EXECUTIVE SUMMARY

This Implementation Plan has been developed to ensure compliance with the objectives of the Mitigation Monitoring, Compliance and Reporting Program (MMCRP) adopted by the California Public Utilities Commission (CPUC) as a condition of project approval for the construction of the Carson to Norwalk Pipeline Project. Aspen Environmental Group (Aspen) has been designated by the CPUC as the environmental consultant responsible for implementing the MMCRP under the direction of the CPUC. This Implementation Plan describes in detail the actions that will be taken by Aspen and its team of subcontractors (the Aspen team) to ensure that the construction of the Carson to Norwalk Pipeline takes place in a manner consistent with the mitigation measures adopted by the CPUC (Lead Agency under CEQA) in the Final Environmental Impact Report (FEIR) and in compliance with project parameters defined by the Applicant in its Application.

Mitigation measures that will be implemented under this program were developed in the Carson to Norwalk Pipeline Project Final Environmental Impact Report (FEIR, 1998). That document also included description of project design and impact-reduction measures to which Santa Fe Pacific Pipeline Partners, L.P. (SFPP) committed as part of their proposed project; the implementation of those "Applicant-proposed measures" and project parameters will also be monitored as part of the Mitigation Monitoring, Compliance and Reporting Program (MMCRP).

Following an Introduction in Section 1, Section 2 of this Implementation Plan describes in more detail the purpose and objectives of the MMCRP, the authorities supporting implementation of the Program, and the background of Program adoption. Section 3 of the Plan describes the management structure for Aspen's monitoring team, and defines responsibilities and organization for Aspen and SFPP and its Contractor/Subcontractors. This section also describes the field monitoring process that will be used, and the Public Access Program that will be in place to provide the necessary information to the public regarding construction of the project.

Also included in this Plan, in Section 4, is a summary of the plans and permits that will be submitted by SFPP or issued by responsible agencies. These plans will be reviewed during the pre-construction and pre-operation phases of the project. Section 5 of this Implementation Plan includes detailed descriptions of training programs and manuals.

The core of this Implementation Plan is contained in Section 6, which will be used as the Field Monitoring Manual. This section includes a description of the Carson to Norwalk Pipeline Project; the roles, responsibilities, and authority of field monitors and expert reviewers in the field; descriptions of agency jurisdictions; guidance on interaction with SFPP and contractor personnel; communication protocols; and instruction on documentation and reporting. Section 6 also defines the compliance evaluation process, including the procedures for determining non-compliance events; dispute resolution process; and variance procedures. Monitoring criteria are presented, along with a general description of the mitigation measures, applicant-proposed measures, and other permits and requirements.

Four Appendices are included in this Implementation Plan. They include the full text of mitigation measures as they appeared in the FEIR adopted by the CPUC, performance and effectiveness criteria for each measure, Applicant-proposed measures, a list of permits issued by other agencies, and other regulatory requirements.

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