Honorable Mayor and Members of the Hermosa Beach City Council Regular Meeting of October 9, 2018
Title
CONSIDERATION OF ALTERNATIVE LOCATIONS
FOR THE GREENBELT INFILTRATION PROJECT
(Environmental Analyst Kristy Morris)
Body
Recommended Action:
Recommendation
Staff recommends that the City Council consider the alternative sites in Hermosa Beach for the Greenbelt Infiltration Project (CIP 16-542) and select a location within its jurisdiction, or alternatively, provide direction to explore the feasibility of satisfying the EWMP requirement at a site located outside of the City’s jurisdiction, with the understanding that if none is reasonably available, staff will return for reconsideration of sites within the City.
Body
Background:
The Los Angeles Regional Water Quality Control Board (Regional Board) adopted the new Municipal Separate Storm Sewer System Permit (Permit) for the region on November 8, 2012. This permit, required under the federal Clean Water Act, regulates stormwater discharges from municipalities in Los Angeles County. The new Permit includes several new requirements as compared to previous permits. Among the most notable changes are three options for how agencies may choose to comply with the permit conditions. Agencies may follow an implementation plan similar to previous permits, but which also requires immediate compliance with some difficult water quality standards, or agencies may choose to develop an implementation program on a watershed basis-either individually or in collaboration with other agencies. A watershed-based approach allows agencies more time and flexibility in reaching compliance with the Permit.
A collaborative, watershed-based approach, referred to as an Enhanced Watershed Management Program (EWMP), identifies a network of control measures (referred to as best management practices (BMPs)) that will achieve the required pollutant reductions while also providing multiple benefits to the community using green infrastructure practices. The EWMP offers the added advantage of combining resources to finance and staff regional projects that satisfy the mandated water quality standards. If the City did not join the Beach Cities EWMP group, it would be solely responsible for the costs of complying with the water quality requirements of the Permit.
The cities of Hermosa Beach, Torrance, Redondo Beach, Manhattan Beach and the Los Angeles County Flood Control District have formed the Beach Cities Watershed Management Group to develop an EWMP to comply with the Board's 2012 Permit and compliance with Santa Monica Bay Beaches Bacteria (SMBBB) TMDL and Santa Monica Bay Toxics TMDL.
On November 26, 2013, Council approved the initial Memorandum of Understanding (MOU) with the Beach Cities Group to develop the EWMP and the Los Angeles Regional Board received the final Beach Cities EWMP on February 9, 2016. The Executive Officer of the Regional Board approved the EWWP via a letter dated April 18, 2016 and the letter directed cities to commence implementing the Beach Cities EWMP immediately, including all actions per associated schedules.
A timeline of critical decision points for the development, approval, and implementation of the EWMP is provided here:
February 26, 2013: City Council decides to proceed with developing an Enhanced Watershed Management Plan (EWMP) to comply with the 2012 Permit.
November 12, 2013: City Council approves an MOU between the Beach Cities agencies to develop the EWMP.
June 23, 2015: City Council authorizes the submission of the draft EWMP to the Los Angeles Regional Board and adopts Los Angeles County Program Environmental Impact Report and Corresponding Documentation.
September 19, 2016: City Council convenes a Study Session and receives an update on the programs and projects the City is undertaking to comply with the Storm Water Permit, including the Greenbelt Infiltration Project.
August 22, 2017: City Council approves an MOU between the Beach Cities Watershed Management Group for implementing the Joint Regional Projects within the EWMP and authorizes staff to submit the grant application for the Greenbelt Infiltration Project.
September 12, 2017: City Council awards a Professional Services Agreement to Tetra Tech, Inc. for Professional Engineering Design Services for the Greenbelt Infiltration Project.
June 19, 2018: City Council convenes a Study Session and receives an update on the Greenbelt Infiltration Project.
Selection of EWMP Best Management Practices
The EWMP identifies strategies and BMPs, that when implemented individually by jurisdictions, or collectively at a watershed scale, will address water quality concerns. Each jurisdiction is responsible for implementing its distributed projects that include public and private Low Impact Development (LID) projects, green streets, and programmatic BMPs such as the Clean Bay Restaurant Program, pet waste stations, bans on single-use plastics, and used oil recycling.
The Pier Avenue Streetscape Project and Hermosa Strand Infiltration Trench are examples of existing distributed projects that capture and infiltrate stormwater, resulting in significant improvements in beach water quality at the Pier Avenue storm drain. The Heal the Bay Report Card shows that this storm drain has improved from consistently receiving “F” grades to “A” grades during wet weather. The Pier Avenue Streetscape project provides multiple benefits including reduced flooding, widening of pedestrian walkways and safer crosswalks, economic revitalization, and water-saving landscaped medians.
Regional Projects are centralized projects located near the downstream ends of large drainage areas and receive large volumes of runoff from extensive upstream areas across multiple jurisdictions. Runoff is typically diverted to regional projects after it has entered the storm drain system and is routed to public parcels for infiltration, versus treating surface runoff near its source, as with green streets and LID. They are a cost-effective mechanism for infiltration and pollutant reduction because jurisdictions share the project costs.
The Herondo Drain outfall is the largest storm drain in the Beach Cities watershed area and typically receives an “F” grade during rain events on the Heal the Bay Beach Report Card due to high bacteria levels, resulting in beach postings. The process for selecting regional project sites to address these water quality issues at the Herondo Drain outfall are as outlined below. In order to comply with the Permit Requirements and water quality standards, a regional project must be installed and operative by 2021.
Hermosa Beach Greenbelt Infiltration Project
A GIS-based modelling tool (SBPAT) approved by the Regional Board, assessed various combinations of potential project sites and predicted the water quality results for the Beach Cities watershed management area. The model considered numerous BMP scenarios and the final strategies presented in the EWMP were selected based on the most cost-effective scenarios that responded to critical water quality priorities to comply with the Permit.
When identifying potential regional project sites, prioritization was given to factors of the Structural BMP Prioritization and Analysis tool (SBPAT), one of the two GIS modelling (2) tools approved by the Regional Board for the BMP siting and Reasonable Assurance Analysis (RAA). RAA determines if the set of BMPs in the EWMP can achieve the water quality requirements.
The prioritization factors are as follows:
1. minimum parcel size of 0.1 acres;
2. within 500 feet of the storm drain;
3. City- or County-owned undeveloped parcels;
4. other publicly-owned undeveloped parcels such as on-grade parking lots; and
5. private commercial or industrial undeveloped parcels acknowledging that the cost and process for acquiring a privately-owned parcel could be quite challenging, but not out of the question.
Site selection modelling was a technical exercise aimed at achieving the required capture and water quality results-as a technical exercise, it did not consider the proximity of the project to high-density residential dwelling units and potential community impacts during and following construction.
Figure 1 shows the output of priority catchments for placement of regional (red) and distributed (blue) projects in the Herondo Drain watershed area. The Torrance Basins Enhancement Regional Project was constructed by the City of Torrance to address significant portions of the red and some of the blue areas south of 190th Street in Torrance.
Figure 1. Priority catchments for Regional (Red) and Distributed (Blue) projects in the Beach Cities Watershed Management Area.
This process identified three (3) regional project sites in the Herondo Drain Watershed that, when implemented collectively and with the Torrance Basins Enhancement Regional Project and distributed BMPs, will meet the mandated reductions in fecal indicator bacteria:
• Hermosa Greenbelt Infiltration Project (543.7 acre-feet treatment volume)
• Redondo Beach Park # 3 (47.3 acre-feet treatment volume)
• Beach Infiltration Trench (33.3 acre-feet treatment volume)
The Hermosa Greenbelt Infiltration Project is the highest priority project that will achieve the greatest reduction in bacterial levels, similar to that achieved by the Torrance Basins, and meeting the Permit requirements. The Southern California Edison (SCE)-owned property to the south of the greenbelt location in Redondo Beach was identified as an alternative site, however, this is a private parcel and permission to implement a regional project at this location was not granted by SCE during this process.
Following the City Council and Regional Board’s approval of the EWMP in 2016, the City of Hermosa Beach, in partnership with the other Beach Cities EWMP parties, submitted a successful application to the State Water Resources Control Board (State Board) for funding for the design and construction of the Hermosa Beach Greenbelt Infiltration Project. The awarded Prop 1 Stormwater Implementation Grant amount of $3,099,400 represents approximately one half of the estimated total project cost, and as such, the balance of the total project cost must be provided as local matching funds.
The City executed a grant agreement with the State Board to accept the grant and to serve as the lead agency for the design and construction of the project with the other partners contributing a proportionate share of the local matching funds.
The total project budget is $7,336,180 and the cost sharing formula is based on each jurisdiction’s contributing tributary area to the project after subtracting the treatment capacity of the City of Torrance Basin Enhancement Project. The City of Hermosa Beach’s share for design costs is $115,550.50 (13.6%) and the current estimate for the City of Hermosa Beach share of construction costs is $460,651.59, for a total project budget of $576,202.09. Redondo Beach, Torrance, and Manhattan Beach will contribute 50.8%, 33.1% and 2.5% of the design and construction costs, respectively.
At the September 12, 2017 meeting, City Council awarded a professional services agreement to Tetra Tech, Inc. for the design of the Hermosa Beach Greenbelt Infiltration Project. A competitive process that included representatives from each of the Beach Cities selected Tetra Tech as the most qualified team based on qualifications and references, experience with similar projects, and the cost proposal.
The Tetra Tech scope of work and schedule (Table 1) includes site-specific studies, developing preliminary designs, community outreach, CEQA analysis and permitting, and construction bidding and support as needed. The scope of work includes producing alternative project designs and developing the preferred design through to a full construction document set.
Community Engagement
In accordance with the scope of work and schedule, Tetra Tech commenced site surveys at the Hermosa Beach greenbelt and developed preliminary designs that were presented at community workshops held on March 29, 2018 and May 10, 2018. City Council convened a special study session on June 19, 2018 to discuss the project background, site selection process and California Environmental Quality Act requirements for the proposed project. Since this was a study session, City Council took no formal actions at this meeting and received public comment following the presentations. Presentations are available on a link through the project page on the City’s website (Attachment 1).
Based on the proximity of the project to residential dwelling units and the potential construction and post-construction impacts, staff is providing an analysis of alternative project sites located in Hermosa Beach. Approximately 720 residential units are within 500 feet of the existing project site, primarily in the large apartment complexes Playa Pacifica and The Gallery, and the Moorings and Beachside condominiums. Approximately 17 dwelling units in the Moorings condominiums directly overlook the project site. In a letter dated July 12, the Moorings Homeowners Association group presented additional sites located in Redondo Beach for consideration. Since these sites are not within the City’s jurisdiction, they are not included in this analysis; however, known site considerations are presented in this reported.
Analysis:
The analysis addresses alternative locations to the Hermosa Greenbelt to meet the mandated water quality priorities at the Herondo Drain outfall. Factors not included in the EWMP site-selection process, including the proximity of the site to residential units, and construction and operational impacts are discussed.
At the June 19 Special Study Session, Tetra Tech presented the following four (4) site alternatives for the Hermosa Beach Greenbelt Infiltration project (Attachment 2):
1) Hermosa Greenbelt between Herondo Street and 2nd Street (existing location)
2) Greenbelt North of 2nd Street
3) Herondo Street at Valley Drive
4) South Park, 425 Valley Drive
Potent benefits of selecting an alternative location in Hermosa Beach include: 1) the ability to retain the grant funding, 2) greater likelihood to be approved by the Regional Board as a timely amendment to the EWMP, and 3) ability to comply with the 2021 operative project completion schedule. The regional project must be operative by 2021 to maintain the compliance schedule. Locations outside of the City will take longer to model the water quality benefits and to be approved by each of the other Beach Cities agencies as well as the Regional Board. The longer this process takes, the greater risk of all beach cities being out of compliance with the permit, creating potential legal vulnerability for all beach cities.
The following considerations apply to all of the alternative sites:
• Site-specific geotechnical surveys and utility investigations have not been performed for these sites.
• The sites are not in liquefaction zones (Attachment 3), however, due to their close proximity to liquefaction zones, all projects need to address the assumed risk.
• Gravity flow to the system (versus pumping) was evaluated, however this is not the preferred conveyance option due to the depth of the storm drain in Herondo Street and groundwater elevation. Therefore, all of the sites require a pump to lift water from the Herondo Drain into the infiltration system which will require a small above-ground enclosure for the electrical equipment.
• All sites capture episodic stormwater, primarily during winter months and are dry for the remainder of the year. An operations and maintenance manual approved by the Greater Los Angeles County Vector Control District is required to ensure the long-term operational efficiency of the system and to protect public health.
Greenbelt North of 2nd Street
The site is located underneath the greenbelt, directly north of 2nd Street and extending for approximately 1,200 feet through to 6th Street (Attachment 4). There are approximately 175 residential dwelling within 500 feet of the project site that could be impacted by construction, and future operation and maintenance activities. A number of condominiums on 2nd Street directly overlook the project site.
The location has sufficient capacity to capture the required volume of stormwater and would be confined to the width of the wood-chip walking path on greenbelt to limit tree removal. The resulting design is narrow and irregularly shaped and would likely require shoring (i.e. pile-driving) that will increase the construction costs and schedule compared to the existing location.
Construction would be enclosed behind construction fencing for the duration of construction and potential impacts could include restricted access to this portion of the greenbelt and the removal of trees and shrubs that would be replanted upon completion of construction activities.
Construction cost estimates are approximately $3.8M higher compared to the existing greenbelt location.
Herondo Street at Valley Drive
This project is located beneath Herondo Street at the intersection with Valley Drive and extends east towards Pacific Coast Highway (Attachment 5). The approximately 720 residential units within 500ft of the existing project site will experience similar impacts to the existing site with additional widespread traffic impacts resulting from road closures.
This location could potentially provide the desired capture volume, however the most significant considerations are the design challenges and additional cost associated with the deep excavation and demolition and construction of the center landscape median that was constructed in 2015 as part of the Harbor Drive/Herondo Street Gateway Improvement Project. The storm drain is flat in comparison to the roadway that slopes steeply therefore increasing the depth from the road surface to the storm drain.
Numerous existing utilities that would need to be removed and replaced, or navigated, including storm drains, sewers, and recycled water. Local traffic and residents will be significantly disrupted during construction as a result of lane/road closures associated with the deep excavation, pile-driving and shoring. Construction cost estimates for this location are estimated to exceed $10M.
South Park
South Park is located 1000 feet north of the existing site at 425 Valley Drive. Park amenities include restroom facilities, a turf field and playground, picnic tables, and classrooms. Renovations to the northern perimeter of the park were completed in 2016 and include the installation of a universally accessible playground and a community garden. There are approximately 200 residential dwelling within 500 feet of the project site that could be potentially impacted by construction activities.
The alternative project is located beneath a portion of the turf field within the existing pathway (Attachment 6). The publicly-owned parcel is sufficient in size to design a system to meet the required water quality priorities for the Permit. Many municipalities place large infiltration projects beneath turf fields in public parks because they are large, regularly shaped, undeveloped publicly-owned parcels that can accommodate this technology. It is a common practice to install infiltration in parks. These factors reduce the construction cost and timeline, and provide an opportunity to enhance park amenities such as picnic shelters, irrigation and landscaping. Examples of similar projects in local parks include the Santa Monica Los Amigos Park Stormwater Demonstration Project (Attachment 7), Los Angeles County Parks Stormwater Infiltration Projects (Attachment 8), and City of Los Angeles Garvanza Park Rainwater Capture Project (Attachment 9).
Construction is estimated to take 12 months and the uniformly shaped system is relatively simple to excavate compared to the other site alternatives. Excavation at this site would not require shoring (i.e. pile-driving), reducing the noise and vibrations during construction. Construction would be enclosed behind construction fencing and the field would be closed for the duration of the construction. All other park amenities, including the playground and community garden, would operate at full capacity during construction. Depending on the staging location and other construction activities, potential impacts could include restricted access to a portion of the sidewalk and parking lot, and the relocation of furniture, lighting and vegetation. Following construction, the park could be enhanced to include many unfinished elements of the South Park Master Plan.
The diversion pipeline from Herondo Drain would be through a conveyance pipe under the greenbelt. The construction of the diversion pipeline would most likely consist of conventional trenching with temporary hydraulic shoring devices. Pile-driving is not expected for pipeline installation. The actuated valve, pretreatment device and possibly the pump station would be located below the Greenbelt. This is the lowest-cost alternative to the current location (+/- ~$865,000) based on construction cost estimates using Caltrans historical cost data, recent bid results, and RSMeans cost data.
Redondo Beach Site Considerations
In addition to the alternative locations in Hermosa Beach, information is provided below on locations presented by the Moorings HOA group in the letter dated July 12 (Attachment 10):
• Dominguez Park, Redondo Beach
• Underneath N. Francisca Street, Redondo Beach
• N. Harbor Drive at Strand Parking Lot/Park, Redondo Beach
• AES Property as part of wetland restoration, Redondo Beach
• SCE-owned Lot east of AES, Redondo Beach
• Beach at outfall Retention/Recycling
Staff met with City of Redondo Beach staff to notify them that alternative sites within their jurisdiction were presented, and to obtain available site information. A summary of the site ownership, a history of site activities, and recorded site contamination is provided below.
The process for selecting a site outside of Hermosa Beach is not known and delaying this process places all of the beach cities at greater of being out of compliance with the permit, creating potential legal vulnerability for all beach cities.
Dominguez Park, Redondo Beach
Dominguez Park is located at 200 Flagler Lane, Redondo Beach and is owned by the City of Redondo Beach. From 1904 to 1932, the site was operated as a sewage farm and from 1932 to 1959 the site was operated as the City of Redondo Beach Municipal Dump. For a period, the site was open for public dumping and was closed to the public in 1959, however city dumping continued until 1967. A one-foot thick layer of interim cover was to be placed at the end of each day following daily fill operations. The final cover ranged from less than one foot to 10 feet. The average depth of the fill is 40 - 45 feet with depths up to 70 feet.
Furthermore, the invert elevation of the existing storm drain along 190th Street is approximately 34 - 35 feet and the existing ground elevation of Dominguez Park ranges from 130 - 150 feet. Therefore, the storm drain is located about 100 feet lower than existing ground elevation.
Former landfill sites and sites with slopes greater than 20% are deemed infeasible for infiltration, unless extensive and expensive site remediation is undertaken.
Underneath N. Francisca Street, Redondo Beach
North Francisca Street is located directly south of Valley Drive at Herondo Street. The City of Redondo Beach owns the street that is approximately 30 feet wide at its narrowest. A system designed to capture the same volume of water as the Hermosa Beach Greenbelt Project will need to occupy the full width of North Francisca Street from Herondo Street to North Catalina Avenue (assuming a 10-footdeep infiltration gallery, that groundwater is deeper than the groundwater at the Greenbelt, and approximately 1,250 feet is available). Numerous utilities run both parallel and perpendicular throughout the site and the feasibility of relocating these utilities would need to be determined.
The site borders the AES property that is listed on the Department of Toxic Substances Control (DTSC) database as an active cleanup site with chemicals of concern (COC’s) detected in soils and groundwater. Soil and groundwater monitoring for the presence of subsurface contamination is required at this location to further determine the feasibility for infiltration.
North Harbor Drive at Strand Parking Lot/Park, Redondo Beach
This location is identified as one of the three (3) regional projects in the Beach Cities EWMP to operate in conjunction with the beach infiltration location in Hermosa Beach and the Hermosa Beach Greenbelt Infiltration Project. The project is modelled to capture 33.3 acre-feet treatment volume which is 6% of the volume treated by the Hermosa Beach Greenbelt project. The project will receive stormwater downstream of the Hermosa Beach Greenbelt project and the feasibility of expanding this system is limited by the shallow water table and future sea level rise impacts that were outlined in the Assessment of Infrastructure Vulnerability to Sea-Level Rise Report (Geosyntec, 2016).
AES Property as part of wetland restoration, Redondo Beach
The property is located on the southwest border of Hermosa Beach and is currently owned by AES. AES is currently marketing the site for sale to a private developer and is requesting that all utility structures be removed from the property at this time, including the SCE switching station. AES has stated verbally and through written communications (Attachment 11) that they will not allow the project on this property at this time.
The Department of Toxic Substances Control (DTSC) database lists the property as an active cleanup site with chemicals of concern (COC’s) present in soils at various locations throughout the site. Groundwater monitoring and soil sampling for the presence of subsurface contamination is required to further determine the feasibility for infiltration.
The restoration of approximately 6-acres of wetlands is likely to occur onsite following a sale and decommissioning of the station in 2020. This will provide additional water quality benefits in the future and could provide approximately 1.5-acre feet of additional storage capacity.
SCE-owned Lot east of AES, Redondo Beach
SCE will not allow infiltration projects on its property or easements and have stated verbally and through written communications that they will not allow the project on their property (Attachment 12).
Beach at Outfall Retention/Recycling
The proposed project is an above-ground retention and recycling facility located on the beach at the outfall. This is the most costly option for treating episodic bacteria in stormwater, primarily during winter months and will be mostly dry for the remainder of the year. For reference, the Santa Monica facility treats an average of 500,000 gallons per day (gpd) of urban runoff year-round that consist of dry weather runoff and small volumes of stormwater flows. A purple-pipe recycled water system would need to be constructed to convey the captured, treated water from the system to the existing recycled water line underneath the greenbelt.
Important Considerations for Selecting an Alternative Location
Relocating the site will require an amendment to Tetra Tech’s scope of work and budget to include additional site-specific analysis including geotechnical surveys. The estimated cost for this work is $50,000.
At the meeting on June 19, the City Manager announced that a project Environmental Impact Report (EIR) would be required for the project. The additional cost for preparing this report is estimated at $130,000.
Staff met with the State Board Prop 1 Grant Manager to discuss the ability to retain the grant funding if the project is relocated to an alternative site. State Board staff expressed that if an alternative project location is identified that achieves equal or greater water quality benefits, and equal native vegetation plantings, the City could direct the current grant funding towards this project or risk losing the funding if a suitable site is not identified.
Staff met with Regional Board staff to provide a project update and discuss potential consequences for the Beach Cities agencies not complying with the Permit and timelines outlined in the EWMP. Part VI.A.13 (a-h) of the Permit (Pages 41-43)
describes enforcement actions and penalties for non-compliance (Attachment 13). The California Water Code provides that any person who violates a waste discharge requirement or a provision of the California Water Code is subject to civil penalties of up to $5,000 per day, $10,000 per day, or $25,000 per day of violation, or when the violation involves the discharge of pollutants, is subject to civil penalties of up to $10 per gallon per day or $25 per gallon per day of violation; or some combination thereof, depending on the violation, or upon the combination of violations.
With the approved EWMP, the City is presently deemed in compliance with the permit and upcoming water quality deadlines contained therein. Should Council decide to relocate the project, it should be done fairly quickly to ensure all of the Beach Cities agencies can comply with the 2021 Permit deadlines.
General Plan Consistency:
The relevant PLAN Hermosa (City’s General Plan) policy(s) are listed below.
1.8 Reduce stormwater runoff. Reduce stormwater runoff consistent with local stormwater permits.
4.3 Collaboration with adjacent jurisdictions. Maintain strong collaborative relationships with adjacent jurisdictions and work together on projects of mutual interest and concern.
4.8 Holistic systems planning. Develop a comprehensive approach to water infrastructure that integrates sewer system planning with potable and recycled water systems, stormwater systems, and increased conservation awareness.
5.7 Stormwater permits. Strictly implement, enforce, and monitor MS4 National Pollutant Discharge Elimination Systems (NPDES) Permit requirements through stormwater ordinances.
Fiscal Impact:
This project budget total is $7,336,180 and the costs are distributed among the Beach Cities agencies based on a cost-sharing formula outlined in the MOU for project design. The cost-sharing formula is based on capture responsibility for the tributary area to the project after subtracting the treatment capacity of the City of Torrance Stormwater Basin Enhancement Project. The City of Hermosa Beach’s share for design costs is $115,550.50 (13.6%) and the current estimate for the City of Hermosa Beach share of construction costs is $460,651.59, for a total project budget of $576,202.09.
Relocating the site to another site within the City would require an amendment to Tetra Tech’s scope of work and budget and is estimated to cost an additional $50,000. The additional cost for preparing the project environmental impact report is estimated at $130, 0000. These cost increases would need to be approved by each of the Beach Cities agencies through an amendment to the MOU for the cost sharing for project design.
Attachments:
1. Link to Project Page on City Website
2. Tetra Tech Presentation (June 19, 2018)
3. Link to Earthquake Zones of Required Investigation Map
4. Greenbelt North of 2nd Street
5. Herondo Street at Valley Drive
6. South Park
7. Link to Santa Monica Los Amigos Park Stormwater Demonstration Project
8. Link to Los Angeles County Parks Stormwater Infiltration Projects
9. Link to City of Los Angeles Garvanza Park Rainwater Capture Project
10. Letter from Moorings HOA
11. Letter from AES regarding site use
12. Letter from SCE regarding site use
13. Link to Permit (Enforcement Actions and Penalties for Non-Compliance on pages 41-43)
Respectfully Submitted by: Kristy Morris, Environmental Analyst
Noted for Fiscal Impact: Viki Copeland, Finance Director
Legal Review: Mike Jenkins, City Attorney
Approved: Suja Lowenthal, City Manager