FEIS - Tahoe Regional Planning Agency
FEIS - Tahoe Regional Planning Agency FEIS - Tahoe Regional Planning Agency
RESPONSE TO COMMENTS ON THE DEIS B o u l d e r B a y C o m m u n i t y E n h a n c e m e n t P r o g r a m P r o j e c t E I S reader. The calculations that were performed are summarized in Tables 4.3-5 through 4.3-12. DEIS Appendix G provides the supporting data. The data that were used are based on the contributing areas, impervious surface areas, and the treatment capacities proposed. These numbers and calculations vary in accordance with the characteristics of the Alternative. The LID strategy assumptions used for the calculations are outlined in DEIS Appendix R. Comment 335-ab: Comment Summary - App. P should describe the certainty of the estimates based on the limited sampling, and how the events compare to 20-, 50-, and 100-year events. DEIS Appendix P presents the results from the pre-project monitoring completed for purposes of characterizing the existing conditions of the project area and to appropriately design and size the proposed stormwater treatment systems. The storm events are summarized on pages 4.3-5 to 4.3-7 of the DEIS and detailed in Appendix P. Comment 335-ac: Comment Summary - Clarify fine sediment sampling methods and results. As stated in DEIS Appendix J and reiterated in the DEIS hydrology analysis, the loading estimates should be used with caution because of the small sample size. See Appendix AB for supplemental surface water quality analysis that further supports the level of impact conclusions for HYDRO-1 and HYDRO-3. Automated samplers are not currently installed. The range is large because the loading estimates are presented by "event basis", meaning that 253 lb/day was measured for one storm event and 9,947 lbs/day was measured for a separate event. The range provided in the DEIS states the range calculated for the 6 events. See Appendix AB for annual loading estimates. The 34,450 lbs/yr is within the predicted range of 12,245 lbs of total sediment in a dry water year (1993-94) to 52,825 lbs of total sediment in a wet water year (1994-1995). Additional estimates for other water year scenarios are listed in Tables 2 and 3. The fine sediment analysis for the events did differ slightly as explained in the JBR report. There is no codified regulation that requires analysis of fine sediment at this time. The analyses were completed voluntarily to characterize the project area and appropriately design and size stormwater treatment systems. Comment 335-ad: Comment Summary - Define the terms "effective coverage", "Minimum capacity (TRPA Coverage): 100% of 50-year/1-hr storm” and “Minimum Capacity (TMDL Reduction Coverage): 100% of 100yr/1hr storm" in relation to TRPA and other agency regulations. As stated on page 4.3-29: Effective coverage is defined as subset of total impervious area that is hydrologically-connected via sheet flow or discrete conveyance to a drainage system or receiving body of water (Washington State University 2005). This is a standard term used when discussing strategies for direct reductions in runoff contributions or attenuation of peak runoff volumes. TRPA does not regulate effective coverage. Assuming that the commenter is referring to DEIS Appendix R, Minimum Capacity (TRPA Coverage) means based on TRPA defined land coverage and Minimum Capacity (TMDL Coverage Reductions) means that LID effective coverage reductions are included. The calculations in support of the 100yr/1hr storm volume capture are summarized in Table 4.3-12. Comment 335-ae: Comment Summary - Provide data supporting the performance of pervious pavement, the sweeper plan, green roofs, and SWT bio-retention systems for reducing fine sediments and nutrients. PAGE 8- 150 HAUGE BRUECK ASSOCIATES SEPTEMBER 8 , 2010
RESPONSE TO COMMENTS ON THE DEIS B o u l d e r B a y C o m m u n i t y E n h a n c e m e n t P r o g r a m P r o j e c t E I S See DEIS Appendix R, which outlines the assumptions made for LID performance strategies (termed TMDL reduction). In all instances, calculations use the most conservative of values. The following references are incorporated as support of LID strategy performance and effectiveness: http://www.unh.edu/erg/cstev/; http://water.washington.edu/Research/stormwater.html; http://www.epa.gov/owow/nps/lid/costs07/documents/reducingstormwatercosts.pdf; http://www.lowimpactdevelopment.org/lidphase2/; http://www.nrdc.org/water/pollution/storm/chap12.asp; http://www.nrdc.org/water/pollution/storm/stoinx.asp; and http://www.dot.ca.gov/dist3/departments/envinternet/deicer/03A1295NEAT_2010Ma rch.pdf. a) Pervious pavers were calculated at 50% reductions, which is already conservative based on reported performance abilities of 70-90%. This conservative approach accounts for variable performance expected for cold weather climates. b) Maintenance will be determined by post-project monitoring results and in accordance with the Inspection, Maintenance and Monitoring Plan (SP-10) developed for the selected Alternative. c) Modeled performance for green roofs was calculated at 20% to account for cold weather climate. Effectiveness of green roofs could be greater, but calculations use a more conservative assumption. The length of monitoring will be determined during permitting of the selected Alternative. Snowfall and freeze/thaw cycles will affect green roofs performance, which is why the conservative 20% was used in the calculations. d) See Appendix AB for predicted load reductions. The supplemental water quality analysis predicts reductions of total sediment of 97-100% for Alternatives C and D. Tables 2 and 3 present the load reductions by pound for a variety of water year conditions between 1993 and the present. Comment 335-af; Comment Summary - Clarify the type of sweeper that will be used: high efficiency, vacuum, regenerative air, dustless. The type of sweeper that will be required will be determined by TRPA based on the selected Alternative. The sweeper will incorporate a vacuum fan design that delivers superior dry-dust control that meets stringent PM-10 environmental requirements consistent with the Tennant Sentinel and Tymco DST sweepers. The regenerative air street sweeper and associated effectiveness for removal of sediment is presented in DEIS Appendix R as an option for the Project. The frequency of sweeping will be determined as part of the Operations and Maintenance Plan and amended based on post-project monitoring results. The TMDL reduction parameters table is a summary of the strategies proposed. Comment 335-ag: Comment Summary - The EIS needs to quantify expected population levels and water supply needs for each Alternative, and compliance with TROA on a project-level and cumulative level; identify water supply sources and rights. Population levels per Alternative are discussed in Chapter 4.11-Socioeconomics, Population, and Housing pages 4.11-10 through 4.11-14. Water supply needs are provided on page 4.12-13 for Alternatives C, D, and E. Please see responses to comments 322-br and 332-be regarding water rights purchase and TROA. SEPTEMBER 8 , 2010 HAUGE BRUECK ASSOCIATES PAGE 8- 151
- Page 99 and 100: RESPONSE TO COMMENTS ON THE DEIS B
- Page 101 and 102: RESPONSE TO COMMENTS ON THE DEIS B
- Page 103 and 104: RESPONSE TO COMMENTS ON THE DEIS B
- Page 105 and 106: RESPONSE TO COMMENTS ON THE DEIS B
- Page 107 and 108: RESPONSE TO COMMENTS ON THE DEIS B
- Page 109 and 110: RESPONSE TO COMMENTS ON THE DEIS B
- Page 111 and 112: RESPONSE TO COMMENTS ON THE DEIS B
- Page 113 and 114: RESPONSE TO COMMENTS ON THE DEIS B
- Page 115 and 116: RESPONSE TO COMMENTS ON THE DEIS B
- Page 117 and 118: RESPONSE TO COMMENTS ON THE DEIS B
- Page 119 and 120: RESPONSE TO COMMENTS ON THE DEIS B
- Page 121 and 122: RESPONSE TO COMMENTS ON THE DEIS B
- Page 123 and 124: RESPONSE TO COMMENTS ON THE DEIS B
- Page 125 and 126: RESPONSE TO COMMENTS ON THE DEIS B
- Page 127 and 128: RESPONSE TO COMMENTS ON THE DEIS B
- Page 129 and 130: RESPONSE TO COMMENTS ON THE DEIS B
- Page 131 and 132: RESPONSE TO COMMENTS ON THE DEIS B
- Page 133 and 134: RESPONSE TO COMMENTS ON THE DEIS B
- Page 135 and 136: RESPONSE TO COMMENTS ON THE DEIS B
- Page 137 and 138: RESPONSE TO COMMENTS ON THE DEIS B
- Page 139 and 140: RESPONSE TO COMMENTS ON THE DEIS B
- Page 141 and 142: RESPONSE TO COMMENTS ON THE DEIS B
- Page 143 and 144: RESPONSE TO COMMENTS ON THE DEIS B
- Page 145 and 146: RESPONSE TO COMMENTS ON THE DEIS B
- Page 147 and 148: RESPONSE TO COMMENTS ON THE DEIS B
- Page 149: RESPONSE TO COMMENTS ON THE DEIS B
- Page 153 and 154: RESPONSE TO COMMENTS ON THE DEIS B
- Page 155 and 156: RESPONSE TO COMMENTS ON THE DEIS B
- Page 157 and 158: RESPONSE TO COMMENTS ON THE DEIS B
- Page 159 and 160: RESPONSE TO COMMENTS ON THE DEIS B
- Page 161 and 162: RESPONSE TO COMMENTS ON THE DEIS B
- Page 163 and 164: RESPONSE TO COMMENTS ON THE DEIS B
- Page 165 and 166: RESPONSE TO COMMENTS ON THE DEIS B
- Page 167 and 168: RESPONSE TO COMMENTS ON THE DEIS B
- Page 169 and 170: RESPONSE TO COMMENTS ON THE DEIS B
- Page 171 and 172: RESPONSE TO COMMENTS ON THE DEIS B
- Page 173 and 174: RESPONSE TO COMMENTS ON THE DEIS B
- Page 175 and 176: RESPONSE TO COMMENTS ON THE DEIS B
- Page 177 and 178: RESPONSE TO COMMENTS ON THE DEIS B
- Page 179 and 180: RESPONSE TO COMMENTS ON THE DEIS B
- Page 181 and 182: RESPONSE TO COMMENTS ON THE DEIS B
- Page 183 and 184: RESPONSE TO COMMENTS ON THE DEIS B
- Page 185 and 186: RESPONSE TO COMMENTS ON THE DEIS B
- Page 187: RESPONSE TO COMMENTS ON THE DEIS B
- Page 190 and 191: REVISIONS TO THE DEIS B o u l d e r
- Page 192: REVISIONS TO THE DEIS B o u l d e r
RESPONSE TO COMMENTS ON THE DEIS<br />
B o u l d e r B a y C o m m u n i t y E n h a n c e m e n t P r o g r a m P r o j e c t E I S<br />
See DEIS Appendix R, which outlines the assumptions made for LID performance<br />
strategies (termed TMDL reduction). In all instances, calculations use the most<br />
conservative of values. The following references are incorporated as support of LID<br />
strategy performance and effectiveness:<br />
http://www.unh.edu/erg/cstev/;<br />
http://water.washington.edu/Research/stormwater.html;<br />
http://www.epa.gov/owow/nps/lid/costs07/documents/reducingstormwatercosts.pdf;<br />
http://www.lowimpactdevelopment.org/lidphase2/;<br />
http://www.nrdc.org/water/pollution/storm/chap12.asp;<br />
http://www.nrdc.org/water/pollution/storm/stoinx.asp; and<br />
http://www.dot.ca.gov/dist3/departments/envinternet/deicer/03A1295NEAT_2010Ma<br />
rch.pdf.<br />
a) Pervious pavers were calculated at 50% reductions, which is already conservative<br />
based on reported performance abilities of 70-90%. This conservative approach<br />
accounts for variable performance expected for cold weather climates.<br />
b) Maintenance will be determined by post-project monitoring results and in<br />
accordance with the Inspection, Maintenance and Monitoring Plan (SP-10) developed<br />
for the selected Alternative.<br />
c) Modeled performance for green roofs was calculated at 20% to account for cold<br />
weather climate. Effectiveness of green roofs could be greater, but calculations use a<br />
more conservative assumption. The length of monitoring will be determined during<br />
permitting of the selected Alternative. Snowfall and freeze/thaw cycles will affect<br />
green roofs performance, which is why the conservative 20% was used in the<br />
calculations.<br />
d) See Appendix AB for predicted load reductions. The supplemental water quality<br />
analysis predicts reductions of total sediment of 97-100% for Alternatives C and D.<br />
Tables 2 and 3 present the load reductions by pound for a variety of water year<br />
conditions between 1993 and the present.<br />
Comment 335-af; Comment Summary - Clarify the type of sweeper that will be used: high efficiency,<br />
vacuum, regenerative air, dustless.<br />
The type of sweeper that will be required will be determined by TRPA based on the<br />
selected Alternative. The sweeper will incorporate a vacuum fan design that delivers<br />
superior dry-dust control that meets stringent PM-10 environmental requirements<br />
consistent with the Tennant Sentinel and Tymco DST sweepers. The regenerative air<br />
street sweeper and associated effectiveness for removal of sediment is presented in<br />
DEIS Appendix R as an option for the Project. The frequency of sweeping will be<br />
determined as part of the Operations and Maintenance Plan and amended based on<br />
post-project monitoring results. The TMDL reduction parameters table is a summary<br />
of the strategies proposed.<br />
Comment 335-ag: Comment Summary - The EIS needs to quantify expected population levels and water<br />
supply needs for each Alternative, and compliance with TROA on a project-level and<br />
cumulative level; identify water supply sources and rights.<br />
Population levels per Alternative are discussed in Chapter 4.11-Socioeconomics,<br />
Population, and Housing pages 4.11-10 through 4.11-14. Water supply needs are<br />
provided on page 4.12-13 for Alternatives C, D, and E. Please see responses to<br />
comments 322-br and 332-be regarding water rights purchase and TROA.<br />
SEPTEMBER 8 , 2010 HAUGE BRUECK ASSOCIATES PAGE 8- 151