Willow Creek Community Services DistrictDowntown Wastewater Development Project

Final Environmental Impact ReportState Clearinghouse #2015012014

September 2015

Downtown Wastewater Development Project

Final Environmental Impact Report State Clearinghouse #2015012014

Prepared for:

P.O. Box 8 Willow Creek, CA 95573

Attention: Lonnie Danel

General Manager (530) 629-2136

Prepared by:

718 Third Street Eureka, CA 95501

Contact: Pat Kaspari

Project Manager (707) 443-8326

September 2015

Project Ref#: 12057-8410746

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Table of Contents

GHD | Willow Creek Community Services District - Downtown Wastewater Development Project Final EIR | i

Table of Contents

Acronyms and Abbreviations ..................................................................................... iii 

1.  Introduction ..................................................................................................... 1-1 

1.1  Purpose of the Final Environmental Impact Report ........................................................ 1-1 

1.2  Environmental Review Process ...................................................................................... 1-1 

1.3  Document Organization .................................................................................................. 1-1 

2.  List of Commenters ......................................................................................... 2-1 

2.1  Comments Received ...................................................................................................... 2-1 

3.  Comments and Responses ............................................................................. 3-1 

3.1  Written Comments and Response to Individual Comments ........................................... 3-1 

Letter A – State Water Resources Control Board Letter .......................................................... 3-2 

Letter A – State Water Resources Control Board – Response to Comments ........................ 3-11 

Letter B – California Department of Transportation – Letter................................................... 3-14 

Letter B – California Department of Transportation – Response to Comments ..................... 3-15 

Letter C – California Department of Fish and Wildlife Letter .................................................. 3-16 

Letter C – California Department of Fish and Wildlife – Response to Comments.................. 3-19 

4.  Revisions to the Draft EIR ............................................................................... 4-1 

5.  References ..................................................................................................... 5-1 

Tables

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2-1 Comments Received ............................................................................... 2-1

Table of Contents

ii | Willow Creek Community Services District - Downtown Wastewater Development Project Final EIR | GHD

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Acronyms and Abbreviations

GHD | Willow Creek Community Services District - Downtown Wastewater Development Project Final EIR | iii

Acronyms and Abbreviations

EOC County Emergency Operations Center EOP Humboldt County Emergency Operations Plan EPA Environmental Protection Agency ESA Federal Endangered Species Act Fed/OSHA Federal Occupational Safety and Health Administration FEMA Federal Emergency Management Agency FMMP Farmland Mapping and Monitoring Program FPD Fire Protection District ft/sec feet per second g gravity GHG Greenhouse Gas gpd gallons per day gpm gallons per minute HAZWOPER Hazardous Waste Operations and Emergency Response HCAOG Humboldt County Association of Governments HCDEH Humboldt County Division of Environmental Health HDD horizontal directional drilling HDPE high-density polyethylene HP horsepower H2O water vapor K-t NeT Klamath Trinity Non-Emergency Transportation kWh kilowatt-hours Ldn Day/Night Average Sound Level Leq equivalent noise level Lmax maximum A-weighted noise level Lmin minimum A-weighted noise level LOP Local Oversight Program LOS Level of Service MAR marine MBR membrane bioreactors MBTA Migratory Bird Treaty Act MGD million gallons per day MG/L Milligrams Per Liter ml milliliter MMT million metric tons MtBE methyl tertiary butyl ether MUN municipal supply NAAQS National Ambient Air Quality Standards NAHC Native American Heritage Commission NCRWQCB North Coast Regional Water Quality Control Board NCUAQMD North Coast Unified Air Quality Management District NFIP National Flood Insurance Program NHPA National Historic Preservation Act

Acronyms and Abbreviations

iv | Willow Creek Community Services District - Downtown Wastewater Development Project Final EIR | GHD

N2O nitrous oxide NOP Notice of Preparation NOX nitrogen oxides NO2 nitrogen dioxide NPDES National Pollutant Discharge Elimination System NRHP National Register of Historic Places NSR New Source Review NTU nephelometric turbidity unit OB optical brighteners OES Office of Emergency Services OMR Office of Mine Reclamation OWTS onsite wastewater treatment systems O3 ozone PAHs polycyclic aromatic hydrocarbons PGA peak ground acceleration PG&E Pacific Gas & Electric PM particulate matter PM10 particulate matter 10 microns or less in diameter PM2.5 particulate matter 2.5 microns or less in diameter Ppm parts per million PPV Peak Particle Velocity PRC Public Resources Code PS-1 pump station 1 PSD Prevention of Significant Deterioration RGF recirculating gravel filter RMS Root Mean Square ROG reactive organic gases ROW right of way RTPA Regional Transportation Planning Agency RWD Report of Waste Discharge RWQCB Regional Water Quality Control Board SAA Stream Alteration Agreement SAL saline SARA Superfund Amendment and Reauthorization Act SBR sequencing batch reactor SF square feet SMARA Surface Mining and Reclamation Act SMGB California Department of Conservation State Mining and Geology Board SRA State Responsibility Areas STED septic treatment effluent discharge STEP septic tank effluent pumping SWPPP Storm Water Pollution Prevention Plan SWRCB State Water Resources Control Board TACs Toxic Air Contaminants TDH total dynamic head TMDLs total maximum daily loads

Acronyms and Abbreviations

GHD | Willow Creek Community Services District - Downtown Wastewater Development Project Final EIR | v

TPZ Timberland Production Zone TSS total suspended solids TVES Trinity Valley Elementary School UBC Uniform Building Code µg/m3 micrograms per cubic meter USACE U.S. Army Corps of Engineers USA North Underground Service Alert North U.S. EPA U.S. Environmental Protection Agency USFWS U.S. Fish and Wildlife Service UST underground storage tank WCCSD Willow Creek Community Services District WDP Waste Discharge Permit WDR Waste Discharge Requirements Willow Creek CAP Willow Creek Community Action Plan

Acronyms and Abbreviations

vi | Willow Creek Community Services District - Downtown Wastewater Development Project Final EIR | GHD

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Introduction

GHD | Willow Creek Community Services District - Downtown Wastewater Development Project Final EIR | 1-1

1. Introduction

1.1 Purpose of the Final Environmental Impact Report

This document provides responses to comments received on the 2015 Draft Environmental Impact Report

(DEIR) for the proposed Downtown Wastewater Development Project (“project”), and includes necessary

revisions to the text and analysis in the DEIR. The DEIR identified the likely environmental consequences

associated with the project, and recommended mitigation measures to reduce potentially significant

impacts.

This document, together with the DEIR, constitutes the Final EIR (FEIR) for the project and will be

considered by the Willow Creek Community Services District (WCCSD) for certification under the

California Environmental Quality Act (CEQA).

1.2 Environmental Review Process

CEQA requires lead agencies to consult with public agencies having jurisdiction over a proposed project,

and to provide the general public and project applicant with an opportunity to comment on the DEIR. This

FEIR has been prepared to respond to the significant environmental points raised in the written comments

received on the DEIR, to make modifications to the DEIR and to clarify some of the findings in the DEIR.

The DEIR was made available for public review on June 15, 2015, at the following locations: 1) WCCSD

office, 135 Willow Road, Willow Creek, CA 95573; 2) WCCSD website at: http://willowcreekcsd.com/. The

DEIR was distributed to local and State responsible and trustee agencies and the general public was

advised of the availability of the DEIR by posting of a public notice in the local newspaper. A public notice

was also posted by the County Clerk as required by law. A public hearing to receive comments on the

DEIR was held by the WCCSD on June 25, 2015. The 45-day public comment period closed on July 29,

2015 at 5 p.m.

Copies of all written comments received on the DEIR are contained in this document (Section 3).

Responses to each comment follow the comment letter.

This document will be provided to the WCCSD Board of Directors, together with the DEIR, for their review

prior to their consideration of resolutions certifying the EIR as a full disclosure of potential impacts,

mitigation measures and alternatives, and approving the project. If the project is approved, recommended

mitigation measures will be adopted and implemented as specified in the resolutions and an

accompanying mitigation monitoring and reporting program unless the Board find the measures infeasible

as specified in CEQA Guidelines Section 15091 (Findings).

1.3 Document Organization

This document is organized into the following chapters:

Chapter 1 – Introduction. This chapter discusses the use and organization of this document, and

summarizes the environmental review process to date for the project.

Chapter 2 – List of Commenters. This chapter includes the names of agencies and individuals who

commented on the DEIR.

Introduction

1-2 | Willow Creek Community Services District - Downtown Wastewater Development Project Final EIR | GHD

Chapter 3 – Comments and Responses. This chapter reproduces all of the written comments received on

the DEIR from public agencies and members of the public and provides responses to those comments.

Chapter 4 – Revisions to the Draft EIR. This chapter includes revisions to the Draft EIR.

Chapter 5 – References. This chapter includes new references that were used in preparation of the FEIR.

List of Commenters

GHD | Willow Creek Community Services District - Downtown Wastewater Development Project Final EIR | 2-1

2. List of Commenters

2.1 Comments Received

During the 45-day public comment period, the WCCSD received three written comments on the Draft EIR.

A list of the comment letters received, including the names and affiliations of the commenters, is shown

below in Table 2-1. The written comments that were received are coded alphabetically.

Table 2-1 Comments Received

Letter Agency/Organization Last

Name First Name

Letter/Email Date

Written Comments Received

A State Water Resources Control Board Dwyer Amanda July 3, 2015

B California Department of Transportation Schofield Jesse July 27, 2015

C California Department of Fish and Wildlife Babcock Curt July 20, 2015

Comments and Responses

3-1 | Willow Creek Community Services District - Downtown Wastewater Development Project Final EIR | GHD

3. Comments and Responses

3.1 Written Comments and Response to Individual Comments

This section includes responses to specific comments received during the comment period. Included are

copies of the written comments received by the WCCSD through July 29, 2015. Comment letters are

labeled “A” through “C,” and each comment within each letter is coded (e.g., Response A-1 is in response

to comment letter A, comment 1). Responses to each comment follow the comment letter, with the

response and number corresponding with the comment letter and number. Comments which do not raise

environmental issues or comment on the adequacy of the DEIR, but merely provide information or

general support for/opposition to the project, will receive “comment noted” in the response.

Water Boards

State Water Resources Control Board

JUL 0 3 2015 Lonnie Danel Willow Creek Community Services District P.O. Box 135 Willow Creek, CA 95573

Dear Mr. Danel:

0 E DMUND G. B ROWN J R. GOVERNOR

'

N~ M ATTHEW R ODRIQU EZ l ............... ~ SECRET ARY FOR ~ ENVIRONMENTAL PROTECTION

ENVIRONMENTAL IMPACT REPORT (EIR) FOR WILLOW CREEK COMMUNITY SERVICES DISTRICT (DISTRICT); DOWNTOWN WASTEWATER SYSTEM DEVELOPMENT PROJECT (PROJECT); HUMBOLDT COUNTY; STATE CLEARINGHOUSE NO. 2015012014

We understand that the District may be pursuing Clean Water State Revolving Fund (CWSRF) financing for this Project. As a funding agency and a state agency with jurisdiction by law to preserve, enhance, and restore the quality of California's water resources, the State Water Resources Control Board (State Water Board) is providing the following information and comments for the environmental document prepared for the Project

The State Water Board , Division of Financial Assistance, is responsible for administering the CWSRF Program. The primary purpose for the CWSRF Program is to implement the Clean Water Act and various state laws by providing financial assistance for wastewater treatment facilities necessary to prevent water pollution, recycle water, correct nonpoint source and storm drainage pollution problems, provide for estuary enhancement, and thereby protect and promote health , safety and welfare of the inhabitants of the state. The CWSRF Program provides low-interest funding equal to one-half of the most recent State General Obligation Bond Rates with a 30-year term. Applications are accepted and processed continuously. Please refer to the State Water Board's CWSRF website at: www.waterboards.ca.gov/water issues/programs/grants loans/srf/index.shtml .

The CWSRF Program is partially funded by the United States Environmental Protection Agency and requires additional "CEQA-Plus" environmental documentation and review. Three enclosures are included that further explain the CWSRF Program environmental review process and the additional federal requirements. For the complete environmental application package please visit: http://www.waterboards.ca.gov/water issues/programs/grants loans/srf/srf forms.shtml. The State Water Board is required to consult directly with agencies responsible for implementing federal environmental laws and regulations. Any environmental issues raised by federal agencies or their representatives will need to be resolved prior to State Water Board approval of a CWSRF financing commitment for the proposed Project. For further information on the CWSRF Program, please contact Mr. Ahmad Kashkoli, at (916) 341-5855.

It is important to note that prior to a CWSRF financing commitment, projects are subject to provisions of the Federal Endangered Species Act (ESA), and must obtain Section 7 clearance from the United States Department of the Interior, Fish and Wildlife Service (USFWS), and/or the United States Department of Commerce National Oceanic and Atmospheric Administration , National Marine Fisheries Service (NMFS) for any potential effects to special status species.

F ELICIA M ARCUS, CHAIR I T HOMAS H OWARD , EXECUTIVE DIRECTOR

1001 I Street, Sacramento , CA 95814 I Mailing Address: P.O. Box 100, Sacramento , Ca 95812-01 00 I www.waterboards .ca.gov

n REC YCLED PAPER

2

Please be advised that the State Water Board will consult with the USFWS, and/or the NMFS regarding all federal special-status species that the Project has the potential to impact if the Project is to be financed by the CWSRF Program. The District will need to identify whether the Project will involve any direct effects from construction activities, or indirect effects such as growth inducement, that may affect federally listed threatened , endangered , or candidate species that are known, or have a potential to occur in the Project site, in the surrounding areas, or in the service area, and to identify applicable conservation measures to reduce such effects.

In addition , CWSRF projects must comply with federal laws pertaining to cultural resources, specifically Section 106 of the National Historic Preservation Act (Section 106). The State Water Board has responsibility for ensuring compliance with Section 106 and the State Water Board must consult directly with the California State Historic Preservation Officer (SHPO). SHPO consultation is initiated when sufficient information is provided by the CWSRF applicant. The District must retain a consultant that meets the Secretary of the Interior's Professional Qualifications Standards (http://www.nps.gov/history/local-law/arch stnds 9.htm) to prepare a Section 106 compliance report.

Note that the District will need to identify the Area of Potential Effects (APE) , including construction and staging areas, and the depth of any excavation . The APE is three-dimensional and includes all areas that may be affected by the Project. The APE includes the surface area and extends below ground to the depth of any Project excavations. The records search request should extend to a ~-mile beyond Project APE. The appropriate area varies for different projects but should be drawn large enough to provide information on what types of sites may exist in the vicinity.

Other federal environmental requirements pertinent to the Project under the CWSRF Program include the following (for a complete list of all environmental requirements please visit: http://www.waterboards.ca.gov/water issues/programs/grants loans/srf/docs/forms/application environ mental package.pdf) :

A. Compliance with the Federal Clean Air Act: (a) Provide air quality studies that may have been done for the Project; and (b) if the Project is in a nonattainment area or attainment area subject to a maintenance plan ; (i) provide a summary of the estimated emissions (in tons per year) that are expected from both the construction and operation of the Project for each federal criteria pollutant in a non attainment or maintenance area, and indicate if the nonattainment designation is moderate, serious, or severe (if applicable) ; (ii) if emissions are above the federal de minimis levels, but the Project is sized to meet only the needs of current population projections that are used in the approved State Implementation Plan for air quality, quantitatively indicate how the proposed capacity increase was calculated using population projections.

B. Compliance with the Coastal Zone Management Act: Identify whether the Project is within a coastal zone and the status of any coordination with the California Coastal Commission .

C. Protection of Wetlands: Identify any portion of the proposed Project area that should be evaluated for wetlands or United States waters delineation by the United States Army Corps of Engineers (USAGE) , or requires a permit from the USAGE, and identify the status of coordination with the USAGE.

D. Compliance with the Farmland Protection Policy Act: Identify whether the Project will result in the conversion of farmland . State the status of farmland (Prime, Unique, or Local Statewide Importance) in the Project area and determine if this area is under a Williamson Act Contract.

E. Compliance with the Migratory Bird Treaty Act (MBTA): List any birds protected under this act that may be impacted by the Project and identify conservation measures to minimize impacts.

3

F. Compliance with the Flood Plain Management Act: Identify whether or not the Project is in a Flood Management Zone and include a copy of the Federal Emergency Management Agency flood zone maps for the area.

G. Compliance with the Wild and Scenic Rivers Act: Identify whether or not any Wild and Scenic Rivers would be potentially impacted by the Project and include conservation measures to minimize such impacts.

Following are specific comments on the District's draft EIR:

1. How much water would be discharged under the waste discharge permit first mentioned in section 2.8.2? Where would this water be discharged to?

2. Page 3.3-7 mentions that the North Coast Unified Air Quality Management District considers construction that lasts for less than a year to have a less than significant impact on air quality. Within the Air Quality section of the report, no estimates for air quality are given. Please note that if the District decides to pursue CWSRF funding, an air quality modeling analysis is necessary of all projects in order to determine if a general conformity analysis is required for the Project.

3. If pursuing CWSRF funding , please provide copies of the USFWS species list, California Natural Diversity Database species list, and California Native Plant Society Inventory of Rare and Endangered Vascular Plants records search that were used for the Project to State Water Board Staff. Please not that the CWSRF program requires these lists to be less than a year old.

4. Will the Project remove any trees or vegetation that could be used for nesting by MBTA protected species?

5. If pursuing funding , please provide the cultural resources study that is mentioned on page 3.5-1 to State Water Board Staff.

6. Were responses received from the two Native American groups that were sent letters, as referenced on page 3.5-1? Was any follow up contact made if no responses were received?

7. Were the two historical sites that are mentioned in section 3.5.1.4 identified by previous studies in the area? Or were they identified during the current study?

8. Please provide a more detailed description of the two historical sites that are within the vicinity of the Project area. Have the two sites been evaluated for eligibility?

9. Section 3.5.3.1 states that no cultural resources were identified during the investigation. However, section 3.5.1.4 states that two sites are within a half mile of the APE. Please provide clarity on this.

10. Page 3.8-2 mentions a Former Pilot Lumber Mill. Are there any buildings still standing on the property? And if so, could they be considered historic properties?

11. In Appendix E, please be more specific in the explanations of a species potential to occur. For example "Suitable habitat is not present as there are no old growth forests within the study area and the closest old growth is located X miles away" instead of "suitable habitat is not present in the study area."

4

Please provide us with the following documents applicable to the proposed Project if seeking CWSRF or other State Water Board funding : (1) one copy of the final EIR, (2) the resolution certifying the EIR and a Mitigation Monitoring and Reporting Program (MMRP) making California Environmental Quality Act (CEQA) findings , (3) all comments received during the review period and the District's response to those comments, (4) the adopted MMRP, and (5) the Notice of Determination filed with the Humboldt Clerk and the Governor's Office of Planning and Research , State Clearinghouse. In addition , we would appreciate notices of any hearings or meetings held regarding environmental review of any projects to be funded by the State Water Board .

Thank you for the opportunity to review the District's draft EIR. If you have any questions or concerns, please feel free to contact me at (916)341-5686, or by email at Amanda.Dwyer@waterboards .ca.gov, or contact Ahmad Kashkoli at (916)341 -5855 or by email at Ahmad .Kashkoli@waterboards.ca.gov.

Sincerely,

. \JYJ fl'l?uVJ ~ [\)_/ w-;jlj\-Amanda Dwyer Environmental Scientist

Enclosures (3)

1. Clean Water State Revolving Fund Environmental Review Requirements 2. Quick Reference Guide to CEQA Requirements for State Revolving Fund Loans 3. Basic Criteria for Cultural Resources Reports

cc: State Clearinghouse (Re: SCH# 2015012014) P.O. Box 3044 Sacramento, CA 95812-3044

The State Water Resources Control Board

(State Water Board), Division of Financial

Assistance, administers the Clean

Water State Revolving Fund (CWSRF)

Program. The CWSRF Program is partially

funded by grants from the United States

Environmental Protection Agency. All

applicants seeking CWSRF financing

must comply with the California

Environmental Quality Act (CEQA), and

provide sufficient information so that

the State Water Board can document

compliance with federal environmental

laws. The "Environmental Package"

provides the forms and instructions

needed to complete the environmental

review requirements for CWSRF Program

financing. It is available at:

http://www.waterboards.ca.govl

water_issues/programs!grants_ /oans!srf!srf_forms.shtml

We've got the green ... to keep California's water clean.

CLE A N WATER STATE REVOLVI NG FUND

LEAD AGENCY The applicant is usually the "Lead Agency" and must prepare and circulate an environmental document before approving a project. Only a public agency, such as a local, regional or state government, may be the "Lead Agency" under CEQA. If a project will be completed by a non-governmental organization, "Lead Agency" responsibility goes to the first public agency providing discretionary approval for the project.

RESPONSIBLE AGENCY The State Water Board is generally a "Responsible Agency" under CEQA. As a "Responsible Agency;' the State Water Board must make findings based on information provided by the "Lead Agency" before financing a project.

ENVIRONMENTAL REVIEW The State Water Board's environmental review of the project's compliance with both CEQA and federal cross-cutting regulations must be completed before a project can be financed by the CWSRF Program.

DOCUMENT REVIEW Applicants are encouraged to consult with State Water Board staff early during preparation of CEQA document if considering CWSRF financing. Applicants shall also send their environmental documents to the State Water Board, Environmental Review Unit during the CEQA public review period. This way, any environmental concerns can be addressed early in the process.

Contact Information: For more information related to the CWSRF Program environmental review process and requirements, please contact your State Water Board Project Manager or Mr. Ahmad Kashkoli at 916-341-5855 or Ahmad.Kashkoli@waterboards.ca.gov

REVISED. FEB 20 14

REQUIRED DOCUMENTS The Environmental Review Unit requires the documents listed below to make findings and complete its environmental review. Once the State Water Board receives all the required documents and makes its own findings, the environmental review for the project will be complete.

./ Draft and Final Environmental Documents:

Environmental Impact Report, Negative

Declaration, and Mitigated Negative Decla­

ration as appropriate to the project

./ Resolution adopting/certifying the environ­

mental document, making CEQA findings,

and approving the project

./ All comments received during the public

review period and the"Lead Agency's"

responses to those comments

./ Adopted Mitigation Monitoring and

Reporting Plan, if applicable

./ Date-stamped copy of the Notice of

Determination or Notice of Exemption filed

with the County Clerk(s) and the Governor's

Office of Planning and Research

./ CWSRF Evaluation Form for Environmental

Review and Federal Coord ination with

supporting documents

~~ Water Boards -

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waterboards.ca.gov

NATIVE AMERICAN and INTERESTED PARTY CONSULTATION • Native American and interested party consultation should

be initiated at the planning phase of the proposed project

to gather information to assist with the preparation of an

adequate Cultural Resources Report

• The Native American Heritage Commission (NAHC) must be

contacted to obtain documentation of a search of the Saued

Lands Files for or near the project APE.

• All local Native American tribal organizations or individuals

identified by the NAHC must be contacted by certified mail,

and the letter should include a map and a description of the

proposed project.

• Follow-up contact should be made by telephone and a phone

log maintained to document the contacts and responses.

• Letters of inquiry seeking historical information on the

project area and local vicinity should be sent to local historical

societies, preservation organizations, or individual members

of the pub I ic with a demonstrated interest in the proposed

project

Copies of all documents mentioned above (project

description, map, phone log and letters sent to the

NAHC and Native American tribal organizations

or individuals and interested parties) must be

included in the Cultural Resources Report.

Contact Information: For more information related to the CWSRF Program Cultural Resources and Requirments, please contact Mr. Ahmad Kashkoli at 916-341-5855 or Ahmad.Kashkoli@waterboards.ca.gov

R[VlllD JAN 1014

PRECAUTIONS · A finding of Hno known resourcesrrwithout supporting

evidence is unacceptable. The Cultural Resources Report

must identify resources within the APE or demonstrate

with sufficient evidence that none are present.

rrThe area is sensitive for buried archaeological

resources/' followed by a statement that rrmonitoring is recommended." Monitoring is not an acceptable option

without good-faith effort to demonstrate that no known

resource is present.

If r1the area is already disturbed by previous construdion" documentation is still required to demonstrate

that the proposed project will not affect"historic properties:'

An existing road can be protecting a buried archaeological

deposit or may itself be a "historic property." Additionally,

previous construction may have impacted an archaeological

site that has not been previously documented.

SHPO CONSULTATION LEITER Submit a draft consultation letter prepared by the qualified

researcher with the Cultural Resources Report to the State Water

Resources Control Board. A draft consultation letter template is

available for download on the State Water Board webpage at:

h'ttp://www.waterboards.ca.gov!water_issues!programs! grants_loans!cwsrf_requirements.shtml

~ ~ Water Boards

STATE W"TEf\ '11!SOUl'tCES CONT'lOL SOA"ID RtGIONAL :,V,t.TEf; Q1,,.t,,,f1'Y co,..-r;oo· SOA~~s

waterboards.ca.gov

For Section 106 Consultation with the State Historic Preservation Officer (SHPO)

under the National Historic Preservation Act

CULTURAL RESOURCES REPORT The Cultural Resources Report must be prepared by a

qualified researcher that meets the Secretary of the Interior's

Professional Qualifications Standards. Please see the

Professional Qualifications Standards at the following website

at: http://www.a.nps.gov/local-law I arch_stnds_ 9.htm

The Cultural Resources Report should include one of the

four "findings" listed in Section 106. These include:

f/No historic properties affected"

(no properties are within the area of potential

effect (APE; including below the ground).

'Wo effed to historic properties" (properties may be near the APE, but the

project will not have any adverse effects) .

''No adverse effect to historic properties"

(the project may affect "historic properties':

but the effects will not be adverse).

"Adverse effect to historic properties" Note: Consultation with the SHPO will be required if a

"no adverse effect to historic properties" or an "adverse

effect to historic properties" determination is made,

to develop and evaluate alternatives or modifications

to the proposed project that could avoid, minimize or

mitigate adverse effects on "historic properties:'

RECORDS SEARCH • A records search (less than one year old) extending to a half­

mile beyond the project APE from a geographically appropriate

Information Center is required. The records search should

include maps that show all recorded sites and surveys in

relation to the APE for the proposed project, and copies of the

confidential site records included as an appendix to the Cultural

Resources Report.

• The APE is three-dimensional (depth, length and width) and

all areas (e.g., new construction, easements, staging areas, and

access roads) directly affected by the proposed project.

We've got th green ... to keep Californias ater clean.

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LATIO

NS

The C

WSRF

Prog

ram re

quire

s con

sulta

tion

with

re

levan

t fede

ral a

genc

ies on

the

follo

wing

fede

ral

envir

onm

ental

regu

lation

s, if a

pplic

able

to the

pro

ject:

• Cle

an A

ir Act

• Co

astal

Barr

iers R

esou

rces A

ct •

Coas

tal Z

one

Man

agem

ent A

ct •

Enda

ngere

d Sp

ecies

Act

• En

viron

menta

l Jus

tice

• Fa

rmlan

d Pr

otecti

on P

olicy

Act

• Flo

odpla

in M

anag

emen

t •

Magn

uson

-Stev

ens

Fishe

ry Co

nserv

ation

an

d M

anag

emen

t Act

• M

igrato

ry Bir

d Trea

ty Ac

t •

Natio

nal H

istor

ic Pr

eserv

ation

Act

• Pr

otecti

on o

f Wetl

ands

•

Safe

Drink

ing W

ater A

ct,

Sole

Sourc

e Aqu

ifer P

rotec

tion

• W

ild a

nd S

cenic

Rive

rs Ac

t

The f

ollow

ing is

a br

ief ov

ervie

w of

requ

ireme

nts

for so

me o

f the

key r

egula

tions

.

Clea

n Ai

r Act

(CAA

) Th

e CA

A ge

neral

con

form

ity a

nalys

is on

ly ap

plies

to

proje

cts in

area

s not

mee

ting

the N

ation

al Am

bient

Air

Quali

ty St

anda

rds o

r sub

ject to

a ma

inten

ance

plan

.

If pro

ject e

miss

ions a

re be

low th

e fed

eral "d

e m

inim

is" le

vels

then: •

A ge

neral

con

form

ity a

nalys

is is

not r

equir

ed.

• Us

ing p

opula

tion

proje

ction

s, ap

plica

nts m

ust e

xplai

n ho

w the

prop

osed

cap

acity

incre

ase w

as ca

lculat

ed.

An a

ir qua

lity m

odeli

ng a

nalys

is is

nece

ssary

of

all p

rojec

ts for

the

follo

wing

crite

ria p

olluta

nts,

regard

less o

f atta

inmen

t stat

us:

• Ca

rbon

mon

oxide

•

Lead

•

Oxide

s of n

itroge

n •

Ozon

e •

Partic

ulate

mat

ter (

PM2.5

and

PM1

0) •

Sulfu

r diox

ide

Enda

nger

ed S

pecie

s Ac

t (ES

A)

The

ESA

requir

es a

n an

alysis

of th

e eff

ects

on fe

dera

lly lis

ted

spec

ies. T

he S

tate W

ater B

oard

will

deter

mine

the

proje

ct's

poten

tial e

ffects

on fe

dera

lly lis

ted sp

ecies

, and

will

initia

te

infor

mal/

form

al co

nsult

ation

with

the

Unite

d St

ates F

ish

and W

ildlife

Serv

ice (U

SFW

S) a

nd/o

r the

Nati

onal

Marin

e Fis

herie

s Serv

ice, a

s nec

essa

ry un

der S

ectio

n 7 o

f the

ESA.

Requ

ired

Docu

men

ts:

.I A s

pecie

s list

, less

than

one

year

old, f

rom

the U

SFWS

and

the

Cali

fornia

Dep

artm

ent o

f Fish

and

Wild

life's

Natur

al Di

versi

ty Da

tabas

e;

.I A b

iolog

ical s

urve

y con

ducte

d du

ring

the a

ppro

priat

e tim

e of

year;

./Ma

ps o

r doc

umen

ts (b

iolog

ical r

epor

ts or

biolog

ical

asse

ssme

nts, i

f nec

essa

ry); a

nd

.I An

ass

essm

ent o

f the

direc

t or in

direc

t impa

cts to

any

If p

rojec

t emi

ssion

s are

abov

e the

fede

ral "d

e m

inim

is" le

vels

feder

ally

listed

spec

ies a

nd/o

r criti

cal h

abita

t. If n

o eff

ects

then:

~~

are e

xpec

ted, e

xplai

n wh

y an

d pr

ovide

the

supp

ortin

g

• A

gene

ral c

onfo

rmity

dete

rmina

tion

for th

e pr

oject

must~

( (C

\··

evide

nce.

be m

ade.

A ge

neral

con

form

ity d

eterm

inatio

n ca

n be

· ..

..

made

if fa

cilitie

s are

sized

to m

eet th

e ne

eds o

f cur

rent ~

--:...:

. po

pulat

ion p

rojec

tions

use

d in

an a

ppro

ved

State

.

'~·

·. -~,,· :~1 ~~

Imple

men

tation

Plan

for a

ir qua

lity.

--~ ~ .

,~~~· t~

-~~~~'\~fl

Natio

nal H

istor

ic Pr

eser

vatio

n Ac

t (NH

PA)

Secti

on 1

06 o

f the

NHPA

requ

ires a

n an

alysis

ofth

e eff

ects

on "

histo

ric p

rope

rties."

The

Sec

tion

106 p

roces

s is d

esign

ed

to ac

comm

odate

hist

oric

pres

erva

tion

conc

erns f

or fe

dera

l ac

tions

with

the

poten

tial to

affe

ct his

toric

prop

ertie

s. Ea

rly

cons

ultat

ion w

ith a

ppro

priat

e go

vern

men

t age

ncies

, Ind

ian

tribes

, and

mem

bers

of the

pub

lic, w

ill en

sure

that

their

vie

ws a

nd c

once

rns ar

e add

resse

d du

ring

the p

lannin

g ph

ase.

Histo

ric p

rope

rties

(i.e.,

build

ings,

struc

tures

, obje

cts,

and

arch

aeolo

gical

sites

50 y

ears

or old

er) a

re pr

oper

ties

that

are i

nclud

ed in

the

Natio

nal R

egist

er of

Hist

oric

Place

s or m

eet th

e cri

teria

for th

e Na

tiona

l Reg

ister.

Requ

ired

Docu

men

ts:

./A

draf

t Stat

e Hi

storic

Pres

ervati

on O

fficer

cons

ultati

on

reque

st let

ter; a

nd

./A

cultu

ral r

esou

rces r

epor

t on

histor

ic pr

oper

ties c

ondu

cted

acco

rding

to th

e Se

cretar

y of th

e Int

erior

's St

anda

rds,

includ

ing:

• A

clear

ly de

fined

Area

of P

otenti

al Ef

fect (

APE)

, sp

ecify

ing th

e len

gth, w

idth,

and

dep

th of

exca

vatio

n, wi

th a

map

clear

ly illu

strat

ing th

e pr

oject

APE;

• A

record

s sea

rch, le

ss th

an o

ne ye

ar old

, exte

nding

to a

ha

lf-mile

bey

ond

the p

rojec

t APE

;

• W

ritten

des

cripti

on o

f field

meth

ods;

• Ide

ntific

ation

and

eva

luatio

n of

histo

ric p

rope

rties

with

in the

pro

ject's

APE

; and

• Do

cum

entat

ion o

f con

sulta

tion

with

the

Nativ

e Am

erica

n He

ritage

Com

miss

ion a

nd lo

cal N

ative

Am

erica

n trib

es.

ADDIT

IONA

L INF

ORMA

TION

If you

r pro

ject h

as th

e po

tentia

l to a

ffect

biolog

ical r

esou

rces

or his

toric

prop

ertie

s, the

con

sulta

tion

proce

ss ca

n be

len

gthy.

Pleas

e co

ntact

the S

tate W

ater B

oard

staff e

arly

in yo

ur p

lannin

g pro

cess

to d

iscus

s wha

t add

itiona

l inf

orm

ation

may

be n

eede

d for

your

spec

ific p

rojec

t.

Pleas

e co

ntact

your

Stat

e Wate

r Boa

rd Pr

oject

Mana

ger

or Mr

. Ahm

ad K

ashk

oli a

t (91

6) 3

41-5

855

or Ah

mad

.Kas

hko/

i@wa

terb

oard

s.ca.

gov f

or m

ore

infor

mati

on re

lated

to th

e CW

SRF

Prog

ram e

nviro

nmen

tal

revie

w pro

cess

and

requ

ireme

nts.

~~

We'

ve g

ot th

e g

reen

... to

kee

p C

alifo

rnia

's w

ate

r cl

ean.

C

LE

AN

WA

TE

R S

TA

TE

RE

VO

LV

ING

FU

ND

~ ~

Wat

er B

oard

s S

TA

TE

WA

TE

R R

ES

OU

RC

ES

CO

NT

RO

L O

OA

RD

R

EG

ION

AL

WA

TE

A Q

UA

LIT

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ON

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00

11.fl

DS

ww

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ater

boar

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.gov

Comments and Responses

3-11 | Willow Creek Community Services District - Downtown Wastewater Development Project Final EIR | GHD

Letter A – State Water Resources Control Board – Response to Comments

Response A-1

This comment includes an introductory statement, background information, and requirements for the

Clean Water State Revolving Fund (CWSRF) financing for the proposed project.

Response A-2

This comment discusses compliance with Section 106 of the National Historic Preservation Act and

identification of the Area of Potential Effect (APE) for projects subject to CWSRF financing. As noted in

the cultural resources report prepared for the Draft EIR (Roscoe and Associates 2015) “The purpose of

this report is to document whether significant archaeological, tribal or historic period cultural resources are

present within the proposed project’s Area of Potential Effects (APE) pursuant to Section 106 of the

National Historic Preservation Act (36 CFR 800) and the California Environmental Quality Act (Section

15064.5).” Reference Section 3.5.1.4 of the Draft EIR for a discussion and definition of the APE.

Response A-3

This comment lists other federal requirements pertinent to the proposed project under the CWSRF

Program. This comment does not discuss the adequacy of the Draft EIR; therefore, no further response is

necessary.

Response A-4

As outlined in Section 2.3.2.4 of the Draft EIR, the average daily flow of treated effluent to be discharged

is anticipated to be 38,000 gallons per day. The effluent will be discharged to the proposed leachfield as

detailed in Section 2.3.2.3 of the Draft EIR.

Response A-5

If the District pursues CWSRF funding for the proposed project then the District will provide the State

Water Resources Control Board (SWRCB) the required air quality modeling analysis with the application.

This comment does not discuss the adequacy of the Draft EIR; therefore, no further response is

necessary.

Response A-6

If the District pursues CWSRF funding for the proposed project then the District will provide the SWRCB

the required species lists (reference Appendix E of the Draft EIR). This comment does not discuss the

adequacy of the Draft EIR; therefore, no further response is necessary.

Response A-7

As noted under Impact BIO-2 of the Draft EIR, the project footprint avoids impacts to riparian habitat or

other sensitive plant communities as defined by CDFW and/or the USFWS. This includes any potential

vegetation or trees that could be used for nesting by Migratory Bird Treaty Act (MBTA) protected species.

Most of the collection system would be within existing road right-of-way (ROW), and the sewage

treatment facility and disposal areas would be within empty fields, which have no shrubs or trees.

Comments and Responses

GHD | Willow Creek Community Services District - Downtown Wastewater Development Project Final EIR | 3-12

However, Mitigation Measure Bio-1 has been added to reduce any potential impacts to nesting birds to a

less than significant level (see Chapter 4 – Revisions to the Draft EIR).

Response A-8

If the District pursues CWSRF funding for the proposed project then the District will provide the SWRCB

with the cultural resources study. This comment does not discuss the adequacy of the Draft EIR;

therefore, no further response is necessary.

Response A-9

A letter was sent to the Native American Heritage Commission (NAHC) requesting a search of the Sacred

Lands Inventory File and a current list of local Native American groups and individuals who may have

interests and/or concerns with the project. Letters were sent on January 5, 2015 to:

1. Hoopa Tribe - Danielle Vigil-Masten, Chairperson

2. Tsnungwe Council - Paul Ammon, Chairperson

Donald Verwayen and James Roscoe (Roscoe & Associates) consulted directly with Bob Benson,

representative of the Tsnungwe Council, who accompanied the authors to the project area on January 16,

2015. Maps of the project area were reviewed and Mr. Benson showed the authors the location of a

previously unrecorded Tsnungwe habitation site to the north of the APE. Project plans for the area were

reviewed and when it was determined that the project would have no impacts to the archaeological

deposit, Mr. Benson indicated that there were no concerns. The site was several hundred meters north of

the project APE, on private property, and was not formally recorded. No response has yet been received

from the Hoopa Tribe.

Response A-10

Yes, the one historical site and one historical feature mentioned in Section 3.5.1.4 were identified by

previous studies [CA-HUM-358 (Arnold and Benson 1976) and CA-HUM-1107 (Eidsness 2006)]. This

comment does not discuss the adequacy of the Draft EIR; therefore, no further response is necessary.

Response A-11

One prehistoric site (Native American village site) is located approximately 450 meters north of the APE

[CA-HUM-358 (Arnold and Benson 1976)] and a historic feature (an 1890’s road) was recorded outside

of, but near the westernmost portion of the APE [CA-HUM-1107 (Eidsness 2006)]. These references are

cited in Section 4 of this Final EIR. The two sites are not within the APE for the proposed project. This

comment does not discuss the adequacy of the Draft EIR; therefore, no further response is necessary.

Response A-12

As stated in the Draft EIR, no cultural resources were identified within the proposed project’s APE, and

two, as noted above, were identified outside the proposed project’s APE.

Response A-13

As shown in Figure 3.8-1 of the Draft EIR, there are no buildings located in the proposed wastewater

treatment plant and disposal areas. The former Pilot Lumber Mill no longer exists on the property.

Comments and Responses

3-13 | Willow Creek Community Services District - Downtown Wastewater Development Project Final EIR | GHD

Response A-14

The species lists in Appendix D and E are used by project Biologists to help determine what species are

found in the region. Actual site visits and surveys determine the species potential to be impacted by the

proposed project. As noted in Section 3.4.5 of the Draft EIR, all potential impacts to special-status species

are less than significant.

Response A-15

If the District pursues CWSRF funding for the proposed project then the District will provide the SWRCB

with the documents listed on page 4 of the SWRCB’s letter. This comment does not discuss the adequacy

of the Draft EIR; therefore, no further response is necessary.

Comments and Responses

3-15 | Willow Creek Community Services District - Downtown Wastewater Development Project Final EIR | GHD

Letter B – California Department of Transportation – Response to Comments

Response B-1

This comment includes an introductory statement and a summary of the project description.

Response B-2

WCCSD will work with Caltrans to avoid any conflicts between project construction and regular highway

maintenance. This comment does not discuss the adequacy of the Draft EIR; therefore, no further

response is necessary.

Response B-3

This is acknowledged in Section 1.3 of the Draft EIR.

Comments and Responses

3-19 | Willow Creek Community Services District - Downtown Wastewater Development Project Final EIR | GHD

Letter C – California Department of Fish and Wildlife – Response to Comments

Response C-1

This comment includes an introductory statement, reiteration of previous comments, and the CDFW’s role

as a responsible and trustee agency per CEQA.

Response C-2

This comment merely summarizes the project description. This comment does not discuss the adequacy

of the Draft EIR; therefore, no further response is necessary.

Response C-3

This comment identifies the significance of Willow Creek and the Trinity River to special status species in

the region. This comment does not discuss the adequacy of the Draft EIR; therefore, no further response

is necessary.

Response C-4

The proposed project does not include the diversion of any water from Willow Creek; therefore, no

additional mitigation is necessary.

Response C-5

This comment includes the CDFW contact’s name and phone number.

Revisions to EIR

GHD | Willow Creek Community Services District - Downtown Wastewater Development Project Final EIR | 4-1

4. Revisions to the Draft EIR

This chapter includes the minor revisions to the DEIR necessary to correct minor errors or omissions in

the DEIR. The changes to the DEIR are indicated by indented text. Text that has been added to the DEIR

is indicated in underline font.

Athough the DEIR concluded that impacts to biological resources would be less than significant. The

following mitigation measure is included for potential impacts to nesting birds. The following mitigation

would ensure that impacts to nesting birds would be less than significant.

Mitigation Measure Bio-1: Conservation Measures to Protect Nesting and Migratory Bird Species.

If possible, vegetation clearing activities would take place between August 16 and March 13,

outside of the active nesting season for migratory bird species (i.e., March 14 to August 15).

If work must be completed during the nesting season, a qualified biologist would conduct

preconstruction surveys of all ground disturbance areas to verify absence of nesting migratory

birds in the project area prior to vegetation removal and the start of construction. These surveys

would be conducted within two weeks prior to start of vegetation removal or any construction

activities. If nesting migratory birds are found in the construction area during the preconstruction

surveys, they would be avoided with an appropriate buffer area until the young birds have fledged.

If state listed (CESA), federally listed (ESA), or raptors are found outside of the construction

(disturbance) area but near the construction area, appropriate buffers will be implemented. If non-

listed state (CESA), non-listed federal (ESA), including state species of special concern are found

near, but outside of the construction area, no buffers will be implemented.

References

5-1 | Willow Creek Community Services District - Downtown Wastewater Development Project Final EIR | GHD

5. References

Arnold, Barbara and Jim Benson, 1976 CA-HUM-358 (Information Sheet), On file at the North West

Information Center, Sonoma State University.

Eidsness, Janet P., 2006, Initial Cultural Resources Study for the Willow Creek Community Park Trail

Project in Willow Creek, Humboldt Country, California. On file at the North West Information Center,

Sonoma State University.

Roscoe and Associates, 2015, A Cultural Resources Investigation for the Willow Creek Wastewater

Development Project, Humboldt County, California, March.

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