Introduction

IV.
F WATER RESOURCES
1. INTRODUCTION
This section addresses the potential impacts of the proposed project on the existing hydrology conditions
on the project site.
a. Environmental Setting
There are no substantial changes to the existing setting regarding site hydrology or flood hazard. It is
expected that storm water runoff volumes generated on the project site would remain similar to
conditions described in the final environmental impact report (EIR) (1987), since there has not been
substantial development within the watershed.
2. REGULATORY FRAMEWORK
a. Surface Water Hydrology
Federal Regulations
U.S. Army Corps of Engineers
Federal regulation of “waters of the United States” stems from Section 10 of the federal Rivers and
Harbors Act of 1899, enacted to regulate activities within navigable waters. In 1972, the federal Clean
Water Act was passed and regulates discharges into “waters of the United States.” Section 404 of this Act
regulates activities including fills placed into waters of the United States.
“Waters of the United States” are defined in 33 CFR 328.3:
(a) Waters of the United States means
(1) All waters which are currently used, or were used in the past, or may be susceptible to
use in interstate or foreign commerce, including all waters, which are subject to the ebb
and flow of the tide;
(2) All interstate waters including interstate wetlands;
(3) All other waters such as intrastate lakes, rivers, streams (including intermittent
streams), mudflats, potholes, wet meadows, playa lakes, or natural ponds, the use,
degradation or destruction of which could affect interstate or foreign commerce including
any such waters;
Los Angeles Department of City Planning IV.F-1 Andora Avenue Subdivision – Tentative Tract No. 53426
Impact Sciences, Inc. (0947.002) Subsequent Draft EIR
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IV.F Water Resources
(i) Which are or could be used by interstate or foreign travelers for recreational or other
purposes; or
(ii) From which fish or shellfish are or could be taken and sold in interstate or foreign
commerce; or
(iii) Which are used or could be used for industrial purpose by industries in interstate
commerce;
(4) All impoundments of waters otherwise defined as waters of the United States under the
definition;
(5) Tributaries of waters identified in paragraphs (a) (1) through (4) of this section;
(6) The territorial seas;
Wetlands adjacent to waters (other than waters that are themselves wetlands) identified in
paragraphs (a)(1) through (6) of this section.
Army Corps of Engineers (USACE) jurisdiction in non-tidal waters typically extends to the ordinary high
water mark (OHWM). The OHWM for streams, for example, can be determined by
…the fluctuations of water as indicated by physical characteristics such as clear, natural lines
impressed on the bank, shelving, changes in the character of soil, destruction of terrestrial
vegetation, the presence of litter and debris, or other appropriate means that consider the
characteristics of the surrounding areas. (33 CFR 328.3(e))
Most impacts to areas delineated as “waters of the United States,” if determined to be jurisdictional by
the USACE, require approval under the authority of the Clean Water Act and its implementing
regulations.
Section 404 Permits
The deposition of fill to an area delineated as “waters of the United States,” including wetlands, as
determined to be under USACE jurisdiction, requires a permit or other approval by the USACE
Regulatory Branch. Fill is broadly defined to include most materials (e.g., rock; soil; pilings; concrete;
wood) that may be discharged into a water or wetland.
Most Section 404 permits require mitigation for reducing overall impacts to wetland area and functions.
National Pollutant Discharge Elimination System
Discharge of pollutants into waters of the United States via stormwater is prohibited by the federal Water
Pollution Control Act of 1972, commonly referred to as the Clean Water Act (CWA). Section 402 of the
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CWA requires National Pollutant Discharge Elimination System (NPDES) permits for stormwater
discharges from storm drain systems1 to waters of the United States.2 Congressional reauthorization of
the CWA in 1987 established the NPDES provisions governing stormwater discharges from municipal,
industrial, and commercial sites. NPDES permits for “non-point” discharges from these types of sites are
commonly referred to as “stormwater permits.”
Every city and county in California with a population greater than 100,000 has been issued a NPDES
permit for stormwater discharges, including Los Angeles County, City of Los Angeles, and 84 other
permittees within the County. A NPDES Municipal Permit No. CAS614001 was issued to Los Angeles
County and co-permittees within its jurisdiction on July 31, 1996, and expired on July 30, 2001, but is still
active until a new permit is adopted by the Los Angeles Regional Water Quality Control Board
(RWQCB). The existing NPDES Municipal Permit No. CAS614001 incorporates 12 of the 13 baseline Best
Management Practices (BMPs), which have been approved by the RWQCB. Several additional water
quality permits and plans are required (e.g., Municipal Permit No. CAS614001, a Countywide Storm
Water Management Plan (CSWMP), a Watershed Management Area Plan (WMAP).
Applicants for development projects in the County of Los Angeles, including the City of Los Angeles,
have two major responsibilities under the NPDES Municipal Permit No. CAS614001. The first is to
submit and then implement a Standard Urban Stormwater Mitigation Plan (SUSMP) containing design
features and BMPs appropriate and applicable to the project.3 The purpose of the SUSMP is to reduce
post-construction pollutants in stormwater discharges. Prior to issuance of any grading or building
permit, the City must approve the SUSMP.
1 Storm drain systems are described as Municipal Separate Storm Sewer Systems (MS4s) and include streets,
gutters, conduits, natural or artificial drains, channels and water courses or other facilities that are owned,
operated, maintained or controlled by any permittee (cities and counties) and used for the purpose of collecting,
storing, transporting or disposing of stormwater.
2 Section 402(p)(3)(B) requires that permits for storm drain systems "(i) may be issued on a system- or jurisdiction-
wide basis; (ii) shall include a requirement to effectively prohibit non-stormwater discharges into the storm
sewers; and (iii) shall require controls to reduce the discharge of pollutants to the maximum extent practicable,
including management practices, control techniques and system, design and engineering methods, and such
other provisions as the Administrator or the State determines appropriate for the control of such pollutants."
3 The RWQCB, Los Angeles Region, approved the SUSMP that requires new construction and development
projects to implement BMPs on March 8, 2000. The SUSMP requires that new developments and re-development
projects employ a variety of general and land use specification measures to reduce the post-project discharge of
pollutants from stormwater conveyance systems to the "maximum extent practicable." In May 2000, the County
of Los Angeles finalized its Manual for the Standard Urban Storm Water Mitigation Plan, which details the
requirements of the SUSMP. Projects that fall into any of the seven SUSMP development categories (including
home subdivisions with 10 to 99 housing units) are required to incorporate appropriate SUSMP requirements
into project plans as part of the development plan approval process for building and grading permits.
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The second responsibility is to prepare a Stormwater Pollution Prevention Plan (SWPPP) for all
construction projects with disturbed areas of 2 to 5 acres. Alternatively, the applicant may conform to the
state Construction Activity Storm Water Permit for projects greater than 5 acres. The applicant must
ensure that an SWPPP is approved, or file a Notice of Intent to comply with the state permit prior to
issuance of a grading permit.
In California, the State Water Resources Control Board (SWRCB) and the RWQCB are responsible for
administering the NPDES Program on behalf of the US Environmental Protection Agency. The SWRCB
issues “general” NPDES permits for construction activities and for certain types of industrial and
commercial operations. General Permits reduce amount of time and expense required for compliance
with the NPDES provisions of the Clean Water Act. The RWQCB recently adopted the SUSMP, which
took effect in October 2000.
State Regulations
California Department of Fish and Game
The State of California regulates water resources under Sections 1600–1616 of the Fish and Game Code of
California. Section 1602 of the Fish and Game Code states:
An entity may not substantially divert or obstruct the natural flow of, or substantially change or
use any material from the bed, channel, or bank of, any river, stream, or lake, or deposit or dispose
of debris, waste, or other material containing crumbled, flaked, or ground pavement where it may
pass into any river, stream, or lake, …” until “the department informs the entity, in writing, that
the activity will not substantially adversely affect an existing fish or wildlife resource, and that
the entity may commence the activity without an agreement, if the entity conducts the activity as
described in the notification, including any measures in the notification that are intended to
protect fish and wildlife resources.
The California Department of Fish and Game (CDFG) considers most natural drainages to be streambeds
unless it can be demonstrated otherwise. Streams are defined in the California Code of Regulations
Title 14, Chapter 1, Section 1.72 as follows:
A stream is a body of water that follows at least periodically or intermittently through a bed or
channel having banks and that support fish or other aquatic life. This includes watercourses
having surface or subsurface flow that supports or has supported riparian vegetation.
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CDFG jurisdiction includes ephemeral, intermittent, and perennial watercourses, and is often extended to
the limit of riparian habitats that are located contiguous to the water resource and that function as part of
the watercourse system. Section 2785(e) of the Fish and Game Code of California states:
Riparian habitat means lands which contain habitat which grows close to and which depends on
soil moisture from a nearby freshwater source.
Streambed Alteration Agreements
Any project that impacts CDFG jurisdictional areas, including fills, vegetation removal, or bridging,
requires a Section 1602 Streambed Alteration Agreement from CDFG. Much of the same information (i.e.,
project description, potential impacts, mitigation measures, etc.) necessary to apply for USACE Section
404 permits is required for the Streambed Alteration Agreement application.
Local Regulations
City of Los Angeles Department of Public Works
The Department of Public Works, the City's third largest Department, is responsible for construction,
renovation, and the operation of City facilities and infrastructure. The Department builds the City streets,
installs its sewers, and constructs storm drains as well as public buildings and service facilities.
The Department is comprised of a staff of over 5,500 employees who design and execute public projects
from sidewalks and bridges to wastewater treatment plants and libraries. Throughout its history, the
Department of Public Works has been responsible for construction, renovation and improvement
programs involving hundreds of major public facilities and systems throughout the City of Los Angeles.
The Bureau of Sanitation provides refuse, recyclables and yard trimmings collection, sewer and storm
drain maintenance and repair, wastewater collection and treatment, and many other related services to
the residents of Los Angeles.
City of Los Angeles Stormwater Program
The goal of the City of Los Angeles Stormwater Program is to improve the water quality of the
surrounding riverways, creeks, and coastal waters by reducing the amount of contaminated runoff that
flows from the urban watershed. This is done by installing pollution control devices, educating the
public, partnering with City departments and other agencies, monitoring the water quality of the Los
Angeles River, catch basin labeling, and catch basin cleaning. Implementation of the Stormwater
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Enforcement, Inspection, and Illicit Discharge Program and the Urban Lakes Program also reduce the
amount of contaminated runoff that flows from the urban watershed.
b. Surface Water Quality
Federal Regulations
Pollution Control Act
The federal Clean Water Act established the national strategy for controlling water quality. The primary
purpose of the Act is "to restore and maintain the chemical, physical, and biological integrity of the
Nation's waters" and to attain a level of water quality "which provides for the protection of and
propagation of fish, shellfish, and wildlife and provides for recreation in and on the water[.]" 33 USC
Section 1251(a).
The federal Clean Water Act contains two strategies for managing water quality. One is a
technology-based approach that sets requirements to maintain a minimum level of pollutant
management using the best available control technology (BACT). The second relies on evaluating the
condition of surface waters and setting limits on the amount of pollution that the water can be exposed to
without adversely affecting the beneficial uses of those waters. Section 303(d) of the federal Clean Water
Act specifies that, once a water body is listed as "impaired," the states must establish total maximum
daily loads (TMDLs) for the pollutants causing the impairment (33 USC Section 1313(d)(c)). The states
must then develop a "pollution budget" or pollutant load allocation for point and non-point sources that
are contributing to the water quality impairment.4 Once these allocations have been set, waste load
allocations for point sources are implemented through NPDES permits for individual dischargers, while
non-point source discharges are subject to load allocations that can be specified in an individual NPDES
permit or may be regulated or addressed in other ways. Section 402 of the CWA, as amended, includes
the NPDES program.
State Regulations
California Porter-Cologne Act
At the state level, the Porter-Cologne Water Quality Control Act of 1970 established the SWRCB, which
regulates water quality. In this act, the Legislature directed that state policy should provide principles
and guidelines for water quality control and objectives for key geographic locations. To accomplish this
4 Point sources are those that generate discharge from a discrete conveyance facility. Non-point sources represent
all other sources.
February 2010
objective, the state is subdivided into nine regions each containing a separate RWQCB. This statute gives
the state and regional water quality control boards broad powers to protect water quality by regulating
waste disposal and requiring cleanup of hazardous conditions.
The SWRCB sets state policy for water quality control that must be followed by the regional water boards
and by other state agencies and offices. Each RWQCB must formulate and adopt a plan for all areas
within their region. The regional plans are to conform to the policies set forth in the Act and established
by the SWRCB in its state water policy. The regional plans must: (a) identify beneficial uses of the waters
that are to be protected, such as domestic, navigational, agricultural, industrial and recreational uses, as
well as aesthetic enjoyment; (b) establish water quality objectives, limits or levels of constituents or
characteristics established to protect beneficial uses and to prevent nuisances; and (c) present an
implementation program necessary to achieve those water quality objectives.
General Construction Activity Storm-Water Permit
An NPDES permit is required for construction activities that disturb soils, including clearing, grading, or
excavation, if the total construction site is 5 or more acres in size. In general, the General Construction
Activity Storm-Water Permit (GCASP) allows stormwater discharges from a construction site, and
prohibits non-stormwater discharges and any discharges containing reportable quantities of hazardous
substances. Permitted stormwater discharges are not restricted by numerical effluent limitations. Instead,
discharges are required to implement appropriate pollution prevention control practices and/or BMPs.
The state General Permit for Construction Activity permitting process requires the submittal of a Notice
of Intent (NOI) to the SWRCB. An NOI is a formal notice to the SWRCB from project
applicants/developers that a construction project is about to begin. The NOI provides information on the
owner, location, and type of project, and certifies that the developer will comply with the construction
general permit conditions. The NOI is not a permit application, and so no approval is required.
After completion of the NOI, an SWPPP must be developed that includes a series of phases and activities
to first, characterize a facility, and second, select and carry out actions that prevent stormwater pollution.
For construction projects, this refers to a report that includes site maps, identification of
construction/contractor activities that could cause pollutants in stormwater, and a description of
measures or practices to control these pollutants. The SWPPP is required for construction sites of at least
5 acres and must be prepared and implemented before construction begins. The NOI and SWPPP shall be
available on site, at all times, along with the approved building and/or grading plans. At the completion
of construction activities, a Notice of Termination must be filed with the SWRCB in Sacramento.
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State Regional Water Quality Control Board
Section 401 of the federal CWA authorizes the State of California to issue Water Quality Certifications for
discharges requiring USACE permits for fill and dredge discharges. The state’s implementing regulations
to conduct certifications are codified under the California Code of Regulations, Title 23 Waters,
Sections 3830–3869. Projects qualifying for an USACE Section 404 permit must submit materials for
review to the appropriate RWQCB and request a Section 401 certification.
Section 401 Certification
The Section 401 Certification requires that certain federal permits, including USACE Section 404 permits,
must be certified as meeting the state’s water quality standards. An application must be submitted to the
RWQCB for approval. Much of the same information (project description, potential impacts, and
mitigation measures) necessary to apply for USACE Section 404 and CDFG Section 1602 permits is
required for the Section 401 Certification.
Waste Discharge Reports
In response to certain federal court decisions that limited USACE jurisdiction, the state issued several
directives to the regional boards regarding the regulation of isolated waters no longer regulated by the
USACE. At present, the SWRCB and the RWQCBs are to:
1. Continue issuing Section 401 certifications for federal permits;
2. Issue Waste Discharge Requirements (WDRs) for dredge or fill discharges to waters deemed by
the USACE as not subject to federal jurisdiction referencing the same regulatory considerations
that are used to issue general WDRs.
A Section 401 certification and WDR applications may be made on the same form, but the SWRCB has
issued a model letter to be submitted with the WDR application to clarify that the WDRs are intended to
cover “waters of the State” not covered by the Section 401 certification, and not subject to USACE
regulations.
Local Regulations
Los Angeles Regional Water Quality Control Board Water Quality Control Plan
Discharges to both surface and groundwaters are regulated by the NPDES, which is administered by the
Los Angeles RWQCB (LARWQCB) as part of its discharge permit program. Any proposed action that
would result in a discharge into the waters of the Los Angeles region must describe the quantity and
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nature of the proposed discharge in a Report of Waste Discharge (ROWD) or an NPDES application. As
part of the NPDES ROWD permit, the RWQCB will incorporate appropriate measures and limitations to
protect public health and water quality.
NPDES permits are required for all construction projects impacting 5 acres or more, or smaller areas that
are part of a larger common plan, including excavation, demolition, grading and clearing to mitigate
potential construction-related water quality impacts.
The project applicant is required to prepare an SWPPP pursuant to the NPDES that would identify the
various BMPs that would be implemented on the site during construction.
Examples of BMPs that may be implemented during site grading and construction as part of the SWPPP
could include the following:
 Covering excavated and graded areas where loose, bare soil might otherwise be subject to wind
and water erosion.
 Disallowing the placement of any soils materials in the path of known drainage areas.
 Providing temporary de-silting basins to ensure that surface water flow do not carry significant
amounts of on-site soils and contaminants downstream.
 Requiring that any construction vehicle maintenance be conducted in staging areas where
appropriate controls have been established to ensure that fuels, motor oil, coolant, and other
hazardous materials are not deposited into areas where they may enter surface water and
groundwater.
 Restricting the use of chemicals that may be transferred to surface waters by storm-water flows
or leach to groundwater basins through water percolation into the soil.
 Requiring that permanent slopes and embankments be vegetated as soon as possible following
final grading.
Also, the NPDES permit requirement applies to all discharges of pollutants to “navigable waters” from a
“point source.”5 A point source is defined broadly in the CWA as “any discernible, confined and discreet
conveyance” such as a well, pipe, ditch, discreet fissure, container, or vessel.6 Navigable waters are
defined broadly as “waters of the United States,” and the U.S. EPA has effectively asserted that these
5 McCutchen, Black, Verleger, and Shea, the Attorneys of: California Environmental Law Handbook, Second Edition,
Government Institutes, Inc. January 1988, p. 61.
6 Ibid.
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comprise most surface waters, including waters that are tributary to navigable waters, interstate waters,
and interstate waters having some impact or involvement in interstate commerce.7
c. Groundwater Quality
LARWQCB Water Quality Control Plan
Discharges to both surface and groundwaters are regulated by the NPDES, which is administered by the
LARWQCB. Refer to Project Impacts, within this section for more information about the LARWQCB
Water Quality Control Plan.
3. ENVIRONMENTAL IMPACT ANALYSIS
a. Significance Criteria
The L.A. CEQA Thresholds Guide states that the determination of a project’s significance in terms of water
resources impacts shall be made on a case-by-case basis, under the following four subcategories.
Surface Water Hydrology
The proposed project would have a significant impact on surface water hydrology if it would:
WR-1 Cause flooding during the projected 50-year developed storm event which would have the
potential to harm people or damage property or sensitive biological resources;
WR-2 Substantially reduce or increase the amount of surface water in a water body; or
WR-3 Result in a permanent, adverse change to the movement of surface water sufficient to produce a
substantial change in the current direction of water flow.
Surface Water Quality
WR-4 The project would have significant impact on surface water quality if discharges associated with
the project would create pollution, contamination or nuisance as defined in Section 13050 of the
California Water Code (CWC) or that cause regulatory standards to be violated, as defined in the
applicable NPDES stormwater permit or Water Quality Control Plan for the receiving water
body.
7 McCutchen, Black, Verleger, and Shea, the Attorneys of: California Environmental Law Handbook, Second Edition,
Government Institutes, Inc. January 1988, pp. 61–62.
February 2010
Groundwater Level
The project would have a significant impact on groundwater level if it would:
WR-5 Change potable water levels sufficiently to:
a. Reduce the ability of a water utility to use the groundwater basin for public water supplies,
conjunctive use purposes, storage of imported water, summer/winter peaking, or to respond
to emergencies and drought;
b. Reduce yields of adjacent wells or well fields (public or private); or
c. Adversely change the rate or direction of flow of groundwater; or
WR-6 Result in demonstrable and sustained reduction of groundwater recharge capacity.
Groundwater Quality
The project would result in a significant impact on groundwater quality if it would:
WR-7 Affect the rate or change the direction of movement of existing contaminants;
WR-8 Expand the area affected by contaminants;
WR-9 Result in an increased level of groundwater contamination (including that from direct
percolation, injection or salt water intrusion); or
WR-10 Cause regulatory water quality standards at an existing production well to be violated, as
defined in the California Code of Regulations (CCR), Title 22, Division 4, Chapter 15 and in the
Safe Drinking Water Act.
b. Project Impacts
The Tentative Tract Map indicates that a paved swale is proposed across a portion of Lot 42, and
continues westward through lots 41, 40, and 39. The swale then empties into a storm drain that proceeds
south along the western edge of Lot 39, continues southward within the center of “B” Court, and
continues westerly along the southern boundary of Lot 23. Another storm drain is proposed from Rogers
Way along the eastern side of Lot 28. These two storm drains meet and empty into open space Lot 48.
Two additional storm drains are located at the western portion of the project site, which cross underneath
Rogers Way at lots 36 and 37.
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The reconnaissance geotechnical investigation prepared by Geolabs-Westlake Village on May 24, 2000,
did not encounter groundwater during their investigation and determined that groundwater is not
anticipated to cause any adverse impacts.
WR-1 The proposed project would have a significant impact on surface water hydrology if it would cause
flooding during the projected 50-year developed storm event which would have the potential to
harm people or damage property or sensitive biological resources.
According to public flood maps provided by the Federal Emergency Management Agency (FEMA),8 the
project site is located within Zone D, which denotes an area of which is as an undetermined, but possible
50- or 100-year flood area. As such, the project applicant would be required to conduct detailed
hydrologic and hydraulic analysis as described in MM-WR-4. With implementation of MM-WR-4,
MM-WR-9, and MM-WR-10, project impacts would be reduced to less than significant levels.
WR-2 The proposed project would have a significant impact on surface water hydrology if it would
substantially reduce or increase the amount of surface water in a water body.
Construction
As discussed above, the site is has three first order streams and one second order stream. As part of this
drainage basin, the project site currently contributes surface runoff into the four drainage areas.
Construction of the proposed project would involve site clearance. Upon completion of site clearance, the
project site would be graded with an estimated 600,000 cubic yards of earth material balanced on site.
With the removal of existing vegetation and an increase in bare soil coverage within the clearance and
grading area, the site could generate a greater volume of surface runoff during project construction.
Therefore, grading and earth-moving activities associated with project construction could potentially
result in a temporary increase in the volume of runoff, which could enter the four drainage ways.
However, the increase in runoff is not anticipated to substantially increase the amount of water within
these streams during construction; therefore, the proposed project would result in a less than significant
impact to surface water hydrology during construction.
Operation
The proposed project would involve the development of 45 single-family residences and open space
areas on the project site. Impervious surfaces would be added with the implementation of the proposed
8 Federal Emergency Management Agency. Flood Insurance Rate Maps. http://www.fema.gov/hazard/

map/firm.shtm. Accessed on March 30, 2007.
February 2010
project and therefore would increase the quantity of surface water runoff, when compared to existing
conditions. As part of the proposed project, a paved swale is proposed across a portion of Lot 39 and
continues eastward to Lot 42. The swale empties into a storm drain that proceeds south along the western
edge of Lot 39, continues southward within the center of “B” Court, and continues westerly along the
southern boundary of Lot 22. Another storm drain is proposed from Andora Avenue along the eastern
side of Lot 28. These two storm drains meet and empty into open space Lot 48. Along the western portion
of the property, there is a storm drain proposed from Lot 47 that empties into the northwestern portion of
open space Lot 48. Another storm drain is proposed that would span from Lot 47 to the northern portion
of Lot 36.
WR-3 The proposed project would have a significant impact on surface water hydrology if it would
result in a permanent, adverse change to the movement of surface water sufficient to produce a
substantial change in the current direction of water flow.
Grading and construction activities on the project site would result in temporary changes to the
movement and flow of surface water.
A greater portion of the site would be dedicated open space (38 acres or approximately 42 percent) than
proposed in the 1987 EIR. The remainder of the site would be developed with buildings, paving, and
landscaping (52 acres or approximately 58 percent). Runoff would generally be intercepted and conveyed
off site via a range of drainage features.
WR-4 The project would have significant impact on surface water quality if discharges associated with
the project would create pollution, contamination or nuisance as defined in Section 13050 of the
California Water Code (CWC) or that cause regulatory standards to be violated, as defined in the
applicable NPDES stormwater permit or Water Quality Control Plan for the receiving water
body.
Construction
Grading and earth-moving activities associated with site preparation would involve removing existing
vegetation on site. The removal of vegetation and other soil-stabilizing features during project
construction could accelerate wind and water driven erosion of soils that would increase sedimentation
during storm events. Additionally, spills and leaks associated with construction-related substances such
as oils, lubricants, paints, cleaning agents and other fluids on the project site would increase the potential
for contamination. Excess sediments and contaminants could affect the water quality of the four drainage
ways in the immediate vicinity of the project site, as well as surface water bodies further downstream
February 2010
such as the Los Angeles River and the Pacific Ocean. Therefore, construction-related erosion and site
contamination could result in a potentially significant impact to surface water quality.
However, through incorporation of mitigation measure MM-WR-12, this impact would be reduced to a
less than significant level. MM-WR-12 requires issuance of a NPDES permit including an SWPPP prior to
the issuance of grading permits. The SWPPP would include site maps, identification of
construction/contractor activities that could facilitate pollutants into stormwater, and a description of
measures or practices to control these pollutants. Compliance with NPDES permit requirements and
preparation of an SWPPP would reduce construction-related erosion, sedimentation, and
site-contamination driven water quality impacts to less than significant levels during construction.
Operation
Upon buildout of the proposed project, household runoff generated by the residential uses typically
contains high levels of nitrogen and phosphorus from fertilizers. If not treated, nitrogen and phosphorus
lead to eutrophication9 in receiving water bodies. The Tentative Tract Map provides some information
regarding proposed drainage facilities.
Groundwater Level
WR-5 The project would have a significant impact on groundwater level if it would change potable water
levels sufficiently to:
a. Reduce the ability of a water utility to use the groundwater basin for public water supplies,
conjunctive use purposes, storage of imported water, summer/winter peaking, or to respond
to emergencies and drought;
b. Reduce yields of adjacent wells or well fields (public or private); or
c. Adversely change the rate or direction of flow of groundwater.
Construction
The project site is located within the San Fernando Valley Groundwater Basin (SFVGB), which has
sustained relatively stable water levels from 1979 to 2000. During site grading, removal of vegetation and
other soil-stabilizing features presently on the site could result in a temporary increase in surface runoff.
This increase in runoff would coincide with a reduced opportunity for ground infiltration and
9 Since nitrogen and phosphorus are the limiting factors for grown in a water body, surface runoff rich in nitrogen
and phosphorus encourage the growth of algae. Once the algae dies and is decomposed by organisms, the
increased population of decomposers increases the overall biological oxygen demand to the point where it
asphyxiates most organisms in the body of water.
February 2010
groundwater recharge in the immediate project area. However, the potential impact to groundwater
levels during construction would be temporary and would not be sufficient enough to reduce the ability
of a water utility to draw upon the SFVGB, reduce yields of adjacent wells or well fields, or adversely
change the flow of groundwater; therefore, based on the historical stability of the underlying aquifer and
temporary nature of construction activities, the impact to groundwater level would be less than
significant during project construction.
Operation
Implementation of the proposed project is not anticipated to substantially deplete groundwater supplies
or substantially interfere with groundwater recharge. The proposed project would rely upon City water
supplies, as provided through the City of Los Angeles Department of Water and Power (LADWP).
LADWP does rely upon groundwater to meet a portion of the water demand for the City; however a
majority of the City’s water supply is from sources other than local groundwater.
Additionally, implementation of the proposed project is not anticipated to substantially interfere with
groundwater recharge. Development would occur on approximately 53 acres of the 91-acre project site;
the remaining land would remain undeveloped and be maintained as permanent open space. Therefore,
opportunities for groundwater recharge on the project site would continue after implementation of the
proposed project and would not reduce yields of adjacent wells or well fields. The opportunities for
groundwater recharge throughout the project site would also reduce the chance of change in rate or
direction of flow of groundwater. Therefore, the project’s impacts to the groundwater level would be less
than significant.
WR-6 The project would have a significant impact on groundwater level if it would result in
demonstrable and sustained reduction of groundwater recharge capacity.
Construction
The project site is located within the San Fernando Valley Groundwater Basin, which has sustained
relatively stable water levels from 1979 to 2000. During site grading, removal of vegetation and other
soil-stabilizing features presently on the site could result in a temporary increase in surface runoff. This
increase in runoff would coincide with a reduced opportunity for ground infiltration and groundwater
recharge in the immediate project area. However, the potential impact to groundwater recharge capacity
during construction would be temporary and would not be sufficient enough to result in a demonstrable
or sustained reduction in groundwater recharge capacity; therefore, based on the historical stability of the
underlying aquifer and the temporary nature of construction activities, the impact to groundwater
recharge capacity would be less than significant during project construction.
February 2010
Operation
Implementation of the proposed project is not anticipated to substantially interfere with groundwater
recharge. Development would occur on approximately 53 acres of the 91-acre project site; the remaining
land would be maintained as permanent open space. Therefore, overall approximately 58 percent of the
project site would be covered with impervious surfaces while the remaining 42 percent of the project site
would consist of permeable surfaces. Therefore, opportunities for groundwater recharge on the project
site would continue even with implementation of the proposed project. As such, implementation of the
proposed project would result in less than significant impacts associated with the interference of
groundwater recharge.
Groundwater Quality
WR-7 The project would result in a significant impact on groundwater quality if it would affect the rate
or change the direction of movement of existing contaminants.
Construction
Project construction could potentially result in a temporary increase in groundwater contamination

through spills and leaks associated with construction-related substances such as oils, lubricants, paints,
cleaning agents and other fluids on the project site. If released, these substances could percolate into the
ground and enter the underlying water table. However, this impact would be reduced to a less than
significant level with incorporation of mitigation measure MM-WR-12, which would require a NPDES
permit for construction activity and preparation of an SWPPP prior to construction. The SWPPP would
include measures to avoid spills and leaks of construction-related contaminants and procedures for
remediation in the event of accidental releases or contamination. Therefore, with incorporation of this
mitigation, the surface water percolating into the ground on the project site would not be contaminated
and the present rate of contamination into the groundwater would not substantially change. As such,
impacts to the rate and direction of contamination would be less than significant.
Operation
Contaminants were detected in well samples in the SFVGB. However, the proposed project would not
utilize this groundwater as its source of water and wells are not anticipated for drinking water; water
would be provided to the project by LADWP. As such, groundwater in the vicinity of the project site
would not be pumped upwards and would not shift groundwater contaminants upwards. The proposed
project would introduce impermeable surfaces onto the project site.
February 2010
WR-8 The project would result in a significant impact on groundwater quality if it would expand the
area affected by contaminants.
WR-9 The project would result in a significant impact on groundwater quality if it would result in an
increased level of groundwater contamination (including that from direct percolation, injection, or
salt water intrusion).
Construction
Project construction could potentially result in a temporary increase in groundwater contamination

through spills and leaks associated with construction-related substances such as oils, lubricants, paints,
cleaning agents and other fluids on the project site. If spilled or released, these substances could percolate
into the ground and enter the underlying water table. However, this impact would be reduced to a less
than significant level with incorporation of mitigation measure MM-WR-12, which would require a
NPDES permit for construction activity and preparation of an SWPPP prior to construction. The SWPPP
would include measures to avoid spills and leaks of construction-related contaminants and procedures
for remediation in the event of accidental releases or contamination. With incorporation of this
mitigation, the impact to groundwater contamination would be less than significant.
Operation
Implementation of the proposed project would not introduce new sources of contaminants to the project
site other than those typically used for residential. As such, impacts to groundwater quality would be
less than significant.
WR-10 The project would result in a significant impact on groundwater quality if it would cause
regulatory water quality standards at an existing production well to be violated, as defined in the
California Code of Regulations (CCR), Title 22, Division 4, Chapter 15 and in the Safe Drinking
Water Act.
Residents of the proposed project would not utilize groundwater for consumption. LADWP, as the water
provider for project residents, would provide potable water for the project. Groundwater accounts for a
small percentage of LADWP’s water source; most of LADWP’s water is provided from the State Water
Project. As a major source of water for the State of California, the State Water Project complies with the
CCR, Title 22, Division 4, Chapter 15 and the Safe Drinking Water Act.
As such, potentially significant impacts to groundwater would be to less than significant levels.
February 2010
c. Cumulative Impacts
Development of the proposed project in combination with the list of related projects identified in Section
III, Project Description, would not significantly impact surface water hydrology in the four watersheds.
Therefore, no related projects would interfere with the surface water drainage associated with the
proposed project. The related projects would likely connect to existing stormwater drainage systems. It is
expected that incremental modifications to the stormwater drainage system to accommodate increased
load would be implemented as needed. Therefore, the proposed project and related projects would result
in less than significant surface water hydrology impacts.
Development of the proposed project in combination with the list of related projects identified in Section
III, Project Description, could result in the violation of water quality and/or waste discharge
requirements during construction and operation without implementation of mitigation. However, each
of the related projects would be subject to the same requirements as the proposed project and, thus,
would be required to prepare an SWPPP for construction activities. As with the project, the SWPPPs
prepared for projects would incorporate BMPs by requiring controls of pollutant discharges that utilize
BAT and BCT to reduce pollutants. In addition to an SWPPP, the construction and operation of related
projects within the City of Los Angeles are required, by Chapter 13.29, Storm Water and Urban Runoff
Pollution Prevention Control and SUSMP of the Los Angeles Municipal Code, to submit and then
implement an SUSMP containing design features and BMPs appropriate and applicable to the project to
reduce post-construction pollutants in stormwater discharges. Potential water quality impacts of the
related projects in combination with the proposed project would be less than significant with preparation
and implementation of the SWPPP and SUSMP and the enforcement of these requirements by the City or
County.
Groundwater Level and Quality
Implementation of Citywide related projects would result in additional development that could
indirectly require an increased withdrawal of groundwater through the provision of potable water
provided by LADWP’s groundwater resources. However, the provision of water, including the increased
utilization of groundwater supplies, as a result of the cumulative development of the proposed project
and identified related projects is within the established demand projections of the LADWP (refer to
Section IV.K.1, Water, of this EIR for supplementary analysis of water supplies). Groundwater to be
consumed by cumulative development would be consumed according to current plans and projections
February 2010
by the LADWP and would not, therefore, be substantially depleted as a result of the implementation of
cumulative development.
Recharge of the basin occurs from a variety of sources. Spreading of imported water and runoff occurs in
the Pacoima, Tujunga and Hansen Spreading Grounds. Water flowing in surface washes infiltrates the
basin, particularly in the eastern portion of the Basin.10 No related projects would be developed within
these recharge areas; therefore, cumulative impacts to groundwater recharge and water quality would be
less than significant. Mitigation Measures
MM-WR-1 The extension of the existing 36-inch collector drain along Andora Avenue.
MM-WR-2 The reduction of grading activity to limit drainage impacts.
MM-WR-3 Construction of permanent drainage facilities, as recommended by the project’s

geotechnical consultants, and as determined by the Bureau of Engineering, to control
surface runoff.
MM-WR-4 Compliance with applicable provisions of the Flood Hazard Management Specific Plan
Ordinance (No. 163,913) and requirements of the Bureau of Engineering.
MM-WR-5 Landscaping all graded slopes and installing an irrigation system that conforms to
Section 91.3007 of the Los Angeles Building Code.
MM-WR-6 Construction of any necessary permanent drainage facilities to the satisfaction of the City
Engineer and Superintendent of Building and Safety.
MM-WR-7 Compliance with the recommendations of the preliminary geotechnical investigation and
hydrology study and all applicable provisions of the Municipal Code.
MM-WR-8 Installation of any necessary private and/or public storm drains as required by the City
Engineer.
MM-WR-9 Final surface water runoff/hydrology design would be approved by the City during the
final tract map, grading and drainage plan approval process.
10 California Department of Water Resources Planning and Local Assistance. California’s Groundwater – Bulletin 118.
http://www.dpla2.water.ca.gov/publications/groundwater/bulletin118/basins/pdfs_desc/4-12.pdf. Accessed on
June 6, 2007.
February 2010
MM-WR-10 The applicant shall prepare a hydrology report and drainage plan which quantifies
runoff from site tributary areas, recommends appropriate drainage facilities, and
includes a maintenance and inspection program to ensure proper functioning of
drainage facilities. The hydrology report and drainage plan shall be submitted to the City
Engineer for review and approval prior to development of any drainage improvements.
MM-WR-11 The project shall comply with the requirements of National Pollution Discharge
Elimination system permit for storm water discharge and with guidelines and policies of
the Regional Water Quality Control Board, EPA, and local agencies. A Notice of Intent
will be filed to be covered under the State Board’s “Waste Discharge Requirements for
Discharges of Storm Water Runoff Associated with Construction Activity.”
MM-WR-12 Pursuant to Section 402 of the Clean Water Act, the project applicant shall obtain a
NPDES stormwater discharge permit and prepare an SWPPP prior to the start of
construction. The SWPPP shall identify BMPs to prevent or reduce the potential for
erosion, sedimentation, and contamination on the project site during construction. The
BMPs shall also identify procedures for clean up in the event of contamination from
construction-related substances such as fuel, oil, grease, lubricants, paint, and
construction debris.
d. Conclusion
With implementation of the above mitigation measures, the proposed project would not result in any
significant and unavoidable impacts in regards to hydrology and water quality,
February 2010

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IV.

a. Surface Water Hydrology

U.S. Army Corps of Engineers

“Waters of the United States” are defined in 33 CFR 328.3:

(a) Waters of the United States means

(2) All interstate waters including interstate wetlands;

(6) The territorial seas;

Section 404 Permits

National Pollutant Discharge Elimination System

California Department of Fish and Game

Streambed Alteration Agreements

City of Los Angeles Department of Public Works

City of Los Angeles Stormwater Program

b. Surface Water Quality

Pollution Control Act

California Porter-Cologne Act

General Construction Activity Storm-Water Permit

State Regional Water Quality Control Board

Section 401 Certification

Waste Discharge Reports

1. Continue issuing Section 401 certifications for federal permits;

LARWQCB Water Quality Control Plan

3. ENVIRONMENTAL IMPACT ANALYSIS

Surface Water Hydrology

Surface Water Quality

The project would have a significant impact on groundwater level if it would:

WR-5 Change potable water levels sufficiently to:

b. Reduce yields of adjacent wells or well fields (public or private); or

c. Adversely change the rate or direction of flow of groundwater; or

WR-6 Result in demonstrable and sustained reduction of groundwater recharge capacity.

The project would result in a significant impact on groundwater quality if it would:

WR-8 Expand the area affected by contaminants;

Surface Water Hydrology

8 Federal Emergency Management Agency. Flood Insurance Rate Maps. http://www.fema.gov/hazard/

Surface Water Quality

b. Reduce yields of adjacent wells or well fields (public or private); or

c. Adversely change the rate or direction of flow of groundwater.

Project construction could potentially result in a temporary increase in groundwater contamination

Project construction could potentially result in a temporary increase in groundwater contamination

Surface Water Hydrology

Surface Water Quality

Groundwater Level and Quality

MM-WR-2 The reduction of grading activity to limit drainage impacts.

MM-WR-3 Construction of permanent drainage facilities, as recommended by the project’s

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