Response to Comment 1-1
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Response to Comment 1-1

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INCREMENTAL RECYCLED WATER PROGRAM FINAL EIR RESPONSE TO COMMENTS COMMENT LETTER 404, MARIA J. CIPRIANI, ASSISTANT GENERAL MANAGER, SONOMA COUNTY AGRICULTURAL PRESERVATION & OPEN SPACE DISTRICT Response to Comment 404-1 Comment Summary: The comment expresses gratitude for the opportunity to comment on the Draft EIR. The City appreciates the comments. Response to Comment 404-2 Comment Summary: The comment asks that the Sonoma County Agricultural Preservation and Open Space District be added to the list, in Section 3.1 of the Draft EIR, of agencies from which approval may be necessary to implement the project. Section 3.1 of the Draft EIR does not list the agencies whose approval may be required for the Program; it lists applicable federal, state, regional, county, and local policies and regulations with which the Program may need to comply. The listing of agencies whose approval may be required for the Program is contained in Chapter 2 of the Draft EIR, and the Sonoma County Agricultural Preservation and Open Space District is included in the list of agencies on page 2-88. Response to Comment 404-3 Comment Summary: The comment asks that Mitigation Measure 3.3.2 and the citations of the Measure in Section 4.1 be clarified with respect to its application to lands held by the District in fee. The intent of Mitigation Measure 3.3.2 is that it would apply to lands in which the District holds an interest, whether in fee or through a conservation ...

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I N C R E M E N T A L R E C Y C L E D W A T E R P R O G R A M F I N A L E I R R E S P O N S E T O C O M M E N T S
C OMMENT L ETTER 404,  M ARIA J.  C IPRIANI ,  A SSISTANT G ENERAL M ANAGER ,  S ONOMA C OUNTY A GRICULTURAL P RESERVATION &  O PEN SPACE D ISTRICT  
Response to Comment 404-1 Comment Summary: The comment expresses gratitude for the opportunity to comment on the Draft EIR. The City appreciates the comments.
Response to Comment 404-2 Comment Summary: The comment asks that the Sonoma County Agricultural Preservation and Open Space District be added to the list, in Section 3.1 of the Draft EIR, of agencies from which approval may be necessary to implement the project. Section 3.1 of the Draft EIR does not list the agencies whose approval may be required for the Program; it lists applicable federal, state, regional, county, and local policies and regulations with which the Program may need to comply. The listing of agencies whose approval may be required for the Program is contained in Chapter 2 of the Draft EIR, and the Sonoma County Agricultural Preservation and Open Space District is included in the list of agencies on page 2 88. -
Response to Comment 404-3 Comment Summary: The comment asks that Mitigation Measure 3.3.2 and the citations of the Measure in Section 4.1 be clarified with respect to its application to lands held by the District in fee. The intent of Mitigation Measure 3.3.2 is that it would apply to lands in which the District holds an interest, whether in fee or through a conservation easement. Therefore the Draft EIR is revised as follows: Page 3-43, Mitigation Measure 3.3.2, first paragraph is revised:
3.3.2 Replacement of Open Space Easements The City shall contribute funds to the Sonoma County Agricultural Preservation and Open Space District to compensate for land acquired for a facility on the Districts land. that the District holds in fee, or land which is encumbered with District conservation easements if the Citys use is determined incompatible or inconsistent with the Districts interest as determined by the language in the easement. The contribution of funds would be based upon the total acreage of incompatible or inconsistent use of lands acquired by the City. The Citys monetary contribution shall be equal to the open space and natural resource value of the total acreage land acquired for the facility. The terms of acquisition and compensation shall be subject
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I N C R E M E N T A L R E C Y C L E D W A T E R P R O G R A M F I N A L E I R R E S P O N S E T O C O M M E N T S to approval by both the District and the City, and shall be incorporated in a Memorandum of Agreement to be signed by the City and the District. All monies contributed by the City shall be utilized in accordance with the Sonoma County Open Space Expenditure Plan. Pages 4.1-30 and 4.1-31 are revised:
Impact: 1.7.6. Will the Storage component convert public open space for IRWP facilities uses not in accordance with restrictions on use of the open space? Analysis : Significant: Alternatives 3 through 6  Potential reservoir sites may include properties for in which the Sonoma County Agricultural Preservation and Open Space District holds an interest. conservation easements. This could result in a use which is inconsistent, depending on the terms and conditions of the individual easement. If so, this would create a significant impact.  Alternatives 1, 2, and 7 do not have a Storage component. Mitigation: 3.3.2 Replacement of Open Space Easements After Mitigation: Less than Significant: Alternatives 3 through 6  Mitigation Measure 3.3.2 reduces this impact to a level below significance by providing funding to the Open Space District for the replacement on a one-for-one basis of existing acreage in which the District holds an interest and where the use is found to be incompatible with the Districts interest open space easements. This would allow purchase of interests in on new acreage in areas of comparable open space character and open space value identified by the Open Space District as a priority acquisition area. The conveyance of funds to the District for the purchase of interests in open space easements would ensure preservation of land as open space which is not now controlled by the District covered by open space easements and otherwise would not be assured of preservation as open space. Replacing the existing value of acreage in conservation easements on a one-for one basis would mitigate the impact of storage reservoirs on regional open space to less than significant. Pages 4.1-37 and 4.1-38 are revised:
 
Impact: 1.9.6. Will the Pump Stations and Tanks component convert public open space for uses not in accordance with restrictions on use of the open space? Analysis: Significant: Alternatives 3 through 6
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 Mitigation: After Mitigation:  
 
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I N C R E M E N T A L R E C Y C L E D W A T E R P R O G R A M F I N A L E I R R E S P O N S E T O C O M M E N T S Llano Pump Station Upgrade. The land south of the Llano Pump Station is not public open space or in a conservation easement, so there would be no impact. West College Pump Station. The site at the West College Ponds is not public open space or in a conservation easement, so there would be no impact. Booster Pump Stations, Geysers Pump Stations (Valley Section), and Urban Reuse Storage Tanks. Sites for these pump stations and tanks have not been determined. If sites for these facilities would be located on properties that are public open space and where the use is found to be incompatible with the Districts interest, the conversion to non-open space use would be a significant impact. Also, if sites would be located on private property in which the Sonoma County Agricultural Preservation and Open Space District holds an interest easements the construction of the facilities could potentially conflict with the status of the affected property as open space under the conservation easements and therefore could result in a loss of open space. This would be a significant impact. Geysers Pipeline Pump Stations (Mountain Section). At least one of the mountain pump stations may be located on property in which the Sonoma County Agricultural Preservation and Open Space District holds an interest. Construction of a pump station on such property could potentially conflict with the status of the affected property as open space under the conservation easements and therefore could result in a loss of open space. This would be a significant impact. Alternatives 1, 2 and 7 do not have a Pump Stations and Tanks component. 3.3.2 Replacement of Open Space Easements
Less than Significant: Alternatives 3 through 6 Mitigation Measure 3.3.2 reduces this impact to a level below significance by providing funding to the Open Space District for the replacement on a one-for-one basis of the existing value of acreage in which the District holds an interest and where the use is found to be incompatible with the Districts interest open space easements. This would allow purchase of interests in easements on new acreage in areas of comparable open space character and open space value identified by the Open Space District as a priority acquisition area. The conveyance of funds to the District for the purchase of interests in open space easements would ensure preservation of land as open space which is not now controlled by the District covered by open space easements and otherwise would not be assured of preservation as open space. Replacing existing acreage in conservation easements on a one-
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I N C R E M E N T A L R E C Y C L E D W A T E R P R O G R A M F I N A L E I R R E S P O N S E T O C O M M E N T S for one basis would mitigate the impact of pump stations and tanks on regional open space to less than significant. Page 4.1-42 is revised: Mitigation: 3.3.2 Replacement of Open Space Easements After Mitigation: Less than Significant: Alternative 6B   Mitigation Measure 3.3.2 reduces this impact to a level below significance by providing funding to the Open Space District for the replacement on a one-for-one basis of existing acreage in which the District holds an interest and where the use is found to be incompatible with the Districts interest open space easements. This would allow purchase of interests in on new acreage in areas of comparable open space character and open space value identified by the Open Space District as a priority acquisition area. The conveyance of funds to the District for the purchase of interests in open space easements would ensure preservation of land as open space which is not now controlled by the District covered by open space easements and otherwise would not be assured of preservation as open space. Replacing existing acreage in conservation easements on a one-for one basis would mitigate the impact of discharge facilities on regional open space to less than significant. Page 4.1-45 is revised: Mitigation: 3.3.2 Replacement of Open Space Easements After Mitigation: Less than Significant: Alternatives 6C through 6E  Mitigation Measure 3.3.2 reduces this impact to a level below significance by providing funding to the Open Space District for the replacement on a one-for-one basis of the existing value of acreage in which the District holds an interest and where the use is found to be incompatible with the Districts interest open space easements. This would allow purchase of interests in easements on new acreage in areas of comparable open space character and open space value identified by the Open Space District as a priority acquisition area. The conveyance of funds to the District for the purchase of interests in open space easements would ensure preservation of land as open space which is not now controlled by the District covered by open space easements and otherwise would not be assured of preservation as open space. Replacing the existing value of acreage in conservation easements on a one-for one basis would mitigate the impact of discharge facilities on regional open space to less than significant.
 
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Page 4.1-49 is revised: Impact: 1.13.6. Will the Advanced Membrane Treatment component convert public open space for uses not in accordance with restrictions on use of the open space? Analysis : Significant: Alternative 6   If a site for these facilities is located on properties that are public open space, the conversion to non-open space use would be a significant impact. Also, if a site is located on property in which the Sonoma County Agricultural Preservation and Open Space District holds an interest and where the use is found to be incompatible with the Districts interest easements the construction of the facilities could potentially conflict with the status of the affected property as open space under the conservation easements and therefore could result in a loss of open space. This would be a significant impact.  Alternatives 1, 2, 3, 4, 5 and 7 do not have an Advanced Membrane Treatment component.  Mitigation: 3.3.2 Replacement of Open Space Easements After Mitigation: Less than Significant: Alternative 6  Mitigation Measure 3.3.2 reduces this impact to a level below significance by providing funding to the Open Space District for the replacement on a one-for-one basis of the existing value of acreage in which the District holds an interest open space easements. This would allow purchase of interests in easements on new acreage in areas of comparable open space character and open space value identified by the Open Space District as a priority acquisition area. The conveyance of funds to the District for the purchase of interests in  open space easements would ensure preservation of land as open space which is not now controlled by the District covered by open space easements and otherwise would not be assured of preservation as open space. Replacing the existing value of acreage in conservation easements on a one-for one basis would mitigate the impact of Advanced Membrane Treatment facilities on regional open space to less than significant.
 
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I N C R E M E N T A L R E C Y C L E D W A T E R P R O G R A M F I N A L E I R R E S P O N S E T O C O M M E N T S Pages 4.1-52, 4.1-53 and 4.1-54, Table 4.1-10 are revised:
 
S UMMARY OF S IGNIFICANT I MPACTS AND M ITIGATION M EASURES  
3.3.2 Re lacement of Open Space Easements
Table 4.1-10 Summary of Significant Impacts and Mitigation Measures  Land Use Impact Level of Significance Mitigation Measure Storage Component 1.7.6. The Storage component may Alts 3 through 6 -~  3.3.2 Re lacement of O en convert public open space for uses not Space Easements in accordance with restrictions on use of the open space. Pump Stations and Tanks Component 1.9.6. The Pump Stations and Tanks Alts 3 through 6 -~  component may convert public open space for uses not in accordance with restrictions on use of the open space. Direct Discharge Component 1.11.6. The Direct Discharge Alt 6B -~  component may convert public open space for uses not in accordance with restrictions on use of the open space. Indirect Discharge Component  1.12.6. The Indirect Discharge Alts 6C through 6E ~  -component may convert public open space for uses not in accordance with restrictions on use of the open space. Advanced Membrane Treatment  Component 1.13.6 The Advanced Membrane Alt 6 -~  Treatment component may convert public open space for uses not in accordance with restrictions on use of the open space.
3.3.2 Re lacement of O en Space Easements
 3.3.2 Re lacement of Open Space Easements
 3.3.2 Re lacement of Open Space Easements
Response to Comment 404-4 Comment Summary: The comment states that although the Draft EIR considers that wetlands would be consistent with the open space intent of the District, their creation on District property may not be consistent with the purposes for which the District acquired the property and therefore the EIR should identify this as a potentially significant impact and include appropriate mitigation.
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I N C R E M E N T A L R E C Y C L E D W A T E R P R O G R A M F I N A L E I R R E S P O N S E T O C O M M E N T S The City of Santa Rosa concurs that the creation of wetlands on District property may not be consistent with the purposes for which the District acquired the property and should be considered a potentially significant impact. Therefore the Draft EIR is revised as follows: Page 4.1-31 is revised:
Created Wetlands Component Impact: 1.8.1 through 1.8.56. Will the Created Wetlands component impact land use based on evaluation criteria 1 through 56? Analysis: Less than Significant: Alternatives 3 through 6 Wetlands could be constructed adjacent to storage reservoirs, indirect discharge facilities or pipelines. These locations would primarily be in unincorporated Sonoma County, but could also be within the City of Santa Rosa or the City of Cloverdale. Wetlands would be consistent with the County policy of maintaining Community Separators in an open or natural character and protecting agricultural lands. If located in Santa Rosa, they support the Citys policy of maintaining a belt of open space around the city, with agricultural and low density uses including community separators. They also help to protect and conserve open spaces and significant natural features. As an open space use created wetlands would also be compatible with any land uses in the City of Cloverdale. The construction of wetlands for purposes of habitat enhancement would create an open space use that would be consistent in all Sonoma County or City of Santa Rosa land use designations. Wetlands sites would be 30 acres or less in size and therefore would not be large enough to create a barrier that would divide established communities. Wetlands would be an appropriate use in a Community Separator, and a compatible land use with any adjacent land use. Wetlands are not an urban use, and would be consistent with the open space intent of the Agriculture and Open Space District should they be sited on any District lands. Alternatives 1, 2 and 7 do not have a Created Wetlands component. No mitigation is needed. 1.8.6. Will the Created Wetlands component convert public open space for uses not in accordance with restrictions on use of the open space? Significant: Alternatives 3 through 6 Potential sites for created wetlands may include properties which the Sonoma County Agricultural Preservation and Open Space District holds in fee, or for which the District holds conservation easements. This could result in a use which is inconsistent, depending on the
 Mitigation: Impact: Analysis :  
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I N C R E M E N T A L R E C Y C L E D W A T E R P R O G R A M F I N A L E I R R E S P O N S E T O C O M M E N T S terms and conditions of the individual easement. If so, this would create a significant impact. Alternatives 1, 2, and 7 do not have a Created Wetlands component. Mitigation: 3.3.2 Replacement of Open Space  After Mitigation: Less than Significant: Alternative 4  Mitigation Measure 3.3.2 reduces this impact to a level below significance by providing funding to the Open Space District for the replacement on a one-for-one basis of the existing value of acreage in which the District holds an interest and where the use is found to be incompatible with the Districts interest. This would allow purchase of interests on new acreage in areas of comparable open space character and open space value identified by the Open Space District as a priority acquisition area. The conveyance of funds to the District for the purchase of interests in open space would ensure preservation of land as open space which is not now controlled by the District and otherwise would not be assured of preservation as open space. Replacing the existing value of acreage on a one-for one basis would mitigate the impact of created wetlands on regional open space to less than significant. Page 4.1-52, Table 4.1-10:
 
Table 4.1-10 Summary of Significant Impacts and Mitigation Measures  Land Use Impact Level of Significance Mitigation Measure Created Wetlands Component 1.8.6. The Created Wetlands Alts 3 through 6 -~  3.3.2 Re lacement of O en com onent ma convert ublic o en Space s ace for uses not in accordance with restrictions on use of the open space.
 Page 4.1-55, Table 4-11:
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S UMMARY OF I MPACTS BY A LTERNATIVE  
I N C R E M E N T A L R E C Y C L E D W A T E R P R O G R A M F I N A L E I R R E S P O N S E T O C O M M E N T S
Table 4.1-11 Summary of Impacts by Alternative Component Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6A Alt 6B Alt 6C Alt 6D Alt 6E Alt 7 Laguna Plant Upgrade == == == == == == == == == == --Indoor Water Conservation == -- -- -- -- -- -- -- -- -- --         I&I Reduction --== -- -- -- -- -- -- -- -- --Urban Irrigation            -- -- == -- -- -- -- -- -- -- --Agricultural Irrigation -- -- --z  -- -- -- -- -- -- --== Pipelines -- -- == == == == == == == --  Storage -- --z  z  z  z  z  z  z  z  --Created Wetlands -- -- == ~  == ~  == ~  == ~  == ~  == ~  == ~  == ~  --Pump Stations -- --z  z  z  z  z  z  z  z  -- Geysers Steamfield - -- == == == == == == ---- -- -Expansion Direct Discharge -- -- -- -- -- ==  ~  -- -- -- --Indirect Discharge -- -- -- -- -- -- --z  z  z  --Advanced Membrane - -- -- --z  z  z  z  z  --- --T atment re No Project -- -- -- -- -- -- -- -- -- -- ==     Notes: Level of Significance z  Significant impact before and after mitigation ~  Significant impact before mitigation; less than significant after mitigation |  Less than significant impact; no mitigation proposed ==  No impact  
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I N C R E M E N T A L R E C Y C L E D W A T E R P R O G R A M F I N A L E I R R E S P O N S E T O C O M M E N T S Page 3-43, Mitigation Measure 3.3.2, is revised: Impacts Mitigated and Mitigation Level  Impacts Mitigated Level of Significance after Mitigation 1.5.6, 1.7.6, 1.8.6, 1.9.6, 1.11.6, 1.12.6, and 1.13.6. Less than Significant The Agricultural Irrigation, Storage, Created Wetlands, Pump Stations and Tanks, Direct and Indirect Discharge, and AMT components may convert public open space for uses not in accordance with restrictions on use of the open space.  Response to Comment 404-5 Comment Summary: The comment states that although the Draft EIR considers that agricultural uses resulting from the provision of recycled water for agricultural reuse under Alternative 4 would be consistent with the agriculture and open space easements on these lands such use may not be consistent with the terms and conditions of the easements that the District holds, because the terms and conditions may vary considerably (as acknowledged in the Draft EIR). The comment also suggests that the EIR should identify this as a potentially significant impact and include appropriate mitigation. The City of Santa Rosa concurs that the agricultural uses on property for which the District holds easements may not be consistent with the terms and conditions of the easements for a given property and that this should be considered a potentially significant impact. Therefore the Draft EIR is revised as follows: Page 4.1-22, Table 4.1-3, Evaluation Criterion 1.5.6 is revised: Agricultural Irrigation Component Table 4.1-3 Land Use Impacts by Component  Agricultural Irrigation of Evaluation Criteria STighnriefischaonlcd e Impact ITmyppaect 1  SigLneifviecla onfc e 2  1.5.6. Will the Agricultural Greater than 0 acres None P == ~  Irrigation component convert public open space for uses not in accordance with restrictions on use of the open space?  
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Impact: Analysis:
 
 Mitigation:       e Aft r Mitigation:  
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1.5.6. Will the Agricultural Irrigation component convert public open space for IRWP facilities uses not in accordance with restrictions on use of the open space? No Impact: Alternative 4C Most of the City-owned land proposed for continued irrigation under this component is subject to a Conservation Easement. Continued farming and irrigation is consistent with the existing easement and would not constitute an impact. Significant: Alternatives 4A and 4B The specific locations of agriculture irrigation areas have not been determined, but they would be located within the East of Rohnert Park and the North County areas. There are public recreational areas and areas with Sonoma County Agriculture and Open Space District easements which could be converted to agricultural uses because of the availability of a new source of water. Lands owned by the Open Space District would be managed according to District policies; on lands where the District has an easement, not direct ownership, the terms and conditions of the easement vary substantially. However, therefore agricultural uses may notwould be consistent with the agriculture and open space easements on these lands. If so, this would create a significant impact. Alternatives 1, 2, 3, 5, 6, and 7 do not have an Agricultural Irrigation component. Alternative 4C No mitigation is needed. Alternatives 4A and 4B 3.3.2 Replacement of Open Space  
Less than Significant: Alternative 4A and 4B Mitigation Measure 3.3.2 reduces this impact to a level below significance by providing funding to the Open Space District for the replacement on a one-for-one basis of the existing value of acreage in open space easements if the use is found to be incompatible with the Districts interest. This would allow purchase of easements on new acreage in areas of comparable open space character and open space value identified by the Open Space District as a priority acquisition area.
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