FINAL
Supplemental Environmental Assessment
FEMA-1203-DR-CA
Federal Emergency Management Agency, Region IX
Project Name: Soule Park Bank Repairs
Subgrantee:  County of Ventura, General Services Agency
Project Number: P.A. ID #111-00000; DSR #73861 and 52055
Date:  July 16, 2002
Project Location: Soule Park, County of Ventura, California
1.0	INTRODUCTION
Ventura County, through the California Office of Emergency Services (OES), has applied to the Federal Emergency Management Agency (FEMA) Public Assistance (PA) Program for funding to repair and stabilize a portion of the stream banks along Thacher and upper San Antonio Creeks.  The stream banks, which were severely damaged during the winter storms of 1998, are located within Soule Park near the City of Ojai, California (Figure 1).
1.1	Scope of Document
This Supplemental Environmental Assessment (SEA) tiers from the Final Programmatic Environmental Assessment (PEA) for Typical Recurring Actions Resulting from Flood Disasters in California as Proposed by the Federal Emergency Management Agency (FEMA 1998a) and hereby incorporates the PEA by reference, in accordance with 40 CFR Part 1508.28.
1.2	Purpose of and Need for Action
The purpose of and need for action is described in Section 1.4 of the PEA.  Heavy rains from the winter storms of February 1998 caused severe slope failure and erosion along Thacher and upper San Antonio Creeks within Soule Park in Ventura County, California.  The proposed bank repairs to Thacher Creek are located adjacent to the main park road and active recreation areas.  The proposed bank repairs to San Antonio Creek are located adjacent to a County equestrian trail, which was also partially destroyed by the floods.  The County of Ventura has identified the need to take action to protect public health and safety, as the steep and unprotected slopes are vulnerable to continued erosion and possible failure.
2.0	ALTERNATIVE ANALYSIS
2.1 Alternatives Analyzed and Dismissed
An alternative that would incorporate buried rock riprap was considered for the repair of Thacher Creek.  With this alternative, the toe of the banks along Thacher Creek would be excavated approximately 5 feet and the banks would be graded to a 2:1 slope.  Filter material would be placed on the new slope, then covered with 3 feet of ungrouted -ton rock riprap.  The filter material and rock slope protection would be placed about halfway up the bank, which would correspond to the water surface elevation during a 10-year storm event.  Two to three feet of native soil would be backfilled over the riprap and along the top of the slope to create a smooth, natural appearing bank.  The bank would then be planted with native riparian and upland species, including a combination of trees, shrubs, and perennial herbs and grasses.  This alternative was dismissed after a meeting between FEMA, Ventura County, the U.S. Army Corps of Engineers (USACE), and the National Marine Fisheries Service (NMFS) in August 2001.  During the meeting, NMFS expressed concerns regarding streambed encroachment and loss of vegetation from the stream bank due to rock riprap.
2.2 Alternatives Analyzed
The No Action Alternative is discussed in Section 2.5.2.1 of the PEA.  Under the No Action Alternative, the repairs to the failed bank slopes would not be conducted along Thacher and upper San Antonio Creeks in Soule Park.  The banks in these reaches of the two subject creeks would continue to be vulnerable to future failure and erosion.
The Proposed Action is described in Section 2.5.2.3 of the PEA.  The Proposed Action would involve two separate bank repair projects, one on Thacher Creek and the other on upper San Antonio Creek (Figure 2).  These repairs are described below:
The Thacher Creek bank repair project is located on the south bank of the creek within Soule Park, approximately 1,500 feet upstream of its confluence with San Antonio Creek.  Soule Golf Course is located on the north side of the creek.  Two areas of the bank were eroded during high flows in 1998, causing loss of the adjacent grassed areas.  In total, the two damaged bank areas measure 784 linear feet.  The two areas are separated by a 300-foot-long, stable, vegetated bank.  The banks on the 445-foot upstream segment would be stabilized using interlocking, x-shaped, concrete blocks called A jacks.  The toe of the banks would be excavated approximately 3 feet deep and 5 feet wide, and the A jacks would be placed in the trench.  Existing willow trees that have become established on the banks would be hand cut into 5- to 6-foot-long poles, stripped of leaves, and placed among the A jacks.  Soil would then be used to fill the voids among the A jacks to facilitate the establishment of the willow poles.  Above the A jacks, the banks would be graded to a more gradual 2:1 (H:V) slope.  Filter material would be placed on the new slope, which would be planted with native grasses.  The banks along the 339-foot downstream reach would be stabilized by cutting the slope to a 2:1 slope, beginning above the streambed.  Filter material would be placed on the new slope and would be seeded with native grasses.  All work would be performed from the top of the bank.  Construction would be approximately 3 to 4 months in duration.
The San Antonio Creek bank repair would occur along 300 linear feet of the creeks eastern bank in an area adjacent to the Soule Golf Course.  The top of the bank would be lowered approximately 3to 5 feet and smoothed to a more gradual slope (2:1, H:V).  A 5-foot-wide, 4-foot-deep trench would be excavated at the base of the bank, and A jacks would be placed in the trench.  Existing willow trees that have become established on the banks would be hand cut into 5- to 6-foot-long poles, stripped of leaves, and placed among the A jacks.  Soil would then be used to fill the voids among the A jacks to facilitate the establishment of the willow poles.  Access to the channel would occur along the equestrian trail and all work would be conducted from the trail.  Construction would be approximately 2 months in duration. 
3.0	AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES
3.1	Geology, Geohazards, and Soils
The affected environment is described in Section 3.1 of the PEA.  Impacts of the No Action Alternative are described in Section 4.1.1.1 of the PEA.  Impacts of the Proposed Action are described in Section 4.2.1.3 of the PEA.
Under the No Action Alternative, the Thacher Creek and San Antonio Creek bank repairs would not be performed.  If the channels are not repaired, future flooding may be exacerbated and could result in soil erosion and aggravated bank instability in Thacher and San Antonio Creeks.
The Proposed Action is not anticipated to have any adverse impacts to geology or geohazards; however, these activities have the potential to cause the disruption and displacement of soils.  To minimize erosion impacts associated with the Proposed Action, the project applicant would develop and implement a Soil Erosion Control Plan, which would include the following measures:
* Silt fences or other appropriate erosion control device would be installed and maintained to prevent discharge of soil from construction activities.
* All construction activities would be conducted between May and October, when flows are typically absent from the two creeks.
* Upon completion of construction, all temporary fill and construction debris would be removed from the project area.
There would be no construction of human-occupied buildings under any alternative; therefore, the Proposed Action would be in compliance with Executive Order (EO) 12699, Seismic Safety of Federal or Federally Regulated New Building Construction.
3.2	Air Quality
The affected environment is described in Section 3.2 of the PEA.  Impacts of all alternatives are described in Section 4.1.2 of the PEA.  Neither the Proposed Action nor the No Action Alternative would result in any changes to air quality.  To control fugitive dust and the release of particulate matter, the contractor would be required to implement dust control practices during construction (i.e., water down the work area).  The use of construction vehicles (including backhoes, graders, and trucks) with the Proposed Action would increase air pollutants; however, their impacts would be temporary and negligible.
3.3	Hydrology and Water Quality
The affected environment is described in Section 3.3 of the PEA.  Impacts of the No Action Alternative are described in Section 4.2.3.1 of the PEA.  Impacts of the Proposed Action are described in Section 4.2.3.3 of the PEA.
Under the No Action Alternative, future erosion of the stream banks could negatively affect water quality through increased siltation or turbidity.
The Proposed Action would not be expected to have an adverse impact on hydrology.  The design of the bank stabilization activities would closely conform to the current vertical height and slope contour of the bank sides, both upstream and downstream of the project site.  The proposed bank stabilization plans were also developed in cooperation with the USACE and the NMFS, and are designed to minimize changes to water turbidity and velocity through the project area.  Therefore, there would be limited potential for scour downstream of the proposed project areas.
Ventura County would need to obtain a Section 401 permit from the Los Angeles Regional Water Quality Control Board prior to construction.  The County would also need to obtain a streambed alteration permit from the California Department of Fish and Game.
In order to minimize short-term impacts to water quality during construction activities, the project applicant would be required to develop and implement the Soil Erosion Control Plan referenced in Section 3.3.  In general, the Proposed Action is anticipated to have a positive impact on water quality in both Thacher and San Antonio Creeks by reducing siltation caused by the presently erosive banks.
3.4	Floodplain Management
The affected environment is described in Section 3.4 of the PEA.  Impacts of the No Action Alternative are described in Section 4.2.4.1 of the PEA.  Impacts of the Proposed Action are described in Section 4.2.4.3 of the PEA.
According to the most recent Flood Insurance Rate Map (FIRM), both project areas are located within the 100-year floodplain; however, no structures would be constructed that would affect the function of the floodplain.  In compliance with FEMA policy implementing EO 11988, Floodplain Management, it has been determined that the Proposed Action would not result in long-term effects associated with the occupancy of or modification to floodplains and the direct or indirect support of floodplain development.  However, it is anticipated that the Proposed Action would require a Floodplain Development Permit to be obtained from the County of Ventura prior to construction activities.  In addition, because the Proposed Action Alternative would potentially occur within the floodplain, a public notice would be circulated explaining the project and reasons for the project being sited in the floodplain for compliance with EO 11988 (Floodplain Management) and 44 CFR Part 9.
3.5	Biological Resources
The affected environment is described in Section 3.5 of the PEA.  Impacts of the No Action Alternative are described in Section 4.2.5.1 of the PEA.  Impacts of the Proposed Action are described in Section 4.2.5.3 of the PEA. 
The top of the Thacher Creek bank at the Soule Park site is located adjacent to an active recreation area with mowed grass and scattered ornamental (ash [Fraxinus spp.]) and native trees (coast live oak [Quercus agrifolia], western sycamore [Platanus racemosa]).  The area is used primarily for picnicking and field games.  The area between the fence and the top of the eroded bank has been colonized by non-native weeds and grasses, including black mustard (Brassica nigra) and wild oat (Avena sp.), among others.
Riparian woodland and scrub occur along the banks and sandbars in Thacher Creek.  The lower slopes and sandbars are dominated by moderate-sized (up to 10 feet tall) mule fat (Baccharis salificifolia) and arroyo willow (Salix lasiolepis) trees, along with telegraph weed (Heterotheca randiflora), horseweed (Conyza sp.), rabbits foot grass (Polypogon onspeliensis), Himalayan blackberry (Rubus discolor), and giant reed grass (Arundo donax).  The vegetation is continually subjected to disturbances from winter flows and remains in an early successional stage of development.  Larger willow trees and occasional sycamore trees are located on the middle and upper portions of the banks.  Figure 3 shows the vegetation along the Thacher Creek site.
The top of the bank along the San Antonio Creek consists of a disturbed corridor that is mostly denuded of vegetation as a result of heavy traffic along the horse trail and dirt bike activities.  Wild oats are present at the fence and along the top of the eroded slope.  Several coast live oak trees are also present along the upstream end of the project area, and a grove of large eucalyptus (Eucalyptus spp.) trees is present at the downstream end.  The channel consists of a mosaic of willow-dominated riparian woodland and scrub.  Young willows and mulefat occur along the base of the eroded slopes and on the nearby sand bars in the center of the channel.  Figure 4 shows the vegetation along the San Antonio Creek site.
In compliance with EO 11990, Protection of Wetlands, and 44 CFR Part 9, the proposed alternatives were analyzed for the impacts to wetlands and other jurisdictional waters of the United States as defined under Section 404 of the Clean Water Act.  On September 1, 2001, biologists from URS Corporation completed a wetlands delineation at the project site along San Antonio Creek.  Based upon the results of the delineation and subsequent correspondence from the USACE (Appendix B), it was determined that the wetlands boundary near the San Antonio Creek project area is approximately 10 feet outside of the work area.  Therefore, placement of the concrete jacks at the base of the eroded slope would avoid jurisdictional wetlands or waters of the U.S. and a Section 404 permit would not be required.  The area proposed for repair along Thacher Creek has not been surveyed for wetlands; however, given the nature of the project and project location, it is likely that the project area is within USACE jurisdiction.  Therefore, prior to implementation of the project, Ventura County would coordinate with the USACE to determine whether a Section 404 permit would be required, and if necessary, obtain appropriate permits.
3.6	Threatened and Endangered Species 
The affected environment is described in Section 3.6 of the PEA.  Impacts of the No Action Alternative are described in Section 4.2.6.1 of the PEA.  Impacts of the Proposed Action are described in Section 4.2.6.3 of the PEA.  
Information concerning threatened, endangered, or other special status species that may occur in the project area was obtained from the U.S. Fish and Wildlife Service (USFWS) Ventura Field Office in a letter to FEMA dated March 19, 2001.  The potential occurrence of these species at the project site was assessed from a review of pertinent scientific literature, previous survey reports, and field surveys in February and April 2001.  Critical habitat for these species is not present at or near the project sites.


List of Special Status Species that Could Occur in the Region
___________________________________________________________________________________
       
       Least Bells Vireo			Vireo bellii pusilus		E
       Southwestern willow flycatcher		Empidonax traillii extimus	E
       California red-legged frog		Rana aurora draytonii		T
       Southern California Steelhead		Oncorynchus mykiss		E
___________________________________________________________________________________

Key:  E=Endangered	T=Threatened

Least bells vireo and the southwestern willow flycatcher are not known to occur at either project site.  Therefore, these species are not expected to be impacted by the Proposed Action.
In a letter dated March 4, 2002 (Appendix B), the USFWS indicated that breeding habitat for California red-legged frog is not present at either project site.  However, suitable foraging habitat is present along both Thacher Creek and San Antonio Creek.  Although no California red-legged frogs were present at the project sites during surveys conducted in 2000, California red-legged frogs were observed within San Antonio Creek in 2001, approximately 2.5 miles from the San Antonio project site, and approximately 3.5 miles from the Thacher Creek project site.  Because of the proximity of known occurrences of California red-legged frogs, the potential exists for California red-legged frogs to disperse into or through the project area.
Ventura County would be responsible for implementing the following measures to avoid adverse effects to the California red-legged frog within the project area:
* A USFWS-approved biologist would conduct a training session for all construction personnel.  At a minimum, the training would include (1) a description of the least Bells vireo, southwestern willow flycatcher, California red-legged frog, and their habitat; (2) the importance of the California red-legged frog and its habitat; (3) the general measures that are being implemented to conserve the California red-legged frog as they relate to the proposed project; and (4) the boundaries within which the project may be accomplished.  Brochures, book, and briefings may be used in the training session, provided that a qualified person is on hand to answer any question.  
* Preconstruction surveys would be conducted by a qualified biologist within 24 hours of construction initiation in both project areas.  If California red-legged frogs are found within the project area, construction would not commence until the USFWS is notified and the appropriate level of consultation with the Service has been completed.  
* Drift fences would be used to exclude California red-legged frogs from the construction area.  Fences would be placed at the project boundaries to prevent frogs and other wildlife from entering the construction area.
* The eroded banks would be graded to a more gradual slope and native grasses would be used to revegetate the project areas.  
* Although some willows would be removed from the project area during the installation of the A-jacks, cuttings of the willows would be used form re-establishment around the A-jacks.
* Construction equipment would be restricted to the terrace above the creeks and at no time would be in the water course.  
* Construction work would be conducted during the dry season to help avoid impacts to potential California red-legged frogs. 
There are no records of the Southern Evolutionarily Significant Unit (ESU) of anadromous steelhead spawning and rearing in upper San Antonio Creek, nor in Thacher Creek.  However, steelhead may occasionally travel to these reaches during winter flows in search of spawning habitat.  Several stray adults were stranded in a man-made pool connected to San Antonio Creek on the Soule Golf Course in 1999. 
Suitable habitat for spawning and rearing is not present at either of the project sites in Soule Park due to the absence of overhanging vegetation, suitable gravel sizes, and shallow water conditions (the creeks are typically dry during the summer months).  Suitable spawning habitat is present downstream of the San Antonio Creek site at the golf course; however, rearing habitat is absent from this reach, as this portion of the creek also dries up in the early summer.
To avoid potential impacts to steelhead or its habitat in the vicinity of the project area, Ventura County would implement the following measures:  
* The project would be constructed during the period of May 1 to October 1, when flows are typically absent from Thacher and upper San Antonio Creeks.  In the event that flows are present, all work must occur outside the wetted channel.  Hence, there would be no direct impact to aquatic species, including fish, in the channel at that time.
* Grading activities at the base of the slope along Thacher Creek would be minimized to the extent feasible to reduce impacts to the channel bed.  All equipment would operate from the bank.  The limits of construction would be flagged and monitored.  Finally, the substrate would be restored to its pre-construction condition, including placement of suitable cobbles.
* The creek bed along San Antonio Creek would not be disturbed, as the jacks would be placed between the base of the slope and the line of willow trees.  The low-flow channel is located over 50 feet away from the base of the slope.
* The contractor would employ standard best management practices to prevent erosion and offsite sedimentation, per requirements of the California Department of Fish and Game and the Regional Water Resources Control Board.  Erosion control devices can be combined with red-legged frog exclusion devices.  
* The banks at both project sites would revegetated with native plants, which would provide long-term stabilization of the banks, as well as provide shade over time that would benefit aquatic habitat and fish.
Based on the above evaluation and with the avoidance and minimization measures outlined above, FEMA has determined that the proposed project is not likely to adversely affect federally listed species.  The Ventura Fish and Wildlife Office issued a letter of concurrence regarding FEMAs determination on March 4, 2002 (Appendix B).  In a letter dated January 24, 2002 (Appendix B), the NMFS also concurred that the proposed action is not likely to adversely affect steelhead.
In addition to the avoidance and minimization measures listed above, the County would notify FEMA to re-initiate consultation if any of the following occur (1) new information becomes available revealing effects of the Proposed Action Alternative on listed species in a manner or to an extent not previously considered, (2) if project plans change, (3) if the agency action is subsequently modified in a manner that causes an effect to listed species that was not considered, or (4) if a new species is designated that may be affected by this action.
3.7	Cultural Resources
The affected environment is described in Section 3.7 of the PEA.  Impacts of the No Action Alternative are described in Section 4.1.7.1 of the PEA.  Impacts of the Proposed Action are described in Section 4.1.7.4 of the PEA.  FEMA has reviewed the Proposed Action as required under Section 106 of the National Historic Preservation Act (NHPA), as amended, and the Programmatic Agreement for FEMA-1203-DR-CA (PA; FEMA 1998b).
Pursuant to the revised implementing regulations of the NHPA found at 36 CFR 800.4(a)(2), a records search was conducted by the South Central Coastal Information Center on February 8, 2001.  The record search encompassed the two project locations and a 0.25-mile radius around them.  The record search indicated one previously recorded prehistoric cultural resource within the 0.25-mile radius.  Excavations at this site have removed numerous burials, artifacts including mortars and pestles, and the base walls of a rock bordered sweathouse.  The easternmost edge of this site is approximately 600 feet from the project area at San Antonio Creek and 900 feet from the Thacher Creek project area.  No historic archeological sites have been recorded within the 0.25-mile search radius of the project area.  
Pursuant to the revised implementing regulations of the NHPA found at 36 CFR 800.4(a)(4), the California Native American Heritage Commission (NAHC) was contacted by FEMA to request a review of its Sacred Lands Files and a list of individuals or groups it believes should be contacted for information or concerns related to the project area.  The NAHC responded to FEMAs request on March 21, 2001 with a negative search of its Sacred Lands Files.  An informational letter was sent by FEMA on March 26, 2001 to 21 groups or individuals listed by the NAHC.  To date, three responses have been received.  These individuals were contacted in April 2001 by FEMAs archaeological consultant who explained that as a condition of funding it will be required that an archeological monitor be present during excavation activities (as described below).  A Native American monitor would also be present during all excavation activities.
On August 22, 2001, the SHPO concurred with FEMAs determination that the Proposed Action would not affect historic properties (Appendix B).  The SHPO also concluded that the project area has a high probability of being archaeologically sensitive.  Therefore, pursuant to the Programmatic Agreement, all ground-disturbing activities within the APE would be monitored by a qualified archaeologist.  In addition, in a letter dated June 19, 2001, FEMA also indicated that the following stipulations would be included in the Proposed Action:
* In the event of an archaeological discovery, all work within 15 meters (45 feet) of the find would halt so the find may be documented and its significance assessed by a qualified archaeologist.  The County would notify FEMA immediately, and FEMA would consult with the SHPO in accordance with Section VII of the PA.
* If the aforementioned find is considered significant, all reasonable efforts would be made to avoid further disturbance of the find through project modification or engineering measures, as may be recommended by the archaeologist.  If the find cannot be avoided or protected through such measures, impacts to the find would be minimized to the greatest extent possible, and the archaeologist shall carry out appropriate data recovery.  Work would be redirected away from the discovery site while data recovery is carried out.  Results of the data recovery would be reported to FEMA, the South Central Information Center, and the SHPO.
* Archaeological monitoring would be continued during any additional excavation in the APE.  In addition, if the find is of Native American origin, a local Native American would be retained to monitor with the archaeologist during any remaining excavation of the APE.
* With respect to discovery of any human remains, the provisions of California Public Resources Code (PRC) 5097 would apply.  The County would halt work, and the County Coroner would be notified immediately.  If the remains are determined to be Native American, the Coroner will contact the NAHC.  If it is necessary to relocate any human remains, a qualified archaeologist would document and excavate the remains in the presence of a Native American monitor.
3.8	Socioeconomics and Public Safety
The affected environment is described in Section 3.8 of the PEA.  Impacts of the No Action Alternative are described in Section 4.1.8.1 of the PEA.  Impacts of the Proposed Action are described in Section 4.1.8.4 of the PEA.
The proposed project is located within land owned by the County of Ventura adjacent to the city of Ojai.  Approximately 75 miles northwest of Los Angeles and 35 miles southeast of Santa Barbara, Ojai is situated in a deep coastal valley at the foot of Los Padres National Forest.  Ojai supports a population of 7,862 and is comprised of 90.7% white, 12.5% of Hispanic origin, 2.7% Asian or Pacific Islander, 1.4% American Indian, Eskimo, or Aleut, and 1% black  (Census 2002a). 
At the present time, the U.S. Census Bureau (Census) has not yet released the results of the 2000 economic census.  Therefore, the 1990 Census data was used.  Based on this data, the median household income for the City of Ojai is $33,247, and of those persons for whom poverty status is determined, 5.75% were classified as being below the poverty threshold (Census 2002b). 
Based on information provided by the applicant, Soule Park draws the majority of its visitors from Ventura, Los Angeles, and Santa Barbara Counties, with the greatest use by residents of Ventura County.
It does not appear from this information that there are any concentrated minority or low-income populations within the city of Ojai.  In compliance with FEMAs policy implementing EO 12898, Environmental Justice, the socioeconomic conditions and potential effects related to the No Action Alternative and Proposed Action have been reviewed.  Neither the No Action Alternative nor the Proposed Action are expected to result in any adverse and/or disproportionate adverse impacts on minority or low-income populations.
At present, the eroded banks along Thacher and San Antonio Creeks pose a risk to public safety due to potential unexpected bank instability and slope failures in the future.  Both areas are presently fenced, so public access is restricted.  Under the No Action Alternative, this risk would continue to be present; however, by stabilizing and reinforcing the stream banks, the Proposed Action would be expected to reduce this risk to public safety.
3.9	Land Use and Zoning
The affected environment is described in Section 3.9 of the PEA.  Impacts of the No Action Alternative are described in Section 4.1.9.1 of the PEA.  Impacts of the Proposed Action are described in Section 4.1.9.4 of the PEA.
No impact to land use or zoning would result from the No Action or Proposed Action Alternatives.  All project activities would occur within the existing County of Ventura property boundaries. 
3.10	Public Services
The affected environment is described in Section 3.10 of the PEA.  Impacts of the No Action Alternative are described in Section 4.1.10.1 of the PEA.  Impacts of the Proposed Action are described in Section 4.1.10.4 of the PEA.
Under the No Action Alternative, no activities would be performed.  The No Action Alternative is not anticipated to cause any immediate and direct impacts to public services, although it is possible that future erosion could result in closures of portions of Soule Park and the adjacent equestrian trail due to public safety concerns.  
The Proposed Action is anticipated to lead to positive impacts to parks and recreation by reducing the risk of future closure due to bank erosion.  
No impacts to police, fire, emergency services, or public utilities are anticipated as a result of the No Action or Proposed Actions.
3.11	Transportation
The affected environment is described in Section 3.11 of the PEA.  Impacts of the No Action Alternative are described in Section 4.1.11.1 of the PEA.  Impacts of the Proposed Action are described in Section 4.1.11.4 of the PEA.
The Proposed Action is not anticipated to have any permanent adverse impacts to transportation in the project vicinity.  During construction activities, no roadways would be closed or otherwise impacted as a result of project activities; however, construction staging areas would be located on parking lots at Thacher Creek.  For construction activities at San Antonio Creek, the project applicant has anticipated using the equestrian trail as the primary staging area and access point for construction.
3.12	Noise
The affected environment is described in Section 3.12 of the PEA.  Impacts of the No Action Alternative are described in Section 4.1.12.1 of the PEA.  Impacts of the Proposed Action are described in Section 4.1.12.4 of the PEA.
The Proposed Action would result in temporary noise impacts during construction.  Noise is expected to remain within legal limits and would comply with local noise ordinances.  To reduce noise impacts to park users and adjacent properties, construction would be conducted during normal business hours.  
3.13 Hazardous Materials and Wastes
The affected environment is described in Section 3.13 of the PEA.  Impacts of the No Action Alternative are described in Section 4.1.13.1 of the PEA.  Impacts of the Proposed Action are described in Section 4.1.13.4 of the PEA.
The No Action Alternative would not result in any new impacts to hazardous materials and wastes at the project site.  To reduce incidental release of hazardous materials (e.g., petroleum-related products) under the Proposed Action Alternative, the contractor would be required to have a Spill Response Plan and appropriate Spill Response materials on-site.  Workers would be instructed on the location of the Spill Response materials and appropriate methods to be used for cleanup.  Refueling of construction equipment would not occur within 60 feet of any waterway.  
3.14 Cumulative Impacts
Ventura County Flood Control District (VCFCD) has plans for a project on Thacher Creek to begin in 2003.  The proposed project site is located on Thacher Creek approximately 0.5 miles downstream of Highway 150, within Siete Robles Tract upstream of Boardman Road east of the City of Ojai, and would involve approximately 1,000 linear feet of the stream.
The proposed project would consist of the following features (Lindsey 2002):
* Widening Avenida del Recreo and Avenida de la Vereda culverts from 22 to 36 feet
* Replacing the existing approximately 800 feet of deteriorating gunited pipe and wire revetment channel with reinforced concrete retaining walls
* Widening the soft bottom channel from approximately 22 feet to 36 feet, and lowering the channel bottom approximately 2 feet
* Placement of flood walls at the easterly boundary of the tract to contain overbank flows from the Creek and storm flows from the Black Mountain watershed 
* Limited land acquisition would be required upstream and downstream of the Tract to accommodate the construction of project features.
* Trees, including 4- to 24-inch-diameter oak trees, within the District's right-of-way would be removed to accommodate the proposed improvements.
The VCFCD is preparing an Environmental Impact Report for their project.  This document would discuss the potential impacts to the environment related to their project.  However, the VCFCDs project is located approximately 0.5 miles upstream of the Soule Park project area.  Therefore, the potential exists for cumulative impacts on Thacher Creek, especially in regard to water quality, threatened and endangered species, riparian habitat, and noise.
The Soule Park project would involve approximately 785 linear feet of Thacher Creek.  The VCFCDs project would involve approximately 1,000 linear feet of Thacher Creek.  The largest contributing factor to the cumulative impacts issue is the limited construction period.  Due to the potential for steelhead in Thacher Creek, the construction period for the Soule Park project has been limited to May 1 to October 1.  It is anticipated that the VCFCDs project would have a similar constraint.  This increases the likelihood that construction of both projects would overlap to some degree, or could occur at the same time.  If this were to happened, impacts related to water quality, threatened and endangered species, riparian habitat, and noise would be additive.
If both projects were under construction at the same time, any potential impacts related to erosion and siltation and their effects on water quality would be additive.  Negative impacts would be limited by Soil Erosion Control Plans for each project and the use of best management practices.  Overall, water quality in the creek would be improved once the projects are completed because bank repair and stabilization would decrease the amount of erosion and siltation within the creek.  However, VCFCD indicated that their project would not increase flows downstream of Boardman; therefore, there would be no increase in erosion within Soule Park related to the VCFCDs project.
Threatened and endangered species with the greatest potential to be affected by the projects include the California red-legged frog and the Southern California Steelhead.  The May 1 to October 1 construction period established for the Soule Park project would minimize potential impacts to these species.  During this period, the creek is typically dry.  As stated above, it is expected that the VCFCDs project would have a similar restriction.  It is also expected that other minimization measures recommended for the Soule Park project (i.e., training for construction personnel, preconstruction survey, gradual slopes, native grass vegetation, tree plantings, minimal impacts to stream channel etc.) would be recommended and implemented for the VCFCDs project.  Therefore, although the impacts of these projects may be additive, they would be minimized to the extent possible.  
Construction noise would also be cumulative if these projects were under construction at the same time.  However, the distance between them (0.5 miles) would limit that effect.
Based on the above evaluation, cumulative effects of the bank repair projects in Soule Park and the VCFCD along Thacher Creek would be minimized through the use of avoidance and minimization measures.  Therefore, the projects are not expected to significantly impact environmental resources within the region.
4.0	REFERENCES
Federal Emergency Management Agency (FEMA).  1998a.  Final Programmatic Environmental Assessment (PEA) for Typical Recurring Actions Resulting from Flood Disasters in California as Proposed by the Federal Emergency Management Agency, FEMA-1203-DR-CA.  April 16.
.  1998b.  Programmatic Agreement among the Federal Emergency Management Agency, the California State Historic Preservation Officer, the California Office of Emergency Services, and the Advisory Council on Historic Preservation, Regarding the El Nino 98 Winter Storms, FEMA-1203-DR-CA.  July 22.
Lindsey, Pam.  2002.  Ventura County Flood Control District.  Thacher Creek Channel Replacement Project.  Unpublished information.  March 26.
U.S. Census Bureau (Census).  2002a.  American Factfinder.  Profile and Demographic Characteristics: 2000.  Website accessed February 8.  http://factfinder.census.gov
.  2002b.  American Factfinder.  Income and Poverty Status in 1989: 1990.  Website accessed February 8. http://factfinder.census.gov

5.0	LIST OF PERSONS AND AGENCIES CONSULTED


Theresa Lubin
Landscape Architect
Parks Department
800 South Victoria Ave., L#1030
Ventura, CA  93009

Rodney R. McInnis
Acting Regional Administrator
National Oceanic and Atmosphere Administration
National Marine Fisheries Service
Southwest Region
501 West Ocean Boulevard, Suite 4200
Long Beach, CA  90802-4213

Anthony A. Klecha
Sanitary Engineering Associate
California Regional Water Quality Control Board
320 W. 4th Street, Suite 200
Los Angeles, CA  90013
Esther Won
South Central Coastal Information Center
California State University, Fullerton
Department of Anthropology
800 North State College Boulevard
Fullerton, CA  92834-6846

Dr. Knox Mellon
State Historic Preservation Officer
Office of Historic Preservation
P.O. Box 942896
Sacramento, CA  94295-0001

Pam Lindsey
Planner IV
Ventura County Flood Control District
800 South Victoria Avenue
Ventura, CA  93009

Ms. Isabel Ayala Valdez
1034 N. 5th Street
Port Hueneme, CA 93041
Chief Joseph Ballesteros
5801 Lone Pine Place
Paso Robles, CA 93446

Mr. Charles Cook
32835 Santiago Road
Acton, CA 93510

Ms. Ernestine DeSoto-McGovern
1027 Cacique Street, #A
Santa Barbara, CA 93103

Ms. Beverly Salazar Folkes
1931 Shadybrook Drive
Thousand Oaks, CA 91362

Dr. Kote Lotah
Owl Clan
48825 Sapaque Road
Bradley, CA 93426

Ms. Lin A-Lul'Koy Lotah
Owl Clan
48825 Sapaque Road
Bradley, CA 93426

Mr. Vincent Armenta
Santa Ynez Band of Mission Indians
P.O. Box 517
Santa Ynez, CA 93460

Ms. Julie Lynn Tumamait
365 North Pole Avenue
Ojai, CA 93023

Mr. Patrick Tumamait
992 El Camino Corto
Ojai, CA 93023

Mr. Mark Steven Vigil
San Luis Obispo County Chumash Council
315 South Elm Street
Arroyo Grande, CA 93420
Mr. Qun-tan Shup
Owl Clan
48825 Sapaque Road
Bradley, CA 93426

Mr. Sal Perez
876 Olympia
Ventura, CA 93004

Mr. Paul Varela
10770 Banning Avenue
Hesperia, CA 92345

Ms. Regina Washtiqoliqol
614 Jordan Avenue
Ventura, CA 93001

Mr. Stephen William Miller
189 Cartagena
Camarillo, CA 93010

Mr. John Valenzuela
P.O. Box 402597
Hesperia, CA 92340

Mr. Art Lopez
Santa Ynez Tribal Elders Council
P.O. Box 365
Santa Ynez, CA 93460

Ms. Carol A. Pulido
165 Mountain View Street
Oak View, CA 93022

Mr. Randy Guzman-Folkes
614 Jordan Avenue
Ventura, CA 93001

Mr. Alfred L. Valenzuela
18678 Pad Court
Newhall, CA 91321



APPENDIX A - FIGURES
































































APPENDIX B  AGENCY CORRESPONDENCE
Not available online, please view hard copy version

APPENDIX C  PUBLIC COMMENTS
Not available online, please view hard copy version.
Final Supplemental Environmental Assessment:		Federal Emergency Management Agency
Soule Park Bank Repair		Page 1
July 16, 2002