STATE OF CALIFORNIA, PETE WILSON, Governor

PUBLIC UTILITES COMMISSION

505 VAN NESS AVENUE

SAN FRANCISCO, CA 94102-3298

October 29, 1998

Dean Shauers, Project Manager

Pacific Pipeline System, Inc.

12201 E. Arapahoe Road, C10

Englewood, CO 80112

RE: Variance Request #124 - Allow for above ground installation of the pipeline at the Los Angeles Aqueduct High Speed Channel and construction of a 200 foot concrete cover, instead of a bore installation as originally proposed, City of Los Angeles (Segment 3).

Clearance #76 - Request for an extra work space along San Fernando Road for the subject installation and concrete cover, City of Los Angeles (Segment 3).

Dear Mr. Shauers:

We have reviewed the above-referenced requests, and our decision of approval is based on the following factors:

• The change of pipeline installation from a bore to above ground technique has been required by the City of Los Angeles and Los Angeles Department of Water and Power (LADWP). The above ground pipeline installation, combined with the construction of the proposed concrete cover, would provide additional mitigation at the Aqueduct channel in preventing an oil spill from entering the Los Angeles water system. The specifications and design of the above ground pipeline installation and concrete cover were developed by LADWP engineering staff (in consultation with the City of Los Angeles, PPSI, and its consultants) and would be constructed under PPSI supervision. The approved LADWP plans for the subject installation have been submitted to the CPUC Lead Environmental Monitor.

• As proposed, the irregular shaped parcels adjacent to the aqueduct channel would be used for construction of the pipeline and cover as required by the City of Los Angeles and LADWP. The subject work space is located on the west side of San Fernando Road near Balboa Road.

• No residences or businesses are located within the area. The concrete cover would bridge the Aqueduct channel approximately five feet above grade. No land use or visual impacts are anticipated from the above ground pipeline installation, including cover, or use of the adjacent area as an extra work space.

• A biological resources survey of the subject work space was conducted by a PPSI biologist (R. Maddox) on October 14, 1998. The subject area has been disturbed by previous construction activities. Vegetation is generally confined to items that thrive on disturbance including mustard, aster, canyon sunflower, Russian thistle, and fiddleneck. A small patch of mulefat was found near a leaking aqueduct pipe and two Eucalyptus trees are located adjacent to San Fernando Road. No active wildlife was seen with the exception of a black phoebe. Wildlife signs indicate that fox, California ground squirrel, cottontail, jack rabbit, and killdeer use the area. No sensitive plant or wildlife species were noted during the survey. No impacts to biological resources are expected.

• A cultural resources survey of the subject work space was conducted by PPSI archaeologists (A. Knight and K. Lord) on October 13, 1998. No prehistoric or historic resources were identified during the survey. Given previous construction activities, no intact, subsurface cultural resources are anticipated. The Aqueduct Pipeline itself as been given a site record number by the County of Los Angeles (Lan 2105-H). A representative from Owl Clan Consultants was contacted regarding Native American concerns. No concerns were noted. No impacts to cultural resources are anticipated with implementation of the measure noted below.

• The following mitigation measures shall be implemented:

- All applicable mitigation measures for the project shall be implemented at the subject site, including dust abatement and traffic control.

- Prior to the commencement of construction, written approval for the above ground pipeline installation and concrete cover from the City of Los Angeles shall be provided to the CPUC Lead Environmental Monitor. All conditions of approval from the City of Los Angeles and LADWP shall be implemented under this variance approval.

- Prior to the use of the extra work space, written landowner approval shall be provided to the CPUC Environmental Monitor.

- The boundary and ingress/egress points to the subject work space shall be clearly flagged. Ingress/egress shall be restricted to the existing driveway. Traffic into and out of the construction site shall be controlled with the use of flaggers.

- A qualified archaeologist and Native American Monitor shall be present during any clearing or grading activities. If any signs of cultural resources are identified, work shall cease immediately, and the site shall be evaluated using the procedures in the Cultural Resources Management Plan.

- The subject site shall not be used for fuel or hazardous material storage.

- All drips, leaks, and/or spills from vehicles and/or equipment shall be excavated immediately and disposed of in appropriate, labeled containers.

- Adjacent streets shall be swept manually or with water sweepers, as appropriate, at the end of each day if visible soil material is carried onto them (as required by Mitigation Measure A-8).

- No parking or storage of vehicles (including personnel vehicles), equipment, pipe, or any other project-related items shall be allowed on adjacent roadways.

- As proposed, the fencing along the Aqueduct channel shall be moved to the edge of San Fernando Road to restrict the public from entering the construction area/extra work space.

- As proposed, the two Eucalyptus trees along San Fernando Road shall be fenced to preclude any impact.

- Signs shall be posted in conspicuous locations along the work area warning of overhead power lines.

- Implementation of this variance approval and use of the subject work space in accordance with the provisions noted above will be verified on a random basis by a CPUC/ANF Environmental Monitor.

Sincerely,

Andrew Barnsdale

Project Manager

cc: R. Borden, ANF

H. Rastegar, Aspen

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