SAN FRANCISCO, CA 94102-3298

April 22, 1998

Dean Shauers, Project Manager
Pacific Pipeline System, Inc.
12201 E. Arapahoe Road, C10
Englewood, CO 80112

RE: Variance Request #60 - Relocation of the project pipeline between Valencia Boulevard and McBean Parkway (a distance of approximately 5,800 feet), Los Angeles County, Segment 2B.

Dear Mr. Shauers:

We have reviewed the above-referenced variance request and approve your request, based on the following factor:

Biological Resources. The proposed realignment was examined by a PPSI biologist (L. Hunt) on March 24, 1998. Vegetation within and adjacent to the survey segment is non-native annual grassland and valley oak/coast live oak savannah, that supports moderate-intensity cattle grazing. Dominant trees within the right-of-way are widely scattered, even-aged valley oak and coast live oak, with little downed wood and an understory of non-native annual grassland. The understory is dominated by annual grasses such as soft chess, red brome, and wild oats, and non-native forbs such as storks-bill and clover. Native forbs included California poppy, fiddlehead, popcorn flower, gold-fields, owls-clover, sky lupine, and other lupine species.

The proposed realignment crosses two minor seasonal drainages which were dry at the time of the survey. In addition, the realignment parallels a small, permanent watercourse at its southern end at McBean Parkway, which had surface flow at the time of the survey. This latter drainage supports a dense willow canopy.

No sensitive wildlife species or signs were observed within or immediately adjacent to the proposed realignment right-of-way. Although this savanna habitat is relatively undisturbed, its proximity to Interstate 5 likely precludes occupation of this area by many wildlife species.

The biological environment of the proposed realignment is essentially unchanged from the originally route, and likely supports fewer wildlife species given its immediate proximity to Interstate 5. Therefore, no additional impact is anticipated with the implementation of the measures noted below.

Cultural Resources. Previous literature reviews of both the approved route and proposed realignment has provided no information on any known cultural resource sites, including sites of historic value. The initial study for the Westridge Project EIR (Appendix 1(b), page 11) states that ... "An archaeological survey completed for the project site indicates that no prehistoric or historic resources exist on the project site." The proposed realignment was also examined by a PPSI archaeologist (M. Carlton) on March 24, 1998 at which time no indication of cultural remains were encountered. PPSI proposes to have a qualified archaeologist and Native American monitor present throughout the construction of the realignment (see below).

Hydrology. The proposed right-of-way would parallel a small, unnamed drainage on its southern end near McBean Parkway. Standard construction practices and implementation of project erosion control mitigation measures would protect the riparian area from impact. In addition, refueling would not be allowed within 0.25 miles of the riparian area. No additional impact is anticipated with the implementation of the measures noted below.

Geotechnical. Both the original right-of-way and the proposed realignment are not in an area of active faults or subject to lateral spreading. No new design parameters are proposed. No impact is anticipated.

Environmental Contamination. No environmental contamination is expected along this portion of the route. This issue was not considered in the Westridge Project EIR since no significant issues were identified in either the original or revised Initial Study, or original or revised Notice to Proceed. No impact is anticipated.

Traffic Control. Traffic concerns associated with either the original route or the proposed realignment would be addressed through the traffic plans for Valencia Boulevard and McBean Parkway. All other construction activities would occur on existing roadways within the Westridge Project site, which are closed to public access. Los Angeles County approval of the traffic control measures, as stipulated in the traffic plans, would be required prior to the commencement of construction. No increased traffic or circulation impact would occur.

Visual Resources. Construction of the realignment would be visible from Interstate 5. Construction would impose a temporary visual impact. However, with the implementation of the measure noted below, this temporary impact would be insignificant.

Other Issue Areas. Since the original and proposed route are essentially the same length, traversing the same immediate region, no increased impacts would result from the proposed realignment for the following issue areas: air quality, socioeconomics, public utilities, system safety, or minority-low income.

- All applicable mitigation measures for the project shall be implemented at the subject location.

- Prior to the commencement of construction, approval of the realignment from Newhall Land & Trust shall be submitted to the Lead Environmental Monitor upon receipt.

- Environmental fencing and sediment control fencing shall be installed to establish prohibition zones prior to the start of construction. This fencing shall be established by a qualified biologist in consultation with the CPUC Environmental Monitor and County of Los Angeles Forestry Division. During construction, no silt or debris (rocks, skids, trash, etc.) shall be allowed to enter the prohibition zones.

- All vehicle and construction equipment are restricted to the established right-of-way, temporary work areas, or the existing roadway system.

- As proposed, a Native American monitor shall be present during construction. 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.

- Prior to initial brush clearing and grading, a qualified biologist shall walk the area to be cleared to identify any coastal whiptails and/or coast horned lizards within the area. If either species is found, the species shall be relocated in accordance with established USFWS and/or CDFG protocols.

- Prior to initial brush clearing and grading, a qualified biologist shall walk the area to be cleared to verify that there are no active bird nests. If an active bird nest is found, PPSI shall consult with the CPUC for further instructions.

- Topsoil from the areas to be cleared and graded shall be salvaged and stockpiled for the duration of site-specific activity. The salvaged soil shall be covered with grubbed vegetation to reduce loss from aeolian transport.

- The County of Los Angeles requirements for oak tree protection shall be implemented (letter dated March 23, 1998 from County of Los Angeles to Henrick Sarkissian, PPSI):

. All remaining oak trees (e.g., those oak trees not bored) shall be fenced around the "protect zone." The term "protected zone" refers to the area extending five feet beyond the dripline of the oak tree (before pruning), or 15 feet from the trunk, whichever is greater.

. Any roots encountered during trenching operations shall be cleanly pruned and covered with soil as soon as reasonably possible (within the same day).

. The arborist of record shall be on site at all times when any work is being done within the protected zone of oak trees.

. The County Forester shall be notified prior to the start of construction.

. A copy of the plan map showing all trees and the proposed pipeline shall be submitted to the County Forester prior to the start of construction.

. Any deviation from these requirements shall be approved by the County Forester or may result in an oak tree violation.

- Excavations shall be covered or fenced to protect free-roaming cattle.

- Adjacent streets shall be swept manually or with water sweepers at the end of each day if visible soil material is carried onto paved public roads (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 Valencia Boulevard or McBean Parkway.

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

- All County of Los Angeles fire control measures shall be implemented during construction.

- Equipment and spoils shall not be stored in a location that is visually prominent from Interstate 5 (screening may be required).

- Implementation of this variance in accordance with the provisions noted above shall be verified on a random basis by a CPUC/ANF Environmental Monitor.


Andrew Barnsdale
Project Manager


cc: R. Borden, ANF
H. Rastegar, Aspen

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