Final Environmental Impact Report Addendum

On Lodi Gas Storage, LLC's

Application for Modification of

Lodi Gas Storage Project

Application 09-09-012

(Original Environmental Impact Report

certified in Application No. A. 98-11-012)

SCH No. 1999022065

Prepared By:

November 2009

Final Environmental Impact Report Addendum

California Public Utilities Commission

Application 09-09-012

(Original Environmental Impact Report

certified in Application 98-11-012)

Lodi Gas Storage, LLC's Application for Certificate of Public Convenience and Necessity for Construction and Operation of Gas Storage Facilities

Summary

Pursuant to California Environmental Quality Act (CEQA) Guidelines Section 15164, the California Public Utilities Commission (Commission) has prepared this Addendum to the Final Environmental Impact Report (FEIR) published for the Lodi Gas Storage, LLC (LGS) project and adopted in Decision (D.) 00-05-048.

On two separate occasions subsequent to that Decision, the Applicant (LGS) informed the Commission of the need to modify the completed project by installing additional wells. This consisted of two new wells on Well Site 4 and two new wells on Well Site 3. This proposed additional construction was reviewed by Commission staff and found not to result in any new, previously undisclosed impacts, or increase the severity of previously disclosed impacts. Therefore, the Commission found that the preparation of Addenda pursuant to CEQA Guidelines Section 15164 was appropriate to the LGS project, as modified.

On September 16, 2009, LGS applied for a third amendment to the project CPCN to install additional wells. That Application is the subject of this CEQA Addendum. In this Application, LGS seeks approval to construct up to 15 new injection/withdrawal wells. These would be in addition to the 15 wells previously authorized. The authorized total capacity, working capacity, and maximum daily injection/withdrawal capacity of the facility would be unchanged. Well construction would include minor piping on the well pads to connect to the new wells to existing flowlines serving the pads.

This Addendum presents an overview of the original and amended LGS project, summarizes the proposed changes to the approved and amended project, and provides recommendations.

Project Description

Original Project. In November 1998, LGS filed an application with the Commission (A.98-11-012) seeking a certificate of public convenience and necessity (CPCN) to allow LGS to develop and operate an underground natural gas storage facility near Lodi in San Joaquin County, California. This project was the subject of an FEIR in February 2000. Following its review, the Commission approved the project under D.00-05-048 on May 18, 2000, and a CPCN was issued.

Essentials of the Original Project Description:

· Use of underground storage reservoirs covering approximately 1,450 acres northeast of Lodi.

· Drilling of eleven gas injection/withdrawal wells into the two reservoirs to allow customers to inject or withdraw gas from the facility several times a day.

· Drilling of three observation wells to monitor critical parameters of the storage reservoir.

· Installation of a water separation and compressor facility.

· Construction of up to 33 miles of 24- to 30-inch diameter pipeline, buried at least four feet underground, connecting the LGS facility to PG&E's gas transmission facility. The gas pipeline traverses agricultural lands and major waterways.

Project Amendments. Subsequent to the Commission's approval to construct the project, LGS determined that a portion of the field contained gas that could not be accessed at the flow rates originally anticipated. LGS submitted written documentation requesting Commission approval to install two additional injection and withdrawal wells at Well Site 4. In its decision D.03-08-048 dated August 21, 2003, the Commission granted the request to construct the two wells and amended the FEIR. Subsequent to this, LGS sought and received approval for two wells to be drilled at Well Site 3. This approval was granted under decision D.04-05-046 and the FEIR amended.

Essentials of First and Second CPCN Amendments

· LGS drilled four additional wells; two from the existing Well Site 4 (first amendment) and two from existing Well Site 3 (second amendment).

· The project required drilling wells, installing wellheads, installing piping to hook the wellheads to the existing flow-lines, and re-erecting fencing around the sites.

September 2009 Proposed Project Modification. On September 16, 2009, LGS submitted an Application to amend its CPCN to allow the construction of additional wells to facilitate how it operates its project. Additional wells would allow for slower rates of withdrawal through any one well, thereby preventing continued operating problems with the existing wells due to sediment accumulation in the down-hole filtering system.

Specifics of the Proposed September 2009 Modification

· LGS would drill up to fifteen additional wells from existing Well Sites 1-2, 3, 4, 5, and 6. Wells depths would be approximately 2,200 feet to 2,500 feet below the ground surface.

· The proposed project modification will require drilling up to fifteen new wells on or adjacent to existing well sites, installing wellheads, installing piping to hook the wellheads to the existing flowlines, and re-erecting or extending permanent fencing.

· The wells would be drilled over time. Within the limits of the project modification, the number and location of new wells would be determined by LGS, based on LGS's analysis of the effectiveness of the wells in achieving a satisfactory flow rate. It is anticipated that 4 to 5 wells would be drilled initially.

· In general, each well would take approximately 10 days, operating 24 hours per day, to drill. An additional 2 weeks per well, 8 to 10 hour days, would be required to install piping. A work crew of approximately 15 persons would be required for each well installation. Drilling mud and cuttings would be held in temporary on-site tanks and would be disposed of in a state-approved landfill authorized to accept this type of waste.

· The nearest residence is approximately 1,200 feet away. There are no public roads adjacent to any well site. Access is provided along existing unpaved farm roads.

· All well sites are surrounded by agricultural land. Each well site at which drilling occurs would require temporary construction workspace adjacent to the site. This land would be fully restored to agricultural use following construction.

· Approximately one acre of additional pad area may be required, depending on final well locations. This land would be adjacent to one or more of the existing well pads. It would be on existing agricultural land, similar to the land occupied by the existing well pads at the time of their construction.

Impacts of the Proposed Project Modification

Likely environmental impacts from the proposed project modification will be similar to those analyzed in the Draft Environmental Impact Report (DEIR) prepared in September 1999 and made final in February 2000.

Since adoption of the Final EIR (FEIR), California has established major programs to address global climate change, and California law has been changed (Senate Bill 97, Chapter 185, 2007) to clarify that the effects of greenhouse gas (GHG) emissions are subject to CEQA. Operation of the facility, including the work of recompleting or reconditioning existing wells as routine maintenance, causes some direct GHG emissions along with the previously-identified environmental effects; however, at the time of the FEIR, GHG emissions were not specifically described. Any additional GHG emissions associated with the amended project could potentially represent a "effect not discussed in the EIR" and must be evaluated.

The additional injection/withdrawal wells would be used to more effectively operate the LGS facility. In particular, they would be used to reduce flow rates in the existing wells by distributing the flow over a larger number of wells. This would reduce problems with clogging of down-hole filters with sediment and screen erosion as occurs in the existing wells. Reducing problems with clogging would reduce the amount of work needed to occasionally recomplete or recondition existing wells. The additional wells would allow LGS to reduce or avoid the amount of activity related to maintaining efficient and reliable operations, which reduces or avoids some previously identified environmental effects as well as GHG emissions.

Except to maintain the additional wells and use lower flow rates in each well as compared to current flow rates, the operation of the LGS facility would be unchanged. There would be no capacity increase authorized for the project, and there would be no new compression, dehydration, or associated facilities constructed. There would be no additional workforce or employees. Therefore because operations would be unchanged, there would be no additional environmental effects, including GHG emissions, associated with the operations.

Construction of up to 15 wells would require use of diesel-fueled rigs to drill the wells and diesel-fueled trucks to deliver materials and remove drilling waste. Workers would use vehicles to commute to the work sites. Construction equipment such as graders and compactors would be needed to prepare any drill pad extensions. This would be a short-term activity resulting in GHG and other air pollutant emissions, along with temporary noise and traffic, spanning roughly four weeks for each well. Emissions from the diesel-fueled drill rigs and other equipment would be managed according to the local air district recommendations. Currently, the agency responsible for implementing climate change programs in California recommends¹ that the discussion of construction-related GHG emissions in CEQA documents emphasizes compliance with performance standards. The mitigation measures adopted in the FEIR require compliance with the current San Joaquin Valley Air Pollution Control District recommendations for construction equipment, which establish performance standards for construction related emissions. Since the construction-related equipment emissions and activities would be subject to local air district recommendations,² GHG and other air pollutant emissions related to construction activity would be presumed to have a less than significant effect related to climate change and local air resources.

It is believed that implementation of mitigation measures adopted in the FEIR and used during the construction of the original and previously amended project will prevent new, previously undisclosed impacts, and will not exacerbate previously disclosed impacts. Additionally, it is believed that the additional wells would allow LGS to reduce activities related to operations, which reduces or avoids some previously identified environmental effects as well as overall GHG emissions.

Mitigation Measures

Table ES-1 (Summary of Environmental Impacts and Mitigation Measures) is included in the Executive Summary of the DEIR. This table of mitigation measures is attached here as Appendix A. The Executive summary is online at:

ftp://ftp.cpuc.ca.gov/gopher-data/environ/lodi/draft-eir/execsum.doc.PDF

Recommendations

With the implementation of existing mitigation measures, the proposed project modifications should have no significant environmental impact. As a result, no further analysis or documentation is required.

Appendix A

Mitigation Measures for the original Lodi Gas Storage project are identified in

the FEIR, Executive Summary, Table ES-1. This table is reproduced here and all measures listed apply to the modified project where pertinent.

Table Source: ftp://ftp.cpuc.ca.gov/gopher-data/environ/lodi/draft-eir/execsum.doc.PDF

Table ES-1

SUMMARY OF ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES


Environmental Impact (Significance before Mitigation)	Mitigation Measures	Significance after Mitigation
LAND USE, PLANNING, AND AGRICULTURAL RESOURCES
Proposed Project
3.1-1: Temporary Disruption of Agricultural Production during Construction (Significant)	Mitigation Measure 3.1-1: Avoid pipeline construction in vineyards during harvesting season	Less than significant
3.1-2: Permanent Loss of Agricultural Production Capability (Less than significant)	Mitigation Measure 3.1-2: Bury pipelines at a depth of 8 feet in lands suitable for grape production that have not already been deep-ripped, or obtain landowner agreement to bury the pipeline at a shallower depth	Less than significant
3.1-3: Loss of Prime Farmland, Farmland of Statewide Importance, and Unique Farmland (Less than significant)	None required	Less than significant
3.1-4: Compatibility with Surrounding Land Uses (Less than significant)	None required	Less than significant
3.1-5: Potential Inconsistency with Plans and Policies
Proposed pipeline alignment (Significant and unavoidable):	No mitigation is available to reduce the inconsistency of the proposed pipeline alignment with local and Delta Protection Commission policies to a less-than-significant level	Significant and unavoidable
Airport land use plan (Significant):	Mitigation Measure 3.1-3: Obtain determination that the project is consistent with or amend the airport land use plan	Less than significant
3.1-6: Potential Conflicts with Lands under Williamson Act Contracts (Less than significant)	None required	Less than significant
3.1-7: Consistency with Proposed Land Uses (Less than significant)	None required	Less than significant
Public Right-of-Way Route Alternative
3.1-8: Temporary Disruption of Agricultural Production during Construction (Significant)	Mitigation Measure 3.1-1: Avoid construction in vineyards during harvesting season	Less than significant
3.1-9: Permanent Loss of Agricultural Production Capability (Less than significant)	Mitigation Measure 3.1-2: Bury pipelines at a depth of 8 feet in lands suitable for grape production that have not already been deep-ripped, or obtain landowner agreement to bury the pipeline at a shallower depth	Less than significant
3.1-10: Loss of Prime Farmland, Farmland of Statewide Importance, and Unique Farmland (Less than significant)	None required	Less than significant
3.1-11: Compatibility with Surrounding Land Uses (Significant)	Mitigation Measure 3.1-4: Minimize effects to the community of Terminous Mitigation Measure 3.1-5: Minimize effects on Brannan Island State Recreation Area facilities	Less than significant
3.1-12: Potential Inconsistency with Plans and Policies (Significant)	Mitigation Measure 3.1-3: Obtain determination that the project is consistent with or amend the airport land use plan	Less than significant
3.1-13: Potential Conflicts with Lands under Williamson Act Contracts (Less than significant)	None required	Less than significant
3.1-14: Consistency with Proposed Land Uses (Less than significant)	None required	Less than significant
Existing Pipeline Corridor Alternative
3.1-15: Temporary Disruption of Agricultural Production during Construction (Significant)	Mitigation Measure 3.1-1: Avoid construction in vineyards during harvesting season	Less than significant
3.1-16: Permanent Loss of Agricultural Production Capability (Less than significant)	Mitigation Measure 3.1-2: Bury pipelines at a depth of 8 feet in lands suitable for grape production that have not already been deep-ripped, or obtain landowner agreement to bury the pipeline at a shallower depth	Less than significant
3.1-17: Loss of Prime Farmland, Farmland of Statewide Importance, and Unique Farmland (Less than significant)	None required	Less than significant
3.1-18: Compatibility with Surrounding Land Uses (Significant)	Mitigation Measure 3.1-6: Minimize effects to residential property in the city of Isleton Mitigation Measure 3.1-5: Minimize effects on Brannan Island State Recreation Area facilities	Less than significant
3.1-19: Potential Inconsistency with Plans and Policies (Significant)	Mitigation Measure 3.1-3: Obtain determination that the project is consistent with or amend the airport land use plan	Less than significant
3.1-20: Potential Conflicts with Lands under Williamson Act Contracts (Less than significant)	None required	Less than significant
3.1-21: Consistency with Proposed Land Uses (Less than significant)	None required	Less than significant
Composite Route Alternative (Preferred Alternative)
3.1-22: Temporary Disruption of Agricultural Production during Construction (Significant)	Mitigation Measure 3.1-1: Avoid construction in vineyards during harvesting season	Less than significant
3.1-23: Permanent Loss of Agricultural Production Capability (Significant)	Mitigation Measure 3.1-2: Bury pipelines at a depth of 8 feet in lands suitable for grape production that have not already been deep-ripped, or obtain landowner agreement to bury the pipeline at a shallower depth	Less than significant
3.1-24: Loss of Farmland, Farmland of Statewide Importance, and Unique Farmland (Less than significant)	None required	Less than significant
3.1-25: Compatibility with Surrounding Land Uses (Significant)	Mitigation Measure 3.1-5: Minimize effects on Brannan Island State Recreation Area facilities Mitigation Measure 3.1-6: Minimize effects to residential property in the City of Isleton	Less than significant
3.1-26: Potential Inconsistency with Plans and Policies (Significant)	Mitigation Measure 3.1-3: Obtain determination that the project is consistent with or amend the airport land use plan	Less than significant
3.1-27: Potential Conflicts with Lands under Williamson Act Contracts (Less than significant)	None required	Less than significant
3.1-28: Consistency with Proposed Land Uses (Less than significant)	None required	Less than significant
POPULATION AND HOUSING
Proposed Project and Project Alternatives
3.2-1: Temporary Increase in Local Population, Resulting in Minimal Growth in Regional Population (Less than significant)	None required	Less than significant
3.2-2: Temporary Increase in Local Population and Temporary Need for Housing for up to 60 People (Less than significant)	None required	Less than significant
3.2-3: No Displacement of Existing Housing Units or Displacement of a Substantial Number of People That Would Necessitate the Construction of Replacement Housing Elsewhere (Less than significant)	None required	Less than significant
GEOLOGY, SOIL, AND PALEONTOLOGY
Proposed Project and Project Alternatives
3.3-1: Potential to Cause Substantial Wind and Water Erosion (Less than significant)	None required	Less than significant
3.3-2: Location of Project Facilities on a Geological Unit or Soil that is Unstable, Potentially Resulting in Exposure of the Pipeline to Loss of Support and Damage (Less than significant)	Mitigation Measure 3.3-1: Identify potential areas of concern regarding potential future interference of the pipeline with agricultural practices and undertake remedial actions as necessary	Less than significant
3.3-3: Potential to Expose People or Structures to Substantial Adverse Geologic Hazards (Less than significant)	None required	Less than significant
HYDROLOGY
Proposed Project and Project Alternatives
3.4-1: Potential Degradation of Surface Water Quality during Construction (Less than significant)	None required	Less than significant
3.4-2: Potential Degradation of Surface Water Quality during Hydrostatic Testing of the Pipeline (Less than significant)	None required	Less than significant
3.4-3: Potential Degradation of Groundwater Quality During Well Drilling (Less than significant)	None required	Less than significant
3.4-4: Potential Degradation of Water Quality during Operation of the Project (Less than significant)	None required	Less than significant
3.4-5: Potential to Expose People or Structures to a Significant Risk of Loss, Injury, or Death Involving Flooding Caused by the Project (Less than significant)	None required	Less than significant
3.4-6: Potential to Expose Structures to a Significant Risk of Loss Involving Flooding Related to Delta Island Flooding (Significant)	Mitigation Measure 3.4-1: Use concrete coated pipe or concrete pipe collars in all areas subject to the 100-year flood, where saturated soils would not prevent the pipeline from floating	Less than significant
AIR QUALITY
Proposed Project and Project Alternatives
3.5-1: Construction-Related PM10 Emissions in San Joaquin County (Significant)	Mitigation Measure 3.5-1a: Comply with the San Joaquin Air District's Regulation VIII (Fugitive Dust Prohibitions) Comply with the San Joaquin Air District's recommendation for construction equipment mitigation measures	Less than significant
3.5-2: Construction-Related PM10 Emissions in Sacramento County (Significant)	Mitigation Measure 3.5-2: Water the construction site with adequate frequency to keep soil moist at all times	Less than significant
3.5-3: Construction-Related ROG and NOx Emissions in Sacramento County (Significant and unavoidable)	No mitigation is available to reduce this impact to a less-than-significant level. However, as a best management practice, CPUC will require implementation of Mitigation Measure 3.5-1b for construction activities within Sacramento County	Significant and unavoidable
3.5-4: Controlled Emissions of NOx and ROG during Project Operation Exceed Emissions Offset Trigger Thresholds (Significant)	Mitigation Measure 3.5-3: Obtain emission offsets for NO_x and ROG emission increases or install electric compressor facilities	Less than significant
3.5-5: Emission of Toxic Air Pollutants from Natural Gas-Fired Equipment (Less than significant)	None required	Less than significant
3.5-6: Potential for Objectionable Odors (Significant)	Mitigation Measure 3.5-4: Properly construct, inspect, and maintain facilities	Less than significant
TRANSPORTATION AND CIRCULATION
Proposed Project and Project Alternatives
3.6-1: Temporary Increase in Traffic in the Project Area during Construction (Less than significant)	None required	Less than significant
3.6-2: Temporary Disruption of Circulation from Project Construction (Significant)	Mitigation Measure 3.6-1: Develop and implement a traffic control plan	Less than significant
3.6-3: Minimal Increase in Traffic during Project Operation (Less than significant)	None required	Less than significant
3.6-4: Potential for Interference with Emergency Response Routes (Significant)	Mitigation Measure 3.6-1: Develop and implement a traffic control plan	Less than significant
BIOLOGICAL RESOURCES
Proposed Project and Project Alternatives
3.7-1: Potential Disturbance to Special-Status Plant Species in Unsurveyed or Modified Portions of the Alignment (Significant)	Mitigation Measure 3.7-1a: Conduct floristic surveys to identify the location and extent, if any, of threatened, endangered, proposed, and special-status plants Mitigation Measure 3.7-1b: Avoid and protect known federal and state listed plants Mitigation Measure 3.7-1c: Minimize long-term impacts on special-status plant populations	Less than significant
3.7-2: Potential Introduction or Spread of Noxious and Invasive Weeds and Pests During Construction Activities (Significant)	Mitigation Measure 3.7-2: Control dispersal of noxious and invasive weeds and pests during construction activities	Less than significant
3.7-3: Potential Removal or Disturbance of Marsh or Riparian Scrub/Woodland Habitat (Less than significant)	None required	Less than significant
3.7-4: Potential Disturbance of Sensitive Habitats (Significant)	Mitigation Measure 3.7-3a: Confine construction activities and equipment to the designated construction work area Mitigation Measure 3.7-3b. Avoid and protect sensitive vegetation and wetland resources near designated construction work area Mitigation Measure 3.7-3c. Reestablish preconstruction site conditions to allow natural colonization of plant species and, if necessary, reseed	Less than significant
3.7-5: Potential Disturbance of Agricultural, Pasture, and Ruderal and Developed Lands (Less than significant)	None required	Less than significant
3.7-7: Potential Impacts on Aquatic Invertebrates, California Tiger Salamander, and Western Spadefoot Toad and Their Habitat (Significant)	Mitigation Measure 3.7-3a: Confine construction activities and equipment to the designated construction work area Mitigation Measure 3.7-3b. Avoid and protect sensitive vegetation and wetland resources near designated construction work area Mitigation Measure 3.7-3c. Reestablish preconstruction site conditions to allow natural colonization of plant species and, if necessary, reseed	Less than significant
3.7-8: Potential Impact on the Valley Elderberry Longhorn Beetle (Significant)	Mitigation Measure 3.7-5. Conduct preconstruction valley elderberry longhorn beetle surveys and avoid or compensate for loss of habitat	Less than significant
3.7-9: Potential Disturbance and Direct Mortality of Giant Garter Snakes (Less than significant)	None required. See Section 2.4.13, "Mitigation Measures Proposed by the Applicant"	Less than significant
3.7-10: Potential Impact on Western Pond Turtles (Less than significant)	None required	Less than significant
3.7-11: Potential Disturbance on the Greater Sandhill Crane (Significant)	Mitigation Measure 3.7-6: Conduct preconstruction surveys for sandhill cranes and avoid key foraging and roosting areas	Less than significant
3.7-12: Potential Disturbance of Active Raptor and Owl Nests and Tricolored Blackbird Nests (Significant)	Mitigation Measure 3.7-7. Conduct preconstruction surveys for nesting raptors, owls, and tricolored blackbirds and establish an appropriate buffer distance around nest sites	Less than significant
3.7-13: Loss of or Disturbance to Nesting Western Burrowing Owls (Significant)	Mitigation Measure 3.7-8: Consult with CDFG and follow CDFG's burrowing owl mitigation guidelines	Less than significant
3.7-14: Project Construction Activities May Cause the Reproductive Failure of Nesting Swainson's Hawks (Significant)	Mitigation Measure 3.7-9. Conduct preconstruction surveys for nesting Swainson's hawks and follow CDFG's mitigation guidelines for Swainson's hawks	Less than significant
3.7-15: Disturbance of Wintering Waterfowl and Shorebirds (Less than significant)	None required	Less than significant
ENERGY AND MINERAL RESOURCES
Proposed Project and Project Alternatives
3.8-1: Potential to Overcover or Preclude Extraction of Mineral Resources (Less than significant)	None required	Less than significant
PUBLIC HEALTH AND PUBLIC SAFETY
Proposed Project and Project Alternatives
3.9-1: Potential for Public Health Hazard Involving the Use, Production, or Disposal of Hazardous Materials (Less than significant)	None required	Less than significant
3.9-2: Potential Risk to Public Safety and the Environment through Release of Emissions or Risk of Upset (Less than significant)	None required	Less than significant
3.9-3: Potential Public Health Hazard Associated with Pipeline Rupture That Could Lead to an Explosion Resulting in Property Damage or Fatalities (Less than significant)	None required	Less than significant
3.9-4: Potential Peat Fire Hazard During Pipeline Construction (Significant)	Mitigation Measure 3.9-1: Develop and implement a peat fire prevention plan	Less than significant
NOISE
Proposed Project and Project Alternatives
3.10-1: Exposure of Noise-Sensitive Land Uses to Noise from Construction Activities Other Than Well Drilling (Significant)	Mitigation Measure 3.10-1: Employ noise-reducing construction practices to reduce construction noise to acceptable levels	Less than significant
3.10-2: Exposure of Noise-Sensitive Land Uses to Noise from Well Drilling Activities (Significant)	Mitigation Measure 3.10-2: Restrict the hours of construction, install noise-reducing barriers around drilling sites, and employ other noise-reducing "best management practices" to reduce drilling noise	Less than significant
3.10-3: Exposure of Noise-Sensitive Land Uses to Noise from Operation of the Separator Facility (Less than significant)	None required	Less than significant
3.10-4: Exposure of Noise-Sensitive Land Uses to Noise from Operation of the Compressor Facility (Less than significant)	None required	Less than significant
PUBLIC SERVICES AND SOCIOECONOMICS
Proposed Project and Project Alternatives
3.11-1: Temporary Increase in Demand for Emergency Response in the Project Area (Less than significant)	None required	Less than significant
3.11-2: Minimal Increase in Demand for Landfill Space Associated with Generation of Waste during Project Construction (Less than significant)	None required	Less than significant
3.11-3: Potential Interference with Existing Utility Infrastructure (Less than significant)	None required	Less than significant
VISUAL RESOURCES
Proposed Project and Project Alternatives
3.12-1: Potential to Degrade the Existing Visual Character of the Site (Significant)	Mitigation Measure 3.12-1: Develop and implement landscaping and site design plan	Less than significant
3.12-2: Potential to Create New Sources of Substantial Light and Glare That Would Adversely Affect Nighttime Views in the Project Area (Less than significant)	None required	Less than significant
3.12-3: Potential to Affect Scenic Vistas and Damage Scenic Resources along a Scenic Highway (Less than significant)	None required	Less than significant
CULTURAL RESOURCES
Proposed Project and Project Alternatives
3.13-1: Potential Disturbance to Previously Unidentified Cultural Resources during Project Construction (Less than significant)	None required	Less than significant

(END OF ATTACHMENT A)

¹ See: http://www.arb.ca.gov/cc/localgov/ceqa/ceqa.htm; accessed November 12, 2009.

² Local air district recommendations currently include: use of alternatively fueled construction equipment, minimizing idling time, and replacing fossil-fueled equipment with electrically driven equivalents (SJVAPCD Guide for Assessing and Mitigating Air Quality Impacts).