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Septic to Gravity Sewer Conversion Project Final Initial Study/Mitigated Negative Declaration Letter 1 Response to Comments The State Water Board's general comment on the project Draft Initial Study/Mitigated Negative Declaration is noted. No specific comments on the content of the MND are provided. Attachment to State Water Board Transmittal 1Q'0I This attachment provides additional guidance as to information needed to support a City application for funding pursuant to the Clean Water State Revolving Fund (CWSRF), but does not comment on the adequacy of the current M N D under CEQA. The CWSRF Program is partially funded by the USEPA and requires additional California Environmental Quality Act (CEQA)-Plus environmental documentation and review. As noted in the attachment, the State Water Board is required to consult with agencies responsible for implementing federal environmental laws and regulations. Any environmental issues raised by federal agencies or their representatives would be addressed prior to the State Water Board approval of a CWSRF financing commitment for the proposed project. 1-3. Due to the lack of habitat and the developed nature of the project area, no impacts to candidate, sensitive, or special status species are anticipated. The project site is located in a fully developed urban area in the Pasadena Street, Medford Avenue, Deodar Street, and 171h Street neighborhood within the City of Santa Ana. Proposed improvements would be below ground level and would be located within existing paved roads where there are no sensitive habitats. 1-4. With regard to cultural resources, the project records search showed that a total of 6 cultural resources investigations have been conducted within the one -half -mile records search radius. The records search results show that 2 built environment cultural resources have been previously recorded within the one -half -mile records search radius: a Craftsman bungalow single family residence at 17391 E. Santa Clara Avenue (P30- 161988) and Cavalry Church at 1010 N. Tustin Avenue (P30-177515). However, none of the previously recorded resources on file at the SCCIC are in or adjacent to the project area. No archaeological sites and no built environment resources have been recorded in the project area. The California Historic Property Data File (HPDF) also lists hundreds of historic -period buildings and structures in Santa Ana. However, none of these are in the project area. Overall, the records search results show that the project area has a low potential for subsurface prehistoric and historic period archaeological material. Pursuant to a CWSRF financing application, a Section 106 compliance report would be prepared. Comments and Responses 2-7 November 2020 75B-22