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YAtrYM1PM,A <br />0 <br />Water Boards <br />Santa Ana Regional Water Quality Control Board <br />February 25, 2016 <br />Mr. Tyrone Chesanek, <br />City of Santa Ana <br />20 Civic Center Plaza <br />Santa Ana, CA 92701 <br />PE, Principal Engineer <br />/ ems �� Bn,nua>C SPrwN .b,. <br />Mnrn�,w .......... <br />ill f.i�n�i <br />Review of California Environmental Quality Act Mitigated Negative Declaration: <br />Ana -Delhi Channel Diversion Project <br />Dear Mr. Chesanek: <br />Thank you for the opportunity to comment on the mitigated negative declaration (MND) <br />for the proposed Santa Ana Delhi Diversion Project (Project). The stated purpose o the <br />Project is to eliminate dry weather flow and floating debris in the Santa Ana -Delhi <br />Channel to help improve water quality in Upper Newport Bay, The City proposes to <br />construct in an unincorporated area of Grange County a dry weather diversion stru ture <br />within the Santa Ana Delhi Channel adjacent the Newport Beach Golf Course. Whe <br />operating, the Project will remove dry weather flows, trash, debris, and low flows du ing <br />the wet season up to 3.0 cubic feet per second, In addition, the Project proposes th <br />construction of a 1.6 miles long pipeline to carry the diverted flows to an Grange Cc nth <br />Sanitation District regional collection system located on Baker Street in the City of ost <br />Mesa. <br />The MND states that the City of Santa Ana, in association with the Cities of Newpo <br />Beach and Costa Mesa, has proposed the diversion project to address surface wai <br />quality issues. The Cities propose to address water quality issues in accordance v <br />the Orange County Municipal Separate Storm Sewer System permit as well as the <br />several total maximum daily loads (TMDLs) developed for Upper Newport Bay. A <br />primary intent of the Project is to address the Current selenium TMDL while also <br />addressing TMDLs for bacteria, toxics, metals, and nutrients, and the recently apps <br />statewide trash amendment. <br />Regional Board staff appreciates that this Project appears likely to improve water <br />in Upper and Lower Newport Bay by reducing the loading of pollutants to the Bay. <br />requests consideration of the following comments on the MND when designing, <br />constructing, and implementing this Project. <br />1. The Project design should consider the impacts of removing all low flows at he <br />diversion structure to downstream aquatic ecosystems. As described in the 993 <br />draft Environmental Impact Report (EIR) #527 "Santa Ana -Delhi System", a d <br />�20,C; 99 <br />