Clovis Unified School District Response to Comments Received
SHIELDS-LOCAN ELEMENTARY SCHOOL PROJECT Initial Study/Mitigated Negative Declaration

September 18, 2018

This document presents the Clovis Unified School District’s responses to the comments received on the Shields-LocanElementary SchoolProject InitialStudy and Mitigated NegativeDeclaration during the 30-day public review period from July 23, 2018 to August 22, 2018. The response to each letter is presented below. Each of the comment letters received is attached for reference.

Email dated July 25, 2018, from the City of Fresno Fire Department, Fire Prevention and Technical Services Division, Ted Semonious, Deputy Chief

The City of Fresno comment provides information provided on the location and distances of the fire stations serving the school site, the fact that a City of Clovis fire station is the closest station to the site, and that there is an automatic aid agreement between the Cities of Clovis and Fresno, which could be modified or cancelled at any time.

In response, the District notes that the City of Fresno has approved substantial urban residential development adjacent to the school site, which would not have been approved and developed if the City of Fresno could not provide adequate urban services, including fire protection and emergency services. The school site is immediately adjacent to this development and such development is necessitating the construction of the new school. Since the City has not indicated that new school cannot be adequately served, a less than significant finding for this impact remains appropriate.

Letter dated July 30, 2018, from the County of Fresno Department of Public Health, Environmental Health Division, Deep Sidhu, R.E.H.S., Environmental Health Specialist

The District acknowledges all the comments made as appropriate and many of them (bullets 4 through 9) reflect existing regulations that the District must comply with. Reponses to bullets 1, 2 and 3 regarding potential noise impacts are as follows:

Bullet 1 indicates concern about the school site being exposed to high noise levels frommajor streets. The school site has limited frontage on one collector street (Locan Avenue) and two future local streets (Cortland and Jewel Avenues). The noise impact analysis prepared for the Initial Study did not indicate any significant impacts to the school site due to traffic noise.

Bullet2 indicates concern about short termconstruction noise.MitigationMeasures N-2a,b andc address this and will reduce potential impacts to a less than significant level.

Bullet 3 indicates concern with the potential for the school to expose nearby residents to elevated noise levels through the use of amplification equipment and crowd noise during athletic and special events. This was specifically addressed in the noise impact analysis prepared for the Initial Study. Mitigation Measures N-1a throughdlimitoperational time for on-siterecreational facilitiesandmaintenance activities,prohibit the use of amplified sound/PA systems, and require a noise barrier consisting of a 6 foot solid masonry wall along the northern and western boundary of the school site that abuts residential uses.

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Response to Comments Received on Shields-Locan Elementary School Project Initial Study and Mitigated Negative Declaration (continued)

Letter dated August 2, 2018, from Fresno Irrigation District, Laurence Kimura, P.E. Chief Engineer

The District’s responses to the numbered items in the Fresno Irrigation District letter are as follows:

1. The comment indicating that FID does notown, operate or maintain any facilities located on the project site is noted.

2. The school site is immediately adjacent to urban residential development within the City of Fresno and is necessitated by this urban development. The District has entered into an extraterritorial service agreement with the City of Fresno to provide the school site with water and sewer service.

3. The District would potentially be interested in using surface water for landscape irrigation if available from FID.

4 and 5. Further clarification of the source of water and the extraterritorial service agreement should be obtained from the City of Fresno.

6. The District’s engineer will contact FID to discuss requirements.

7. The City of Fresno has indicated it can serve the project with the imposition of the conditions of the extraterritorial service agreement, which is intended to minimize the impact on water supplies (i.e. the water supply necessary for the project will be provided by the District either through assignment of water entitlements associated with the property, the acquisition of additional surface water rights or the payment of a fee per acre-foot of water needed for the project to the City of Fresno).

8. Comment regarding the Sustainable Groundwater management Act adopted in 2014 is noted. This was discussed in on page 36 of the Initial Study under item E, 10, b.

9 and 10. The District is aware of the locations of the FID irrigation pipeline (Gow No. 99) in Locan Avenue 100 feet from west side of the site and the private pipeline (Gould No. 97) traversing the east side of the site. Any street or utility improvements that would affect the FID pipeline would require FID review and approval.

11. The District recognizes that FID will make additional comments and requests as the project progresses and more detail becomes available.

Letter dated August 27, 2018, from the Fresno Metropolitan Flood Control District (FMFCD), Gary Chapman, Engineering Technician III. (Note: although this letter was received after the August 22, 2018 comment deadline, the District has chosen to prepare a response.)

For more than 30 years, the District has worked with FMFCD to successfully develop numerous school sites and the stormwater drainage system improvements for those schools in accordance with the plans and polices of FMFCD and the District. As is our practice, we will continue to work with FMFCD to ensure that appropriate stormwater drainage improvements are provided for new school sites, with the District paying its appropriate fees. The provision of storm drainage services to schools and other urban development has traditionally not been a significant environmental issue in that FMFCD has extensive environmental policies and procedures to ensure that its drainage basins and drainage pipeline infrastructure are designed in a way that minimizes water quality impacts and stormwater capacity issues

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Response to Comments Received on Shields-Locan Elementary School Project Initial Study and Mitigated Negative Declaration (continued)

and maximizes groundwater recharge. Being part of the FMFCD system also has the advantage of having a regional NPDES permit in compliance with EPA laws and requirements.

As requested in FMFCD’s letter, the District fully intends to have FMFCD facilities serve the project. As further requested in the letter, the District intends to reach an agreement with FMFCD that will cover items 2a through d included in FMFCD’s letter.

It is important to note that the District’s engineer spoke with FMFCD on September 17, 2018 and confirmed that the FMFCD Master Plan can accommodate the stormwater generated from the school site without any additional mitigation measures related to stormwater runoff system capacity.

The Master Plan designates the school site area as being planned for medium to high density residential development. The school site is equivalent to a medium density residential development with regard to stormwater runoff potential, which means the school site will be generating less stormwater runoff than the Master Plan design. This is noted in the preliminary comment letter from FMFCD dated March 21, 2018.

Since FMFCD has not yet constructed the Master Plan basin for this area, the District will need to retain stormwater on site in a temporary basin until permanent facilities have been constructed. The District’s construction documents show the construction of a 3.86 acre-foot basin at the northeast corner of Locan and Cortland. This basin is sized using the City’s temporary storm drainage basin design criteria.

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On Jul 25, 2018, at 11:08 AM, Theodore Semonious <Theodore.Semonious@fresno.gov> wrote:

I have a comment on the initial study. The reference to Fire Protection in that the Fresno Fire Department indicated that the closest fire station was between two and three miles is
correct. However the closest fire station does not belong to the City of Fresno. That station is a City of Clovis fire station located 2.6 miles from the project. The closest Fresno fire station is 3.4 miles from the proposed intersection of Cornell and Locan, which is still not the entrance to the school.

I bring this to your attention because although Clovis has an automatic aid agreement with the City of Fresno, that agreement could be modified or canceled at any time. We have approved projects in the past based on that agreement. If the agreement were to terminate the fire response from the current fire station 10 would be significantly greater than 4 ½ minutes in travel time. The Building and Fire Codes require just about any building now to include fire sprinklers, so from the fire protection side, the project is acceptable with the agreement in place. Please keep in mind that the fire department is the first responder in medical emergencies. Those responses will also be delayed without that agreement.

This is not an attempt to require the construction of a new fire station, simply to bring attention to the fact that the highlighted section on page 42 may be misleading in saying that section 15. (a) is less than significant. Additional or modified language in that section may be appropriate.

Thanks in advance for taking this into consideration.

Ted Semonious Deputy Chief
Fire Prevention and Technical Services Division Fresno Fire Department
559 908 9712 cell 559 621 4101 office

	County of Fresno

DEPARTMENT OF PUBLIC HEALTH David Pomaville, Director
Dr. Ken Bird, Health Officer

July 30, 2018

Clovis Unified School District Kevin Peterson (via e-mail)
Assistant Superintendent, Facility Services 1450 Herndon Avenue
Clovis, CA 93611

LU0019372 PE 2600

Dear Mr. Paterson:

SUBJECT:

LOCATION:

Clovis Unified School District; Shields and Locan Elementary School Project

Clovis, CA, APN(s) 310-230-24, 34

The Department of Public Health, Environmental Health Division has completed a review of the Request for Preliminary Comment for the proposed project and offers the following comments for consideration:

	The location of the proposed school site is adjacent to major thoroughfares. Construction and layout of the facility should take this into consideration during the design phase in an effort to reduce potentially significant noise impacts from traffic along the thoroughfares.

	Appropriate measures should be incorporated into the construction phase of the project to minimize potentially significant short-term localized noise impacts to noise sensitive receivers caused by the operation of construction equipment. Construction specifications for the project should require that all construction equipment is maintained according to the manufacturers’ specifications, and that noise generating construction equipment is equipped with mufflers. In addition, consideration should be given to limiting noise-generating construction activities to daytime hours.

	 The proposed project has the potential to expose nearby residents to elevated noise levels through the use of outdoor sound amplification equipment and crowd noise during athletic and special events. Consideration should be given to the layout and design of the facilities to provide shielding of sound amplification and noise generating items from the surrounding neighborhoods.

	As a measure to protect groundwater, all water wells (not intended for use) and septic systems within the property shall be properly destroyed by an appropriately licensed contractor. Contact the Department of Public Health, Water Surveillance Program at (559) 600-3357 for more information.

	 If any underground petroleum storage tank(s) are discovered during construction activities, the applicant/property owner shall apply for and secure an Underground Storage Tank Removal Permit from the Fresno County Department of Public Health, Environmental Health Division. Contact the Certified Unified Program Agency at (559) 600-3271 for more information.

	Prior to issuance of building permits for the swimming pool, the applicant shall submit complete pool

Promotion, preservation and protection of the community’s health
1221 Fulton Mall / P.O. Box 11867 / Fresno, California 93775 / Phone (559) 600-3271 / FAX (559) 455-4646 Email: EnvironmentalHealth@co.fresno.ca.us  www.co.fresno.ca.us  www.fcdph.org Equal Employment Opportunity Affirmative Action Disabled Employer

Kevin Peterson Clovis USD July 30, 2018 Page 2 of 2

facility plans and specifications to the Fresno County Department of Public Health, Environmental Health Division, for review and approval. And prior to operations, the applicant shall apply for and obtain a permit to operate a Public Swimming Pool from the Fresno County Department of Public Health, Environmental Health Division. A permit, once issued, is nontransferable. Contact the Recreational Health Program at (559) 600-3357 for more information.

	 Prior to issuance of building permits for proposed food facilities, the applicant shall submit complete food facility plans and specifications to the Fresno County Department of Public Health, Environmental Health Division, for review and approval. And prior to operations, the applicant shall apply for and obtain a permit to operate a food facility from the Fresno County Department of Public Health, Environmental Health Division. A permit, once issued, is nontransferable. Contact the Consumer Food Protection Program at (559) 600-3357 for more information.

	 Facilities proposing to use and/or store hazardous materials and/or hazardous wastes shall meet the requirements set forth in the California Health and Safety Code (HSC), Division 20, Chapter 6.95, and the California Code of Regulations (CCR), Title 22, Division 4.5. Any business that handles a hazardous material or hazardous waste may be required to submit a Hazardous Materials Business Plan pursuant to the HSC, Division 20, Chapter 6.95 (http://cers.calepa.ca.gov/ or https://www.fresnocupa.com/). The default State reporting thresholds that apply are: >55 gallons (liquids), >500 pounds (solids), >200 cubic feet (gases), or at the threshold planning quantity for extremely hazardous substances. Contact the Certified Unified Program Agency at (559) 600-3271 for more information.

	 All hazardous waste shall be handled in accordance with requirements set forth in the California Code of Regulations (CCR), Title 22, Division 4.5. This Division discusses proper labeling, storage and handling of hazardous wastes.

If I can be of further assistance, feel free to contact me at (559) 600-3271.

Sincerely,

Deep Sidhu, R.E.H.S. Environmental Health Specialist Environmental Health Division

CUSD Shields and Locan Elem Sch.docx