ-
    mental impacts involved.  It is clear that all alternates to provide a safe
    economical method of treating sewage wastes with final disposal to the ocean
    have  been carefully considered,  including the many  associated enviro.nme.ntal
    impacts involved.
    
    In behalf of this community this is to advise you of its endorsement of Aliso
    Water Management Agency's  recommendation of the construction of Modified
    Alternate 2-F, which includes a gravity interceptor flowing from the El
    Toro Area, along Aliso Creek, to Moulton Parkway as it provides a regional
    system with central treatment and ocean disposal of most  treated wastes.
    However, we are advised and could concur, after evaluation of secondary
                                       q-199
                                  HIUS, CALIrOffhnA
    post orncf HOX ???o. IACUNA HIUS, CAitfOftwX 91653-if.IEPHONE IAREA 7u) 637-3550
    

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    U.S. Environmental Protection Agency                      3/18/75
    Attn. :  Hearings Office HE-118                              Page 2
    impacts, that Alternate 1-A may be acceptable, providing a grant would
    be available for the higher construction cost of this alternate.
    
    We are greatly concerned over the increased costs of the project due to
    inflation, etc.,  caused by delays over the past few years.  We sincerely
    hope a suitable grant can now be awarded to help solve a critical problem
    we now have  and to help  solve future problems.
    
                                             Very truly yours,
                                             Robert L.  Price
                                             Administrator
    
    RLP/nrh
                                     9-200
    

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                                                                                    AI20
                                                                   ^e/'ji'O'A :\
                                                                CO MM. CENTER
                            P.O.  BOX  357 • 61 tORO • CAllf.
    
                                                                          MAR 25
                                                    March 19, 1975
                                                                           REGION ix
    
    
     U.  S.  Environmental Protection Agency (3)
     Attention:  Hearings Office HE-118, Region IX
     100 California Street     '
     San Francisco, Ca. 941H
                    Subject:  Draft Environmental Impact Statement D-EPA-2JW)11-CA
                              Aliso Water Management Agency
                              Regional Waste Wate'r Treatment System
     Gentlemen:
    
     The Saddleback Area Coordinating Council representing the preponderance of
     existing unincorporated communities to be served by the proposed regional waste
     water  treatment system has monitored with great concern the development of
     proposals which are now being heard by your agency.  Our representatives have
     reviewed the draft environmental impact statement prepared by/for you.
    
     The Executive Board of SACC has listened to presentations made by the Aliso  *
     Water  Management Agency.  It has considered the impact of the AWMA proposed
     facilities  construction upon the trails system and open space programs initiated
     and sponsored by SACC over the past three years.
    
     It  is  clear to us that the upgrading of our sewage treatment facilities is a
     matter of necessity.  It is also clear to us from an economic viewpoint that one
     alternative proposal stands out clearly as the most desirable.  From an ecological
     viewpoint however it is far from acceptable; with certain tradeoffs a palatable
     resolution may be achieved.
    
     The Executive Board of SACC,  sitting in an extra-ordinary session March IS,  1975,
     voted  unanimously in favor of endorsement of Modified Alternative 2-G (itself a
     further modification of Alternative 2-F), with the following provisos:
    
     That the AWMA acquire sufficient usable level ground to the west of their
     proposed creek bed re-location site to provide for the full triple trail system
     parallel thereto (a description of that trail system is found in the Aliso Creek
     Study  Team Report of 1974).  Further,  that a perpetual easement be provided to
     the County of Orange for public transit of the area in the use of the trails.'
    
     That the area of the narrows  in the Aliso Creek Channel (canyon) immediately
     downstream of the existing facility remain fully accessible for trail usage
     and unimpeded by road,  structure or other improvement.
    
     That a limiting factor be exercised with regard to the establishment of a
    maintenance road to these facilities so that it may be used by emergency
    vehicles only (except during  the period of construction of the new facilities).
                                          9-201
    

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                                        Page 2
    U. S. Environmental Protection Agency (3)
                                    March 19, 1975
    We are addressing this to you to express both the public awareness of the need
    for upgrading our sewage treatment facilities and its recognition of a sincere
    desire to provide open space amenities to succeeding generations.  We ask that
    you consider these factors in the entirety in providing a grant sufficient to
    enable the task to be accomplished with immediacy and adequacy.
    Respec;
         Bohay,
    SADDLEBACK AREA
    COUNCIL, INC,
    Copies to:
    
    SACC Review Board
    Aliso Water Management Agency
    Orange County Aliso Creek Task Force
    H. G. Osborne, County of Orange
      Director, Environment Management Agency
                                          9-202
    

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                                                                   REGIONAL HEARING CL.KKK
                                                                        APR 1 5 1975
                                                                          REGION DC
                SAN  DIEGO  AUDUBON  SOCIETY,  INC.
                          BRANCH OF THE NATIONAL AUDUBDN SOCIETY
                                                                3942  Hughes Court
                                                                San Diego, Ca. 92115
                                                                12 April  1975
                                                                File No. D-EPA-24011-CA
    Environmental Protection Agency
    Region IX
    100 California Street
    San Francisco, Ca. 94111
    Att'n:  Hearing Officer, HE
                            118
    This Society opposes EPA participation in the proposed  Aliso Water Management Agency
    Wastewater Treatment System propject,  primarily because it would be growth-inducing
    in ah area that urgently needs growth  stabilization at  the very least.
    
    The projected increase in vehicle traffic alone is  sufficient  reason for EPA not to
    participate.  This, particularly because the  indications are that nothing is really
    going to be done, in the apprent future, to reduce  vehicle emissions, or to bring about
    truly non-polluting vehicles.
    
    Even a scaled-down project should be postponed until whatever  coastal authority and
    policy comes out of the present coastal commission's recommendatios and the State
    Legislature's reactions to those recommendations, goes  into effect.
    
                                                         (^\~^) Sincere!
                                                         V_/2o<3-c^ufc.
                                                               Roscoe A. Poland
                                                               Conservation Committee
                                            9-203
    

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            SIERRA CLUB                           _;  \   v "
    
            ANGELES CHAPTER                  . :v"v  ,VNTER
    
            ORANGE  COUNTY GROUP      ^ij  M53H{
                                       9#32 Harriet  Lane
                                       Anaheim,  California  92704
                                       April «,  1975
    
     EPA
     Hearings Office, RE 11$, Region IX
     100 California Street
     San Francisco, California   94111
    
     Gentlemen:
    
         The Laguna Greenbelt is important to t he  people of Laguna.  It is
     also very important to the rest of Orange County.
    
         We, in Orange County, are already hopelessly entangled  in the
     problems of congestion, pollution,  noise, and  crime  - all evils of too
     much growth, too fast.  Such "progress" makes  the rich  richer, and the
     general public poorer, both spiritually and  environmentally.  It is
     past time to hold the line against  the exploitation of our natural re-
     sources by a relative few and give  highest consideration to what is best
     in t he long run for the majority.   When we err,  let  us  err on the side
     of restraint, and leave some environmental decisions for those who will
     follow.
    
         With these thoughts in mind, t he  Orange County  Group of the Sierra
     Club goes on record in favor of any proposal that would insure the
     integrity of the Laguna Greenbelt.   Since the  preservation of the La-
     cuna and Aliso watersheds is vital  to  the whole  concept, any worthwhile
     plan should guarantee these agreas  full protection.   The large treatment
     plant and outfall is not acceptable for several  reasons.  It is too ex-
     oensive, it is not needed, and, most important,  it would serve to in-
     duce further development of the Greenbelt.
    
         We, therefore, support the EPA proposal which in our mind comes the
     closest to assuring the above,  and  urge anyone with  the public interest
     in mind to do likewise.
    
                                            Sincerely yours,
                                                                  ,
    
                                           Herb Baasch, Conservation Chairman
                                           Orange County Group
                                           Angeles Chapter
                                           Sierra Club
    HB : ji
                                       9-204
    

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    TEMPLE   HBLLS  COMMUNITY  ASSOCIATION
    1940 SAN REMO DR., LACUNA BEACH, CA. 92651                  TELEPHONE 497-2218 «  494-5383
                                                     March 23, 1975
     Director
     Federal  Environmental Protection Agency
     San  Francisco,  California
    
     Dear Director!
    
                The Temple Hills Community Association opposes any plan
     which would  destroy the basic residual water supply of the Laguna
     Greenbelt  and its  two watersheds--Aliso and Laguna Canyon water-
     sheds.   We support a coupling of open space preservation with
     maximum  water conservation.
    
                In our opinion this objective can best be assured through
     several  small dispersed treatment plants which would enhance agri-
     cultural irrigation and would provide a clear stream flowing to the
     ocean.   We are  opposed to the establishment of a gigantic treatment
     plant.   Not  only do we feel  that this would be unnecessarily costly
     but  it would destroy the quality of our environment.
                                      Sincerely
                                      Tom Alexander
                                      Chairman
                                      Ron Chilcote
                                      Coordinator
                                       9-205
    

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    THE LAGUNA 6REEN6ELT, INC.
                                REGIONAL HEARING —.IRK
    
                                     MAR 2 1 1975
    
                                 ...     REGION LX
                                                                          '
    a non-profit corporation Box 1611, Laguna Beach, California, 92652  n.'fi 7|   JJf co f-M '
                                                  March 19,  1975
                                                 For:  AWMA Project Hearing,
                                                      Maroh 25
                      US Environmental Protection Agency
                      Region IX
                      100 California Street
                      San Francisco,  CA  94111
    
                      Gentlemen,
    
                           The  Laguna Greenbelt,  Inc.,  appreciates  this  opportunity to comment
                      on the Draft EIS prepared  by EPA on the Aliso Water Management Agency
                      Proposal  for a Regional Hiastewater Treatment  System.
    
                           Following our  review  of the  EIS prepared by AKUA on  its  project, we
                      expressed a  number  of concerns  that have been further justified  by  the
                      EPA draft document. Two of these  major concerns are:
                              a)  Deterioration  of Air  Quality due  to encouragement of
                                  further growth and  development, appreciation  of land
                                  values  and generation of more VMTj
                              b)  Physical  impact of  construction of proposed treatment
                                  facilities in  the Aliso and Laguna Greenbelts.  AWMA
                                  chooses to ignore the faot of the designation of  these
                                  areas as  Open  Space in the Open Space  and  Conservation
                                  Elements  of the General Plans of  Orange County  and the
                                  City of Laguna  Beach.
    
                          Recognizing the  need  for improved wastowater management  in  this  araa,
                     we  strongly  support consideration of two of the alternatives  suggested
                      by  the  EPA Draft EIS:
    
                               Ideally,  the advanced tertiary treatment  system outlined  by
                               alternative 3-C is most desirable in terms  of minimizing  adverse
                               environmental effects.  However, its associated  high cost  and
                               large  new plant requirements make this choice somewhat  less
                               attractive.
    
                               With a more conservative  approach calling for expansion of
                               existing treatment facilities, Alternative 1-A  is felt  to be far
                               more  sympathetic  to the  environment than the ATfMA Plan.
    
                          Tie would hope the EPA  in its  ensuing studies would opt for a combination
                     of  best features  of 1-A and 3-C,  aimed at maximum reclamation, land treatmeit
                     snd  recycling of pollutants. Elimination of ocean outfalls and replacement
                     by  clear stream  outflow are vital goals for achievement.  Greater  emphasis
                     on  land treatment and agricultural  irrigation can facilitate  this objective
                     and  provide  economic gains  as well. We also support the various mitigation
                     plans suggested by EPA as a corollary to their alternatives.
    
                          Inoonolusion, we commend EPA on their in-depth study of  our wastewater
                     management problems. Their EIS can help to inform the public  of dangers
                                9-206
    

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    LAGUNA GREENBELT. INC.
              a non-prof it corporation Box 1611, Laguna Beach, California, 92652
    
                  Tot EPA
                  For Hearing. Maroh 25,  1975
    
                  p. 2
    
                  inherent in funding unrestricted,  development-inducing major public works
                  at a time when if* need  to consider how  to maintain our environmental
                  quality while satisfying our  other basic needs.
    
                       Supplementary data will  be submitted at  the Hearing.
    
    
                                                          Sincerely yours,
                       By/
                         .';
            l\J. yUt^^U                  BOARD OF TRUSTEES
    James W. Dilley   I                  TEE LAGUNA GREENBELT,  INC.
      President      /
                                           9-207
    

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    REGIONAL^HKARING CLERK
    
    
    
    
          APR 4   1975
    
    
    
            REGION DC                                             /
                                      9-208
    

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    /   -
    j>7Wteiune:
                                                  RECEIVED
                                           BSGIONAL HEARING CLEStK
    
    
                                                 APR  8  1975
    
                                                  BEXHONJX
                             9^209
    

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    *s4*^-*s
    <*^
                                                                    A Q o
    /0*+-&
    
                         9-210
    

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           2 4 \S1     '        -T Via Puerta
           **'*"*        Laguna Hills, California 92653
                          March 21, 1975
     Environmental Protection. Agency
     Hearings Office,  HE 118,  Region. IX
     100 California Street
     San Francisco, California 94111'
    
     Gentlemen:        '
    
          I  have long  been a supporter of the La,-
     guna Oreenbelt, with the  conservation of nat-
     ural resources included strongly  in its values;
     and 1 "believe in  the urgency of preserving the
     Allso and Laguna  Water sheds.            .-n
    
          For these reasons I  \vish to  express my '
     view in favor of  the alternative  E?A proposal
     on 'the  Aliso  Vvastev.'ater Manageiuent Project.
     which would assure  the preservation of. these.
     watersheds, would include  smaller,  dispersed
     treatment plants  in place  of  the  formerly-
     proposed . single large treatment plant.,  and
     would place emphasis  upon  agricultural  irri-
     gation'  and  a  clear  stream  s.ya.t.em^. flowing to
     the  sea.
    
         Thank  you for  adding  my  letter  to  those
     filed in the  formal hearings  (to  take place
    March 25) if  it is  at  all  possible  to do  so.
                         Yours very truly,
                         Helen F. Brockmeier
                   9-211
    

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                                      1355 Terrace rfay
                                      Lnguna neach, California  92651
                                      frarch 16, 1975
    iii'A, Hearings Office
    Ilti 118, Region IX
    100 California Street
    oan if'rancisco, California  .94111
    
    Gentlemen:
    
          The Aliso and Lsguna Canyon Watersheds will go on the market next
    week.  Unless sufficient support for the KFA propose 1 is shown, the basic
    and residual water supply of these lynds will undoubtedly be destroyed.
    I am writing to ask you to urge the Aliso wastewater Management i'rogect
    to support the preservation of our dwindling natural resources.
    
          Maintaining the present condition of these immediate watersheds of
    the Laguna Greenteelt Area is vital.  The situation will be made much worse
    by construction in Aliso of an enormous 3/4 mile long treatment plant
    with its costly outf .-• 11 system.  Current levels of oollutents in our coastal
    waters necessitates plcns for clear stream systems flowing to the ocean.
    Possible agricultural irrigation with wnsteweter products represents the
    kind of positive direction we must pursue in our struggle to preserve
    rather than destroy ourselves.  An equj.lly basic concern in this struggle
    worth mentioning rngy be the increasingly rare opportunity of on investment
    thc'.t would further the preservation of the beauty that this land affords
    us in open space.
    
          It seems to me that construction of smaller and more dispersed
    treatment plants would assure adequate conservation of the Laguna and Aliso
    water resource.
                                      Very truely jours,
                                      John N. Daniel
                                           9-212
    

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    f
                        f
    
                                                  c_n
    
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             dfas%
               "*•
    9-214
    

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        s? -   /•?-—. // v   •—T~~/'- -  XX/7
    ^^^?-x^^r-^-N  J^^€  ^t-
                         -^ ^C^zft^-*/
    C/^-C-x^
                        fr^s^y^-t^(
          9-215
    

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                                             -flit
                     "
      nA****
     9-
    ^^w*-^ sCl*^,
                    9-216
    

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      BETTY HECKEl
      290 Dolphin Way
    Uguna B..ch, CA 92*51
                                                                           /- 1 i
                                                              3-19-7 ?
               ;?e:;eral  Environmental  Protection
                       B Office HE  118, Kepi on IX
               100   California St.
               San  Francisco CA 94111
               Gentlemen.
    
               The Alioao  Wastewnter Management intend^ to  build p tic- i  cot
               plant  3/4 mile long in  the  Alirac Canyon,with the treM-3  v\nter
               fcing  i ^to  the ocean.
    
               I vvisb  to. object to tbig' projectrb cau;: e it v.oul; i-  locricj
               • i f) the  Alisae and Laguna  watersbeds,witb . tbeir .^r-i.-'ic   ?n3
               residual water supply,          ..       .  •'.   ,,.'......,  P,..v
                .  .'  the  treated'water,  would  go into  tbe' oce.an,f;,;.Auc^  Y.ilT
                    pollute tbe ocean,                       ,,..' r.1.., ;•'
                    tbe  treated water  is needed for  irripation,
                    if  not for irrigation-, i t sbould  go >rck to  r . . icultui tf i
                    l&nd,becaUfee it comes  rfiilee from  Colornt^Pf^o.' \->  ulcj  It-
                    used over "fipaioj                            Toi^'A
                    there  should be. small  treatm6oti.plao:ts s^at'l; ~. i~d  r-;rcur.c'f
                    to ;se<>ure irrigation in  tbe c'o-ufttry floe*   " J'-
                                                     • .     -:'•'• • .; '.   •"; HC'
               I wipb-t.-p Soptiorli tbe FPA prep'oeal, thr, t  e;?,n- ^.:: rrbO'c^ (t be
               reservation of tbe watershed areas  '-ptt^ 'prevcn'f-"' 't'^ve-  encnrour
               treatment nlant in Aliso  with an outfall into tbe ocean.
                                                            U   f(
                                      9-217
    

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      BETTY HECKEL                                                       f) 4 7
      290 Dolphin Way
    Laguna Beach. Co. 92651                                         '
               U. St. Environmental Protection Ageo^ 7  II 57 AiM7r
               Region IX                                   J Nn 'J
               100  California St.
               Sao Praocisco CA
              Dear Mr.de Palco Jr.
    
              Tbaok you for  the most  inter  sting environmental impact
              statement,wbicb I read  very careful and  attended one  bearing
              here as well.
                     May I suggest, to  build  several  small plants instead
              of tbe planned giant plant 3/4  mile long in   Aliso Canyon.
              Tbe small plants could  accomodate  tbe surrounding agricultur-
              al areas better by  irrigating tbf1  surrounding acres witb
              tbe reclaimed  water,insteadvlending it  off  into tbe ocean.
              Tbis kind of operation  will be  higher money  wise,yet
              saving tbe ocen from runoff water  and irrigate agricultural
              land sbould be more important to be considered.
    
                      By all means I  wish to  object strongly against tbe
              location of tbe giant plant*  if really  approved, in tbe
              Aliso Canyon.  Tbe  Aliso  canyon,tbe moot scenic valley
              in Orange County, is part of  a  greenbelt corridor, wbicb is
              supposed to be connected  witb tbe   Cleveland Forest.  How
              can such marvelous plan be accomplished, when a 22 acres
              plant 3/4 of a mile oog will  be located  io  tbe proposed
              greenbelt area ?
    
                                                   Very truly
    
    
                                              -~"
                                   9-218
    

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       BETTY HECK&
      290 Dolphta Way
    Laguno Beach. Co. 9265l
                  U.3.r;'nvironmeotal Protection Agency
                  Attn: Hearings Office
                  HE 118, Region IX,                      AO CLERK
                  100  California St.                              CLERK
                  Sao Francisco CA 94111                 APR g  1975
                                                           REGION DC
                 Dear Agency members.
    
                 Re:   Waste  Watt r Plant in  Aliso Creek,Scutb  Ir-
    
                 After another hepring before tbe AWtdA Board of directors
                 I  wisb to object rr.ore strongly against tbe  location
                 of tbis  plant 3/4 of a mile long
    
                     in tbe greenbelt area, which will be  connected
                     wit'1  tbe Cleveland Forest ,accorfli ng to  tbe General  FIFO.
    
                     The existing Golf Course is in aanger,  becau1 e  a
                     8(:rvice  road bas to be built around or  tbrour.b  the
                     Gblf  Course.
    
                     Tbe slugtfe murt be bauled awa.y daily  from  Fei t-i 1 iiser
                     plants or be- brought to tbe dump by 20  ton trucks,
                     between  3-10 times a c'ay.
    
                 Tbe  County  of Orange Environmental Management Aftncy in
                 Santa Ana bad 7 other sites , f.i.Salt Creek,sue^er-- ted,
                 wbicb seem  mere suitable.
                                   9-219
    

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    30
                        9-220
    

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                                      ft 81
    9-221
    

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     SL,
    1^'   *
                                               MAR 19 1975
                     9-222
    

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                                 RAY M. MOOSE, M.D.
                                  783N VIA LOS ALTOS
                              LACUNA HILLS, CALIFORNIA 92653
                                       3/16/75.
     To:  The Federal EPA,
    
       San Francisco, Ca.      Re:
                                     The EPA Hearings on Aliso Wastewter
                                     Management Project, March 25th,
    Dear Sirs:
    
               We  the  undersigned,  seeing the ever increasing need
    
     for conserving the  resources in our county, urge you to:
    
        !•  Support the  Laguna Qreenbelt in its far sighted con-
    
    servation efforts, specifically the preservation of two vital
    
     immediate watersheds,  the Aliso and Laguna Watersheds.
    
    2.  Support the EPA  proposal that can assure the above and pre-<
    
     vent the enormous treatment plant (3/U mile long)' in Aliso and
    
    the costly outfall system.
                                          smaller
    3«  Support the EPA  proposal that can assure/and dispersed plants,
    
    accent on agricultural  irrigation and a clear stream system flowing
    
    to the oceon.
                      Signed:
                                    9-22?
    

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                                          :^T  :V  r;.p-&
                   WILLIAM ROBERT SUDDABY       ^c J "~5 * '£
                      128 CEDAR WAY         COMM CtNTtR
                LACUNA BEACH, CALIFORNIA 92681
                                            .7   IU29W75
                                   April  1,  1975
    'Environmental  Protection Agency
     1000  California  Street
     San Francisco, California
    
     Dear  Members:
    
          I  strongly  support  Alternate  Plan 1A  for
     the All so  Canyon sewage  plant.   It is  an area
     of much natural  beauty in my  community to  be
     valued and cared for  in  the greatest degree
     possible.
                       Most  sincerely,
                             9-224
    

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                   MRS. R. M. THOMPSON
                       3IZ5I BROOKS ST.
                     SOUTH LACUNA, CALIF.
                           92677
      #£=-//?.
                      / Xf
       r'i c '.: •• •'.'> \  i X.
    COVtt  Crlf
                                             24   3  joPM1 75
    /o
    
                            9-225
    

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                         9-226
    

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                          MRS. GERALD A. WOODS
                          137 C AVEN1DA MAJORCA
                        LACUNA HILLS, CALIF.  92633
                                                              /112
      <  ('
                            /x
                                                  RECEIVED
                                            REGIONAL HEARING CLERK
    
                                                 MAR 2 0 1975
    
                                                   REGION IX
    
    &&L
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                                 f ^*~ j^=*-	—^  r-     / ',
    
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         1-       ,  izJ&<£*«.* a~k-
    ^^i^JlAMvU^l^ C*
                               9-227
    

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                                BIBLIOGRAPHY
    GENERAL
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              _, December 27, 1973.  Environmental Opportunities Workshop
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                                      10-1
    

    -------
         	,  1972.   Engineering Plan and Report on Plan of Works of Sewage
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               ,  1972.   Engineering Plan and Report on Plan of Works of Sewage
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         	,  1974.   Engineering Plan and Report on Revised Plan of Works
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         	,  1972.   Engineering Plan and Report on Plan of Works of Sewage
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               ,  1972.   Engineering Plan and Report on Water Distribution,
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         	, 1973.  Feasibility Report for Water Quality Improvement
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               , 1963.  Preliminary Sewerage Survey for the El  Toro, Los
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    Brown and Caldwell, 1973.  Water Reclamation Feasibility Study and Prepara^
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    California Air Resources Board, 1970. California Air Quality Data, Vol.
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              ,. 1973.  California Air Quality Data, Vol. V, No. 1, 2, 3.
    
    •	, 1973.  New Vehicle Standard Summary.
    
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    California Division of Highways,  1972.   Air Quality Manual  - Motor Vehicle
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    California Department of Human Resources Development, 1973.   Employment
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              , 1973.  Employment by  Industry for Cities in Orange  County
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                                        10-2
    

    -------
               ,  1970.   Estimated  Numbers of Wage and Salary Workers in Non-
          Agricultural  Establishments, by Industry, Anaheim-Santa Ana-Garden
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     California Division of Finance.  Population Research Unit, 1974.  Population
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     California Division of Mines  and Geology, 1973.  Gee-environmental Maps
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              _,  1974.   Geology and Engineering Geologic Aspects of the San
         Juan Capistrano Quadrangle, Orange County, California, Special
         Report  112.
    
          ...'   ,  1974.  Geology of the South Half of the El Toro Quadrangle,
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         	,  1973.  Urban Geology.  The Resources Agency, Bulletin 198.
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    	_, 1974i  Orange County Labor Market Bulletin (issued monthly).
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    	, 1974.  Wage and Salary Workers in Non-Agricultural Establishments,
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    California Regional Water Quality Control Board, San Diego Region, 1969.
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              , 1970.  Addendum No. 3 to Resolution 67-R33.
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    California Regional Water Quality Control  Board, San Diego Region,  1972.
         Resolution Concerning the Need for Immediate Faction for Planning
         and Construction of Water Quality Control  Facilities for the Aliso
         Creek and Laguna Creek Drainage Basins.
                                        10-3
    

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              _,  1974.  Waste  Discharge  Requirements for Aliso Water Manage-
          ment Agency  Ocean  Outfall,  Order  No. 74-72.
    
         	,1974.   Waste  Discharge  Requirements for the City of Laguna
          Beach Ocean  Outfall,  Order  No. 74-98.
    
               _, 1974.   Waste  Discharge  Requirements for South Laguna Sanitary
          District Ocean  Outfall.
    
     California  Regional  Water  Quality Control Board, Santa Ana Region, 1973.
          Rossmoor Sanitation,  Inc., Cease and Desist Hearing - Order No.
          74-160.
    
     California  Regional  Water  Quality Control Board, 1974.  Waste Discharge
          Requirements  for  Rossmoor Sanitation,  Inc., Order No. 74-5.
    
     California  State Resources Agency of California, 1973.  Guidelines for
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               , 1965.  An  Investigation of the  Fate of Organic and Inorganic
          Wastes  Discharged  into the Marine Environment and their Effects
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         	,  1972.  Guidelines for Technical Reports and Monitoring Programs.
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          of Public Hearing.
    
              _,  1971.  Water Quality Control Plan (Interim) San Diego, Basin
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               , 1971.  Water Quality Control Plan (Interim) Santa Ana River,
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         	, 1972.  Water Quality Control Plan for Ocean Waters of California,
    Chapman, Phillips, Brandt, Reddick and Associates, Inc., 1974.  General
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    	, 1974.  General Plan for Rancho de Los Alisos.
              _, 1974.  General Plan for Rancho Serrano.
    
              _, 1974.  General Plan for Moulton Ranch.
    
              , 1974.  Moulton Ranch Noise Element; Irvine, California.
    City of Irvine, 1973.  Census Enumeration - Final Report.
    
    	, 1973.  Community Profile - Spring 1973.
                                        10-4
    

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               ,  1974.   Housing Implementation  Plan  -  Phase One.
    
               ,  1973.   Employee Survey  of  Irvine  Industrial  Complex West.
     Council  on Environmental  Quality,  1974.   Interceptor Sewers and Suburban
          Sprawl.
    
     County of Orange,  1973.   Orange  County Local Park Code.
    
     Danielian, Moon, Sampieri and  Ilg,  1973.  Orange County General Plan,
          Capistrano Valley Area  1983 Land Use Element.
    
     Don  Owen Associates,  1974.   Project Report, Aliso Water Management Agency
          Regional  Wastewater  Treatment  Facilities.
    
     Fay,  E.  C., 1972.   Southern  California's Deteriorating Marine Environ-
          ment, Center  for California Public Affairs.
    
     Fay,  Rimmon C., 1972.  An Evaluation of the Health of the Benthic Biota
          of  Ventura, Los  Angeles and Orange Counties prepared for the Southern
          California Association  of Governments.
    
     Federal  Home Loan  Mortgage Bank, 1964-1974.  Monthly Newsletter.
    
     Federal  Highway Administration,  1972.  Noise Standard and Procedures
          for Implementing Section 109.  Title 23, U.S.C.
    
     Galloway,  W. S., W. E. Clark, and J. S. Kerrick, 1969.   Highway Noise"-
          Measurement,  Simulation and Mixed Reactions.  Highway Research
        . Board,. National  Cooperative Highway Research Progress Report 78.
    
     Geolabs-California, Inc., 1974.  Preliminary Grading Plan Review #1,
          Golf  Course Hill, Laguna Niguel, Orange County, California.
    
               , 1973.  Soil  Engineering and Geological  Planning Report for
         Golf Course Hill, Laguna Niguel, Orange County, California.
    
    Highway Resources Board, 1971.  "Highway Noise, A Design Guide for Highway
         Engineers,"  National Cooperative Highway Research Program Report
         117.
    
    Hinton, L., 1971.  Seashore Life of Southern California.  University
         of California Press, Berkeley.
    
    Inman, Douglas L. and Richard Baush, 1973.   The Coastal  Challenge.
    
    Inter-Company Correspondence from Jim Saivar to Don McMullen, May 17,
         1974. Avco Community Developers Inc.  Subject:  Laguna Niguel Buyers
         Profiles, April-December, 1973.
    
    J. D. Drachman Associates, June 1974.  East Irvine Transportation Study.
                                        10-5
    

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     Johns, R. H., 1973.  A Profile of Southern California Geology, and Seis-
         micity of Los Angeles Basin, A.A.P.G.  Annual Meeting Guide Book.
    
     Jones and Stokes, 1974.  Alternative Mitigation Plans to Reduce Poten-
         tial Adverse Air Quality impacts in the AWMA area.
    
     Los Angeles County Air Pollution Control District, 1973. Emission Factors
         for the Average Gasoline Powered Motor Vehicle in Los Angeles.
    
     Lowry & Associates and Engineering Science, Inc., 1966.  Wastewater
         Disposal and Reclamation for the County of Orange, California.
         1966-2000.
    
     Lowry & Associates, 1974.  Amendment to Environmental Impact Assessment
         of SERRA Water Disposal, Orange County, California.
    
     	, 1974.  Project Report for Waste Water Disposal System for
         SERRA (3 volumes).
    
     Magoon, Orville, 1973.  Use of Earth Resources Technology Satellite
         (ERTS-I) in Coastal Studies.
    
     Mearns, A. J., M. J. Allen and M. J. Sherwood, 1973.   An Otter Trawl
         Survey of Central Orange County Coast, Southern  California Coastal
         Water Res. Project Tech. Report TM 200.
    
     Metropolitan Water District of Southern California, 1972.  Report for
         the Fiscal Year July 1, 1971 - July 30, 1972.
    
     Miller, Wade E., Pleistocene Vertebrates of the Los Angeles Basin and
         Vicinity (Exclusive of Rancho La Brea), Bull, of the L.A.C.M.  of
         Nat. Hist. Science No. 10.
    
     Mission Viejo Employment Location Analysis, Mission Viejo Company.
    
     Mission Viejo Homebuyers Survey; Advertising and Buyer Survey, to December
         1970.
    
     Moulton-Niguel Water District, 1974.  Amended Rules and Regulations of
         Moulton-Niguel  Water District for Water and Sewer Service.
    
    National  Academy of Sciences, Waste Management Concepts for the Coastal
         Zone.
    
    North,  W. F., 1972.   A Marine Biological  Survey of Central  Orange County
         Near Three Sewage Outfalls.
    
    Orange  County Administrative Center, Forecast and Analysis,  1974.   The
         INCOM Project:   Employment  by Industry for Sub-Sectors  of Orange
         County.
                                        10-6
    

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     Orange County Air Pollution Control; District, 1973.  Profile of Air
          Pollution Control,  1972.
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          Activity in  the  Unincorporated Areas of Orange County (issued monthly).
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          Orange  County General Plan.
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               . 1973.  State of the County.
              _, 1973.  The Proposed Master Plan of Riding and Hiking Trails
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         General Plan.
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              , 1974.  Dial-A-Ride Analysis.
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         ground, Orange County, California" unpublished  data.
                                        10-7
    

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     Public  Utilities Commission, 1973.  California Gas Report.
     Pollution  Research and Control Corporation, 1972.  Air Quality Study
          Aliso Water Management Agency Area.
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         Ground Motions During  Earthquakes,"   Jour,  of Soil  Mech.  and  Found.
         Div., ASCE,  Vol.  95.
                                         10-8
    

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    Seed, H. B., I. M. Idriss, and F. W. Keifer, 1968.  "Characteristics
         of Rock Motions During Earthquakes,"  Jour, of Soil Mech. and Found.
         Div., ASCE, Vol. 95.
    
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    	, 1974.  The Energy Element for the South Coast Region.
    
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         No. EPA-909/9-73-001; "The Aliso Water Management Agency Study;
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         County."
    
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         (3 volumes).
    
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         Emission Factors.
    
    	_, 1973.  Supplement No. 1  for Compilation of Air Pollutant
         Emission Factors.
    
    United States Department of Agriculture, Soil  Conservaton Service,  1966.
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         of Soil Conservation Service, Tustin, California.
    
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         Administration, Environmental Data Service,  Climatological  Data,
         Summary 1972.
                                        10-9
    

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     United States Department of the Interior,  1972.   United  States  Energy,
          a Summary Review.
    
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     AIR QUALITY
    
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    • •••  • Destinations Survey.  LARTS Base Year Report.
    
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          fornia,  1971  Annual Report.
    
     	, 1972.  Motor Vehicles Emission Data.  Unpublished.
     "Data  Pertaining  to Present Characteristics of the Central Areas of
         Major  Cities."  Highway Research News.  July 1973.
    
     Hazucha, Milan, M.D., et al, September 1973.  "Pulmonary Function in
         Man After Short-Term Exposure to Ozone."  Arch Environ Health,
         Vol. 27.
    
     Jacobs, Cecil F.  M.D., MPH, and Bettye Ann Langdoc, AB, September 1972.
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         Health Services Report.
    
     Levinson, H.S., and F. H. Wynn, 1962.  Some Aspects of Future Transportation
         in Urban Areas.
    
     National Committee on Urban Growth Policy, 1969.  The New City.  Praeger
         Publishers,  New York.
    
     Orange County Transit District, 1974.  County-Wide Research Study.
    
     Public Law 91-608, 91st Congress, H. R. 19436, December 31, 1970.  Title
         VII, Part B, Section D.
                                        10-10
    

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     U.S. EPA, 1973.  Compilation of Air Pollution Emission Factors.
    
    	, 1973.  Compilation of Air Pollutant Emission Factors.  Second
         Edition, Publication No. AP-42.
    
     Wilbur  Smith and Associates, 1961.  Future Highways and Urban Growth.
    
    
     ARCHAEOLOGY
    
     Archaeological Research, Inc., 1973.  A Final Report on the Scientific
         Resources Survey for the Moulton Ranch.
    
     Irwin,  Charles N., 1974.  Laguna Canyon Archaeological Survey.
    
     Leonard, N. Nelson, 1973.  Archaeological  Reconnaissance of the Rancho
         San Juan Capistrano Development.
    
              , 1974.  Archaeological Resources of Proposed Development
         West of San Juan Capistrano (a parcel of Bear Brand properties).
    
              _, 1974.  An Archaeological Reconnaissance of Parcel  2 of the
         Bear Brand Ranch.
    BIOLOGICAL RESOURCES
    
    Abrams, Leroy and Roxana S. Ferris, 1960.  Illustrated Flora of the
         Pacific States. Vol. IV.   Stanford University Press.   Stanford,
         California.
    
    American Ornithologist's Union, 1957.   Check-List of North American
         Birds, 5th ed.  Baltimore, Maryland.  American Ornithologist's
         Union.
    
    Bakker, E., 1972.  An Island Called California.   University of California
         Press, Berkeley, California.
    
    Brockman, C.F., 1968.  Trees of North  America.   Golden Press,  New  York.
    
    Brown, V., and G. Lawrence, 1965.   The California Wildlife Regions.
         Naturegraph Publishers, Healdsburg,  California.
    
    Brown, V., H. Weston and J. Buzzell, 1973.   Handbook of California Birds.
         Naturegraph Publishers, Healdsburg,  California.
    
    Burt, W.H., 1964.  A Field Guide to the Mammals.   Houghton Miff!in Company,
         Boston Massachusetts.
    
    California Resources Agency, 1972.   At the  Crossroads.   Fish and Game
         Commission, Department of Fish and Game.  Sacramento, California.
                                        10-11
    

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    Collins, B.J., 1973.  Key to Coastal and Chaparral  Flowering Plants of
         Southern California.  California State University Foundation,  North-
         ridge, California.
    
    Dawson, E.Y., 1971.  The Cacti of California.  University of California
         .Press, Berkeley, California.
    
    Grilles, S. J., 1971.  Ferns and Fern Allies of California.   University
         of California Press.  Berkeley, California.
    
    Head, W. S., 1972.  The California Chaparral on Elfin Forest.   Naturegraph
         Publishers, Healdsburg, California.
    
    Hoffman, R., 1955.  Birds of the Pacific States.  Houghton Mifflin  Company.
         Boston Massachusetts.
    
    Hutchinson, J., 1967.  Key to the Families of Flowering Plants of the
         World.  Clarenden Press, Oxford.
    
    Ingles, L.F., 1965.  Mammals of the Pacific States.   Stanford  University
         Press.  Stanford, California.
    
    Jaeger, E. C. and A. C. Smith, 1971.  Introduction  to the Natural  History
         of Southern California.  University of California Press,  Berkeley,
         California.
    
    Martin, A. C., H. S. Zim, and A. L. Nelson, 1951.   American  Wildlife
         and Plants, A Guide to Wildlife Food Habits.   Dover Publications,
         Inc.  New York.
    
    Martin, Alexander C. 1972.  Weeds.  Golden Press.   New York.
    
    Munz, P. A., 1972.  California Spring Wildflowers.   University of California
         Press, Berkeley, California.
    
    Munz, P. A. and D. D. Keck, 1973.  A California Flora with Supplement.
         University of California Press, Berkeley,  California.
    
    Murie, 0. J., 1954.  A Field Guide to Animal Tracks.   Houghton Mifflin
         Company, Boston, Massachusetts.
    
    Petersen, R. T., A Field Guide to Western Birds.  Houghton Mifflin  Com-
         pany, Boston Massachusetts.
    
    Petersen, P. V., 1970.   Native Trees of Southern California.   University
         of California Press, Berkeley, California.
    
    Raven, P. H., 1970.  Native Shrubs of Southern  California.  University
         of California Press, Berkeley, California.
                                        10-12
    

    -------
     Robbins,  C.  S.,  B.  Brunn, and H. S. Zim, 1966.  Birds of North America.
          Golden  Press,  New  York.
    
     Santa Barbara  Botanic Gardens, 1969.  Native Plants for Southern California
          Gardens.  Leaflets of the Santa Barbara Botanic Garden, Vol. 1,
          No.  12.
    
     Smith,  R.  L.,  1966.  Ecology and Field Biology.  Harper and Row, Publishers,
          New  York.
    
     Stebbins,  R. C.,  1966.  A Field Guide for Western Reptiles and Amphibians.
          Houghton  Mifflin Company, Boston, Massachusetts.
    
     U.'S.  Department of the Interior, 1973.  Threatened Wildlife of the
          United  States.  Bureau of Sport Fisheries and Wildlife, Washington,
          D. C.
    
               ,  Conservation Bulletin No. 1, Fish and Wildlife Service,
          Attracting  and Feeding Birds.
    
     Zim,  H. S. and A. C. Martin, 1950.  Flowers.  Golden Press, New York.
     ENVIRONMENTAL IMPACT REPORTS
    
     Boyle Engineering, 1975.  Draft EIR for Zone Change 73-18, Dana Point.
    
              , 1973.  Draft EIR for South Laguna Sanitary District Beach
         Interceptor Sewers.
    
         	, 1973.  Draft EIR for South Laguna Sanitary Master Plan.
    Chapman Phillips Brandt Reddick, 1974.  Draft EIR for Northern El  Toro
         Planning Reserves.
    
    Community Science Technology Inc., 1973.  Draft EIR for Laguna Hills
         Business Center.       ..
    
    Culp/Wesner/Cult, 1974.  Draft EIR for the Irvine Lake Pipeline and
         Future Treatment Facilities.
    
    	, 1975.  Draft EIR for Construction of Regional  Wastewater
         FacTRties for AWMA.
    
    Environmental Data Research, 1974.  Draft EIR for Glenn Ranch.
    
    Envista, 1974.  Draft EIR for Tract 8780.
    
    Envista, 1974.  Final EIR on Irvine Industrial  Complex-East.
    
    J. L. Webb Planning, 1975.  Draft EIR for Sea Village,  South  Laguna Zone
         Change.
    
                                        10-13
    

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     Jones  and Stokes  Asso.,  Inc.,  1974.   Final EIR for ATiso Water Management
         Agency  Regional Wastewater Treatment Project.
     Jones  and Stokes  Asso.,,.Inc.. and Boyle Engineering, 1973.  Draft EIR
         for Aliso  Water Management Agency.
              _,  1972.  Aliso Water Management Agency Environmental Support
          Study.
     Marsh,  Gordon and  Patrick O'Brien, 1974.  Environmental Impact on the
          Plants and Animals of Laguna Canyon by the Construction of Flood
          Control Alternatives.
     Newport Investments,  Inc., 1973.  Sycamore Hills Planned Community District
          Regulations and  Draft EIR.
     Orange  County Environmental Management Agency, 1975.  EIR on Flood Control
          Alternatives  in  Laguna Canyon.
     Richard Tevig and  Assoc., 1973.  Draft EIR for SERRA Waste Water Disposal.
     Toups Inc., 1974.  Draft EIR for Colinas de Capistrano.
     Ultrasystems, Inc., 1974.  Draft EIr for Laguna-Niguel, Tracts 7885
          and 7479.
     	, 1974.  Draft EIR for Laguna-Niguel, Tract 7885.
              _, 1974.  Draft EIR for Laguna-Niguel Area B.
               , 1974.  Draft EIR for Laguna-Niguel Area G.
    U.S. EPA, 1975.  Draft Environmental Impact Statement, Southeast Regional
         Reclamation Authority Ocean Outfall.
    	, Region II, 1974.  Draft Environmental Impact Statement for
         the Central Service of the Ocean County Sewerage Authority in Ocean
         County, N.J.
    	, Region III, 1974.  Draft Environmental Impact Statement;
         Valley Forge Area Wastewater Treatment Facility, Chester County,
         PA.
    U.S. General Services Agency, 1974.  Final EIR for the Proposed Occupancy
         of the North American Rockwell Facility at Laguna NigueT, California.
    VTN, Inc., 1973.  Draft EIR for Laguna-Niguel, (2 volumes).
    	, 1973. Draft EIR for Laguna-Niguel, Area A.
    	, 1973.  Draft EIR for Laguna-Niguel, Area E.
                                     10-14
    

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               ,1975.  Draft EIR for a Zone Change at Moulton Parkway and
          La  Paz Roa d.
    
    Westec Services,  Inc/James A. Roberts Assoc., 1974.  Final EIR for Irvine
          Center.
     GEOLOGY AND PALEONTOLOGY
    
     Arnbld',' R., 1906.  Tertiary and Quaternary Pectens of California.  U.S.G.S,
         Prof. Paper 47.
    
     Downs, Tl, 1955.  "A Fossil Sea Lion from the Miocene of the San Joaquin
         Hills, Orange County, California."  Bull. So. Calif. Acad. Sci.
    
              ,1968.  Fossil Vertebrates of Southern California.  Univ.   .
         Calif. Press, Berkeley and Los Angeles.
    
    Howard, H., 1968.  Tertiary Birds from Laguna Hills, Orange County,"
      •''"Science, Los Angeles Co. Museum, No. 142.
    
    Ingle, J. C., 1962.  Paleoecology, Sedimentation, and Structural  History
         of the Late Tertiary Capistrano Embayment, Orange.County, California.
         unpubl. Master's Thesis, Univ. Southern California.
    
    Klemme, N., and L. Fife, 1973.  "Geology of the Upper Aliso Creek Area," v:
         Guidebook to the Tertiary of Eastern Orange and Los Angeles  Counties,
         California.  South Coast Geol. Soc'.  pp. 41-46;
    
    Loel, W. and W. H. Corey, 1932.  The Vaqueros Formation, Lower Miocene
         of California.  Univ. Calif. Press, Berkeley.
    
    Merriam, C. W., 1941, "Fossil Turritellas from the  Pacific Coast  Region
         of North America,"  Bull, of Dept.  Geol. Sci., Univ. of California,'
         Vol. 26, No. 1, pp. -214.
    
    Miller, W; E., 1971.  "Pleistocene Vertebrates of the Los Angeles Basin
         and Vicinity (Exclusive of Rancho La Brea)," Bull, of the L.A.C.M.
         of .Nat. Hist. & Science, No. 10.
    
    Morton, P. K., V. Miller and D. L. Fife, 1973.  Preliminary Report,
         Geo-environment of Orange County, California.   Cal. Div.  Mines
         and Geol., Spec. Report 15.                              .
    
              , Geology of Orange County, California.  Cal. Div.  Mines and
         Geol.
    
    Vedder, J. G., R.  F.  Yerkes and J.  E.  Schoellhamer,  1957.   Geologic
         Map of the San Joaquin Hills - San Juan Capistrano  Area,  Orange
         County, California.   U.S.G.S:  Oil  and Gas  Invest.,  Map OM-193.
                                      10-15
    

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     Woodford, A. 0.,  1970.  Geologic Guidebook:  Southeastern Rim of the
          Los Angeles  Basin, Orange County, California, Newport Lagoon - San
          Joaquin Hills, Santa Ana Mountains, AAPG SEPM BEG Pacific Section
          Field Trip.
    
              , 1972.  Geologic Guidebook to the Northern Peninsular Ranges,
          Orange and Riverside Counties, California.  National Association
          of  Geology Teachers and South Coast Geological Society.
    
               , 1954.   "Geology of Southern California."  Historical Geology,
          California Division of Mines.
    
    	, 1925.   "The San Onofre Breccia."  Geol. Sci., Univ. Calif.,
          VbTn5, No. 7.
    
    Woodring,  W. P. and W. P. Popenoe, 1945.  Paleocene and Eocene Stratigraphy
          of Northwestern Santa Ana Mountains, Orange County, California.
          U.S.G.S. Oil and Gas Invest. Prelim. Chart 12.
    
    Yerkes, R. F., et al, 1965.  Geology of the Los Angeles Basin, California -
          An Introduction.  U.S.G.S. Prof. Paper 420-A.
    HYDROLOGY
    
    Boyle Engineering and Lowry & Associates, July 1972.  Study of Ocean
         Outfall Locations in Southeasterly Orange County.
    
    California State Water Resources Control Board, San Diego Region, 1974.
         Comprehensive Water Quality Control Plan for the San Diego Basin.
    
    Feth, L. H., 1973.  Water Facts and Figures for Planners and Managers.
    
    Koebig & Koebig, Inc., 1961.  Scope of Work for Comprehensive Conservation
         Planning Project in the Aliso Watershed.
    
    Orange County Harbors, Beaches, and Parks District, 1973.  Silt Removal -
         Upper Newport Bay.
    
    Orange County Planning Department, 1971.  A Plan for the Aliso Creek
         Watershed.
    
    U.S. Army Corps of Engineers, 1972.  Flood Plain Information for San
         Diego Creek and Peters Canyon Wash.
    
    	, 1973.  Flood Plain Information for Aliso Creek.
    
    	, 1970.  Flood Plain Information for San Juan Creek.
    U.S. EPA, 1972.  Guidelines for Erosion and Sediment Control  Planning
         and Implementation.
                                        10-16
    

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    VTN, 1971.  Master Plan of Drainage for the Laguna-Niguel  Area.
    
    	, 1973.  Salt Creek Sedimentation Study.
    
    
    OCEANOGRAPHY
    
    Brooks, N.H., 1960.  "Diffusion of a Sewage Effluent in an Ocean  Current."
         Proceedings, First International  Conference on Waste  Disposal  in
         the Environment.  Permagon Press, N.Y.
    
    Brown and Caldwell, 1974.   Oceanographic Aspects of Aliso  Creek Ocean
         Outfall.
    
    California State Resources Agency, 1969.  Interim Report on the Study
         of Beach Nourishment  Along the Southern California Coastline.
    
    Hyperion Engineers, 1957.   Ocean Outfall Design.
    
    Pearson, E.  A.,  1956.  An  Investigation of the  Efficacy of Submarine
         Outfall Disposal of Sewage and Digested Sludge.   California  State
         Water Pollution Control  Board Publication  No.  14.
    
    Rawn, Bowerman and Brooks, 1960.  "Diffusers for Disposing of  Sewage
         in Sea  Water."  Journal  of the Sanitary Engineering Division,  American
         Society of Civil Engineers.
                                        10-17
    

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              APPENDIX A
    ENVIRONMENTAL PROTECTION AGENCY
     PREPARATION OF ENVIRONMENTAL
          IMPACT STATEMENTS
    

    -------
    MONDAY, APRIL 14, 1975
    WASHINGTON, D.C.
    
    Volume 40 • Number 72
    
    PART III
     ENVIRONMENTAL
        PROTECTION
          AGENCY
    
     Preparation of Environmental
         Impact Statements
          Final Regulations
    A-l
    

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    16814
         RUL1S AND REGULATIONS
       Title 40—Protection of Environment
         CHAPTER I—ENVIRONMENTAL
             PROTECTION AGENCY
                  [PEL 327-5]
     PART 6—PREPARATION OF ENVIRON-
         MENTAL IMPACT STATEMENTS
                Final Regulation
      The  National Environment^  Policy
    Act  of 1969  (NEPA), implemented by
    Executive Order 11514 of March 5, 1970,
    and  the  Council  on   Environmental
    Quality's  (CEQ's)  Guidelines of  Au-
    gust 1,1973, requires that all agencies of
    the  Federal  Government prepare  de-
    tailed environmental impact statements
    on proposals for legislation  and other
    major  Federal actions significantly  af-
    fecting the  quality of the human  en-
    vironment. NEPA requires that agencies
    include in their decision-making process
    an appropriate and careful consideration
    of all environmental aspects of proposed
    actions, an explanation of potential en-
    vironmental effects of proposed actions
    and  their alternatives for public under-
    standing, a discussion of ways to avoid
    or minimize adverse effects of proposed
    actions and a. discussion of how  to  re-
    store or enhance environmental quality
    as much as possible.
      On January 17,  1973,  the  Environ-
    mental Protection Agency  (EPA)  pub-
    lished a new Part 6 in interim form in
    the FEDERAL REGISTER (38 FR  1696), es-
    tablishing EPA policy and procedures for
    the identification and analysis of envi-
    ronmental impacts  and  the preparation
    of  environmental  impact  ^statements
    (EIS's) when significant impacts on the
    environment are anticipated.
      On July 17, 1974, EPA published a no-
    tice  of proposed rulemaking  the  FED-
    ERAL REGISTER (39 FR 26254).  The rule-
    making provided detailed procedures- for
    applying  NEPA to EPA's nonregulatory
    programs only. A separate notice of ad-
    ministrative procedure published in  the
    October 21,  1974, FEDERAL REGISTER  (39
    FR  37419)  gave  EPA's procedures  for
    voluntarily preparing EIS's on certain
    regulatory activities. EIS procedures for
    another regulatory  activity, issuing  Na-
    tional  Pollutant Discharge Elimination
    System (NPDES)  discharge permits to
    new  sources, will appear in 40 CFR 6.
    Associated  amendments to the NPDES
    operating regulations, covering permits
    to new sources, will appear in 40 CFR
    125.
      The  proposed regulation on  the prep-
    aration of EIS's for nonregulatory pro-
    grams  was published for public review
    and  comment. EPA received comments
    on this proposed regulation from envi-
    ronmental  groups;  Federal,  State  and
    local governmental agencies;  industry;
    and  private individuals.  As a result of
    the  comments received, the  following
    changes have been made:
      (1)  Coastal  zones, wild  and  scenic
    rivers,  prime agricultural land and wild-
    life habitat were included In the criteria
    to be considered during the environmen-
    tal review.
      The Coastal Zone  Management Act
    and the Wild and Scenic Rivers Act are
    Intended to protect these environmen-
    tally  sensitive areas;  therefore,  EPA
    should consider the effects of its projects
    on these areas. Protection of prime agri-
    cultural lands and wildlife habitat has
    become an Important concern as  a re-
    sult of the need to further increase food
    production from domestic sources as well
    as commercial harvesting of fish and
    other wildlife resources and from the
    continuing need to preserve the diversity
    of natural resources for future genera-
    tions.
      (2) Consideration of the use of flood-
    plains as.required by Executive  Order
    11296 was added to the environmental
    review process.
      Executive Order 11296 requires agen-
    cies   to  consider  project alternatives
    which will  preclude  the  uneconomic,
    hazardous or unnecessary use of flood-
    plains to  minimize the  exposure of fa-
    cilities to  potential flood damage, lessen
    the need for future Federal expenditures
    for flood  protection and  flood disaster
    relief and preserve the  unique and sig-
    nificant public value of the fioodplain
    as an environmental resource.
      (3)  Statutory  definitions  of  coastal
    zones and wild and scenic rivers  were
    added to § 6.214 (b).
      These statutes  define sensitive  areas
    and  require  states to  designate  areas
    which must be protected.
      (4) The review  and comment period
    for  negative  declarations  was extended
    from  15 days to 15 working days.
      Requests for negative declarations and
    comments on negative declarations are,
    not acted on during  weekends and on
    holidays. In addition, mail requests often
    take two or three days to reach the ap-
    propriate office and several more days for
    action and delivery of response. There-
    fore, the new time frame for review and
    response  to  a negative declaration  Is
    more realistic without adding too much
    delay to a  project.
      (5) Requirements for more data in the
    negative declaration to  clarify the pro-
    posed action were  added in § 6.212(b).
      Requiring a summary of the impacts
    of a project  and  other  data  to support
    the negative declaration  in this docu-
    ment improves its usefulness as a tool to
    review the decision not to prepare  a full
    EIS on a project.
      (6) The definitions of primary and
    secondary impacts in  § 6.304 were  clari-
    fied.
      The definitions were made more spe-
    cific,  especially in  the issue areas of in-
    duced growth and growth rates, to reduce
    subjectivity in deciding  whether an im-
    pact is primary or secondary.
      (7) Procedures for  EPA public  hear-
    ings in Subpart D  were clarified.
      Language was added to this subpart
    to distinguish EPA public hearings from
    applicant hearings required by statute or
    regulation, such  as the facilities  plan
    hearings.
      (8) The discussion  of retroactive ap-
    plication  (|  6.504) was  clarified  and
    abbreviated.
      The new language retains flexibility in
    decision making for the Regional Admin-
    istrator while eliminating the ambiguity
    of the langauge in the interim regulation.
      (9) The criteria for writing an EIS if
    wetlands may be affected were modified
    in § 6.510(b).
      The new language still requires an EIS
    on a project which will be located on
    wetlands but limits the requirements for
    an EIS on secondary wetland effects to
    those which are significant and adverse.
      (10) A  more detailed  explanation of
    the data required  in environmental as-
    sessments (§ 6".512)  was added.
      Requiring more specific data in several
    areas, including energy production .and
    consumption as well as land use  trends
    and population projections, from the ap-
    plicant will provide a more complete data
    base for the environmental review. Doc-
    umentation  of  the  applicant's data will
    allow EPA to evaluate the validity of this
    data.
      (11) Subpart F,  Guidelines for Com-
    pliance with NEPA  In Research and De-
    velopment Programs and Activities, was
    revised.
      ORD simplified  this  subpart  by re-
    moving the internal procedures and as-
    signments! of responsibility  for circula-
    tion  in internal memoranda.  Only  the
    general application of this regulation to
    ORD programs was retained.
      (12) The discussions of responsibilities
    and  document  distribution procedures
    were moved to appendices attached to the
    regulations.
      These sections were removed from the
    regulatory language to improve the read-
    ability of the regulation and because
    these discussions are more  explanatory
    and  do not need to have the legal force
    of regulatory language.
      (13) Consideration of the  Endangered
    Species Act of 1973  was incorporated in-
    to the regulation.
      EPA recognizes its responsibility to as-
    sist with Implementing legislation which
    will help preserve or improve our natural
    resources.
      The major issues raised on this regula-
    tion  were on new and  proposed criteria
    for determining when to  prepare an .EIS
    and  the retroactive application  of  the
    criteria to projects started before  July 1,
    1975. I n addition  to  the new  criteria1
    which were added, CEQ requested the ad-
    dition of several quantitative criteria for
    which parameters  have not  been  set.
    These new criteria are being discussed
    with CEQ and may be added to the regu-
    lation at a future date: Changes  in the
    discussion of retroactive application of
    the criteria are described in item 8 above.
      EPA believes that Agency compliance
    with the regulations of Part 6 will en-
    hance the present quality of human life
    without endangering the quality  of the
    natural environment for future genera-
    tions.
      Effective date: This regulation will be-
    come effective April 14, 1975.
      Dated: April 3, 1975.
                     RUSSELL E. TRAIN,
                          Administrator.
                                   FEDERAL REGISTER, VOL. 40, NO. 72—MONDAY, APRIL 14,  1975
                                                                 A-2
    

    -------
                                                  RULES AND REGULATIONS
                                                                             1681',
                Subpart A—General
    
    Sec.
    6.100  Purpose and policy.            '
    6.102  Definitions.
    6.104  Summary  of  procedures for  Imple-
            menting NEPA,
    6.106  Applicability.
    6.108  Completion of NEPA  precedures  be-
            fore start of administrative action.
    G.110  Responsibilities.
    
              Subpart B—Procedures
    6.200  Criteria for determining when to pre-
            pare an environmental Impact state-
            ment.
    6.202  Environmental assessment.
    6.204  Environmental review.
    6.206  Notice of intent.
    6.208  Draft  environmental  Impact  state-
            ments.
    6.210  Final  environmental  Impact  state-
            ments.
    6.212  Negative  declarations  and environ-
            mental Impact appraisals.
    6.214  Additional procedures.
    6.216  Availability of documents.
    
      Subpart C—Content of Environmental Impact
                  ' Statements
    6.300  Cover sheet.
    6.302  Summary sheet.
    6.304  Body  of statement.
    6.306  Documentation.
    
       Subpart  D—EPA Public Hearings on Impact
                   Statements
    6.400  General.
    6.402  Public hearing process.
    
    Subpart  E—Guidelines for Compliance  With
      NEPA  In  the Title II Wastewater Treatment
      Works Construction  Grants Program and the
      Areawlde Waste Treatment Management Plan-
      ning Program
    6.500  Purpose.
    6.502  Definitions.
    6.504  Applicability.
    6.506  Completion of NEPA  procedures  be-
            fore start of administrative actions.
    6.510  Criteria for preparation of environ-
            mental Impact statements.
    6.512  Procedures  for Implementing NEPA.
    6.514  Content  of  environmental  Impact
            statements.
    
    Subpart F—Guidelines for Compliance With NEPA
      In Research and  Development Programs  and
      Activities
    6.600  Purpose.
    6.602  Definitions.
    6.604  Applicability.
    6.608  Criteria for determining when to pre-
            pare environmental  Impact  state-
            ments.
    6.610  Procedures for compliance with NEPA.
    
    Subpart G—Guidelines for Compliance With NEPA
         In Solid Waste Management Activities
    6.700  Purpose.
    6.702  Criteria for the preparation of envi-
            ronmental assessments and EIS's.
    6.704  Procedures for compliance with NEPA.
    
    Subpart  H—Guidelines for Compliance  With
      NEPA  In  Construction of Special Purpose Fa-
      cilities and Facility Renovations
    6.800  Purpose.
    6.802  Definitions.
    6.804  Applicability.
    6.808  Criteria for the preparation of envi-
            ronmental assessments and EIS's.
    6.810  Procedures for compliance with NEPA.
    
                    EXHIBITS
    
    1. (Page 1.)  Notice of  Intent Transnilttal
        Memorandum Suggested Format.
       (Page 2.)  Notice of Intent  Suggested
        Format.
    1. Public Notice and News Release Suggested
        Format.
    S. Negative Declaration Suggested Format.
    4. Environmental  Impact  Appraisal  Sug-
        gested Format.
    5. Cover Sheet Format for  Environmental
        Impact Statements.
    6. Summary Sheet Format for Environmental
        Impact Statements.
    7. Flowchart for  Solid Waste Management
        Program Operations.
    Appendix A—Checklist for  Environmental
     Reviews.
    Appendix B—Responsibilities.
    Appendix C—Availability  and Distribution
      of Documents.
     Authority:  Sees.  102, 103 of 83 Stat.  854
    (42U.S.C. 4321etseq.)
    
              Subpart A—General
    § 6.100  Purpose and policy.
      (a) The National  Environmental Pol-
    icy Act (NEPA)  of 1969, implemented by
    Executive Order 11514 and the Council
    on  Environmental   Quality's  (CEQ's)
    Guidelines  of  August  1,  1973 (38  PR
    20550), requires that all agencies of  the
    Federal Government prepare detailed  en-
    vironmental impact statements on pro-
    posals for  legislation and  other major
    Federal  actions significantly affecting
    the quality  of the human environment.
    NEPA requires that  agencies include In
    the decision-making process appropriate
    and careful consideration of all environ-
    mental effects  of proposed actions,  ex-
    plain potential environmental effects of
    proposed actions  and their aternatives
    for public understanding, avoid or mini-
    mize  adverse effects of proposed actions
    and restore or  enhance environmental
    quality as much as possible.
      (b) This part establishes Environmen-
    tal Protection Agency (EPA)  policy and
    procedures  for  the  Identification  and
    analysis of the environmental Impacts of
    EPA nonregulatory actions and the prep-
    aration and processing of environmental
    impact statements (EIS's) when signifi-
    cant  impacts on the environment  are
    anticipated.
    
    § 6.102  Definitions.
      (a)  "Environmental assessment" Is a
    •written analysis submitted to EPA by its
    grantees or contractors  describing  the
    environmental impacts of proposed  ac-
    tions undertaken with the financial sup-
    port of EPA. For facilities or section  208
    plans as denned in  S 6.102  (J) and (k),
    the  assessment  must  be  an  Integral,
    though identifiable, part of the plan sub-
    mitted  to EPA for review.
      (b)  "Environmental  review" is a for-
    mal evaluation undertaken by EPA to
    determine  whether a proposed EPA  ac-
    tion may have  a significant  Impact on
    the environment. The environmental as-
    sessment is one of the major sources of
    information used in this review.
      (c) "Notice of Intent" is a memoran-
    dum, prepared  after the environmental
    review, announcing  to Federal, regional,
    State, and local agencies, and to Inter-
    ested persons,  that  a draft EIS will be
    prepared.
       (d)   "Environmental  Impact  state-
    ment"  is a report,  prepared by  EPA,
    which identifies and analyzes in detail
    the environmental Impacts of a proposed
    EPA  action and feasible alternatives.
      (e) "Negative declaration" Is a written
    announcement,  prepared after the en-
    vironmental  review,  which states that
    EPA has decided not to prepare an EIS
    and  summarizes  the  environmental Im-
    pact appraisal.
      (f) "Environmental impact appraisal"
    is based on an environmental review and
    supports a negative  declaration.  It de-
    scribes a  proposed EPA action, its ex-
    pected environmental impact,  and the
    basis for the conclusion that no signifi-
    cant impact is anticipated.
      (g) "NEPA-associated    documents"
    are any one  or  combination of: notices
    of intent, negative declarations, exemp-
    tion certifications, environmental impact
    appraisals, news  releases, EIS's, and en-
    vironmental  assessments.
      (h) "Responsible official" is an Assist-
    ant Administrator, Deputy Assistant Ad-
    ministartor.  Regional Administrator  or
    their designee.
      (i) "Interested  persons"   are  Indi-
    viduals, citizen groups, conservation  or-
    ganizations, corporations, or other non-
    governmental units, including applicants
    for EPA contracts or grants,  who may
    be interested in, affected by,  or techni-
    cally competent to comment on the en-
    vironmental  impacts of  the   proposed
    EPA action.
      (j) "Section 208 plan" is an  areawide
    waste treatment management  plan pre-
    pared under section  208 of the Federal
    Water Pollution  Control Act (FWPCA),
    as amended,  under 40 CFR Part 126 and
    40 CFR Part 35, Subpart F.
      (k) "Facilities plan" is  a preliminary
    plan prepared as the basis for construc-
    tion of  publicly owned waste treatment
    works  under Title  n  of  FWPCA,  as
    amended, under 40 CFR 35.917.
      (1) "Intramural project" is  an  in-
    house   project   undertaken   by  EPA
    personnel.
      (m) "Extramural project" is a project
    undertaken by grant or contract
    § 6.104  Summary of procedures for  im-
         plementing NEPA.
      (a) Responsible official. The respon-
    sible official shall utilize a systematic, in-
    terdisciplinary  approach  to  integrate
    natural and social sciences as well  as
    environmental design arts In  planning
    programs and making decisions which
    are subject to NEPA review. His staff may
    be supplemented  by  professionals from
    other agencies,  universities or consult-
    ants whenever In-house capabilities  are
    Insufficiently interdisciplinary.
      (b) Environmental assessment.  En-
    vironmental  assessments must be sub-
    mitted to EPA by its grantees and con-
    tractors, as required in Subparts E. F, G,
    and H  of this part.  The  assessment is
    used by EPA to  decide if  an  ETS is  re-
    quired and to prepare  one if necessary.
      (c)  Environmental review.  Environ-
    mental reviews shall be made of pro-
    posed and certain ongoing EPA actions
    as  required  in  § 6.106(c). This process
    shall consist of a study of the  action to
    Identify and evaluate toe environmental
    impacts of the action.  Types of grants,
    contracts and  other actions  requiring
    study are listed in toe subparts following
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     16816
          RULES AND REGULATIONS
    Subpart D. The process shall Include a
    review of any environmental assessment
    received to determine whether any sig-
    nificant Impacts are anticipated, whether
    any changes can be made in the proposed
    action to  eliminate significant adverse
    Impacts, and whether an EIS Is required.
    EPA has overall responsibility for this
    review, although its grantees and con-
    tractors will  contribute  to  the  review
    through  their  environmental  assess-
    ments.
       (d) Notice of intent and EIS's. When
    an environmental review indicates that
    a significant environmental impact may
    occur and the significant adverse Impacts
    cannot be eliminated by making changes
    In the project, a notice of intent shall be
    published, and a draft EIS shall be pre-
    pared and distributed. After external co-
    ordination and evaluation of the com-
    ments received, a final EIS shall be pre-
    pared and distributed.  EIS's should  be
    prepared first on those proposed actions
    with the most adverse effects which are
    scheduled  for  earliest  implementation
    and on other proposed actions according
    to priorities assigned by the responsible
    official.
       (e) Negative declaration and environ-
    mental impact appraisal. When the en-
    vironmental  review  indicates no  signi-
    ficant Impacts are anticipated or when
    the project is changed  to eliminate the
    significant adverse impacts,  a negative
    declaration shall be issued. For the cases
    In Subparts E, F, G, and H of this part,
    an environmental impact appraisal shall
    be prepared which summaries the im-
    pacts, alternatives and reasons an EIS
    was not prepared. It shall remain on file
    and  be available for public inspection.
    § 6.106   Applicability.
      (a)  Administrative  actions covered.
    This part  applies  to the administrative
    actions listed below. The subpart  refer-
    enced with each action lists the detailed
    NEPA procedures associated with the ac-
    tion. Administrative actions  are:
      (1) Development  of  EPA  legislative
    proposals;
      (2) Development of favorable reports
    on legislation Initiated elsewhere and not
    accompanied by an EIS, when they relate
    to or affect matters within  EPA's pri-
    mary areas of responsibility;
      (3) For the programs under Title II of
    FWPCA, as amended, those administra-
    tive actions in § 6.504;
      (4) For the Office of Research and De-
    velopment, those administrative actions
    in § 6.604;
      (5) For the Office of Solid Waste Man-
    agement Programs, those administrative
    actions hi § 6.702;
      (6) For  construction  of special pur-
    pose facilities and facility renovations,
    those administrative actions  in § 6.804;
    and
      (7) Development of an EPA project In
    conjunction with or located near a proj-
    ect or complex of projects started by one
    or more  Federal  agencies  when the
    cumulative effects of all the projects will
    be major allocations of resources or fore-
    closures of future land use options.
       (b) Administrative  actions excluded.
    The requirements of this part do not ap-
    ply to environmentally protective regu-
    latory activities undertaken by EPA, nor
    to projects  exempted in § 6.504,  § 6.604,
    and § 6.702.
       (c) Application  to  ongoing  actions.
    This regulation shall  apply to  uncom-
    pleted and  continuing EPA actions ini-
    tiated before the promulgation of these
    procedures when modifications of or al-
    ternatives to  the EPA action are  still
    available, except for the  Title  n con-
    struction grants program. Specific appli-
    cation for the  construction grants pro-
    gram is in  §6.504(c). An EIS shall be
    prepared for each project found to have
    significant environmental  effects as de-
    scribed in § 6.200.'
       (d) Application to legislative  propos-
    als.  (1) As noted in paragraphs (a) (1)
    and (2) of this section, EIS's or negative
    declarations shall be prepared for legis-
    lative proposals or favorable reports re-
    lating to legislation which may  signifi-
    cantly affect the environment. Because
    of the nature of the legislative  process,
    EIS's for legislation must  be prepared
    and reviewed  according  to  the  proce-
    dures followed  in the  development  and
    review of the legislative  matter. These
    procedures  are described in Office of
    Management and Budget  (OMB) Circu-
    lar No. A-19.
       (2) A working draft EIS shall be pre-
    pared by the EPA  office responsible for
    preparing the legislative proposal or re-
    port on legislation. It shall be prepared
    concurrently with  the development of
    the  legislative  proposal or report  and
    shall contain .the information required
    in § 6.304. The EIS shall be circulated for
    internal EPA review with the legislative
    proposal or  report and other supporting
    documentation.  The working draft EIS
    shall be  modified  to  correspond  with
    changes  made in the proposal or report
    during the internal review. All major al-
    ternatives developed during the formu-
    lation and review of the proposal or re-
    port should be  retained in the working
    draft EIS.
      (i)  The working draft  EIS shall ac-
    company the legislative proposal or re-
    port to OMB. EPA shall revise the work-
    ing draft EIS to respond  to comments
    from OMB and other  Federal agencies.
      (ii) Upon transmittal of the  legisla-
    tive proposal or report  to Congress, the
    working draft EIS will  be forwarded to
    CEQ and the Congress as a formal leg-
    islative  EIS. Copies will  be distributed
    according to procedures described in Ap-
    pendix C.
      (iii) Comments  received  by  EPA on
    the legislative EIS shall be forwarded to
    the appropriate Congressional Commit-
    tees. EPA also  may respond to  specific
    comments and forward its responses with
    the comments. Because legislation under-
    goes continuous changes in Congress be-
    yond  the  control of EPA, no final EIS
    need be prepared by EPA.
    
    § 6.108   Completion of NEPA procedures
         before starting administrative action.
    
      (a) No administrative action shall be
    taken until the  environmental  review
    process, resulting in an EIS or a nega-
    tive declaration with environmental ap-
    praisal, has been completed.
      (b) When an EIS will be prepared.
    Except when requested by  the respon-
    sible official in writing and  approved by
    CEQ, no administrative action shall be
    taken sooner than ninety (90) calendar
    days after  a draft EIS has been distrib-
    uted or sooner than thirty (30) calendar
    days after  the  final  EIS has been made
    public. If the final text of  an EIS is filed
    within ninety (90)  days after a draft EIS
    has been  circulated for comment, fur-
    nished to  CEQ and made  public,  the
    minimum thirty (30) day  period and the
    ninety (90)  day period may run  con-
    currently if they overlap.  The minimum
    periods for review and advance avail-
    ability of EIS's shall begin  on the date
    CEQ publishes the notice of receipt of
    the EIS in the FEDERAL REGISTER. In ad-
    dition, the proposed action  should be
    modified to conform with any changes
    EPA considers necessary before the final
    EIS is published.
      (c) When an EIS will not be prepared.
    If EPA decides not  to  prepare an  EIS
    on any action  listed  in  this part for
    which  a  negative  declaration with  en-
    vironmental appraisal has  been prepared,
    no administrative  action  shall be taken
    for at least fifteen  (15)  working  days
    after the negative declaration Is issued to
    allow public review  of  the  decision. If
    significant   environmental   issues   are
    raised during the review period, the deci-
    sion may be changed and a new environ-
    mental appraisal or an EIS  may be pre-
    pared.
    § 6.11Q  Responsibilities.
      See Appendix B for responsibilities of
    this part.
            Subpart B—Procedures
    § 6.200  Criteria for determining  when
        to prepare an EIS.
      The following general criteria shall be
    used when reviewing  a proposed  EPA
    action to  determine if it  will  have  a
    significant  impact on  the environment
    and therefore require an EIS:
      (a) Significant environmental effects.
    (1) An action with both  beneficial and
    detrimental effects should be classified
    as having significant effects on  the  en-
    vironment,  even if  EPA  believes  that
    the net effect will be beneficial. However,
    preference  should be given to preparing
    EIS's on proposed actions  which, on bal-
    ance, have adverse effects.
      (2)  When determining  the  signifi-
    cance of a proposed action's impacts,
    the  responsible official shall  consider
    both its short term and long term effects
    as well as  its  primary and  secondary
    effects  as defined in  § 6.304(c). Particu-
    lar attention should be given to changes
    in land use patterns; changes in energy
    supply and demand; increased develop-
    ment in floodplains;  significant changes
    in ambient  air and water quality or noise
    levels; potential violations of air quality,
    water quality and noise level standards;
    significant changes in surface or ground-
    water quality or quantity; and encroach-
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                                                RULES AND REGULATIONS
                                                                           16817
    ments on wetlands, coatstal zones, or fish
    and wildlife habitat, especially  when
    threatened or endangered species may be
    affected.
      (3) Minor actions  which may  set a
    precedent for future major actions with
    significant adverse Impacts or a number
    of actions with Individually Insignificant
    but cumulatively significant adverse Im-
    pacts shall be classified  as having sig-
    nificant environmental Impacts. If EPA
    is taking  a number of minor, environ-
    mentally Insignificant actions  that are
    similar in execution and purpose, during
    a limited time span and  in  the  same
    general geographic area,  the cumulative
    environmental  impact of  all  of  these
    actions shall be evaluated.
      (4) In determining the significance of
    a proposed action's Impact, the unique
    characteristics of the project area should
    be  carefully considered. For  example,
    proximity to historic sites,  parklands or
    wild and  scenic rivers may  make the
    Impact significant. A project discharging
    into a drinking water aquifier may make
    the Impact significant.
      (5) A proposed EPA action which will
    have direct and significant adverse ef-
    fects on a property listed in or eligible
    for listing In the National Register of
    Historic Places or will cause irreparable
    loss or destruction  of significant scien-
    tific, prehistoric, historic or archaeolog-
    ical  data  shall be  classified  as having
    significant environmental impacts.
      (b)  Controversial  actions.  An EIS
    shall be  prepared  When the  environ-
    mental impact of a proposed EPA action
    is likely to be  highly controversial.
      (c)  Additional  criteria  for  specific
    programs.  Additional criteria for vari-
    ous  EPA  programs are In Subpart E
    (Title n Wastewater Treatment Works
    Construction Grants Program), Subpart_
    P   (Research and   Development  Pro-
    grams), Subpart G  (Solid  Waste  Man-
    agement  Programs)  and  Subpart  H
    (Construction of  Special Facilities and
    Facility Renovations).
    § 6.202  Environmental assessment.
      Environmental assessments  must be
    submitted  to EPA  by Its grantees and
    contractors as  required  in Subparts  E,
    F, G, and H of this part. The assessment
    Is to ensure that the applicant considers
    the environmental  Impacts of the pro-
    posed action at the earliest possible point
    in his planning process. The assessment
    and other relevant information are used
    by  EPA to decide If an EIS Is required.
    While EPA is responsible  for ensuring
    that EIS's are factual and comprehen-
    sive,  it expects assessments  and  other
    data submitted by grantees and contrac-
    tors to be accurate and complete. The
    responsible official  may request  addi-
    tional data and analyses from grantees
    or other sources any time he  determines
    they are  needed to comply  adequately
    with NEPA.
    § 6.204   Environmental review.
      Proposed EPA actions, as well as on-
    going  EPA actions listed  to  § 6.106(c),
    shall be subjected  to an environmental
    review. This review shall be a continu-
    ing one, starting at the earliest possible
    point In the development of the project.
    It shall consist of a  study of the pro-
    posed action, including a review of any
    environmental  assessments received,  to
    Identify and evaluate  the environmental
    Impacts of the proposed action and feas-
    ible alternatives. The review will deter-
    mine  whether  significant impacts are
    anticipated  from the proposed action,
    whether  any  feasible alternatives can
    be adopted  or change? can be made  In
    project  design  to eliminate significant
    adverse   impacts,  and   whether   an
    EIS  or  a  negative  declaration  is re-
    quired. The responsible official shall de-
    termine the proper scope of the environ-
    mental  review.  The responsible  official
    may delay approval of related projects
    until the proposals  can be reviewed to-
    gether to allow EPA to properly evaluate
    their  cumulative impacts.
    
    § 6.206   Notice of intent.
      (a)  General.  (1)  When an environ-
    mental review indicates a significant im-
    pact may occur and significant adverse
    impacts cannot be eliminated by making
    changes in the project, a notice of Intent,
    announcing the preparation of a draft
    EIS, shall be Issued by the  responsible
    official. The notice shall briefly describe
    the EPA action, its location, and the Is-
    sues involved (Exhibit 1).
      (2)  The purpose of a notice of intent
    Is to involve other government agencies
    and Interested persons as early as possi-
    ble In the planning and evaluation  of
    EPA actions which may have significant
    environmental   impacts.   This  notice
    should encourage agency and public In-
    put to a draft  EIS  and assure that en-
    vironmental values will be identified and
    weighed  from  the  outset rather than
    accommodated  by  adjustments at the
    end of the decision-making process.
      (b) Specific actions.  The specific ac-
    tions to be taken by the responsible offi-
    cial on notices of Intent are:
      (1) When the review process Indicates
    a significant impact may occur and sig-
    nificant adverse impacts cannot be elim-
    inated by making changes In the project,
    prepare a notice of intent Immediately
    after the environmental review.
      (2) Distribute copies of the notice  of
    intent as required in Appendix C.
      (3) Publish in a local newspaper, with
    adequate  circulation  to cover the area
    affected  by the project, a brief public
    notice stating that an EIS will be pre-
    pared on a particular  project, and the
    public may  participate  in preparing the
    EIS (Exhibit 2). News releases also may
    be submitted to other media.
       (c> Regional  office assistance to pro-
    gram offices. Regional offices will provide
    assistance  to program  offices In  taking
    these specific actions when the EIS orig-
    inates in a program office.
    § 6.208  Draft EIS's.
       (a) General.  (1)  The responsible offi-
    cial shall assure that  a draft EIS Is pre-
    pared as soon as possible after the release
    of the notice of Intent. Before releasing
    the draft EIS to CEQ, a preliminary ver-
    sion may be circulated for review to other
    offices  within EPA with Interest In or
    technical expertise related to the action.
    Then the draft EIS shall be sent to CEQ
    and circulated to Federal, State, regional
    and local agencies with special expertise
    or jurisdiction by law, and to Interested
    persons. If the responsible official  deter-
    mines that a public hearing  on the pro-
    posed action Is warranted, the hearing
    will be held after the draft  EIS Is pre-
    pared,  according  to the requirements of
    § 6.402.
      (2) Draft EIS's should be  prepared at
    the earliest possible point in the project
    development. If the project involves a
    grant applicant or potential  contractor,
    he must submit any data EPA requests
    for preparing the EIS. Where a plan or
    program has been developed by EPA or
    submitted to EPA for approval, the re-
    lationship  between  the  plan  and the
    later projects encompassed by its shall
    be evaluated to determine the best time
    to prepare an  EIS.  Whenever possible,
    an EIS will be drafted for the total  pro-
    gram at the initial planning stage. Then
    later component projects included in the
    plan will not require individual EIS's un-
    less they  differ substantially from the
    plan, or unless the overall plan did not
    provide enough  detail to fully  assess
    significant impacts of individual projects.
    Plans  shall be reevaluated  by the re-
    sponsible official to monitor the cumula-
    tive Impact of the component projects
    and to preclude the  plans' obsolescence.
      (b) Specific actions. The  specific ac-
    tions to be taken by the responsible of-
    ficial on draft EIS's are:
      (1)  Distribute  the draft EIS accord-
    Ing to the procedures in Appendix C.
      (2)   Inform  the  agencies  to  reply
    directly to  the originating  EPA office.
    Commenting agencies shall have at least
    forty-five (45)  calendar days  to reply,
    starting from the date of publication in
    the FEDERAL  REGISTER of lists of state-
    ments  received by CEQ. If no comments
    are received during the reply period and
    no  time extension has been requested. It
    shall be presumed that the agency has
    no  comment to make. EPA  may grant
    extensions of fifteen (15) or  more calen-
    dar days. The time limits for review and
    extensions for State and local agencies;
    State,  regional, and  metropolitan clear-
    inghouses; and interested persons shall
    be the  same as those available to Federal
    agencies.
      (3)  Publish  a  notice  in  local news-
    papers stating that the draft EIS  Is
    available for comment and listing where
    copies  may be obtained (Exhibit 2), and
    submit news releases to other media.
       (4) Include in  the draft EIS a notice
    stating that only those Federal, State,
    regional, and local agencies and Inter-
    ested persons who make substantive com-
    ments  on the draft EIS or request a copy
    of the final EIS will be sent a copy.
      (c) Regional office assistance to pro-
    gram office. If requested, regional offices
    will provide assistance to program offices
    in taking these specific actions when the
    EIS originates in  a program office.
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         RULES AND REGULATIONS
    § 6.210  Final EIS'o.
      (a)  Final EHB's shall respond to an
    substantive  comments  raised  through
    the review of the draft £13. Special care
    should be taken to respond fully to com-
    ments disagreeing with EPA's  position.
    (See also § 6.304(g).)
      Ob)  Distribution and  other  specific
    actions are described In Appendix C. If
    there is an applicant, he shall be sent a
    copy. When the number of comments on
    the draft EIS is so large that distribution
    of the final EIS to all commenting en-
    tities appears impractical, the program
    or  regional  office preparing  the EIS
    shall  consult with  OFA, which will con-
    sult with CEQ about alternative arrange-
    ments for distribution of the EIS.
    § 6.212  Negative  declaration and  envi-
        ronmental impact appraisals.
      (a) General. When an  environmental
    review indicates there will be no signifi-
    cant  impact  or significant adverse im-
    pacts have been eliminated  by making
    changes'in the project, the  responsible
    official shall prepare a negative declara-
    tion to allow public review of his decision
    before it becomes final.  The  negative
    declaration and news release must state
    that interested persons disagreeing with
    the decision may  submit  comments for
    consideration  by  EPA. EPA  shall  not
    take administrative action on the proj-
    ect for at least fifteen (15) working days
    after  release of the negative declaration
    and may  allow more time for response.
    The responsible official shall  have an
    environmental  impact  appraisal  sup-
    porting the negative  declaration avail-
    able for public review when the negative
    declaration is  released  for  those cases
    given in Subparts  E,  F, G, and H.
      Ob)  Specific  actions.  The  responsible
    official shall take  the following specific
    actions on those projects for which both
    a negative declaration and  an  impact
    appraisal will be prepared:
      (1) Negative declaration, (i) Prepare
    a negative declaration immediately after
    the environmental review.  This  docu-
    ment shall briefly summarize the purpose
    of the project, its location, the  nature
    and extent of the  land use changes re-
    lated to the project, and the major pri-
    mary  and secondary impacts of  the
    project. It shall describe  how the more
    detailed environmental impact appraisal
    may be obtained at cost. (See Exhibit 3.)
      (ii) Distribute the negative declaration
    according to procedures in Appendix C.
    In addition, submit to local newspapers
    and other appropriate media a brief news
    release with a  negative declaration at-
    tached, informing  the public that a de-
    cision not to prepare an EIS has  been
    made and a negative declaration and en-
    vironmental impact appraisal are avail-
    able for public review and comment (Ex-
    hibit  2).
      (2)  Environmental impact appraisal.
    (i)  Prepare  an environmental  impact
    appraisal concurrently with the negative
    declaration. This document shall briefly
    describe the proposed action and feasible
    alternatives,  environmental Impacts of
    the proposed action, unavoidable adverse
    Impacts of the proposed action, the re-
    lationship  between short term  uses of
    man's environment and the maintenance
    and enhancement of long term produc-
    tivity, steps to minimize harm to the en-
    vironment, irreversible and irretrievable
    commitments of resources to implement
    the action, comments and consultations
    on the project, and reasons for conclud-
    ing there will  be no significant impacts.
     (See Exhibit 4.)
       (ii) Distribute the environmental  im-
    pact appraisal according to procedures
    in Appendix C.
    § 6.214  Additional procedures.
      (a) Historical and archaeological sites.
    EPA is subject to the requirements of sec-
    tion 106 of the National Historic Preser-
    vation Act Of 1966, 16 U.S.C. 470 et seq.,
    Executive Order 11593, the Archaeologi-
    cal and Historic Preservation Act of 1974,
    16 U.S.C. 469 et seq., and the regulations
    promulgated under this legislation. These
    statutes  and  regulations establish  en-
    vironmental review procedures which are
    independent of NEPA requirements.
       (1) If an EPA action may affect prop-
    erties   with   historic,   architectural,
    archaeological  or cultural value which
    are listed in the National Register of His-
    toric Places (published in the FEDERAL
    REGISTER  each  February with  supple-
    ments on  the  first  Tuesday  of each
    month),  the  responsible  official shall
    comply with the procedures  of the Ad-
    visory Council on Historic Preservation
    (36 CFR 800), including determining the
    need for a Memorandum of Agreement
    among EPA, the State Historic Preserva-
    tion Officer and the Advisory Council. If
    a Memordandum of Agreement is  exe-
    cuted, it shall be included  in  an EIS
    whenever one  is prepared on a proposed
    action. See §  6.512(c)  of this part for
    additional  procedures for the construc-
    tion grants program under Title n of the
    FWPCA, as amended.
      (2) If  an EPA action may cause ir-
    reparable loss or destruction of signifi-
    cant scientific, prehistoric,  historic  or
    archaeological data, the responsible offi-
    cial shall consult with the State Historic
    Preservation Officer in compliance with
    the Archaeological and Historic Preser-
    vation Act (P.L. 93-291).
      (b)  Wetlands, floodplains,  coastal
    zones, wild and  scenic rivers, fish and
    wildlife. The following procedures shall
    be applied to all EPA administrative ac-
    tions covered by  this part that may af-
    fect  these environmentally sensitive
    resources.
      (1) If  an EPA action may affect wet-
    lands, the responsible official shall con-
    sult with the  appropriate offices of  the
    Department of the Interior, Department
    of Commerce,  and the U.S. Army Corps
    of Engineers during the environmental
    review to determine the probable impact
    of the action  on the pertinent fish and
    wildlife resources and land use of these
    areas.
       (2) If an EPA action may  directly
    cause or Induce the construction of build-
    Ings or other facilities in a floodplain, the
    responsible official  shall evaluate flood
    hazards in connection with these facili-
    ties as required by Executive Order 11296
    and shall, as far as practicable, consider
    alternatives to preclude the uneconomic,
    hazardous or unnecessary use of flood-
    plains to minimize the exposure of facili-
    ties to potential flood damage, lessen the
    need for future Federal expenditures for
    flood  protection and flood disaster relief
    and preserve the unique and significant
    public value of the floodplain as an-;en-
    vironmental resource.                ,
      (3) If an EPA action may affect coastal
    zones or coastal waters as defined in Title
    III of the Costal Zone Management Act
    of 1972  (Pub. L.  92-583), the  responsible
    official shall consult with the appropriate
    State offices  and with  the  appropriate
    office of the  Department of  Commerce
    during the environmental review to de-
    termine  the probable  impact  of the
    action on coastal zone or coastal water
    resources.
      (4) If an EPA action may  affect  por-
    tions  of rivers designated wild and_ scenic
    or being considered for this designation
    under the  Wild and Scenic  Rivers Act
    (Pub. L. 90-542), the responsible  official
    shall  consult with  appropriate State
    offices and with the Secretary of the
    Interior or, where national forest lands
    are involved, with the Secretary of Agri-
    culture  during  the environmental re-
    view  to determine the  status  of an
    affected river and the probable impact
    of the action on eligible rivers.
      (5) If an EPA action will result in the
    control or structural modification of any
    stream  or other body of water for any
    purpose, including navigation and drain-
    age, the responsible official shall consult
    with  the United States Fish and Wild-
    life Service (Department of the  Inte-
    rior) , the National Marine Fisheries
    Service of the  National Oceanic  and
    Atmospheric  Administration (Depart-
    ment of  Commerce),  the  U.S.  Army
    Corps of Engineers and the head of the
    agency  administering the wildlife re-
    sources  of the particular State in which
    the action will take place with a view  to
    the conservation of  wildlife resources.
    This  consultation shall follow the  pro-
    cedures  in the Fish  and Wildlife Coordi-
    nation Act (Pub. L.  85-624) and shall
    occur during the environmental  review
    of an action.
      (6) If  an  EPA  action  may  affect
    threatened or endangered species defined
    under section 4 of the Endangered Spe-
    cies Act of 1973 (Pub. L. 93-205), the'
    responsible official shall consult with the
    Secretary of  the Interior or  the  Secre-
    tary  of  Commerce,  according  to the
    procedures in section 7 of that act.
      (7) Requests for consultation and the
    results  of  consultation shall be docu-
    mented  in writing.  In  all cases  where
    consultation has  occurred, the agencie?,
    consulted should receive copies of either
    the notice of intent and EIS or the nega-
    tive declaration  and environmental ap-
    praisal prepared on the proposed action.
    If a decision has already been  made  to
    prepare an EIS on a project and wet-
    lands, flocdplains,  coastal zones,  wild
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                                                                           16819
    and scenic rivers, fish or wildlife  may
    be  affected,  the required consultation
    may be deferred until the preparation of
    the draft EIS.
    § 6.216  Availability of documents.
      (a) EPA will print copies of draft and
    final EIS's for agency and public  dis-
    tribution. A nominal fee may be charged
    for copies requested by the public.
      (b) When  EPA no longer has copies
    of an.EIS  to distribute, copies shall  be
    made available for public inspection  at
    regional  and headquarters  Offices  of
    Public Affairs. Interested  persons  also
    should be advised of the availability (at
    cost) of the EIS from the Environmental
    Law Institute, 1356 Connecticut Avenue
    NW., Washington, B.C. 20036.
      (c) Lists of EIS's prepared or under
    preparation and lists  of negative decla-
    rations prepared will be available at  both
    the regional and headquarters  Offices
    of Public Affairs.
      Subpart C—Content of Environmental
               Impact Statements
    § 6.30.6  Cover sheet.
      The cover sheet shall indicate  the
    type of EIS (draft or final), the  official
    project name and number, the respon-
    sible EPA office,  the date, and the sig-
    nature of  the  responsible official.  The
    format Is shown In Exhibit 5.
    § 6.302  Summary sheet.
      The summary sheet shall conform  to
    the format in Exhibit 6, based  on Ap-
    pendix I  of  the August 1,  1973,  CEQ
    Guidelines, or the latest revision of the
    CEQ Guidelines.
    § 6.304  Body of EIS.
      The body of the EIS shall identify, de-
    velop, and analyze the pertinent issues
    discussed  in  the seven sections  below;
    each  section need not  be a separate
    chapter.  This analysis should Include,
    but not be limited to, consideration  of
    the impacts of the proposed project  on
    the environmental areas listed  in  Ap-
    pendix A which are relevant to the proj-
    ect. The EIS shall serve as a means for
    the responsible official and the public to
    assess  the  environmental Impacts  of a
    proposed EPA action,  rather than  as a
    justification for decisions already made.
    It shall be prepared using a systematic,
    interdisciplinary approach and shall In-
    corporate  all relevant analytical  dis-
    ciplines to provide meaningful and  fac-
    tual data, information, and analyses.
    The presentation of data should be clear
    and concise,  yet Include  all facts  nec-
    essary to permit independent evaluation
    and appraisal of the beneficial and ad-
    verse environmental effects of alterna-
    tive actions.  The amount of detail  pro-
    vided should  be commensurate with the
    extent and expected Impact  of the ac-
    tion and the  amount of Information re-
    quired at the particular level of decision
    making. To the extent possible, an EIS
    shall hot be drafted In a style which re-
    quires extensive  scientific or technical
    expertise  to  comprehend and evaluate
    the environmental Impact of a proposed
    EPA action.
      (a) Background and description of the
    proposed action. The EIS shall describe
    the recommended or proposed action, Its
    purpose, where it Is located and its time
    setting. When a decision has been  made
    not to favor  an alternative  until public
    comments  on a  proposed action  have
    been received, the draft EIS may treat
    all feasible alternatives  at similar  levels
    of detail;  the final EIS  should  focus on
    the alternative the draft EIS and pub-
    lic comments indicate is the best. The
    relationship  of the  proposed action to
    other projects and proposals directly af-
    fected by  or  stemming  from it shall be
    discussed, including not only other EPA
    activities, but also those of other govern-
    mental and private organizations.  Land
    use patterns  and population trends in
    the project area and the assumptions on
    which they are based also shall be  In-
    cluded. Available maps,  photos,  and art-
    ists' sketches  should be incorporated
    when they help depict the environmen-
    tal setting.
      (b)  Alternatives to the proposed  ac-
    tion.  The  EIS shall develop,  describe,
    and  objectively  weigh feasible  alterna-
    tives to any  proposed action, including
    the options of taking no action or post-
    poning action. The  analysis should be
    detailed enough to show EPA's compara-
    tive evaluation of the environmental  im-
    pacts,  commitments of  resources,  costs,
    and  risks  of  the proposed  action and
    each  feasible alternative. For  projects
    involving  construction,  alternative sites
    must be analyzed In enough detail  for
    reviewers independently to judge the rel-
    ative desirability of each site. For alter-
    natives involving regionalization,.  the
    effects of varying degrees of  regionaliza-
    tion should be addressed. If a cost-bene-
    fit analysis Is prepared,  It should be  ap-
    pended to the EIS and referenced in the
    body of the EIS. In addition, the reasons
    why the proposed action is believed by
    EPA to be the best course of action shall
    be explained.
      (c) Environmental impacts of the pro-
    posed action.  (1) The positive and nega-
    tive effects of the proposed  action as it
    affects both  the national and  Interna-
    tional  environment should be  assessed.
    The attention given to different environ-
    mental factors  will vary according to
    the nature, scale,  and location of pro-
    posed actions. Primary attention should
    be given to those factors most evidently
    affected by the proposed action.  The fac-
    tors shall include, where appropriate, the
    proposed action's effects on the resource
    base, Including land, water  quality and
    quantity, air  quality, public services and
    energy  supply. The  EIS  shall  describe
    primary and  secondary environmental
    impacts, both beneficial and adverse,  an-
    ticipated from the action. The descrip-
    tion  shall Include  short term and long
    term impacts on both the natural and
    human environments.
      (2) Primary impacts  are  those that
    can  be attributed directly to  the pro-
    posed action. If the action is a  field  ex-
    periment,  materials introduced  Into  the
    environment  which might damage cer-
    tain plant communities or wildlife species
    would be a primary impact. If the action
    involves construction of a facility, such
    as a sewage  treatment works,  an office
    building or a laboratory, the primary Im-
    pacts of the action would  Include  the
    environmental impacts related to con-
    struction and operation of  the facility
    and land use  changes at the  facility site.
      (3) Secondary impacts are Indirect or
    Induced changes. If the action involves
    construction  of a facility, the secondary
    impacts would include the environmental
    impacts related to:
      (i)  induced changes in the pattern
    of land use,  population density and re-
    lated effects  on air and water quality
    or other natural resources;
      (11) increased growth at a faster rate
    than planned for or above the total level
    planned by the existing community.
      (4) A discussion of how socloeconomic
    activities and land use changes related
    to the proposed  action conform or con-
    flict with the goals and objectives of ap-
    proved or proposed  Federal,  regional,
    State and local  land use plans, policies
    and controls  for the project area should
    be included In the EIS. If a  conflict ap-
    pears to be unresolved in  the EIS, EPA
    should explain why  it has  decided  to
    proceed without full reconciliation.
      (d) Adverse impacts which cannot be
    avoided should the proposal be imple-
    mented and steps  to  minimize  harm to
    the environment. The EIS shall describe
    the kinds  and  magnitudes  of adverse
    impacts which cannot be reduced in se-
    verity or which can be reduced to an ac-
    ceptable level but not eliminated. These
    may include  water  or air pollution, un-
    desirable land use  patterns,  damage to
    fish  and wildlife habitats,  urban con-
    gestion, threats to human health or other
    consequences adverse to  the  environ-
    mental goals  in section 101 (b) of NEPA.
    Protective  and  mitlgative  measures  to
    be taken as part of the proposed action
    shall  be  identified. These  measures  to
    reduce or compensate for any  environ-
    mentally detrimental aspect of the pro-
    posed action  may include those of EPA,
    its contractors and grantees and others
    involved in the action.
      (e) Relationship betwen  local  short
    term uses, of man's environment and the
    maintenance  and enhancement of long
    term  productivity.  The  EIS shall  de-
    scribe the extent to which the  proposed
    action involves tradeoffs between short
    term environmental gains at the expense
    of long term  gains or vice-versa and the
    extent to which the proposed action fore-
    closes future options.  Special attention
    shall  be  given to effects which narrow
    the range  of future uses of land  and
    v/ater resources  or  pose long term risks
    to health or safety. Consideration should
    be given to windfall gains or significant
    decreases   in  current property  values
    from implementing the proposed action.
    In addition,  the reasons  the  proposed
    action is believed by EPA to be justified
    now, rather than reserving a long term
    option for other alternatives, including
    no action, shall be explained.
      (f)  Irreversible and irretrievable com-
    mitments of  resources to the  proposed
    action should it be implemented.  The
    EIS shall describe  the extent to which
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    16820
         RULES AND REGULATIONS
    the proposed  action  requires  commit-
    ment of construction  materials,.person-
    hours and funds to design and  imple-
    ment the project, as well as curtails the
    range of future  uses of land and water
    resources. For example, induced growth
    in undeveloped areas  may curtail alter-
    native uses of that  land. Also, irreversi-
    ble environmental  damage  can  result
    from  equipment malfunctions or  indus-
    trial accidents at the project site. There-
    fore, the need for any irretrievable and
    significant commitments of  resources
    shall be explained fully.
       (g> Problems and objections raised by
    other Federal, State and local agencies
    and by interested persons in the  review
    process. Final EIS's (and draft EIS's if
    appropriate)  shall summarize the com-
    ments and suggestions made by review-
    ing organizations and shall describe the
    disposition of issues raised, e.g., revisions
    to the proposed action to mitigate  an-
    ticipated impacts or objections. In  par-
    ticular, the EIS  shall  address the major
    issues raised when the EPA position dif-
    fers  from  most  recommendations  and
    explain the factors  of overriding impor-
    tance overruling the adoption of sugges-
    tions. Reviewer's statements should be
    set forth in a "comment" and discussed
    in a "response." In addition, the  source
    of all comments should be  clearly iden-
    tified,  and  copies  of the  comments
    should be attached to the  final  EIS.
    Summaries of comments should  be at-
    tached when a response has been  excep-
    tionally long or the same comments were
    received from many reviewers.
    § 6.306   Documentation.
      All books, research reports, field study
    reports, correspondence and other docu-
    ments which provided the data base for
    evaluating the proposed action and al-
    ternatives discussed in the EIS shall be
    used  as references  in the body  of  the
    EIS  and  shall be  included in a bibli-
    ography attached to the EIS.
    Subpart D—EPA Public Hearings on  EIS's
    § 6.400   General.
      While EPA  is  not required by statute
    to hold public hearings on EIS's, the re-
    sponsible  official should hold  a  public
    hearing on a draft EIS whenever a hear-
    ing may facilitate the resolution of  con-
    flicts  or  significant public controversy.
    This hearing may be in addition to public
    hearings held on facilities plans or sec-
    tion 209  plans.  The responsible  official
    may take special measures to involve in-
    terested persons through personal  con-
    tact.
    § 6.402   Public hearing process.
       (a) When  public hearings are to be
    held, EPA shall inform the public of the
    hearing, for example, with a notice in the
    draft EIS. The notice should follow the
    summary  sheet at the beginning  of the
    EIS. The draft EIS shall be available for
    public review  at least thirty (30)  days
    before the public hearing. Public notice
    shall be given at least fifteen  (15) work-
    ing days before  the public hearing and
    shall  include:
      (1) Publication of a public notice in a
    newspaper which covers the project area,
    identifying the project, announcing the
    date, time and place of the hearing and
    announcing the availability  of detailed
    information on the proposed action for
    public inspection at one or more locations
    in the area in which the project will be
    located. "Detailed information" shall in-
    clude a copy of the project  application
    and  the draft EIS.
      (2) Notification of appropriate  State
    and local agencies and appropriate State,
    regional   and  metropolitan  clearing-
    houses.
      (3) Notification of interested persons.
      (b) A  w.ritten record of the hearing
    shall be  made. A stenographer may  be
    used to record the  hearing. As a mini-
    mum, the record shall contain a list of
    witnesses with the text of each presenta-
    tion. A summary of the record, including
    the issues raised, conflicts  resolved and
    unresolved,  and  any  other  significant
    portions of the record,  shall be appended
    to the final EIS.
      (c) When a public  hearing has been
    held by another Federal, State, or local
    agency  on an EPA  action,  additional
    hearings are not necessary. The respon-
    sible official  shall decide if additional
    hearings are needed.
      (d) When a program office is the origi-
    nating office,  the appropriate regional
    office will provide assistance to the origi-
    nating office in holding any public hear-
    ing if assistance is requested.
    
    Subpart  E—Guidelines  for   Compliance
      With NEPA  in the Title II  Wastewater
      Treatment Works Construction Grants
      Program and the Areawide Waste Treat-
      ment Management Planning Program
    
    § 6.500  Purpose.
      This subpart amplifies the general EPA
    policies and procedures described in Sub-
    parts A through D with detailed proce-
    dures for compliance with NEPA in the
    wastewater treatment works construction
    grants program and the areawide waste
    treatment  management  planning  pro-
    gram.
    
    § 6.502  Definitions.
      (a) "Step 1 grant." A grant for prepa-
    ration of a facilities plan as described in
    40 CFR 35.930-1.
      (b) "Step 2  grant." A grant for prepa-
    ration  of  construction  drawings  and
    specifications  as described  in 40 CFR
    35.930-1.
      (c) "Step 3  grant." A grant for fabri-
    cation and building of a publicly owned
    treatment works as described in 40 CFR
    35.930-1.
    
    § 6.504  Applicability.
      (a)  Administrative  actions  covered.
    This subpart applies to the administra-
    tive  actions listed below:
      (1) Approval of all  section 208 plans
    according  to  procedures  in  40  CFR
    35.1067-2;
      (2) Approval of all facilities plans ex-
    cept those listed in paragraph (a) (5) of
    this  section;
      (3) Award of step 2 and step 3 grants,
    if an approved facilities plan was not re-
    quired;
      (4) Award of a step 2  or  step 3  grant
    when either the project or its impact has
    changed significantly from that described
    in the  approved facilities plan, except
    when the situation  in paragraph (a) (5)
    of this  section  exists;
      (5) Consultation  during the NEPA re-
    view process. When there are overriding
    considerations of cost  or impaired pro-
    gram effectiveness,  the Regional Admin-
    istrator may award a step 2 or a step 3
    grant for a discrete  segment of the proj-
    ect  plans  or  construction  before the
    NEPA review is completed if this project
    segment is noncontroversial. The.remain-
    ing portion of the project shall be evalu-
    ated to determine if  an EIS is required. In
    applying the criteria for  this determina-
    tion,  the entire  project shall be  con-
    sidered, including those parts  permitted
    to proceed. In no case may these types of
    step 2 or step 3  grants be awarded unless
    both the Office  of Federal Activities and
    CEQ  have  been consulted, a negative
    declaration  has been issued on the seg-
    ments permitted to  proceed,  and  the
    grant award contains  a specific  agree-
    ment prohibiting action  on  the segment
    of planning or construction for which the
    NEPA review is not complete. Examples
    of consultation during the NEPA review
    process are: award  of a step 2 grant for
    preparation of  plans and specifications
    for a large treatment plant,  when the
    only unresolved NEPA issue is where to
    locate the sludge disposal site; or award
    of a step 3 grant for site clearance fo'r a
    large treatment plant, when  the  unre-
    solved NEPA issue is whether sludge from
    the plant should be incinerated at the
    site  or  disposed  of elsewhere  by  other
    means.
      (b)  Administrative  actions excluded.
    The actions listed below  are not subject
    to the requirements of this part:
      (1) Approval of State priority lists;
      (2) Award of a step 1 grant;
      (3) Award of a  section 208 planning
    grant;
      (4) Award of a step 2 or  step 3  grant
    when no significant changes in the facil-
    ities plan have occurred;
      (5) Approval of  issuing an  invitation
    for bid or awarding a  construction con-
    tract;
      (6) Actual physical commencement of
    building or fabrication;
      (7) Award of a section 206  grant for re-
    imbursement;
      (8) Award of  grant increases when-
    ever  § 6.504(a) (4)  does  not apply;
      (9) Awards of training assistance un-
    der FWPCA, as amended, section 109(b).
      (c) Retroactive application.  The new
    criteria in | 6.510 of this subpart do not
    apply to step 2  or step 3  grants awarded
    before July 1,1975. However, the Region-
    al Administrator may apply  the new cri-
    teria of this subpart when he considers it
    appropriate. Any negative  declarations
    issued before the effective  date of this
    regulation shall remain in effect.
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    S 6.506  Completion of NEPA procedures
         before start of administrative actions.
      See 5 6.108 and § 6.504.
    § 6.510  Criteria  for preparation of en-
         vironmental impact statements.
      In addition to considering the criteria
    In  § 6.200, the Regional Administrator
    shall assure that an EIS will be prepared
    on a treatment works facilities plan, 208
    plan or other appropriate water quality
    management plan when:
      (a) The treatment works or plan will
    Induce significant changes (either abso-
    lute changes or increases in the rate of
    change)  in industrial, commercial, agri-
    cultural, or residential land use concen-
    trations  or distributions. Factors  that
    should be considered In determining if
    these changes are significant include but
    are not limited to: the vacant land sub-
    ject to increased development pressure
    as a result of the treatment works; the
    increases in population  which may be
    induced; the  faster  rate of change of
    population; changes In population den-
    sity; the potential for overloading sew-
    age treatment works; the extent to which
    landowners may benefit  from the areas
    subject to increased development;  the
    nature of land use regulations in the af-
    fected area and  their potential  effects
    on development; and deleterious changes
    in the availability or demand for energy.
      (to) Any major part of the  treatment
    works will be located on productive wet-
    lands or will have  significant adverse
    effects on wetlands, including  secondary
    effects.
      (c) Any major part of the  treatment
    works will be  located on or  significantly
    affect the habitat of wildlife on the De-
    partment of Interior's threatened  and
    endangered species lists.
      (d) Implementation of the  treatment
    works or plan may directly  cause or in-
    duce changes that significantly:
      (1) Displace population;
      (2)  Deface  an  existing  residential
    area; or
      (3)   Adversely   affect   significant
    amounts of prime .agricultural land or
    agricultural operations on this land.
      (e) The treatment works or plan will
    have significant adverse effects on park-
    lands, other public lands or areas of rec-
    ognized  scenic, recreational,  archaeo-
    logical or historic value.
      (f) The works or plan  may directly or
    through  induced development have a
    significant adverse effect upon local am-.
    blent air quality, local  ambient noise
    levels,  surface or groundwater quantity
    or quality, fish, wildlife, and their natu-
    ral habitats.
      (g) The treated effluent is being  dis-
    charged into a body of water  where the
    present classification is too  lenient or is
    being challenged as too low to protect
    present or recent uses, and the effluent
    will not be of sufficient quality to meet
    the requirements of these uses.
    § 6.512  Procedures   for implementing
         NEPA.
      (a)  Environmental assessment.  An
    adequate environmental assessment must
    be an integral, though Identifiable, part
    of any facilities or section 208 plan sub-
    mitted to EPA. (See § 6.202 for a general
    description.) The information in the fa-
    cilities  plan,  particularly the environ-
    mental assessment, will provide the sub-
    stance of an EIS and shall be submitted
    by the applicant. The analyses that con-
    stitute  an adequate environmental as-
    sessment shall include:
      (1) Description of the existing envi-
    ronment loithout the project. This shall
    include for the delineated planning area
    a description of the present environmen-
    tal conditions relevant to the analysis of
    alternatives  or determinations of  the
    environmental impacts of the proposed
    'action. The description shall include, but
    not be limited to, discussions of which-
    ever areas are applicable to a particular
    study:  surface and groundwater  qual-
    ity;  water supply and use;  general hy-
    drology; air quality; noise levels, energy
    production and consumption;  land use
    trends; population projections, wetlands,
    flpodplains, coastal zones and other en-
    vironmentally  sensitive  areas;  historic
    and  archaeological sites; other related
    Federal or State projects in the area; and
    plant and animal communities  which
    may be affected, especially those contain-
    ing threatened or endangered species.
      (2) Description of the future environ-
    ment without the  project.  The  future
    environmental conditions with the no
    project alternative shall be forecast, cov-
    ering the same areas listed  in § 6.512
      (3) Documentation. Sources of infor-
    mation used to describe the existing en-
    vironment and to assess future environ-
    mental impacts should be documented.
    These sources  should Include regional,
    State and Federal agencies with respon-
    sibility or interest in the types of impacts
    listed in  § 6.512(a) (1) . In particular, the
    following agencies should be consulted:
      (i) Local and regional land use plan-
    ning agencies  for  assessments of  land
    use  trends and population projections,
    especially those  affecting  size, timing,
    and location of facilities, and planning
    activities funded under section 701 of
    the  Housing and Community Develop-
    ment Act of  1974 (Pub. L. 93-383) ;
      (ii) The HUD Regional Office if a proj-
    ect involves a flood risk area identified
    under the Flood Disaster Protection Act
    of 1973 (Pub. L. 93-234) ;
      (ill) The State coastal zone manage-
    ment agency, if a coastal zone is affected;
      (iv) The Secretary of the Interior or
    Secretary of Agriculture, if a wild  and
    scenic river is affected;
      (v) The Secretary  of  the Interior or
    Secretary of  Commerce, if a threatened
    or endangered  species is affected;
      (vi) The Fish and Wildlife Service
    (Department of Interior), the Depart-
    ment of  Commerce, and the U.S. Army
    Corps of Engineers,  if a wetland is
    affected.
      (4)  Evaluation of  alternatives.  This
    discussion shall include a  comparative
    analysis  of feasible options and a sys-
    tematic  development  of  wastewater
    treatment alternatives. The alternatives
    shall be screened with respect to capital
    and operating costs; significant primary
    and secondary  environmental  effects;
    physical,  legal  or  Institutional  con-
    straints; and whether or not they meet
    regulatory requirements. Special atten-
    tion should be given to long term Im-
    pacts, Irreversible impacts and  induced
    Impacts such as development. The rea-
    sons for rejecting any alternatives shall
    be presented In addition to any signifi-
    cant environmental benefits  precluded
    by rejection of an alternative. The anal-
    ysis should consider, when relevant  to
    the project:
      (i)  Flow  and  waste reduction meas-
    ures, including infiltration/inflow reduc-
    tion;
      (ii) Alternative locations, capacities,
    and construction  phasing of facilities;
      (iii)  Alternative waste management
    techniques, includign treatment and dis-
    charge,  wastewater reuse and land ap-
    plication;
      (iv) Alternative methods  for disposal
    of sludge  and other residual waste, In-
    cluding  process  options  and  final dis-
    posal options;
      (v) Improving effluent quality through
    more efficient operation  and  mainte-
    nance ;
      (vi) For assessments associated  with
    section 208 plans, the analysis of options
    shall include in addition:
      (A) Land use  and  other regulatory
    controls, fiscal controls, non-point source
    controls,  and  institutional  arrange-
    ments; and
      (B) Land management practices.
      (5) Environmental impacts of the pro-
    posed action. Primary and secondary
    impacts of the proposed action shall  be
    described, giving special attention to un-
    avoidable impacts, steps to mitigate ad-
    verse impacts, any Irreversible or Irre-
    trievable commitments of resources  to
    the project and the relationship between
    local short  term uses of the  environ-
    ment and  the maintenance  and en-
    hancement  of long term  productivity.
    See § 6.304 (c), (d), (e), and (f) for  an
    explanation of these terms and examples.
    The significance  of land use Impacts
    shall  be  evaluated, based  on  current
    population of the  planning area; de-
    sign year population for the service area*
    percentage of the service area currently
    vacant; and plans for staging facilities.
    Special  attention  should be  given to in-
    duced changes in population patterns and
    growth, particularly if a project involves
    some degree of regionalization. In addi-
    tion to  these items, the  Regional Ad-
    ministrator may renuire that other anal-
    yses and data,  which  he determines
    are needed to  comply with NEPA,  be
    included with the facilities or section
    208 plan. Such requirements should  be
    discussed  during  preapplication  con-
    ferences.  The  Regional  Administrator
    also may  require submission of supple-
    mentary information  either  before  or
    after a step 2 grant  or  before  a step
    3 grant award If  he determines  It la
    needed for compliance with NEPA. Re-
    quests for  supplementary information
    shall be made In writing.
      (6) Steps to minimize adverse effects.
    This section shall describe structural and
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    16822
          RULES AND REGULATIONS
    nonstructural measures, if  any,  in the
    facilities plan to mitigate or eliminate
    significant adverse effects on the human
    and natural environments. Structural
    provisions include changes in facility de-
    sign,  size,  and  location; nonstructural
    provisions  include  staging  facilities as
    well as developing and enforcing  land
    use  regulations  and  environmentally
    protective regulations.
       (b) Public hearing. The applicant shall
    hold at least one public hearing before a
    facilities plan is adopted, unless  waived
    by the Regional  Administrator  before
    completion of'the facilities plan accord-
    ing to  § 35.917-5 of the Title n construc-
    tion grants regulations. Hearings should
    be held on section  208  plans. A copy of
    the environmental assessment should be
    available for public  review before the
    hearing and at the hearing, since these
    hearings provide an opportunity to ac-
    cept public input on  the environmental
    issues  associated with the facilities plan
    or the 208 water quality management
    strategy. In addition, a Regional Admin-
    istrator may elect to hold an EPA hear-
    ing if  environmental  issues remain un-
    resolved. EPA  hearings  shall  be  held
    according to procedures in § 6.402.
       (c)  Environmental review. An envi-
    ronmental  review of a facilities plan or
    section 208  plan  shall  be conducted
    according  to the procedures in  § 6.204
    and% applying the criteria of §6.510. If
    deficiencies exist in the  environmental
    assessment, they shall  be identified In
    writing by the Regional Administrator
    and  must be corrected before the  plan
    can be approved.
       (d)  Additional procedures. (1)  His-
    toric and archaeological sites. If a facil-
    ities or section 208 plan  may affect prop-
    erties   with   historic,  architectural,
    archaeological or cultural value  which
    are listed in or eligible for listing in the
    National  Register of  Historic Places' or
    may cause irreparable loss or destruction
    of significant scientific, prehistoric, his-
    toric or archaeological  data, the appli-
    cant  shall  follow  the  procedures  in
    §6.214(a).
       (2) If the facilities or section 208 plan
    may affect  wetlands, floodplains, coastal
    zones,  wild and scenic rivers, fish  or
    wildlife,  the  Regional  Administrator
    shall follow the appropriate procedures
    described in § 6.214(b).
       (e) Notice of intent. The notice of in-
    tent on a facili/us plan or section 208
    plan shall be issued according to § 6.206.
       (f) Scope of E/S. Jt is the Regional
    Administrator's  responsibility to  deter-
    mine the scope  of  the  EIS. He should
    determine if an EIS should  be prepared
    on a facilities plan(s)  or section 208 plan
    and  which environmental areas should
    be discussed in greatest detail in the EIS.
    Once an  EIS has been prepared for the
    designated  'section 208 area,  another
    need not be prepared unless the signifi-
    cant impacts of individual  facilities or
    other plan  elements were not'adequately
    treated in  the  EIS. The Regional Ad-
    ministrator should document his decision
    not  to prepare an EIS on Individual
    facilities.
       (g)  Negative declaration. A negative
     declaration on a facilities  plan  or sec-
     tion 208 plan shall be prepared according
     to § 6.212. Once a negative declaration
     and environmental appraisal have been
     prepared for the facilities plan for a cer-
     tain  area,  grant awards  may proceed
     without preparation of additional nega-
     tive declarations, unless the project has
     changed  significantly  from that  de-
     scribed in the facilities plan.
    
     §6.514   Content.of environmental im-
         pact statements.
    
       EIS's  for treatment works or plans
     shall be prepared according to § 6.304.
    
     Subpart   F-r-Guidelines for Compliance
       With NEPA in Research  and  Develop-
       ment Programs and Activities
     § 6.600   Purpose.
    
       This  subpart  amplifies  the  general
     EPA policies and procedures described
     in Subparts A through D  by providing
     procedures for compliance with NEPA
     on actions undertaken by  the Office of
     Research  and Development  (ORD).
    
     § 6.602   Definitions.
       (a)  "Work plan." A document which
     defines and schedules all  projects re-
     quired to fulfill the  objectives of the
     program plan.
       (b)  "Program plan." An  overall plan-
     ning document for a major research area
     which describes one or more research
     objectives, including outputs and target
     completion dates, as well as person-year
     and dollar resources.
       (c)  "Appropriate  program  official."
     The official at each decision level within
     ORD to whom the Assistant Administra-
     tor delegates  responsibility  for .NEPA
     compliance.
       (d)  "Exemption certification." A cer-
     tified  statement delineating those ac-
     tions specifically exempted from NEPA
     compliance by existing legislation.
     § 6.604   Applicability.
       The requirements of this subpart are
    •applicable  to  administrative   actions
     undertaken to approve program plans,
     work plans, and projects,  except those
     plans  and projects excluded by existing
     legislation. However, no administrative
     actions are excluded from the additonal
     procedures in § 6.214 of this part con-
     cerning historic sites,  wetlands,  coastal
     zones, wild and scenic  rivers, floodplains
     or fish and wildlife.
    
     § 6.608  Criteria for determining when
         to prepare EIS's.
       (a)  An EIS shall be prepared by ORD
     when any of the criteria in  § 6.200 apply
     or when:
       (1)  The  action will have  significant
     adverse  impacts on public parks, wet-
     lands, floodplains, coastal zones, wildlife
     habitats,  or areas of  recognized  scenic
     or recreational  value.
       (2) The action will significantly deface
     an existing residential  area.
       (3) The action may directly or through
     induced  development have  a significant
     adverse  effect upon local  ambient air
     quality, local ambient noise levels, sur-
    face or groundwater quality; and fish,
    wildlife or their'natural habitats.
       (4) The treated effluent is being dis-
    charged into a body of water where the
    present classification is being challenged
    as too low to protect  present or recent
    uses, and the  effluent will not  be of
    sufficient  quality to meet the require-
    ments of these uses.
       (5) The project consists of field tests
    involving the introduction of significant
    quantities of: toxic or polluting agricul-
    tural chemicals, animal  wastes,  pesti-
    cides,  radioactive  materials, or  other
    hazardous substances  into the environ-
    ment by  ORD,  its grantees or its con-
    tractors.
       (6) The action may involve the intro-
    duction of  species or subspecies  not
    indigenous to an area.
       (7) There is a high probability of an
    action ultimately being implemented on
    a  large scale, and this implementation
    may result in significant environmental
    impacts.
       (8) The project involves commitment
    to a new technology which is significant
    and may restrict future viable alterna-
    tives.
       (b) An EIS will not usually be needed
    when:
       (1)  The  project  is  conducted com-
    pletely  within a laboratory or other fa-
    cility, and external environmental effects
    have been  minimized  by methods for
    disposal of laboratory wastes and safe-
    guards  to prevent  hazardous materials
    entering the environment accidentally;
    or
       (2) The project  is a relatively small
    experiment or investigation that is part
    of a non-Federally funded activity of
    the private  sector, and it makes no sig-
    nificant new or additional  contribution
    to existing pollution.
    § 6.610  Procedures for compliance with
         NEPA.
      EIS  related activities for  compliance
    with NEPA will be  integrated into the
    decision levels of ORD's research plan-
    ning system to  assure  managerial con-
    trol. This control includes those adminis-
    trative actions which do not come under
    the applicability of  this subpart by as-
    suring that they are made the subject
    of an exemption certification and filed
    with the Office of Public Affairs (OPA).
    ORD's internal  procedures provide de-
    tails for NEPA compliance.
      (a) Environmental  assessment.  (1)
    Environmental assessments shall be sub-
    mitted with  all grant applications  and
    all unsolicited contract proposals. The .
    assessment shall contain the same In-
    formation required for EIS's in § 6.304.
    Copies of  § 6.304 (or more detailed guid-
    ance when available) and a notice of the
    requirement for assessment shall be In-
    cluded in  all grant application kits  and
    attached to letters  concerning the sub-
    mission of unsolicited proposals.
      (2) In  the case  of  competitive  con-
    tracts,  assessments  need  not be  sub-
    mitted by potential contractors since the
    NEPA procedures must be completed be-
    fore  a request for proposal (RFP) Is Is-
    sued. If there is a question concerning
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                                                 RULES AND  REGULATIONS
                                                                           16823
    the need for an assessment, the poten-
    tial contractor should contact the official
    responsible for the contract.
      (b) Environmental review. (1) At the
    start  of the planning year, an environ-
    mental review will be performed for each
    program plan with Its supporting sub-
    structures (work plans and projects)  be-
    fore Incorporating them Into the ORD
    program planning system,  unless they
    are excluded from review by existing leg-
    islation. This review Is an evaluation of
    the potentially adverse environmental ef-
    fects  of the efforts required by the pro-
    gram plan. The criteria in § §.608 shall be
    used in conducting this review. Each pro-
    gram plan with its supporting substruc-
    tures  which does not have significant ad-
    verse impacts may be dismissed from fur-
    ther current year environmental consid-
    erations with  a single negative declara-
    tion.  Any supporting substructures of a
    program plan which cannot be dismissed
    with  the parent plan shall be  reviewed
    at the appropriate subordinate levels of
    the planning system for NEPA compli-
    ance.
      (i)  All continuing program plans and
    supporting substructures, including those
    previously dismissed from consideration,
    will be  reevaluted annually for NEPA
    compliance. An environmental review
    will coincide with the annual  planning
    cycle  and whenever a major redirection
    of  a  parent  plan  is undertaken.  All
    NEPA-associated documents will be  up-
    dated as appropriate.
      (il) All approved program plans and
    supporting substructures, less budgetary
    data,  will be filed in the OPA with a  no-
    tice of Intent or negative declaration and
    environmental appraisal.
      (ill) Later  plans  and/or  projects,
    added to  fulfill the mission objectives
    but not Identified at  the time  the pro-
    gram  plans were approved,  will be sub-
    jected to the same NEPA requirements
    for environmental assessments and/or
    reviews.
      (Iv) Those projects subjected to  en-
    vironmental assessments as outlined In
    paragraph  (a) of this section  and  not
    exempt  under  existing legislation also
    shall  undergo an environmental review
    before work begins.
      (c)  Notice of intent and EIS.
      (1)  If the reviews conducted accord-
    Ing to paragraph Cb)  of  this section re-
    veal  a  potentially  significant  adverse
    effect on the environment  and the  ad-
    verse  impact cannot be eliminated by re-
    planning, the  appropriate program offi-
    cial shall, after making sure the project
    is to be funded, issue a notice of intent
    according to § 6.206, and  through proper
    organizational channels, shall request the
    Regional Administrator to assist him in
    the preparation and distribution of  the
    EIS.
      (2)  As soon as possible after release of
    the notice of intent, the appropriate pro-
    gram  official shall prepare a draft EIS us-
    ing the criteria In Subpart B, § 6.208 and
    Subpart C.  Through proper organiza-
    tional channels, he shall request the Re-
    gional Administrator to assist him in  the
     preparation and distribution of the draft
     EIS.
       (3) The appropriate program official
     shall prepare final  EIS's  according to
     criteria In Subpart B, § 6.210 and Sub-
     part C.
       (4) All draft and final EIS's  shall be
     sent through the proper organizational
     channels to the Assistant Administrator
     for ORD for approval. The approved
     statements then  will be distributed ac-
     cording to the procedures in Appendix C.
       (d) Negative declaration and environ-
     mental impact appraisal. If an environ-
     mental  review  conducted  according to
     paragraph (b) of this section reveals that
    •proposed actions will not have significant
     adverse environmental impacts, the ap-
     propriate program official shall prepare a
     negative declaration and environmental
     impact appraisal  according to Subpart B,
     § 6.212. Upon assurance that the program
     will be funded, the appropriate program
     official shall distribute the negative dec-
     laration  as  described  in § 6.212  and
     make copies of the negative  declaration
     and appraisal available in the OPA.
       (e) Project start.  As required by § 6.
     108,  a contract  or  grant  shall not  be
     awarded for an extramural project, nor
     for continuation  of what was previously
     an Intramural project,  until  at least
     fifteen (15) working days after  a nega-
     tive declaration has been issued or thirty
     (30)  days after forwarding the final EIS
     to the Council on  Environmental Quality.
    
     Subpart  G—Guidelines  for   Compliance
       With NEPA in Solid Waste Management
       Activities
     § 6.700   Purpose.
       This subpart amplifies the general pol-
     icies and  procedures described in Sub-
     parts A through D  by providing addi-
     tional procedures for compliance with
     NEPA on actions  undertaken  by the Of-
     fice of Solid Waste Management Pro-
     grams (OSWMP).
     § 6.702   Criteria  for  the preparation of
        environmental assessments and EIS's.
       (a) Assessment preparation  criteria.
     An environmental assessment need not
     be submitted with all grant applications
     and contract proposals. Studies  and in-
     vestigations do not require assessments.
     The following sections describe when an
     assessment is or is not required for other
     actions:
       (1) Grants,  (i) Demonstration proj-
     ects. Environmental  assessments must
     be submitted with all applications  for
     demonstration grants that will involve
     construction, land use  (temporary  or
     permanent), transport, sea disposal, any
     discharges into the air or water, or any
     other activity having any direct or in-
     direct effects on the environment ex-
     ternal to the facility in which the work
     will be  conducted. Preapplication .pro-
     posals for these  grants will not require
     environmental assessments.
       (il) Training.  Grant applications for
     training  of  personnel will not  require
     assessments.
       (iii) Plans. Grant applications for the
     development  of  comprehensive  State,
    Interstate, or local solid waste manage-
    ment plans will not require environmen-
    tal assessments. A detailed analysis  of
    environmental   problems  and   effects
    should be part of  the planning process,
    however.
       (2) Contracts,  (i)  Sole-source con-
    tract proposals.  Before  a sole-source
    contract can be awarded, an environ-
    mental assessment must be  submitted
    with a bid proposal for a contract which
    will involve construction, land use (tem-
    porary or permanent), sea disposal, any
    discharges into the air or water, or any
    other activity that will  directly or Indi-
    rectly affect the environment external
    to  the facility in which the work will
    be performed.
       (ii) Competitive  contract  proposals.
    Assessments  generally  will not be re-
    quired on competitive contract proposals.
       (b) EIS preparation criteria. The re-
    sponsible official shall  conduct  an -en-
    vironmental  review on  those OSWMP
    projects  on which an. assesment Is re-
    quired or which may have effects on the
    environment external to the  facility  in
    which the work will be performed. The
    criteria In § 6.200  shall be  utilized  in
    determining  whether an EIS need  be
    prepared.
    
    § 6.704  Procedures for compliance with
         NEPA.
       (a)  Environmental  assessment. (1)
    Environmental assessments shall be sub-
    mitted to EPA according to procedures
    in § 6.702. If there is a question concern-
    ing the need for an assessment,  the po-
    tential contractor or grantee should con-
    sult with the appropriate project officer
    for the grant or contract.
       (2) The assessment shall contain the
    same sections  specified  for EIS's  in
    § 6.304. Copies  of  § 6.304 (or more de-
    tailed guidance  when available)  and a
    notice alerting potential grantees and
    contractors of  the assessment require-
    ments in § 6.702 shall be included in all
    grant application kits, attached to letters
    concerning the submission of unsolicited
    proposals, and included with  all RFP's.
       (b) Environmental review. An envi-
    ronmental review  will be conducted on
    all projects which require  assessments
    or  which will  affect the environment
    external to the facility in which the work
    will be performed. This review must be
    conducted  before  a grant  or contract
    award is  made on an extramural project
    or before an intramural project begins.
    The guidelines in § 6.200 will be used
    to determine if the project will have any
    significant environmental  effects. This
    review will include an evaluation of the
    assessment by both the  responsible offi-
    cial  and  the appropriate Regional Ad-
    ministrator. The Regional Administra-
    tor's comments will include his  recom-
    mendations on the need for an EIS. No
    detailed review or  documentation Is re-
    quired on projects for which assessments
    are not required and which will not affect
    the environment external to a facility.
      (c) Notice  of intent and EIS. If any
    of the criteria In § 6.200 apply, the re-
    sponsible official will assure that a notice
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    16824
          RULES AND  REGULATIONS
    of intent and a draft EIS are prepared.
    The responsible official may request the
    appropriate Regional  Administrator, to
    assist  him  in the distribution  of the
    NEPA-associated  documents. Distribu-
    tion procedures are listed in Appendix C.
      (dyNegative declaration and environ-
    mental impact appraisal. If the environ-
    mental review indicated no significant
    environmental impacts, the responsible
    official will assure that a negative decla-
    ration and environmental appraisal are
    prepared. These documents need not be
    prepared for  projects  not requiring an
    environmental review.
      (e) The EIS process  for  the Office of
    Solid Waste Management  Programs  is
    shown graphically in Exhibit 7.
    Subpart  H—Guidelines   for  Compliance
      With NEPA  in Construction of  Special
      Purpose Facilities and Facility Renova-
      tions
    § 6.800  Purpose.
      This  subpart amplifies general EPA
    policies and procedures described in Sub-
    parts A through D by providing detailed
    procedures for the preparation  of  EIS's
    on  construction and renovation  of spe-
    cial purpose facilities.
    
    § 6.802  Definitions.
      (a) "Special purpose facility." A build-
    Ing or space, including land incidental to
    its use, which is wholly or predominantly
    utilized for the  special  purpose  of an
    agency and  not generally suitable for
    other uses,  as determined by the  Gen-
    eral Services Administration.
      (b)  "Program  of  requirements."  A
    comprehensive document  (booklet) de-
    scribing program activities to be accom-
    plished in the new special purpose facili-
    ty or Improvement. It includes architec-
    tural, mechanical, structural, and space
    requirements.
      (c)  "Scope  of work." A  document
    similar in-con tent to the program of re-
    quirements but substantially abbreviated.
    It is usually prepared  for small-scale
    projects.
    
    § 6.804  Applicability.
      (a) Actions covered.  These guidelines
    apply to all new special purpose facility
    construction,  activities  related to  this
    construction (e.g., site acquisition  and
    clearing),  and any  improvements or
    modifications  to facilities having poten-
    tial environmental effects external to the
    facility, including new construction and
    improvements undertaken and funded by
    the  Facilities  Management   Branch,
    Facilities and Support Services Division,
    Office of Administration; by a regional
    office;  or  by a National Environmental
    Research  Center.
      (b)  Actions excluded.  This  subpart
    does not apply to those activities of the
    Facilities  Management Branch,  Facili-
    ties  and Support Services  Division, for
    which the branch does not have full fis-
    cal  responsibility for  the entire project.
    This includes  pilot plant construction,
    land acquisition, site clearing and access
    road construction  where  the Facilities
    Management  Branch's activity is only
    supporting a project financed by a pro-
    gram office. Responsibility for consider-
    ing  the  environmental impacts  of such
    projects  rests with the office managing
    and funding  the entire  project. Other
    subparts of this regulation apply depend-
    ing on the nature of the project.
    § 6.808  Criteria for the preparation of
         environmental assessments and EIS's.
       (a)  Assessment  preparation criteria.
    The responsible official shall  request an
    environmental assessment from a con-
    struction contractor or consulting archi-
    tect/engineer  employed by EPA  if he is
    involved in the planning, construction or
    modification of special purpose facilities
    when his activities have potential en-
    vironmental effects external to the facil-
    ity. Such modifications include  but are
    not limited to: facility additions, changes
    in central heating systems or wastewater
    treatment systems, and land clearing for
    access roads and parking lots.
       (b) EIS preparation criteria. The re-
    sponsible official shall conduct  an en-
    vironmental review of all actions involv-
    ing  construction  of  special  purpose
    facilities and improvements to these fa-
    cilities. The guidelines in § 6.200 shall be
    used to determine whether an EIS shall
    be prepared.
    § 6.810  Procedures for compliance with
         NEPA.
       (a) Environmental review and assess-
    ment. (1) An environmental review shall
    be conducted  when the program of re-
    quirements or scope of work has been
    completed for the construction, improve-
    ment, or modification of special purpose
    facilities. For special purpose  facility
    construction, the Chief, Facilities Man-
    agement Branch, shall request the assist-
    ance of  the appropriate  program office
    and  Regional Administrator  in  the rer
    view. For  modifications  and improve-
    ments,   the   appropriate   responsible
    official shall request assistance in  making
    the  review from other cognizant EPA
    offices.
       (2) Any assessments  requested shall
    contain the same sections listed for EIS's
    in § 6.304.  Contractors and consultants
    shall be notified in contractual docu-
    ments  when  an  assessment must be
    prepared.
       (b) Notice of intent, EIS, and negative
    declaration. The responsible official shall
    decide at the completion of the environ-
    mental review whether there may be any
    significant environmental  impacts. If
    there could be significant environmental
    impacts,  a notice of  intent and  an EIS
    shall be  prepared according to the pro-
    cedures in § 6.206.  If there may not be
    any  significant environmental impacts,
    a negative declaration and environmental
    impact appraisal shall be prepared ac-
    cording  to the procedures in § 6.212.
       (c)  Project start. As required  by
    § 6.108, a contract shall not be awarded
    or construction-related activities begun
    until at  least  fifteen (15) working days
    after release of a negative declaration, or
    until thirty (30)  days after forwarding
    the final EIS to the Council on Environ-
    mental Quality.
                                                                                                    EXHIBIT 1
    NOTICE OF INTENT TRANSMITTAL MEMORANDUM
                SUGGESTED FORMAT
                             (Date)
    
       ENVIRONMENTAL PROTECTION  AGENCY
               (Appropriate Office)
    
          (Address, City, State, Zip Code)
    
    To All Interested Government Agencies and
        Public Groups:
      As required by guidelines for the prepara-
    tion of environmental  Impact  statements
    (EIS's), attached  Is a notice of intent  to
    prepare an EIS for the proposed EPA action
    described below:-
                    (Official Project Name
                       and Number)
    
                         (City, State)
    
      If j'our organization  needs additional In-
    formation  or wishes to participate  In  the
    preparation of the draft EIS, please advise
    the (appropriate office,  city, State).
          Very truly yours,
                  (Appropriate EPA Official)
    (List Federal, State, and local agencies to be
      solicited for comment.)
    (List public action groups to be solicited for
      comment.)
    
       NOTICE OP INTENT SUGGESTED FORMAT
    
        NOTICE  OF  INTENT	ENVIRONMENTAL
               PROTECTION AGENCY
    1. Project location:
      City	
      County	_._..__
      State	1-
    2. Proposed EPA action;
    3. Issues Involved:
    4. Estimated project costs:
      Federal Share (total)	$..
      Contract $	Grant $	Other $.
      Applicant share (if any):
        (Name)  	$.
      Other (specify)	$-
       Total		$.
    5. Period covered by project:
      Start date:	
               (Original date. If project covers
                    more than one year)
      Dates of different project phases:	
      Approximate end date:	
    6. Estimated application filing-date:	
                   EXHIBIT 2
    
    PUBLIC  NOTICE AND NEWS RELEASE SUGGESTED
                    FORMAT
    
                 PUBLIC  NOTICE
    
      The  Environmental  Protection Agency
    (originating office)  (will prepare, will not
    prepare, has prepared) a (draft, final) en-
    vironmental Impact statement on the follow-
    ing project:
        (Official Project Name and Number)
    
    
              (Pxirpose of Project)
    
    
       (Project Location, City, County, State)
                                    FEDERAL REGISTER, VOL. 40,  NO.  72—MONDAY,  APRIL 14,  1975
                                                                 A-12
    

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                               RULES  AND REGULATIONS
    16825
    ------------------------------------------  B. Summarize Assessment.
    (Where EB3 or negative declaration and en-    1. Brief description of project: ___________
      vlronmental  Impact  appraisal  can  be  ------------------------------------------
      obtained)                                  2. Probable Impact of the project on the
      This notice  Is to Implement EPA's policy  envlronment: .................... --------
    of encouraging public participation  In the
    decision-making process on  proposed  EPA
    
    ZKSS
    
    
                    EXHIBIT 3                  ------------------------------------------
                                                 4. Alternatives considered with evaluation
     NEGATIVE  DECLARATION  SUGGESTED  FORMAT   of each : ________ __________________________
    
    
                            (Date)             — ........ ----- ................ - ........ -
    
        ENVIRONMENTAL PROTECTION AGENCY        §. Relationship between local short-term
                                               uses  of man's  environment and  malnte-
    
    ""( Appropriate" Office")""                    dSctt.^!^ enhancement  ol  long-term pro-
    
    
     Address, City, State, Zip                      6. Steps to minimize harm to the envlron-
             Code)                             ment:  ___________________________________
    
                                Asencies and  "T^'S^S^^'SSSSrVbST'cSi:
                                               mitment of resources: _______ .. ........ ____
      As required by  guidelines  for the prep-  -------------------------------------------
    aratton of environmental Impact statements    8. Public objections to project, if any, and
    (EES's), an environmental review has  been  their  resolution: ______ . __________________
    performed  on  the  proposed EPA  action  ------------------------------------------
    below:                                       9. Agencies consulted about the project: —
    
                      (Official Project Name and   -----------------------------------------
                             Number)              State representative's name: __________ .
                                                   Local representative's name: ___________
                      ------------------------      Other: ................ _ ..............
                         (Potential Agency      c. Reasons for concluding there will be no
                          Financial Share)          significant impacts.
    
                      " (Project Locatianl'city,"                         (Signature of
                           County, State)                            appropriate official)
                                                                         (Date)
                      ------------------------                  EXHIBIT  5
                       (Other Funds Included)
                                                  COVER SHEET FORMAT FOR ENVIRONMENTAL
        PROJECT DESCRIPTION, ORIGINATOR, AND                 IMPACT STATEMENTS
                     PURPOSE                                 (Draft, Final)
    
      (Include a map of the project area and a       ENVIRONMENTAL IMPACT STATEMENT
    brief narrative summarizing  the  growth the
    project will serve, the percent of vacant land  ~               ~~             "~
    the project will serve,  major primary and     "(b^CTlbeVltfe"orp"roject"pian"and"give
    secondary Impacts of the project, and the            Identifying number)
    purpose of the project.)                      Prepared by:           ____ .............
      The  review process  did not indicate slg-                  (Responsible Agency Office)
    niflcant environmental  Impacts would re-  Approved by
    suit from the proposed action or significant              ' "(Responsible Agency'offlcial^
    adverse Impacts have been  eliminated  by
    making changes  In  the project. Conse-                      ~   (Date)
    quently, a  preliminary decision not to  pre-
    pare an EIS has been made.                                   EXHIBIT  6
      This action  Is  taken on the  basis  of  a  SUMMARY SHEET FORMAT FOR  ENVIRONMENTAL
    careful  review  of the  engineering report,              IMPACT STATEMENTS
    environmental   Impact  assessment,   and
    other  supporting data, which are on file in      /   >
    the above office with the environmental 1m-      J   '
    pact appraisal and are  available for public      '   '
    scrutiny upon request. Copies of the environ-      ENVIRONMENTAL PROTECTION  AGENCY
    mental Impact appraisal will be sent at cost
    on your request.                             (Responsible Agency'offlce)"
      Comments supporting or disagreeing  with  ...      ,   „    ,,«,^,v „„.,
    this decision may be submitted for consider-  *•  Name°r af lon- <°»«* °™>
    atlon  by EPA. After evaluating the com-     <    Administrative action.
    ments received, the Agency will make a  final     < . ' J^gis}**1/8 action.
    decision; however, no administrative action  2-  Brief description of act on Indicattag what
    will be taken on  the project tor at  least     s*atf . )  *™ particularly
    fifteen  (16) working  days after release  of     affected.
    the negative declaration.                     a-  Summary  of environmental Impact and
                                                  adverse environmental effects.
          Sincerely,                             4  Llst alternatives considered.
                    ------------------------    5  ^ jfor draft  statements)  List all Federal
                    (Appropriate EPA Official)         state,  and  local agencies  and  other
                    EXHIBIT 4                       comments have been requested.
                                                  b. (for final statements)  List all  Federal
         ENVIRONMENTAL IMPACT  APPRAISAL             ctate.  and  local agencies  and  other
                SUGGESTED FORMAT                    sources from,  which  written  com-
    A. Identify Project.                              ments have been received.
       Nam*  of Applicant: ___________________  6.  Dates draft statement and  final state-
       Address:  __________________________ ...     ment made available to  Council  on En-
       Project  Number: ______________________     vlronmental Quality and public.
    
                 fEDERAL REGISTER,  VOl. 40,  NO. 72— MONDAY, APRIL  14,  1975
                                          A-13
    

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    16826
          RULES  AND REGULATIONS
                                          EXHIBIT 7
    
                                     MWHART FOR OSHMP
                        MtttWMI in PirUMIMIM I' W lit It »nmm 9N C»WW WWff
         JSSJf
                    APPENDIX A
       CHECKLIST FOB ENVIRONMENTAL BEVIEWS
    
      Areas to be considered, when appropriate,
    during an environmental review Include, but
    are not limited to, the Items on this check-
    list, based on Appendix II of the CEQ guide-
    lines for the  preparation of environmental
    Impact  statements which appeared  in the
    FEDERAL REGISTER August 1, 1973. The classi-
    fication of items is not, mandatory.
      I. Natural environment. Consider the Im-
    pacts of a proposed action on air  quality,
    water supply  and quality, soil conservation
    and hydrology, fish, and wildlife populations,
    fish and wildlife habitats, solid wastej?dis-
    posal, noise levels, radiation, and hazardous
    substances use and disposal.            .•
      II. Land use planning  and  management.
    Consider the impacts of a proposed action-.ori
    energy supply and natural resources develop)!;
    ment; protection of en'-ironmentally critical
    areas, such as floodplains. wetlands, beacheq
    and dunes,  unstable soils, steep slopes and\
    aquifer recharge areas, coastal area land use;
    and redevelopment   and  construction  In
    built-up areas.
      III. Socioeconomic environment. Consider
    the impacts of a proposed action on popula-
    tion density changes, congestion mitigation,
    neighborhood character and  cohesion, low
    Income  populations, outdoor recreation, In-
    dustrial/commerclal/resldentlal development
    and tax ratables, and historic, architectural
    and archaeological- preservation.
    
                    APPENDIX B
                  RESPONSIBILITIES
    
      I. General responsibilities, (a) Responsible
    official. (1) Requires contractors and grantees
    to submit environmental assessments and re-
    lated documents  needed  to comply  with
    NEPA, and assures environmental reviews are
    conducted on proposed EPA  projects at the
    earliest  possible  point  In EPA's decision-
    making process.
      (2) When required, assures  that draft EIS's
    are  prepared  and distributed at the earliest
    possible  point  in  EPA's decision-making
    process, their Internal and external review is
    coordinated, and final EIS's are prepared and
    distributed.
      (3) When an EIS is not prepared, assures
    that negative declarations and environmental
    aj5»raisals  are  prepared  and  distributed for
    tlroS^ actions requiring them.
      (4)'Consults  with   appropriate  officials
    identified  in  § 6.214 of this part.
      (5) Consults with the Office  of  Federal
    Activities  on  actions  Involving  unresolved
    conflicts with other Federal  agencies.
      (b) Office of Federal Activities.  (1)  Pro-
    vides EPA with policy guidance and assures
    that EPA offices establish and maintain ade-
    quate administrative procedures to comply
    with this part.
      (2) Monitors  the overall  timeliness and
    quality of the EPA effort to comply With this
    part.
      (3) Provides assistance to  responsible offi-
    cials as required.
      (4) Coordinates the training of personnel
    involved in the review and preparation of
    EIS's and other NEPA-assoclated documents.
      (5) Acts as EPA liaison  with the Council
    on Environmental Quality and other Federal
    and  State entities on matters of EPA  policy
    and  administrative mechanisms to facilitate
    external review  of  EIS's,  to  determine lead
    agency and to improve the uniformity  of the
    NEPA procedures of Federal agencies.
      (6) Advises the Administrator and Deputy
    Administrator on projects which Involve more
    than one EPA office, are controversial, are na-
    tionally significant, or "pioneer" EPA policy,
    when these projects have had or should have
    an EIS prepared on them.
      (c) Office of Public Inquiries. Assists the
    Office of Federal Activities  and  responsible
    officials by answering the public's  queries on
    the EIS process and on specific EIS's and by
    directing requests for copies of specific docu-
    ments to the appropriate  regional office or
    program.
      (d) Office  of Public Affairs. Analyzes the
    present procedures for public participation,
    and  develops  and recommends to the Office
    of Federal Activities a program to Improve
    those procedures and increase public partic-
    ipation.
      (e) Regional  Office  Division   of  Public
    Affairs.  (1) Assists  the responsible official or
    his designee on  matters pertaining to nega-
    tive  declarations,  notices of  intent,  press
    releases, and  other public notification pro-
    cedures.
      (2) Assists  the responsible official  or his
    designee by answering the  public's queries
    on the EIS process  and on specific EIS's, and
    by filling requests for copies  of specific docu-
    ments.
      (f) Offices of the Assistant Administrators
    and  Regional Administrators. (1) Provides
    specific policy guidance to  their  respective
    offices and assures that those offices  estab-
    lish  and maintain adequate administrative
    procedures to comply with this part.
      (2) Monitors  the  overall  timeliness  and
    quality  of their respective office's efforts to
    comply  with this part.
      (3) Acts as liaison between their offices and
    the  Office of Federal  Activities and between
    their offices and other Assistant Administra-
    tors  or  Regional AdminIstrators on matters
    of agencywlde policy and procedures.
      (4) Advises the Administrator and Deputy
    Administrator through the Office  of Federal
    Activities on projects  or activities  within
    their respective areas of responsibilities which
    involve  more  than one EPA office, are con-
    troversial,  are  nationally  significant,  or
    "pioneer" EPA policy,  when these projects
    have had or should have an  EIS prepared on
    them.
      (g) The Office of Legislation. (1) Provides
    the  necessary liaison with Congress.
      (2) Coordinates  the  preparation of EIS's
    required on reports on legislation originating
    outside EPA. (See § 6.106(d)).
      (h) The Office of Planning and Evaluation.
    Coordinates the preparation of EIS's required
    on  EPA legislative proposals.  (See   § 6.106
     (d)).
      II. Responsibilities for  Title II Construc-
    tion Grants Program.  (Subpart E). (a) Re-
    sponsible official. The responsible  official for
    EPA actions  covered  by this subpart  Is the
    Regional Administrator.. The responsibilities
                                       fEDERAL  REGISTER, VOL. 40, NO. 71—MONDAY,  APRIl  14,  1975
                                                                    A-14
    

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                                                      RULES  AND REGULATIONS
                                                                                   16827
    of the Regional Administrator In addition to
    those In Appendix B.I. are.to:
      (1) Assist  the  Office of Federal Activities
    In coordinating the training of personnel In-
    volved in  the review and  preparation  of
    NEPA-associated documents.
      (2) Require grant applicant? and those who
    have  submitted plans for  approval to pro-
    vide the Information the regional office re-
    quires to comply with these guidelines.
      (3) Consult with  the Office of Federal
    Activities concerning works or plans which
    significantly  affect  more than one regional
    office, are controversial, are of national sig-
    nificance  or "pioneer"  EPA policy,  when
    these  works  have  had or  should  have
    had an EIS prepared on them.
      (b) .Assistant Administrator. The respon-
    sibilities of the Office of the Assistant Admin-
    istrator, as described in  Appendix B.I, shall
    be assumed by the Assistant Administrator
    for Water and Hazardous Materials for EPA
    actions covered by this subpart.
      (c) Oil and Special Materials Control Divi-
    sion,  Office of Water Program  Operations,
    coordinates all activities  and responsibilities
    of the Office of Water  Program Operations
    concerned  with preparation and  review  of
    EIS's. This includes providing technical as-
    sistance to the Regional Administrators  on
    EIS's and assisting the Office of Federal Ac-
    tivities In coordinating the training of per-
    sonnel Involved in the review and preparation
    of NEPA-associated documents.
      (d)  Public  Affairs   Division,   Regional
    Offices.  The  responsibilities  of  the regions'
    Public Affairs Divisions, in addition to those
    in Appendix B.I, are to:
      (1) Assist  the  Regional  Administrator  In
    the preparation and dissemination of NEPA-
    associated documents.
      (2)  Collaborate  with  the Headquarters
    Office of Public Affairs to analyze procedures
    In the regions for public participation and
    to develop and recommend to the Office of
    Federal Activities a program to improve those
    procedures.
      III. Responsibilities for Research and De-
    velopment  Programs  (Subpart  F).  The
    Assistant  Administrator for.  Research and
    Development, in addition to those responsi-
    bilities  outlined  in  Appendix  B.I(a), will
    also assume the responsibilities  described in
    Appendix B.I(f).
      IV. Responsibilities for Solid  Waste  Man-
    agement Programs (Subpart G). (a) Respon-
    sible Official. The responsible official for EPA
    actions covered by this subpart is the Deputy
    Assistant   Administrator  for Solid  Waste
    Management Programs. The responsibilities
    of this official, In addition to those in Appen-
    dix B.I(a), ire to:
      (1) Assist the  Office of Federal Activities
    In  coordinating  the training of  personnel
    involved In the  review  and preparation  of
    all NEPA-associated documents.
       (2)  Advise the  Assistant  Administrator
    for Air and Waste Management concerning
    projects which significantly affect  more than
    one regional office, are controversial, are na-
    tionally significant, or "pioneer" EPA policy.
      V.  Responsibilities  for  Special Purpose
    Facilities  and Facility Renovation Programs
    (Subpart H).
       (a)  Responsible  official.  The responsible
    official for new construction and modification
    of special purpose facilities is as  follows:
       (1)  The  Chief,  Facilities  Management
    Branch, Data and Support Systems Division,
    shall be the responsible official on all new
    construction of special purpose facilities and
    on all Improvement and modification proj-
    ects  for which  the Facilities Management
    Branch has received a funding allowance.
      (2) The Regional Administrator shall be
    the responsible  official on all improvement
    and  modification  projects  for  which the
    regional  office   has received  the  funding
    allowance.
      (3) The Center Directors shall be the re-
    sponsible officials on all  improvement and
    modification projects for which the National
    Environmental  Research  Centers have  re-
    ceived the funding allowance.
      (b) The responsibilities of the responsible
    officials,  in addition to  those in Appendix
    B.I, are to:
      P) Ensure that environmental assessments
    are submitted  when requested,  that envi-
    ronmental reviews are conducted on all proj-
    ects, and EIS's are  prepared and circulated
    when there will be significant impacts.
      (2) Assist the Office of Federal Activities
    In coordinating the training of  personnel
    involved In the review and preparation of
    NEPA-associated documents.
                    APPENDIX C
    DISTRIBUTION AND AVAILABILITY  OF DOCUMENTS
    
      I.  Negative Declaration,  (a)  The respon-
    sible official shall  distribute  two copies of
    each negative declaration to:
      (1)  The  appropriate  Federal, State and
    local agencies and  to the appropriate State
    and  areawide clearinghouses.
      (2) The Office of Legislation, the Office of
    Public  Affairs  and the  Office   of  Federal
    Activities.
      (3) The headquarters  EIS coordinator for
    the program office originating the document.
    When ^the  originating office  Is  a regional
    office and the action is related to water qual-
    ity  management, one  copy should be for-
    warded to the Oil and Special Materials Con-
    trol  Division, Office of  Water Program Oper-
    ations.
      (b) The responsible official shall distribute
    one  copy of each negative declaration to:
      (1) Local newspapers and other local mass
    media.
      (2) Interested persons on request.  If It Is
    not practical to send copies to all Interested
    persons,  make  the  document   available
    through local libraries or post offices, and
    notify individuals that this action has been
    taken.
      (c) The responsible official shall have  a
    copy of the negative declaration and any doc-
    uments supporting the negative declaration
    available for public review at the originating
    office.
      II. Environmental Impact Appraisal,  (a)
    The  responsible official shall have the envi-
    ronmental impact  appraisal available when
    the  negative declaration is distributed and
    shall forward one copy to the headquarters
    EIS coordinator for the program office origi-
    nating the document and to any other Fed-
    eral  or State agency which requests a copy.
      (b)  The responsible official shall have  a
    copy of the environmental impact  appraisal
    available for public review at the originating
    office and shall provide copies at cost  to per-
    sons who request them.
      in. Notice of Intent, (a) The responsible
    official shall forward one copy of the notice
    of Intent to:
      (1) The  appropriate Federal, State and
    local agencies and to the appropriate State,
    regional  and metropolitan  clearing houses.
      (2) Potentially Interested persons.
      (3) The Offices of Federal Activities, Pub-
    lic Affairs and Legislation.
      (4) The headquarters Grants Administra-
    tion Division, Grants Information  Branch.
    .  (5) The headquarters EIS coordinator for
    the  program  office  originating the  notice.
    When the originating office is a regional office
    and the action  Is related to  water quality
    management, one copy should be forwarded
    to the Oil and Special Materials Control Di-
    vision, Office of  Water Program Operations.
      IV. Draft EIS's. (a) The responsible official
    shall send two copies of the draft EIS to:
      (1) The Office of Federal Activities.
      (2) The headquarters EIS coordinator for
    the program office originating  the document.
    When the originating office is a regional of-
    fice and the project is related  to water qual-
    ity management, send two copies to the Oil
    and Special Materials Control Division,  Of-
    fice  of Water Program Operations.
      (b) If none of the above offices requests
    any changes  within ten (10)  working days
    after notification,  the  responsible  official
    shall:
      (1) Send five copies  of the draft  EIS to
    CEQ.
      (2) Send two copies  of .the draft  EIS to
    the Office of Public Affairs and to the Office
    of Legislation.
      (3) Send two copies  of the draft  EIS to
    the  appropriate  offices of reviewing Federal
    agencies that have special expertise or juris-
    diction by law with respect to any  impacts
    Involved.  CEQ's  guidelines (40 CFR 1500.9
    and Appendices n and III) list those agencies
    to which draft EIS's will  be sent for official
    review and comment.
      (4) Send two copies of the draft EIS to the
    appropriate Federal, State,  regional  and
    metropofltan clearinghouses.
      (5) Send one copy of  the  draft EIS to
    public libraries In the project "area  and in-
    terested  persons. Post offices,  city halls or
    courthouses may  be used as  distribution
    points if public library  facilities are  not
    available.
      (c) The responsible official shall  make a
    copy of  the draft EIS  available for public
    review at the originating office and  at  the
    Office of Public  Affairs.
      V. Final EIS.  (a)  The  responsible official
    shall distribute the  final  EIS  to the follow-
    ing offices, agencies  and Interested persons:
      (1) Five copies to CEQ.
      (2) Two copies to the Office of  Public
    Affairs, Legislation  and  Federal Activities.
      (3) Two copies to the headquarters  EIS
    coordinator for the program office originating
    the document.
      (4) One copy to Federal, State and local
    agencies and Interested persons who made
    substantive comments on the draft  EIS or
    requested a copy of the final EIS.
      (6) 'One copy to a grant applicant.
      (b) The responsible official shall  make a
    copy of  the  final EIS  available for public
    review at the originating  office and  at  the
    Office of Public Affairs.
      VI. Z.e0isZatit>e EIS. Copies of the legisla-
    tive EIS shall be distributed by the responsi-
    ble official according to the  procedures in
    section IV(b)  of this appendix. In addition,
    the responsible official shall send two copies
    of the EIS to the Office  of Federal Activities
    and the  EIS  coordinator of the originating
    office.
    
      [FR Doc.75-9553 Filed 4-11-75; 8:45 am]
                                       FEDERAL REGISTER, VOL  40, NO. 72—MONDAY, APRIL 14,  1975
    
    
                                                               A-15
    

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                     APPENDIX B
       ALTERNATIVE MITIGATION PLANS TO REDUCE
    POTENTIAL ADVERSE AIR QUALITY IMPACTS IN THE
                     AWMA AREA
    

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                       ALTERNATIVE MITIGATION PLANS TO REDUCE
                    POTENTIAL ADVERSE AIR QUALITY IMPACTS IN THE
                                      AWMA AREA
     Introduction
    The first step is determining the number of automobile trips that will be
    generated within AWMA.  For a project of this nature, with the limited
    information available, the most reliable parameter of trip generation is the
    forecasted population.  Using data from recent traffic engineering studies*
    on specific residential projects in or near AWMA, we can predict that the daily
    trips per capita and trip length factors will be 3.82 trips per capita and
    7.98 miles respectively.  The derivation of the trip generation factor is based
    on traffic engineering analysts' correlation of density types with predicted
    trips per dwelling unit as follows:
    
              Low density:        12 trips per unit
              Medium density:     10 trips per unit
              High density:        8 trips per unit
    
    Since these density types have an average occupancy rate as follows:
    
              Low density:        3.5 persons per unit
              Medium density:     2.5 persons per unit
              High density:       2.0 persons per unit
    
    the average per capita trip generation rates according to density types are:
    
              Low density:        3.4 trips per capita
              Medium density:     4.0 trips per capita
              High density:       4.0 trips per capita
    
    Then, from the zoning summary presented in a previous section we can  de-
    duce that approximately 30% of the total future population will live in low
    density areas, and the remaining 70% in medium to high density areas.
    Therefore, an average trip generation per capita for the AWMA area would be:
    
              (.3) x (3.4) + (.7) (4) = 3.82 trips per capita
    *Source:  Herman Kimmel and Associates, Traffic Engineering Study
              for Moulton Ranch General  Plan, 1973 et al.
                                         B-l
    

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     There  are  no  specific  data on  trip  lengths  for various  destinations  in  the
     southern Orange  County area.   Cal Trans  has  provided  the  best available
     information.  A  1967 regional  origin  and destination  survey  revealed the
     following  trip lengths for the indicated purpose:
    
               Home-Other (H-0):            5.76 miles*
               Other-Other  (0-0):           4.82 miles
               Other-Work (0-W):            7.24 miles
               Home-Work  (H-W):             9.12 miles
               Home-Shop  (H-S):             3.04 miles
    
               Average  for  all trips:       6.24 miles
    
     Cal Trans  Transportation Planning Department currently  uses  the following:
    
               H-0:     6.92 miles
               0-0:     5.54 miles
               0-W:     8.33 miles
               H-W:     10.49 miles
               H-S:     3.50 miles
    
               Average  for  all trips:       7.2 miles
    
     Using  a straight-line  projection of these trends we can predict the  follow-
     ing trip lengths for 1985:
    
               H-0:     7.33 miles
               0-0:     6.13 miles
               0-W:     9.21 miles
               H-W:     11.61 miles
               H-S:     3.87 miles
    
              Average  for  all trips:       7.98 miles
    
    These  factors appear to correlate reasonably well with what might be ex-
     pected in  the AWMA area.  For  example, the average distance from AWMA
    origin to  the most significant employment center, the Irvine Industrial
    Complex, will be 11-  12 miles.
    
    Orange County Modified Growth  Rate (Worst Case)
    
    Relating these data for the Orange County Modified Growth Rate Forecast
    for AWMA produces  the  following computations:  (1985 is selected as the
    sample year because it is assumed that emission standards will  largely
    be realized by that time).
    *Source:  LARTS Study, LART Base Year Report, 1967 Origin and Destinations
              Survey, Cal-Trans, 1971.
                                         B-2
    

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    Trip Generation  (1985)
    
                 w  	  y   Y
    
                        X2 =  Trips/Capita  =  3.82
    
                     Xj  = Projected  Population =  163,700
                   =  (163,700)  x  (3.82)
                   =  625,334  Trips
    
              VMT  =  Y X3
    
                      X3 = Trip  Length =7.98 miles
    
                   =  (625,334)  x  (7.98)
                   =  4,990,165.3  miles
    
    NOTE:  Diesel  trucks comprise an insignificant component and are not
           included  in  this  analysis.
    
    
    E-0 Growth 1985
    
    A similar analysis  for the SCAG E-0 series population projections reveals
    the following:
    
                 Y  =  y   y
                 I    A-i  AO
    
                   =  (120,400)  (3.82)
    
                   =  459,928  trips generated
    
              VMT =  Y X3
    
    
                  =  (459,928)  (7.98)
    
                  = 3,670,225.4 miles
    
    The land already committed to specific uses within AWMA based on approved
    developer plans and the GSA facility will have the following effect:
    
                V — Y  Y
                Y - AI A2
    
                  =  (95,000)  x (3.82)
    
                  = 362,900 trips
    
              VMT = Y X3
    
    
                  =  (362,000) x (7.98)
    
                  = 2,895,942 miles
                                         B-3
    

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     VMT MITIGATION PLANS
    
     Mitigating the potential adverse air quality is obviously a problem of
     reducing the vehicular miles traveled.  Reducing the emissions through an
     emission control program is important, but, as has been demonstrated,
     the total VMT will overcome the beneficial effect of reduced emission rates.
    
     Digressing for a moment on this point, experience to date with exhaust
     control systems on automobiles indicates that the government emission
     control programs alone may not be totally effective on either a short-
     term or a long-term basis.  The principal difficulty is ensuring that the
     exhaust control systems are properly maintained.
    
     Although the schedule for implementation may be delayed for a year or
     so*, EPA requirements on reducing vehicle emissions are proceeding.
     Fortunately, there are unmistakable trends today indicating in the future
     that smaller cars and smaller engines will be utilized.  This trend plus  ,
     some of the new engine technology that is being demonstrated currently,
     such as the Honda stratified-charge engine, provide reasonable indication
     that the EPA requirements will indeed be met.
    
     The opportunities for reducing VMT lie in land use planning and develop-
     ment of alternative transportation models.  Life style is often blamed for
     the emergence of the automobile as the dominant mode of transportation, and,
     in a sense, this is true, but if it were not for the low density sprawl
     pattern of residential development it probably would not have developed
     into such a significant component.  The geometry of the low density sprawl
     pattern produces inordinately long travel distances to and from work, shop-
     ping and other destinations.   The following mitigation plans are presented
    with the obvious need for VMT reduction, but is should be pointed out
     that none of these are within the power of AWMA to implement, it can only
     encourage:
    
    Mitigation Plan 1
    
    High density cluster residential  development with neighborhood shopping
    centers in lieu of low density residential development with regional
    shopping centers.
    
    
    VMT Analysis
    
              Based on the Orange County modified Growth Rate, approximately
              98,100 people will  be added to the area by 1985.  This is the
              segment of the AWMA population whose travel  characteristics
              will  have to be modified in order to affect a VMT reduction.
    *Already the original 1976-(CO and HC) and 1977-(NOX) standards slipped
     one year respectively and relaxed interim standards for CO and HC
     specified for 1975 model  vehicles.
                                         B-4
    

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              Based on local traffic engineering studies which project an
              ownership rate of 0.62 cars per capita*, there will be 60,822
              cars added to the AWMA area by 1985.
    
              An assumption critical to this analysis must be made on how
              much of this new population will live in cluster-type develop-
              ment.  Obviously, while it could vary over a wide range, the
              trend in development site design in southern Orange County is
              toward cluster types (e.g., Mission Viejo, Rancho Serrano, et al).
              To be conservative we've selected to use a factor of 40% although
              the actual percentage is likely to be much higher.
    
              The trips that will be affected by the cluster concept are
              those whose destination are for business, shopping, social,
              and recreational purposes.  While a specific origin-destination
              study was not available, studies** in other areas indicate that
              approximately 55 percent of daily trips are for these purposes.
    
              The average car in low density sprawl patterns operates within
              a radius of 6.6 miles (based on the previous trip length factors).
              In a cluster design the average distance would be approximately
              3.5 miles for business, shopping, social and recreational  purposes.
    
    VMT Reduction
    
              Trips   =Xj_ X2 X3
    
                          X2 = Trips/capita =3.82
    
                       X, = Population Affected
    
                          = (98,100) (.4) = 39,240
    
                       X3 = Bus, Shopping, Social, Rec.  = .55
    
                          = (39,240) (3.82) (.55)
    
                          = 82,443.24 say 82,443
    
                          = Mileage Reduction X Trips
    
                          = (6.6 - 3.5)  x Trips
    
                          = (3.1) (82,443)
    
                          = 255,573.3 Miles
    
     *Reciprocal  of the 1.613 persons per car average for Orange County.
    
    **Source:  Wilbur Smoth and Associates,  Future Highways  and Urban Growth,
               1961.
    
    
                                        B-5
    

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    Mitigation Plan  la
    
    Plan  la  is not a different suburban design concept but an analysis of a
    beneficial consequence likely to arise because of the cluster development
    pattern  - the increased usage of regional transit systems.
    
    A  survey* recently conducted by OCTD on attitudes affecting the use of
    public transportation showed that while public transit is viewed as safer,
    more  relaxing, and less expensive, it is also perceived as less simple and
    less  convenient  to use.  But the survey also indicated that Orange County
    residents desire a modal mix, so it seems reasonable to assume that if the
    service  was  frequent and within a close proximity of the commuter's home and
    destinations that the usage would increase.
    
    
    VMT Analysis
    
              35 percent of total trips occurring in the AWMA area will be
              for the purpose of commuting to and from work.**
    
              The average commuting distance to nearby employment centers
              (e.g., the Irvine Industrial Complex) will be approximately
              12 miles.
    
              Less than one percent of Orange County commuters currently use .
              the regional transit system.***
    
              Studies of urban trip generation have found a close relationship
              to exist between car ownership, population density, and mode of
              travel****, and while the AWMA area travel characteristics do
              not correlate precisely with those studied by Levinson and Wynn
              it does seem reasonable to assume a modest increase in regional
              transit usage if cluster designs are employed and the level  of
              transit service is adequate.  The Levinson and Wynn studies
              indicate that at a 3.82 trips per capita per day rate the use of
              transit systems would be approximately 17%.  To reflect area
              characteristics and life styles, we will use a conservative
              increase to 6% which is in line with some preliminary indications
              of a survey currently being conducted by the Orange County
              Transit District.
       *Source:  OCTD, County-Wide Research Study, November 1974.
    
      **Source:  Herman Kimmel and Associates, Traffic Engineering Study
                 for Moulton Ranch General Plan, 1973.
    
     ***Source:  Orange County Transit District.
    
    ****Source:  H. S. Levinson and F. H.  Wynn, "Some Aspects of Future
                 Transportation in Urban Areas," 1962.
                                        B-6
    

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     VMT  Reduction
              Work commuting  trips = X
                                       ,
                                           X3 =  .35  (% commuting)
    
    
                                        X^ = 3.82  (trips per capita)
    
    
                                        = 39,240 (Population)
                   trips = 52,463.9 say 52,464
    
              Trip reduction = 52,464 x .06
    
                             = 3147.8 say 3148
    
              VMT reduction  = 3248 x 12
    
                             = 37,776 miles
    
    
    Mitigation Plan Ib
    
    This Plan like the previous one is not a different design concept but a
    consequence likely to arise from the imposition of cluster development
    as a major mitigation strategy in the AWMA area.  Cluster designs with
    neighborhood shopping facilities are likely to encourage the use of
    bicycles and walking as alternative travel modes for some shopping needs.
    Recent trends in cluster designs incorporating extensive bicycle pathways
    reinforce this as a real  possibility.
    
    
    VMT Analysis
    
              Area traffic studies predict that approximately 14 percent of
              the trips occurring in the AWMA area will  be for the purpose
              of shopping.*
    
              Studies of trip generation indicates that pedestrian trips and
              other travel  mode trips, e.g., bicycle, increase as the travel
              factor increases and the number of destinations within walking
              distance increases.**  Levinson and Wynn estimate based on a
              trips per capita per day rate of 3.82, the percentage of uses
              of these alternate modes could be as high as 42.8 percent.
              Again, to be conservative but reflective of area trends and
              life styles,  we will employ  a factor of 21.4 percent, although
              a much higher factor is  likely to be realized.
     *Source:   Traffic engineering study for Moulton Ranch,  Kimmel  and
               Associates, 1973.
    
    **Source:   H.  S.  Levinson and F.  H.  Wynn, "Some Aspects  of Future
               Transportation in  Urban Areas,"  1962.
                                         B-7
    

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    VMT Reduction
    
              Shopping Trips = X, X2 X-
    
    
                                     X. = % of total trips for shopping purposes = .14
    
    
                                  X? = trip generation rate per capita = 3.82
    
    
                               Xj = population = 39,240
    
    
                             = (39,240) (3.82) (.14)
    
                             = 20,985.6 say 20,986
    
              Trip reduction = (Shopping Trips) x (% usage of ped. & bicycles)
    
                             = 20,986 x .214
    
                             = 4,491
    
              VMT reduction  = (Trip reduction) x (Mileage reduction)
    
                             = (4,491) x (3.87)
    
                             = 17,380.2 miles
    
    Summary of Mitigation Plan 1                                              '
    
    The encouragement of cluster development in the AWMA area can have a
    significant beneficial effect in reducing the total  vehicular miles travel-
    led and consequently in reducing potential air quality problems.   Even the
    previous conservatively based analyses predict that a savings of on the order
    of 310,730 vehicular miles travelled can be realized.  Imposing this
    residential  pattern in the AWMA area is obviously a necessary component of
    the total solution but it must be emphasized  again that dictating and  en-
    forcing any type of land use regulations is not within the purview of  AWMA.
    Regardless of the perhaps minimal  power of AWMA to participate in enforcing
    implementation strategies, the following are  presented:
    
    Implementation Strategies:
    
              Rezone low density residential  areas to high density residential
              with extensive open space.
    
              Subsidize low income residential cluster development with state
              and federal  grants.
    
              Require large residential  developments to  include  neighborhood
              shopping centers.
    
              Require developers  of  large  residential  areas  to include  bicycle
              paths  throughout the development with  focus on  the  shopping  area.
    
                                        B-8
    

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              Advertise  the  health, recreation and energy conservation  benefits
              of bicycling on television and  in schools.
    
    
    Mitigation  Plan  2
    
    The  automobile,  so firmly entrenched in the lifestyle created by low
    density  residential  sprawl  patterns, is a virtual necessity for most com-
    muting and  shopping.  One attractive possibility for reducing the frequency
    of usage, especially in  view of the recent fuel shortage and threat of
    future recurrence, would be to encourage  the use of commuter car pooling.
    The  greatest opportunity would seem to be with work commuters and this
    strategy could be applied to the entire AWMA work force, not just the
    incremental addition from this point in time.
    
    
    VMT  Analysis
    
              There  is a scarcity of data upon which to base a performance
              prediction for commuter car pooling.  Car pools are currently
              operated on a  limited basis by a few large industrial companies
              and a  few  public  agencies.  But because people seem more receptive
              to energy  and  money conserving alternatives now, a few assumptions
              can confidently be made.
    
                   Car pools would average 3 persons per car* (non car pool
                   cars  average 1.2 persons per car).
    
                   The average one-way trip length for work commuting (e.g.
                   to the nearby employment center at the Irvine Industrial
                   Complex)  would be 12 miles.
    
                   25% of all commuters would use the car pool  system.
    
                   35% of trips occurring within AWMA are for work commuting
                   purposes.
    
    
    VMT  Reduction
    
    Work Commuting Trips = X. X« X,
    
                                 X3 = % of trips for work commuting = 35%
    
                              Xp = trip generation rate per capita =3.82
    
                           Xj = total  population O.C.  mod.  growth rate  proj.= 163,700
    
              Trips = 218,866.9 say 218,867
    
    
    
    *Source:   Orange County Transit District Survey Preliminary Indications.
    
    
                                         B-9
    

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    Trip Reduction
    
    The vehicle occupancy rate of 1.2 persons per vehicle implies
    
               (218,867) x 1.2 = 262,640.4 person trips
    
    a figure that would remain constant.  If 25% of these persons could be
    reduced, or in other  words, if 25% of all commuters would use car pools,
    then
    
               (262,640.4) x (.25) = 65,660.1
    
    person trips would be in car pools.  At the assumed occupancy rate, 3
    persons per car would mean 21,886.7 vehicle trips.  The remainder of the
    total person trips, 196,980.3, would continue at the average occupancy of
    1.2, for a total of 164,150.25 vehicle trips.  Therefore, the total under
    this scheme would be 186,036.95 daily vehicle trips, say 186,037.
    
    
              The trip reduction that could be realized then, would be:
    
                   218,867 - 186,037 = 32,830 trips
    
              VMT Reduction = Trip reduction x average commuting distance
    
                            = (32,830) x (12)
    
                            = 393,960 miles
    
    
    Summary of Plan 2
    
    Car pools represent a promising technique for reducing VMT.   They require
    virtually no capital  expenditure, and they provide more convenience than
    scheduled bus service.   According to our analysis, a savings of on the
    order of 394,000 miles  travelled may be possible.   But to realize such a
    savings would require a program of both incentives for a car pooling and
    disincentives for solo  driving.
    
    Implementation Strategies;
    
              Computers would be used to establish a data base,  facilitate
              data handling, and locate partners for similar sources and
              destinations.
    
              Cost would  be free to all  drivers  in the program.
    
              Companies in  the  private sector would be encouraged to assist
              employees in  forming  car pools by  distributing lists to each
              employee of 10 fellow employees living near them.
    
              Car pool  autos would  receive  preferential  parking  treatment.
    
              Car pool  autos would  get parking spaces  free.
                                         B-10
    

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               Parking would  be  limited  either  by  increasing  fees  for  non  car
               pool  cars  or by limiting  available  spaces at places of  employment.
    
               Reserved lanes on  the  freeway  could be established  for  car  pools.
    
               Modify building codes  to  reduce  parking  space  to building size
               ratios.
    
    
    Mitigation Plan 3
    
    Another opportunity  to reduce VMT would  be to modify the behavior of
    commuters  and shoppers concerning the use  of .public transit systems.
    Because of the  dependence on automobiles as the primary  travel mode,  the
    United States is virtually the only area in the world (with the exception
    of Sweden)  that exhibits a daily ratio of  public transportation passengers
    to auto passengers of less than  1:1*.  The reasons for this also  include
    a complex  interaction of social and economic  factors, but the point is,
    that if most of the  world's population is  conditioned to use public transit
    systems then perhaps, assuming adequate and timely service, Orange County
    residents  and AWMA residents, in particular,  can be encouraged to use public
    systems.
    
    VMT Analysis
    
    At a trip  generation rate per capita of 3.82,  approximately 17% of the
    person's trips  could be predicted to be on a  public transit system.**
    The Orange  County Transit District estimates  that 7% would be more
    realistic  for a saturated bus system in the south county area.***
    
    VMT Reduction
    
              Trips reduction = X,  Xp X3
    
                                      Xo = % of transit usage = 7%
    
                                   X« = trip generation rate per capita = 3.82
    
                                Xj  = population =  163,700
    
              Trips = 43,773.38 say 43,773
    
    
    
    
      *Source:   "Data Pertaining to Present Characteristics  of the Central
      ;         Major Cities, Highway Research News, July 1963.
    
     **Source:   H.  S.  Levinson and  F. H. Wynn, "Some Aspects  of Future
                Transportation in Urban Areas," 1962.
    
    ***Source:   Preliminary indications from the OCTD South  County Survey.
    
    
                                         B-ll
    

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     VMT  Reduction =  (Trips) x  (Weighted average trip length for both commuters
                                                               and shoppers)
    
                  =  (43,773) x  (4.6)
    
                  =  201,355.8 miles say 201,356
    
     Implementation Strategies:
    
              The use of a "bus land only" land on local freeways.  This could
              include use of "wrong way" bus lanes.
    
              Limit  parking by space limitations or increased fee.
    
              Reduce or eliminate bus fare.
    
              Provide "park-and-ride" systems where regular bus service would
              be impractical such as in steep, hilly areas.
    
              "Dial-a-ride" service would be provided in areas where regular
              bus service would be difficult to implement.
    
              Modify building codes to reduce parking space to building size
              ratios.
    
              This alternative would require approximately 130 buses for the
              AWMA area by 1977.  This is based on the premise that 15 percent
              of the commuters would ride buses to work and the buses have a
              capacity of 40 (a peak capacity of 5,000 passengers).  Presently
              Orange County transit has 108 buses for the whole county and is
              adding 44 more.   There are seven "dial-a-ride" buses in La Habra
              and a grant to obtain 67 more (15 - 19 passenger).
    
    Mitigation Plan 4 - Reduction of VMT's by Planned Development Around
                        GSA Facilities
    
    In 1971, the General Services Administration (GSA) exchanged government
    property for the North American Rockwell  (NAR) building.  Beginning in
    September 1974 and extending over several  years, the GSA will  move 4,000
    employees into the building.  Because of environmental reservations ex-
    pressed by the EPA  about the proposed use of the facility by low-grade
    employees who may not be able to afford to live in the AWMA area and
    controversy over the nature of the transaction, GSA has decided to use
    the center initially for record storage and to phase ultimate utilization
    of the facility with mass  transit which could mitigate the air quality
    impact of employee commuting.   Presently,  only about 250 employees are
    working in the building,  most of whom commute from the Los Angeles area
    although low-cost housing  is available in  Santa Ana and Costa Mesa.  In
    regards to the future work force,  no determination has been made as to where
    these employees will be transferred from.
                                        B-12
    

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     GSA has  predicted  that  approximately  40  percent  of  the  eventual  employees
     will  be  of  GS2  - GS6  pay  levels with  annual  salaries  of between  $5,682
     and $11,668.  A standard  multiplier of 2.5  times yearly salary is  used
     to  determine  the amount a person  can  normally  afford  to pay  for  a  house.
     Thus,  40 percent of the GSA  employees could  not  afford  houses costing
     more  than $25,000.  There is  virtually no housing of  this  type in  the
     AWMA  area and tentative plans do  not  call for  the development of this
     priced housing  by  the private sector.  Therefore, GSA with the coopera-
     tion  of  the Department  of Housing and Urban  Development (HUD) intends to
     provide  some  housing  in the AWMA  area which  can  be  afforded  by GSA em-
     ployees  by  the  time the work  force reaches  1,200.   If such housing is
     not provided  -  either by  the  public or private sector -  a  large  number of
     employees will  be  forced  to commute from outside AWMA,  probably  20 to
     30  miles  and  perhaps  further.
    
     Unique opportunities  for  reducing VMT connected  with  this  project  are
     possible  and  realistic.   Short-term opportunities such  as  carpools and
     busing will reduce the  VMT outside AWMA.  Both of these  methods  will not
     completely  eliminate  the  need  for an  average 40  to  70 mile round trip
     commute  to  the  AWMA area  and  the  GSA  facility.
    
     The long-term opportunity primarily entails  the  design  and construction
     of  a new  town around  the  GSA  facility.   A new  town  could ultimately house
     approximately 40,000  people.   This represents  about 33  percent and 25
     percent of  the  predicted  population for  the entire AWMA  area for 1985
     assuming  E-0  growth and modified  growth  respectively.  This also repre-
     sents  65  percent and  40 percent respectively,  of the  predicted new growth
     planned  in  the  area.  The reduction in miles driven in AWMA during the
     build-up  period to 40,000 is  not  discussed since the  time  period cannot
     be  predicted.
    
     This alternative, proposed by  the  applicant, considers housing probably
     in  the form of a new  town, located near  the GSA Building.  The new town
     would  be  a moderate to  high density mix  of single family,  cluster and
     multiple  family residences.  A greenbelt-type  layout  could be used to
     consolidate residential,  commercial and  industrial  components, provide
     aesthetic variety and provide  corridors  for the bikeway system.   Essen-
     tial to the new town  concept,  service industries, stores and light pri-
     mary industries would be  located within  the community.  Extensive bike-
     ways could connect residential areas, shops and industry,  including the
     GSA Building.   Other  transit could include a combination of mini  buses,
     regular buses, and elephant train buses  (for rush hour peak loads).
    
     VMT Analysis
    
              Information is  extremely limited on bicycle trip generation
              characteristics in the United States.  Information is  more
              readily available from Europe where trip  generation rates for
              bicycle trips are high,  ranging from 10 percent of all  person
              trips  to a high 43 percent in Rotterdam,  Holland.*  The GSA
    *Source:  Planning Criteria for Bikeways, American Automobile Association.
                                        B-13
    

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              new town would be somewhat analogous since destination in
              both cases would be within a short radius.  This considered
              with the planned incorporation of an extensive bikeway system
              make a bicycle trip factor estimate of 15 percent of all work
              commuting trips seem reasonable.
    
              The total work force in the new town would be approximately
              10,000 persons.
    
              There will initially be approximately 1,500 employees at the
              GSA facility with a gradual buildup to a maximum of 4,000 in
              several years.
    
              Most of the employees to be moved or hired persently live
              outside of Orange County and AWMA.
    
              No point in the community will be more than 3.5 miles away
              from the GSA facility.
    
              The total maximum population of the community is 40,000.
    
              There will be 24,799 automobiles in the city (assumes an
              ownership rate of 1.6 persons per car).
    
              Approximately 35 percent of the total  city work force will use
              public transportation.
    
              The balance of the community's work force (8,500 persons) will
              drive to and from work an average of six miles per day with
              each one carrying 1.2 persons.
    
              Figures do not include shopping trips.
    
              Trip generation rate per capita for this density would be 4.
    
              Commute distances in AWMA are based on previously noted average
              of 11.61 miles per trip, rounded off to 12.
    
    VMT Reduction
    
    From Bicycle Usage:
    
              Trip reduction = X,  X« X3 X^
    
                                        X4 = % bicycle use = 15%
    
                                     X3 = % work commuter  trips =  35%
    
                                  X« = trip generation  rate per capita = 4-0
    
                               X  =  population = 40,000
                                         B-14
    

    -------
                             = (40,000) x (4.0) x (.35) x (.15)
                             = 8400 trips
              VMT reduction  = trips x commuting distance
                             = (8400) x (12)
                             = 100,800 miles
    From Public Transit Usage:
              Trip reduction = X, X? X3 X.
                                        X. = % public transit use = .35
                                     X- = % work commuter trips = 35%
                                  Xp = trip generation rate per capita =2.5
                               Xj = population = 40,000
                             = (40,000) x (4.0) x (.35) x (.35)
                             = 19,600 trips
              VMT reduction  = trips x commuting distance
                             = 19,600 x 12
                             = 235,200 miles
    Individual  Automobile Usage:
              Trips           = xl X2 X3 X4
                                        X. = bicycle use = 15%
                                     X3 = % work commuter trips = 35%
                                  X? = trip generation rate per capita =  4-0
                               X, = population = 40,000
                             = (40,000) x (4.0) x (.35) x (.15)
                             = 8400 trips
    
                                         B-15
    

    -------
    From Public Transit Usage:
             Trip reduction = Xj X2 X3 X^
                                       X^ = % public transit use = .35
                                    X3 = % work commuter trips = 35%
                                 X2 = trip generation rate per capita = 2.5
                              X, = population = 40,000
                            = (40,000) x (4.0) x (.35) x (.35)
                            = 19,600 trips
             VMT reduction  = trips x commuting distance
                            = 19,000 x 12
                            = 235,200 miles
    
    Individual  Automobile Usage:
             Trips          = Xj X2 X3 X4
                                       X. = % auto  use = .5
                                    X~ = % work commuter trips = 35%
                                 Xp = trip generation rate per capita =2.5
                              Xj = population = 40,000
                            = (40,000) x (4.0)  x (.35) x (.5)
                            = 28,000 trips
             VMT reduction  =trips x reduced  commuting distance (12-3.5)
                            = 28,000 x 8.5
                            = 238,000 miles
                                      B-16
    

    -------
     Summary, this new town surrounding the GSA facility would be a significant
     step in reducing VMT in the AWMA area, on the order of 574,000 miles
     daily, not to mention the consequent reduction in basin-wide VMT of
     approximately 167,000 miles daily.
    
     NOTE:  Until a planned community or housing near the NAR facility is
     constructed, the projected 4,000 employees will be forced to commute a
     30 to 70 mile round trip per day.  Eighteen of these miles will be in
     AWMA.  This represents 60,000 VMT per day for AWMA alone.  Eighty-five
     'percent car pooling with three persons per car would reduce this figure
     to 30,600 VMT per day (total 70 mile round trip without car pooling is
     233,330 VMT per day and 119,000 miles with car pools).  It is estimated
     that it would require 44 busses at 45 people per bus to replace 1,653
     automobiles which represent 50 percent of the NAR work force.  Buses
     would reduce'the VMT per day in AWMA (18 mile trip) by about 30,000
     VMT per day.
    
     Implementation Strategies:
    
              Use of federal  programs such as the Title VII, urban growth and
              new community acts of 1970*»2 to acquire land or low cost loans
              to the private sector for development of a model community as
              described above.
    
              Low interest loans, subsidies, inexpensive transportation to
              induce workers  to  move to the new community.
    
              High parking costs, reduced parking to induce residents to use
              alternative means  of transportation.
    
              Resolution by County Board of Supervisors.
    
              Commitment by landowners and developers.
    
    
     Mitigation  Plan 5
    
    .Public recreation opportunities abound along the AWMA  coast,  and are a
     major seasonal  traffic generator, especially on weekends.   Establishing a
     park-and-ride transit system could not only significantly reduce beach-
     going VMT but also reduce congestion.   The system would feature large
     inland parking areas, perhaps at the Orange County Airport and/or the
     intersection of Interstate  5 and Interstate 405.   Beach-goers would park at
     these areas and shuttle  buses for the remainder of their journey.
    
    
     1.   Public  Law 91-608,  91st Congress,  H.  R.  19436,  December 31,  1970.
         Title.VII,  Part B,  Section D.
    
     2.   National  Committee on Urban Growth Policy.   The  New City.   New York:
         Praeger Publishers,  1969.
                                         B-17
    

    -------
    VMT Analysis
             Predicting VMT reduction for a park-and-ride system is difficult
             at best because of the scarcity of base data relating to the
             numbers of beach destined cars and their occupancy rates.  Cal
             Trans is currently conducting a study that may shed some light
             on this but the results are not yet available.
    
             Based on visitations at Newport Beach and Laguna Beach though,
             it seems reasonable to assume approximately 20,000 daily visitors
             and an occupancy rate of 3 persons per car.  This implies a
             daily influx of approximately 6,667 cars.
    
             Most of the beach visitors would come from within a 50 mile
             radius with a conservative average of 20 miles.*  The park-and-
             ride system would reduce the trip length for users by approximately
             12 miles depending on the location selected, and the specific
             beach destination.
    
             Assuming convenient parking and excellent service, 20 percent of
             the influx might use the park-and-ride system, or about 1333
             cars.
    VMT Reduction
             Trips          = Xl X2
    
                                 X« = 2 (two-way trip)
    
    
                              X1 = average influx = 6,667 cars
    
    
                            = (6,667) x (2)
    
                            = 13,334
    
             VMT (without park-and-ride) = (trips affected) x (reduced trip length)
                                  i
                                         = 13,334 x 20 miles
    
                                         = 266,680 miles
    *According to the Orange County Road Department,  the average recreational
     trip length is 25 miles.
                                        B-18
    

    -------
              VMT reduction  (with park-and-ride)  =  (trips  affected)  x  (reduced
                                                                        trip length)
    
                                                 =  (13,334) x  (.2) x (12)
    
                                                 =  32,001.6 miles say  32,002 miles
    
     Implementation  Strategies:
    
              Make Route  1 a  toll  road  similar  to Monterey's 17-mile drive with
              passes for  residents.   Toll  road  income would be used  to subsidize
              buses.
    
              Charge high fees at beach parking lots.
    
              Provide free parking at the  park-and-ride lots.
    
              Bus  fare should be  very low  or free.
    
              Initiate a  contract for bus  services with Orange County Transit
              District (OCTD).  (At present OCTD  does not  have buses available,
              but  they are expanding  their fleet.)
    
    Mitigation Plan  6
    
    A beneficial  application of  the  park-and-ride system could be for reducing
    the automobile  use created by Laguna Art Festival.
    
    The Laguna Art  Festival in Laguna  Beach is an annual summer event within
    the AWMA  area.   Its  history  dates  back over  40 years.  The festival  normally
    runs for  40 to 45 days in July and August  and draws over 200,000 people
    per season.*   Visitors arrive almost exclusively by automobile with the
    greatest  influx occurring on weekends.  This increase in local  traffic is
    a significant contributor to local  air quality problems and occurs when
    Laguna Beach's population is nearly doubled  by summer residents.  The limited
    number of access routes and  the deficiency of parking in Laguna Beach should
    aid in establishing a park-and-ride bus service from the periphery of the
    area.
    
    VMT Analysis
    
             A daily average of 4700 people are attracted to the Art Festival
             which implies a vehicular influx of 1568 cars.
    
             All  art festival visitors  arrive via either State Highway 1 or
             Laguna Canyon Road driving 15 miles round trip from major free-
             way connectors.   This accounts for approximately  27,750 vehicle
             miles per day in the AWMA  area.
                                                           «
    
    *Source:   Laguna Beach Chamber of Commerce.
                                        B-19
    

    -------
             Park-and-ride lots will be located at the junction of Interstate 5
             and Laguna Canyon Road, and possibly at the junction of State
             Highway 1 and State Highway 73.
             The usage rate by art festival destined visitors would probably
             be high because of the local parking deficiencies surrounding
             the festival area.  It seems likely that on the order of 40%
             would use the system.
    VMT Reduction
             Trips affected = Xj X? X3
    
                                    X- = % park-and-ride users = .4
                                 X2 = 2 (two-way trip)
                              Xj = average influx - 1568
                            = (1568) x (2) x (.4)
                            = 1254.4 say 1254
             VMT reduction  = (Trips affected) x (reduced trip length)
                            = (1254) x (7.5)
                            = 9,405 miles per day of art festival  or
                              399,713 miles per season
    NOTE:   The shuttle buses would add VMT themselves, but the amount is not
           considered significant compared to the reduction benefit.
    Implementation Strategies:
             Limit the number of parking spaces available in the vicinity
             of the festival.
             Increase the cost of parking in and near the festival  area.
             Provide low cost or free bus service from parking areas.
             Initiate a contract for bus service with the Orange County  Transit
             District.   (At present OCTD does not have available buses,
             but they are expanding their fleet.)
                                        B-20
    

    -------
             APPENDIX C
    SAN DIEGO REGIONAL WATER QUALITY
       CONTROL BOARD REQUIREMENTS
    

    -------
                   CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD
                                   SAN DIEGO REGION
                                   ORDER NO. 74 - 72.
    
                                  NPDES NO. CA0107611
    
                             WASTE DISCHARGE REQUIREMENTS
                                         FOR
                            ALISO WATER MANAGEMENT AGENCY
                                    OCEAN OUTFALL
    
    
    THE CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD,  SAN DIEGO REGION (HEREAFTER
    BOARD), FINDS THAT:
    
         1.  THE AL.ISO WATER MANAGEMENT AGENCY (AWMA) SUBMITTED A REPORT OF WASTE
             DISCHARGE DATED JUNE 28,  1974 IN APPLICATION FOR A NATIONAL POLLUTANT
             DISCHARGE ELIMINATION SYSTEM PERMIT FOR A PROPOSED DISCHARGE.
    
         2.  AWMA PROPOSES TO DISCHARGE UP TO 18.5 MILLION GALLONS PER DAY  (MGD)
             OF TREATED; DOMESTIC SEWAGE CONTAINING  POLLUTANTS INTO THE PACIFIC
             OCEAN, A NAVIGABLE  WATER  OF THE UNITED STATES, FROM A NEW REGIONAL
             OCEAN OUTFALL TO BE LOCATED OFFSHORE OF THE  MOUTH OF ALI SO CREEK IN
             ORANGE COUNTY.
    
         3.  AWMA IS AN AGENCY WHICH WAS FORMED DURING EARLY 1972 TO PROVIDE REGIONAL
             SEWERAGE FACILITIES FOR A MAJOR PORTION OF THAT PORTION OF SOUTHEAST
             ORANGE COUNTY LYING WITHIN THE SAN DIEGO WATER QUALITY CONTROL REGION.
             MEMBER AGENCIES OF  AWMA AT THE PRESENT TIME  ARE THE Los ALISOS WATER
             DISTRICT, EL TORO WATER DISTRICT, MOULTON-NIGUEL WATER DISTRICT, SOUTH
             LAGUNA SANITARY DISTRICT, EMERALD BAY  SERVICE DISTRICT, IRVINE RANCH
             WATER DISTRICT, SANTA; ANA MOUNTAINS COUNTY-WATER DISTRICT, AND THE
             CITY OF LAGUNA BEACH.
    
         4.  PRESENTLY, THE CITY OF LAGUNA BEACH.DISCHARGES APPROXIMATELY 1.8 MGD
             OF PRIMARY EFFLUENT .INTO  THE PACIFIC OCEAN VIA AN OCEAN OUTFALL.  THE
             CITY .OF LAGUNA: BEACH.  HAS APPLIED  .FOR-A NATIONAL POLLUTANT DISCHARGE
             ELIMINATION SYSTEM  PERMIT FOR THEIR EXISTING DISCHARGE.
    
         5.  PRESENTLY, .THE SOUTH LAGUNA SAN.ITARY DISTRICT DISCHARGES  APPROXIMATELY
             1.4 MGD OF SECONDARY EFFLUENT INTO THE PACIFIC OCEAN VIA  AN OCEAN
             OUTFALL.  THE WASTEWATER  UNDERGOES TREATMENT IN A 3.2 MGD CAPACITY
             TREATMENT PLANT JOINTLY OWNED BY THE SOUTH LAGUNA SANITARY DISTRICT
             AND THE MOULTON-^NlGUEL WATER DISTRICT.  THE  SOUTH LAGUNA  SANITARY
             DISTRICT'S EXISTING DISCHARGE is REGULATED BY ORDER No. 74-42, A
             NATIONAL POLLUTANT  DISCHARGE ELIMINATION SYSTEM PERMIT ADOPTED BY
             THIS REGIONAL BOARD ON SEPTEMBER 16, 1974.
                                        C-l
    

    -------
    ORDER No. 74-72
         6.  IN ADDITION TO THE ClTY OF LACUNA BEACH FACILITIES AND  THE  SOUTH LAGUNA
             SANITARY DISTRICT/MOULTON-NIGUEL WATER DISTRICT JOINT FACILITIES,
             INLAND SECONDARY WASTEWATER TREATMENT PLANTS,  LOCATED WITHIN  THE
             AWMA SERVICE AREA AND UTILIZING LAND DISPOSAL  OF EFFLUENT,  ARE
             PRESENTLY OPERATED BY THE MOULTON-NIGUEL WATER O.ISTRICT (2  FACILITIES,
             SERVING THE 1-A AND 2-A IMPROVEMENT DISTRICTS), THE LOS ALISOS WATER
             DISTRICT, AND ROSSMOOR SANITATION, INC. THE ROSSMOOR SANITATION,
             INC. FACILITIES ARE LOCATED WITHIN THE BOUNDARIES OF THE EL TORO
             WATER DISTRICT.  WASTEWATER FROM BOTH MOULTON-NiGUEL WATER  DISTRICT
             INLAND FACILITIES CAN BE CONVEYED TO THE SOUTH LACUNA SANITARY
             DISTRICT'S OCEAN OUTFALL FOR DISPOSAL.
    
         7.  THE MOULTON-NiGUEL WATER DISTRICT PLANS TO  ABANDON ITS  TREATMENT
             PLANT SERVING IMPROVEMENT DISTRICT 2-A ANO  USE THE TREATMENT  PLANT
             SERVING IMPROVEMENT DISTRICT 1-A FOR" WASTEWATER RECLAMATION PURPOSES.
             USE OF THE CITY OF LAGUNA BEACH'S TREATMENT PLANT AND OCEAN OUTFALL
             AND THE SOUTH LAGUNA SANITARY DISTRICT'S OCEAN OUTFALL  WOULD  BE
             DISCONTINUED.  AWMA WOULD CONSTRUCT A NETWORK  OF PIPELINES  AND PUMP
             STATIONS, A NEW REGIONAL 16.0 MGD CAPACITY  SECONDARY TREATMENT PLANT,
             AND A NEW- REGIONAL OCEAN OUTFALL.  UPON COMPLETION, ESTIMATED BY
             AWMA AT APPROXIMATELY THE END OF 1975, .THE  NEW FACILITIES WOULD BE
             UTILIZED IN CONJUNCTION WITH THE EX I STING SOUTH LAGUNA  SANITARY
             DlSTRICT/MOULTON-NlGUEL WATER DISTRICT JOINT TREATMENT  PLANT  TO
             PROVIDE SEWERAGE WITHIN THE AWMA SERVICE AREA.
    
         8.  THE NEW REGIONAL TREATMENT PLANT WOULD BE CONSTRUCTED ADJACENT TO
             ALISO CREEK, JUST UPSTREAM FROM THE SOUTH LAGUNA SANITARY DISTRICT/
             MOULTON-NIGUEL JOINT TREATMENT PLANT,  THE  NEW REGIONAL TREATMENT
             PLANT WOULD TREAT RAW WASTEWATER FROM ALL OF THE AWMA SERVICE AREA
             EXCEPT THAT PRESENTLY SERVED BY THE SOUTH LAGUNA SANITARY DISTRICT'S
             SOUTH COAST INTERCEPTOR.  EFFLUENT FROM THE NEW REGIONAL TREATMENT
             PLANT WOULD BE DISCHARGED THROUGH THE NEW REGIONAL OCEAN OUTFALL.
    
         9.  THE NEW; REGIONAL OCEAN OUTFALL WOULD BE CONSTRUCTED OFFSHORE  OF THE
             MOUTH or ALISO CREEK.  THE OUTFALL WOULD BE APPROXIMATELY 7000 FEET
             LONG AND TERMINATE IN APPROXIMATELY 170 FEET OF WATER AT A  POINT
             33°29'52" NORTH LATITUDE AND 117°46T09" WEST LONGITUDE.   FINAL
             SIZING OF THE PROPOSED OUTFALL HAS NOT BEEN COMPLETED,  ALTHOUGH
             PRESENT PLANS CALL FOR A CAPACITY IN THE RANGE OF 25 HGD.
    
        10.  THE EXISTING SOUTH LAGUNA SANITARY DISTRICT/MOULTON-NIGUEL  WATER
             DISTRICT JOINT TREATMENT PLANT WOULD SERVE  THE AREA TRIBUTARY TO THE
             SOUTH LAGUNA SANITARY DISTRICT'S SOUTH COAST INTERCEPTOR.   THE PLANT
             WOULD BE USED TO TREAT A MAXIMUM OF ONLY 2.5 MGD,  RATHER THAN THE
             3.2 MGD PRESENT DESIGN CAPACITY.   EFFLUENT  WOULD BE DISCHARGED  INTO
             THE NEW REGIONAL OCEAN OUTFALL.
                                      C-2
    

    -------
    ORDER No. 74-72
        11.  THE EXISTING FACILITIES OF THE LOS At-1 SOS WATER DISTRICT AND THE
             ROSSMOOR SANITATION DISTRICT WOULD BE USED IN CONJUNCTION WITH A
             PROPOSED ADVANCED WASTEWATER TREATMENT PLANT TO PROVIDE WASTEWATER
             FOR RECLAMATION  IN INLAND AREAS ON DEMAND.
    
        12.  THE STATE WATER RESOURCES CONTROL BOARD ADOPTED THE*WATER QUALITY
             CONTROL PLAN. OCEAN WATERS OF CALIFORNIA. ON JULY 6, 1972.  THIS
             PLAN CONTAINS WATER QUALITY OBJECTIVES FOR THE FOLLOWING PARAMETERS
             IN ORDER TO PROTECT THE BENEFICIAL USES OF THE PACIFIC OCEAN:
    
             (A)  BACTERIA
             (a)  PHYSICAL CHARACTERISTICS
             (c)  CHEMICAL       "
             (D)  BIOLOGICAL     "
             (E)  TOXICITY
             (F)  RADIOACTIVITY
    
        13.  THE BENEFICIAL USES OF THE PACIFIC OCEAN INCLUDE INDUSTRIAL WATER
             SUPPLY, RECREATION, AESTHETIC ENJOYMENT, NAVIGATION,  AND PRESERVATION
             AND ENHANCEMENT OF FISH AND WILDLIFE, AND OTHER MARINE RESOURCES
             AND PRESERVES.
    
        14.  EFFLUENT LIMITATION,  NATIONAL STANDARDS OF PERFORMANCE, TOXIC AND
             PRETREATMENT EFFLUENT STANDARDS, AND OCEAN DISCHARGE CRITERIA
             ESTABLISHED PURSUANT TO SECTIONS 208(8), 301, 302,  303(o), 304, 306,
             307 AND 403 OF THE FEDERAL WATER POLLUTION CONTROL  ACT AND AMENDMENTS
             THERETO ARE APPLICABLE TO THE DISCHARGE.
    
        15.  THE BOARD HAS NOTIFIED THE DISCHARGER AND INTERESTED AGENCIES AND
             PERSONS OF ITS INTENT TO PRESCRIBE WASTE DISCHARGE  REQUIREMENTS FOR
             THE PROPOSED DISCHARGE AND HAS PROVIDED THEM WITH AN OPPORTUNITY FOR
             A PUBLIC HEARING AND AN OPPORTUNITY TO SUBMIT THEIR WRITTEN VIEWS
             AND RECOMMENDATIONS.
    
        16.  THE BOARD IN A PUBLIC MEETING HEARD AND CONSIDERED  ALL COMMENTS
             PERTAINING TO- THE DISCHARGE.
    
        17.  THIS ORDER SHALL SERVE AS A NATIONAL POLLUTANT DISCHARGE ELIMINATION
             SYSTEM PERMIT PURSUANT TO SECTION 402 OF THE FEDERAL WATER POLLUTION
             CONTROL ACT, OR AMENDMENTS THERETO, AND SHALL TAKE  EFFECT AT THE END
             OF TEN (10) DAYS FROM THE DATE OF ADOPTION.
    
    IT IS HEREBY ORDERED, THE ALISO WATER MANAGEMENT AGENCY, IN  ORDER TO MEET THE
    PROVISIONS CONTAINED IN DIVISION 7. OF THE CALIFORNIA  WATER CODE AND REGULATIONS
    ADOPTED THEREUNDER AND THE PROVISIONS OF THE FEDERAL  WATER POLLUTION CONTROL
    ACT, AND REGULATIONS AND GUIDELINES ADOPTED THEREUNDER, SHALL COMPLY WITH THE
    FOLLOWING:
                                       C-3
    

    -------
    ORDER No., 74-72
    A.   EFFLUENT LIMITATIONS
    
         1..  THE DISCHARGE THROUGH THE OCEAN OUTFALL OF AN EFFLUENT CONTAINING
             POLLUTANTS  IN EXCESS OF THE FOLLOWING LIMITS  IS PROHIBITED:
                                         TABLE A
                 CONSTITUENTS
    
             5-DAY 20° c BIOCHEMICAL
               OXYGEN DEMAND
    
             SUSPENDED SOLIDS
             pH
                MONTHLY^/  V/EEKLYJ=/
                AVERAGE    AVERAGE    MAXIMUM
    LBS,
       M,G/L5/
    LBS/DAY^
    
      UNITS
    
      TABLE B
      30^
    4630
      3
    4630
      45
    6940
    
      45
    6940
      50
    7720
    
      50
    7720
    (WITHIN RANGE 6-9)
                                                        NOT To BE
                                                    EXCEEDED MORE THAN
    UN i TS
    MG/L
    LBS/OAY
    MG/L
    LBS/DAY
    ML/L
    JTU
    50$ OF TIME
    10
    1540
    1.0
    154
    0.1
    50
    DAILY
    MAXIMUM
    15
    2310
    2.0
    309
    0.2
    75
                 CONSTITUENTS
    
             GREASE AND OIL
    
    
             FLOATiNG PARTiCULATES
    
    
             SETTLEABLE SOLIDS
    
             TURBIDITY
         2.  THE GEOMETRIC MEAN OF THE NUMBER OF FECAL COLIFORM BACTERIA IN SAMPLES
             OF THE EFFLUENT DISCHARGED THROUGH THE OCEAN OUTFALL SHALL NOT EXCEED
             200 PER 100 MILLILITERS FOR ALL SAMPLES COLLECTED IN A PERIOD OF 30
             CONSECUTIVE DAYS, OR 400 PER 100 MtLLILITERS FOR ALL SAMPLES COLLECTED
    
             IN A PERIOD OF SEVEN CONSECUTIVE DAYS.
    NOTE:   MG/L = MILLIGRAMS PER LITER
           L3S/OAY = POUNDS PER DAY
           ML/L = MILLILITERS PER LITER
           JTU = JACKSON TURBIDITY UNITS
    
           A LIST OF ALL FOOTNOTES REFERENCED WILL BE FOUND FOLLOWING
           THE LAST PAGE OF THE WASTE DISCHARGE REQUIREMENTS SECTION.
                                     C-4
    

    -------
     No. 74—72
    3.
    THE TOTAL COL I FORM BACTERIA IN ANY SAMPLE OF THE EFFLUENT DISCHARGED
    THROUGH THE OCEAN OUTFALL SHALL NOT EXCEED 1000 PER 100 MILLILITERS.
    5.
        PRIOR TO JULY 1, 1978, THE ANNUAL ARITHMETIC MEAN TOTAL CONCENTRATION
        OF CADMIUM, CHROMIUM, COPPER, LEAD, NICKEL, ZINC, COBALT, AND OTHER
        HEAVY METALS SHALL NOT EXCEED 2.0 MG/L AND THE TOTAL CONCENTRATION OF
        SAID METALS SHALL NOT EXCEED 5.0 MG/L AT ANY TIME.
    THE DISCHARGE THROUGH THE OCEAN OUTFALL OF AN EFFLUENT CONTAINING
    POLLUTANTS IN EXCESS OF THE LIMITS ESTABLISHED BY THE STATE WATER
    RESOURCES CONTROL BOARD'S WATER QUALITY CONTROL PLAN, OCEAN WATERS
    OF CALIFORNIA. TABLE B, IN THEIR PRESENT FORM OR AS THEY MAY BE
    MODIFIED, IS PROHIBITED AFTER JULY 1, 1978.  HOWEVER, PROVIDED IT
    CAN BE CONCLUSIVELY DEMONSTRATED BY THE DISCHARGER THAT THE TREATMENT
    PROCESS REQUIRED BY WATER CODE SECTION 13379(A AND B) PLUS SOURCE
    CONTROL WILL NOT RESULT IN COMPLETE COMPLIANCE WITH THE FOLLOWING
    LIMITS BY JULY 1, 1978, THE STATE BOARD MAY ALLOW ADDITIONAL TIME
    FOR COMPLIANCE NOT TO EXCEED JULY 1, 1983.  PRESENTLY, THE LIMITS
    ESTABLISHED BY TABLE B OF THE OCEAN PLAN ARE AS FOLLOWS:
             CONSTITUENTS
    
        AR.SEN i c
    
    
        CADMIUM
    
    
        TOTAL CHROMIUM
    
    
        COPPER
    
    
        LEAD
    
    
        MERCURY
    
    
        NICKEL
    
    
        SILVER
                                  UNITS
                                   MG/L
                                   S/DAV
      MG/
    LBS/DAY
                                   MG/L
                                 LBS/DAY
    
    
                                   MG/L
                                 LBS/OAY
                                   MG/L
                                   S/DAV
    LBS/DAY
    
    
      MG/L
    LBS/OAY
    
    
      MG/L
    LBS/DAY
    
    
      MG/L
    LBS/DAY
    
    
      MG/L
    LBS/DAY
                  NOT To BE
               EXCEEDED MORE THAN
                                    DAILY
                  50% OF TIME      MAXIMUM
     0.01            0.02
     1.54            3.09
    
     0.02            0.03
     3.09            4.63
    
     0.005           0.01
     0.77            1.54
    
     0.2             0.3
    30.9            46.3
    
     0.1             0.2
    15.4            30.9
    
     0.001           0.002
     0.15            0.31
    
     0.1             0.2
    15.4            30.9'
    
     0.02            0.04
     3.09            5.17
                                  C-5
    

    -------
     ORDER Mo.  74-72
                                                            NOT To  BE
                                                        EXCEEDED MORE THAN
    UNITS
    MG/L
    L8S/OAY
    MG/L
    UBS/DA*
    MG/L
    LBS/DAY
    MG/L
    LBS/OAY*
    . MG/L
    LBS/DAY
    MG/L
    LBS/DAY
    TU
    PCJ/L
    50$ OF TIME
    0.3
    46.3
    0.1
    15.4
    0.5
    77.2
    1.0
    154
    40*0
    6170
    0.002
    0.32
    1.5
    NOT TO EXCEED THE
    DAILY
    MAXIMUM
    0.5
    77.2
    0.2
    30.9
    1.0
    154
    2.0
    309
    60.0
    9260
    0.004
    0.62
    2.0
    LIMITS
                   CONSTITUENTS
    
              ZINC
    
    
              CYANIDE
    
    
              PHENOLIC COMPOUNDS
    
    
              TOTAL CHLORINE RESIDUAL'
    
    
              AMMONIA (EXPRESSED .AS
                NITROGEN)
    
              TOTAL IDENTIFIABLE
                CHLORINATED HYDROCARBONS
    
              TOXICITY. CONCENTRATION
    
              RADIOACTIVITY
                                                        SPECIFIED IN TITLE 17,
                                                        CHAPTER 5, SUBCHAPTER 4,
                                                        GROUP 3, ARTICLE 5,
                                                        SECTIONS 30285 AND 30287 OF
                                                        THE CALIFORNIA ADMINISTRATIVE
                                                        CODE.
    
    B.   RECEIVING WATER LIMITATIONS
    
         1.  THE DISCHARGE THROUGH THE OCEAN OUTFALL SHALL NOT CAUSE THE.FOLLOWI NG
             LIMITS TO BE EXCEEDED OUTSIDE OF THE INITIAL DILUTION ZONE6*/:
    NOTE:  TU = TOXICITY.UNITS
           PCl/L = PlCOCURIES PER LITER
                                      C-6
    

    -------
     ORDER No. 74-72
                  CONSTITUENTS
    
              GREASE AND OIL
    
              FLOATING PARTICIPATES
    
    
              TOXICITY
    
              RADIOACTIVITY
    MG/DRY
     WT/M2
    
      TU
    
    
     PCl/L
                                            CONCENTRATION NOT To BE
                                               EXCEEDED MORE THAN
    
                                           50$ OF TIME  10# OF TIME  MAXIMUM
    
                                               10.0         20.0
    
                                                1.0-          .1.5
    
    
                                                —                     0.05
    
                                           NOT TO EXCEED THE LIMITS SPECIFIED
                                           IN TITLE 17, CHAPTER 4, SUBCHAPTER 4,
                                           .GROUP 3, ARTICLE 5, SECTIONS 30285
                                           AND 30287 OF THE CALIFORNIA ADMIN-
                                           ISTRATIVE CODE;
    
    2.  THE DISCHARGE THROUGH THE OCEAN OUTFALL SHALL NOT CAUSE CONCENTRATIONS
        OF COLIFORM ORGAtUSMS WITHIN A ZONE BOUNDED BY THE SHORELINE AND A
        DISTANCE .OF 1,000, FEET FROM THE SHORELINE OR THE 30-FOOT DEPTH CONTOUR,
        WHICHEVER IS FURTHER FROM THE SHORELINE, AND IN AREAS OUTSIDE OF THIS
        ZONE USED FOR BODY-CONTACT SPORTS, TO EXCEED THE FOLLOWING:
    
             (A)  A MOST PROBABLE NUMBER OF 1000 PER 100 ML (10 PER ML) IN
                  MORE THAN 20 PERCENT OF THE SAMPLES AT ANY SAMPLING STATION
                  IN ANY 30-DAY PERIOD; OR A MOST PROBABLE NUMBER OF 10,000
                  PER 100 ML (100 PER ML) IN ANY SINGLE SAMPLE WHEN VERIFIED
                  BY A REPEAT SAMPLE TAKEN WITHIN 48 HOURS.
    
             (a)  A LOG MEAN MOST PROBABLE NUMBER OF FECAL COLIFORM ORGANISMS
                  OF 200 PER 100 ML, OR A MOST PROBABLE .NUMBER OF FECAL
                  COLIFORMS OF 400 PER 100 ML IN MORE THAN 10 PERCENT OF THE
                  TOTAL SAMPLES DURING ANY 30-DAY PERIOD;  AS DETERMINED BY
                  MULTIPLE TUBE FERMENTATION PROCEDURES AND BASED ON A
                  MINIMUM OF NOT LESS -THAN. FIVE SAMPLES. FOR ANY 30-DAY PERIOD.
    
    3.  THE DISCHARGE THROUGH THE OCEAN OUTFALL SHALL NOT CAUSE THE CONCEN-
        TRATION OF TOTAL COLIFORM ORGANISMS IN ANY AREAS WHERE SHELLFISH MAY
        BE HARVESTED FOR HUMAN. CONSUMPTI ON TO EXCEED THE FOLLOWING:
    
                  A MEDIAN MOST PROBABLE NUMBER OF 70 PER 100 ML WITH NOT
                  MORE^THAN.-10 PERCENT OF THE SAMPLES EXCEEDING A MOST
                  PROBABLE NUMBER OF 230 PER 100 ML.
    NOTE:   MG/M^ = MILLIGRAMS PER SQUARE METER
           MG DRY WT/M  = MILLIGRAMS DRY WEIGHT PER SQUARE METER
                                      C-7
    

    -------
    ORDER No. 74-72
         4.  THE DISCHARGE THROUGH THE OCEAN OUTFALL SHALL NOT CAUSE:
    
             (A)  FLOATING PARTICULATES OR GREASE AND OIL TO BE VISIBLE AT ANY
                  LOCATION;
    
             (a)  AESTHETICALLY UNDESIRABLE DISCOLORATION ON THE OCEAN SURFACE
                  AT ANY LOCATION;
    
             (c)  THE TRANSMITTANCE OF NATURAL LIGHT OUTSIDE OF THE INITIAL
                  DILUTION ZONE7-'  TO BE REDUCED BY MORE THAN ONE STANDARD
                  DEVIATION FROM THE MEAN DETERMINED FOR UNAFFECTED WATERS
                  DURING THE SAME PERIOD;
    
             (D)  THE DISSOLVED OXYGEN CONCENTRATIONS OF WATERS OUTSIDE OF THE
                  INITIAL DILUTION ZONE"/ TO BE DEPRESSED MORE THAN 10 PERCENT
                  FROM CONCENTRATIONS WHICH OCCUR NATURALLY;
    
             (E)  THE pH OUTSIDE OF THE INITIAL DILUTION ZONE-^ TO  BE  CHANGED
                  MORE THAN 0.2 UNITS FROM THE pH WHICH OCCURS NATURALLY?
    
             (F)  THE RATE OF DEPOSITION OF INERT SOLIDS AND THE CHARACTERISTICS
                  OF INERT SOLIDS IN OCEAN SEDIMENTS,TO BE CHANGED  SUCH THAT
                  BENTHIC COMMUNITIES ARE DEGRADED^-';
    
             (G)  THE DISSOLVED SULFIOE CONCENTRATION OF WATERS IN  AND NEAR
                  SEDIMENTS TO BE INCREASED BY MORE THAN ONE STANDARD  DEVIATION
                  FROM THE MEAN DETERMINED UNDER NATURAL CONDITIONS;
    
             (H)  THE CONCENTRATIONS OF HEAVY METALS, CYANIDE, PHENOLIC COMPOUNDS,
                  TOTAL IDENTIFIABLE CHLORINATED HYDROCARBONS AND RADIOACTIVITY
                  IN SEDIMENTS TO BE INCREASED BY MORE THAN ONE STANDARD DEVIATION
                  FROM THE MEAN DETERMINED UNDER NATURAL CONDITIONS;
    
             (l) - THE CONCENTRATIONS OF ORGANIC MATERIALS IN MARINE S'EDIMENTS TO
                  BE .INCREASED ABOVE THOSE WHICH WOULD DEGRADED* MARINE LIFE;
    
             (j)  NUTRIENT MATERIALS IN CONCENTRATIONS THAT WOULD. CAUSE OBJECTION-
                  ABLE AQUATIC GROWTHS OR DEGRAOE'^^/ INDIGENOUS BIOTA;
    
             (K)  MARINE COMMUNITIES INCLUDING VERTEBRATE,  INVERTEBRATE, AND
                  PLANT SPECIES TO BE DEGRADEDi2/;  OR
    
             (L)  ALTERATION OF NATURAL TASTE, ODOR, AND COLOR OF FISH, SHELLFISH
                  OR OTHER MARINE RESOURCESUSED FOR HUMAN CONSUMPTION.
                                     C-8
    

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    ORDER Mo. 74—72
    C.   PROVISIONS
    
         1.  THIS ORDER is ESTABLISHED ONLY FOR A WASTE DISPOSAL OPERATION AS
             HEREINBEFORE DESCRIBED AND A WASTE DISCHARGE VOLUME NOT IN EXCESS
             OF 18.5 MGO.
    
         2.  NEITHER THE;TREATMENT NOR THE DISCHARGE OF POLLUTANTS SHALL CREATE
             A POLLUTION, CONTAMINATION OR NUISANCE..AS DEFINED BY THE CALIFORNIA
             WATER COD'E.
    
         3.  BYPASSING OR DIRECT DISCHARGE OF TREATED-OR UNTREATED:-LIQUID OR
             SOLID WASTES TO ANY INLAND WATERCOURSE IS PROHIBITED.
    
         4.  ODORS, VECTORS AND OTHER NUISANCES OF SEWAGE OR SEWAGE SLUDGE ORIGIN
             BEYOND THE/LIMITS OF THE TREATMENT PLANT SITE ARE PROHIBITED.
    
        • 5.  ALL WASTE TREATMENT AND DISPOSAL FACILITIES. SHALL BE. PROTECTED
             AGAINST A 100-YEAR-FREQUENCY FLOOD AS DEFI NED BY THE ORANGE COUNTY
             FLOOD CONTROL AGENCY.
    
         6.  THIS ORDER INCLUDES ITEMS 1, 2,  4'AND 5 OF THE ATTACHED "REPORTING
             REQUIREMENTS."
    
         7.  THIS ORDER INCLUDES ITEMS 1, 2,  3,.-4, 5, 6, 7, 8, 9, 10 AND 11 OF
             THE ATTACHED "STANDARD PROVISIONS."
    
         8.  THIS ORDER INCLUDES THE ATTACHED "GENERAL MONITORING AND REPORTING
             PROVISIONS."
    
         9. ;THE DISCHARGER SHALL COMPLY WITH THE-MONITORING AND KEPORTING
             PROGRAM CONTAINED . IN THIS ORDER,
    
        10.  THE DISCHARGER SHALL COMPLY WITH THE FOLLOWING TIME SCHEDULE  TO
             ASSURE COMPLIANCE WITH EFFLUENT  LIMITATION A.5 OF THIS ORDER:
    
                                                     COMPLETION      REPORT OF
               	TASK                       DATE ..     COMPLIANCE DATE
    
               BEGIN STUDY TO^ DETERMINE                6-1-75         6-15-75
               FEASIBILITY OF COMPLIANCE
    
               PROGRESS REPORT ON STUDY TO             3-1-76         3-15-76
               DETERMINE FEASIBILITY OF COMPLIANCE
    
               COMPLETE STUDY TO DETERMINE            12-1-76        12-15-76
               FEASIBILITY OF' COMPLIANCE AND
               PREPARE REPORT
                                     C-9
    

    -------
     ORDER Wo. 74-72
    
    
                                                       COMPLETION     REPORT OF
                	TASK                       DATE      COMPLIANCE DATE
    
                SUBMIT REPORT TO'REGIONAL BOARD          l-rl-77 :..
    
                DEVELOP PLAN FOR COMPLIANCE              3-1-77         3-15-77
    
        •  .  .    BEG'IN IMPLEMENTATION OF PLAN     r   '-\~::7-1-77'..'-.  ••. 7-15-77
                                                                  ...  ' «v
                PROGRESS REPORT ON IMPLEMENTATION        1-1-78        -1-15-78
                OF PLAN'FOR COMPLIANCE             .             .
    
     ..:...-     FULL COMPLIANCE                          7-1-78     '    7-15-78
    
              THE ALIso WATER MANAGEMENT AGENCY SHALL SUBMIT To THE BOARD ON/OR-
              BEFORE EACH COMPLIANCE REPORT DATE, A REPORT OF COMPLIANCE OR NON-
        .'  •-'   COMPLIANCE WITH THE SPECIFIC TASK.  IF NONCOMPL I ANCE IS BEING
              REPORTED, THE REASONS FOR SUCH NONCOMPLIANCE SHALL BE STATED, PLUS
              AN ESTIMATE OF THE DATE OF COMPLIANCE.., THE ALISO WATER MANAGEMENT
              AGENCY SHALL NOTIFY THE BOARD BY LETTER UPON RETURN  TO COMPLIANCE
              WITH THE TIME SCHEDULE.
    
         11.   THIS ORDER EXPIRES SEPTEMBER l,  1979,  AND THE ALIso  WATER MANAGEMENT
              AGENCY MUST FILE A REPORT OF WASTE DISCHARGE IN ACCORDANCE'WITH
              TITLE 23, CALIFORNIA ADMINISTRATIVE CODE, NOT LATER  THAN 180 DAYS IN
              ADVANCE OF SUCH DATE, AS APPLICATION FOR' ISSUANCE OF NEW WASTE DISCHARGE
              REQUIREMENTS.
    
         12.   IN THE EVENT OF ANY CHANGE IN CONTROL  OR  OWNERSHIP OF LAND OR WASTE
              DISCHARGE FACILITIES PRESENTLY OWNED OR CONTROLLED BY THE ,D ISCHARGER,
              THE DISCHARGER SHALL NOTIFY THE  SUCCEEDING OWNER  OR  OPERATOR OF THE
              EXISTENCE OF THIS ORDER BY LETTER, A COPY OF WHICH SHALL BE FORWARDED
          .;   TO THIS.BOARO. ••      '    "    .   '  .,  ../ .
    
         13.   THIS ORDER DOES NOT RELIEVE THE  DISCHARGER OF THE  RESPONSIBILITY TO
         .     OBTAIN OTHER NECESSARY LOCAL, STATE, AND  FEDERAL  PERMITS TO CONSTRUCT
      •.'..•.....V  FACILITIES NECESSARY .FOR COMPLIANCE WITH  THIS ORDERJ  NOR DOES THIS
              ORDER PREVENT IMPOSITION OF ADDITIONAL STANDARDS, REQUIREMENTS,  OR
              CONDITIONS' BY ANY OTHER REGULATORY AGENCY.
    I, LEONARD BURTMAN, EXECUTIVE OFFICER,:DO HEREBY CERTIFY THE FOREGOING is A FULL,
    TRUE, AMD CORRECT COPY OF AN ORDER ADOPTED BY THE CALIFORNIA REGIONAL WATER QUALITY
    CONTROL SOASO, SAN DIEGO REGION, ON. NOVEMBER 4, 1974.
                                                         LEONARD BURTMAN
                                                         EXECUTIVE OFFICER
                                         C-10
    

    -------
                   CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD
                                   SAN DIEGO REGION
    FOOTNOTE REFERENCES FOR WASTE DISCHARGE REQUIREMENTS OF ORDER No. 74-72
    (NPDES PERM17-Ho. CA0107611) - ALI SO WATER MANAGEMENT AGENCY OCEAN OUTFALL
    
         1.  THE MONTHLY AVERAGE SHALL BE THE ARITHMETIC MEAN, USING THE RESULTS
             0'~ ANALYSES OF ALL SAMPLES COLLECTED DURING ANY 30 CQNSECUTIVE
             CALENDAR DAY PERIOD..
    
         2.  THE WEEKLY AVERAGE SHALL BE THE ARITHMETIC MEAN, USING THE RESULTS
             OF ANALYSES OF ALL SAMPLES COLLECTED DURING ANY SEVEN CONSECUTIVE
             CALENDAR DAY PERIOD.
    
         3.  THE PAILY MAXIMUM SHALL BE DETERMINED FROM THE RESULTS OF A SINGLE
             3RA3 SAMPLE OR FROM THE RESULT OF A SINGLE COMPOSITE SAMPLE COLLECTED
             OVER A PERIOD OF 24 HOURS.
    
         4.  THE ARITHMETIC MEAN OF BOD AMD SUSPENDED SOLIDS VALUES, BY WEIGHT,
             FOR EFFLUENT SAMPLES COLLECTED IN A PERIOD OF 30 CONSECUTIVE
             CALENDAR DAYS SHALL NOT EXCEED 15 PERCENT OF THE ARITHMETIC MEAN
             OF VALUES, BY WEIGHT,  FOR INFLUENT SAMPLES COLLECTED AT APPROXIMATELY
             THE SAME TIMES DURING THE SAME PERIOD.
    
         5.  THE DISCHARGE RATE IN POUNDS PER DAY IS OBTAINED FROM THE FOLLOWING
             CALCULATION FOR ANY CALENDAR DAY:
                                                      N
                     DISCHARGE RATE (LBS/DAY) = 8.34 -^cr Q. C  ,
                                              •   N   -^     *
                                                      1  '
    
             IN WHICH N IS THE NUMBER OF SAMPLES ANALYZED IN ANY CALENDAR DAY.
             Q, AND C, ARE THE FLOW RATE (MGD) AND THE CONSTITUENT CONCENTRATION
             (MG/L) RESPECTIVELY, WHICH ARE ASSOCIATED WITH EACH OF THE N GRAB
             SAMPLES WHICH MAY BE TAKEN IN ANY CALENDAR DAY.  |F A COMPOSITE
             SAMPLE'IS TAKEN, C, IS THE CONCENTRATION MEASURED IN THE COMPOSITE
             SAMPLE, AND Q,  IS THE AVERAGE FLOW RATE OCCURRING DURING THE PERIOD
             OVER WHICH SAMPLES ARE COMPOSITED.
    
         6.  THE INITIAL DILUTION ZONE SHALL BE AS DEFINED IN THE WATER QUALITY
             CONTROL PLAN. OCEAN WATERS OF CALIFORNIA. ADOPTED BY THE STATE WATER
             RESOURCES CONTROL BOARD ON JULY 6, 1972.
    
         7.  I3!D
    
         3.  IBID
    
         9.  laic
        10.  DEGRADATION SHALL BE DETERMINED BY ANALYSIS OF THE EFFECTS OF WASTE '
             DISCHARGE ON SPECIES DIVERSITY, POPULATION DENSITY, GROWTH ANOMALIES,
             DEBILITY, OR SUPPLANTING OF NORMAL SPECIES BY UNDESIRABLE PLANT AMD
             AMIMAL SPECIES.
    
        11.  !S;D
    
        12,  !310
    
        13.  1310
    
                                       C-ll
    

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                 APPENDIX D
    CALIFORNIA COASTAL ZONE CONSERVATION
          COMMISSION REQUIREMENTS
    

    -------
    ' itabjrt F. Roortey, Ph.D., Chairman
     Russell Rubley, Vice-Chairman
     Jamas A. Hayes, State Representativa
    W. J. Carpenter,  Executive Director
                                              Temporary Addresr
                                        925 Harbor Plaza, Second Floor
                                            P'°* Box 1U50
                                         Long Bsach, California 90301
                                 Teljphonsr. (213) 4384201.
                           RESOLUTION OF APPROVAL AND PERMIT
          Application Number:   P-2-21-73-29	
    
          Name of Applicant:    Alis'o Water Management Agency 	
    
            27281 Aliso  Creek Road, Laguna Niguel, California   92677
          Permit Type:
    Standard
                          j    {   Administrative
    
    
                          }|   Emergency
    
    
          Development Location:  Aliso Beach,  Aliso Canyon, and adjacent
    
            to the shoreline from Dana Point  to Laguna Beach
          Development Description:  An ocean  outfall, pumo stations, a
    
            portion of the  north coast interceptor line? a portion of
    
            "Reach A" Xand  outfall line, "North" Coast" and "South  Coast"
            interceptor lines  and associated  construction of the  Aliso
    
            Water Management Agency in the coastal zone permit  area.
          Commission Resolution:
    
          I,   The South Coast  Regional Coastal  Zone Conservation Commis-
               sion finds that  the proposed development:
    
               A.   NiiS/will  not have a substantial adverse environmental
                   or "ecological effect in that:
    
                    Short term  adverse environmental effects of boTtsrbr.anstrtcsn-
                                          D-l
    

    -------
    Resolution of Approval and  Permit
            will be minimal in view of the net environmental  gain
            .associated with construction and operation of  the system.
    
            The deep ocean outfall is designed to •minimize'adverse
            ecological effects.	v.  '•
        B.  , Is/is not  consistent  with the findings and declarations
            jet forth  in Public Resources Code Sections 27001, and
            27302 in that:
    
             It will aid in the preservation of the present  coastal
          '''-'       *    -%'•'•   .   '     •          •"•    . •.'  • . - '-
             zone resources for future maintenance planning.
        C.  Is  subject  to  the  following other resultant statutory
            provisions  and policies:          -        -
    
             Requirements  of State Water Resources Board
        D.  SSjz&sxsmfc. consistent with the  aforesaid other statutory
           0 provisions and-policies  in .that:   ---0    -•  - ,,  .„.;.-•',..,.
    
        •.. -..:  State Water Resources Board and County requirements
                                        •               '
         -.- •• -have- been-complied with. - ;:  ....    •.  ..  •..-  -.-.   .  ....•   •
        E.  The following  language  and/or drawings  clarify and/or
            facilitate  carrying  out the  intent  of the South Coast.
            Regional Zone  Conservation Commission:
    
             Maps, reports, documents and EIR on file with  the	
    
             commission.   -  -. ..   .  •  ...       .-•...-
                                  D-2
    

    -------
      Resolution of Approval and Permit
     II.  Whereas, at a public hearing held on 	April 16, 1973
                                                      (date)
          at 	Long Beach	 •
             ~ '.    . ..  .  ~    ~  (location) rTrT;.-...'
          by a     8       to __i____V. vote hereby approVes
          the application for Permit Number   P-2-21-73-29 J    pursuant
          to the California Coastal Zone Conservation Act\of 1972,  sub-
          ject ,to the following conditions imposed pursuant" to the
          Public Resources Code'Section 27^03: that Aliso Water Management
          Agency does hereby declare its intention to utilize the following
          design criteria for Its Regional Treatment Plan, and all
          additional treatment facilities constructed to utilize the land
          outfall  and ocean outfall for discharge of effluent:	'
          (a)  Dissolved oxygen concentration shall be not less than 2 MG/lj
          (b)  C6ncentration"of ammonia-nitrogen shall not be greater than
          2 MG/1;  and (c) The removal of 5-day bio-chemical oxygen demand
          (BC-Dp shall be'not less than 90% of the raw sewage (BODc)
          concentration.Appropriate sensors shall be installed which shall
          be  connected to recorders to provide a continuous record of the
          concentration of oxygen, and ammonia in the effluent delivered
          to  the ocean which, records shall be-made available, upon request,
          to  the California Regional v/ater Quality Control Board—San Diego
          Region.                                  •
    III.  Said terms and conditions shall be perpetual and bind all
          future owners and possessors of the property or any part
          thereof unless otherwise specified herein.
    
    
     IV.  Section 560 of the Regulations of the California Coastal  Zone
          Conservation Commission specifies that no structure or area of
          land or water shall be used or occupied in the manner authorized
          by the permit or in any other manner until the Executive
          Director has issued a Certificate of Compliance with the  terms
          and conditions of the permit.
    
    
      V.  The grant of this permit is further made subject to the.fol-
          low Ing:
    
          A.  That this permit shall not become effective until a copy
              thereof has been returned to the South Coast Regional
              Conservation Commission upon which copy all permittees  have
              acknowledged that they have received a  copy of the permit
              and understood its contents.  Said acknowledgement should
              be returned within ten working days following issuance  of
              this permit.
    
          B.  That upon completion of the activity authorized by this
              permit the permittee(s) shall promptly  complete the "Notice
              of Completion" and file it with the Executive—n-U-^t-.or, of.
              this Regional Commission.
                                   D-3
    

    -------
           C.   That said development to be commenced on or before
    
              120 days from'the date of issuance o.f.this permit
     VI.   Therefore,  said Permit (Standard,
           Number   p-2-21-73-29   is hereby granted/dsodbexic for the  above
           described development .only, subject to the above conditions
    ''' "'  ..and subject to "all terms and provisions; of "the Resolution of-
           Approval by the South Coast Regional Conservation Commission.
    
    
     VII.  ".'Executed, at       Long''Beach   "•   -1 California"on]behalf of
          ' the South' Coast Regional Conservation Commission on • .•  "'  '	
           \ '•"    April 23  ,1973 ^  . ";..':  .     \,.   ' ^ •  '•       :
                                      Executive Director
                                   D-4
    

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    gCALIFORNIA COASTAL ZONE CONSERVATION  COMMISSION
    • 540 MARKET STREET. 2nd FLOOR
     SAN FRANCISCO, CALIFORNIA 9410?
     (415) 557-1001
                                                                 July 3,  1973
       Mr. vJllllaa F. Wolf son
       Aliso Hater E^rggacent Agency
       27234 Aliso- Orsek Boad
            a l&gual,. CA 92&T7          .                        APPML HO.  29-7?
       Itear i-Ir, Wolf sons.
    
            (h. Juna 20*  1973f bj a TOto of 11 in faror,  nons agrjinsfc,  ths California
       Coastal Zono Consenrauion CocsaLssian granted tha  application of tho Aliso VJat
                  Ageacy to parfora tha developaexifc 03 scribed in tho attached Sta£f
            Thia persjifc is linritad to the aboro-dascribsci davclopnjent and is cubjact to
                 2iai coc/ditions- contained in tbo
                   any activity axtthoriaed by ths pozrait shall tolcs piaco? you smst
       to thia office and to tha Sotrth Coast  SagLonal Coaaisoion cifrics  copies or t^iis
       statsGerrt vdth your signatura acleaowledglag that jrou hare nsceived It cind undarstood
       its contsata*                                                      •         .
            Please note that TOCO, conplatioa of the activitioa axithoriasd you nrast prcnptly
       ccuaplate the Rotica of CkKrolation and file it with the  Bxscutiva Director of ths
                                                                       E.  BCDC7ITS
                                                                E>3cutiv»  Director-
         j South Coast-
           J-!r. A- Bovda
       Tha ts-idarsigaed porsittee acJcar.-ilsdgaa rocaipt of tha C.n'll foraia Coastal 2tons Conservation.
       COCTHJ. ssion pernit- coverad by Appeal !Io» 29-73 and fully understands its contents
       including ?1I conditions imposed.
                                                     D-5 	
    

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                     Market St.,  San Francisco  (415j  557-lOOi
    
                              STAFF RECOMMENDATION
    PERMIT
    APPLICATION:
    DECISION 0?
    REGIONAL COMMISSION:
    APPELLANT:
    DEVELOPMENT
    LOCATION:
    
    DEVELOPMENT
    DESCRIPTION:
    PUBLIC HEARING:
                                                   Appeal No. 29-73
                                                   60th Day:  6/29/T3
     Aliso Water Management Agency (AWMA),-
     Permit approved by the  South1 .'Coast Regional
     Commission.on April.16,  1973 subject  to  conditions.
    
     Orange County Environmental  Coalition, Dale Secord.
     At Aliso Creek in the  County  of Orange.
     A land outfall from the proposed AWMA Aliso Creek   "
     Regional Water Pollution Control Plant  southerly  '
     through the  bed of Aliso Creek and through a tunnel
     i>or Pacific Coast Highway.  Across ,the beach, the
     outfall will be buried to a depth of approximately
     25 to 30 feet.   The ocean outfall will be permanently
     buried to'a  water  depth of approximately 50 feet
    ~fb~r~¥pproxlinately  2,100 feet offshore where it
     will  be constructed on the ocean floor.  The
     outfall, will extend to a-water depth of approximately
     200 feet, approximately 7,000 feet offshore.
    
      June 6, 1973,  at  Monterey.                       .  .-
    STAFF RECOMMENDATION;  The staff recommends that the Commission approve
    the permit on the basis that it will not have substantial adverse    -•
    environmental or ecological impacts and is consistent with the findings
    and declarations of the Coastal Zone Conservation Act of 1972^; subject
    to the conditions below.                  '                       . .
    
    STAFF ANALYSIS.   '"     ;'."'•".'.':.'''''    .  V: '•'':  ' :        • .-•'  .  ;. v..'   '
    
         1.  General Considerations.  The overall plans of the AWMA, of which
    the land and ocean outfalls covered in this permit application are only
    3 small portion, are complex, extensive, and will have substantial
    impacts, on development both within and outside the permit area.
    Moreover, many factors in the overall.development are not yet re-
    solved.  Ordinarily, the staff would be reluctant to recommend approval
    of a major project under such circumstance, at this early stage in the
    Commission's planning, but in this instance there are other consider-
    ations that lead to the recommendation for approval..
         2.  Status of Water Quality.  The treatment plant and outfall of
                                                     the
    

    -------
     city of Laguna Beach are outdated and under a "cease and desist" orde~r*
     from the Regional.Water Quality Control Board.  The city has received
     grant funds and an exemption from the South Coast Regional Commission
     to make temporary repairs, but-these will be inadequate in the long run
     to meet water quality standards.  The other inland plants are reaching
     their ultimate capacities.  The RWQCB has required the area to solve
     its waste treatment problems in 197^ and the lead time, for such large
     projects necessitates that a decision be .made quickly.  The State Water
     Resources Control Board and the ayironmental Protection Agency have;   •;•
     taken the position, in which the staff concurs, that regional solutions
     to sewage treatment problems are preferred. ; The RWQCB had approved  .  __..
     the proposed project.  The appellants agree that new facilities with V'
     additional capacity must be constructed, but they question the size of
     the facility and the necessity for immediate action. ;;:''-;>•.-.:•- • .•^-r^:'.-':-:'z:•--.'
              ' •'  •.".*" ,     • .  "  • •   •'• •   .  •      .'"•••-••-' .  .' '!'':•'••,» " .'•""••.' ;.'_«"•*•"'••.•*"••". . • - !•• . -
                 -' .  • •   • -  - '  •' *-' "   ,-'"•'"''•''•• " '   •-.:--•• _  .••*•'••'..•  r : ' '-_._•'.  ^ •  	-•.,.*. i . ',  „, .
          3.  Planning Issues.  New waste-treatment facilities can help en-    :
     fcourage population growth(on. the assumption that without adequate  :v;,'r \
     sewers and waste-treatment plants, residential construction will be made
     impossible or at least will ba delayed for some time).'.- On the other .  ,..  ..
     hand, building inadequate facilities means increased costs, if the -  .   ';
     facilities later have to be added onto or replaced,,  In this., application>
     much of the cpaacity is designed to serve areas inland .from the coast,  •-
     but high population growth in these areas would affect the coast.    .;;> '
          The area of this proposal has been designated as a critically-im-'.
     p-acted area with regard to air pollution.  There is thus a concern that  ,
     new sewer construction, by providing for increased population will have
     the unintended result of increasing air pollution in an area with an
     already-severe smog problem.  Both the State Water Quality Control .:  • . ''•"„'
    •Board and the EPA- are studying, the proposed AWMA project in relation; to  .
     their grant programs^ and the results of these studies may have an im-  .
     portant impact on design, of-the project;  Because of the high cost;" of-..
     preparing detailed engineering plans for such a large system, and be-   ^
     cause of the uncertainties • of governmental approval, the applicant does
     not yet have detailed plans for the outfall design.'V:;;-•';'X.-',rv^<.;':v' V.;--'^:•••''/•'•"
    
          4.  Population.  The 1970 census population"pfT the area was slightly
     less than 50,000 persons, the AWMA has proposed, with the concurrance
     of SCAG and Orange County, that the facilities be designed for an
     ultimate population of about 230,000.  This figure is based on a
     population projection to the year 2000.  Due to the designation of    •
     the area as a critical air pollution area, however,the state and federal
     governments will only grant funds for a capacity based on a lower
     population projection to the year 199^* or a population of about
     1^4.000.  Neither the state nor the federal grant programs prohibit
     construction of greater capacities, but they do represent a policy of not
     encouraging such growth.                    ...  ' ..:.    . .-;'.'     .••  ..'•   •  .'
    

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          3.  No transfer, sale, or lease of the- capacity assigned to any
     member agency of AWP4A by Condition'No. 2 shall be made  from one member
     agency of  AWHA to another member agency without the prior approval of
     the South .Coast Regional Coastal Zone Conservation Commission or its
     successor,  and in the event of no  such successor, such  approval shall
     be obtained from the SWRCB or its  successor.     . ;.•  '  ~:. ,: ;  ;   -    ••••••:
    
          4.  .The contracts between the AWMA and its member  agencies .shall
     contain  a  provision prohibiting any transfer, sale, or.  lease, in  . .-;":•.,
     violation  of the provisions of Condition No. 3. ;^;:^;-r•:;;/>;;:;' .,-.-..^-iV-Vy:
           5.   The land traversed by the facilities between  the  proposed AWMA
     Aliso Creek Regional Water Pollution Control Plant and  the: low tide line
     shall be  restored to substantially its present condition by the applicant
    . after construction. ''••• •:;•'• '••• •>/.'•'••;'•'•.•".,": T V^:•;.•/:;-:-.C;-^•/'•V;^-:^.Sw/:V-:;;^>;:'':^;jr^.::- •-';-:.-:
    
           6.   Vegetation, including trees, shrubs, and grasses,  in:the area
     considered-in Condition No. 5 that is removed or destroyed or otherwise
     substantially damaged during the construction of the facilities shall be
     replanted by the-applicant..''  • .-"  '.••  .;•'.':-...''/'.-.'. ..  '%:^ ^v..;-/^  .',:•:••.':'•:--.'].••".
    
           7.   The applicant shall design and construct the facilities in such.
     a manner  as not to significantly increase the rate of erosion or the area
    .considered in Condition- No-;- 5 or to create or increase  flood'control'.
    "problems  in Aliso Creek and its flood plain.   ':-;-;; ;/.V:V =;;":. •• •  . j\   • .   '
    
           8.   The applicant shall design and construct the facilities in a
     manner so as not to expose the facilities to damage from the waters of •'••'
     Aliso Creek. :: •.-.;-• v;v •:>•;<;;:, .-.••,•.•; ..•;•'.•• •'-•'- -.'/:•'--• •••••.•. -:X',;-:> .^;;•;-•;.'-'^•'.':^Ko;.^'::^/.;.-.,•; .'•,
    
           9.   At least 60 days prior to calling; for bids for construction of
     the facilities  and restoration of the area arter construction,  .the   V \  •
     applicant shall submit its detailed plans to the South  Coast Regional    '
     Coastal Zone Conservation Commission.  The Regional Commission shall, '•
     within 60 days  from receipt of the plans, determine whether  they are  : .  ;•
     adequate  to fullful Conditions 5, 6, 7,  and 8.  If the  Regional '    -•  .
     Commission has  not acted within 60 days after submission of  the plans,
     the applicant will be free to proceed with construction.   !       . . . :
    
           10.   The applicant shall accomplish the environmental mitigation
     measures  specified on pages 35 and 36 of the Aliso Water Management  •
     Agency Environmental Impact Report (Draft) dated September 1972 prior
     tOj during,  or  immediately following completion of construction of the
     facilities.   All such requirements,  including those listed in
     Conditions No.  5,  6, 7,  and 8,  shall be accomplished prior to the issuance
     of a  Certificate of Completion for the construction of  the facilities.
    
           11.   The applicant shall require that the contractor  av?arded tha
     contract  for the  construction  of the facilities shall provide  a  faithful
     performance  bond in  the amount  of 100 per cent of the  estimated
    amount of the contract price.       ^,7
    

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          The appellants  suggest  that the tnajcirnum capacity funded By grants
     also "be the maximum  design capacity of the outfalls.  Although  recognizing
     the impacts of population growth on air quality and on coastal  resource.
     the staff also recognizes that initial construction for an underestimated
     population capacity  would also increase the costs to the taxpayers  for •
     subsequently-needed  facilities, and for this reason the staff proposes  .
     that a population projection to the year 2000 and not 199^ be used,
    
          5.  Construction in the Bed of Aliso Creek,  Ordinarily, the staff
     would not recoosiend  construction of any major facility in a stream  bed
     because of the potential for adverse environmental impacts, particularly
     when detailed plans  have not been prepared.  But Aliso Creek is an
     intermittent stream  and a utility easement with a 27-inch outfall al-
     ready exists in the  creek.   And the recommended conditions require  that
     plans for.the proposed facility be approved by the South Coast
     Regional Commission  before construction, to insure that there will  be no
     significant adverse  environmental impacts.
    
     Recommended Permit Conditions for Appeal Number 29-73.
                       ' •  .   ' ••   '' '   -    .   " ' •    '   '•••'•";"'••" »   •   •  •  '.."•"
          1.  The facilities shall be constructed with only the capacity
     reasonably necessary to satisfy appropriate engineering standards,  and
     in no event shall such capacity be greater than that reasonably necessary
     to serve a permanent population derived from an E-0 population  projection
     to the year 2000 plus commercial and industrial needs for the area,
     seasonal population  increases, infiltration, and peak flows as  determined
     by the Statester Resources  Control  Board.  .
           •  •    f\       .  .           ' •'    .     '..  ,       •      -•'.•".
    
          2.  The maximum proportion of the total capacity of the facilities
     that can be used by  any of the member agencies of AWMA shall be determined
     by that .proportion of total  capacity assigned to that member agency in
    'Table I with, appropriate adjustments among the member agencies  for  the
     capacity necessary to service the respective seasonal populations,    .
     commercial and industrial needs,  infiltration,  and peak flows as
    , determined by the SWHCB pursuant to Condition No. 1.        .  .        .
    
    .. .  '•  '.:•'..  --.-    -..  •.:•••;.  Table I .  .-.  .       ';.''/:•  -.:•;' •' .'•-••   •    •  '.'•'  ,'•-•• ••,••".'..  ••  .
                      .:'.;-. .                 Capacity       .Proposition
                                      Average Flow (MGD)     of Total
     Agency   :         '••:              (Proposed by AWMA)     Capacity
    
     Santa Ana  Mountains  County  .              . .     ;
     Water District                        . 1.0               .028
    Los AliscsWster District               5.5                .154
    El Toro Water  District              .   5.5                [15^
    Noulton-Nlguel Water  District        12.9                .361
    South iaguna Sanitary District         3.2                ,090
    City of Laguna  Beach                   A.*l                .123
    Emsraid Bay Service District           0.2                .006
    Irvine  Ranch Water District           . 3.0	       .
                           Total           35.7              1.000
                                         D-a
    

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         12f  The applicant shall comply with all conditions established by
    the South .Coast Regional Coastal Zone Conservation Comm-is-slon att- its-
    meeting of April 16, 1973 for Permit No. 29-73.
    
         13. If the applicant does,not diligently commence construction of
    the facilities within 2 years of the date that the State Coastal
    Zone Conservation Comaission approves this permit, this permit shall
    automatically expire.                                   •   .
    
         14.  'This permit does not commit the Coastal Zone Conservation
    Commission to approving any other developments or to planning decisions
    based on population figures referred to herein.
                                       D-9
    

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                             CALIFORNIA COASTAL ZONE CONSERVATION COMMISSION         666 E. Ocean Blvd.
                                       SOUTH COAST REGION                   Long Beach, CA
    
    Robert F.Rconey.P*.D.. Chair™      '                                   Kail:  P.O. BOX lU50
    Ri^ell Rubley. Vice-chairman                                                  wng Beach, CA  QO
    James A. Hayes, Stata Representativs                                          (213)^36-^201
    II, J.  Carpenter, Executive Director    •                        (71^)8^6-061*8
    
    
    
                          RESOLUTION OF APPROVAL AND PERMIT
          Application Number:     P-4-17-73-779                •
    
          Name of Applicant:      Aliso Water Mangement Agency	
    
            27231 Aliso Creek  Rd.,  Laguna Niguel . 92677     	'__
    
    
          Permit  Type:   1 X j   Standard                       •        .
    
    
                          |   |   Administrative
    
    
                          |   j   Emergency
    
    
          Development Location:   Laguna Beach  and South Laguna,  Coast
    
            Highway and Aliso  Creek Road
    
    
                                                    *
    
          Development Description:    "North Coastal Interceptor Sewer"
          Commission Resolution:                             '
    
          I.  The  South Coast  Regional Coastal Zone Conservation  Commis-
              sion finds that  the proposed  development:
              A.   Uoddj/will not have a substantial adverse environmental
                   or ecological effect in  that:
    
                    it redirects sewage to  a new sewage treatment plant.
                                           D-10
    

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    B.  Is/±sanadx consistent with the findings and  declarations
        set forth in Public Resources Code Sections 27001,  and
      __ 27302 in that:                           ,
    
         it does not  hinder preservation of coastal  zone re-	
    
         sources -for  future planning purposes.	.	'
    C.  Is subject to the following other resultant  statutory
        provisions and policies:
    
         approvals  from the 'County of Orange, -the Water Quality
    
         Control  Board, Water Resources Control Board, SCAG, State
    
         Lands  Commissions, Corps of Engineers and The City of
    
         Laguna Beach	•      	 .'
    
    
    D.  IS/JCSXHB&.consistent with the aforesaid  other statutory
        provisions and policies in that:
    
         ':••.approvals have been grante'd  by all but  the  State Lands
    
         Commission and the Corps of Engineers.	.
        The following language and/or drawings  clarify and/or
        facilitate carrying out the intent of the  South Coast
        Regional Zone Conservation Commission:
    
          on file -with .the Regional  Commission.	
                              D-ll
    

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     II.  Whereas, at a public hearing held on      July 9,  1973
                                                      (date )
          at _ Long Beach
             •                      (location)  ~~
          by a _ 9     to 0 w/3 abs.  vote hereby appro ves/j
                                                            '
               _
          the application for Permit Number   ' F-4-17-7 3-779''    pursuant
          to the California Coastal Zone Conservation Act .'of 1972, sub-
          ject to .the '.following conditions imposed pursuant' to the
          Public Resources Code Section 27^03:
                                                       *                -
              that the applicant limit the capacity of the North _
    
              Coastal Interceptor Sewer necessary to serve an  estimated
    
          --   population of -37,100 in the year 2000 plus  commercial and
    
              industrial needs for the area,  seasonal population increases.
    
              infiltration, and peak flows as determined  by the State
    
              Water Resources Control Board.
    III.  Said terms and conditions shall be perpetual and bind all
          future owners and possessors of the property or any part
          thereof unless otherwise specified herein.
    
    
     IV.  Section 560 of the Regulations of the California Coastal Zone
          Conservation Commission specifies that no structure or area of
          land or water shall be used or occupied in the manner authorized
          by the permit or in any other manner until the Executive    .  .
          Director has issued a Certificate of Compliance with the terms
          and conditions of the permit.
    
    
      V.  The grant of this permit is further made subject to the fol-
          lowing:                          '
    
          A.  That this permit shall not become effective until the verifi-
              cation  has been returned to the South Coast Regional
              Conservation Commission upon which copy all permittees have
              acknowledged that they have received a copy of the permit
              and understood its contents.  Said acknowledgement should
              be returned within ten working days following issuance of
              this permit.
    
          B.,  That upon completion of the activity authorized by this
              permit the permittee(s) shall promptly complete the "Notice
              of Completion" and file it with the Executive Director of
              this Regional Commission.
                                   D-12
    

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          C.  That said development to be commenced on or before
    
              two. years after effective date -of approval
                                                        t •*
    
     VI.  Therefore, said Permit (Standard,
          Number     P-4-17-73-779 is hereby gratited/&sw±s3' for the above
          described development only, subject to the above conditions
          and subject to all terms and provisions of the Resolution of
          Approval by the South Coast Regional Conservation Commission.
    
    
    VII.  Executed at _ Long Beach •     .  , California on behalf of-
          the South Coast Regional Conservation Commission on
                  July 1?  , 197 3 _ .           -    .         - ---- '•
                                     M. J. Ci
                                     Executive Director
                                    D-13
    

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