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May2013

City of Ukiah
Recycled Water Project
Final Initial Study / Mitigated Negative Declaration
SCH #2013032072

Prepared by:

SMB Environmental, Inc.

May 2013

City of Ukiah Recycled Water Project

Final IS/MND

Table of Contents
Chapter 1 Introduction .........................................................................................................1-1
Chapter 2 Comments Received ...........................................................................................2-1
Chapter 3 Responses to Comments ....................................................................................3-1
Chapter 4 Revisions to the Public Draft IS/MND .................................................................4-1
Chapter 5 CEQA Findings and Determination: ...................................................................5-1
Appendicies
Appendix A Mitigation Monitoring and Reporting Program .............................................. A-1

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Chapter 1

Introduction

Pursuant to the California Environmental Quality Act (CEQA; Public Resources Code Section 21000, et
seq. and CEQA Guidelines), the City of Ukiah, California (City) prepared a Public Draft Initial
Study/Mitigated Negative Declaration (IS/MND) to evaluate potential environmental impacts associated
with the Citys proposed Recycled Water Project (Proposed Project/Action). The purpose of the Proposed
Project/Action is to replace/augment existing water supplies in Ukiah Valley. Recycled water use within
the Ukiah Valley would offset existing and future water demands for irrigation and frost protection of
agricultural land, and in doing so, would support the local agricultural industry. It would also offset urban
irrigation demands, ease storage limitations at the Ukiah Wastewater Treatment Plant (UWWTP) and
reduce treated wastewater discharges to the Russian River.
On March 27, 2013, to initiate public review of the Draft IS/MND, the City filed a Notice of Completion
(NOC) for the project with the Governors Office of Planning and Research (State Clearinghouse or SCH)
and the County of Mendocino and released the Draft IS/MND for a 30-day public review. The State
Clearinghouse identified the project with SCH #2013032072. The 30-day public review period was
established between March 27 and April 26, 2013, with copies of the Draft IS/MND available for review
at the Citys Public Works Administration Office, at 300 Seminary Avenue, Ukiah, CA 95482; and the
Main Branch Library, 105 North Main Street, Ukiah, CA 95482. On March 27, 2013, the Ukiah Daily
Journal published the Notice of Intent/Notice of Availability (NOI/NOA) to adopt a Mitigated Negative
Declaration for the Proposed Project/Action. A Public Draft of the IS/MND was also posted on the Citys
website at http://www.cityofukiah.com/.
This Final IS/MND was prepared according to CEQA Guidelines and considers and incorporates all
comments received by the State Clearinghouse and the City during the 30-day public review period. The
purpose of this document is to clarify facts set forth in the Public Draft IS/MND, as necessary, to ensure
accuracy. This City must consider the IS/MND, together with any comments received, before approving
the Proposed Project/Action (Public Resources Code Section 21091(f); and CEQA Guidelines Section
15074). The City has no affirmative duty to prepare formal responses to comments on the Proposed
Project/Action IS/MND, but should have adequate information on the record explaining why the
comment does not affect the conclusion that there are no potential significant environmental effects. The
City is required to, however, to notify, in writing, any commenting agencies of the date of the public
hearing on the Proposed Project/Action for which an IS/MND is prepared and will be decided upon for
approval (Public Resources Code Section 21092.5(b); and CEQA Guideline Section 15073).
This Final IS/MND is being distributed to agencies, stakeholder organizations, and individuals who
commented on the Public Draft IS/MND to ensure that interested parties have an opportunity to express
their views regarding the environmental impacts of the project, and to ensure that information pertinent to
permits and approvals is provided to decision makers for the City and CEQA responsible agencies. A
public hearing was held by the City Council on May 15, 201. Both written comments and oral testimony
from the public hearing have been incorporated into the Final IS/MND for the City Council to consider
whether to approve the Proposed Project. The City Council is scheduled to make a final decision on
the Proposed Project/Action on June 5, 2013 at 6:00 at the City Council Chambers, 300 Seminary
Avenue, Ukiah, CA 95482.
.

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Chapter 2

Comments Received

During the 30-day public review period (March 27 through April 26, 2013), the City received a total of
four (4) comment letters on the Proposed Project/Action. The City has reviewed and considered the
comments from each agency as follows in Table 2-1 below:
TABLE 2-1
AGENCY COMMENT LETTER RECEIVED

Date
April 25, 2013

April 25, 2013

April 25, 2013

April 26, 2013

May 2013

Commenting Agency
Mona Dougherty, Senior Water Resources Control Engineer
North Coast Regional Water Quality Control Board
5550 Skyline Boulevard, Suite A
Santa Rosa, CA 95400
Bruce. C Baracco, Executive Officer
Mendocino Local Agency Formation Commission
Ukiah Valley Conference Center
200 South School Road, Site F
Ukiah, CA 95482
Ahmad Kaskoli, Senior Environmental Scientist
State Water Resources Control Board
1001 I Street
Sacramento, CA 95814
Devon Jones, Director
Mendocino County Farm Bureau
303-C Talmage Road
Ukiah, CA 95482

Comment
Letter

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Chapter 3

Responses to Comments

This chapter evaluates the comments received during the 30-day public review period (March 27 through
April 26, 2013). The City received a total of four (4) comment letters on the Proposed Project/Action.
The City has reviewed and considered the comments from each agency and provides a response to each of
those comments as provided for below.

NORTH COAST REGIONAL WATER QUALITY CONTROL BOARD

Comment A-1. Comment Noted. The City also agrees that the activities that occur on each proposed use
site is an integral part of the Proposed Project/Action. Specific end users have not formally signed up for
the Recycled Water Project at this time and therefore specific details regarding those activities are not
fully known at this time. The City is in the process of identifying specific end users and developing
agreements with them. It is expected that most of the users will receive the recycled water on demand as
most do not have their own storage. Those with storage will receive recycled water for the irrigation
season and limited times for the frost season use based on conditions of use from the permitting agencies.
As part of the permitting process, the City is preparing a Report of Waste Discharge and Recycled Water
Technical Report that will address these issues more specifically.
Comment A-2. Comment Noted. The City agrees that there are distinct differences between the use of
recycled water for frost protection and irrigation. As part of the permitting process, the City is preparing
a Report of Waste Discharge and Recycled Water Technical Report that will address these issues more
specifically.
Comment A-3. Comment Noted. Specific end users have not formally signed up for the Recycled Water
Project at this time and therefore specific details regarding those activities are not fully known at this
time. The City is in the process of identifying specific end users and developing agreements with them.
It is expected that most of the users will receive the recycled water on demand as most do not have their
own storage. Those with storage will receive recycled water for the irrigation season and limited times for
the frost season use based on conditions of use from the permitting agencies. As part of the permitting
process, the City is preparing a Report of Waste Discharge and Recycled Water Technical Report that
will address these issues more specifically. In this report, detailed figures will be provided to identify all
significant features of the project, including the locations of existing ponds proposed for recycled water
storage and potential locations of future storage ponds, when known. The figures will also identify the
locations of the 6 ephemeral streams/drainages that will be crossed by the proposed pipeline and the
locations of any existing water supply wells within 100 feet of the proposed irrigation areas.
Comment A-4. Comment Noted. The City is preparing a Report of Waste Discharge and Recycled Water
Technical Report that will include a summary of each proposed recycled water use site, including but not
limited to, the site characteristics, total and irrigable acreage, crop, type of irrigation system, and
proximity of the proposed irrigation area to surface water features. The Annual Recycled Water Demand
as summarized in Table 2 of the IS/MND was derived from the Citys 2012 Recycled Water Feasibility
Study. Please refer to that document which describes how these figures were determined. The Citys
Report of Waste Discharge and Recycled Water Technical Report will provide a detailed analysis to
demonstrate that the proposed recycled water irrigation rates will not exceed the most stringent of the
nutrient or hydraulic agronomic rate and also demonstrate that ground or surface water will not be
degraded.
Comment A-5. Comment Noted. The City is preparing a Report of Waste Discharge and Recycled Water
Technical Report that will include a summary of each proposed recycled water use site, including but not
limited to, the site characteristics, total and irrigable acreage, crop, type of irrigation system, and
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proximity of the proposed irrigation area to surface water features. The Citys Report of Waste Discharge
and Recycled Water Technical Report will also provide a detailed analysis to demonstrate that the
proposed recycled water irrigation rates will not exceed the most stringent of the nutrient or hydraulic
agronomic rate and also demonstrate that ground or surface water will not be degraded.
Comment A-6. Comment Noted. Table 4 - Regulatory Requirements, Permits and Authorizations for
Project/Action Facilities has been revised to reflect these comments. Please see changes to the Public
Draft IS/MND in Chapter 4 Revisions to the Public Draft IS/MND.
Comment A-7. Comment Noted. The page numbering in Chapter 3 has been revised per the comment
provided. Please see changes in to the Public Draft IS/MND in Chapter 4 Revisions to the Public Draft
IS/MND.
Comment A-8. Comment Noted. The Comment is a general statement which is acknowledged and with
which the City agrees.
Comment A-9. Comment Noted. The Comment is a general statement which is acknowledged and with
which the City agrees.
Comment A-10. Comment Noted. Mitigation Measure BIO-6: Obtain Required Authorizations, is also to
be implemented in conjunction with Mitigation Measure BIO-3 Avoid Cutting Through Creeks;
Mitigation Measure BIO-4: Implement Construction Best Management Practices; and Mitigation
Measure BIO-5: Develop and Implement a Frac-Out Contingency Plan for Trenchless Construction
Activities. As a result, we are not simply proposing to conduct studies and obtain permits. We have
identified mitigation measures to help avoid and reduce potential impacts to wetlands and other sensitive
areas. As part of the permitting process, additional mitigation measures may also be identified and
implemented as project design details become more fully developed.
Comment A-11. The City is in the process of identifying the details regarding the design and construction
of the proposed recycled water storage pond(s). At a minimum, the recycled storage pond(s) will be
designed to minimize the movement of recycled water and pollutants such as salts and nutrients to
groundwater and/or surface waters. The storage pond(s) will have a synthetic liner and will meet all of the
design criteria required by the Regional Water Board.
Comment A-12. Comment Noted. The Geology and Soils section of the IS/MND has been revised to
reflect this comment. Please see changes in to the Public Draft IS/MND in Chapter 4 Revisions to the
Public Draft IS/MND.
Comment A-13. Comment Noted. The Hydrology and Water Quality section of the IS/MND has been
revised to reflect this comment. Please see changes in to the Public Draft IS/MND in Chapter 4
Revisions to the Public Draft IS/MND.
Comment A-14. Comment Noted. The Citys Report of Waste Discharge and Recycled Water Technical
Report will also provide a detailed analysis to demonstrate that the proposed recycled water irrigation
rates will not exceed the most stringent of the nutrient or hydraulic agronomic rate and also demonstrate
that ground or surface water will not be degraded.
Comment A-15. Comment Noted. The Citys Report of Waste Discharge and Recycled Water Technical
Report will also provide a detailed analysis to demonstrate that the proposed recycled water irrigation
rates will not exceed the most stringent of the nutrient or hydraulic agronomic rate and also demonstrate

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that ground or surface water will not be degraded. An antidegradation analysis will be prepared and
submitted as part of the Report of Waste Discharge.
Comment A-16. Comment Noted. On page 2-8 in the Public Draft IS/MND, the City identifies a
summary of the operational plans to enforce an irrigation schedule among its users. Additionally, the
comment correctly notes that Mitigation Measure HWQ-2 identifies BMPs that the City proposes to
implement to reduce the potential effects of increased salt loading potential from the use of recycled
water. The City also notes that prior to any permit action related to operation of the recycled water
system, the City will need to prepare and submit for approval of the Regional Water Board, a recycled
water operations and maintenance plan and recycled water users guide to identify general and site-specific
BMPs that will be implemented to ensure that recycled water will be used in a manner that protects
ground and surface water. As requested, the City has revised existing Mitigation Measure HWQ-2 and
has added a new mitigation measure (HQW-3) to identify the preparation of measures to protect against
recycled water runoff that is not incidental, provide for detection and correction of leaks, and ensure that
pollutants such as salts and nutrients are not discharged at concentrations that could adversely impact
groundwater. The BMPs will also address both agronomic irrigation and frost protection uses. Please see
changes in to the Public Draft IS/MND in Chapter 4 Revisions to the Public Draft IS/MND.
Comment A-17. Comment Noted. As requested, the City has added a mitigation measure to identify the
preparation of measures to protect against recycled water runoff that is not incidental, provide for
detection and correction of leaks, and ensure that pollutants such as salts and nutrients are not discharged
at concentrations that could adversely impact groundwater. The BMPs will also address both agronomic
irrigation and frost protection uses. Please see changes in to the Public Draft IS/MND in Chapter 4
Revisions to the Public Draft IS/MND.
Comment A-18. Comment Noted. As requested, the City has added a mitigation measure to identify the
preparation of measures to protect against recycled water runoff that is not incidental, provide for
detection and correction of leaks, and ensure that pollutants such as salts and nutrients are not discharged
at concentrations that could adversely impact groundwater. The BMPs will also address both agronomic
irrigation and frost protection uses. Please see changes in to the Public Draft IS/MND in Chapter 4
Revisions to the Public Draft IS/MND.
Comment A-19. Comment Noted. The City agrees with the comment and has included Mitigation
Measure HWQ-1 Implement Construction Best Management Practices in the Public Draft IS/MND which
identifies the need to prepare and implement a Storm Water Pollution Prevention Plan (SWPPP) pursuant
to the requirements of the construction storm water general permit. The mitigation measure also addresses
post-construction erosion control measures that will be implemented to ensure protection of water quality.
These measures include, but are not limited to: returning all drainage patterns to pre-construction
conditions, re-grading and re-gravelling or repaving road surfaces, as necessary, to prevent erosion and
provide stable road beds and the inclusion of vegetation on recycled water reservoir embankments to
prevent erosion.
Comment A-20. Comment Noted. The City does not anticipate that construction activities would be
within, or disturb, the riparian zone. Nevertheless the City has revised Mitigation Measure BIO-3 to
identify setbacks from creeks for starting and ending the drilling activities and the need to have equipment
on site to handle any spills. Please see changes in to the Public Draft IS/MND in Chapter 4 Revisions to
the Public Draft IS/MND.
Comment A-21. Comment Noted. The City agrees and Mitigation Measure HAZ -2 identifies the need to
coordinate with appropriate regulatory agencies and develop a contingency plan to dispose of any
contaminated soil or groundwater.
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Comment A-22. Comment Noted. The City agrees and has revised Mitigation Measure HAZ-1 to
reflect this comment. Please see changes in to the Public Draft IS/MND in Chapter 4 Revisions to
the Public Draft IS/MND.
Comment A-23. Comment Noted. The City does not believe the Proposed Project/Action would have any
impacts on temperature in the Russian River or its tributaries as it does not propose any activities where
applied recycled water would run-off into the Russian River or its tributaries, including under frost
control measures. The City has revised existing Mitigation Measure HWQ-2 and has added a new
mitigation measure (HQW-3) to identify the preparation of measures to protect against recycled water
runoff that is not incidental, provide for detection and correction of leaks, and ensure that pollutants such
as salts and nutrients are not discharged at concentrations that could adversely impact groundwater and
surface water. The BMPs will also address both agronomic irrigation and frost protection uses. Please see
changes in to the Public Draft IS/MND in Chapter 4 Revisions to the Public Draft IS/MND.
Comment A-24. Comment Noted. Table 4 - Regulatory Requirements, Permits and Authorizations for
Project/Action Facilities has been revised to reflect these comments. Please see changes in to the Public
Draft IS/MND in Chapter 4 Revisions to the Public Draft IS/MND.
Comment A-25. Comment Noted. Table 4 - Regulatory Requirements, Permits and Authorizations for
Project/Action Facilities has been revised to reflect these comments. Please see changes in to the Public
Draft IS/MND in Chapter 4 Revisions to the Public Draft IS/MND.
Comment A-26. Comment Noted. Table 4 - Regulatory Requirements, Permits and Authorizations for
Project/Action Facilities has been revised to reflect these comments. Please see changes in to the Public
Draft IS/MND in Chapter 4 Revisions to the Public Draft IS/MND.
Comment A-27. Comment Noted. Table 4 - Regulatory Requirements, Permits and Authorizations for
Project/Action Facilities has been revised to reflect these comments. Please see changes in to the Public
Draft IS/MND in Chapter 4 Revisions to the Public Draft IS/MND.

MENDOCINO LOCAL AGENCY FORMATION COMMISSION

Comment B-1. Comment Noted. We agree that Government Code Section 56133does not apply in this
case because recycled water is considered to be exempt as non-potable surplus water.
Comment B-2. Comment Noted. The City will enter into an agreement for each user of the recycled water
which will state and require that service will not include or support development of any kind. As a result,
an Out-of-Agency Service Approval, Annexation, and/or a Sphere of Influence (SOI) Amendment will
not be required.

STATE WATER RESOURCES CONTROL BOARD

Comment C-1. Comment Noted. The City will provide the State Board with the requested documents
following the CEQA process and which address the specific points and federal requirements for financing
under the Clean Water State Revolving Fund (CWSRF) Program.
Comment C-2. Comment Noted. The City does not anticipate that construction activities would be
within, or disturb, the riparian zone and/or special status fish species. Nevertheless the City has revised

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Mitigation Measure BIO-3 to identify setbacks from creeks for starting and ending the drilling activities
and the need to have equipment on site to handle any spills. Please see changes to the Public Draft
IS/MND in Chapter 4 Revisions to the Public Draft IS/MND.
Comment C-3. Comment Noted. The City will research alternative lubricants to replace bentonite during
construction-related drilling activities. If or when a more suitable substitute is found, we will revise the
construction plan that correlates with construction-related drilling.
Comment C-4. Comment Noted. Due to the scale of the Project and the maps included in the IS/MND
and the Cultural Resources Investigation report, detailed mapping showing the buffer footprints of the
Projects APE would not provide much distinction except for on a much larger scale and on a pipeline
segment by segment basis. Due to the nature of this IS/MND and Cultural Resources Inventory Report,
the City feels the mapping along with the description is more than adequate at this point. Once detailed
design drawings are developed, the buffers will be displayed at that time.
Comment C-5. Comment Noted. The City agrees and has revised Mitigation Measure HAZ-1 to reflect
this comment. Please see changes in to the Public Draft IS/MND in Chapter 4 Revisions to the Public
Draft IS/MND.
Comment C-6. Comment Noted. The City agrees and has revised Mitigation Measure HAZ-1 to reflect
this comment. Please see changes in to the Public Draft IS/MND in Chapter 4 Revisions to the Public
Draft IS/MND.

MENDOCINO COUNTY FARM BUREAU

Comment D-1. Comment Noted. The purpose of the Proposed Project/Action is to replace/augment
existing water supplies in Ukiah Valley. Recycled water use within the Ukiah Valley would offset
existing and future water demands for irrigation and frost protection of agricultural land, and in doing so,
would support the local agricultural industry. It would also offset urban irrigation demands, ease storage
limitations at the Ukiah Wastewater Treatment Plant (UWWTP) and reduce treated wastewater discharges
to the Russian River.

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Chapter 4

Revisions to the Public Draft IS/MND

This chapter shows revisions to the March 2013 Public Draft IS/MND, subsequent to the documents
publication and public review. The revisions are presented in the order in which they appear in the Public
Draft IS/MND and are identified by section and page number in respective chapters. These revisions are
shown as excerpts from the Public Draft IS/MND, with strikethrough (strikethrough) text in indicate
deletions and underlined (underlined) text to indicate additions.

Chapter 2

Project Description and Alternatives

Detailed below are the changes to the Project Description and Alternatives chapter in the Public Draft
IS/MND.

2.1.4 Storage Facilities

On page 2-4 of the Public Draft IS/MND, Section 2.1.4 Storage Facilities is hereby revised as follows.
As also shown on Figure 2 and Figure 2a below, the Proposed Project/Action also includes the
construction and operation of a new single tertiary treated recycled water storage pond at the wastewater
treatment plant sized at a capacity of approximately 1.6 MG and encompassing approximately 5 acres of a
43-acre parcel which is owned by the City. The storage pond at the wastewater treatment plant will
accommodate the variation in potential customer demand patterns and also serve as an equalization basin
to buffer the potential variation in effluent flow at the WWTP. This storage pond will be setback from the
Russian River by approximately 500 feet and will be designed and lined with a synthetic liner to prevent
the movement of recycled water and pollutants such as salts and nutrients to groundwater or surface
waters. In addition to this storage pond, individual farmers will either use their existing storage ponds
and/or develop additional storage ponds on their own which will be designed to the same water quality
design standards as the Citys proposed storage pond. These specific farmer activities are not included in
the Proposed Project/Action known at this time, but will be developed once individual agreements are
made with each farmer/individual. These activities will be further identified and explained in the Citys
Report of Waste Discharge and Recycled Water Technical Report that the City will submit to the North
Coast Regional Water Quality Control Board for approval prior to implementation.

Figure 2a Recycled Water Storage Pond

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On page 2-8, Table 4 Regulatory Requirements, Permits, and Authorizations for Project/Action
Facilities is hereby revised as follows.
Table 4: Regulatory Requirements, Permits, and Authorizations for Project/Action Facilities
Agency

Type of Approval

Nationwide Permit #12 for Construction

Activities (or) Section 404 (Wetlands)
Permit

Water Quality Certification (401

Certification)

Coordination with Federal Aviation

Administration (FAA) for permitting of new
wastewater storage pond

National Pollutant Discharge Elimination

System General Permit for Stormwater
Discharge Associated with Construction
Activities

Waste Discharge Requirements (WDRs) or

Conditional Waiver of WDRs

General Construction Activity Storm Water

Permit

Low Threat Discharge Permit

Recycled Water Use Permit

California Division of Dam Safety

Storage Pond Design, if necessary

California Division of Occupational Safety and

Health

Construction activities in compliance with

CAL/OSHA safety requirements

California Department of Fish and Game Wildlife

Streambed Alteration Agreements

Title 22 Recycled Water Engineering

Report for Urban Reclamation and
recycled Water Pipe Installation
Regulations

Ukiah Municipal Airport Operations

Permitting of new wastewater storage pond

Authority to Construct

Permit to Operate

Encroachment Permit County Roads

U.S. Army Corps of Engineers

North Coast Regional Water Quality Control

Board

California Department of Public Health

Federal Aviation Administration (FAA)
Mendocino County Air Quality Management
District (BAAQMD)
County of Mendocino

3.4

Biological Resources

On Page 3-14, Mitigation Measure BIO-3: Avoid cutting through the creeks is hereby revised as follows.
Mitigation Measure BIO-3: Avoid cutting through the creeks. As described in the Proposed
Project/Action description, all of the creek crossings will be crossed by using trenchless construction
techniques in the dry season. Specifically, no pipeline construction activities shall occur between
December 1 and May 31 (a work window identified by the National Marine Fisheries Service), which is
the period when adult and juvenile salmonids are likely to occur in the Russian River. Construction crews
shall avoid entering the stream channels during installation. In Addition, the City shall require that there

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is a minimum setback of 100 feet from creeks for the starting and ending of any drilling or
trenchless construction activities. Additionally, the City shall have or require its contractor(s)
have the needed equipment on site to handle any spills.

3.6

Geology and Soils

On Page 3-23, Mitigation Measure: GEO-1: Perform Geotechnical Investigation is hereby revised as
follows.
Mitigation Measure GEO-1: Perform Geotechnical Investigation. The City shall require a designlevel geotechnical study to be prepared prior to project implementation to determine proper design and
construction methods, including any cathodic protection measures needed for installing the pipelines in
these soils as well as the design of the storage pond(s). The geotechnical study shall evaluate the
potential for impacts to groundwater by determining soil permeability and other characteristics that affect
water movement, in addition to issues related to erosion and seismic hazards.

3.8

Hazards and Hazardous Materials

Page 3-0 has been revised to Page 3-26 and the subsequent pages have been revised to be in their proper
consecutive order. In addition, Mitigation Measures HAZ-1 and HAZ-2 below have been hereby revised
as follows.
Mitigation Measure HAZ-1: Store, Handle, Use Hazardous Materials in Accordance with
Applicable Laws. The City shall ensure that all construction-related hazardous materials and hazardous
wastes shall be stored, handled, and used in a manner consistent with relevant and applicable federal,
state, and local laws and done in a manner that protects surface waters and groundwater. In addition,
construction-related hazardous materials and hazardous wastes shall be staged and stored away from
stream channels and steep banks to keep these materials a safe distance from near-by residents and
prevent them from entering surface waters in the event of an accidental release. Additionally, the City
shall develop a spill contingency plan that addresses measures to address spills and leaks of hazardous
materials as well as appropriate use of adequate storage containers for containment.
Mitigation Measure HAZ-3: Properly Dispose of Hydrostatic Test Water. Dewatering and of the
pipeline during hydrostatic testing in the during construction phase as well as any dewatering needed as a
result of operations and maintenance activities shall be discharged to land and not into any creeks,
drainages, or waterways and shall require prior approval from the North Coast Regional Water Quality
Control Board.

3.9

Hydrology and Water Quality

On Pages 3-5 and 3-6 of the Public Draft IS/MND (now pages 3-31 and 3-32), the discussion under item
(a) is hereby revised as follows.
Discussion
(a) Less-than-Significant Impact with Mitigation.
Excavation, grading, and construction
activities associated with the Proposed Project/Action could violate water quality as those
activities would expose and disturb soils, resulting in potential increases in erosion and siltation
in the Project area. Construction during the rainy season could result in increases in erosion,

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station, and water quality issues. Generally, excavation, grading, paving, and other construction
activities would expose disturbed and loosened soils to erosion by wind and runoff. Construction
activities could therefore result in increased erosion and siltation, including nutrient loading and
increasing the total suspended solids concentration. Erosion and siltation from construction have
the potential to impact the creeks and drainage crossings, therefore posing a potentially
significant impact to water quality. With the incorporation of the following mitigation, any
potential impacts to water quality are reduced to less-than-significant levels.
Mitigation Measure HWQ-1: Implement Construction Best Management Practices.
To reduce potentially significant erosion and siltation, the City and/or its selected
contractor(s) shall obtain a Stormwater Pollution Prevention Permit (SWPPP) and
implement Best Management Practices and erosion control measures as required by the
North Coast RWQCB. Best Management Practices to reduce erosion and siltation shall
include the following measures: Avoidance of construction activities during inclement
weather; limitation of construction access routes and stabilization of access points;
stabilization of cleared, excavated areas by providing vegetative buffer strips, providing
plastic coverings, and applying ground base on areas to be paved; protection of adjacent
properties by installing sediment barriers or filters, or vegetative buffer strips;
stabilization and prevention of sediments from surface runoff from discharging into storm
drain outlets; use of sediment controls and filtration to remove sediment from water
generated by dewatering; and returning all drainage patterns to pre-existing conditions.
In addition, the operation of the Proposed Project/Action and application of recycled water will
increase salts and nutrient loadings on the soils which could result in significant impacts to
adjacent surface and groundwater resources. Agricultural farmers within the area maintain their
own onsite pumping and distribution systems to supply water to their crops. Depending on their
access and water rights, they rely on water from the Russian River and its tributaries as well as
groundwater. Groundwater and Russian River are similar in water quality and generally have an
average TDS level of approximately 224 milligrams per liter (mg/l)1. At build out, the Proposed
Project/Action would offset approximately 1,375 afy of that supply with recycled water for
irrigation purposes. The proposed new recycled water supply would have an average TDS level
of approximately 345 mg/l2 which would result in an approximately 54 percent increase in salt
loading for the 1,375 afy of water to be used for irrigation purposes. It is assumed that with
proper irrigation best management practices, recycled water operations would have an 80 percent
irrigation efficiency, meaning that 80 percent of the applied recycled water would be lost through
evapotranspiration and the remaining 20 percent of the flow would percolate through the root
zone. All of the applied salts are assumed to remain with the 20 percent flow and would
percolate into the groundwater as a result of winter rains. The increased salt loading would result
in approximately 200 tons per year. However, in context to the overall Ukiah Valley
Groundwater Basin which has a capacity of 324,000 acre-feet, this incremental increase is not
considered to be a significant impact. Also, recycled water has higher amounts of nitrogen,
phosphorus, and potassium than potable supplies. Thus, recycled water would help alleviate the
need to use fertilizers which are more readily applied if potable supplies are used for irrigation
and which are not accounted for in its TDS calculations. Further, with the implementation of the
following recycled water best management practices mitigation measures, any adverse impacts
can will be further reduced and remain to be less-than-significant.

1
2

California, Department of Water Resources (DWR), Californias Groundwater Basin, Bulletin 118. February 2004.
City of Ukiah, Reclaimed Water Effluent TDS Study. September 2012.

May 2013

4-4

City of Ukiah Recycled Water Project

Final IS/MND

Mitigation Measure HWQ-2: Implement Recycled Water Best Management

Practices. In order to help reduce the potential effects of increased salt loading potential
as a result of using recycled water, the City shall:

Ensure that water is applied consistent with Title 22 requirements and in amounts
(frequency and intensity) which meet the demands of the plant (agronomic rates), but
not in excessive amounts such that salts buildup in the soil beyond the root zone
and/or otherwise are leached to groundwater;
Ensure that adequate soil drainage is maintained;
Ensure that salt-sensitive plants are not to be spray wet; and
Addressing sodium and alkalinity concerns through addition of water and soil
amendments, including addition of gypsum.

In addition and prior to operation of the recycled water system, the City shall prepare and
submit for approval of the North Coast Regional Water Quality Control Board, a recycled
water operations and maintenance plan and recycled water users guide to identify general
and site-specific BMPs that will be implemented to ensure that recycled water will be
used in a manner that protects ground and surface water. The BMPs shall address
measures to protect against recycled water runoff that is not incidental, provide for
detection and correction of leaks, and ensure that pollutants such as salts and nutrients are
not discharged at concentrations that could adversely impact groundwater. The BMPs
shall also address both agronomic irrigation and frost protection uses.
Specifically, the recycled water for irrigation BMPs shall include the type of irrigation
system, proper design and operation of the irrigation system, application methods (e.g.,
agronomic application, use of repeat start times and multiple water days to increase
irrigation efficiency and reduce runoff potential, no application during precipitation
events), setbacks to surface waters, physical systems to capture runoff and prevent it from
reaching surface waters. BMPs shall also describe how salts and nutrients will be
managed in a manner that protects groundwater quality.
Frost protection BMPs shall include limiting frost protection use to relatively flat parcels,
use of very low application rates for the shortest period possible, pre-season system
inspections and testing, regular in-season system checks, inspection checks during spray
events that include checking for ponding and runoff, logging of spray events, and
maintenance of a cover crop between vineyard rows to provide capacity for retention and
limited treatment.

Mitigation Measure HWQ-3: Prepare Antidegradation Analysis. Prior to

implementation, the City shall prepare and submit to the North Coast Regional Water
Board an antidegradation analysis as part of its Report of Waste Discharge that
demonstrates that the storage and irrigation of recycled water will not result in
degradation of groundwater or surface water. The analysis shall identify the fate and
transport of pollutants of concern, and shall address salts, nutrients, and any other
pollutants that could be present in the recycled water at concentrations that could
affect groundwater quality. For the pond(s), the analysis shall determine the leakage
rate through the pond liner and the impact of pond leakage on groundwater and
nearby surface water. The analysis shall determine whether there are any anticipated
increases in pollutant concentrations over background groundwater quality. If any

May 2013

4-5

City of Ukiah Recycled Water Project

Final IS/MND

potential degradation is identified, the analysis shall demonstrate that any degradation
is in the best interest of the people of the state and that it will not result in the
exceedance of any groundwater quality objectives. This antidegradation analysis shall
be prepared and submitted as part of a Report of Waste Discharge.
With the implementation of Mitigation Measures HWQ-1, and HWQ-2, and HWQ-3, any
water quality impacts as a result of the use of recycled water will be reduced to less-thansignificant levels. No additional mitigation measures or demineralization facilities would be
required.

May 2013

4-6

Appendix A
Mitigation Monitoring and Reporting Program
City of Ukiah Recycled Water Project

MITIGATION MONITORING AND REPORTING PROGRAM

City of Ukiah
Recycled Water Project
Final Initial Study / Mitigated Negative Declaration
SCH #2013032072

Prepared for:
City of Ukiah
Public Works Administration Office
300 Seminary Avenue
Ukiah, CA 95482

Prepared by:

SMB Environmental, Inc.

May 2013

INTRODUCTION

In May 2013, the City prepared a Final IS/MND according to CEQA

Guidelines and incorporates all comments received by the State
Clearinghouse and the City during the 30-day public review period. As a
result, some of the mitigation measures identified in the Public Draft
IS/MND have been revised to reflect those comments. Based on the Final
IS/MND, the Proposed Project/Action would not result in new significant
impacts, substantially increase the severity of previously disclosed impacts,
or involve any of the other conditions related to changed circumstances or
new information that can require a subsequent or supplemental EIR under
Public Resources Code section 21166 and CEQA Guidelines section 15162
beyond those impacts and conditions already identified in the Citys Public
Draft IS/MND.

Pursuant to the California Environmental Quality Act (CEQA; Public

Resources Code Section 21000, et seq. and CEQA Guidelines), the City of
Ukiah, California (City) prepared a Public Draft Initial Study/Mitigated
Negative Declaration (IS/MND) to evaluate potential environmental impacts
associated with the Citys proposed Recycled Water Project (Proposed
Project/Action). The purpose of the Proposed Project/Action is to
replace/augment existing water supplies in Ukiah Valley. Recycled water use
within the Ukiah Valley would offset existing and future water demands for
irrigation and frost protection of agricultural land, and in doing so, would
support the local agricultural industry. It would also offset urban irrigation
demands, ease storage limitations at the Ukiah Wastewater Treatment Plant
(UWWTP) and reduce treated wastewater discharges to the Russian River.

PURPOSE OF MITIGATION MONITORING AND REPORTING

PROGRAM

CEQA Guidelines require public agencies to adopt a Mitigation Monitoring

and Reporting Program (MMRP) for changes to the project which it has
adopted or made a condition of project approval in order to mitigate or avoid
significant effects on the environment. A MMRP is required for the proposed
project because the IS/MND identifies potentially significant adverse impacts
related to project implementation, and mitigation measures have been
identified to reduce those impacts.

This MMRP has been prepared to ensure that all required mitigation
measures are implemented and completed in a satisfactory manner before
and during project construction and operation. The MMRP may be modified
by the City during project implementation, as necessary, in response to
changing conditions or other refinements. Table A (included at the end of
this document) has been prepared to assist the responsible parties in
implementing the mitigation measures. The table identifies individual
mitigation
measures,
monitoring/mitigation
timing,
responsible
person/agency for implementing the measure, monitoring and reporting
procedure, and space to confirm implementation of the mitigation measures.
The numbering of mitigation measures follows the numbering sequence
found in the Public Draft IS/MND.

On March 27, 2013, to initiate public review of the Draft IS/MND, the City
filed a Notice of Completion (NOC) for the project with the Governors
Office of Planning and Research (State Clearinghouse or SCH) and the
County of Mendocino and released the Draft IS/MND for a 30-day public
review. The State Clearinghouse identified the project with SCH
#2013032072. The public review period was established between March 27
and April 26, 2013, with copies of the Draft IS/MND available for review at
the Citys Public Works Administration Office, at 300 Seminary Avenue,
Ukiah, CA 95482; and the Main Branch Library, 105 North Main Street,
Ukiah, CA 95482. On March 27, 2013, the Ukiah Daily Journal published
the Notice of Intent/Notice of Availability (NOI/NOA) to adopt a Mitigated
Negative Declaration for the Proposed Project/Action. A Public Draft of the
IS/MND
was
also
posted
on
the
Citys
website
at
http://www.cityofukiah.com/.

ROLES AND RESPONSIBILITIES

Unless otherwise specified herein, the City is responsible for taking all
actions necessary to implement the mitigation measures under its jurisdiction
according to the specifications provided for each measure and for
demonstrating that the action has been successfully completed. The City, at
its discretion, may delegate implementation responsibility or portions thereof
to a licensed contractor or other designated agent. The City would be
responsible for overall administration of the MMRP and for verifying that

Recycled Water Project

City of Ukiah
Mitigation Monitoring and Reporting Program
2

City staff members and/or the construction contractor has completed the
necessary actions for each measure.

The categories identified in Table A are described below.

The City would designate a project manager to oversee implementation of

the MMRP. The City of Ukiahs Public Works Department is primarily
responsible for implementing the mitigation measures for the Proposed
Project as described in this MMRP. Duties of the project manager include the
following:

Ensure that routine inspections of the construction site are conducted

by appropriate City staff; check plans, reports, and other documents
required by the MMRP; and conduct report activities.

Serve as a liaison between the City and the contractor or project

applicant regarding mitigation monitoring issues.

Complete forms and maintain reports and other records and

documents generated by the MMRP.

Coordinate and ensure that corrective actions or enforcement

measures are taken, if necessary.

Mitigation Measure This column provides the text of the

mitigation measures identified in the IS/MND.

Timing This column identifies the time frame in which the

mitigation will take place.

Enforcement This column identifies the party responsible for

enforcing compliance with the requirements of the mitigation
measure.

Dated Signature for Verification of Compliance This column is

to be dated and signed by the person (either project manager or
his/her designee) responsible for verifying compliance with the
requirements of the mitigation measure.

The responsible party for implementation of each item would identify the
staff members responsible for coordinating with the City on the MMRP.
REPORTING
The Citys project manager shall prepare a monitoring report, upon
completion of the project, on the compliance of the activity with the required
mitigation measures. Information regarding inspections and other
requirements shall be compiled and explained in the report. The report shall
be designed to simply and clearly identify whether mitigation measures have
been adequately implemented. At a minimum, each report shall identify the
mitigation measures or conditions to be monitored for implementation,
whether compliance with the mitigation measures or conditions has occurred,
the procedures used to assess compliance, and whether further action is
required. The report shall be presented to the City Council.
MITIGATION MONITORING AND REPORTING PLAN TABLE
Recycled Water Project

City of Ukiah
Mitigation Monitoring and Reporting Program
3

Table A
Mitigation Monitoring and Reporting Plan for the City of Ukiahs Recycled Water Project IS/MND
Mitigation Measure

3.3 AIR QUALITY

Mitigation Measure AIR-1: Dust Control. During all phases of construction,
the following dust control procedures shall be implemented:

Water all active construction sites as necessary.

Cover all trucks having soil, sand, or other loose material or maintain
at least two feet of freeboard on all trucks.

Apply water as necessary, or apply non-toxic soil stabilizers on all

unpaved access roads, parking areas and staging areas at construction
sites.

Sweep if visible soil material is carried into adjacent streets.

Water or apply non-toxic soil binders to exposed soil stockpiles.

Limit traffic speeds on unpaved areas to 15 mph.

3.4 BIOLOGICAL RESOURCES

Mitigation Measure BIO-1: Conduct Breeding/Nesting Surveys. For
construction activities that occur between February 1 and August 31,
preconstruction breeding bird surveys shall be conducted by a qualified biologist
prior to and within 10 days of any initial ground-disturbance activities. Surveys
shall be conducted within all suitable nesting habitat within 250 feet of the
activity. All active, non-status passerine nests identified at that time should be
protected by a 50 foot radius minimum exclusion zone. Active raptor or specialstatus species nests should be protected by a buffer with a minimum radius of
200 feet. CDFW and USFWS recommend that a minimum 500-foot exclusion
buffer be established around active white-tailed kite and golden eagle nests. The
following considerations apply to this mitigation measure:

Survey results are valid for 14 days from the survey date. Should
ground disturbance commence later than 14 days from the survey date,
surveys should be repeated. If no breeding birds are encountered, then
work may proceed as planned.

Exclusion zone sizes may vary, depending on habitat characteristics

and species, and are generally larger for raptors and colonial nesting
birds. Each exclusion zone would remain in place until the nest is
abandoned or all young have fledged.

Implementation1

Timing

Prior to
construction of
The Proposed
Project/Action.

City of Ukiah Public

Works Department

Prior to and during

construction of the
Proposed
Project/Action.

City of Ukiah Public

Works Department

Enforcement1

Dated Signature for

Verification of Compliance

City of Ukiah Public Works

Department
Mendocino County Air
Quality Management District

City of Ukiah Public Works

Department
California Department of Fish
and Wildlife
U.S. Fish and Wildlife
Service

The City of Ukiahs Public Works Department is primarily responsible for implementing the mitigation measures for the Proposed Project/Action as described in this MMRP.
Recycled Water Project
4

City of Ukiah
Mitigation Monitoring and Reporting Program

Table A
Mitigation Monitoring and Reporting Plan for the City of Ukiahs Recycled Water Project IS/MND
Mitigation Measure

Implementation1

Timing

Enforcement1

Dated Signature for

Verification of Compliance

The non-breeding season is defined as September 1 to January 31.

During this period, breeding is not occurring and surveys are not
required. However, if nesting birds are encountered during work
activities in the non-breeding season, disturbance activities within a
minimum of 50 feet of the nest should be postponed until the nest is
abandoned or young birds have fledged.

Mitigation Measure BIO-2: Conduct A Preconstruction Survey for Western

Pond Turtles and Relocate, if Necessary. A qualified biologist shall conduct a
pre-construction survey for western pond turtles no more than 30 days prior to
construction in suitable aquatic habitats within the project corridor, including
stream crossings, drainage ditches, and culverts. A combination of visual and
trapping surveys may be performed with authorization from CDFW. If the
species is found near any proposed construction areas, impacts on individuals
and their habitat shall be avoided to the extent feasible. If occupied habitat can be
avoided, an exclusion zone shall be established around the habitat and temporary
plastic fencing shall be installed around the buffer area with Sensitive Habitat
Area signs posted and clearly visible on the outside of the fence. If avoidance is
not possible and the species is determined to be present in work areas, the
biologist with approval from CDFW may capture turtles prior to construction
activities and relocate them to nearby, suitable habitat a minimum of 300 feet
downstream from the work area. Exclusion fencing should then be installed if
feasible to prevent turtles from reentering the work area. For the duration of work
in these areas the biologist should conduct monthly follow-up visits to monitor
effectiveness.

Prior to and during

construction of the
Proposed
Project/Action.

City of Ukiah Public

Works Department

Mitigation Measure BIO-3: Avoid cutting through the creeks. As described

in the Proposed Project/Action description, all of the creek crossings will be
crossed by using trenchless construction techniques in the dry season.
Specifically, no pipeline construction activities shall occur between December 1
and May 31 (a work window identified by the National Marine Fisheries
Service), which is the period when adult and juvenile salmonids are likely to
occur in the Russian River. Construction crews shall avoid entering the stream
channels during installation.

Prior to and during

construction of the
Proposed
Project/Action.

City of Ukiah Public

Works Department

Mitigation Measure BIO-4: Implement Construction Best Management

Practices. To reduce potentially significant erosion and siltation, the City and/or
its selected contractor(s) shall obtain a Stormwater Pollution Prevention Permit
(SWPPP) and implement Best Management Practices and erosion control
measures as required by the North Coast RWQCB. Best Management Practices
to reduce erosion and siltation shall include, at a minimum, the following

Prior to the
construction of
the Proposed
Project

City of Ukiah Public Works

Department
California Department of Fish
and Wildlife

City of Ukiah Public Works

Department
North Coast Regional Water
Quality Control Board
National Marine Fisheries
Service

City of Ukiah Public

Works Department

City of Ukiah Public Works

Department
North Coast Regional Water
Quality Control Board

Recycled Water Project

City of Ukiah
Mitigation Monitoring and Reporting Program
5

Table A
Mitigation Monitoring and Reporting Plan for the City of Ukiahs Recycled Water Project IS/MND
Mitigation Measure

Implementation1

Timing

Enforcement1

Dated Signature for

Verification of Compliance

measures: Avoidance of construction activities during inclement weather;

limitation of construction access routes and stabilization of access points;
stabilization of cleared, excavated areas by providing vegetative buffer strips,
providing plastic coverings, and applying ground base on areas to be paved;
protection of adjacent properties by installing sediment barriers or filters, or
vegetative buffer strips; stabilization and prevention of sediments from surface
runoff from discharging into storm drain outlets; use of sediment controls and
filtration to remove sediment from water generated by dewatering; and returning
all drainages to preconstruction conditions. Construction crews shall avoid
entering the stream channels during installation.
Mitigation Measure BIO-5:
Develop and Implement a Frac-Out
Contingency Plan for Trenchless Construction Activities. For trenchless
construction activities that use drilling lubricants, the City or its contractor shall
prepare and implement a frac-out contingency plan that is intended to minimize
the potential for a frac-out associated with tunneling activities; provide for the
timely detection of frac-outs; and ensure an organized, timely, and minimumimpact response in the event of a frac-out and release of drilling lubricant (i.e.,
bentonite). The contingency plan will require, at a minimum, the following
measures.

Trenchless construction activities to be conducted during a work

window identified by the National Marine Fisheries Service when adult
and juvenile salmonids are not present in the project area (June 1
through November 30).

A full-time monitor will attend all drilling to look for observable fracout conditions or lowered pressure readings on drilling equipment. If a
frac-out is identified, all work will stop, including the recycling of
drilling lubricant. In the event of a frac-out into water, the pressure of
water above the tunnel will keep excess mud from escaping through the
fracture. The location and extent of the frac-out will be determined, and
the frac-out will be monitored for 4 hours to determine whether the
drilling lubricant congeals (bentonite will usually harden, effectively
sealing the frac-out location).

If the drilling lubricant congeals, no other actions will be taken that

would potentially suspend sediments in the water column.

Surface releases of bentonite will be allowed to harden and then will be

removed.

Prior to and during

construction of the
Proposed
Project/Action.

Recycled Water Project

City of Ukiah Public

Works Department

City of Ukiah Public Works

Department

City of Ukiah
Mitigation Monitoring and Reporting Program
6

Table A
Mitigation Monitoring and Reporting Plan for the City of Ukiahs Recycled Water Project IS/MND
Mitigation Measure

Implementation1

Timing

Enforcement1

Dated Signature for

Verification of Compliance

The contingency plan will identify additional measures to be taken to

contain or remove the drilling lubricant if it does not congeal.

Mitigation Measure BIO-6: Obtain all Required Authorizations. Prior to

issuance of encroachment permits for the Proposed Project/Action, the City, as
necessary, shall conduct a wetlands delineation study in sensitive areas of the
Proposed Project/Action and obtain all required authorization from agencies with
jurisdiction riparian habitats and jurisdictional wetlands in the area. Such
agencies may include, but are not limited to, the United States Army Corps of
Engineers, the California Department of Fish and Wildlife, and the North Coast
Regional Water Quality Control Board. Impacted habitat shall be offset through
onsite restoration, offsite restoration, or purchase of credits at a CDFW and
USFWS-approved mitigation bank in the region at no less than a 1:1 ratio.

Prior to and during

construction of the
Proposed
Project/Action.

City of Ukiah Public

Works Department

City of Ukiah Public Works

Department
North Coast Regional Water
Quality Control Board
California Department of Fish
and Wildlife
U.S. Fish and Wildlife
Service
U.S. Army Corps of
Engineers

3.5 CULTURAL RESOURCES

Mitigation Measure CR-1:
Conduct Pre-construction Survey and
Avoidance of Identified Cultural Resources. Prior to and/or during the
engineering and final design phase, a qualified professional archeologist or
cultural resources specialist will provide a final pre-construction survey of the
exact proposed pipeline alignment and placement of the project facilities within
the proposed construction corridor and ensure that the construction activities of
the Proposed Project/Action will not affect the archeological resources P-23004814, P-23-004815, and P-23-003663 as identified by NWIC above. In the
unlikely event that the Proposed Project/Action could affect these resources, the
proposed project facilities shall be constructed in a manner that will avoid
damaging these resources. Specifically, the pipeline shall either be installed by
avoidance of the resource by realignment of the pipeline or facility around the
resource(s) and/or as in the case of crossing the Northwestern Railroad, the
resource shall be avoided by going beneath through the implementation of
horizontal directional drilling (HDD) or another equally effective construction
technique(s). In addition, the archeological resource sites shall include the
installation of barrier fencing or other physical barriers to prevent construction
personnel and vehicles from coming onto the sites during construction. During
construction, the area shall be monitored by a professional archaeologist to
ensure that (1) barrier fencing is maintained, (2) vehicles and workers do in fact
remain off the site, and (3) violations of the exclusion area are reported and
infractions are policed in accordance with treatment of other environmental
violations. Any construction or postconstruction use of the road adjacent to the
sites in support of the pipeline shall be confined to the road which shall be used

Prior to and
throughout
construction

City of Ukiah Public

Works Department

Recycled Water Project

City of Ukiah Public

Works Department

City of Ukiah
Mitigation Monitoring and Reporting Program
7

Table A
Mitigation Monitoring and Reporting Plan for the City of Ukiahs Recycled Water Project IS/MND
Mitigation Measure

Implementation1

Timing

Enforcement1

Dated Signature for

Verification of Compliance

as is and shall not be modified by grading or expanded in width.

Mitigation Measure CR-2: Halt work if cultural resources are discovered.
In the event that any prehistoric or historic subsurface cultural resources are
discovered during ground disturbing activities, all work within 100 feet of the
resources shall be halted and after notification, the City shall consult with a
qualified archaeologist to assess the significance of the find. If any find is
determined to be significant (CEQA Guidelines 15064.5[a][3] or as unique
archaeological resources per Section 21083.2 of the California Public Resources
Code), representatives of the City and a qualified archaeologist shall meet to
determine the appropriate course of action. In considering any suggested
mitigation proposed by the consulting archaeologist in order to mitigate impacts
to historical resources or unique archaeological resources, the lead agency shall
determine whether avoidance is necessary and feasible in light of factors such as
the nature of the find, project design, costs, and other considerations. If
avoidance is infeasible, other appropriate measures (e.g., data recovery) shall be
instituted. Work may proceed on other parts of the project site while mitigation
for historical resources or unique archaeological resources is carried out.

Upon discovery of
cultural resources

City of Ukiah Public

Works Department

City of Ukiah Public Works

Department

Mitigation Measure CR-3: Stop work if paleontological remains are

discovered. If paleontological resources, such as fossilized bone, teeth, shell,
tracks, trails, casts, molds, or impressions are discovered during
ground-disturbing activities, work will stop in that area and within 100 feet of the
find until a qualified paleontologist can assess the significance of the find and, if
necessary, develop appropriate treatment measures in consultation with the City.

Before and during

ground-disturbing
activities.

City of Ukiah Public

Works Department

City of Ukiah Public Works

Department

Mitigation Measure CR-4: Halt work if human remains are found. If

human remains are encountered during excavation activities conducted for the
Proposed Project/Action, all work in the adjacent area shall stop immediately and
the Mendocino County Coroners office shall be notified. If the Coroner
determines that the remains are Native American in origin, the Native American
Heritage Commission shall be notified and will identify the Most Likely
Descendent, who will be consulted for recommendations for treatment of the
discovered human remains and any associated burial goods.

Upon the
discovery of
suspected human
remains.

City of Ukiah Public

Works Department

For actions taken to satisfy

the requirements of Section
106: the State Historic
Preservation Office (SHPO)
For all project-related
improvements that would be
located within the City of
Ukiah and County of
Mendocino: City of Ukiah
Public Works Department and
Mendocino County Coroner

3.6 GEOLOGY AND SOILS

Recycled Water Project

City of Ukiah
Mitigation Monitoring and Reporting Program
8

Table A
Mitigation Monitoring and Reporting Plan for the City of Ukiahs Recycled Water Project IS/MND
Mitigation Measure

Mitigation Measure GEO-1: Perform Geotechnical Investigation. The City

shall require a design-level geotechnical study to be prepared prior to project
implementation to determine proper design and construction methods, including
any cathodic protection measures needed for installing the pipelines in these soils
as well as the design of the storage pond(s). The geotechnical study shall
evaluate the potential for impacts to groundwater by determining soil permability
and other characteristics that affect water movement, in addition to issues related
to erosion and seismic hazards.

Implementation1

Timing

Enforcement1

Prior to
completion of
engineering plans
for the Proposed
Project/Action.

City of Ukiah Public

Works Department

City of Ukiah Public Works

Department

Prior to
construction and
operation the
Proposed
Project/Action

City of Ukiah Public

Works Department

City of Ukiah Public Works

Department

Mitigation Measure HAZ-2: Properly Dispose of Contaminated Soil and/or

Groundwater. If contaminated soil and/or groundwater is encountered or if
suspected contaminated is encountered during project construction, work shall be
halted in the area, and the type and extent of the contamination shall be
identified. A contingency plan to dispose of any contaminated soil or
groundwater will be developed through consultation with appropriate regulatory
agencies.
Mitigation Measure HAZ-3: Properly Dispose of Hydrostatic Test Water.
Dewatering and of the pipeline during hydrostatic testing in the construction
phase as well as any dewatering needed as a result of operations and maintenance
activities shall be discharged to land and not into any creeks, drainages, or
waterways and shall require prior approval from the North Coast Regional Water
Quality Control Board.

Prior to
construction and
operation the
Proposed
Project/Action

City of Ukiah Public

Works Department

City of Ukiah Public Works

Department

Prior to
construction and
operation the
Proposed
Project/Action

City of Ukiah Public

Works Department

City of Ukiah Public Works

Department

Mitigation Measure HAZ-4: Consult with FAA, Ukiah Municipal Airport,

USFWS, and CDFW. The City shall initiate consultation with the Ukiah
Municipal Airport operations manager as well as with the FAA, USFWS, and
CDFW to disclose plans for developing the new wastewater storage facility and

Prior to
construction and
operation the
Proposed

City of Ukiah Public

Works Department

City of Ukiah Public Works

Department

3.8 HAZARDS AND HAZARDOUS MATERIALS

Mitigation Measure HAZ-1: Store, Handle, Use Hazardous Materials in
Accordance with Applicable Laws. The City shall ensure that all constructionrelated hazardous materials and hazardous wastes shall be stored, handled, and
used in a manner consistent with relevant and applicable federal, state, and local
laws and done in a manner that protects surface waters and groundwater. In
addition, construction-related hazardous materials and hazardous wastes shall be
staged and stored away from stream channels and steep banks to keep these
materials a safe distance from near-by residents and prevent them from entering
surface waters in the event of an accidental release. Additionally, the City shall
develop a spill contingency plan that addresses measures to address spills and
leaks of hazardous materials as well as appropriate use of adequate storage
containers for containment.

Recycled Water Project

Dated Signature for

Verification of Compliance

Ukiah Municipal Airport

City of Ukiah
Mitigation Monitoring and Reporting Program

Table A
Mitigation Monitoring and Reporting Plan for the City of Ukiahs Recycled Water Project IS/MND
Mitigation Measure

seek their input resulting in the development of a specific plan and/or

management activities to avoid or reduce the potential for attracting hazardous
wildlife movement into or across the approach or departure airspace.

Implementation1

Timing

Enforcement1

Dated Signature for

Verification of Compliance

Project/Action.
Federal Aviation
Administration
California Department of Fish
and Wildlife

Mitigation Measure HAZ -5: Develop and Maintain Emergency Access

Strategies. In conjunction with Mitigation Measure Traffic-1: Develop a Traffic
Control Plan identified below in the Traffic and Transportation section,
comprehensive strategies for maintaining emergency access shall be developed.
Strategies shall include, but not limited to, maintaining steel trench plates at the
construction sites to restore access across open trenches and identification of
alternate routing around construction zones. Also, police, fire, and other
emergency service providers shall be notified of the timing, location, and
duration of the construction activities and the location of detours and lane
closures.
3.9 HYDROLOGY AND WATER QUALITY
Mitigation Measure HWQ-1: Implement Construction Best Management
Practices. To reduce potentially significant erosion and siltation, the City and/or
its selected contractor(s) shall obtain a Stormwater Pollution Prevention Permit
(SWPPP) and implement Best Management Practices and erosion control
measures as required by the North Coast RWQCB. Best Management Practices
to reduce erosion and siltation shall include the following measures: Avoidance
of construction activities during inclement weather; limitation of construction
access routes and stabilization of access points; stabilization of cleared,
excavated areas by providing vegetative buffer strips, providing plastic
coverings, and applying ground base on areas to be paved; protection of adjacent
properties by installing sediment barriers or filters, or vegetative buffer strips;
stabilization and prevention of sediments from surface runoff from discharging
into storm drain outlets; use of sediment controls and filtration to remove
sediment from water generated by dewatering; and returning all drainage patterns
to pre-existing conditions.
Mitigation Measure HWQ-2: Implement Recycled Water Best Management
Practices. In order to help reduce the potential effects of increased salt loading
potential as a result of using recycled water, the City shall:
Ensure that water is applied consistent with Title 22 requirements and in amounts

Prior to
construction and
operation the
Proposed
Project/Action.

City of Ukiah Public

Works Department

U.S. Fish and Wildlife

Service
City of Ukiah Public Works
Department

Develop SWPPP
prior to and
throughout
construction.

City of Ukiah Public

Works Department

City of Ukiah Public Works

Department

Incorporation
measures into
SWPPP prior to
construction and
implementation

City of Ukiah Public

Works Department

Recycled Water Project

North Coast Regional Water

Quality Control Board

City of Ukiah Public Works

Department
North Coast Regional
Water Quality Control Board
City of Ukiah
Mitigation Monitoring and Reporting Program

10

Table A
Mitigation Monitoring and Reporting Plan for the City of Ukiahs Recycled Water Project IS/MND
Mitigation Measure

(frequency and intensity) which meet the demands of the plant (agronomic rates),
but not in excessive amounts such that salts buildup in the soil beyond the root
zone and/or otherwise are leached to groundwater;

Implementation1

Timing

Enforcement1

Dated Signature for

Verification of Compliance

throughout
construction,
as appropriate

Ensure that adequate soil drainage is maintained;

Ensure that salt-sensitive plants are not to be spray wet; and
Addressing sodium and alkalinity concerns through addition
of water and soil amendments, including addition of gypsum.

In addition and prior to operation of the recycled water system, the City shall
prepare and submit for approval of the North Coast Regional Water Quality
Control Board, a recycled water operations and maintenance plan and recycled
water users guide to identify general and site-specific BMPs that will be
implemented to ensure that recycled water will be used in a manner that protects
ground and surface water. The BMPs shall address measures to protect against
recycled water runoff that is not incidental, provide for detection and correction
of leaks, and ensure that pollutants such as salts and nutrients are not discharged
at concentrations that could adversely impact groundwater. The BMPs shall also
address both agronomic irrigation and frost protection uses.
Specifically, the recycled water for irrigation BMPs shall include the type of
irrigation system, proper design and operation of the irrigation system,
application methods (e.g., agronomic application, use of repeat start times and
multiple water days to increase irrigation efficiency and reduce runoff potential,
no application during precipitation events), setbacks to surface waters, physical
systems to capture runoff and prevent it from reaching surface waters. BMPs
shall also describe how salts and nutrients will be managed in a manner that
protects groundwater quality.
Frost protection BMPs shall include limiting frost protection use to relatively flat
parcels, use of very low application rates for the shortest period possible, preseason system inspections and testing, regular in-season system checks,
inspection checks during spray events that include checking for ponding and
runoff, logging of spray events, and maintenance of a cover crop between
vineyard rows to provide capacity for retention and limited treatment.
Mitigation Measure HWQ-3: Prepare Antidegradation Analysis. Prior to
implementation, the City shall prepare and submit to the North Coast Regional
Water Board an antidegradation analysis as part of its Report of Waste Discharge
that demonstrates that the storage and irrigation of recycled water will not result
in degradation of groundwater or surface water. The analysis shall identify the
fate and transport of pollutants of concern, and shall address salts, nutrients, and

Development of
the Report of
Waste Discharge.

City of Ukiah Public

Works Department

City of Ukiah Public Works

Department
North Coast Regional
Water Quality Control Board

Recycled Water Project

City of Ukiah
Mitigation Monitoring and Reporting Program
11

Table A
Mitigation Monitoring and Reporting Plan for the City of Ukiahs Recycled Water Project IS/MND
Mitigation Measure

Implementation1

Timing

Enforcement1

Dated Signature for

Verification of Compliance

any other pollutants that could be present in the recycled water at concentrations
that could affect groundwater quality. For the pond(s), the analysis shall
determine the leakage rate through the pond liner and the impact of pond leakage
on groundwater and nearby surface water. The analysis shall determine whether
there are any anticipated increases in pollutant concentrations over background
groundwater quality. If any potential degradation is identified, the analysis shall
demonstrate that any degradation is in the best interest of the people of the state
and that it will not result in the exceedance of any groundwater quality
objectives. This antidegradation analysis shall be prepared and submitted as part
of a Report of Waste Discharge.
3.12 NOISE
Mitigation Measure NOI-1: Limit Construction Hours. Construction
activities will be limited to the least noise-sensitive times and will comply with
both the City and Mendocino County noise ordinances. Construction, alteration,
repair or land development activities shall be allowed on weekdays between the
hours of 7 a.m. and 7 p.m., on Saturdays between the hours of 8 a.m. and 5 p.m.
No construction shall be permitted on Sundays.

Prior to and during

construction of the
Proposed
Project/Action.

City of Ukiah Public

Works Department

City of Ukiah Public Works

Department

Mitigation Measure NOI-2: Locate Staging Areas away from Sensitive

Receptors. The Citys construction specification shall require that the contractor
select staging areas as far as feasibly possible from sensitive receptors.

Prior to and during

construction of the
Proposed
Project/Action.

City of Ukiah Public

Works Department

City of Ukiah Public Works

Department

Mitigation Measure NOI-3: Maintain Mufflers on Equipment. The Citys

construction specifications shall require the contractor to maintain all
construction equipment with manufacturers specified noise-muffling devices.

Prior to and during

construction of the
Proposed
Project/Action.
Prior to and during
construction of the
Proposed
Project/Action.

City of Ukiah Public

Works Department

City of Ukiah Public Works

Department

City of Ukiah Public

Works Department

City of Ukiah Public Works

Department

Prior to and during

construction of the
Proposed
Project/Action.

City of Ukiah Public

Works Department

City of Ukiah Public Works

Department

Prior to and during

construction of the
Proposed

City of Ukiah Public

Works Department

City of Ukiah Public Works

Department

Mitigation Measure NOI-4: Idling Prohibition and Enforcement. The City

shall prohibit and enforce unnecessary idling of internal combustion engines. In
practice, this would mean turning off equipment if it will not be used for five or
more minutes.
Mitigation Measure NOI-5: Equipment Location and Shielding. The City
shall require locating all stationary noise-generating construction equipment such
as air compressors as far as possible from homes and businesses.
3.17 TRAFFIC AND TRANSPORTATION
Mitigation Measure TRA-1: Prepare and Implement Traffic Control Plan.
As is consistent with existing policy, the City shall require the contractor to
Recycled Water Project

City of Ukiah
Mitigation Monitoring and Reporting Program
12

Table A
Mitigation Monitoring and Reporting Plan for the City of Ukiahs Recycled Water Project IS/MND
Mitigation Measure

Implementation1

Timing

prepare and implement effective traffic control plans in the areas of City and
County streets to show specific methods for maintaining traffic flows. Examples
of traffic control measures to be considered include: 1) use of flaggers to
maintain alternating one-way traffic while working on one-half of the street; 2)
use of advance construction signs and other public notices to alert drivers of
activity in the area; 3) use of positive guidance detour signing on alternate
access streets to minimize inconvenience to the driving public; 4) provisions for
emergency access and passage; and 5) designated areas for construction worker
parking.

Project/Action.

Mitigation Measure TRA-2: Return Roads to Pre-construction Condition.

Following construction, the City shall ensure that road surfaces that are damaged
during construction are returned to their pre-construction condition or better.

Prior to and during

construction of the
Proposed
Project/Action.

Recycled Water Project

City of Ukiah Public

Works Department

Enforcement1

Dated Signature for

Verification of Compliance

City of Ukiah Public Works

Department

City of Ukiah
Mitigation Monitoring and Reporting Program
13