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