_Executive SummaryExecutive Summary
Executive Summary
Espola Road Improvement Project Final EIR ES-1
May 2013
EXECUTIVE SUMMARY
This summary provides a brief synopsis of the Espola Road Improvement Project (Project), the
results of the environmental analysis, and Project alternatives considered within this
Environmental Impact Report (EIR). The summary does not contain the extensive background
and analysis found in this EIR. Therefore, the reader should review the entire EIR to fully
understand the Project, its alternatives and its environmental consequences.
ES.1 INTRODUCTION
The City of Poway (City) is proposing to address roadway capacity and safety enhancements on
Espola Road, located within the City. This EIR addresses the Project and is an informational
document intended for use by both decision makers and the public. It has been prepared
specifically to disclose information regarding the Project and its potential environmental impacts
and benefits for any interested member of the public, as well as the City Council, which will be
making a decision about whether or not to approve the Project based on its contents.
Because the City proposes partial use of federal funds for the Project, the Project is subject to
federal, as well as City and state, environmental review requirements. Project technical
documentation has been prepared in compliance with the California Environmental Quality Act
(CEQA). This EIR has been prepared in accordance with the requirements of CEQA, the State
CEQA Guidelines (as amended) and City standards.
There are two lead agencies for this Project under state and federal laws. Lead agencies are
those public agencies with responsibility for preparing and approving the document. The City is
the lead agency for CEQA because the roadways are located within City boundaries, the Project
falls under the jurisdiction of the City’s Development Services Department and the City is the
Project proponent. Because of anticipated partial federal funding, the Federal Highway
Administration (FHWA) traditionally would be lead agency under the National Environmental
Policy Act (NEPA), with the California Department of Transportation (Caltrans) acting as its
agent and providing oversight for the NEPA processing. While retaining responsibility for
engineering, in 2007, the FHWA delegated responsibility for environmental analysis on local
roadways to Caltrans, so that Caltrans now acts as lead agency for NEPA documentation.
Should the City continue to pursue partial federal funding, it is anticipated that Caltrans will
prepare a Categorical Exclusion under NEPA (which will be separately circulated).
Updates/modifications to NEPA-required technical studies prior to Categorical Exclusion
preparation would also be completed.
Following public circulation of this EIR and receipt of comments from the public and reviewing
agencies, the City may: (1) give environmental approval to the proposed Project, (2) undertake
additional environmental studies, or (3) abandon the Project. If the Project is given
environmental approval and funding is appropriated, the City could design and construct all or
part of the Project.
Executive Summary
Espola Road Improvement Project Final EIR ES-2
May 2013
ES.2 PROJECT LOCATION AND ENVIRONMENTAL SETTING
Location and Relation to Surrounding Roadways
The Project site is located in the eastern portion of the City of Poway in San Diego County,
California. Espola Road, also known as County Road S5, serves as a primary link between
Poway’s northern, northeastern, and central residential areas. It also provides the northernmost
link between Poway and Interstate 15 (I-15), and, as such, it provides an important east-west
route in the northern portion of Poway. The Project area contains a variety of land uses
overwhelmingly dominated by single-family residential dwelling units. The number of cross
streets and driveway access points onto Espola Road on this portion of the roadway decreases its
usefulness for through traffic. The segment of Espola Road south of the Project area, between
Twin Peaks Road and Poway Road, also serves as an important inter-city link and a regional link
between I-15 and State Route 67 (SR 67).
Within the study area, Espola Road is currently a two-lane collector extending in a north-south
direction with a posted speed limit of 45 miles per hour. The current Master Transportation
Element uses a design capacity threshold for service. The threshold is 80 to 90 percent of
capacity, which translates to level of service (LOS) D. (Capacity, at a 1:1 volume equals
capacity, translates to LOS E.) According to the 2006 Traffic Analysis, the segments of Espola
Road between Twin Peaks Road and Titan Way operate at the equivalent of LOS F with an
average daily traffic (ADT) ranging between 19,327 and 21,165. By 2030, Espola Road between
Twin Peaks Road and Titan Way is forecasted to carry ADT ranging between 21,378 and 23,411,
all of which would remain LOS F.
LOS A through D is considered acceptable for street segments and intersections in urbanized
areas by the City. These levels assume that delays at intersections do not exceed 10, 20, 35, and
55 seconds, respectively. The unsignalized intersection of Espola Road and Durhullen
Drive/Golden Sunset operates at LOS F (greater than 80 seconds delay) in the a.m. peak hour,
and at LOS E in the p.m. peak hour. Per the 2006 Traffic Analysis, all other intersections
operate at an acceptable LOS C or B for both the a.m. and p.m. peak hours. The Transportation
Master Element (TME) of the City’s General Plan, amended in 2010, specifies that this segment
of Espola Road be improved to include a 12-foot wide two-way left-turn lane in the roadway
median, as well as bike lanes. The road would then have a design threshold of 24,000 ADT, with
a capacity of 29,000 ADT (City 2010).
Changes in Adjacent Uses/Planning Constraints
Within a period of 50 years, the community grew from less than 1,600 persons (in 1957) to a
primary residential and commercial community with a population of approximately 50,000.
During the 1970s, Poway’s population increased by 139 percent (from 14,000 people to nearly
33,500). Between 1980 and 1990, City population growth increased 30 percent—from
approximately 33,500 to over 43,500 (City 1991b); and in 2010, a population of 47,811 people
lived in the City (2010 U.S. Census). The projected rate of growth is now slowing. By 2020, an
estimated 54,070 people will reside in City, and population is projected to increase to 59,808 by
2050 (SANDAG 2010b).
Executive Summary
Espola Road Improvement Project Final EIR ES-3
May 2013
Within the segment of Espola Road addressed by this Project, the above-described growth was
clearly reflected during this same period (1955 on). The portion of Espola Road between Twin
Peaks Road and the northern Project terminus was primarily undeveloped at the beginning of this
period. Currently, Espola Road is edged by a fairly dense concentration of primarily single-
family residential uses (individually designed and built homes as well as housing tracts),
although some commercial, religious, recreational and educational facilities also are present.
Facilities abutting or accessed via Espola Road include both open space and developed uses.
The Blue Sky Ecological Reserve (Reserve), located approximately 0.7 mile northeast of the
Project alignment, is a 700-acre natural habitat reserve with hiking, horseback riding and
interpretive trails. Lake Poway Recreational Area, located just to the south of the Reserve, also
offers multiple recreational activities. The Poway Center for the Performing Arts (PCPA), an
815-seat professional theater, is located just north of the northern terminus of the proposed
Project, adjacent to Poway High School (PHS) at Titan Way. At the extreme south end of the
Project alignment, immediately south of Twin Peaks Road, the Church of Jesus Christ of Latter-
day Saints is located east of Espola Road. The Montessori Child Development Center is located
on the east side of Espola Road, approximately mid-way through the Project to the west. The
Poway Valley Riders Association (PVRA) equestrian center is located approximately 0.25 mile
west of Espola Road, south of Twin Peaks Road.
Elements of native habitat still exist within the Project study area. These areas contain remnants
of southern mixed chaparral, Diegan coastal sage scrub, non-native grassland, southern willow
riparian forest, and southern willow scrub.
Overall, although the nature of the community abutting the roadway has physically changed, one
of the City’s enduring characteristics is a population that retains interest in more rural pursuits.
Of particular note is the fact that a number of properties along this segment of the road (as well
as residences set off the road, but using Espola Road as primary access) support equestrian uses
in addition to residences.
North-south trails are shown in the TME in the vicinity of Espola Road, and the primary local
equestrian center (PVRA) is located south of Twin Peaks Road to the west of the Project area.
Equestrians cross Espola Road at signalized intersections using signal change buttons sited for
pedestrians at Del Poniente, and cross from sidewalk to sidewalk using equestrian signal change
buttons at Twin Peaks Road. A signed unsignalized horse crossing also is located at Mountain
Road, which may contribute to riders routing themselves along Espola Road (where no
equestrian path exists or is planned).
ES.3 PROJECT HISTORY
The City has been monitoring conditions of vehicular congestion and pedestrian/equestrian uses
along Espola Road for the past decade. According to the City General Plan TME, the roadway
has been slated for widening and associated improvements for over 25 years. A program to
widen the road was first actively pursued by the City in the late 1990s, but lapsed due to funding
issues (as well as opposition from abutting property owners).
Executive Summary
Espola Road Improvement Project Final EIR ES-4
May 2013
In 2002, however, the regional need to pursue improvements to this roadway segment, as well as
the possibility of obtaining federal funding to help pay for the Project, led the City to again
pursue bringing the roadway into compliance with the City’s General Plan. At that time, Espola
Road was planned to be four lanes in this area, and 2003 design efforts identified three
alternatives that would improve this segment of the road to that standard, as well as associated
improvements for pedestrian, equestrian and bicycle users.
New modeling undertaken by the City to update the traffic projections through 2030 (earlier
modeling covered the period through 2025) also focused on specific segments of Espola Road rather
than relying on more generalized modeling provided by SANDAG for all area roads (and upon
which earlier traffic modeling had been based). This more specific review indicated that a three-lane
design would be functional and operate within desired standards. As noted above, the current TME
plans Espola Road to be two through lanes with a center two-way left-turn in this area, and 2003
design efforts identified three alternatives that would improve this segment of the road to that
standard, as well as associated improvements for pedestrian, equestrian and bicycle users.
The three-lane alternative is the Project described below and addressed in Chapters 2.0 and 3.0
of this EIR. The three-lane design is located wholly within the footprint of design scenarios
evaluated for a four-lane roadway and would result in fewer environmental impacts while still
meeting Project objectives (see below). Another beneficial aspect of the smaller footprint is that
a full parcel acquisition that would have been required under one of the previously analyzed
design scenarios (Assessor’s Parcel Number [APN] 321-011-24; see Chapter 6.0 of this EIR)
would not occur under the current Project.
ES.4 PROJECT OBJECTIVES
As stated in the City of Poway General Plan, it is the goal of the City “…to provide a safe,
realistic, efficient, and integrated transportation system to serve the present and future mobility
needs of all the residents of Poway” (City 1991a:2, as amended). The proposed Project is
designed to relieve congestion, and improve safety (vehicle, pedestrian, bicycle and equestrian)
and roadway operations on Espola Road.
The Project would increase the capacity of the existing roadway, resulting in Espola Road
meeting the design capacity threshold and operating at the equivalent of an improved LOS D or
C for Espola Road segments between Titan Way and Twin Peaks Road. Intersections would
operate at LOS D (Espola Road at Twin Peaks in the a.m. peak hour) to LOS A, B or C for all
other signalized intersections (including Espola Road and Durhullen Drive/Golden Sunset, which
would be signalized as part of the Project). Roadway safety also would be improved, due to
incorporation of consistent (and continued) bike lanes and pathways edging the road.
ES.5 PROJECT DESCRIPTION
In overview, the proposed Project would provide circulation improvements to Espola Road from
approximately 1,000 feet south of the intersection of Espola Road and Titan Way (just north of
Willow Ranch Road) to the intersection of Espola Road and Twin Peaks Road, with drainage
improvements continuing to approximately 500 feet south to where Espola Road crosses
Executive Summary
Espola Road Improvement Project Final EIR ES-5
May 2013
Rattlesnake Creek. Improvements would consist of widening and resurfacing the road from a
two-lane to three-lane facility. Necessary traffic safety (new or upgraded signals), utilities
(undergrounding), drainage (increased capacity), pedestrian (sidewalks and pathways), bikeway
(designated bicycle lanes), equestrian crossings (a marked crossing with equestrian push buttons
at Del Poniente Road) and landscaping improvements (slope and parkway plantings with street
trees) also would occur. These improvements would take place within slightly expanded road
right-of-way; new right-of-way would total 18,687 square feet.
Roadway Upgrades
One 12-foot wide vehicle lane would carry traffic in each direction from the northern Project
terminus south of Titan Way to the intersection of Espola Road and Twin Peaks Road. A
dedicated 12-foot wide turn lane would be located between them. The Project generally would
be superimposed on the existing road right-of-way, and would follow both the horizontal and
vertical alignment of the current road. Roadway right-of-way would range from 60 to 96 feet in
width. The road would continue to have a design speed of 45 miles per hour.
One traffic signal would be upgraded (at the intersection of Espola Road with High Valley
Road/Del Poniente Road), and one new signal would be constructed at the intersection of Espola
Road and Golden Sunset/Durhullen Drive.
Minimum eight-foot wide bike lanes and five-foot wide sidewalks would parallel improved
portions of the road on both sides, which is consistent with the 2010 TME. Where possible, a
non-contiguous sidewalk would be installed with a landscaped parkway to separate vehicular
traffic from pedestrian traffic.
New landscaping generally would be provided along the length of the improved roadway, and is
planned to both provide a unifying Project element (both along this section of Espola Road, as
well as with other major City streets) and screen potential sound walls proposed as sound
mitigation. The proposed landscape plant palette complies with the City’s Landscape and
Irrigation Design Manual (City 2010), as well as Executive Order 13112 for federally funded
projects, which prohibits use of invasive plant species.
A total of approximately 1,850 feet of retaining walls—varying from 3 to 11 feet in height—is
proposed as part of the Project. All of these retaining walls would be provided north of Jerome
Drive, with the highest (11-foot) wall located on the east side of Espola Road.
New street lighting would consist of concrete poles supporting 180-watt low-pressure sodium
lamps spaced 250 to 300 feet apart on both sides of Espola Road. Proposed improvements to
Espola Road also would require the relocation of several existing electric, gas, cable, telephone
and water utility lines. No sewer relocations would be required.
The City also would modify and/or replace the existing storm drain system along the roadway
with upgraded facilities. The existing system is primarily corrugated metal pipe and, over the
years, has deteriorated significantly, and the existing systems are undersized in many locations.
Accordingly, all proposed storm drain facilities would be designed to accommodate 100-year
Executive Summary
Espola Road Improvement Project Final EIR ES-6
May 2013
storm flows (per City standards) and would consist of reinforced concrete pipe or reinforced
concrete box culverts. In addition, the existing outlet structure discharging to the Rattlesnake
Creek tributary at the southern end of the study area would be modified or replaced in the same
location.
Construction Activities
Project implementation would include excavation, grading and construction activities associated
with the above-described road improvements, culminating in a total of approximately 17.2 acres
of hardscape at ultimate buildout (including both existing and new hardscape).
Construction activities generally would occur within the existing roadway right-of-way, as well
as a Project staging area, which is a City-owned parcel located on Twin Peaks Road just west of
the Espola Road. Two open travel lanes would be maintained during construction during the
a.m. and p.m. peak traffic hours. Excluding a.m. and p.m. peak travel periods, traffic control
flaggers would route drivers and bicyclists along a single lane adjacent to the construction zone.
Lane closures would not be allowed during commute hours (7:00 to 9:00 a.m., 2:00 to 3:00 p.m.
and 4:00 to 6:00 p.m.).
Approximately 12.1 acres would be graded and primary grading activities would be completed
within a four-month period. Preliminary earthwork totals assume approximately 5,691 cubic
yards of cut and 7,905 cubic yards of fill material (soil import is anticipated). Maximum cut and
fill slopes generally would be approximately 25 feet in height, with maximum grades of
50 percent (2:1) for manufactured slopes. Blasting may be required in areas of shallow bedrock,
and some large rocks are present in the vicinity of Northcrest Lane on the east side of Espola
Road. (It is possible that the rocks may be broken rather than blasted apart.) Where blasting is
necessary, these operations would precede other roadway grading activities and would be
completed in a relatively short time period.
In accordance with the Poway Municipal Code (PMC), Project construction typically would be
limited to the hours of 7:00 a.m. to 7:00 p.m. Monday through Saturday (excluding holidays), and
the construction activity noise level would not be permitted to exceed an 8-hour average of
75 decibels during any 24-hour period when measured at an existing (or proposed) residential
property line. Work would occur on Sundays, holidays or nighttime only if required and approved
by the City for health and safety purposes (e.g., emergency access is somehow blocked or blasting
has left an unsafe condition).
The proposed Project would require the reconstruction of several driveway approaches located
along Espola Road. Driveways in areas of steeper slopes would be realigned/reconstructed at a
maximum grade of 25 percent, in accordance with City standards. It is anticipated that
reconstruction of individual driveway approaches temporarily would interrupt driveway access
for approximately 6 to 72 hours. The timing of driveway approach reconstruction and location
of alternative parking would be coordinated with each individual property owner prior to
construction.
Executive Summary
Espola Road Improvement Project Final EIR ES-7
May 2013
The Project design would include a number of standard measures to minimize effects related to
air and water contamination during construction. The Project construction program would
include a temporary traffic control plan to minimize interruptions of existing traffic patterns and
avoid related safety hazards during construction, in accordance with California Manual on
Uniform Traffic Control Devices (MUTCD). It is possible that during reconstruction of
driveways a portion of the existing driveways could be maintained for use. In any event, access
to existing homes and businesses along or adjacent to the Project site would be maintained
during construction by creating temporary driveways, and/or providing alternate access points,
all within the evaluated Project footprint.
ES.6 REQUIRED DISCRETIONARY PERMITS AND ACTIONS
City Discretionary Actions
Following receipt of public comments on the EIR and circulation of the Final EIR, the City
Council will determine whether to certify the EIR and issue Findings. The Findings will
summarize significant impacts associated with the Project. If mitigation is not proposed that
would reduce the impact to less than significant levels following implementation, a Statement of
Overriding Considerations (SOC) will identify each of those impacts, and explain both why the
impact is not being fully mitigated and what overriding consideration supports the City in
moving forward. (Overriding considerations would explain the City’s reason[s] regarding why
on balance Espola Road conditions with the Project impact would be more beneficial than
conditions without the Project.) The City Council also must make a decision in the future
whether to approve the Project for construction and approve required land acquisitions.
Other Discretionary Actions
As the federal Lead Agency with authority delegated by the FHWA, Caltrans will prepare a
Categorical Exclusion based on technical studies to support the separate federal NEPA
documentation process and make the appropriate conclusions regarding the level of significance
of Project impacts.
The City will not be able to access federal funds for final design, right-of-way arrangements or
construction until both the City’s CEQA process and the federal NEPA environmental process
are complete. In addition, the FHWA will only provide federal funding for a project that is
considered feasible under NEPA, meaning the Project provides all features needed to completely
meet the purpose and need. Therefore, if the City selects a design that is not considered to be
feasible by FHWA/Caltrans, federal funding would not be provided and Project monies would
have to be obtained by the City from a different source.
Other agencies would use this document to make discretionary decisions regarding Project
permits in accordance with CEQA and NEPA requirements, as summarized in Table ES-1.
Executive Summary
Espola Road Improvement Project Final EIR ES-8
May 2013
Table ES-1
PERMITS AND APPROVALS
Agency Permit/Approval Status
U.S. Army Corps of
Engineers (Corps)
Nationwide Permit 14 (Linear
Transportation Crossings) under
Section 404 of the Clean Water Act
Requires Section 401 Water
Quality Certification for permit
authorization (see below)
U.S. Fish and Wildlife
Service (USFWS) Section 7 Consultation (informal) Informal consultation was
completed June 2007
Caltrans Headquarters Post-1960 structures analysis under
Programmatic Agreement
Concurrence received
May 2005
State Historic
Preservation Officer Section 106 Consultation
Concurrence on finding of No
Historic Properties Affected
received January 3, 2006, with
update concurrence obtained
October 11, 2010
California Department
of Fish and Wildlife
(CDFW)
1602 Streambed Alteration
Agreement
Requires EIR certification for
Agreement issuance
Regional Water
Quality Control Board
(RWQCB)
Section 401 Water Quality
Certification
Requires EIR certification for
Certification issuance
Conformance with Municipal Storm
Water Permit
Conformance with existing
permit required; will be
demonstrated through
implementation of the approved
project Water Quality Technical
Report
Conformance with General
Groundwater Extraction Waste
Discharge Permit
Conformance with existing
permit required; will be
demonstrated through
application to the RWQCB and
implementation of appropriate
best management practices
(BMPs) by the construction
contractor
State Water Resources
Control Board
General Construction Activity Storm
Water Permit
Conformance with existing
permit required; will be
demonstrated through
implementation of a SWPPP to
be prepared by construction
contractor
Executive Summary
Espola Road Improvement Project Final EIR ES-9
May 2013
ES.7 ENVIRONMENTAL ANALYSIS
This EIR contains an environmental analysis of the potential impacts associated with
implementing the Project. Impacts associated with land use, visual/aesthetics, noise, biological
resources, cultural resources and geology/soils would be significant. Table ES-2 (at the end of
this section) summarizes the Project’s potentially significant environmental impacts and
proposed mitigation measures by issue, as analyzed in Chapter 2.0 of this EIR. The last column
of the table indicates whether the impact would be reduced to below a level of significance after
implementation of the proposed mitigation measures or could remain significant.
ES.8 EFFECTS FOUND NOT TO BE SIGNIFICANT
During preparation of this EIR, impacts associated with the following environmental issues were
determined to not be significant: traffic/transportation, air quality, hazards/hazardous materials,
paleontological resources, public services and population/housing.
Based on the initial study prepared for the proposed Project, the City has determined that the
Project would not have the potential to cause significant adverse effects in the following areas:
scenic highways and light and glare (aesthetics); agricultural resources; odor (air quality);
transport of hazardous materials, airport/airstrip conflict and risk of wildlife (hazards and
hazardous materials); mineral resources; airport proximity (noise); construction of replacement
housing and parks (population and housing); recreation; air traffic, hazards and emergency
access, and alternative transportation (traffic/transportation); and water and waste systems.
ES.9 PROJECT ALTERNATIVES
The alternatives addressed for this Project include the No Project, the Alternative Location, a
series of build alternatives developed for a potential four-lane roadway, and design alternatives
attempting to retain a two-lane configuration.
No Project Alternative
A “No Project” alternative discussion is an EIR requirement (State CEQA Guidelines Section
15126.6[e]). The No Project Alternative is included to provide a basis against which the impacts
from the build alternatives are compared. The No Project Alternative assumes that no major
improvements would be made and no major construction would occur on Espola Road and the
associated intersections within the Project area. Ongoing maintenance activities would continue.
Existing failing LOS on roadway segments and intersections would continue, and the City design
capacity threshold would not be met. The lack of standardized sidewalks/pathways along certain
portions of the road would be retained. The upgrades specified in the TME of the City’s General
Plan would not be implemented, and existing adverse conditions would be exacerbated as a
result of growth planned for the region in general.
As part of the No Project review, Traffic Management Systems (TMS) revisions were evaluated
to see if traffic flow could be improved without widening. Types of revisions/measures
evaluated for Espola Road include traffic signal coordination along the corridor, re-striping and
Executive Summary
Espola Road Improvement Project Final EIR ES-10
May 2013
any other measures that would improve operations without necessarily widening or physically
improving the roadway. Along the Project corridor, there are two traffic signals that could be re-
timed to provide better progression of vehicular traffic. The two signals are spaced
approximately 1.5 miles apart. Although re-timing them to be coordinated could gain some
additional vehicle progression efficiency, the additional efficiency gained would not provide
enough additional capacity to provide better LOS under the future timeframes. Re-striping
Espola Road also is not considered effective due to the limited roadway width available to
provide for additional lanes. Public transit operations, provided by Metropolitan Transit System
(MTS) are serving this section of Espola Road, with two bus routes that serve the area.
Therefore, of the limited number of options to revise the existing TMS, none is seen as a
practical alternative to the proposed Project. The future traffic volumes are such that non-
construction system modifications would not provide for the additional capacity necessary to
have acceptable operations and LOS. Roadway capacity and operational and safety deficiencies
would not be corrected with the implementation of the No Project Alternative. As a result, this
alternative does not meet the objectives of the proposed Project.
Alternatives Considered But Rejected
Alternative Location
Under CEQA, off-site alternatives should be considered if development of another site is feasible
and would reduce or avoid the significant impacts of a proposed project. Factors that need to be
considered when identifying an off-site alternative include the size of the site, its location, the
General Plan (or other applicable planning document) land use designation and availability of
infrastructure.
For Espola Road, the overall purpose is to alleviate congestion on an existing roadway in a
developed setting. If another road sited in an alternative location were to be improved, it could
not guarantee meeting the objective of satisfying reduction in congestion on Espola Road.
Travelers might choose to still use the existing congested roadway option due to familiarity, or
because it is in a more direct line of travel.
In addition, a baseline requirement of the CEQA alternative location is that the new location
reduces significant impacts associated with the location of the proposed project. Because there
are so few relatively direct north-south routes through the City, and because the surrounding
areas also are heavily developed or in dedicated open space, it is not anticipated that an
alternative location would lessen potential impacts. Any effort to find a route crossing open
space would result in likely increased biological impacts, which are minimal in amount with the
proposed Project. Similarly, although significant noise impacts are identified for the Project,
there is no location just west or east of Espola Road that would not affect existing adjacent
residences. A new road route would increase noise impacts by moving the road closer to other
homes, and potentially require removal of homes as well. A potential for greater, rather than
reduced, impacts overall would occur if the crossing location were to be changed.
Taking all of these factors into account, the identification of an alternative location was rejected
due to infeasibility.
Executive Summary
Espola Road Improvement Project Final EIR ES-11
May 2013
Design Alternatives Reviewed in Detail
Three build alternatives were given detailed analysis during earlier phases of this Project. These
include the Conventional Roadway (Alternative 1), the Split Grade Roadway (Alternative 2), and
the Westerly Roadway Alignment (Alternative 3).
Each of these build alternatives would have provided roadway and associated improvements to
Espola Road from approximately 1,000 feet south of the intersection of Espola Road and Titan
Way to the intersection of Twin Peaks Road and Espola Road (the same distance assumed for the
proposed Project). For all three alternatives, improvements would have consisted of widening
the two-lane road to a four-lane secondary arterial, as well as necessary traffic safety, drainage,
pedestrian, equestrian and landscaping improvements.
Alternative 1 – Conventional Roadway
Alternative 1 was generally superimposed on the existing road right-of-way, and would have
followed both the horizontal and vertical alignment of the current road. Alternative 1 also would
have included the following:
Re-routing of driveways for three properties south of High Valley Road on the east side
of the roadway. The re-routing would have required alternative access areas and
additional private access easements for these three properties
Substantial soil excavation (50 to 60 feet) into the slope on the east side of the roadway in
the area of Northcrest Lane and south of High Valley Road
Right-of-way and slope easement acquisition totaling 4.46 acres
One full parcel acquisition (APN 321-011-24) of property adjacent to Espola Road
immediately north of Jerome Drive
Similar to existing conditions, City secondary arterials have a design speed of 45 miles per hour.
An approximately 14-foot wide striped or raised median would have been included for the entire
length of the roadway widening. Similar to the proposed Project, one new signal would have
been constructed at the intersection of Espola Road and Golden Sunset Lane.
Alternative 2 – Split Grade Roadway
Alternative 2, a split grade alternative, incorporated many of the elements of Alternative 1. From
the vicinity of Golden Sunset Lane southerly, Project elements would have been identical.
Variations would have occurred on the east side of Espola Road just south of High Valley Road,
and in the area approximately 250 feet south of the water tank. The western (southbound) lanes
would have retained the existing grade and the eastern (northbound) lanes would have been
constructed at a higher grade supported by retaining walls, thereby minimizing cuts into slopes
on the east side of the roadway. The retaining walls would have ranged up to 10 feet in height.
Alternative 2 also would have included the following:
Reconstruction of the driveways for three properties south of High Valley Road on the
east side of the roadway
Executive Summary
Espola Road Improvement Project Final EIR ES-12
May 2013
Reduction in the size of cuts into slope required for Alternative 1 on the east side of the
roadway in the area of Northcrest Lane and south of High Valley Road
Reconstruction of several hundred feet of existing waterline in the area of Northcrest
Lane
Right-of-way and slope easement acquisition totaling 4.24 acres
Alternative 2 would vary from Alternative 1 in that:
No re-routing of driveways would be required
The full parcel acquisition of property (APN 321-011-24) adjacent to Espola Road
immediately north of Jerome Drive would have been eliminated
Alternative 3 – Westerly Roadway Alignment
Alternative 3, the residential property impact minimization alternative, also shared many
elements with Alternative 1, and was identical from High Valley Road northerly, and from the
vicinity of Golden Sunset Lane southerly. Just south of High Valley Road, and on the east side
of the roadway, right-of-way acquisition from residential properties would have been minimized,
with increased right-of-way acquisition occurring on the western side of the road. Right-of-way
and slope easement acquisition would total 4.82 acres.
Alternative 3 would have varied from Alternative 1 in:
Elimination of the full parcel acquisition of property (APN 321-011-24) adjacent to
Espola Road immediately north of Jerome Drive
Demolition and reconstruction of detached garage on property (APN 321-011-41) on
west side of roadway (across from APN 321-011-24)
No re-routing of the driveways for three properties south of High Valley Road on the east
side of the roadway
Reduction in size of excavation cuts into slope on the east side of the roadway in the area
of Northcrest Lane and south of High Valley Road and increases in fill on the west side
of Espola Road
Rationale for Rejecting Design Alternatives Reviewed in Detail
Because an objective of the Project is to improve conditions on an existing roadway, the
potential impact footprint within which to consider alternatives is relatively constrained. Any
roadway improvements would, therefore, necessarily affect abutting parcels. Project design was
guided by a desire on the part of the City to limit the adverse effects associated with roadway
widening, and retain the community’s rural character to the extent possible while still achieving
the improved LOS as outlined in the General Plan. Accordingly, project alternatives that would
sufficiently improve traffic conditions, while not requiring unnecessary expansion of the road
with greater need to acquire private property, were considered to be superior. As the Traffic
Analysis (Appendix F) discusses, the use of a two-way left-turn lane is appropriate for roadways
with less than 24,000 projected ADT and would still accomplish the LOS objectives on such a
road (KOA Corporation 2006). Because an alternative (the proposed Project) exists that would
Executive Summary
Espola Road Improvement Project Final EIR ES-13
May 2013
meet the Project objectives while requiring less acquisition of private property and minimizing
visual changes that might alter the rural character of the community, the three build alternatives
that involved construction of additional lanes were rejected.
Additional Design Alternatives
During the Project alternatives development process, additional build alternatives were considered
but eliminated from more detailed review in this EIR. The purpose of the following alternatives
was to reduce the amount of new right-of-way needed by reducing the Project footprint. These
include the Two-lane Collector with Safety Improvements (Alternative 4), Four-lane Intersection
Alternative (Alternative 4A), and Single-lane Roundabout Alternative (Alternative 5).
Alternative 4 – Two-lane Collector with Safety Improvements
Alternative 4 generally would have maintained Espola Road as a two-lane collector beginning
approximately 1,000 feet south of the intersection of Espola Road and Titan Way and ending
200 feet south of the crossing of Rattlesnake Creek. Improvements would consist of the
necessary traffic safety, drainage, sidewalk and pathway upgrades, and landscaping
improvements described for Alternative 1. A 12-foot wide striped or raised median would be
included for the entire length of the roadway widening.
Although the roadway would be maintained as a two-lane collector, the Espola Road and High
Valley Road traffic signal would be upgraded and one new signal would be constructed at the
intersection of Espola Road and Golden Sunset Lane. At each of these intersections,
Alternative 4 would add one through lane in each direction, and retain turn pockets for north-
and southbound traffic.
This alternative was eliminated from further evaluation because it was unable to meet the Project
objectives in their entirety. Improvements provided by the alternative would not adequately
meet the Project objectives for increased roadway capacity along the street segments. Each
roadway segment would continue to fail (equivalent to LOS F) with this alternative under both
the near-term and future scenarios.
Alternative 4A – Four-lane Intersection
Alternative 4A generally would have maintained Espola Road as a two-lane collector beginning
approximately 1,000 feet south of the intersection of Espola Road and Titan Way and ending
200 feet south of the crossing of Rattlesnake Creek. Improvements would have consisted of the
necessary traffic safety, drainage, sidewalk and pathway upgrades, and landscaping
improvements described for Alternative 1. A striped or raised median (12 feet wide) would have
been included for the entire length of the roadway widening.
Although the roadway would have been maintained as a two-lane collector, intersections would
have been improved by adding one additional through lane (for a total of two new lane segments)
in each direction to Espola Road at its intersection with Durhullen Drive/Golden Sunset Lane
and High Valley Road/Del Poniente Road. Similar to the proposed Project, one traffic signal
Executive Summary
Espola Road Improvement Project Final EIR ES-14
May 2013
would have been upgraded (at the intersection of Espola Road with High Valley Road), and one
new signal would have been constructed at the intersection of Espola Road and Golden Sunset
Lane. At each of these intersections, the alternative would retain turn pockets for north- and
southbound traffic.
This alternative was eliminated from further evaluation because it was unable to meet the Project
objectives in their entirety. Improvements provided by the alternative would not adequately
meet the Project objectives for safety or increased roadway capacity along the street segments.
With capacity enhancements (two through lanes in each direction) only at two intersections,
vehicles traveling through the improved intersections would have to immediately merge back
into a single travel lane in each direction between the signalized four-lane intersections and the
two-lane roadway segments. These conflict points would result in adverse effects on safety as
vehicles merge back onto the narrower roadway segments. A slight increase in roadway capacity
would have been realized from the additional lanes at the two intersections and the addition of a
raised median as discussed above but each roadway segment would continue to fail with this
alternative under both the near-term and future scenarios.
Alternative 5 – Roundabout
Alternative 5 also would have maintained Espola Road as a two-lane collector beginning at
approximately 1,000 feet south of the intersection of Espola Road and Titan Way and ending 200
feet south of the crossing of Rattlesnake Creek. Improvements would have consisted of the
traffic safety, drainage, sidewalks and pathways, and landscaping improvements described for
Alternative 1. A striped or raised median approximately 14 feet in width would have been
included for the entire length of the roadway widening.
Although the roadway would have been maintained as a two-lane collector, intersections would
have been improved by adding a two-lane roundabout at the intersection of Espola Road and
Twin Peaks Road, and single-lane roundabouts at the intersections of Espola Road with
Durhullen Drive/Golden Sunset and Del Poniente Road/High Valley Road, to provide continuous
traffic flow through these intersections.
This alternative was rejected due to its inability to meet Project objectives with regard to traffic
flow, as well as increased private property acquisition for necessary road right-of-way at the
Espola Road and Twin Peaks Road two-lane roundabout locale.
Environmentally Superior Alternative
Although the No Project Alternative would result in minimal or substantially reduced
environmental impacts, Section 15126.6(e)(2) of the State CEQA Guidelines requires
identification of an alternative other than the No Project Alternative as the environmentally
superior alternative. Accordingly, the proposed Project is considered to be the environmentally
superior alternative for the widening of Espola Road. As opposed to the other build alternatives
analyzed in detail, which would widen Espola Road to a four-lane secondary arterial, the
proposed Project would only widen the road to three lanes, thereby resulting in reduced impacts
to visual/aesthetics, biological and cultural resources, and geology/soils. In addition, the
Executive Summary
Espola Road Improvement Project Final EIR ES-15
May 2013
proposed Project would not result in any additional impacts not assessed for the four-lane build
alternatives. Also, as discussed in Section 6.3.3, the additional design alternatives that involved
reduced roadway improvements were rejected because they would not have met the basic Project
objectives of improving traffic to operate within design capacity thresholds.
Executive Summary
Es
p
o
l
a
R
o
a
d
I
m
p
r
o
v
e
m
e
n
t
P
r
o
j
e
c
t
F
i
n
a
l
E
I
R
ES-16
Ma
y
2
0
1
3
Ta
b
l
e
E
S
-
2
SI
G
N
I
F
I
C
A
N
T
I
M
P
A
C
T
S
A
N
D
P
R
O
P
O
S
E
D
M
I
T
I
G
A
T
I
O
N
Si
g
n
i
f
i
c
a
n
t
I
m
p
a
c
t
M
i
t
i
g
a
t
i
o
n
M
e
a
s
u
r
e
s
Analysis of Significance After Mitigation
La
n
d
U
s
e
Ci
t
y
p
o
l
i
c
i
e
s
s
u
p
p
o
r
t
a
s
a
f
e
a
n
d
pl
e
a
s
a
n
t
a
c
o
u
s
t
i
c
a
l
e
n
v
i
r
o
n
m
e
n
t
fo
r
C
i
t
y
r
e
s
i
d
e
n
t
s
.
C
e
r
t
a
i
n
re
s
i
d
e
n
t
i
a
l
p
r
o
p
e
r
t
i
e
s
a
l
o
n
g
E
s
p
o
l
a
Ro
a
d
w
o
u
l
d
e
x
p
e
r
i
e
n
c
e
p
o
t
e
n
t
i
a
l
ad
v
e
r
s
e
n
o
i
s
e
e
f
f
e
c
t
s
d
u
e
t
o
ex
i
s
t
i
n
g
o
r
p
r
o
j
e
c
t
e
d
t
r
a
f
f
i
c
vo
l
u
m
e
s
.
R
e
s
t
r
i
c
t
i
o
n
o
f
s
o
u
n
d
wa
l
l
s
t
o
e
i
g
h
t
f
e
e
t
i
n
h
e
i
g
h
t
i
s
co
m
m
o
n
l
y
n
o
t
e
d
i
n
C
i
t
y
p
l
a
n
n
i
n
g
do
c
u
m
e
n
t
s
(
e
.
g
.
,
P
u
b
l
i
c
S
a
f
e
t
y
Ma
s
t
e
r
E
l
e
m
e
n
t
S
t
r
a
t
e
g
y
8
)
.
Mi
t
i
g
a
t
i
o
n
m
e
a
s
u
r
e
s
r
e
l
a
t
e
d
t
o
n
o
i
s
e
,
w
h
i
c
h
a
r
e
f
o
u
n
d
i
n
S
e
c
t
i
o
n
2
.
3
,
w
o
u
l
d
b
e
im
p
l
e
m
e
n
t
e
d
.
(
T
h
e
r
e
a
d
e
r
i
s
r
e
f
e
r
r
e
d
t
o
t
h
is
s
e
c
t
i
o
n
f
o
r
s
p
e
c
i
f
i
c
s
.
)
P
o
t
e
n
t
i
a
l
a
d
v
e
r
s
e
im
p
a
c
t
s
t
o
l
a
n
d
u
s
e
p
o
l
i
c
y
c
o
n
s
i
s
t
e
n
c
y
f
o
r
n
o
i
se
c
o
u
l
d
b
e
a
d
e
q
u
a
t
e
l
y
m
i
t
i
g
a
t
e
d
t
h
r
o
u
g
h
im
p
l
e
m
e
n
t
a
t
i
o
n
o
f
a
l
l
n
o
i
s
e
m
e
a
s
u
r
e
s
a
n
d
n
o
ad
d
i
t
i
o
n
a
l
m
i
t
i
g
a
t
i
o
n
wo
u
l
d
b
e
r
e
q
u
i
r
e
d
fo
r
n
o
i
s
e
.
No
n
e
t
h
e
l
e
s
s
,
a
c
o
n
s
e
r
v
a
t
i
v
e
f
i
n
d
i
n
g
i
s
m
a
d
e
r
e
l
a
t
i
v
e
t
o
p
o
l
i
c
y
c
o
n
f
o
r
m
a
n
c
e
f
o
r
t
w
o
so
u
n
d
w
a
l
l
-
r
e
l
a
t
e
d
i
s
s
u
e
s
:
(
1
)
a
l
l
s
o
u
n
d
w
a
l
l
s
m
a
y
n
o
t
b
e
c
o
n
s
t
r
u
c
t
e
d
(s
e
e
S
e
c
t
i
o
n
2
.
1
.
3
an
d
d
e
t
a
i
l
s
i
n
S
e
c
t
i
o
n
2
.
3
.
4
o
f
t
h
i
s
E
I
R
)
in
w
h
i
c
h
c
a
s
e
t
h
e
P
r
o
j
e
c
t
w
o
u
l
d
n
o
t
c
o
m
p
l
y
wi
t
h
C
i
t
y
t
r
a
n
s
p
o
r
t
a
t
i
o
n
n
o
i
s
e
s
t
a
n
d
a
r
d
s
;
or
(
2
)
a
l
t
e
r
n
a
t
i
v
e
l
y
,
a
l
l
r
e
c
o
m
m
e
n
d
e
d
s
o
u
n
d
wa
l
l
s
w
o
u
l
d
b
e
b
u
i
l
t
,
a
n
d
a
n
in
c
o
n
s
i
s
t
e
n
c
y
w
o
u
l
d
o
c
c
u
r
w
i
t
h
r
e
g
a
r
d
t
o
w
a
l
l
h
e
i
g
h
t
a
n
d
po
t
e
n
t
i
a
l
v
i
s
u
a
l
e
f
f
e
c
t
s
.
Ro
u
t
i
n
e
m
i
t
i
g
a
t
i
o
n
f
o
r
l
a
n
d
u
s
e
p
o
l
i
c
y
i
n
c
o
n
s
i
s
te
n
c
i
e
s
i
s
a
n
a
m
e
n
d
m
e
n
t
t
o
t
h
e
r
e
l
e
v
a
n
t
po
l
i
c
y
b
y
t
h
e
p
l
a
n
n
i
n
g
j
u
r
i
s
d
i
c
t
i
o
n
.
Th
e
C
i
t
y
d
o
e
s
n
o
t
p
r
o
p
o
s
e
t
o
a
m
e
n
d
C
i
t
y
-w
i
d
e
p
o
l
i
c
i
e
s
f
o
r
t
h
e
s
e
i
s
o
l
a
t
e
d
(
l
i
m
i
t
e
d
lo
c
a
t
i
o
n
s
o
n
a
n
a
p
p
r
o
x
i
m
a
t
e
l
y
o
n
e
-
m
i
l
e
s
t
re
t
c
h
o
f
o
n
e
s
p
e
c
i
f
i
c
a
r
t
e
r
i
a
l
)
a
n
d
o
n
l
y
po
t
e
n
t
i
a
l
oc
c
u
r
r
e
n
c
e
s
.
A
s
a
r
e
s
u
l
t
,
c
o
n
s
e
r
v
a
t
i
v
e
as
s
e
s
s
m
e
n
t
s
o
f
l
i
m
i
t
e
d
s
i
g
n
i
f
i
c
a
n
t
a
n
d
un
m
i
t
i
g
a
t
e
d
i
m
p
a
c
t
s
a
r
e
m
a
d
e
r
e
l
a
t
i
v
e
t
o
s
ou
n
d
w
a
l
l
e
f
f
i
c
a
c
y
a
n
d
h
e
i
g
h
t
p
o
l
i
c
i
e
s
.
Significant
Executive Summary
Es
p
o
l
a
R
o
a
d
I
m
p
r
o
v
e
m
e
n
t
P
r
o
j
e
c
t
F
i
n
a
l
E
I
R
ES-17
Ma
y
2
0
1
3
Ta
b
l
e
E
S
-
2
(
c
o
n
t
.
)
SI
G
N
I
F
I
C
A
N
T
I
M
P
A
C
T
S
A
N
D
P
R
O
P
O
S
E
D
M
I
T
I
G
A
T
I
O
N
Si
g
n
i
f
i
c
a
n
t
I
m
p
a
c
t
M
i
t
i
g
a
t
i
o
n
M
e
a
s
u
r
e
s
Analysis of Significance After Mitigation
Vi
s
u
a
l
/
A
e
s
t
h
e
t
i
c
s
Th
e
i
m
p
l
e
m
e
n
t
a
t
i
o
n
o
f
t
w
o
s
o
u
n
d
wa
l
l
s
w
i
t
h
r
e
t
a
i
n
i
n
g
w
a
l
l
s
o
n
t
o
p
of
t
h
e
m
i
s
i
n
c
o
n
s
i
s
t
e
n
t
i
n
s
c
a
l
e
an
d
n
a
t
u
r
e
w
i
t
h
a
n
y
o
t
h
e
r
w
a
l
l
fe
a
t
u
r
e
a
l
o
n
g
t
h
i
s
s
t
r
e
t
c
h
o
f
Es
p
o
l
a
R
o
a
d
.
F
o
r
a
p
p
r
o
x
i
m
a
t
e
l
y
33
0
f
e
e
t
n
o
r
t
h
o
f
J
e
r
o
m
e
D
r
i
v
e
an
d
s
o
u
t
h
o
f
H
i
g
h
V
a
l
l
e
y
R
o
a
d
o
n
th
e
e
a
s
t
s
i
d
e
o
f
t
h
e
r
o
a
d
,
a
si
g
n
i
f
i
c
a
n
t
v
i
s
u
a
l
i
m
p
a
c
t
i
s
id
e
n
t
i
f
i
e
d
f
o
r
t
h
i
s
c
o
m
b
i
n
a
t
i
o
n
o
f
fe
a
t
u
r
e
s
t
h
a
t
w
o
u
l
d
n
o
t
b
e
mi
t
i
g
a
t
e
d
e
v
e
n
w
i
t
h
1
0
0
p
e
r
c
e
n
t
ve
g
e
t
a
t
i
v
e
c
o
v
e
r
a
g
e
r
e
q
u
i
r
e
d
i
n
th
e
m
i
t
i
g
a
t
i
o
n
m
e
a
s
u
r
e
b
e
l
o
w
.
Th
i
s
s
i
g
n
i
f
i
c
a
n
t
i
m
p
a
c
t
c
o
u
l
d
b
e
m
i
t
i
g
a
t
e
d
th
r
o
u
g
h
a
d
d
i
t
i
o
n
a
l
s
l
o
p
e
m
o
d
i
f
i
c
a
t
i
o
n
,
w
i
t
h
ad
d
i
t
i
o
n
a
l
i
n
c
u
r
s
i
o
n
i
n
t
o
p
r
i
v
a
t
e
l
o
t
s
a
n
d
C
i
ty
p
u
r
c
h
a
s
e
o
f
p
r
i
v
a
t
e
p
r
o
p
e
r
t
y
.
E
v
e
n
i
f
po
t
e
n
t
i
a
l
s
l
o
p
e
m
o
d
i
f
i
c
a
t
i
o
n
w
o
u
l
d
e
l
i
m
i
n
a
t
e
n
e
e
d
f
o
r
a
r
e
t
a
i
n
i
n
g
w
a
l
l
,
s
o
u
n
d
w
a
l
l
s
wo
u
l
d
s
t
i
l
l
b
e
r
e
q
u
i
r
e
d
.
Th
e
C
i
t
y
h
a
s
w
e
i
g
h
e
d
t
h
e
v
i
s
u
a
l
e
f
f
e
c
t
o
f
m
o
d
i
f
i
e
d
s
l
o
p
e
s
a
n
d
s
o
u
n
d
w
a
l
l
s
c
o
m
b
i
n
e
d
wi
t
h
t
h
e
i
n
t
e
r
e
s
t
s
o
f
t
h
e
i
n
d
i
v
i
d
u
a
l
p
r
o
p
e
r
ty
o
w
n
e
r
a
g
a
i
n
s
t
t
h
e
v
i
s
u
a
l
i
m
p
a
c
t
o
f
t
w
o
wa
l
l
s
e
g
m
e
n
t
s
o
f
v
a
r
y
i
n
g
h
e
i
g
h
t
s
f
o
r
a
p
p
r
o
x
i
m
a
t
e
l
y
3
3
0
f
e
e
t
.
Al
t
e
r
a
t
i
o
n
o
f
P
r
o
j
e
c
t
d
e
s
i
g
n
w
o
u
l
d
r
e
q
u
i
r
e
g
r
e
a
t
e
r
n
e
e
d
f
o
r
u
s
e
o
f
p
r
i
v
a
t
e
p
r
o
p
e
r
t
y
.
Th
e
C
i
t
y
w
i
l
l
c
o
n
t
i
n
u
e
t
o
m
i
n
i
m
i
z
e
i
m
p
a
c
t
s
i
n
t
o
p
r
i
v
a
t
e
p
r
o
p
e
r
t
y
.
A
f
i
n
d
i
n
g
o
f
si
g
n
i
f
i
c
a
n
t
a
n
d
u
n
m
i
t
i
g
a
t
e
d
i
m
p
a
c
t
r
e
l
a
t
i
v
e
t
o
t
h
e
c
o
m
b
i
n
e
d
w
a
l
l
d
e
s
i
g
n
i
n
t
h
i
s
s
i
n
g
l
e
ar
e
a
i
s
i
d
e
n
t
i
f
i
e
d
.
Significant
Executive Summary
Es
p
o
l
a
R
o
a
d
I
m
p
r
o
v
e
m
e
n
t
P
r
o
j
e
c
t
F
i
n
a
l
E
I
R
ES-18
Ma
y
2
0
1
3
Ta
b
l
e
E
S
-
2
(
c
o
n
t
.
)
SI
G
N
I
F
I
C
A
N
T
I
M
P
A
C
T
S
A
N
D
P
R
O
P
O
S
E
D
M
I
T
I
G
A
T
I
O
N
Si
g
n
i
f
i
c
a
n
t
I
m
p
a
c
t
M
i
t
i
g
a
t
i
o
n
M
e
a
s
u
r
e
s
Analysis of Significance After Mitigation
Vi
s
u
a
l
/
A
e
s
t
h
e
t
i
c
s
(
c
o
n
t
.
)
Pr
o
j
e
c
t
d
e
s
i
g
n
w
o
u
l
d
l
a
r
g
e
l
y
mi
t
i
g
a
t
e
v
i
s
u
a
l
i
m
p
a
c
t
s
t
h
r
o
u
g
h
la
n
d
s
c
a
p
e
d
i
n
t
e
r
s
e
c
t
i
o
n
f
o
c
a
l
po
i
n
t
s
,
s
t
r
e
e
t
s
c
a
p
e
,
h
y
d
r
o
s
e
e
d
i
n
g
of
m
o
d
i
f
i
e
d
s
l
o
p
e
s
a
n
d
p
l
a
n
t
i
n
g
o
f
wa
l
l
-
s
c
r
e
e
n
i
n
g
v
i
n
e
s
.
A
n
y
m
a
t
u
r
e
oa
k
o
r
s
y
c
a
m
o
r
e
t
o
b
e
r
e
m
o
v
e
d
by
t
h
e
P
r
o
j
e
c
t
w
o
u
l
d
b
e
me
a
s
u
r
e
d
.
I
f
m
e
a
s
u
r
e
d
t
r
e
e
s
ex
c
e
e
d
t
h
r
e
e
i
n
c
h
e
s
i
n
d
i
a
m
e
t
e
r
at
b
r
e
a
s
t
h
e
i
g
h
t
,
t
h
e
t
r
e
e
w
o
u
l
d
b
e
re
p
l
a
c
e
d
i
n
c
o
n
f
o
r
m
a
n
c
e
w
i
t
h
Ci
t
y
p
o
l
i
c
y
a
s
a
m
a
t
t
e
r
o
f
P
r
o
j
e
c
t
de
s
i
g
n
.
S
o
u
n
d
w
a
l
l
l
a
n
d
s
c
a
p
i
n
g
(c
o
v
e
r
a
g
e
w
i
t
h
v
i
n
e
s
)
c
o
u
l
d
r
e
s
u
l
t
in
i
n
c
o
m
p
l
e
t
e
o
r
i
n
c
o
n
s
i
s
t
e
n
t
co
v
e
r
a
g
e
d
u
e
t
o
c
l
u
m
p
i
n
g
w
i
t
h
o
u
t
en
h
a
n
c
e
d
m
a
i
n
t
e
n
a
n
c
e
.
In
o
r
d
e
r
t
o
l
o
w
e
r
r
e
m
a
i
n
i
n
g
l
a
n
d
s
c
a
p
i
n
g
-
a
s
s
o
c
i
a
t
ed
a
d
v
e
r
s
e
v
i
s
u
a
l
i
m
p
a
c
t
s
t
o
l
e
s
s
t
h
a
n
si
g
n
i
f
i
c
a
n
t
l
e
v
e
l
s
,
f
o
r
a
l
l
s
t
a
n
d
-
a
l
o
n
e
re
t
a
i
n
i
n
g
o
r
s
o
u
n
d
w
a
l
l
s
,
a
n
e
n
h
a
n
c
e
d
ma
i
n
t
e
n
a
n
c
e
a
n
d
m
o
n
i
t
o
r
i
n
g
p
r
o
g
r
a
m
s
h
a
l
l
b
e
im
p
l
e
m
e
n
t
e
d
b
y
t
h
e
C
i
t
y
t
o
e
n
s
u
r
e
t
h
a
t
10
0
p
e
r
c
e
n
t
v
e
g
e
t
a
t
i
v
e
c
o
v
e
r
i
s
o
b
t
a
i
n
e
d
.
T
h
i
s
p
r
o
g
r
a
m
s
h
a
l
l
r
e
q
u
i
r
e
t
h
a
t
:
Vi
n
e
s
p
l
a
n
t
e
d
i
n
c
u
t
-
o
u
t
s
a
l
o
n
g
s
i
d
e
w
a
l
k
a
r
e
a
s
f
r
o
n
t
i
n
g
s
o
u
n
d
w
a
l
l
s
w
i
l
l
b
e
es
p
a
l
i
e
r
e
d
t
o
c
o
v
e
r
t
h
e
w
a
l
l
s
(
r
a
t
h
e
r
t
h
a
n
a
l
l
o
w
i
n
g
t
h
e
m
t
o
g
r
o
w
i
n
a
v
e
r
t
i
c
a
l
bu
s
h
f
o
r
m
)
Less than Significant
Executive Summary
Es
p
o
l
a
R
o
a
d
I
m
p
r
o
v
e
m
e
n
t
P
r
o
j
e
c
t
F
i
n
a
l
E
I
R
ES-19
Ma
y
2
0
1
3
Ta
b
l
e
E
S
-
2
(
c
o
n
t
.
)
SI
G
N
I
F
I
C
A
N
T
I
M
P
A
C
T
S
A
N
D
P
R
O
P
O
S
E
D
M
I
T
I
G
A
T
I
O
N
Si
g
n
i
f
i
c
a
n
t
I
m
p
a
c
t
M
i
t
i
g
a
t
i
o
n
M
e
a
s
u
r
e
s
Analysis of Significance After Mitigation
No
i
s
e
Fo
l
l
o
w
i
n
g
c
o
n
s
t
r
u
c
t
i
o
n
,
E
s
p
o
l
a
Ro
a
d
t
r
a
n
s
p
o
r
t
a
t
i
o
n
n
o
i
s
e
w
o
u
l
d
ex
c
e
e
d
(
o
r
c
o
n
t
i
n
u
e
t
o
e
x
c
e
e
d
)
de
c
i
b
e
l
l
e
v
e
l
s
e
s
t
a
b
l
i
s
h
e
d
b
y
t
h
e
Ci
t
y
a
t
a
n
u
m
b
e
r
o
f
r
e
c
e
i
v
e
r
s
wi
t
h
p
r
o
t
e
c
t
e
d
o
u
t
d
o
o
r
u
s
e
a
r
e
a
s
.
Pr
e
l
i
m
i
n
a
r
y
i
n
f
o
r
m
a
t
i
o
n
o
n
t
h
e
p
o
t
e
n
t
i
a
l
p
h
ys
i
c
a
l
l
o
c
a
t
i
o
n
a
n
d
h
e
i
g
h
t
o
f
r
e
c
o
m
m
e
n
d
e
d
no
i
s
e
b
a
r
r
i
e
r
s
i
s
p
r
o
v
i
d
e
d
i
n
T
a
b
l
e
2
.
3
-
3
.
S
o
u
n
d
b
a
r
r
i
e
r
s
o
f
v
a
r
i
o
u
s
h
e
i
g
h
t
s
a
r
e
pr
o
p
o
s
e
d
b
a
s
e
d
o
n
w
h
i
c
h
o
f
t
h
e
c
r
i
t
e
r
i
a
t
h
e
r
ec
e
i
v
e
r
f
a
l
l
s
w
i
t
h
i
n
(
c
u
r
r
e
n
t
l
y
u
n
d
e
r
6
0
dB
A
,
b
e
t
w
e
e
n
6
0
a
n
d
6
5
d
B
A
,
o
r
o
v
e
r
6
5
d
B
A)
,
a
s
d
e
s
c
r
i
b
e
d
i
n
S
e
c
t
i
o
n
2
.
3
.
1
.
I
n
ge
n
e
r
a
l
,
s
o
u
n
d
w
a
l
l
s
o
f
s
i
x
t
o
e
i
g
h
t
f
e
e
t
in
h
e
i
g
h
t
a
r
e
p
r
o
p
o
s
e
d
t
o
a
d
d
r
e
s
s
t
h
e
c
u
r
r
e
n
t
an
d
i
n
c
r
e
a
s
e
d
n
o
i
s
e
a
l
o
n
g
E
s
p
o
l
a
R
o
a
d
.
A
f
e
w
w
a
l
l
s
m
a
y
e
x
c
e
e
d
t
h
o
s
e
h
e
i
g
h
t
s
,
a
s
in
d
i
c
a
t
e
d
o
n
T
a
b
l
e
2
.
3
-
3
.
F
i
g
u
r
e
2
.
3
-
2
s
c
h
e
m
a
t
i
c
a
l
l
y
i
n
d
i
c
a
t
e
s
t
h
e
p
r
o
p
o
s
e
d
w
a
l
l
lo
c
a
t
i
o
n
s
.
Fi
n
a
l
d
e
s
i
g
n
a
n
d
p
l
a
c
e
m
e
n
t
o
f
n
o
i
s
e
w
a
l
l
s
w
ou
l
d
r
e
q
u
i
r
e
a
d
d
i
t
i
o
n
a
l
e
n
g
i
n
e
e
r
i
n
g
i
n
p
u
t
,
in
c
l
u
d
i
n
g
c
o
n
s
i
d
e
r
a
t
i
o
n
o
f
s
i
t
e
-
s
p
e
c
i
f
i
c
c
o
n
d
it
i
o
n
s
a
n
d
f
u
r
t
h
e
r
n
o
i
s
e
m
o
d
e
l
i
n
g
.
F
u
t
u
r
e
mo
d
e
l
i
n
g
r
e
q
u
i
r
e
d
a
s
p
a
r
t
o
f
t
h
e
N
E
P
A
c
o
m
p
li
a
n
c
e
a
n
d
f
u
n
d
i
n
g
e
f
f
o
r
t
f
o
r
t
h
e
P
r
o
j
e
c
t
,
as
w
e
l
l
a
s
i
n
p
u
t
f
r
o
m
p
r
o
p
e
r
t
y
o
w
n
e
r
s
(
w
h
o
ma
y
n
o
t
d
e
s
i
r
e
w
a
l
l
s
)
c
o
u
l
d
r
e
s
u
l
t
t
o
ch
a
n
g
e
s
t
o
w
a
l
l
p
a
r
a
m
e
t
e
r
s
.
I
f
p
e
r
t
i
n
e
n
t
e
ng
i
n
e
e
r
i
n
g
p
a
r
a
m
e
t
e
r
s
ch
a
n
g
e
s
u
b
s
t
a
n
t
i
a
l
l
y
du
r
i
n
g
t
h
e
f
i
n
a
l
P
r
o
j
e
c
t
d
e
s
i
g
n
,
o
r
i
f
p
r
o
p
e
r
ty
o
w
n
e
r
s
r
e
j
e
c
t
p
r
o
p
o
s
e
d
w
a
l
l
s
l
o
c
a
t
e
d
o
n
th
e
i
r
p
r
i
v
a
t
e
p
r
o
p
e
r
t
y
,
p
r
e
l
i
m
i
n
a
r
y
n
o
i
s
e
b
a
r
r
i
e
r
d
e
s
i
g
n
s
m
a
y
b
e
m
o
d
i
f
i
e
d
(
i
n
h
e
i
g
h
t
o
r
ex
t
e
n
t
)
o
r
e
l
i
m
i
n
a
t
e
d
f
r
o
m
t
h
e
f
i
n
a
l
P
r
o
j
e
c
t
.
B
e
c
a
u
s
e
o
f
t
h
i
s
p
o
t
e
n
t
i
a
l
,
t
h
e
C
i
t
y
i
s
ma
k
i
n
g
a
c
o
n
s
e
r
v
a
t
i
v
e
a
s
s
e
s
s
m
e
n
t
o
f
s
i
g
n
i
f
i
ca
n
t
a
n
d
u
n
m
i
t
i
g
a
t
e
d
i
m
p
a
c
t
f
o
r
t
h
i
s
i
s
s
u
e
in
t
h
e
P
r
o
j
e
c
t
S
O
C
.
Potentially Significant
Executive Summary
Es
p
o
l
a
R
o
a
d
I
m
p
r
o
v
e
m
e
n
t
P
r
o
j
e
c
t
F
i
n
a
l
E
I
R
ES-20
Ma
y
2
0
1
3
Ta
b
l
e
E
S
-
2
(
c
o
n
t
.
)
SI
G
N
I
F
I
C
A
N
T
I
M
P
A
C
T
S
A
N
D
P
R
O
P
O
S
E
D
M
I
T
I
G
A
T
I
O
N
Si
g
n
i
f
i
c
a
n
t
I
m
p
a
c
t
M
i
t
i
g
a
t
i
o
n
M
e
a
s
u
r
e
s
Analysis of Significance After Mitigation
No
i
s
e
(
c
o
n
t
.
)
Al
t
h
o
u
g
h
s
h
o
r
t
-
t
e
r
m
c
o
n
s
t
r
u
c
t
i
o
n
-
pe
r
i
o
d
i
m
p
a
c
t
s
w
o
u
l
d
b
e
l
e
s
s
th
a
n
s
i
g
n
i
f
i
c
a
n
t
,
n
o
i
s
e
-
s
e
n
s
i
t
i
v
e
lo
c
a
t
i
o
n
s
w
o
u
l
d
b
e
a
f
f
e
c
t
e
d
du
r
i
n
g
P
r
o
j
e
c
t
c
o
n
s
t
r
u
c
t
i
o
n
.
Th
e
C
i
t
y
i
s
r
e
c
o
m
m
e
n
d
i
n
g
t
h
e
f
o
l
l
o
w
i
n
g
c
o
n
s
t
r
u
c
t
i
o
n
n
o
i
s
e
c
o
n
t
r
o
l
m
e
a
s
u
r
e
s
t
o
f
u
r
t
h
e
r
mi
n
i
m
i
z
e
n
o
i
s
e
e
f
f
e
c
t
s
a
t
n
o
i
s
e
-
s
e
n
s
i
t
i
v
e
l
o
c
a
t
i
o
n
s
d
u
r
i
n
g
P
r
o
j
e
c
t
c
o
n
s
t
r
u
c
t
i
o
n
:
Ea
c
h
i
n
t
e
r
n
a
l
c
o
m
b
u
s
t
i
o
n
e
n
g
i
n
e
,
u
s
e
d
f
o
r
a
n
y
p
u
r
p
o
s
e
o
n
t
h
e
j
o
b
o
r
r
e
l
a
t
e
d
t
o
th
e
j
o
b
,
s
h
a
l
l
b
e
e
q
u
i
p
p
e
d
w
i
t
h
a
m
u
f
f
l
e
r
o
f
a
t
y
p
e
r
e
c
o
m
m
e
n
d
e
d
b
y
t
h
e
ma
n
u
f
a
c
t
u
r
e
r
.
N
o
i
n
t
e
r
n
a
l
c
o
m
b
u
s
t
i
o
n
e
ng
i
n
e
s
h
a
l
l
b
e
o
p
e
r
a
t
e
d
o
n
t
h
e
P
r
o
j
e
c
t
wi
t
h
o
u
t
s
a
i
d
m
u
f
f
l
e
r
.
Th
e
n
o
i
s
e
l
e
v
e
l
r
e
q
u
i
r
e
m
e
n
t
s
h
a
l
l
a
p
p
l
y
t
o
t
h
e
e
q
u
i
p
m
e
n
t
o
n
t
h
e
j
o
b
o
r
r
e
l
a
t
e
d
to
t
h
e
j
o
b
,
i
n
c
l
u
d
i
n
g
b
u
t
n
o
t
l
i
m
i
t
e
d
t
o
t
r
u
c
k
s
,
t
r
a
n
s
i
t
m
i
x
e
r
o
r
t
r
a
n
s
i
e
n
t
eq
u
i
p
m
e
n
t
t
h
a
t
m
a
y
o
r
m
a
y
n
o
t
b
e
o
w
n
e
d
b
y
t
h
e
c
o
n
t
r
a
c
t
o
r
.
Th
e
u
s
e
o
f
l
o
u
d
s
i
g
n
a
l
s
s
h
a
l
l
b
e
a
v
o
i
d
e
d
i
n
f
a
v
o
r
o
f
l
i
g
h
t
w
a
r
n
i
n
g
s
e
x
c
e
p
t
t
h
o
s
e
re
q
u
i
r
e
d
b
y
s
a
f
e
t
y
l
a
w
s
f
o
r
t
h
e
p
r
o
t
e
c
t
i
o
n
o
f
p
e
r
s
o
n
n
e
l
.
Un
n
e
c
e
s
s
a
r
y
i
d
l
i
n
g
o
f
i
n
t
e
r
n
a
l
c
o
m
b
u
s
t
i
o
n
e
n
g
i
n
e
s
w
i
t
h
i
n
1
0
0
f
e
e
t
o
f
re
s
i
d
e
n
c
e
s
s
h
o
u
l
d
b
e
s
t
r
i
c
t
l
y
p
r
o
h
i
b
i
t
e
d
.
St
a
g
i
n
g
o
f
c
o
n
s
t
r
u
c
t
i
o
n
e
q
ui
p
m
e
n
t
b
e
y
o
n
d
2
0
0
f
e
e
t
o
f
r
e
s
i
d
e
n
c
e
s
a
n
d
l
o
c
a
t
i
o
n
of
a
l
l
s
t
a
t
i
o
n
a
r
y
n
o
i
s
e
-
g
e
n
e
r
a
t
i
n
g
c
on
s
t
r
u
c
t
i
o
n
e
q
u
i
p
m
e
n
t
,
s
u
c
h
a
s
a
i
r
co
m
p
r
e
s
s
o
r
s
a
n
d
p
o
r
t
a
b
l
e
p
o
w
e
r
g
e
n
e
r
a
t
o
r
s
,
s
h
a
l
l
o
c
c
u
r
a
s
f
a
r
a
s
p
r
a
c
t
i
c
a
l
f
r
o
m
no
i
s
e
s
e
n
s
i
t
i
v
e
r
e
s
i
d
e
n
c
e
s
.
T
h
e
c
o
n
t
r
a
c
t
o
r
w
i
l
l
p
l
a
c
e
a
l
l
s
t
a
t
i
o
n
a
r
y
c
o
n
s
t
r
u
c
t
i
o
n
eq
u
i
p
m
e
n
t
s
o
t
h
a
t
e
m
i
t
t
e
d
n
o
i
s
e
i
s
d
i
r
e
c
t
e
d
a
w
a
y
f
r
o
m
s
e
n
s
i
t
i
v
e
r
e
c
e
p
t
o
r
s
(r
e
s
i
d
e
n
c
e
s
)
.
As
d
i
r
e
c
t
e
d
b
y
t
h
e
C
i
t
y
,
t
h
e
c
o
n
t
r
a
c
t
or
w
i
l
l
i
m
p
l
e
m
e
n
t
a
p
p
r
o
p
r
i
a
t
e
a
d
d
i
t
i
o
n
a
l
no
i
s
e
m
i
t
i
g
a
t
i
o
n
m
e
a
s
u
r
e
s
,
i
n
c
l
u
d
i
n
g
c
h
a
n
g
i
n
g
t
h
e
l
o
c
a
t
i
o
n
o
f
s
t
a
t
i
o
n
a
r
y
co
n
s
t
r
u
c
t
i
o
n
e
q
u
i
p
m
e
n
t
,
t
u
r
n
i
n
g
o
f
f
i
d
l
i
ng
e
q
u
i
p
m
e
n
t
,
r
e
s
c
h
e
d
u
l
i
n
g
c
o
n
s
t
r
u
c
t
i
o
n
ac
t
i
v
i
t
y
,
n
o
t
i
f
y
i
n
g
a
d
j
a
c
e
n
t
r
e
s
i
d
e
n
t
s
i
n
a
d
v
a
n
c
e
o
f
c
o
n
s
t
r
u
c
t
i
o
n
w
o
r
k
,
a
n
d
in
s
t
a
l
l
i
n
g
a
c
o
u
s
t
i
c
b
a
r
r
i
e
r
s
a
r
o
u
n
d
s
t
a
ti
o
n
a
r
y
c
o
n
s
t
r
u
c
t
i
o
n
n
o
i
s
e
s
o
u
r
c
e
s
.
Less than Significant
Executive Summary
Es
p
o
l
a
R
o
a
d
I
m
p
r
o
v
e
m
e
n
t
P
r
o
j
e
c
t
F
i
n
a
l
E
I
R
ES-21
Ma
y
2
0
1
3
Ta
b
l
e
E
S
-
2
(
c
o
n
t
.
)
SI
G
N
I
F
I
C
A
N
T
I
M
P
A
C
T
S
A
N
D
P
R
O
P
O
S
E
D
M
I
T
I
G
A
T
I
O
N
Si
g
n
i
f
i
c
a
n
t
I
m
p
a
c
t
M
i
t
i
g
a
t
i
o
n
M
e
a
s
u
r
e
s
Analysis of Significance After Mitigation
Bi
o
l
o
g
i
c
a
l
R
e
s
o
u
r
c
e
s
Th
e
P
r
o
j
e
c
t
w
o
u
l
d
r
e
s
u
l
t
i
n
si
g
n
i
f
i
c
a
n
t
d
i
r
e
c
t
i
m
p
a
c
t
s
t
o
so
u
t
h
e
r
n
w
i
l
l
o
w
r
i
p
a
r
i
a
n
f
o
r
e
s
t
(
a
Ca
l
i
f
o
r
n
i
a
D
e
p
a
r
t
m
e
n
t
o
f
F
i
s
h
an
d
W
i
l
d
l
i
f
e
j
u
r
i
s
d
i
c
t
i
o
n
a
l
ha
b
i
t
a
t
)
,
D
i
e
g
a
n
c
o
a
s
t
a
l
s
a
g
e
sc
r
u
b
,
s
o
u
t
h
e
r
n
m
i
x
e
d
c
h
a
p
a
r
r
a
l
(i
n
c
l
u
d
i
n
g
d
i
s
t
u
r
b
e
d
)
a
n
d
n
o
n
-
na
t
i
v
e
g
r
a
s
s
l
a
n
d
.
Mi
t
i
g
a
t
i
o
n
r
a
t
i
o
s
f
o
r
s
i
g
n
i
f
i
c
a
n
t
i
m
p
a
c
t
s
t
o
se
n
s
i
t
i
v
e
b
i
o
l
o
g
i
c
a
l
h
a
b
i
t
a
t
s
a
n
d
r
e
s
o
u
r
c
e
s
ar
e
b
a
s
e
d
o
n
t
h
e
C
i
t
y
’
s
S
u
b
a
r
e
a
H
a
b
i
t
a
t
Co
n
s
e
r
v
a
t
i
o
n
P
l
a
n
(
H
C
P
)
a
n
d
w
i
l
l
b
e
co
n
f
i
r
m
e
d
b
y
t
h
e
r
e
s
o
u
r
c
e
a
g
e
n
c
i
e
s
.
A
l
l
m
i
t
i
g
at
i
o
n
s
h
a
l
l
o
c
c
u
r
p
r
i
o
r
t
o
o
r
c
o
n
c
u
r
r
e
n
t
wi
t
h
i
m
p
a
c
t
s
.
Co
m
p
e
n
s
a
t
o
r
y
m
i
t
i
g
a
t
i
o
n
f
o
r
i
m
p
a
c
t
s
t
o
s
ou
t
h
e
r
n
w
i
l
l
o
w
r
i
p
a
r
i
a
n
f
o
r
e
s
t
w
i
l
l
b
e
ob
t
a
i
n
e
d
t
h
r
o
u
g
h
p
u
r
c
h
a
s
e
o
f
w
e
t
l
a
n
d
c
r
e
d
i
t
s
a
t
a
l
o
c
a
t
i
o
n
a
c
c
e
p
t
a
b
l
e
t
o
t
h
e
C
i
t
y
a
n
d
re
s
o
u
r
c
e
a
g
e
n
c
i
e
s
i
n
c
o
m
p
l
i
a
n
c
e
w
i
t
h
t
h
e
a
p
p
r
o
v
e
d
C
i
t
y
H
C
P
,
o
r
t
h
r
o
u
g
h
i
n
-
l
i
e
u
pa
y
m
e
n
t
a
c
c
e
p
t
a
b
l
e
t
o
t
h
e
C
i
t
y
a
n
d
r
e
s
o
u
r
c
e
ag
e
n
c
i
e
s
i
n
c
o
m
p
l
i
a
n
c
e
w
i
t
h
t
h
e
a
p
p
r
o
v
e
d
Ci
t
y
H
C
P
.
C
r
e
d
i
t
s
o
r
i
n
-
l
i
e
u
p
a
y
m
e
n
t
s
h
a
ll
s
u
p
p
o
r
t
s
o
u
t
h
e
r
n
w
i
l
l
o
w
r
i
p
a
r
i
a
n
f
o
r
e
s
t
re
p
l
a
c
e
m
e
n
t
a
t
a
3
:
1
r
a
t
i
o
b
y
a
c
o
m
b
i
n
a
t
i
o
n
o
f
c
r
e
a
t
i
o
n
(
a
t
l
e
a
s
t
1
:
1
o
r
0
.
0
2
a
c
r
e
)
a
n
d
en
h
a
n
c
e
m
e
n
t
(
u
p
t
o
2
:
1
o
r
0
.
0
4
a
c
r
e
)
,
f
o
r
a
t
o
t
a
l
o
f
0
.
0
6
a
c
r
e
.
Up
l
a
n
d
m
i
t
i
g
a
t
i
o
n
w
i
l
l
o
c
c
u
r
a
t
V
a
n
D
a
m
P
e
a
k
o
n
a
C
i
t
y
-
o
w
n
e
d
p
a
r
c
e
l
w
i
t
h
i
n
t
h
e
Ci
t
y
’
s
S
u
b
a
r
e
a
H
C
P
.
T
h
e
f
o
l
l
o
w
i
n
g
m
i
t
i
g
a
t
i
on
w
i
l
l
r
e
d
u
c
e
i
m
p
a
c
t
s
t
o
b
e
l
o
w
a
l
e
v
e
l
o
f
si
g
n
i
f
i
c
a
n
c
e
:
Di
e
g
a
n
c
o
a
s
t
a
l
s
a
g
e
s
c
r
u
b
t
o
b
e
m
i
t
i
g
a
t
e
d
a
t
2
:
1
i
n
-
k
i
n
d
,
f
o
r
a
t
o
t
a
l
o
f
0
.
0
8
a
c
r
e
So
u
t
h
e
r
n
m
i
x
e
d
c
h
a
p
a
r
r
a
l
t
o
b
e
m
i
t
i
g
a
t
e
d
a
t
1
:
1
i
n
-
k
i
n
d
,
f
o
r
a
t
o
t
a
l
o
f
0
.
1
9
a
c
r
e
So
u
t
h
e
r
n
m
i
x
e
d
c
h
a
p
a
r
r
a
l
–
d
i
s
t
u
r
b
e
d
t
o
b
e
m
i
t
i
g
a
t
e
d
a
t
1
:
1
i
n
-
k
i
n
d
,
f
o
r
a
t
o
t
a
l
of
0
.
0
5
a
c
r
e
No
n
-
n
a
t
i
v
e
g
r
a
s
s
l
a
n
d
t
o
b
e
m
i
t
i
g
a
t
e
d
a
t
1
:
1
o
u
t
-
o
f
-
k
i
n
d
(
D
i
e
g
a
n
c
o
a
s
t
a
l
s
a
g
e
sc
r
u
b
)
,
f
o
r
a
t
o
t
a
l
o
f
0
.
1
1
a
c
r
e
Wi
t
h
r
e
g
a
r
d
t
o
s
o
u
t
h
e
r
n
m
i
x
e
d
c
h
a
p
a
r
r
a
l
(i
n
c
l
u
d
i
n
g
d
i
s
t
u
r
b
e
d
)
,
a
j
u
r
i
s
d
i
c
t
i
o
n
m
a
y
re
q
u
i
r
e
m
i
t
i
g
a
t
i
o
n
o
r
l
e
v
y
a
n
i
n
-
l
i
e
u
m
i
t
i
g
a
t
i
o
n
f
e
e
f
o
r
i
m
p
a
c
t
s
i
f
i
t
f
i
n
d
s
t
h
a
t
s
u
c
h
ac
t
i
o
n
s
a
r
e
n
e
c
e
s
s
a
r
y
t
o
m
e
e
t
M
u
l
t
i
p
l
e
S
p
e
c
i
e
s
C
o
n
s
e
r
v
a
t
i
o
n
P
r
o
g
r
a
m
(
M
S
C
P
)
o
r
Po
w
a
y
S
u
b
a
r
e
a
H
C
P
g
o
a
l
s
.
W
h
e
n
l
i
s
t
e
d
s
p
e
c
i
es
o
c
c
u
r
,
r
e
p
l
a
c
e
m
e
n
t
r
a
t
i
o
b
e
c
o
m
e
s
2
:
1
.
Less than Significant
Executive Summary
Es
p
o
l
a
R
o
a
d
I
m
p
r
o
v
e
m
e
n
t
P
r
o
j
e
c
t
F
i
n
a
l
E
I
R
ES-22
Ma
y
2
0
1
3
Ta
b
l
e
E
S
-
2
(
c
o
n
t
.
)
SI
G
N
I
F
I
C
A
N
T
I
M
P
A
C
T
S
A
N
D
P
R
O
P
O
S
E
D
M
I
T
I
G
A
T
I
O
N
Si
g
n
i
f
i
c
a
n
t
I
m
p
a
c
t
M
i
t
i
g
a
t
i
o
n
M
e
a
s
u
r
e
s
Analysis of Significance After Mitigation
Bi
o
l
o
g
i
c
a
l
R
e
s
o
u
r
c
e
s
(
c
o
n
t
.
)
Th
e
P
r
o
j
e
c
t
w
o
u
l
d
r
e
s
u
l
t
i
n
pe
r
m
a
n
e
n
t
i
m
p
a
c
t
s
t
o
0
.
0
4
a
c
r
e
of
D
i
e
g
a
n
c
o
a
s
t
a
l
s
a
g
e
s
c
r
u
b
,
t
h
e
ha
b
i
t
a
t
o
f
t
h
e
o
r
a
n
g
e
-
t
h
r
o
a
t
e
d
wh
i
p
t
a
i
l
,
a
s
t
a
t
e
s
p
e
c
i
e
s
o
f
s
p
e
c
i
a
l
co
n
c
e
r
n
c
o
v
e
r
e
d
u
n
d
e
r
t
h
e
P
o
w
a
y
Su
b
a
r
e
a
H
C
P
.
Im
p
a
c
t
s
t
o
t
h
e
h
a
b
i
t
a
t
o
f
t
h
e
o
r
a
n
g
e
-
t
h
r
o
a
te
d
w
h
i
p
t
a
i
l
s
h
a
l
l
b
e
m
i
t
i
g
a
t
e
d
t
h
r
o
u
g
h
t
h
e
pr
e
s
e
r
v
a
t
i
o
n
o
f
D
i
e
g
a
n
c
o
a
s
t
a
l
s
a
g
e
s
c
r
u
b
h
a
b
i
t
a
t
o
c
c
u
p
i
e
d
b
y
t
h
e
o
r
a
n
g
e
-
t
h
r
o
a
t
e
d
wh
i
p
t
a
i
l
,
a
s
p
a
r
t
o
f
t
h
e
0
.
0
8
a
c
r
e
o
f
D
i
e
g
a
n
c
o
a
s
t
a
l
s
a
g
e
s
c
r
u
b
m
i
t
i
g
a
t
i
o
n
a
t
V
a
n
D
a
m
Pe
a
k
(
d
i
s
c
u
s
s
e
d
a
b
o
v
e
)
.
Less than Significant
Ra
p
t
o
r
s
a
n
d
m
i
g
r
a
t
o
r
y
b
i
r
d
s
h
a
v
e
th
e
p
o
t
e
n
t
i
a
l
t
o
n
e
s
t
i
n
v
e
g
e
t
a
t
i
o
n
wi
t
h
i
n
t
h
e
P
r
o
j
e
c
t
l
i
m
i
t
s
,
in
c
l
u
d
i
n
g
e
u
c
a
l
y
p
t
u
s
t
r
e
e
s
.
Co
n
s
t
r
u
c
t
i
o
n
o
f
t
h
e
P
r
o
j
e
c
t
c
o
u
l
d
re
s
u
l
t
i
n
s
i
g
n
i
f
i
c
a
n
t
i
m
p
a
c
t
s
t
o
ne
s
t
i
n
g
r
a
p
t
o
r
s
a
n
d
/
o
r
m
i
g
r
a
t
o
r
y
bi
r
d
s
.
Po
t
e
n
t
i
a
l
i
m
p
a
c
t
s
t
o
a
c
t
i
v
e
n
e
s
t
s
s
h
a
l
l
b
e
a
vo
i
d
e
d
b
y
e
i
t
h
e
r
(
1
)
r
e
m
o
v
a
l
o
f
v
e
g
e
t
a
t
i
o
n
in
c
l
u
d
i
n
g
e
u
c
a
l
y
p
t
u
s
a
n
d
o
t
h
e
r
n
o
n
-
n
a
t
i
v
e
t
r
e
e
s
o
u
t
s
i
d
e
o
f
t
h
e
b
r
e
e
d
i
n
g
s
e
a
s
o
n
f
o
r
m
o
s
t
mi
g
r
a
t
o
r
y
b
i
r
d
s
(
F
e
b
r
u
a
r
y
1
5
t
h
r
o
u
g
h
A
u
g
u
s
t
3
1
)
o
r
(
2
)
s
u
r
v
e
y
s
b
y
a
q
u
a
l
i
f
i
e
d
bi
o
l
o
g
i
s
t
p
r
i
o
r
t
o
r
e
m
o
v
a
l
t
o
e
n
s
u
r
e
t
h
a
t
n
o
r
a
p
t
o
r
s
o
r
m
i
g
r
a
t
o
r
y
b
i
r
d
s
a
r
e
n
e
s
t
i
n
g
.
I
f
ne
s
t
i
n
g
b
i
r
d
s
a
r
e
i
d
e
n
t
i
f
i
e
d
,
t
h
e
t
r
e
e
(
s
)
s
h
a
l
l
re
m
a
i
n
i
n
p
l
a
c
e
u
n
t
i
l
a
l
l
c
h
i
c
k
s
a
r
e
f
l
e
d
g
e
d
.
Co
n
s
t
r
u
c
t
i
o
n
a
c
t
i
v
i
t
i
e
s
w
i
l
l
b
e
p
r
e
c
l
u
d
e
d
w
i
t
h
in
5
0
f
e
e
t
o
f
a
n
y
a
c
t
i
v
e
m
i
g
r
a
t
o
r
y
b
i
r
d
ne
s
t
a
n
d
3
0
0
f
e
e
t
o
f
a
n
y
a
c
t
i
v
e
r
a
p
t
o
r
n
e
s
t
.
Less than Significant
Al
t
h
o
u
g
h
n
o
t
a
n
t
i
c
i
p
a
t
e
d
t
o
o
c
c
u
r
wi
t
h
i
n
3
0
0
f
e
e
t
o
f
t
h
e
P
r
o
j
e
c
t
co
n
s
t
r
u
c
t
i
o
n
a
r
e
a
,
i
f
c
o
a
s
t
a
l
Ca
l
i
f
o
r
n
i
a
g
n
a
t
c
a
t
c
h
e
r
s
a
r
e
pr
e
s
e
n
t
i
n
t
h
e
a
r
e
a
,
a
s
i
g
n
i
f
i
c
a
n
t
im
p
a
c
t
c
o
u
l
d
o
c
c
u
r
.
Pr
e
-
c
o
n
s
t
r
u
c
t
i
o
n
s
u
r
v
e
y
s
f
o
r
t
h
e
c
o
a
s
t
a
l
C
a
l
i
f
or
n
i
a
g
n
a
t
c
a
t
c
h
e
r
s
h
a
l
l
b
e
c
o
n
d
u
c
t
e
d
i
n
a
l
l
co
a
s
t
a
l
s
a
g
e
s
c
r
u
b
h
a
b
i
t
a
t
a
r
e
a
s
w
i
t
h
i
n
t
h
e
P
r
oj
e
c
t
l
i
m
i
t
s
.
I
f
b
i
r
d
s
a
r
e
p
r
e
s
e
n
t
(
n
o
t
ex
p
e
c
t
e
d
)
,
E
s
p
o
l
a
R
o
a
d
c
o
n
s
t
r
u
c
t
i
o
n
a
c
t
i
v
i
t
i
e
s
sh
a
l
l
b
e
l
i
m
i
t
e
d
t
o
p
e
r
i
o
d
s
o
u
t
s
i
d
e
t
h
e
br
e
e
d
i
n
g
/
n
e
s
t
i
n
g
s
e
a
s
o
n
i
n
t
h
e
a
b
u
t
t
i
n
g
p
o
r
t
i
o
n
o
f
t
h
e
r
o
a
d
.
Less than Significant
Executive Summary
Es
p
o
l
a
R
o
a
d
I
m
p
r
o
v
e
m
e
n
t
P
r
o
j
e
c
t
F
i
n
a
l
E
I
R
ES-23
Ma
y
2
0
1
3
Ta
b
l
e
E
S
-
2
(
c
o
n
t
.
)
SI
G
N
I
F
I
C
A
N
T
I
M
P
A
C
T
S
A
N
D
P
R
O
P
O
S
E
D
M
I
T
I
G
A
T
I
O
N
Si
g
n
i
f
i
c
a
n
t
I
m
p
a
c
t
M
i
t
i
g
a
t
i
o
n
M
e
a
s
u
r
e
s
Analysis of Significance After Mitigation
Cu
l
t
u
r
a
l
R
e
s
o
u
r
c
e
s
Th
e
P
r
o
j
e
c
t
c
o
u
l
d
r
e
s
u
l
t
i
n
si
g
n
i
f
i
c
a
n
t
p
e
r
m
a
n
e
n
t
i
m
p
a
c
t
s
t
o
ar
c
h
a
e
o
l
o
g
i
c
a
l
r
e
s
o
u
r
c
e
s
a
n
d
/
o
r
hu
m
a
n
r
e
m
a
i
n
s
,
i
f
s
u
c
h
i
t
e
m
s
a
r
e
en
c
o
u
n
t
e
r
e
d
d
u
r
i
n
g
g
r
a
d
i
n
g
ac
t
i
v
i
t
i
e
s
.
Du
e
t
o
t
h
e
p
r
e
s
e
n
c
e
o
f
a
l
l
u
v
i
a
l
a
n
d
c
o
l
l
u
v
i
a
l
s
o
i
l
s
w
i
t
h
i
n
t
h
e
P
r
o
j
e
c
t
a
r
e
a
b
e
t
w
e
e
n
D
e
l
Po
n
i
e
n
t
e
R
o
a
d
a
n
d
a
p
p
r
o
x
i
m
a
t
e
l
y
2
1
0
f
e
e
t
to
t
h
e
n
o
r
t
h
,
a
p
r
o
f
e
s
s
i
o
n
a
l
a
r
c
h
a
e
o
l
o
g
i
s
t
th
a
t
m
e
e
t
s
t
h
e
s
t
a
n
d
a
r
d
s
s
e
t
f
o
r
t
h
a
t
3
6
C
F
R
§
8
0
0
.
2
(
a
)
(
1
)
s
h
a
l
l
m
o
n
i
t
o
r
t
h
e
g
r
o
u
n
d
di
s
t
u
r
b
a
n
c
e
d
u
r
i
n
g
t
r
e
n
c
h
i
n
g
i
m
m
e
d
i
a
t
e
l
y
n
o
r
t
h
o
f
D
e
l
P
o
n
i
e
n
t
e
R
o
a
d
t
o
o
b
s
e
r
v
e
wh
e
t
h
e
r
a
r
c
h
a
e
o
l
o
g
i
c
a
l
d
e
p
o
s
i
t
s
a
n
d
/
o
r
h
u
m
a
n
r
e
m
a
i
n
s
a
r
e
p
r
e
s
e
n
t
.
I
f
a
r
c
h
a
e
o
l
o
g
i
c
a
l
de
p
o
s
i
t
s
a
r
e
f
o
u
n
d
,
t
h
e
C
i
t
y
s
h
a
l
l
c
o
m
p
l
y
w
i
t
h
3
6
C
F
R
§
8
0
0
.
1
3
(
b
)
(
3
)
;
i
.
e
.
,
t
h
e
C
i
t
y
sh
a
l
l
u
n
d
e
r
t
a
k
e
r
e
a
s
o
n
a
b
l
e
e
f
f
o
r
t
s
t
o
a
v
o
i
d
,
m
i
n
i
m
i
z
e
o
r
m
i
t
i
g
a
t
e
a
d
v
e
r
s
e
e
f
f
e
c
t
s
t
o
su
c
h
p
r
o
p
e
r
t
i
e
s
,
i
n
c
l
u
d
i
n
g
d
e
t
e
r
m
i
n
a
t
i
o
n
o
f
a
c
t
i
o
n
s
t
o
r
e
s
o
l
v
e
a
d
v
e
r
s
e
e
f
f
e
c
t
s
,
a
n
d
no
t
i
f
i
c
a
t
i
o
n
o
f
t
h
e
S
t
a
t
e
H
i
s
t
o
r
i
c
P
r
e
s
e
r
v
a
t
i
o
n
O
f
f
i
c
e
r
(
S
H
P
O
)
a
n
d
/
o
r
a
p
p
r
o
p
r
i
a
t
e
Tr
i
b
a
l
H
i
s
t
o
r
i
c
P
r
e
s
e
r
v
a
t
i
o
n
O
f
f
i
c
e
r
(
T
H
P
O
)
,
a
n
y
I
n
d
i
a
n
t
r
i
b
e
t
h
a
t
m
i
g
h
t
a
t
t
a
c
h
re
l
i
g
i
o
u
s
a
n
d
c
u
l
t
u
r
a
l
s
i
g
n
i
f
i
c
a
n
c
e
t
o
t
h
e
a
ff
e
c
t
e
d
p
r
o
p
e
r
t
y
,
a
n
d
t
h
e
A
d
v
i
s
o
r
y
C
o
u
n
c
i
l
on
H
i
s
t
o
r
i
c
P
r
e
s
e
r
v
a
t
i
o
n
w
i
t
h
i
n
4
8
h
o
u
r
s
o
f
t
h
e
d
i
s
c
o
v
e
r
y
.
T
h
e
n
o
t
i
f
i
c
a
t
i
o
n
s
h
a
l
l
de
s
c
r
i
b
e
t
h
e
C
i
t
y
’
s
a
s
s
e
s
s
m
e
n
t
o
f
N
a
t
i
o
n
a
l
Re
g
i
s
t
e
r
e
l
i
g
i
b
i
l
i
t
y
o
f
t
h
e
p
r
o
p
e
r
t
y
a
n
d
pr
o
p
o
s
e
d
a
c
t
i
o
n
s
t
o
r
e
s
o
l
v
e
t
h
e
a
d
v
e
r
s
e
e
f
f
e
c
t
s.
T
h
e
S
H
P
O
/
T
H
P
O
,
t
h
e
I
n
d
i
a
n
t
r
i
b
e
a
n
d
th
e
C
o
u
n
c
i
l
s
h
a
l
l
r
e
s
p
o
n
d
w
i
t
h
i
n
t
w
o
w
o
r
k
d
a
ys
o
f
t
h
e
n
o
t
i
f
i
c
a
t
i
o
n
.
T
h
e
a
g
e
n
c
y
of
f
i
c
i
a
l
s
h
a
l
l
t
a
k
e
i
n
t
o
a
c
c
o
u
n
t
t
h
e
i
r
r
ec
o
m
m
e
n
d
a
t
i
o
n
s
r
e
g
a
r
d
i
n
g
N
a
t
i
o
n
a
l
R
e
g
i
s
t
e
r
el
i
g
i
b
i
l
i
t
y
a
n
d
p
r
o
p
o
s
e
d
a
c
t
i
o
n
s
,
a
n
d
t
h
e
n
c
a
rr
y
o
u
t
a
p
p
r
o
p
r
i
a
t
e
a
c
t
i
o
n
s
.
T
h
e
a
g
e
n
c
y
of
f
i
c
i
a
l
s
h
a
l
l
p
r
o
v
i
d
e
t
h
e
S
H
P
O
/
T
H
P
O
,
t
h
e
t
r
i
b
e
a
n
d
t
h
e
C
o
u
n
c
i
l
(
a
s
a
p
p
r
o
p
r
i
a
t
e
)
a
re
p
o
r
t
o
f
t
h
e
a
c
t
i
o
n
s
w
h
e
n
t
h
e
y
a
r
e
c
o
m
p
l
e
t
e
d
.
If
a
n
y
h
u
m
a
n
b
o
n
e
s
a
r
e
d
i
s
c
o
v
e
r
e
d
,
t
h
e
C
o
u
n
t
y
C
o
r
o
n
e
r
s
h
a
l
l
b
e
c
o
n
t
a
c
t
e
d
.
I
n
t
h
e
ev
e
n
t
t
h
a
t
t
h
e
r
e
m
a
i
n
s
a
r
e
d
e
t
e
r
m
i
n
e
d
t
o
b
e
of
N
a
t
i
v
e
A
m
e
r
i
c
a
n
o
r
i
g
i
n
,
t
h
e
M
o
s
t
L
i
k
e
l
y
De
s
c
e
n
d
a
n
t
,
a
s
i
d
e
n
t
i
f
i
e
d
b
y
t
h
e
N
a
t
i
v
e
A
m
e
r
i
c
a
n
H
e
r
i
t
a
g
e
C
o
m
m
i
s
s
i
o
n
,
s
h
a
l
l
b
e
co
n
t
a
c
t
e
d
i
n
o
r
d
e
r
t
o
d
e
t
e
r
m
i
n
e
p
r
o
p
e
r
t
r
ea
t
m
e
n
t
a
n
d
d
i
s
p
o
s
i
t
i
o
n
o
f
t
h
e
r
e
m
a
i
n
s
.
Less than Significant
Executive Summary
Es
p
o
l
a
R
o
a
d
I
m
p
r
o
v
e
m
e
n
t
P
r
o
j
e
c
t
F
i
n
a
l
E
I
R
ES-24
Ma
y
2
0
1
3
Ta
b
l
e
E
S
-
2
(
c
o
n
t
.
)
SI
G
N
I
F
I
C
A
N
T
I
M
P
A
C
T
S
A
N
D
P
R
O
P
O
S
E
D
M
I
T
I
G
A
T
I
O
N
Si
g
n
i
f
i
c
a
n
t
I
m
p
a
c
t
M
i
t
i
g
a
t
i
o
n
M
e
a
s
u
r
e
s
Analysis of Significance After Mitigation
Ge
o
l
o
g
y
a
n
d
S
o
i
l
s
Ba
s
e
d
o
n
t
h
e
c
o
n
c
l
u
s
i
o
n
s
pr
o
v
i
d
e
d
i
n
t
h
e
P
r
o
j
e
c
t
Ge
o
t
e
c
h
n
i
c
a
l
D
e
s
i
g
n
R
e
p
o
r
t
a
n
d
th
e
r
e
l
a
t
i
v
e
u
n
c
e
r
t
a
i
n
t
y
r
e
g
a
r
d
i
n
g
th
e
p
r
e
s
e
n
c
e
a
n
d
e
x
t
e
n
t
o
f
co
r
r
o
s
i
v
e
m
a
t
e
r
i
a
l
s
w
i
t
h
i
n
t
h
e
st
u
d
y
a
r
e
a
,
l
o
n
g
-
t
e
r
m
i
m
p
a
c
t
s
a
r
e
co
n
s
i
d
e
r
e
d
p
o
t
e
n
t
i
a
l
l
y
s
i
g
n
i
f
i
c
a
n
t
.
Ot
h
e
r
r
o
a
d
w
a
y
c
o
n
d
i
t
i
o
n
s
a
n
d
de
s
i
g
n
s
p
e
c
i
f
i
c
s
w
o
u
l
d
b
e
co
n
f
i
r
m
e
d
d
u
r
i
n
g
f
i
n
a
l
d
e
s
i
g
n
.
Ex
c
l
u
d
i
n
g
c
o
r
r
o
s
i
v
e
s
o
i
l
s
,
a
l
l
i
d
e
n
t
i
f
i
e
d
po
t
e
n
t
i
a
l
g
e
o
t
e
c
h
n
i
c
a
l
i
m
p
a
c
t
s
w
o
u
l
d
b
e
ap
p
r
o
p
r
i
a
t
e
l
y
a
d
d
r
e
s
s
e
d
t
h
r
o
u
g
h
r
e
q
u
i
r
e
d
re
g
u
l
a
t
o
r
y
c
o
m
p
l
i
a
n
c
e
a
n
d
/
o
r
p
r
o
p
o
s
e
d
Pr
o
j
e
c
t
d
e
s
i
g
n
m
e
a
s
u
r
e
s
f
o
l
l
o
w
i
n
g
c
o
n
f
i
r
m
a
t
i
o
n
o
f
r
o
a
d
w
a
y
c
o
n
d
i
t
i
o
n
s
,
d
r
a
i
n
a
g
e
,
e
t
c
.
du
r
i
n
g
f
i
n
a
l
c
o
n
s
t
r
u
c
t
i
on
d
r
a
w
i
n
g
s
r
e
v
i
e
w
.
An
i
n
v
e
s
t
i
g
a
t
i
o
n
o
f
p
o
t
e
n
t
i
a
l
c
o
r
r
o
s
i
o
n
h
a
z
a
r
ds
w
i
t
h
i
n
t
h
e
P
r
o
j
e
c
t
s
t
u
d
y
a
r
e
a
s
h
a
l
l
b
e
co
n
d
u
c
t
e
d
b
y
a
q
u
a
l
i
f
i
e
d
c
o
r
r
o
s
i
o
n
e
n
g
i
n
e
e
r
pr
i
o
r
t
o
P
r
o
j
e
c
t
i
m
p
l
e
m
e
n
t
a
t
i
o
n
.
T
h
e
re
s
u
l
t
s
o
f
t
h
i
s
a
n
a
l
y
s
i
s
s
h
a
l
l
b
e
i
n
c
o
r
p
o
r
a
t
e
d
i
n
t
o
f
i
n
a
l
P
r
o
j
e
c
t
d
e
s
i
g
n
,
a
s
a
p
p
r
o
p
r
i
a
t
e
,
t
o
mi
t
i
g
a
t
e
p
o
t
e
n
t
i
a
l
c
o
r
r
o
s
i
o
n
i
m
p
a
c
t
s
,
a
n
d
m
a
y
in
c
l
u
d
e
(
b
u
t
n
o
t
b
e
l
i
m
i
t
e
d
t
o
)
m
e
a
s
u
r
e
s
su
c
h
a
s
:
(
1
)
e
x
c
a
v
a
t
i
o
n
(
o
r
o
v
e
r
e
x
c
a
v
a
t
i
on
)
a
n
d
t
r
e
a
t
m
e
n
t
,
a
n
d
/
o
r
r
e
m
o
v
a
l
a
n
d
re
p
l
a
c
e
m
e
n
t
(
i
.
e
.
,
w
i
t
h
n
o
n
-
c
o
r
r
o
s
i
v
e
e
n
g
i
n
e
e
r
e
d
f
i
l
l
)
o
f
c
o
r
r
o
s
i
v
e
m
a
t
e
r
i
a
l
s
;
(
2
)
u
s
e
o
f
no
n
-
c
o
r
r
o
s
i
v
e
a
n
d
/
o
r
c
o
r
r
o
s
i
o
n
-
r
e
s
i
s
t
a
n
t
b
u
i
l
d
i
n
g
m
a
t
e
r
i
a
l
s
i
n
a
p
p
r
o
p
r
i
a
t
e
l
o
c
a
t
i
o
n
s
;
an
d
(
3
)
i
n
s
t
a
l
l
a
t
i
o
n
o
f
c
a
t
h
o
d
i
c
p
r
o
t
e
c
t
i
o
n
d
e
v
i
c
e
s
.
Less than Significant