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HomeMy WebLinkAboutMINUTES - 05232006 - D.4 --- 4 ED TO: BOARD OF SUPERVISORS r'; `` ; Contra Costa FROM: CARLOS BALTODANO, BUILDING INSPECTION °' `"' ;r County DEPARTMENT DIRECTOR ~ rlll:elr DATE: May 9, 2006 SUBJECT: HEARING ON AN APPEAL OF THE ADMINISTRATIVE DECISION TO ISSUE A GRADING PERMIT FOR THE DELTA COVES DEVELOPMENT PROJECT. LISA KIRK (APPELLANT) (DISTRICT V). SPECIFICREQUEST(S)OR RECOMMENDATION(S)& BACKGROUND AND JUSTIFICATION RECOMMENDATIONS A. Open the public hearing, accept public testimony, CLOSE the hearing. B. Deny the appeal by Lisa Kirk of the administrative decision to issue a grading permit for the Delta Coves project. C. Sustain the issuance of the grading permit. CONTINUED ON ATTACHMENT: YES SIGNATURE ✓RECOMMENDATION OF COUNTY ADMINISTRATOR RETOMMMENDATIO OF BOARD COMMITTEE APPROVE OTHER SIGNATURE(S): ACTION OF BO D N cls APPROVED AS RECOMMENDED O R Speakers: Paul Lai,Berlogar Geotechnical Consultants; Joseph Fanelli,DUC Housing Partners; Michael Boyten,resident of Bethel Island; Leonora Bron,resident of Bethel Island; Samantha Turner,Homeowners of Bethel Island; John Tuxaw,DUC Housing Partners. VOTE OF SUPERVISORS I HEREBY CERTIFY THAT THIS IS A TRUE AND ,10 UNANIMOUS(ABSENT` CORRECT COPY OF AN ACTION TAKEN AND AYES: NOES: ENTERED ON THE MINUTES OF THE BOARD OF ABSENT: ABSTAIN: SUPERVISORS ON THE DATE SHOWN Contact: Carlos Baltodano(925)335-1107 ATTESTED JOHN C01-14h, CLERK OF THE BOARD OF SUPERVIS RS AND COUNTY ADMINISTRATOR Orig: Building Inspection Department(BID) cc: Lisa Kirk(Appellant) Dennis Barry, Community Development Department Ruben Hernandez, Community Development Department County Counsel BY DEPUTY May 9, 2006 Board of Supervisors Permit#348984 Page 2 FISCAL IMPACT None. BACKGROUND Delta Coves is a 560 unit (495 single family, 65 condominiums) water oriented, planned development to be constructed on Bethel Island. The project site consists of approximately 300-acres of vacant property located between Stone Road and Gateway Road, east of Bethel Island Road. DUC Housing Partners are handling development of the project. This project was the subject of extensive litigation in the 1980s. In 1986, the then-property owner sued the County in Federal District Court. (L.E. Weisenberg and Delta Coves v. County of contra Costa, USDC ND Cal. Case No. CV-86-5842-MHP.) In 1989, judgment was entered against the County. The judgment ordered the approval of the final development plan and tentative subdivision map for the Delta Coves project. The judgment also prohibited the County from imposing any conditions on the project other than those contained in the judgment. Within the last few years, DUC Housing Partners acquired interest in the project and began to pursue entitlements for the development. The tentative map for the project remained valid for a number of years, and after complying with relevant conditions of approval, the developer had the final map recorded 2002. More recently, the developer began to pursue approval of a grading permit, and after complying with relevant conditions of approval, a grading permit for the site work was issued by the Building Inspection Department on October 5, 2005, (permit No.GS 348984). Prior to issuance of the grading permit the Building Inspection Department confirmed with the Community Development Department and Public Works Department that the submitted grading plans complied with the approved tentative map and conditions of approval. On October 31, 2005, Ms. Lisa Kirk filed a timely appeal of the issuance of the grading permit. APPEAL In a two-page letter (Exhibit A), Ms. Lisa Kirk stated her reasons for appealing the issuance of the grading permit. The appeal points and staff responses are identified below. Appeal Point#1: The Bethel Island Municipal Improvement District has not issued a permit or resolution for the proposed grading operations. Staff Response #1: There is nothing in the approved development permit requiring the County to obtain approval from the Bethel Island Municipal Improvement District (BIMID) prior to issuance of a grading permit. Condition of approval #22 does require the developer to obtain a resolution from BIMID (or other County approved agency) indicating the district's May 9, 2006 Board of Supervisors Permit#348984 Page 3 agreement to accept and maintain the levee and lagoon. This requirement was met when BIMID passed Resolution No. 05-02-03 on February 3, 2005, which indicated BIMID's acceptance of maintenance responsibility of the Delta Coves perimeter levee and lagoon. Appeal Point #2: Is the use of deep dynamic soil compaction technique allowed under the grading permit? Staff Response #2: The judgment in the above-referenced case required the conditions contained in the judgment to be imposed on the project. Condition No. 14, which is contained in the judgment, requires the developer to perform geotechnical work. Condition No. 14 states as follows: "Geotechnical work shall include levee breaching, soil and excavation, dewatering, removal, replacement and compaction of soil, on-site water development, erosion control measures, and design and installation of subsidence measurement." Deep Dynamic Compaction (DDC) is one of the compacting methods to be utilized by the developer and is recognized by the County as an acceptable method for compacting liquefiable soils (sandy soils). Utilizing DDC was recommended by the project soils engineer and was determined to be consistent with the approved development permit by the Building Inspection Department. Appeal Point #3: This appeal point is divided into eight separate items (a-h) relating to an August 12, 2005, letter prepared by Hultgren-Tillis Engineers, who are in contract with the County as the geotechnical consultant for the project. A contract with Hultgren-Tillis was approved and executed by the Board of Supervisors on October 26, 2004, as required by condition of approval #13 of the Delta Coves project. Appeal Point #3a: Who is permitting the levee construction and oversight — Contra Costa County? Staff Response #3a: The Building Inspection Department grading permit covers the activities associated with the excavation for the lagoon and the fill placement for the construction of the project levees under the recommendations from the project soils engineer. The oversight of the levees while being built will be observed and monitored by the soils engineer of record, and inspected by the Building Inspections Department. The Army Corps of Engineers and other appropriate agencies and jurisdictions may also have an interest during this project. It is the owners' responsibility to obtain those approvals. Appeal Point #3b: Once mass grading starts under permit 348984, what is the amount of soil to be removed? May 9, 2006 Board of Supervisors Permit#348984 Page 4 Staff Response #3b: The estimated earthwork quantity as shown on the reviewed grading plans is 3,100,000 cubic yards of material. All distributed soil will be used on-site with no off haul. Appeal Point #3c: Once mass grading starts under permit 348984, at what point is substantive ground water to be encountered? Staff Response #3c: Per volume 1 of 2 of the Berlogar liquefaction investigation report dated May 27, 2003, ground water was encountered between zero and twenty feet below the surface. However, water levels are expected to fluctuate depending on the time of year. Appeal Point#3d: Under permit 348984, what is to be done with the "dewatering" water? Staff Response #3d: The dewatering water will be utilized on site for dust control and moisture requirements for the fill placement. At this time no off site discharge is anticipated. Appeal Point #3e: Is permit 348984 allowing construction dewatering to be pumped back into the existing drainage ditches on the island that flow to the surrounding slough and affect the California drinking water? Staff Response #3e: Any dewatering water being discharged to any existing on site or off site drainage ditches will require prior approval from the Bethel Island Municipal Improvement District and the Regional Water Quality Control Board. Appeal Point #3f: Does permit 348984 address the volume of water (construction dewatering), the amount of TDS that will be pumped into the drainage ditches? Staff Response #3f: The amount of ground water that might have to be discharged has not yet been determined. Any dewatering water being discharged to any existing on site or off site drainage ditches will require prior approval from the Bethel Island Municipal Improvement District and the Regional Water Quality Control Board. Appeal Point #3g: No individual NPDES permit has been issued by CURWQCD. Does permit 348984 authorize the above activity? Construction dewatering and discharge into the State of California waters without obtaining an individual NPDES? Staff Response #3g: No plan has been submitted for the dewatering discharge locations. If the determined location does become the drainage ditches, which then discharges to the waters of the state, the grading permit does not cover this activity and a separate permit or approval from the appropriate agency or department will be required. The issuance of the grading permit does not relieve the owner of the responsibility of securing permits or licenses that may be required from other departments or divisions of the governing agencies. Appeal Point #31h: I protest the project based on statement BIMID comments on page 8 paragraph 214 pg. 16 on 10/27/05. 1 request a copy of permit 348984 and date issued and May 9, 2006 Board of Supervisors Permit#348984 Page 5 activities permitted under the Freedom of Information Act. I only received a date issued statement and no copies of activities permitted under 348984. 1 received this information on 10/31/05. 1 request again a list of activities to be permitted under permit 348984 along with this appeal. I request the right to amend this appeal when the information is forthcoming under the act. Staff Response #3h: The appellant is protesting the issuance of the grading permit based on a BIMID document. The grading permit was issued to the applicant based on a number of documents and submittals including geotechnical reports, grading plans and numerous other related documents all of which are public record. Copies of the grading permit, plans, geotechnical reports and other documents were provided to Ms. Kirk on 10/31/2005. CONCLUSION The County Building Inspection department issued the grading permit only after confirming with the Community Development Department and Public Works Department that the proposed grading plan is consistent with the approved tentative map and development plan and that the grading plan has complied with all relevant conditions of approval, zoning codes and building codes. Staff recommends that the Board of Supervisors uphold the issuance of the grading permit and deny the request to amend the appeal. The judgment in the above-referenced case prohibits the County from denying the issuance of the grading permit for this project. LISA KIRK PO BOX 435 _ BE1'1i>-1, 1,S1,AN1:) CA 94511 925-684-9250 05-23-2200- MEMBERS 5-23-2200MEMBERS OFTHE BOARD OF SUPERVISORS CONTR COSTA COUNTY GRADING PERMIT 348984 1 WOULD LIKE TO•THANK THE BOARDTODAY FOR THE OPPORTUNITY TO GIVE PUBLIC TESTIMONY ON THE DELTA COVES GRADING PERMIT. I UNDERSTAND THE BECAUSE OF THE 1989 LAWSUIT JUDGMENT, THAT IT PROHIBITS THE COUNTY FROM DENYITVG THE ISSUANCE OF THE-- GRADING HEGRADING PERMIT FOR THE PROJECT. WHICH WOULD EXPLAIN THAT ALTHOUGH I FILED THE APPEAL ON 10-31-2005, THE GRADING WAS ALLOWED TO PRECEDE IN MARCH OF 2006 AND THIS HEARING WAS NOTSCHEDULED UNTIL MAY OF 2006. THE 16 YEAR ULD JUDGMENT HAS ALSO DENTED MY RIGHT AS A CITIZEN, AFFECTED BY THE DEVELOPMENT, TO INCORPORATE MY CONCERNS REGARDING PUBLIC SAFETY. I AM NOT HERE TODAY TO STOP OR HINDER THE DELTA COVES PROJECT, ACTUALLY I THINK, NEW RESIDENTS MOVING TO BE•THEL ISLAND, WILL BE A GREAT BENEFIT•1'O THE COMMUNI•I'Y IN MANY WAYS. BUT, THE 38 CONDITION THAT FOLLOWED THE LAWSUIT, COULD HAVE NOT FORSEEN THE CHANCES OCCURRING IN THE DELTA_AND TTS PROBLEMS ASSOCIATED WITH DEVELOPMENTS IN THE FLOOD PLAIN. MY CONCERNS ARE 1. THE CHANGE IN THE ARMY CORP POSITION AS IT RELATES TO CONDITION 11. 2. THE COUNTY OVERSIGHT ANT—)PERA ITTING OF A BREECH STRUCTURE 3.. THE LACK OF THE CURRENT APPROVAL FROM BETHEL ISLAND MUNICIPAL DISTRICT IMPROVEMENT DISTRICT AS IT RELATES TO THE COUNTY GRADING ORDINANCE 716-2.606 AND B1MID'S OWN ORDINANCE 9 4. THE LACK OF STUDIES REGARDING THE USE OF DEEP DYNAMIC.COMPACTION IN FLOOD PLAINS AND THE IA PACT TO ADJOINING PROPERTIES AND LE`•TES. 5. THE BUILDING OF NEW LEVEE OF FINE TO MEDIUM GRAINED SAND. ARMY COE LE'T'TER PLEASE NOTE A JUNE 30, 1995 LETTER FROM THE US ARIt4Y CORPS OF ENGINEERS, STATING TO MR WEISENBURG,"THAT THE COE WILL NOT EVALUATE OF VALIDATE YOUR LEVEE DESIGN". THE DEPARTMENT OF THE ARMY EVALUATION AND DECISION DOCUMENT SIGNED 6-1-1998 PAGE 27 STATE THAT THE COE WILL REVIEW THE PLANS AND DESIGNS TO ENSURE HAVE BEEN DEVELOPED AND REVIEWED BY LICENSED PROFESSIONAL ENGINEERS, ONLY. THE 1989 CONDITION 11 STATES THAT GRADING PLANS SHALL INCORPORATE L IQLTEFACTION-RESIST_ANTT DESIGN ACCEPTABLE TO THE CORPS OF ENGINEERS, YET THE 1995 AND 1998 DOCUMENTS FROM THE COE STATES NO EVALUATION OF THE DESIGN, ONLY REVIEW IS TO CONFIRM THAT PLANS AND DESIGN HAVE BEEN DEVELOPED AND REVIEW BY LICENSED ENGINEERS. page 1 LISA KIRK PO BOX 435 I3LI- bL I.SLAW CA 945].1 925-684-9250 COUNTY OVERSIGHT OFTHE BREACH S'TRUCT'URE TIE BREACHING OF THE E_XiST?NGLE1,TTE IS A SEPAR-NTE ACTION, THAN CONSTRUCTING A BREACH STRUCTURE. SINCE THIS ACTION COMES UNDER THE GRADING PLAN AND IS AN EXTENSION OF THE NEW LEVEE SYSTEM, I CAN ONLY CONCLUDED FROM THE STAFF RESPONSE 3A, 'THA'T OVERSIGHT OF'THIS SECTION OFTHE LEVEE WILL BE INSPECTED BY 'THE BUILDING INSPECTION DEPARTMENT. THE PROBLEM WITHTHIS FORM OF STRUCTURE 1S THAT, THE COUNTY HAS NO EXPER'T'ISE IN A STRUCTURE THAT ATTACHES AN NEW URBAN LEVEE TO A 125 YEAR OLD AGRICULTURE LEVEE, EVEN THE RECLAMATION DISTRICT BL tm- HAS NO EXPERIENCE iN THiS FORA;T OF STRUCTURE, NOR DO.THEY HAVE A FULL-TIME:ENGINEER ON STAFF.NOR ARE THERE`DEFINE STANDARDS FOR ATTACHING A COMPACTED FILLED,ENGINEERED LEVEE TO A NON COMPACTED, NON ENGINEER LEVEE SYSTEM. THIS BREECH STRUCTURE 1 S A PROT'O'TYPE OF A'TT'ACHING AN OLD LEVEE TO A NEW LEVEE. THIS IS NOT DISCOVERY BAY, THEY DID NOT HAVE TO DEAL WITH AN EXISTING 125 YEARI OLD PEAT LEVEE ,,AXr!TH OLDER RON ES,MANY ENR_OACHING iNTCT Ti-iE LEVEE OR SITTING BELOW SEA LEVEL PLEASE NO'T'E A LETTER DA'T'ED 06-23-19139 FROM RICHARD MEEHAN, AN GEOTECH ENGINEER AND PROFESSOR AT STANFORD. HE WAS ASKED TO COMMENT ON THE DELTA COVES PROJECT BY THE BETHET ISLAND N41-fl-W-CIPAL LRQROVENIENT DISTRICT.MR MEEHAi 4 OUTLINE THE AGGRAVATION OF FLOOD HAZARD TO EXISTING DEVELOPMENT ALONG STONE ROAD. UNDER MANAGEMENT OF GEOTECHNICAL SAFETY AND QUALITY HE STATES, 'THIS MISMATCH OF OLD AND NEW DEVELOPMENT IS A COMMON CAUSE OF TEURNICAL PROBLEMS, COST OVERRUNS, AND FAILURES. IDEALLY FROM A TECHNICAL STANDPOINT A MUCH BETTER PROJECT COULD BE F-EALIZED IF THE ENTIRE STONE ROAD ARE,OLD AND NEW,WERE RFBi TILT TQ CURRENT STANDARDS. PRECEDE IN HIS REPORT HE WRITES ABOUT AN EMBANKMENT SEISMIC STABILITY ANALYSIS FOR THE EXISTING LEVEE, ADAM BREAK EVALUATION: AND FLOOD ROUTING. SUCH A PROJECTREQUIRES EXAC iNG MANAGEMENTOF SAFETY '1'HROUGHOU'T.DESIGN, CONSTRUCTION, AND OPERATION,MUCH THE SAME AS A DAM PROJECT . EXISTING SUBDIVISION ANT) BUILDING CODE REGULATIONS DO NOT PROVIDE, AND ARF NOT INTENDED TO PROVIDE, ADEQUATE ASSURANCE OR CONTROL. THIS IS THE FiRST BREACH STRUCTURE THAT CONTRA COSTA COUNTY HAS EVER PERMITTED THROUGH A GRADING PERMIT. SINCE CONTRA COSTA COUNTY DOES NOT HAVE CODES TO COVER SUCH A BREACH S'TRUCT'URE, WHAT BUILDING CODES ARE BEING FOLLOWED? HAS ANY CONSULTATION BEEN INITIATED WITH THE BOARD OF P-ECi ANU TION OR THE iiFPARTMENT OF WATERRESOURCE'?`NOTE CONCERNS OF DWP.LETTER DATED 10-4-1977,POTENTIAL LEVEE FAILURE CONCERNS). WAS THIS BREACH STRUCTURE DESIGN TO A SET OF CODES OR TO THE PROJECT ENGINEERS' OWN DESIGN? 1 STRONGLY URGE THIS BOARD'1'O CON'TAC'T APPROPRIATE STATE:AENCIES FOR EXPER'1'1SE AND INPUT INTO THIS STRUCTURE AND CLEARLY DEFINE WHAT BUILDING STANDARDS AND CODES WERE LIED FOR TIM, BREACH STRUCTURE DESiGN. I HAVE BEEN UNABLE TO FIND A COMPLETE SET OF SIGNED OFF PLANS ON THE BREACH STRUCTURE. 1 CAN NOTCOMMENT ON 'THIS ASPECT OF'THE GRADING PERMIT, BECAUSE THE INFORMATION IS NOT AVAILABLE. I ASK THAT THE HEARING}BE CONTINUE UNTIL THIS PLANS ARE FiNA.L1ZED. page 2 LISA KIRK PO BOX 435 BE-1 E L 1 S-LXN), CA 94511 925-684-9250 LACK OF CURRENTAPPROVAL FROM THE BEl'HEL ISLAND MUNICIPAL IMPROVEMENT DISTRICT AS IT RELATED TO ORDINANCE 9 AND COUNTY GRADING CODE 716-2. 606 THE COUNTY'S GRADING ORDINANCE 716-2.606 S'I'A'1'ES 'I'HA'I'APPLICANTS'I'HA'1'UU ANY WORK ON LEVEES OR DRAINAGE GET APPROVAL FROM THE LOCAL RECLAMATION DISTRICT. THE PROCESS THAT EXISTS FOP.PROPERTY OWNERS ON BETHEL ISLAND IS AS FOLLOWED,( WED YOTT FIRST APPLIED TO BIMID, AND AFTER THE APPLICATION PROCESS AND APPROVAL, YOUR APPLICATION AND PLANS ARE STAMPED AND THEN YOU PROCEED WITH THE COUNTY AGENCIES. THIS PROCESS ASSURES T'HA'I"I'HE ACTIVITY COMPLIES WITH BIMIDS OWN ORDINANCES. ORDNANCE 9 SECTION LI (F)STATE THAT THIS ORDINANCE IS INTENDED TO SAFEGUARD BIMID'S ABILITY TO PROTECT ITS LEVEES AND TiiFRFRY TFTF HEALTH ATV7) SAFETY OF THE RESIDENTS Of, BETHEL ISLAND, AND TO ENSURE THAT DEVELOPMENT ON THE ISLAND CONFORMS TO STATE AND.FEDERAL STANDARDS. ALTHODUH THE 38 CONDI'T'IONS MAKES REFERENCE TO BIM1D, I'1'ALSO ALLOWS OTHER ENTITY TO TAKES ON NEW RESPONSIBILITIES. RATHER OR NOT BIMID PASSES RESOLUTION TO TAKE ON THE NEW RESPCINSMII ITIFS,IT DOES NOT RELIEVE THETA(FROM TIFF BASIC RFSPONSIBLI ITIFS OUTLINE IN ORDINANCE 9. I HAVE BEEN UNABLE TO FIND A CURRENT BIM1D BOARD APPROVAL OF THE PROJECT. AFTER NUMEROUS PUBLIC INFORMATION REQUEST I WAS GIVEN A LETTER DATED 12-29-1975, STATING THAT THE BLA;IiT1 BOARD OF DIRECTORS APPROVED THE PRESENT PLANS FOR DELTA COVES. ALTHOUGH THERE IS AN APPLICATION NUMBER,I BELIEVE THAT NUMBER IS THE COUNTY'S FILE NUMBER, NOT THE BIMID APPLICATION NUMBER, AS THE DISTRICT MANGER REFERENCED ASTHE BIMTD APPROVAL NUMBER IN A LETTER DATED MAY 17, 2006. MORE CONFUSINIG IS A LETTER DATED 06-73-198z0,STATING,THAT THE DISTRICT ORIGINALLY SUPPORTED THIS PROJECT,BUT SINCE IT'S APPROVAL, HAVE BEEN ABLE TO OBSERVE AND STUDY MORE THAN FIFTEEN DELTA LEVEE FAILURES, AND THAT THEIR CONCLUSION IS THAT THE "STONE ROAD CORRIDOR"PRESENTSTHE POT'ENT'IAL FOR A DISASTROUS LUSS OF LIFE AND PROPERTY WHICH DOES NOT EXIST TODAY. BIM.IDS COMMENTS '1'O THE REISSUING OFTHE CEO PERMIT 6063 A PAGE 8 GRADING S'L'A'T'ES `CONTRA COSTA COUNTY DOES NOT HAVE THE SOLE AUTHORITY TO GRANT LEVEE GRADING PERMITS. INT IE CALF OF DELTA COVES, THE FIRST PERr.IITT_ING.AGENCY IS BLA41D. NVITITOUT AN CURRENT APPROVAL FROM THE BIMID BOARD STATING THAT THE ACTIVITY OF THIS PROJECT HAS BEEN DEEMED IN COMPLIANCE WITH THEIR OWN ORDINANCE 9, WHAT ASSURANCES DOSE THIS COUNTY HAVE THAT THE CONSTRUCTION ACTIVITY WONT IMPACT' THE EXISTING LEVEE SYSTEM OR PROPERTY, AND THAT MITIGATION MEASURES HAVE BEEN APPRON-TED BY THE Bal-11)BOARD WHO IS RESPONSIBLE FOF MAKING THAT DETERMINATION? page 3 LISA KIRK PO BOX 435 UETH-ElSi_.ANU, (;A 94511 925-684-9250 SINCETHE COUNTY ISSUED THE GRADING PERMITWITHOUT"THAI'WRITTEN APPROVAL FROM THE B1MID BOARD, I CAN ASSUME THAT, ONE IT WAS AN OVERSIGHT,OR TWO THE CONCERNS TO THE EXIST_rNG LEVEE SYSTEn4 WERE ADDRESSED UNDER THE, SOIL ENGINEERS REPORT AND MITIGATED BY THE GRADING SUPERVISOR. ONE EXAMPLE IS THAT CREST SURVEY OF THE EXISTING LEVEE WERE TO BE DONE, SO THAT IF THE EXISTING LEVEE STARTS TO SUBSIDE, (EITHER BECAUSE OF DEWATERING OF THE PROJECT SITE OR SETTLEMENT DUE TO COMPACTING TECHNIQUES), IT WILL BE NOTED. BUT THE SOIL ENGINEER MAKES NO REFERENCE WHO IS RESPONSIBLE FOR CORRECTING.A SUBSIDING EXISTING LEVEE. ON MAY 3 2006,BIMID DECLARED ON EMERGENCY AT.4472 STONE ROAD APPROXIMATELY 1/2 MILE FKOM THE BREACH SITE. A'IEMPORARY SOLUTION OF SHEETPLILING WAS INSTALLED. THIS IS THE SECOND DECLARED EMERGENCY IN THE LAST 5 MONTHS. UNFOR'TUNAT'ELY, THE 38 CONDITIONS FROM THE JUDUMENT, DID NOTRECOGNIZE ANY OF THESE SITUATIONS,NOR DID IT ANTICIPATE THE FAILURES OF THE LEVEE SYSTEM IN CALIFORNIA. BOARDS TR T HAVE OVEPRSIGHT OF PROJECTS A,PPROVFID IN FLOOD PI AINC PROTECTED BY A LEVEE SYSTEM THAT DOES NOT HAVE 100 YEAR FLOOD PROTECTION, SHOULD ASSURE THAT MAXIMUM SAFETY GOALS ARE REACHED. SINCE THE COUNTY DOES NOT HAVE A CURRENT B1MlD APPROVAL ON 'I.'HIS PROJECT, IS THIS T'O BE TAKENTHE COUNTY HAS REVIEW AND IS RESPONSIBLE FOR THE SAFETY OF THE EXISTING LEVEE SYSTEM? DEEP DYNAMIC COMPACTION STAFF RESPONSE 2 STATES,T'HA'T DEEP DYNAMIC COMPACTION IS ONE OF THE METHODS TO BE UTILIZED BY THE DEVELOPER AND IS RECOGNIZED BY THE COUNTY AS AN ACCEPTABLE METHOD FOR CONTIPACTING LIQLTFIARr E SOILS. YET, IN A STATEIMErNT OF FINDINGS AND OVERRIDING CONSIDERATION FOR THE CYPRESS LAKES AND COUNTRY CLUB PROJECT,(NOW KNOWN AS SU A ER LAKES), ADOPTED BY THE BOS IN JUNE 8, 1993, PAGE 35 STATES,"DUE TO THE PUBLIC'S CONCERN ONTHE USE OF THE DEEP DYNAMIC COMPACTION METHOD, 'PHIS METHOD SHOULD NOT BE USED". 1N 2001, THE EAST COUNTY REGIONAL PLANNING CONfMISSION SIGNED OFF ON THE DEVELOPERS REQUEST TO USE THE ALETHOD, WHICH NOW HAS RESULTED IN DAMAGES TO ADJOINING PROPERTIES AND PENDING LITIGATION. SINCE THE COUNTY HAS ACCEPTED THIS METHOD, CAN THE COUNTY PRODUCE STUDIES CONCERNING DEEP DYNAMIC COMPACTION IN FLOOD PLANES? THE'TRIAL TESTINCLUDED A 9 T'ON BLOCK DROPPED A'I'A HEIUHT OF 50 FEET, YET THE LIQUEFACTION INVESTIGATION REFERS TO A20 TON BLOC WITH DROPS HEIGHT OF ABOUT 40 TO 60 FEET. WHAT WOULD BE THE PREDICTED ACCELERATION AND WHAT COULD WE EXPECT AS FAR AS DAMAGE'1'O OUR HOMES? HOW DO YOU EXPECT THE ENERGY TO TRA TE L AFTER MIP ACT IF NO STUDIES NAVE BEEN CONDUCTED IN FLOOD PLANES? page 4 LISA KIRK PO BOX 435 BETHEL,I�LANtj, CA 94511 925-684-9250' ALSO, WILL DOWNHOLE AND SEISMIC AND SPECTRAL ANALYSIS OF SURFACE WAVES IN THE VICINITY OF THE COMPACTION AND AT VARIOUS DISTANCE AWAY FROM THE COMPACTION CONDUCTED AND IF SO SVM .ALN OUTSIDE PARTY BE RESPONSIBLE FOR REVIEWING THE RESULTS? IF DRAW DOWN METHODS ARE SUCCESSFUL WILL THERE BE WATER BEl'WEEN "THE SOIL PARTICLES AND IF SO HOW CAN YOU COMPACT SATURATED OR WET SOIL AND IF SOIL IS CONSIDERED SATn?ATED FONT ACCEL ERATION ABOVE FASTER THROUGH TILE SOIL INDUCING GREATER DISPLACEMENT IN THE NEAR BY STRUCTURES? SINCE STABILITY OF THE NEW LEVEES WILL BE A CONCERN TO FUTURE PROPER'L'Y OWNER., AND A MAJOR LIMITATION OF DDC IS THE LACK OF MONITORING AND QUALITY CONTROL DURING THE PRODUCTION PHASE, WILL THE OVERSIGHT OF THE LEVEES BY THE .SOILS ENGINEER OF RECORD INCLUDED WRITTEN STATEMENTS OF QUALITY CONTROL FOR DDC? NEW SAND LEVEE THE NEW LEVEE.ARE TO BE CONSTRUCTED FRO11%4 SAND LOCATED AT TI-IE PROJECT SITE, PLEASE NOTE THAT AN EXPERT PANEL MONITORING RECONSTRUCTION OF NEW ORLEANS , WARNED FEDERAL ENGINEERS ABOUT THE PRESENCE OF WEAK, SANDY SOILS IN THE NEWLY REBUILT LEVEES. RAYMOND SEED, AN ENGINEERING PROFESSOR Al' UC BERKELEY, AND PART OF THE PANEL FUNDED BY THE NATIONAL SCIENCE FOUNDATION, STATING IN A LETTER THAT HE OBSERVED CORP CONTRACTORS CONSTRUCTING]A SECTION OF TI-TE LEA-TE USING"CLEAN FINE GRAINED SAN,WHICH IS HIGHLY ERODEABLE. THE SAND DESCRIBE IN THE DDC FIELD TRIAL ARE DESCRIBED AS FINE TO MEDIUM GRAINED SAND. WHAT PERCENT OF THE NEW LEVEES ARE TO BE CONSTRUCTED Wl'1'H THIS TYPE OF SAND? IN CLOSING I lI lU D LIKE TO ACTS FOR A CONTINUANCE I NTIlI THE BREACH STRUCTURE IS FINALIZED AND CAN BE REVIEWED AT A PUBLIC HEARING, I REQUEST THE BOS ASK FOR A CURRENT APPROVAL FROM THE BIMID BOARD OF DIRECTORS, STATING THAT THE PROJECT COMPLIES W[TH THEIR ORDINANCE 9 AND ALL CONCERNS TO THE EXISTING LEVEE SYSTEM HAVE BEEN ADDRESSED, AND THAT MY QUESTION REGARDING DDC AND SAND LEVEES BE ADDRESSED IN WRITTEN FORA1. I WOULD REQUEST TII?T ALL DOCr mENTATI4N SUBMITTED TODAY BE PART OF THE PUBLIC RECORD 1 WOULD ALSO LIKJ~TO'LHANK THE COUNTY STAFF FOR ALL THELK ASSISTANCE. 1 HAVE ALWAYS BEEN TREATED WITH RESPECT AND PROFESSIONALISM ALMOST EVERYDAY, TRE MEDIA PRESENT A STORY REGARDING THE FRAGILE LEVEE SYSTEM. IN 2001 A CONTRA COSTA TIMES STORY, INTERVENING MR DAVE MARZ FROM THE DEPARTMENT OF NATER RESOILTRCES, STATED THAT IT WO ULD T AKE N,AII LLIONS TO BRING THE BE T 14EL 1SLAND LEVEE SYSTEM UP TO CURRENT STANDARDS. LISA KIRK page 5 DEPARTMENT OF THE ARMY S. ARMY ENGINEER DIS I RIC T. SA(-RAML:N 7 CORPS OF ENGINEEFIS 1325 J STREET SACHAMEN TO. CALIFORNIA 95614 2922 A11EN11-OF Branch ( 1994 � helua Cov, L. P . C C n Mr . Warren L. We : sevLurg 29 Sarrenyw Way Son Rafae — California 0490 ! �aav Mr . .. isenburq : I ha . - reviewed yes our rponse Lo comments, rwceiveA : cu� 7 �:: I- ' is your priposed Delva Coves prctecl Nni . se fcr island , C : Afornia . . You ve adequately addressed the comments and coNoerns inLswd Ly : ederal , scate and local agencies and .xcepu to: the questions involving an alternatives sra _ ysis nn .. nppropriamitiyat ion . ks stated in your May 17 , LOS ! , _ - : ! ezver , r �-se two issues AQ be addressed under sepsuoto _.. = Y . yuur Ma rch ! n , 1 99V etodr Idequats 1 y yus 7 n-.:� trict . ufr ' s decisiLr . Along with une Amenv : c �"Hu ior� of Approval , the Order Amending judqeme7L o . _- . a - V, rdict , we have one irfornatLyn we reej vidi : onal inEormanicn trom the tiial . Last : i need to ciarify 6 misunderstanding yaw r erd 1 nu . a 1 idat ton of vcur proposed luvee des iqr . f . soared in our response to comments that the Corps w : 1 1 rL 1 1 nil p! a�:'; and construcza or procedares for une 1 even A 1 UK Dc a this wbs permit condivion when this proDect was aurharizet 2 :. 1175 , , it no lonyer the case . The Ccrps of ENqikeeys vil : no * ovdindLe val- jdaue your levee design . As you know , you .- pro j I al-so requ) re approvals Ercm the Rec2amanicp Kcar nnd pole: , . vl Q the Department of Water Resources ' Div s inn 4 :: army 01 '.tams . These aqenckes would be the apprvpwlav r author i Anq evee construct ton . IR e F F cpy Fur-is ed Sac ramenL a I i DEPAR'rATENT OF THE Aiaty AND DECISION DoCU11TENT .applicant: Delta Coves L.P. Application No: 199400393 This document constitutes my Environmental Assessment, Statement of Findings, and review and compliance determination according to the Section 404(b)(1 ) guidelines for the proposed work described in the public notice attached as Appendix A. 1. Proposed Project: The location and description of work are described in the attached Public notice. There have been no modifications of the location or the description or the proposed work since the public notice except for the mitigation described below. "Thr applicant will implement an off-site mitigation plan as described in the docum-Init titled "'C?elta Cx.)ves Project Weiland Mitigation Pian," prepared by Earl Cooley, Manager, Medk rd Island H.lhitat Conservation Area, dated May'1996, and revised October 7, 1996. Additionally. the applicant will conStruct shallow-water habitat ori-site for mitigation required as a result xif consultation with the U.S. Fish and Wildlife Service for the pro ject's effects (:)il the threatened delta smelt, HVonlesus tiwn.Jpcicificus. Project History: 1 . Oil AtlgtlSt 20, 1973, the applicant filed an application for rezoning and a preliminary development plan with Contra Costa County, On September 21 , 1976, the county Board of Supervisors certified the final Environmental Impact Report (EIR),, rezoned the property P-1 (planned unit development) and approved a preliminary development plan. ?. On November 11, 1976, Public Notice Number 6063 for a Department of the Arirly Permit was issued. A Final Environmental Impact Statement (EIS) was completed by the Corps in February 1978. A Public Hearing was held oil June 15. 1978 and Department of' the Army Permit Number 6063 was issued on i.)(_tohCI 1978. This permit expired on Octobcr 31, 1983. May 11, 1982, the applicant submitted a fina al developmetlt plan nd tcnta[i L tiubdlvlslon slap ti-) Contra Costa County. On April 12,. 1983, the County P1L-lnnln-I Commission determined that a focused EIR would need to be prepared for the pl-OJV�A. 4. Oil June 6, 1983, the Corps issued Public Notice Number 6063-1' requeS(ing comments oil an extension of time for the ])Mje I. Contra Costa Count, subsequently denied approval of the final development plan and tentative subdivision map. In compliance with regulations supporting denial when local authorization is denied, time request for a time extension was denied without prejudice by the Corps on AW-lust >, IQS g tkp2nment of the Army EVallla[IOn and Decision DC)CUnlent Past b. A plan for a boater education program consisting of signs and 113-ers about the effects of excessive noise and erosion resulting from boat operation oil resident fish and their habitats shall be submitted to the Service for approval. The plan shall be implemented at least 30 days prior to boating activity occurring in the project area. c. No gas.docks shall be constructed within the project boundaries. Restrictions on bilge pumping within the proposed project area shall be strictly, enforced. d. The permittee shall create 1.25 acres of shallow water habitat on-site. This mitigation shall be located adjacent to the landward recreation area (tennis courts) or in another area with minimal boat traffic. Tile permittee shall develop a detailed on-site mitigation plan. Two copies of the plan will be submitted to the Corps of Engineers, one of which \\'ill be forwarded to the Service for approval prior to implementation. Upon approval front the Service through the Corps, the on-site mitigation \will be graded and prepared for planting prior to breaching the levee. The area can be planted once the lagoon is filled or after the levee breach occurs but must be completed within 60 days of breaching the levee. 4. The marina will be designed to include pumpout facilities for sewage and an oily water separator for bilge waters. S. The permittee shall ensure that the CC&R's for the individual home lots include language stating that: a) each of the individual boat docks will be constructed as shown. on drawing number 7 and in a manner such that neither the floating portion of the dock or boats which may be moored to the dock will come to rest ort the levee bench during low water; and b) a Department of the Array permit, separate from that authorizing this project, will be needed prior to any work in, over or Linder the constructed lagoon, including any individual boat docks \with a design other than what is authorized by this permit. 6. The perillrttee shall provide an updated supplemental soils report to the District Engineer tip later than 90 days prior to the proposed date of initiating construction, For ruvic'\5 and approval to ensure that (lie soil report (dated June 1980, is still valid. 7. In ordelfor the C Dips t0 ensure that plaits and designs have been developed and reviewed by licensed professional engineers, the permittee shall submit final development plans and construction methods of the proposed levee system to the District Engineer no liter than 90 days prior to the proposed date of initiating construction. 'These plans shall include a description of the procedure for breaching of the existing levee, details ()It joining proposed and existing levees, and the location of all utilities and plantings \\ithin and oil the proposed and existing levees; \which shall incorporate the following restrictions: I ailcd 1.11ld[I Ick cc kvIvIr—, I'rorn the s I,trt. cmirt I(dd I'a,c I cit 4 iV ()t '1,,-� I -� Publishcc!/'riclut .1 Aril /3. •'Illi/ Failed Linda levet wrong from the start, court told SrcIWOI-cl prolt's.vur 1r.Mfies (11./loot/Trial nA j 1 Y /Appeal-I)emocI'tlt Richard ;1irrlun7. cr f.ivil C17('U7eCI- (IIIc! �f c,rc�lrrric frl rr7�irrcu r ur crrl/ (.i,rcl rriVCI_ it l. �•.�/,lcrin.� lri.� /iriclin�.� 7 hlu scicn al.07c Yuba 110041 trial. \ppcal-1)enlc,crat IIIc Linda kite was located in the wrong place, hulll p6orly and dcstined to Lail. a Stclnlurcl LJIiiversity prod.Cs�4()r tc�tilied I hurscla�-. :.: "The Linda Icvcc post(./ a rclativcly hiuh risk compared to most levees." said Richard Meehan. "It's a IiILh-risk )eycc fr0117 191 1 until it IiUled in IQ86. ' I'hc Icvcc "clilcrcd linlc resistance tk) seepaLc" anti the resultirt�-1 Fchruan 1980 disaster "\vas hasically [I scepaLe lailurc." he said. "The sail was Idose rind 1.111SUthle and very suu:elllihle W seepage instability." htt�}:''������. tanlill'd.c'dU ` Il1Cl11alUlii nlarVS\'IIIC.l1lI11 i 1 ir.,.il=4 RICHARD L. MEEHAN CONSULTING ENGINEER 701 WELCH ROAD,SUITE 1120 - PALO ALTO. CALIFORNIA 84304 (415) 323-0525 1 • Bethel Island Municipal Improvement District 8 5 Stone Road O. Box 244 Bethel Island .CA 94511 June 23 1989 ^: Attention• Christine Thresh -Re: Proposed Delta Coves Subdivision -.. `Ladies and Gentlemen; t your request I have reviewed various documents pertaining to e safety and environmental impact of the proposed Delta Coves ' roject, among which are the William F. Jones Inc. "Soil and eological Investigation for Delta Coves" dated June 1980; a followup letter regarding the potential for disaster at Bethel 1'; : Island by the same firm dated April 14, 1988 ; and a letter from Ray B. Krone and Associates on the subject of flooding of the Island "corridor" dated Decmber 28, 1987. I refer to these particular documents because they are pertinent to the concerns which I will raise herein. '• ': I have also made my own engineering review of certain impacts of the Delta Coves project based in part on the information you ,y provided but also on my familiarity with the site and the ;condition of the existing Bethel Island levees attained from work which I have performed there in the past. My comments are based as well on experience working on many similar problems V over the past twenty years. - -;`I conclude that the existing documents do not adequately evaluate at least two adverse specific technical impacts and one eneral safety management issue arising from the project. Permits for breaching the existing levees should not be ranted g g g '- until these issues are adequately investigated and appropriate plans for their mitigation devised. The two potential adverse technical conditions are (1) BIMID Comments, page 14 aggravation of flood hazard to existing development along Stone Road, and (2) increased seepage due to underflow beneath the proposed new levees. The third management issue relates to the absense of a suitable plan allocating and managing future geotechnical risks associated with the project. A discussion of the basis for my opinions follows. INCREASED FLOOD HAZARD In the past Bethel Island residents could depend on the presence f.: of a large flood basin provided by the interior of the island to absorb floodwaters in case of a break in the existing levee system. The Delta Coves project largely eliminates this {� protection and results in increased flood hazard to the several dozen homes, businesses, public buildings, and their occupants within the mile-long "corridor" between old and new levees along E :. . Stone Road. This adverse impact arises from the project-induced confinement and redirection of floodwaters in the case of a ( failure of the old levee. Such a failure is a realistic E; possibility and could come about in several ways, e.g. through natural deterioration of the levee, construction accident, or earthquake. Consider the latter as an example. The 1980 Jones report concludes that the silty sands beneath this part of Bethel Island "satisfy all the requisite conditions for liquefaction" (p 27) . The preliminary engineering plan for the new levees calls for appropriate measures for stabilizing the ground beneath the proposed new levees. But the liqefiable sands underlie the existing levee as well and are likely to fail during a strong nearby earthquake, say M=6+ on the Greenville-Mt. Diablo fault. Moreover the existing levee embankments have a low factor of safety against slide failures. Either way, there is a significant risk of seismic failure of the existing levees. Liquefaction failures of embankments or their foundations are sudden and would probably involve simultaneous failure of hundreds of feet of levee. If the breach occurred at high tide the failed levee would be subject to a head difference of typically 8 feet (elev. -5 land side, elev. +3 water side) . r, A 1986. 1evee failure at Marysville occurred with a head difference of 12 feet acting across a 20-ft high levee. The breach was only 140 ft. wide but even then had flow rates on the 'F BIMID Comments, page 15 order of 10, 000 cubic feet per. second. Flood damage was k..; Substantial as it was; however, if the waters had been confined by another parallel dike system, similar to the proposed ,Y condition at Bethel Island the rise in flood level would have .':":been much faster and potentially dangerous to life. I believe that with the proposed project a breach of similar magnitude occurring along Stone Road would confine and direct the flood to the area of existing residences. The hazard to life would be particularly serious if the breach happened at night. It follows that this is an impact on public safety attributable to the ,pro]ect. '.' '` '.The impact of such an event can and should be analyzed using '.: :current engineering techniques, including probabilistic seismic `analysis incorporating current information on local seismicity; an embankment seismic stability analysis for the existing levee; dam break evaluation; and flood routing. If this were a dam rather than a levee project, all but the last step would be required by state engineers. Apparently such evaluations have r. '' ', not been made for this project. Levee projects that do not have control structures are not subject to the same review as dams ''•because of a loophole in the regulations, but this does not i` :` relieve other reviewers and parties from responsibility for ' .: insisting that state-of-the-art techniques be used to allow the of the project to be properly understood by the people ' .who will be affected by it. Krone December 28, 1987 and Jones April 14, 1988 letters dismiss the flood hazard on the basis of misleading and -.:. :meaningless. anecdotes and negative evidence. The Jones letter aims to respond to the concern of increased flood hazard arising from earthquake failure of the existing °,­ ­. .... ..levee system, Having earlier concluded that liquefaction of the existing levees is a potential hazard ("from which the Delta Coves project itself can be isolated") , and agreeing that ` .. ... instantaneous failure of the old levee (the normal mode of .:' `: failure in the case of liquefaction) would create a situation in which the "prospects of the residents on Stone Road are dim f: ".;indeed" , the report dismisses the hazard ("very low indeed") only because the failure has not occurred in the past! This is an acceptable method of risk analysis where life and major ; Property damage is at stake. The Krone letter adds the misinformation that "recent studies BIMID Comments, page 16 show that failure of earth structures due to earthquakes is not _ catastrophic. " I believe that this statement is incompetent and irresponsible. The writers of these letters claim that they are "not aware of" such accidents as I have outlined here (other than "lurid descriptions given in novels", according to the Jones letter) . The tone of the letters is contemptuous toward the concerns of Bethel Island residents, which are in fact valid concerns. I believe the letters are inadequate by current standards of risk analysis, which require a balanced and, where possible, quantitative presentation of any changes in the probability of future damage brought about by a project. Such an analysis is standard for any project such as a dam where there are significant safety issues at stake. To my knowledge the. applicant has not produced such an analysis, and the Jones and Krone letters should not be accepted as a substitute for it. INCREASED SEEPAGE PROBLEMS Preliminary plans call for provision of a toe drain to handle seepage beneath the new levee. BIMID will apparently be responsible for maintaining the drain system. Flow rates of 1000 gallons per minute are estimated. Drainage flow rates are estimated by the applicant's consultants on the basis of a single laboratory permeability test and use of the Hazen Empirical Formula (an older "handbook" method) , k: coupled with the unproven assumption that the foundation permeability does not vary significantly with depth, i.e. that there are no significantly more permeable strata within the sands. These methods are highly approximate and generally not acceptable for a case where quantity of seepage may be significant. Not surprisingly the seepage flows estimated by the two techniques differ by a factor of 36 times. The higher value i; is used for the final estimate because it is closer to levee Pump rates observed elsewhere. But considering that the seepage quantities calculated by the two methods differ so greatly there is little assurance that the estimated seepage is accurate by a factor of 2 or even 5. Hence there is no real assurance that the f rate wont be 2000 or 5000 gpm rather than the estimated 1000 gpm. The impact of such flows might well be important. A standard pump test would permit an accurate estimate; this should be required. In addition, if permeability increases with depth then seepage may bypass the shallow drain system proposed BIMID Comments, page 17 i :J' k As an alternative to avoiding participation, BIMID or the county might consider a policy of actively managing the risks. For a project of this complexity and difficulty the latter approach would require a substantial program of quality assurance including independent review of design, construction, and operation. This might involve use of an consulting board, as at the comparable Redwood Shores project built in Redwood City in early 1970s or in stabilization and development in the Palos Verdes peninsula area currently. It would also require a special program of quality control during construction. All of this would require a substantial commitment, which in itself would be a significant impact on the responsible local agencies. The impact of imposing clearly identifiable risks and liabilities on local agencies has not been dealt with to my knowledge. I hope this report will help BIMID in effectively presenting its point of view to the Corps of Engineers, to other responsible agencies, and to the developer. I would be happy to nPet with any of the parties involved to explain any of the :issues raised here. Ve Tr, y Y rs, Richard L. Meehan LZ ' 4: BIMID Comments, page 19 c:T A.TC OF !A FGR! PS�Dli I'mc '-,_-N'c THE RECLAMATION BOARD 1415 9;!l STRFE; IRA,,?,L N 10 551 i 4 n XT STAW.I,\ V- KIR01,49-K. P­,il..:7f J. J. MADIGAN WALLACE McCORAIACK GEOWE W. NTM A. HAROLD J OBANiON MAX S. VANN, TZ DONA& L. WEILER October F , ick- COL. A E. YC3LLi,M. --ro! RXrW Atnel island huninval in�rovekent Distric-C, U. -sox. islanc, Gelifornia hz �entlon: Ers . keud K. Peterson Secretary Wentlemen: Reference is made to your ieLter of SepreoUn inforp� ny this office that the board of Directors of the Bethel islana Y1njclyai improvement District ayprovsd E reavest N; W.r . L. eisenuurg, jr . for the abandonment of a portion of Stone Am! . We are greatly concerned with your . statenent tno- tnis pr. a' included the r6location of the District ' s main WVe , . in accordwace with Section 8710 of the Californis Wooer- CA5 every plan that proposes the alterution or ingroveme7t cy nAy leve� w � tniq Lne ave s of jurisdiction of sc,Kthe Reclanstiu! eqirhe pprovel o ,said asr , srd opco s t,s,,_ h,e �n your ic-tur is definitely wirhin the jurisdictfan of vae �wnrj . Thenefore, it is necessary thot an a;ylicntign for wy�ruvyj oi Mns fon the 0- 10�etion of the M21n levee of . zhe both ! lslunY: Anicipal im,rovement District oe submitted Lo the Rei ciamstion unald ap�_vrecieze knowing the present status of ttis Sincerely urs, Genera l/Anbeer 4�1 Assistant Secretar.-i his : A: cc : M . i . E. Weisenburg, jr . Q . S. Corps of Engineers Department of Water Resources of rHE SFC5 aAa EDMUND G. BROiti'I^J JR, UES BUiL'DING GOVERNOR OF Alf RaSJ1,rcos Board .i BC _ Colorado River Board CALIFORNIA Sz F,tl .: c eco Bc.', %on]nrVulc:i. tl.,. 0 NINTH STREiT r IDBVeI()prlltll 11 i., IIRII SSCI 9561a Solid Yrnnto 61 nn u;;ern tlnl He ur.l ` Suutl L I.J.is b) Q4iJ--JbUU •' '`� Stain Rur.lnrnauun Hon ri 1; I E-on enrvuiwn y� � i-I HnUuo.a, .:nluU..u.•.:'. ;,,, , ;,i 6.,n.,•:. L i ul F. eh end Gump V.� °i ,nl , J tri nrUy kn nli,.ru tl:, •_,: ::uvni: ,,:,.i ,nof Nnvi pu4un and Jnvnl,r L'm uni i:..omixsp . nDOVRIopme"I California Coastal ;�`�: p, , I Purl.w nail Rar.rnnuun 1:., ,il Wninr fl.,...iir..uw Commission. rtment of ForestryTHERESOURCES AGENCY OF CALIFORNIA State Coastal Conser- vancy SACRAh:1E1NTO, CALIFORN4A California Conser- � vation Corps 1� V. f; ' OCT 41977. Colonel Donald M O' Shei District Enqineer Sacramento District U. S . fumy Corps of Engineers 650 Capitol Mall Sacramento, CA 95814 Dear Colonel O ' Shei : The State of California has reviewed your "Draft Environmental Impact Statement , Delta Coves Proposed Subdivision, Permit Application" transmitted by Notice of Intent (SCH 77080255) dated August 7 , 1977, p� and submitted to the Office of Planning and Research (State Clearing- house) in the Governor ' s Office . This review fulfills the requirements under Part II of the U. S. Office of Management and Budget Circular >I A-95 and the National Environmental Policy Act of 1969 . The State ' s review has been coordinated with the Departments of 'i Conservation, Fish and Game , Parks and Recreation, Water Resources , Food and Agriculture , Health, and Transportation; the Fir Resources 'r1 Board , the Solid Waste Management Board , the State Water Resources Il Control Board, the Energy Resources Conservation and Development >I Commission, and the Public Utilities Commission. { Air Quality Concerns �-ie have sone concerns about this project since its design. seems to continue a high dependency upon the automobile for transportation . The location of the project will require residents to travel several gel Donald M: O' Shei age 5 i- E ap-proaches the around water table , a pond site will be prr •%-icied for the containment of water. A well point system f7 .ill be utilized to lower the water table and provide suit- able traction for the machines engaged in the haulout of material . " (Emphasis added) Page 3 , Paragraph 8 "Ac this point in time the water cul-de-sac would be gradually ' filled by siphoning procedures thereb,,,7 eliminating any hydro- static differential_ which could induce water seepage or failure of the Bethel Island Levee. " (Emphasis added) Page 18 , Paragraph 2 "The present Bethel Island levee in several locations does not meet the requirements for a standard project levee . In some places , the levee crown is +8 . 0 feet mean sea level (MSL) or less . In two locations, it is as low as +6 . 9 feet (MSL) . "1; Page 28 , Paragraph 2 " In summary, the island has unique geologic conditions due to: a. A high water table . b. The presence of low bearing strength from compressable muds . C . Loose , water-saturated sands . d. Susceptibility to earth shaking and potential amplification of movement on the surface due to subsurface soil characteristics . " Page 36 , Paragraph 2 "Bethel Island , as compared with other Delta islands , has a sand soil base . The integrity and stabilitCy have not . been pi-oven .. race 37 , Paragraph 1 "Bu.i.ldi-ng a bridge large enough to meet these requirements would necessitate the use of heavy equipment and construction along Stone Road near the proposed entrance channel . Heavy construction in this area could jeopardize the existing peat evee . (Emphasis added) December 29, 1975 Contra Costa County >`is Planning Department Martinez, Gal .fornia 94553 moo got £_O DELTA COVES (Application No. 1832"1'.G.) L.E. :'eL.Qi e1Fburg, Jr. avvyK fi' S:`.`.`' Gentlemen: _ht the regular meeting of theoard of Lirecto;.s of Bethel Island!-='_:.:1 is :..._ Municipal improvement ;;,...;. District, held on �ece��er �I, 1975, the �','••'>'<= ;-,�'.� s:;. '. Board unanimously approved the present plans for Belts Coves, instructing the secretary to advise the planning Department of the hoard'' actioa in this regard. TWA you fay your past considerations. Yours ssiacerely, Gladys C. Brlllon Secretary to the Board of Directors i' Bethel Island Municipal Improvement District 3085 Stone Road PO Box 244 Bethel Island, CA 94511-0244 (925) 684-2210 Fax: (925) 684-0724 Ernail bimid@sbcglobal net Web site www.bimid.com .May 17. 2006 Lisa Kirk PO Box 435 Bethel Island. CA 94511 Re: Public Information Request dated May 8, 2006 Ms Kirk: Item #1 of your request is "final changes of the breach structure You indicated you wanted a copy of the final plans with a signature of a District (Bethel Island Municipal Improvement District:' representative. The District does not have a signed copy of the final changes of the breach structure in its records. Itefti #2 of your request is a pre-construction survey of crest elevations of the District evee a.,.ang Stone Road' The District does not have this survey in its records However. Duc Housing 1;;.35 contracted with "Exponent" to independently perform site'and visual surveys of property iii tre mirnediate vicinity of Delta Coves Item #3 of your request is an 'embankment of seismic stability analysis for the existing Stone Road levee' This information is not currently available and if information is received by the District in the near future, it can be forwarded to you Item #4 of your request is 'an application number for the Delta Coves breach site'. rhe District approved the entire Delta Coves project (Application No 1832-RZ) on December 11, 1975 (Copy of letter to the Contra Costa County Planning Department regarding same is attached' Sincerely, Paul Harper District Manager Bethei Island Municipal Improvement District PI iih Bethel Island Municipal Improvement '(strict 3085 STONE ROAD POST. OFFICE FOX 244 BETHEL ISLAND, CALIFORNIA 94511 (415) 684-2210 June 20 of swpervysor-:� cw� tfa Costa Count:, Kan7Aqz , _.-. - -_. . . _ Deny Supervisors : Ti-' s ? _ r by _.!_ice_ ,__. ._`1_'._ _ _ .. . asked - - T)V District originally supported this jro:ect , but Sin— ._ ,_.,.. r. . Delta - ...� r,.-. , '- - rr - r - - - ond s Ap nelievo that this matter deserves 010 sn �c.Y a�c. 2 on „ ... �- � will '�� 1l 1. Very lruly yours , 1 _ Board of Slrv�nVrl� - -�-... �� �•�,LyL _ C...'% �:x`.4,1 1 The Department of the Army, South Pacific Division, Corps of Engineers , San Francisco, submitted material for the October 1988 :l: .. Congressional Subcommittee hearing record. The Corps ' statement Y was made b Brigadier General John F . Sobke, South Pacific Divi- .. ;.ri. . Sion Commander . His concluding statement included the following : XT will continue to monitor relative sea level rise on the coastal environment . In doing so, the environmental impact as- gessment process will continue as an integral part of project G - .feasibility studies . Also, regional geology will be careful '_ ) considered along with the historical records of relative sea ,`;� ..' level rise . Where warranted and economically feasible , our pro- . .` . posals will include sufficient flexibility to accommodate future change. In light of the foregoing, the Corps ' decision-makers must take a hard look at the proposed Delta Coves project which lacks .mitigations to accommodate future changes in sea levels . z Grading: The conditions of a ,;t.. pproval for Contra Costa County state (#15) "Grading permits shall be required for each phase . All ` grading and earthwork plans , whether temporary or permanent changes , shall be reviewed and approved by the County Community Development Department prior to issuance of a permit . " The Coun- `;: . . ty' s own ordinances specifically prohibit issuance of permit for levee grading without prior approval from the agency responsib'• e . : for maintenance of the levee . C . C.C. ' s Ordinance Division 716 - `. Grading, Section 2 . 608 , "Prohibited action -- Levee work . No person shall excavate, or remove any. material from any levee or i.. . do any work on levees required for river or local drainage con- trol without prior approval of the local governmental agency responsible for the maintenance of the levee. " Contra Costa k., County does .not have the sole authority to grant levee grading Permits . In the case of Delta Coves , the first permitting agency is the Bethel Island Municipal Improvement District . Drainage : No provisions. have been made for new drainage courses to replace those removed if the proposed project is built . In 1983 , ' the Contra Costa County conditions of approval for the project acknowledged this g problem, however the final conditions approved ` t.. BIMID Comments, Page 8 � � � i:• i 716-2.425 Z ZO i � Ina :',;,;;,•, 716-2.428 Natural grade. 716-2.604 Prohibited action—Gradi �_ "Natural rade"is the vertical location of the ground No person shall grade,whether or not a unit !.; i surface prior to any excavation or fill. (Ord. 69-59 § 1, quired therefor under this division,so that dirt;soi)ltr'1:x i 1969). debris,or other material washed,eroded,or mo'ed fi ;; the property by natural or artificial means.cresite3".1'*' i! 716-2.430 Quarry. public nuisance or hazard,or an unlawful encroac :.; "Quarry" means any premises or site from which on other property or on a public road or street:Auy,tii i ; rock,sand,gravel,stone,earth soil or mineral is removed matter deposited within the right-of-way of apubli 4 :" or excavated for immediate or delayed disposition away or street which may constitute a nuisance or.hazard b. from the premises,except: public traffic shall be removed immediately;and,fyil!lt¢ . (1) Excavation which is necessary for the devel- to do so on notice from the county,authorizes theCotll opment of a lot or parcel,if permits for construction have to have the matter removed at the expense.of:lhet0i'`. been issued pursuant to this division, and if the s onsible party and/or permit holder.(Ord. development conforms to the provisions of Title 9; 1969). (2) Excavation which is necessary to bring the contour of the land,within a subdivision for which a map 716-2.606 Prohibited action—Water has been recorded, to the grades shown on a land obstruction. development plan for subdivision,which subdivision has No person shall obstruct,impede or interfete'wllh'1 been approved as a part of the grading permit authorizing natural flow of storm waters, whether unconfine 'ypd$ the excavation. Ord.69-59 § 1, 1969 . the surface of the land,within land de ressions f drainage ways, within unimproved chain' 716-2.432 Rough grade. . watercourses, or within improved ditches;.chameltE�; "Rough grade"is the elevation of the ground surface conduits,except for construction operations pelted :, established by grading that approximates the final the.county. (Ord.69-59 § 1, 1969). elevation shown on the approved design.(Ord.69-59§ 1, F 1969). ff 716-2.608 1 Prohibited action--Levee wotii;' NoerseW shall excavate, or remove an P� Y: 716-2.434 Site. from any levee or do any work on levees requiied` 4. "Site"is any area,lot or parcel of land or contiguous river or local drainage control without prior approvllN combination thereof, under the same ownership, where. the local governmental agency responsible fot':1 grading or development is proposed orper-formed.(Ord. maintenance of the levee. (Ord.69-59§1,1969 -Ar 69-59 § 19 1969). 716-2.610 Prohibited action--Co i .A .. 716-2,436 Soil engineer. public rights-of-way.* "Soil engineer"is a civil engineer who is experienced No person shall perform any work or Constii><'t f in soil mechanics, who investigates and reports on the facility(including excavation or embankment;treoi stability of existing or proposed slopes,who controls the driveway construction, or drainage facility)ivithi>; ;�:. i ' .. I.: ! installation and compaction of fills, who recommends right-of-way of a public road or street, Or VA soil bearing values,and who provides design criteria and easement under the jurisdiction of this county;IMI! ut calculations for special earth structures such as buttress permit from the county agency having jurisdiction:(OIdS fills.(Ord.69-59§ 1, 1969). 69-59§ 1, 1969). kI y' Article 716-2.6.Prohibited Actions * For encroachments of public rights-of-way,see Div:.1Q01 U) code. W Z. 716-2.602 Prohibited action—Work without 5 ermit Article 716-2.8.Administration. P +1 !. Q i No person shall perform any work within the scope of f '#xis. Qe this division without first having obtained a permit from 716-2.802 Administration—Authority. . '; The building inspection department shall building inspection department Pursuant to this atimia ',; division. (Ord. 69-59 § 1, 1969). this division. (Ord.69-59§ 1, 1969). , ' * For building inspection department,see Ch.72.2, 7 t'''1. i >a 366 ` 'R! I W Y M .,v (Revised September 15, 1988. (Revised July 20, 1989.) :)rdinarce Of LK BETHEL QLAND YUKIMPM, 1KPP0VnMKT P1 9TR T CT Pega Q E ing Ac i i v i L 1 es a nd Cons C_ 1_'r 1 oA Up ik, ?P : a� i r. Over An Di sz r A 1- is Le- ;eE. S'ys-, em he it Onjained by Llie Maid �;f Direllors �t 7rY MTKK;__ PAL TMPROVEMENT DISTPVT as fn! Ws : I . !-- Purpose and FindOgs (a) Bethel -slant _-.'-s s',--r-ro'uncied by the waters -.-,i-_e 3c'r Joaquin-Sacramento River Delta, and is prnrecn-�-�d from Ov che levee system operwed and noinzained by BIMID. The integr1r..i A tno javees, and BIMID ' s ability La inspect, M00LDr, Mairrain, repair, and rehatilitate tl:em is essenlial W t K�-. heaM, safeEy and welrare of the residenEs of Bethel lsiaLd, anci; is nathorized by section 96 of [he BT ,':ID J_).', _-:r0pe_r mainueriancc.L and operaT_-...ori tne '; e-,,reE: Tequires a program of continuouc s inspeticri and rEqWY tb' EANQ and iis agents and employees, as well as r", We i�iv�n47nd oil,:,' 'cut-.l Lc. RAID receives financial WsIsCancl for loyno 10�011 --- Wton spa vaintenance trom MG State of Califocnin Code sec7LG2 12980 ek seq. and onnwn laws . Sn�h ±Tf : �Lonod par= of BIMID' s budgeL, siuhouL whiah RIVP tm be ON Lo MaKLain As Avees in &Eir aoifent =mLion . (d) Part of rhe levee rekabiliZdLiul Carriet C� ty B ! 147 �: Liicjudes raising the levees zo the height ! : D . 2 ' USGS) reccmmendel W srare and federai agencies, ar the slopes ( 3 : 1 lanaside; 2 : L by Ehose agencies . also wnchslonally Z-e(.IL-' LeS --isaster assiszance from Ll_\ rederal governmenu, in order to pay for levee repa±rs . Ordinance is innended to safeguard 1IMID' s abMuv, 7n prore v ins levees, and thereby _.Cie healih and SafeLV A vim, residepns of Berhel island, wid to enshrc III t a Bache! RAW corf._=ns uc s-c-ate and federal s7and ards for FTocw- � Icln of levens and in, f_' C' _.'C sv3A1M ! ] ±cy wT aucivreedeo suana anj Eadets! YiqaP& n ! jesLj(n, j , 2- - Finding Regarding Levee 2nke snA --aised Q adding MaLYKa� Y :� M�11 1 K 4 YJ szope . T�nrefore, as levAs a---e !J axtocn furEher Lowaros the inreri& of Bad:­_l .7 :7,- tance to which the landward slope of any givem par _ of rne Ail exwnd as a result of being raised to 10 . . " USGS denends ol: iis existing Wight and slope, as well ---as ',A-_.e surface of BeEhel Island in Ehe area Cr chat par E A &e levee . Ebr zhds reason A it impossible zo de-tirie a spe(_'-iric, infl-L�:,,iLle etback ihab wili adequately pr,otect BIMID' s c sompelling iAreresr_c_� ir levee mainnenance and rehabilitation, wjrhouL unfairly tzrdenln;j some landowners .This Ordinance cherefore sers forrh a sewnc-_ i cr wi 1 1 be subjec7 ro modif 1canion on a case by case tnn!5, I SM nq­ at uempOng w camh A sh, Val I �ish, or Othar auuavic aninlais Q use of a rMe, live, q�[, IMP— to esunNish 01 PVCh, or nVOMPO no eHLanl3sh resKn at otkarwise in any canp, Lent cr temporafy Shelter . Boaz— My vessel for Eransport Vy water regafaless V 5 A Z Q� ase, or met't-,:."rJ of M M An' , horses, cal tin, sneep, goats, ps, an anHOAS, exceptj �; honsehold po�g, A Mer- The leual owner, equirsci, o�pn � , �rn Firearms— pav/ handgun, s h a 0 an 1GAI USGS elavatinp-- �M r- ! �7 "7 line ezvennen pErpendscalm 2c: cne ievee nowinas wo rv��w : MOO island, at a slope or 2 : 1 , frcm M upqeuvnn� pnMn waterside slope of Che exiscinq levee, reaches an eLevon - � Z2 Van, accirding tc USGS dara : Phu rOMWng a7mvinies on, cver cc trum ME levee cc lwv&L zw�v ary ;Twhibited, except as perminen Oy BIM:D Or mad a3�:Sa wars�SP7 to section 8 nerect . in ) leaving, placing , mairtalniw, ridi�q, Klvl �q CoUroti.ng .�.Ilv stock; �'il 1__.-a 17113 a Vj Lawnchipg aAy boat, eXCEF7 fro� 0 A"P��t �q ! �� p other faci!icy regul ar i y Nc ! KY. . s� ; Q ) Driving, paf A ng, or operauinc onv ven 1 �T� ,n ­��i� ;An-z kirid crKer than official ennrgepn VVKI�IAV ;y kriviKq, apera7lng or parking any n --�Vlrq cocys or o r n e r w i c G cad ing , exy Va;yg 1 1 eve j 2 raisinq, Watling, JiggIng, C emv�! 4 -- prunitiVed Objears, Things Q : WAS, VelenDnieR, 3ad Vehicle-i 51in ne a ACIStion of this DIOIKOin� 7, OMSKY��I' Inaw, "�Vcn, Kare, maintain, Pdann OY park, �nv 0 � F03 1 i_-.,ver the �vvee, 1&vee zone, or proiecW Ac "All i Any building cr major struin"i o �O.ec " Ke� YsPA Y; i!.,Lmuter, pipe, pipeiine 4naiaQina lines, or sJun-L-lar iPOCes fOL the C,.--)I i 1 ic herewi tri Sectiln K - Enforcemenn, Pubfic Nuisance, Coscs , an:-i P e na-1 t i e S (a) All -v-,-' olat ions of this Ordinance awe decla,--e.,:a' �_C? b((, 3 pub! i c raiisance, and may be summarily abated by the Leis crici: pursuant co Government Code sections 38170 thr!)Ugh 38790, Ur remedied pursuant co Civil Code sections 3490 througn 3495. b) Vin ac.-?or, Z.c enforce this Ordinance, in whin, the Discrict is the prevaKing party, it shall recover izs Costs, wnich shall become a lien upon the property where the viclanion occurred. (c) Any owner or other person commicring any acc erumeraEs-J in section 3 or undertaking any consrrucEion enumera:ed in sec- cion I without or in excess Of a permit, shail snop such yc�k )istrLU an Ion C"afr�/ CoUt any corrective work ordered b. LAhie i represencative immediately upon vwriMen �Dkificazion by Lr:e Discrict or any representative thereof chat he or she A (d) When iLhe District s?-m-,minarily abates C.,rdi- r�ance more than seventy-Liv.o (72) hours after notik::e t.,, mail, by publication (in accoMance wic'n Gover.-mienz Code sec�,ion 6U6_,., pursuant to section 11 (c) of , this Ordinance, such sugmary a:: s neaten stall be az the cost and expense of the ow-ner, and shall be a lier, 'L,-i-pon upcn i.-Jrich te viciation, (e) Pursuant to Section 96 of Chapter 22 of Srac&as of 1960, any viqlaLion of Ms Ordinance consticutes an infraction. As such, - I -e I I -: violc4c.ioiis oC this ChAinance ai ymmishab-' e. b:y 1 a. fi :,.,e exceeding one hundred dollars ($100. 00) for a first violation; a fine r.cc two l-,"u-1-dred do _Lars ($200.00) Lor .a second vbjIaLi,::)n 1--ii.thin one year; and a fine !-,or e.xceed'Ing five hundred dollars (Y500 . 00) f o r e ac r. a a d a L. -,-o r!a-, -v :L 0 'L 5 E 1 C F.- wichin the. same year. Each tea`, for which 3 J sepnLace v_iblacion. W The remedies and penalties proMded by this Ordinance an,�- cumulative co each other and to che remedies aid pon& nes Section 12-- Amendment and Adoption -` .'1E_ b c.)a r d from z_,,Trie t .r. Lima establish nenva .], MaHdauds and guidelines for its implementation, which snall W, nondinions to the issuance of any permiu . The board may from :!.me co cime in its discretUn adopt a standardapplicarAn form or forms, for use in administration of the permit procedwre pro- vided herein . This Ordinance, any general standards ancz guide- lines, and any standard permit application forms adopted by tM% board shall be Mifable to the public at the District offices,- (b) This Ordinance and any amendrents to it , and aw penerm sEaNdards and guidelines for AS implementation, shail posted --I e ',%, he Ai=st..-cjt-:c 0 1 eek in three public places in take effect upon expi,acion of fifteen days ca" s= posLAg . A subsecuenc finding of p board, entered in its s, i.h,-. C. posting , has been made is conciusive evidence chac Ae posArc ha: - �40mer?ts of ;ra:. , ,r er', r G'... _ Love FII! and Mass Grading r' f T.-1e e 0 F;S �' ,!!c des; ;ners for :he p.,o;ec; ncri,de recc)n;rl:rr'Icf.,t cf, t :poi.: [ a reino`✓ed ;iGlow the tootprin: cd ieV(-';'._.'. Sar1C7 ::'i!l tnC'n De Dla�t:!.! anC (?;._,,. Ih(' I"rFl 1:�.Ie F'.avt nd C.:!(JlriC'.lJ ;)r e?: coris f C, 7.asba ]•r 2. Liquefaction Lle.siylnE::`: :,aye evaluated the potential for liquetanon ana neve onif ie:ic:u.ii;rl .: �:atlOii cif areas ';'!th tf,e potent!ai for liquefaction. l.''`e have re.1�vlell P-ie Ia;, fv: rerr',ed!ali-,n. Fhe rpmedlallon Alan Includes removal ano cornpact!C;r-I of 6!i,iilov' sarid deposits. For the thicker deposits, the plan, is to 'Jse diver, i ;n a rn I;: -om L. iiC!: DD' ` ! e :cep: vithlr. 20. feet Oi eXlsuric residences. Within the 2rJ(.' fee: z o r i t sis"', e C if.:!::' ._. rc.p anne(�. VV''e cencluce that the remediation plan is a reasonacle C t f ar-,Ll redJce the fist; of carriage to the Ie.VEeS dfid IrTlpro`;C !rlc".!`: JII. t; . ,.. cK;.-)Q. Tspecifications on DDS, and stone columns have not bec-rl rt':`.'Iced. a' lr:c- ,'Jrl?rac;or A,i.I provide the specifications and constiuct!on sell.:i::!I; ;"i:_:: ..'I 'I'.' .... L:' :;I--io of the stork columns. The contractor should provide the iniorm ar,c'f: ;,, : le " ,_. i ol_,r !e'✓ie`,N prior to proceeding. aiid other construction aclivities v,.ill cause ground vibration. Vvu •Jnoer,ianc' t'f ai ir:!- "'faUiv' `+rill mc'r,3F -vibration during constructlo�,. he ConlraClO' a'�G IJrI iC• rCriur'l' u . :jt exisii g cof.,ditions on adjacent properies prior to construction. i ht� preconstrL:l; psi: !I ;+� s.nouid Inclr,dr� documenting the cr-est elevations of the B!MID 'e',ee along `-:tCirlE ;c. oulc! case some settiemer o` lite e:is:inq evee. Tne conn-ractor s c)L,ic sot=:,,!:_G— :iC;c: fllCinrlof'rlg Jlaf� tC tfle OUntY and for cur re:'le`:' before start:m,, '`)DC-. 3. Slurry Wal! and Dewatering r: :Ie': IS ll- Cilcn;l i:_, :3Itef The i2-ccentia! IIIIPci :! of `uepage Is consideraE,!`j greate, u,i i; fC,7 _I..Jrlr ns."Jct:c-, tr,c _ )rlt,aclo pial , to lo'::E r gr 'u' :;l•:c:..: � _... .: . rernod a 'ci burro:•: rTlater!a: and Ir1S121 ailUrl iif ut!litiet(r.i ;'1':: :-:':isi: the Gr'o(!nd`::ater levels beneath the property :":Iii be raise l :e-1 :eve!s Feat and ;•trier marsh deposits Jnderlle some of uI' ai d ic,. +tri; )rl II r,a pea' Is hlghi) conlprrasslble and lowering the gFOUnd`:;aler below., aiu::t n! 'Pr:); J. ];;e t.1-le stress in the peat aric cause grounc se'.l!eme, .. and oil grate. Obviously; this Is uildaslrable. C. CC:: `:.ill curlst'uct a siurf, ,:'alb is a depth The ,-, r-r r 1 r i dl aoout -+� IEf:I. .1_ ''.1t_ f tl::: II iviII be Constructed by slurry Irenctl (Tletnods. I; 'L:+lli e.,�,Iencl tr I gri trlE'.U(IUcrl}' ii: atlur't_r ttlat starts at exlStlrlg grade and penetrates Into arl l !' Icy ta`r'e r Ti;' i?i mon OC tnC SiUr"� '✓VGII `,n•'ll be COn5IrllCtC'd V':Itr': IOv:' pert Tl Evabinij• „OII"1 ri Fj CCE'l. III' = uli `,i%ry s.:wo funCtlorls. Uurirlq site grading the s!urn:" v:a; .:i ;�Il",•., :] ,:st ,i 1' ail;, Iiilt;fi(Df .:Itti(:l:l iC.:il?i'I(I�' -�roL:rldl':titer levels or. till; U[�jjC;J'tC '�Illt;' ;Jl .'Ifs ..=;i: HULTGP.EN-TILLIS ENG PAGE 05/02/2006 15:44 9256856768 • . , , . .. '� •-A•Co�fc�riila.`CorPn�dfldn: •. 5peclalbJng In Gd6techn1cal•Eng1n•3ering ;fir t! • '�� �. �" May 2, 2006 Project 156.10 BIMI® Bethel Island Municipal Improvement District MAY — 2 2006 P.O:'Box 244 Bethel Island, California 94511 Attention: Mr. Paul Harper 'SheetPiles for Seepage 4472 Stone Road . Existing Levee Bethel Island, Callfornia Dear Mr. Harper: This letter presents our recommendation for installing interlocking steel sheetpiles for seepage control at 4472 Stone Road on Bethel Island, California.. This letter is a follow-up to our letter dated May 1, 2006. The purpose'of the letter is to provide design details and recommendations for installation of the sheetpiles. We recommend that sheetpiies be driven Into the existing levee crest and extend to at least 26 feet'below the levee crest The top of sheetpiles should extend below the levee crest. The top of the sheetpile should be at or above Elevation 8 feet (1 foot above the 100-year flood), nominally 2 feet below the existing crest top. A 2-to 3-feet deep trench should be excavated into the levee at to facilitate installation of the sheetpiles. The viall should be installed in the levee crest, within 5 feet of the slough-side hinge point. The sheetpile wall should extend 20 feet beyond the projected edges of the existing retalning walls and the point sources of seepage. The nominal length of the wall is 90 feet. The sheetpiles should be Larssen 600 or equivalent. The sheetpiles shall have a section modulus of at least 9.5 cubic inches per foot of sheetpile and a minimum wall thickness of 318- Inch. The intent of the sheetpiles Is to cut off flow of water of 4472 Stone Road and stop the movement of sand. The extent of the sheetpiles is based on our-Judgement and the general belief that water Is flowing directly across the levee from the slough. Additional sheetpiles may be. needed If the Initial sheetpiles do not effectively stop the movement of fines. The bid should include a provision for installing additional sheetpiles beyond the 90 feet limit. The installation of the sheetpiles may lower the water level within the levee and existing . properties. The reduction in water levels will increase the effective lrveight of the peat and cause the peat to consolidate. Some settlement.of the downslope properties may occur due to the installation of the sheetpiles. 2221 Commerce Avenue,Sulte A-1 • Concord, California 94520-4987 Phone(925)685-6300 Fay.(925) 685-67,38 STATEMENT OF FINDINGS AND OVERRIDING CONSIDERATIONS FOR THE CYPRESS LAKES & COUNTRY CLUB PROJECT ADOPTED BY CONTRA COSTA COUNTY BOARD OF SUPERVISORS JUNE 81 1993. � J c_ approved by Contra Costa County prior to the .issuance of building permits . Facts : The liquefaction potential of the .project site was thoroughly assessed by Kleinfelder, Inc. , based on soil borings and other tests conducted for the geotechnical analyses . (This issue was discussed previously with respect to Mitigation Measure 3 . 7-8 . ) These assessments analyzed techniques to minimize. liquefaction. Such techniques include removal of the liquefiable material and recompacting it by conventional means, deep dynamic compaction, vibrocompaction and vibroreplacement, soil mixing, pile foundations and slurry wall cutoff and permanent site dewatering. Due to the public' s concern on the use of the deep dynamic coma action meth=, this mettiocl `s all not i iga ion Measure 3 . 8-1 is modifte o reflect this change and Mitigation Measure 3 . 8-2 shall not be adopted. As briefly mentioned above, other techn.iq..aes have been thoroughly analyzed by Kleinfelder , Inca to nait.igate. liquefaction . Prior to the building of any structure or facility , a site specific analysis will be conducted to determine the use of the appropriate liquefaction method. Mitigation. Measure 3 . 8-5 is modified to be mandatory as opposed to optional . Findings : The Board of Supervisors rejects Mitigation Measure 3 . 8-2 for the reasons stated above . The Board of Supervisors adopts Mitigation Measures 3 . 8-1 and 3 . 8-5 as modified , and 3 . 8-8 . The Board of Supervisors finds that the project plans (which include Measures 3 . 8-1 as modified) , in addition 'to the adopted Measures and conditions of approval , will mitigate the project' s potential impacts on liquefaction to a level of insignificance . 2 . Impact.: Construction of the project will result in significant grading for the homes, golf course, lakes and otiaer- facilities . These activities will expose soils to wind erosion . rhe- site is located in an area of strong winds , which r.i :, in a significant loss of soil . Mitigation: The project plans include this followinc3 e-ruls Lun control measures to address this impact : • 3 . 8-4a . Existing vegetated areas sl}e-u-fdl--shall be left undisturbed until construction is actually ready to commence . b. A1.1 disturbed areas should shall be protected from both wind and water erosion upon the completion of grading activities . C . Runoff she id=s b. 1a be directed away from all areas disturbed by construction , if practical . d . Temporary check dams , sediment f:,onds, 0C siltation . basins s1r�3t-1-6--sball be uscad to traE 35 i' DEEP DYNAMIC COMPACJ ION FIELD TRIAL. DELTA COVES GATEWAY ROAD CONTRA COSTA COUNTY, C.AI_tEORNIA 1-OR Dt_ICHOUSING PARTNEI:S, INC. March 1,2004 BGC BERLOGAR GEOTECHNICAL CONSULTANTS �1r Si:-% Spence 110LIS1rlg Partners, Inc. 111, Winchester Boulevard, Suite 11 I.os Gatos, California 9503? Subject: Deep Dynamic Compaction field 'hrial Delta Coves Gateway Road Contra Costal County, California Dcar Mr. Spence: ']'his report presents the result, of our observation and testint, during f luld trail of'dcc1) dymilllic compaction (DDC) at 11o Delta Coves project on Bethel Island in Conti-1-1 COSLz, Cuunt� California.. The fieftrai was performed at two locations 1. \IZI:.� I and .ARI1 21 as hOW11 on Plate: I (Vicinity Map). and Plates 2 and i (.Site Plan). Densification, Inc. \\as the deep d\rlanllc compaction contractor. The deep dynamic compaction was generally conducted by dropping a 9-ton block at a height of' about >U Deet at square spicing of about I ) feet. Each impact point received > drops and t',vo passes were applied at each treated area. The first and second passes were separated by a ��aiting. pel'lod of ahciut 3 d111'S. as sho��ll on Plate 4; the impact holI1IS for the hist and second passes kwere off set M• about S-Ih feet diagonally. The organic soils and/or peat were not removed prior to compaction. The craters created by the drops were generally backfilled with louse sails. The contractor also measured the ground vibration and the results are presented on Plate �. fo study the effectiveness of the (deep dynamic compaction. three boring-s II,,\o in :\I- a 1 and otic In .`ilea ?) wele drilled within the treated areas tlsink a track-mounted drill riL� %\III 1A.,h equipment about three to four weeks atter the second pass (A'conlpacti<)n �tand,.ud pcn;:tralu ti tests .were perfOrnied and soil samples were taken for m(.)11 tWre content. dr\ derlsit\ and passfflLl ��flt.l ;leve tests at each horim, at a vertical interval of ahout , fc.et. Hit: daiC� .d CoInpLILt1 111 :ald borin�� are listed on Plate 6. The boring logs showing the blow cOunts. soil CLISsilicalloll. moisture content and dry density are shown on Plates 7 through 10. A Kc� to Borin_­ Lu, Svmbols is included on Plate I I. The results of the passing 4r.'200 sI'C%'e tests arC sLill lrnarli/c d on Plate 12. The hammer energy was measured to be about 7? percent of� free fall. The calculated pic-DDC and post-DDC values are fgraphicaliv depicted on Plates { ; and 14. .... .As shown or, Platcs I ; and 14, we conclude that DDC.' usin" a e)-ton hlocl< .with aAli-ii)i)t drop can generally remedy the liquefiable sod condition to a depth of' about 1.i ti) 15 feet bc1cm the 1 existing ground surface. The Lipper about 4 feet of the soils relllain relall%el loose :old require PERMT PdUMIBER R LEE FGF'. C',L:F��i c ?:, ';OU ,T THL ;TAMPING i ',,tSS (LAN ANL TO F=F.V:i OR TO EF" �DVA:GF TFE aA'y v)C�KT'�OR�i}ik}— t3tJt L.tplhl Ce�f!`,i?E';'TIJN kosf,7 OL-,f� it to the inspa,-Lor at ail tv:ies l 4 p Mav 27, 2003 V. .fc.lh W O-i , l!.Ill ('-tp N i `lind should 11: llc;lt:d 10 Ila\c tl mil1111111111 (�' 1 ),:,,C� of lo. PIC 01 !hC r�" null:nd d r:nit=diatiun arras are shown oil Plate 5. O11enabicAl wondldon can gellc'1'all\ he lemic limed by rei110\cel of'Ll1C ICllll.;\ :l`, ioo, .: �,Illd _Ill,: hl:!CCnlc!1', v,Itli :n'_incel_ed Illi. 'Ibis uplloll is more apprclpi—ime in al'Cas \\here Itow wnd is !+.aic:d I1C,11' Lhl : \I�[IIl'_' �211VLlild SL1ri`Lice and Illi' ground \\';llcr is i-C L!ll`.'el\ deep. '�izulliIIC:wl 11111 hC C:CILIIr a lli I1ru\'li;{C it rCl;.11t\:f\ al'\ C i.)Ill{1LI11!1 (l l"Iii 1^C anCl O\cl'C\ l\;Ill .ill ad pi,icC111_ 1 .''! 1111. Ground ,\.,iter >IIOLIW be lowered lei ill lc;l.>l _ !i� lcct !:I(,\\ the i1,�ll:.�!li ��ltll';��\`CI'C\C�t\Alli:I1. :X11:1"Il:l!I\'Cl\, (1"ill;li: t'�'lilC�lll?Il:ill!'ll`�lll�:'Ci'll?'� i;llllillll�!I11. i;lll�iif. 11`. Is 11-trc:IICil ,AI-till: i;111d1 rune\' b: l.sccl to hdCkfIII the 0VCreXCa\;pilin. 1110 U. ;iII ( Cc11-1C211t. Ash lrcal_._1 i',IC:I'A-dl Call lcs�.Crl LI-lc dcilland oI deep CIc"vint-in`! aili_I Ina\ all,!\\ unkIcr\\',ilei' plac.IllC!'! 01 c:ll"ICIiL l;'', hacks-ill li\ "tvernit�" incl od. .\dditiol"l'il shill''• Llli,.l II,:ICI �:ial :t!-- Ilce:l:t1 pri\'l to til: use C1( .,.,hent Ov add-lr:it ed back All in farm scab-' titI'LlctUreS arc berated 1111le than 110 li ,011 IC'CI ;I\\.I'. . I::i ! .I'. i:;llil:'_ Il?1' :clitil . 1)I 11. I Call ,ilC LItiC d It, _Icll.ill\ loosC sand Ill-place. i.)cup ,.I` li;lnd .: .yip l! m .'il I , _ li\11 :1 h":�I`.`. .itCCI or C: 111CI'clC 111010:1`, illi We `rCamd surkwc at a Ile i1C1`'llL ()l 111' C.11'011 is a 1Llllcllon of tht: \\'C:i`_'lll i�I' [11�- hk,cl. ;lilt! 'It:I?il: i�, tilt i.lt'_ Iwl!:!I;lf?le {":'il[l!_' ;l 2I-1-Bill {1lt,K ClI"c)I) IlelLllts o F aNall A l,' t,!...I lCc1 Ili;;\ fir;' Cl\ trc;o licluehilble stills Ii) depths of allllllt 10 L•,:1 15 I:Ct. I I-OLMill i1! ciilT;l?'.I ll.:';1 .lI'C l\hical appllCd. I_aCh rOUIld of i_C)nitlaC: on is sepanakwd h\ a \\a:l!n'_ pCri,nl iii ;:ill'.'\\ PO: \\;I!cl 111-Z�UrC L!CllerLllcLl J111-illi-, comp l�!Ij ill to dissipatt• ! riiir 1'., ill: 1111: lie tIioll i?I ill".I lOund Of 11i11:iC1!011i LO II1CI-CaSC LhC ClteCtl\':Il:ti; of Jcep CIN mimic ctimpacuon. I he hdocl•: 011:_11 ;ll iii creme:' I'cl;.ltl` A, ll' ' 1 i C c'raICIS LIt impact pmts and SI`?Ililicarlll\' Lhwurll the upper about 4 to l ail the ;; els. l ile critters are to he filled with loose soils and the entire: treated area \\ill h.: icoiled the block from lower heiLdit-s. AItCI'ilall\'Cl\. tll: CraL'el' aIle{ diSltlrh:d ;(-Ii! col-ldhi\in can hi• renlediaLed bw removal of the upper 4 to 5 feet of tile stills and play:cnl' at ,'! Cn`'inCCrca till COII\'CllnolliI Carthlllil\', equIpnlenl and corllpactors. i i:id trial sll,iuld bC Carl-Od om t0 deur!ilintl Lhe optirriunl lirelp hCighm. Ic' ah ul \\aitir:y fieri wl mid t:oIllpat.tlkill ;11aC1i1'_'. hiput. {rom the speckly (DDC)contractor should be c:onsidcrcd i\i !':?;11!,'.c life "dell (_il'1.)llnd 1 Ihi-Mi Irl Should also be nlorllimed during Ad tl'lal and priiductlon ciirnpai 110;11 w i-,duce tilt risk 11I darlla`ing Lhc c`:1SLIng SIrLIClllres locate.,{ in the \`ICIillt\ of tile nvatlnam arc:l . lel \\h:!: shcl{I(,\\ -,ri.lulIJ. \\atcr condition exits. partial dewatering of the treatm:nt area `.\ill h�' required to provide a ;table \working plaffornl and increase the effectiveness ol' deep c{\namnc CC)Inpaction h.c!6vt;N W soil,. such as the omarlic soils or heat Ioi:m& "Am the trcat!1 em mm" should he i' ',IlU\ed prior it) Cleep d\'nand., Compaction. REOG,\R GEOTECHWAL ( N91 it TA wyc BUilding Inspection Contra Departrnent Costa 1.J m n s t ra t --j n B 1i;i d inq County P1 a.-i i n e-7. C I i i u i r)i a 91555 12, 5 FA X 2 754 6 .]Line 7. 2004 I-Asa Kirk and Robert Bovter 116() Chess Drive, Ste 12 Foster City, CA 94404 Subject: Delta Coves Project Dear Ms. Kirk and Mr. BoNqer: This letter is in response to your meeting with Supervisor Federal Glover regarding the Delta Coves Project. The Building Inspection Department would like to clarify fbr the record that the Deep Dynamic Compaction DDII) . method was not authorized at the discretion of the Community Development Department Director. The method of DDP is an accepted industry process that is applied in a variety of cases. While there may be other alternatives. they may also cause additional costs and problerils. One such alternative could be the removal of all soil 10 I This would require leet below grade level and replaced with new imported soil. I ire a monumental efli-)rl in hauling off all existing dirt and bringing new soil to the site, not to mention the compaction that would be needed f0r future building 101S. We have no knowledge that the DDP beim; used at C%-press Lakes has had problems. In 11WI, It is our understanding that the process has been successful. We have recently requested that the developer furnish documentation on the process and we NN 111.1)e revie.\N im,, these doCUrnenis \:ci-\: shortly. Also_ it is our understanding that the DDP will probably last another lour to live mollifis 01 Lit the Delta Coves Project. The statement that the developer has seven years is a reference to the project time lines not the DDP process. If' you should have any question oil the DD.P, please feel free to contact Kevin DumCord, Supervisor Inspection Services at 92-5-335-1158. -58. Sincerely, Carlos Baltodano Director p, Board Members of die Board Kevin Durnford.Sllpel%:15or Inspection Semtxs Car\ Fana,Senior Grading Inspector STAFF RESPONSES "I'O CITIZEN CONCERNS REGARDING; THE DE-LTA C 'OVL- Pl:t..:UI--'.'G BETHEL ISLAND July 1 , 2004 Purpose 1\'e understand that you have expressed concerns about development activity and procedures. At the request of Supervisor Federal D. Glover, the Community Development Department staff has prepared this report to try to summarize concerns about planning agenc} procedures, and to address the concerns raised by the community. Background The Delta Coves project is a planned unit development that was approved i-)\ a j ud-mew made in the United States District Court in 1989. The judgment overturned the Board of SuperVlsors decision to require additional environmental review for the project and approv l-d the project as proposed. As part of the judgment, the County was barren from requiring additional conditions of approval and/or fees, except for the fees specified in the conditions of approval. The Delta Coves project consists of a 495 single family residences, a 65 unit condominlUill complex, planned unit, water-oriented, project %vith numerous commercial areas on a OU- acre parcel located north of Stone Road and east of Bethel Island Road. The project incluil-s flue construction of fill-er levees and lagoon, which mill require breaclliilgof the existUhl, Island levee. Summary ol*Citizen Concerns 1. Citizen Concern- There is c•cnacern that the pr(.)jCC1 '.s UAL 01 117C ILVIZI7i(llle Di-namic Compaction (DD ) nI(Ilhave adverse impOc is (-li lsilan l orof-Ici lrL'S. Staff Response- The Court decision allowed the project to proceed as shop\n on the numerous exhibits that were referenced in the judgment. One of tile exhibits (Exhibit "B" Tentative Map and Grading Plan) identified the proposed gradiil`1 that will take place for the project. The proposed grading is based on recommendations contained in a geotechnical report prepared by,geotechnical professionals. The techniques for grading the site were not specified in the Colirl decision or on the approved grading plan and are left to the discretlon of the developer consistent xvith the requirements of the �Iradim-, ordinance. EZ-i _17110 COLIFt decision did ]lot CIIII)ONVCI' UIC County lu detcrmffl:.: % 11,11 ICCIIIII�.ILJC [h" dC\.eIOPtI_ could be employ in completing the project F11C.CL)Lill t" 's role IS Iar,_,cly Hnifled to deterrnlmin(.�, whether the. subdivision developer has In1­1 the conditions of approval associated with the Court decision. and III(: I)ro_'cCCS compliance with the grading ordinance. Condition of Approval T'i14 of the project approval states: "Geotechnical work shall Include levee breachina, soil and excavation, clewater-ling, removal, replacement and compaction of soil. on-site water development, erosion control measures, and dcsj`.,:n and Installation Of' Subsidence measurement." Deep Dynamic Compaction (DDC) is one of' the methods bclll, Used 6C)v III-,- Cypress Lakes project near Bethel Island. The Bethel Island Municipal Improvement District (BI-N-11D.) is the Welic" responsiblefor maintaining and reQLIatI - use Of existing lei ees around theisland, and will be responsible for review'Ing the plans for the proposed levees. Citi - en Concei-n - There is cov,ern about the existing condition of rhe leives. To _- - Which Imblic cy-enc.V should concerns be clii-eciecl on ihescifetY cjf(he levees., Staff Response -The Bethel Island Municipal Ufflmr District is the public agency responsible for maintaining the Island levees. If you have concerns about the sal'etv of the levees, we suggest that VOU contact that agency. 'File B11\411.) office is located at 3085 Stone Road, Bethel Island. i. cc -n about the zoning regul- Cilizell C atioll-S C171a1 onceivi -.Holl' in one lem Plan, including policies relating to Bethel Mand.,` Staff Response - Interested Citizens may cotyle to the C011111-11_1111tV l-) eIOI�I11CIlI Department during normal Department bLISIne.ss 11C)LIF5 to I-eVIC"N tile L/011111`' ordinance and maps, and the General Plan. One portion of the Land 1,-Ist Flement of the General Plan specifically addresses planning policies for the Bettie] Island area. C_'i1i_7C17 C017C(-'7-11 - 11771' (11-e SOMe bllilciill-s 017 the W(117f] 170[ elevated(IbOl c the, . - a floociplain level that has been determined bY the Feclerul Emergence, Mcmcilemcw A(Tenev C117CI regalatecl b); the c1esigI7 7_eqU11-e177e17[S oi 1110 C'0111711!'S F100C1j)1L1i77 ,�lanagc�n7cnt Ordinance. Staff Response - The County adopted the Floodplain Management Ordinance HI 1987 (Chapter 82-28). Sti-Lictures that obtained and complied V,71th I-mildlM, permits Prior to the effective date of the ordinance are not Subject to its I)K)VIS1011S. A 111.1111bCr of conventional residenccs and trailers III (I-Lallcl 1)a I i.:-, R-2 very coarse sand: 2.00 - 1.00 mm diameter coarse sand: 1.00 - .50 mm diameter medium sand: 0.50 - 0.25 mm diameter fine sand: 0.25 - 0.10 mm diameter very fine sand. 0.10 - 0.05 mm Although these values may not mean much, but if you compare sand to clay in grain size the differences is on the order of .000005 mm smaller. I hope this brief understanding of sand levees helps you. I would like to further substantiate my opinion with other.geotechnical and scientists working in New Orleans. Warning Sounded About Levees If the only thing standing between you and a powerful storm surge or high tidal conditions is. a levee made of sand, you might consider moving. These are the types of comments made by engineers and scientist investigating the failures in New Orleans. By the way this was considered compacted or engineered sand. Roughly 80 percent of the city was flooded - with up to 20 feet of water in places - because of levee failures in Katrina's aftermath. The most likely causes, researchers said at the hearing, ranged from overtopping and seepage to improperly set pilings made from steel sheets. Steel sheet piles typically range from 20 to 25 feet in length. This inability to penetrate deep foundation soil for support diminished there integrity to act as a proper water cut-off system. Allowing seepage beneath the steel. "if it's earth versus concrete, the earth will lose," Dr. Nicholson noted in the USA Society & Culture from the November 3, 2005 edition. An expert panel monitoring reconstruction of New Orleans's hurricane-protection system warned federal engineers last month about the presence of weak. sandy soils in a newly rebuilt levee, the panel's leader said yesterday, escalating a dispute over the soundness of the government's rebuilding effort. Ar Raymond Seed, an engineering professor at the University of California at Berkeley, also disclosed in a letter to Lt. Gen. Carl A. Strock, the Corps' commander. "These same levees eroded catastrophically during Katrina, and were the principal source of. the massive flooding" of neighborhoods east of downtown New Orleans. Seed's group, an engineering panel funded by the National Science Foundation, and a separate Louisiana panel of experts have questioned the reconstruction effort: saying the Corps is misleading state residents into believing the levee system will be safe by summer. In the letter, Seed said he and another Berkeley engineer personally observed Corps contractors constructing a section of the levee using "clean, fine grained sand, which is highly erodeable." The soil properties of the levee recently constructed along Sandmound has similar grain size characteristic observable by the significant erosion from recent rain events. Prohlcros with the: upper Sacrarncntu River "Rivers have been.formed and wandered back and forth over the flood plain for millennia. depositing all kinds of soils and sediments. Mud, sand, gravel, brush, dead trees -- all these things combine to make a complicated soil structure. And. to make it even more complicated, when the levees were first built, less permeable soil from "borrow pits'' on the river side of the levee was used. The borrow pits exposed sand and gravel layers near levees to flood waters. That made the levees more vulnerable to under-seepage and sand boil formation." Old Slurry ` Wall Method 4 M-pq 1 GrandJu y 725 Court street � ..s.._' �� Contra , --= • ;' — , P.O. Box 911 Martinez,CA 93553-0091 `S Costa UNpry County '9 COK Contact: Antonio Medrano Foreperson (925) 646-2345 For Immediate Release Executive Summary Cracks to Patch at Bethel Island Grand Jury issues report on the levee and water systems of Bethel Island. The 2004-2005 Contra Costa County Grand Jury has concluded an investigation of Bethel Island's compliance with federal levee standards and the direction the Bethel Island Municipal Improvement District ("BIMID") is headed in developing an island water treatment facility. Bethel Island is an unincorporated delta community in northeast Contra Costa County that is protected from flooding by a 125-year-old levee. "Tap water for the island is provided by wells, some of which do not meet current or proposed water quality standards. BIMID has not uniformly enforced local ordinances such as those designed to prohibit actions that could weaken the levee,to provide quick access to all levee areas, and to ensure that property owners keep drainage systems on their property free of debris. The Grand Jury recommends BIMID develop a long-range plan to upgrade the island's levee to the standards recommended by CALFED, a partnership of federal and state agencies. This plan should prioritize levee maintenance and rehabilitation tasks, estimate their costs, and include available and needed funding sources. The Grand Jury also recommends BIMID.prepare a comprehensive study comparing options for providing water to island residents, so that both BIMID and residents are better informed about the ramifications of their choice. Finally, the Grand Jury recommends BIMID enforce existing ordinances to protect the levees and maintain the drainage systems. The complete report is available on the Grand Jury web site: www.cc-courts.org/jgrandjUrv. J The island's private water companies are faced with the increasingly stringent water quality standards being implemented by the Environmental Protection Agency ("EPA") and DHS. For example, effective January 23, 2006, the allowable arsenic level will be reduced. Other even more stringent standards are proposed for the future. Development on the island has been limited. However, the Delta Coves development ("Delta Coves"), scheduled to start construction in 2005, will add 494 homes and 15 acres of commercially zoned property to the island. The additional residents will increase the island's population by about 50%. . FINDINGS Levee 1. Should a levee fail, and the island flood, 2300 residents will be affected, with substantial damage to property as well as potential loss of life. 2. Bethel Island is one of eight islands in the west Delta, which are particularly critical to protecting Delta water quality because they are adjacent to a major Delta channel where fresh and salt-water mix. . . 3. In the 1980's, the Federal Emergency Management Agency ("FEMA") adopted a minimum standard that requires levees to be, among other requirements, one foot higher than flood stage and required reclamation districts, such as BIMID, to meet minimum levee standards. 4. Reclamation districts had until 1991 to comply with the requirements or be ineligible for federal disaster assistance. 5. BIMID did not meet that 1991 FEMA deadline. 6. FEMA turned down requests from BIMID for disaster assistance fundsTor emergency work performed by BIMID following the 1995, 1997, and 1998 winter storm disasters because BIMID had not met the 1991 deadline. 7. BIMID continues to upgrade the levee, and recently concluded that the levee is now compliant with FEMA standards. However, BIMID has not documented its position to FEMA in an attempt to be formally recognized as eligible for federal disaster funds. 8. Over the past decade, BIMID has requested assistance from elected state and federal representatives in finding a solution to the FEMA compliance issue. The assistance involves these representatives intervening on BIMID's behalf with FEMA and other involved agencies. 3 22. Diablo Water's filter plant has the capacity to serve all of Bethel Island. Diablo Water plans to install a pipe large enough to service Delta Coves and to meet all future water needs for the rest of Bethel-island. 23. The Local Agency Formation Commission ("LAFCO")was petitioned ("LAFCO Petition") to designate Diablo Water as the supplier of Delta Coves. 24. BIMID appealed the LAFCO Petition. 25. The LAFCO Petition was approved after BIMID and Delta Coves entered into a written agreement as follows: • The developer of Delta Coves agreed to pay BIMID $250,000 to drill test wells to determine if BIMID could find water in adequate quantity and quality to supply a proposed BIMID water treatment facility and distribution system. • If the test wells identify an adequate water supply that is certified by DHS, the developer of Delta Coves agreed to pay BIMID an additional $2,000,000 towards the design and construction of a water treatment facility. • BIMID agreed to withdraw its appeal of the LAFCO Petition. . 26. The two primary options for replacing most private wells on Bethel Island are: • Water from a new Bethel Island water treatment facility ("Bethel Island Option"). • Water from Diablo Water.("Diablo Water Option"). 27. No comparative study exists for the above options that includes: • Advantages/disadvantages of each option. • Adequacy of flow to provide service to the island including fire suppression. • The quality of water to be provided. • The infrastructure needed, including capital and operating costs. • User connection and usage costs. • Financing options for infrastructure costs and for individual connection fees. • Emergency backup requirements and source(s). Other 28. BIMID has adopted ordinance numbers 4 and 9 to protect emergency levee access, to protect the drainage systems, and to regulate activities upon, through, or over the levee system. 29. BIMID has seldom taken action to enforce ordinances regarding locked levee access gates, residents' requirements to clean out drainage ditches and boxes, and the planting of vegetation on the levee. 5 Water 7. Negotiate a revision to the agreement, immediately, with the developer W'Delta Coves so that the $2,000,000 is not restricted solely to develop a eater treatment I'acilit.. but can be used for other purposes that benefit the entire community, such as le\CC maintenance or installation of water mains servicing the entire island. 8. Prepare and make public a comprehensive study of the Bethel Island Option (defined in Finding 27). Include in that study a comparison to the Diablo Water Option and the status quo. Funding for the study could come from the $2,000,000 provided by Delta Coves. 9. Conduct a series of public meetings whereby residents may direct comments and questions to the BIMID Board of Directors regarding the proposed water system options. lu. 1I'BIMID selects the Bethel Island Option, establish a reciprocal agreement with Diablo Water to interconnect the water systems and provide back up should there be an interruption of service.. Other I I . Communicate with property owners and residents regarding their responsibilily, B1MiD's responsibility, and BIMID's enforcement authority tier the lCVCC and drauiage systems, as outlined in BiMID ordinances 4 and 9. Make regular use of BIMID's enforcement authority under ordinances 4 and 9, including fines, assessments, and liens. I Adopt a written policy regarding the acceptance ofcontributions that requires Written agreements and full disclosure of such contributions. REQUIRED RESPONSES Findings: Board of Directors, Bethel Island'Municipal Improvement District: i-18, 23-33. Recommendations: Board of Directors, Bethel Island Municipal Improvement District: I-I 7 Y23��i4�+ Bethel Island Municipal Improvement District ••II 'i1Ff' . 3085 STONE ROAD POST OFFICE BOX 244 f I.'r�,-.:�i; `rte L,,• . r'�a': _ BETHEL ISLAND, CALIFORNIA 94511 (415) :;; ;s,'�.•._' .. �. : :;..:. 684-2210 •�=Fier?;1:•=iv1 ,,,`�y�::^l'i �..;:, UA :+ '•'� "�;r .' -,��,;'-�;;.;�;'�' . The Bethel Island Municipal Improvement District .welcomes opportunity to comment on public notice 6063A, Delta Coves ' o Y " "> application for the reissuing of an Army permit to breach Bethel x ' nd's Sandmound Slough levee and to place fill materials in �:. 34Iti°` >Y'wetlands on Bethel Island. 'i •:' 1:�, - r:='•'`' Much time has passed since the original permit was issued , and circumstances have greatly changed. New information is avail - `' gable now on potential detrimental effects of the proposal which .. , ; were not considered or .not known in 1978 . A new or supplemental 'MiTnvironmental Impact Statement should be prepared to thoroughly >explore the new information and changed circumstances . The District' s written comments present new. information, flµ:"•��' ,;.y.=ji�y . , ej a'•; : x,engineering research, and technical material regarding the pro- ,a.:;:posal . These comments will follow the guidelines outlined in the f, public notice (page 4) . I4.. - f;,; :ECONOMICS: . ' + At the time of the Environmental Impact Statement (1978 ) and s 'rthe final Environmental Impact Report (1976) the property taxing " = F-R� tructure was different in California . It was then believed that :;increased service demands , capital expenditures , and infrastruc- ":ture costs would be covered b the increased property tax base Y P P Y x --provided by new development . This is not true today . Since the passage of Proposition 13, economic reality has changed. Yra ; The proposed project ' s perimeter levee. section would consti- _ Ft. :;.: ute a continuation of the District 's levee system and would erefore be under the jurisdiction of BIMID. The project will pr. add approximately 7 miles of waterside slopes to the District ' s `:: :existing 11 . 5 miles . This will increase the District ' s mai; te- - ance responsibility by approximately 60 percent . Additional PersanneI and equipment will be needed to handle this new respon- T. BIMID comments, page 1 `..Y. A. F. sibility . ongoing staffing may be covered by increased property tax revenues , but facility and equipment costs will not be ade- quately funded. Moreover, since the Corps ' notice indicates the project is planned for lot sales , not a housing subdivision, full property tax revenue may not be forthcoming for many years . In the meantime the District will have the responsibility for rou- tine inspections and maintenance of the new waterside slopes . At least one new patrol vehicle and an additional dump truck will be required. The developer will be responsible for these necessary t capital expenditures . The District ' s annual levee maintenance budget is supple- mented by State Levee Subvention funds administered by the De- partment of Water Resources . Levees constructed after March 1988 (SB-34 enactment date) will not be eligible for state subvention j+ monies . Therefore , an assessment district will have to be estab- lished for any new levee sections on Bethel Island to fund ongo- ing maintenance requirements over and above routine inspection covered by BIMID' s budget from local property tax revenues . Rip rap replacement , slope failure repairs , rodent control , rodent damage repairs , and other maintenance activities are necessary for new levees as wel.l. as old. Preconstruc.tion fees will be needed to cover engineering review of the project design, monitoring , and inspection of con- .h struction by the District . These expenditures will occur before any new tax revenue is generated and they cannot be taken from { the District ' s current budget which must cover maintenance and improvement of the existing levee . Preconstruction fees will also be neededto hire and train new personnel in water quality man- agement procedures and to purchase required equipment for this work. New District drainage pumps .will be needed to accommodate some of the project ' s storm water runoff . Higher drainage pumping costs can be expected if the project is built . Expenditures for new pumps , a drainage study, and the relocation of the District ' s existing drainage channels must be paid for by the developer. AESTHETICS: Standard county-supervised landscape plans as specified in Contra Costa County' s conditions of approval may not be suitable :i P f. BIMID Comments, page 2 �.... levee plantings . The Corps ' public notice drawing. sheet 3 of . 7 indicates trees and other vegetation in the patrol roadway area on the waterside crown. New plantings on levee slopes and crowns in Bethel Island must conform to the "Interim Guide for Vegeta tion on Flood Control Levees" adopted September lb , 1988 , State of California Resources Agency, Reclamation Board. The guidelines vegetation on the levee crown which interferes . with prohibit maintenance and inspection of the levee . Also, the California Department of Water Resources Superintendent ' s Guide to Operation and Maintenance of California ' s Flood Control Projects notes that some levee areas , including crown roadways are usually kept free of any vegetation: " GENERAL ENVIRONMENTAL CONCERN: New information which sheds light on potential detriments posed by the Delta Coves project has been discovered and studied since 1978 . This new information must be thoroughly evaluated while considering the project '.s application. 1 . There have been new studies of subsidence in the Delta by the State Department of Water Resources and other agencies.. (See. Burns Engineering sectio=n of these comments . ) 2 . The rise in sea level caused by the greenhouse :.. .. ...' effect , now recognized as a significant environmental .: .. constraint by the Federal Environmental Protection Agency , was not .a consideration in 1978 . (See Burns Engineering and D.B. Flett & Associates .sections of these comments . ) 3 . Dewatering problems and resulting damage in .the s .. Bethel Island area were experienced during the sewer system installation in 1979. (See D. B. Flett & Associ- ates section of these. comments . ) 4 . There have been many levee failures due to instabil - ity, rather than overtopping, since 1978 . This new p . '� . information requires reconsideration of the comments in r the final EIS submitted by the Resources Agency of y .. California, Appendix D, page 4, : regarding potential for _p failure of the existing Bethel Island levee as a conse- ;d BIMID Comments., page 3 r quence of Delta Coves construction. ( See summary of levee failures in D. B . Flett and Associates section of these comments . ) n 5 . In 1980 , the Corps of Engineers stopped all rehabil - �:;; i.tation assistance to non-Federal levees in the Sacra- mento-San Joaquin Legal Delta under PL 84-99 until such time that the non-Federal levees could be considered ``' .. flood-control levees that provide a dependable adequate degree de of protection . Subsequently, the Corps of En i- iii; �J neers developed National Guidelines that were published in 1986 and amended in 1987 . These guidelines prescribe minimum standards that non-project levees such as �, ,, •;:, Bethel Island .s existing levee must meet to be eligible for assistance from the Corps . " 6 . The State of California' s Flood Hazard Mitigation Plan, 1986 , identifies seepage as a contributing factor to levee instability . ' = 7 . There is new recognition of the interaction of flooded island affecting seepage rates of neighboring islands and the detrimental effect excessive seepage J has on levee stability . (see Burns Engineering section. of these comments if 8 . The Federal Emergency Management Agencyhas issued FIRM maps for the Bethel Island area . The proposed ..Z.r—d.•.:;.' parallel levee corridor which would result if the project were constructed would necessitate a reevalua- ='``'_ tion of the flood hazard zone rating in this area . y{ The project 's own soils study, "Soil and Geological Investi- :#.•:..:gation for .Delta Coves , dated June 1980 by William F. Jones g g . .:.;.�V:.•:�:..:, .. nc . , recognizes that changes can occur over the Passage of time . The report says on page 47 : "The findings of this report are valid as of the date o f the report .�;• �::;� ;-:.. . port . However , changes in the conditions of a * ' ;`;: :''.:::�_: •• -!�- property can occur with the passage of time , whether they be due to natural' processes or to the works of k, man on this or adjacent properties . In addition changes in applicable or appropriate standards occur , whether they result from legislation or the broadening of knowledge . Accordingly, the findings of this . report N. ,; f BIMID Comments, page 4 7' . may be invalidated, wholly or partially , by changes •I:,s outside of our control.. Therefore this report is sub- ject to review, and should not be relied upon, after a period of three years . " [Emphasis . added] Discrepancies : There are discrepancies between the original Corps ' permit based on the 1978 EIS; Contra Costa County 's Final Development Plan and Tentative Subdivision Map including the 38 conditions of approval attached to the app judgment based on the 1976 EIR; and the Jure , 1989 Corps ' public notice . Water quality control and levee maintenance jurisdic- tions are not consistent between the Corps ' EIS and the County ' s conditions of approval . The county conditions 11 call for a resolution from BIMID . . .which shall indi- cate the District ' s agreement to accept and maintain ` : the new levees and lagoon. " The Corps ' EIS indicates that a Homeowners Association will be responsible for "levee maintenance (though not for lagoon water quality) , but that BIMID would accomplish any required repair or rehabilitation not accomplished in a timely or satisfactory manner . A homeowners group cannot s "accept" a . new levee section in Bethel Island, nor can it pass a resolution. indicating the District ' s accept- ance. Furthermore, District supervision of homeowners ' Jmaintenance and rehabilitation efforts to ensure that they are carried out in a timely and satisfactory s manner would entail constant patrolling and supervi- 'l' Sion. The proposed project ' s levee section would con- stitute a continuation of the District ' s existing levee. It would be under BIMID' s jurisdiction if a permit is granted by the Improvement District . r There are no lagoon water circulation pumps in Contra Costa County 's Final Development Plan, and yet the Corps ': permit application includes discharge pumps located at the head of each interior cove to flush the coves and maintain water quality . The county ' s condi- tions call for "an adequate lagoon flushing system approved by the Public Works Department . " = Setback areas on waterside slopes are shown as 4. BIMID Comments, page 5 three-foot "non access areas" on the Final Development Plan, while the Corps ' public notice , sheet 3 of 7 , indicates a five-foot unidentified area on t'-_e water- side crown. Waterside "benches" are shown as 10-feet in Corps ' . . notice and 15-feet on the county's plan. - The project ' s entrance opening is specified as 150 k : feet on page 2 of the Corps ' notice and as 160 feet on sheet 2 of 7 in the same notice . . : '.`s: - Levee elevations and lagoon finger elevations are not -A specified on the Corp ' s notice , sheet 3 of 7 , and s scaling of the typical sections in the notice does not .�.. ., appear to match those on the Final Development Plan. Waterside levee "benches" indicated on the Final Devel - opment Plan and on sheet 5 of 7 o the Corps ' s notice, are not shown on sheet 3 of 7 . The county ' s condition. number 29 . E. says the "minimum top of levee elevation of the perimeter levee shall be at 10 foot USGS datum. " ¢ : BIMID' s minimum levee elevation is set at 10 . 2 feet and =C ' the District ' s long range plans call for a levee height A; — of 10 . 5 feet . ;. Inadequate Subsidence Mitigation: Contra Costa County' s Condition 12 calls for an automatical - ly recording tide gauge or other subsidence measuring instrument ;t to be installed in the project marina and maintained by BIMID or ,T . a county agency or the homeowners to monitor subsidence . The condition specifies that "If at any time the maintenance agency has reason to believe subsidence threatens the development it ':; .. shall report its finding to the Contra Costa County Water Agency with recommendations to mitigate the hazard of flooding due to subsidence ." Mitigation measures for hazards of flooding must be con.sid- ered and planned long before it becomes an imminent threat . s .. .. Expecting an agency to come up with recommendations to mitigate a . ..::;r .: life or property threatening situation when it is in progress is not reasonable. The project proponent must be required to have mitigation measures specified or in place prior . to the granting ,.;..: any approvals . BIMID' s Ordinance 9 requires levee ,,.,{. .. '. .. y permit '` " '` BIMID Comments, page 6 -;,.. building setbacks which provide adequate room for increasing freeboard if needed to compensate for subsidence and/or sea level rise. Sea Level Rise: A Congressional Subcommittee Hearing on Global Warming , entitled "Implications of Global Warming for Natural Resources , " held in San ' Francisco' in October of 1988 brought together re- pected experts from all over the United States to discuss the ;;,::`greenhouse effect and appropriate planning for the possibility of rising sea levels . Richard Morgenstern, Directorof the Environ- mental Protection Agency ' s Office of Policy Analysis , Washington, D.C . , testified at the hearing . He said, when speaking of Cali- +::'"+ .'' forma concerns , "Another possible concern for California is sea levelrise, which could inundate wetlands and low lands , e::acer- bate flooding and increase the salinity of surface and ground .water . . . . Sea level rise would also jeopardize the delta islands if levees around the islands are not maintained. " Jeffry S . Blanchfield, Chief Planner for the Sari Francisco Conservation and Development Commission, also presented mate- rial at the Congressional Subcommittee Hearing . He said. "If the ... sea level were to rise four feet in the next century , as has been ' suggested by the United States Environmental Protection Agency as useful figure for long-range planning purposes , the following on the Bay-Delta system could be expected: . . . ( 2 ; levees protecting . . .Delta islands would fail . " He co^timed , ocal state and federal coastal agencies should take into con- sideration on-sideration the relative rise in sea level in project development , and and water use planning, and in land and water use regula- tion. Agencies should include projected sea level change in the design of . . . any project reviewed and approved . . . Shoreline protec- E. -tion devices should be designed so that the facility can he easily increased in height during the normal maintenance process :°.y : .,.•: .. if relative sea 1 evelshould increase at a greater rate than pro- ': .:;;...r.:....:.:.:::.:.: jected . . . .Local governments , special purpose districts with responsibility for flood control , and FEMA have major responsi- lities for assuring that new structures are not located inap- P p y . . . [M]any of the adverse impacts to coastal a:-eas caused by relative sea level change are gradual and can be avoid- k.,....:;.i.>;.,., ;.:'. ed or mitigated by planning in anticipation of future significant . hanges in sea level . + BIMID Comments, page 7 .;;..in 1989 did not contain mitigation measures for island drainage roblems . The 1983 conditions stated, "Construction of the per4rr- . ter levee will block or disrupt the existing surface drainage here surface and ditch flows enter the site. Adequate provision for storm drains should be installed to pick up and convey all runoff entering the site that would be blocked by the new levee. p, particular. concern is where the new perimeter levee will front existing residential lots blocking lot drainage . . . The ;:'....Bethel Island Municipal Utility [sic] District (BIMID) states that the existing pumping capacity is not adequate to handle the .-..,..Volume of water generated during periods of heavy rains and high '' tides which increase seepage flows . The district requests that the project assist the district in adding to the present capacity either at the site or at existing or an alternate pumping sta- tion. " A drainage study of the entire island drainage. system is :needed prior to the design of replacement drainage courses for the project . Higher pumping costs can be expected if the pro4ect built . Expenditures for new pumps and a drainage study must be paid for by the developer . Building Sites and Setbacks : The residential building sites and setbacks on the proposed levee as shown in the county ' s Final Development Plan and the { Corp 's public notice do not comply with BIMID' s Ordinance 9 or Contra Costa County ' sZoning Ordinance 84-34 . 1006 or the State of 'California Department of Water Resources Standards for Encroach- 7 ments , Resources Agency, April 1976, page 30 , "Buildings will not .::,�....:.::...... be permitted on or over the levee section within the area bounded by the levee toes . " [emphasis in original ] Public notice sheet 3 of 7 , shows what appears to be five-foot setback from the water- " side crown edge . The County' s Final Development Plan drawings indicate a "non access strip" of 3 feet . BIMID' s Ordinance 9 ,.. prohibits construction of structures on or over the levee or in e levee setback area. The District ' s "General Standards and . .:'.`► :: '`::.:..:..Guidelines for Permit Applications" defines the levee setback as approximately 60 feet from the waterside edge of the levee crown. -contra Costa County' s Ordinance prohibits construction of new tructures within a 50 foot setback from the centerline of the levee . BIMID Comments, page 9 F+'` Vh Setbacks are necessary to provide an easement for a 2C-foot } : de, all -weather driving surface for levee patrols along the -;Waterside edge . The waterside easement area also must be wide enough to allow for additional fill. to maintain the required ;-levee height and slope in the event of subsidence and/or sea level rise . Easements for patrol vehicles and fill will preclude the planting of vegetation such as trees and shrubs in this area . The concept of placing patrol roads between residences as ` .:.:, discussed in the EIS , page 3 , 1 . 03 , f . , is not acceptable to IMID . All levee maintenance , patrol , and emergency procedures outlined in the State of California' s Department of Water Re- sources , Division of Flood Management Superintendent ' s Guide are based on levee crown roadways . BIMID, along with many other reclamation. districts in the Delta, relies on the state Guide as .a basis for proper operations . There is no necessity to charge well established, proven levee patrol , maintenance , and emergency '`� ' operations . t... '� Theoretical Levee Section: Contra Costa County' s Final Development Plan indicates a "theoretical levee section" of 20 feet on the landside of the - proposed perimeter levee . This arbitrary placement of a theoreti- <'•`.:--.:'.:cal levee section ignores the .true function of a levee which is . to hold back water . Any theoretical levee section would have to ':.be situated on the .waterside of a barrier levee . The Final Dever ... . opment Plan shows the invert of the outlet of a storm drain pipe at an internal lot at +2 . 0 waterside . The inverts of all pipes , longitudinal. and transverse, in the theoretical levee section P flood ear -must be above the 100lain. Y BIMID' s minimum standards for its levee call for a crown 'F' .. width of 20 feet with a 2 : 1 waterside slope and a 3 : 1 landside slope . Any meaningful theoretical levee would have to include theoretical slopes which the plan does not .. BIMID' s minimum levee standards, . and ordinance 9 waterside setback regulations are based ={ on the need to inspect , monitor , maintain the levee for the safety of the island residents . "' WETLANDS : The wetland areas outlined in the Corps ' public notice on BIMID Comments, page 10 p the 310 acre Delta Coves property are less extensive than those found in the most recent study of the Bethel Island area, Draft EIR, Bethel Island Specific Plan , 1989 . ( See EIR Maps in appen- dix . ) ` Contra Costa County 's Revised Draft Bethel Island Specif'_c plan, June .1989 , specifies low density in areas identified as wetlands . The Plan says on page 3-3 , "Areas that have been iden- 4 tified as seasonal or permanent wetlands have been designated as Delta-Recreation. The density in these areas would be one dwell - ing unit per 20 acres . The County policy requires that there shall be no net loss of wetlands in either quantity or value . " FISH AND WILDLIFE VALUES : Erosion of the large Sandmound Slough tule island, directly '% in front of the entrance to the project , is likely due to the flushing action and increased water velocity at the project ~� entrance . Wildlife islands in the project lagoon, as a mitigation for loss of habitat, were an important part of the Environmental Impact Statement of 1978 . Now, these islands have been eliminated in the Final Development Plan and the Corps public notice draw- t °` r Ings . What mitigation is provided for loss of habitat? FLOOD HAZARDS and SAFETY : Contra Costa County ' s Revised Draft Specific Plan for the Bethel Island Area , June 1989 , says on page 3-4 , "Safety �, _ y of t � study area and its residents from flooding and .levee failures is a key concern of the Specific Plan land use program (Po.licy 3 . 1 . 11) . As a result of this concern, the opening or breach-ing _g levees will not be permitted in conjunction with development in the planning area . " [emphasis added] j` '=` '' Delta Coves is not a standard subdivision housing L '' - g p 'o ject `'' ` j` :"' Subdivision and building code regulations , under which this project was granted approval in January 1989 , do not provide : •.,; .;.;,:.:,,. ,: adequate safety standards for a lagoon project in a below-sea- ^ ,�=e ==:::; .level island protected by levee . BIMID Comments, page 11 ry5 .LTi . The configuration of the project ' s proposed perimeter levee parallel to the District ' s existing levee along Stone Road poses a significant potential hazard to residents and property in this 1 s . . narrow corridor area. Should the island ' s existing levee in this area break, flood waters would be confined in a 300- to 400-foot Wide channel and move through it with great speed and depth. gecognition of this hazard, which was not discussed in the Corps ' 1978 EIS, has caused much concern . Because BIMID has the respon- sibility of protecting residents and structures in Bethel Island, further studies of this hazard were deemed necessary . In 1988 , the District contracted with D.B . Flett & Associates for a study of the project ' s potential problems which could affect Bethel Island. Flett ' s report was submitted to the Contra Costa Board of Supervisors . His complete report follows in this comment section on flood hazards and safety. In 1989 , the District so 'ght =� further information on the Delta Coves project and engaged Rich- and Meehan, a geotechnical engineer to study the project . Mee= han' s report follows in this comment section. A report by Burris Engineering , BIMID District Engineer , is also included in this section . f: :t !i is 'S -� BIMID Comments, page 12 A i1 B &A CIVIL ENGINEERING D, B. FLETT & ASSOCIATES, INC. 1280 Civic Drive, Suite 210, R'alnut Creek, CA 94596 (415) 935-7710 June 27 , 1988 Contra Costa County -Board of Supervisors 651 Pine Street 1st Floor , North Wing Martinez , CA 94553 Subject : Subdivision 6013 (Delta Coves ) Honorable Supervisors , We have been retained by Bethel Island Municipal Improvement District (BIMID) to review the proposed Subdivision 6013 and its impact on the existing and future Bethel Island Levee System. In completing this review we have examined the Soils and Geologic Investigation, EIR, several recent California Department of Water Resources reports published between 1982 and 1986, and other documents listed in the attached bibliography . In addition we have consulted with Board members and staff of BIMID. BIMID's primary concern is the safety and integrity of the levees which form and protect Bethel Island . The Bethel Island Levee System is probably one of the best systems in the Delta . The Corps of Engineers estimated the statistical frequency of the Bethel Island levee failures to be 0.20 failures per 100 years in 1974 . However , the Corps also indicated that without a levee improvement project after BO years , the frequency of failure would rise to 4.29 failure=_ per 100 years , or about once every 25 years . BIMID's mission is to improve and maintain the existinq r: levees so that levee failures do not occur . iS t Historically , Bethel Island levees have not failed since 1907 . R Although there is some recollection of a possible failure in the 1930's, the only documented failure is one that occured in 1907. The location of the 1907 break however , was near the site of the ;j: breach proposed by Subdivision 6013. It is this concern for the levee system which has caused BIMID to request that Subdivision 6013 not be approved in its present form. In the last 6 years several additional studies of Delta Islands and levees have been completed by the State of California, Department of Water Resources (DWR ) and additional data affecting the levee integrity have become available. As a result of this information BIMID has concerns in the following areas: STABILITY OF THE EXISTING LEVEE: - A. The April 1984 Nonproject Levee Hazard Mitigation report by DWR lists the following principal causes and contributing factors for levee failures : BIMID Comments, page 20 Principal causes of levee failures are: Structural failure of levee by surface erosion or internal erosion (piping ) . * Foundation failure of underlying soils . Overtopping by floodf-lows, tides , and waves . Contributing factors include: Improper levee design or construction. Poor construction or foundation material . * Erosion by current and wave action. Seepage through or under the levee. Rodent burrows in the levee . Improper levee repairs . Improper structures placed in or on levee . Lack of regular and adequate maintenance. The 1980 soils report for the project indicates that the .existing levee near the entrance channel area and for almost one mile along Stone Road is underlain by up to 10 feet of peat . It is recognized that this foundation condition is less favorable than in other areas of the project . Two possible causes of failure of the existing levee related to the construction of Subdivision 6013 which are of concern to BIMID are: a . Structural failure related to internal erosion. - The 1980 borings actually encountered a void in 'the levee. Although the soils engineer declined to speculate on the reason for the cavity's existence he did suggest that there must be other cavities in the existing levee . I.t is possible that these cavities are evidence of internal etosion. Neither the 1980 soils report , the 1976 EIR or the 19BB letter from Mr . Jones addresses the impact on internal erosion resulting from lowering I the water table to facilitate construction of the new t levees. BIMID's experience with dewatering on a much ;i smaller scale for the installation of the Bethel Island :A sewer system indicates that this may be a significant problem. ..F l BIMID Comments, page 21 �. D. B. FLETT & ASSOCIATES, INC. 1280 Civic Drive, Suite 210,Walnut Creek, CA 94596 (415) 935-7710 -,: b . Foundation failure of underlying soils . - Given the fact that about 1/2 mile of the existing levee is founded on peat and that the 1907 levee break occurred in this area, BIMID i= concerned that any additional weight on the levee or increase in the water pressure caused by lowering of the water table inside the levee may result in a failure of the poor foundation material . Between 1983 and 1986 there were over 25 levee failures in the delta , most of which were a result of structural or foundation failure rather than overtopping . Some of these failures occured during the summer when repairs were being made to the levees and the weight of the levee exceeded the strength of the underlying foundation. II . SUBSIDENCE RELATED ISSUES: Levee Subsidence.- As part of the increased levee }* maintenance and improvement program in the delta , BIMID completed a survey in September 19e7 of the existing >rr'. centerline profile and levee cross sections . Comparison of this data with earlier data indicate that the levee 4 centerline is subsiding at a rate of about 1 to 2 inches per year . BIMID deals with this subsidence by continual maintenance of the levees which requires that the levees be constantly - ` raised . For this reason BIMID has adopted a rule prohibiting structures within 50 feet of the centerline of "' ``''`•` lan existing levee. The proposed plan for Subdivision 6013 locates residences in this area making maintenance of the new levees more difficult . B. Deep seated subsidence, - DWR Bulletin 182-82 indicates that there is deep seated subsidence in the vicinity of the Rio Vista gage that may be permanent and ,on-going . DWR began a Delta Subsidence Investigation in July of 1985. Specific data . relating to Bethel Island is inconclusive in regard to the rate of subsidence. At this date a deep subsidence well has been drilled on the island , but instrumentation has not :''•'"' yet been installed . The actual subsidence rate has not been determined . `':<^ -'',': C- Sea Level Rise. - The BCDC sea level rise study is the most recent study available . An analysis of the tide level gage at the Presidio in San Francisco indicates that the rate of rise of sea level over the last 100 years has been 0.0039 feet per year . More over , 'this rate appears to have increased to 0.0072 feet per year in the last . 19 years .. This report concludes that when the sea level rise is ►,:;:'...: coupled with deep subsidence the relative mean sea level r projection for Pittsburg for the year 2037 (50 years from the date of the report ) is 0.8 feet above the present level . In view of the relative increase in sea level , the BCDC BIMID Comments page 22 FLET']'& ASSOCIATES, INC. 31280 Civic Drive, Suite 210, Walnut Creek, CA 945% (415) 935-7710 report is recommending a sophisticated approach to the determination of levee height in order to provide protection to the new structures. The existing project plan has not considered this data , nor developed a method of providing a continual levee protective device over the life of the project . The conditions of approval do require monitoring for possible subsidence , but do not require development and implementation of a plan for controlling settling and subsidence. The conditions of approval call for a levee height of 10 ft . This may or may not be adequate for the present conditions when allowance for the still water height and wave runup is made . Under likely future conditions it is most probably inadequate . It should also be noted that raising the floor level of structures protected by the levee above an elevation derived by adding a freeboard allowance to the expected maximum high tide does not provide adequate protection. Especially if the ground on which the structure rests subsides. On the other hand it is not necessary that the minimum floor level be - above the top of the levee . BCDC recommended criteria require that the structure be floodproof , floor level be above maximum still water elevation, and levee crest above maximum water surface elevation. III . CHANGED GROUNDWATER CONDITIONS: The DWR Flood Hazard Mitigation Plan prohibits dredging material below -35 feet for levee repair or restoration within 135 feet of the centerline of the levee . The reasons for this relate to levee stability and a concern regarding seepage when the impervious river bottom layer of silt is removed . The removal of soil within the proposed lagoon may have a similar effect . Furthermore , subsequent filling of the lagoon may alter seepage patterns elsewhere on the island and thereby impact SIMID 's seepage control program. It is recognized that soil removal will not be as deep as -35 feet . However , recent experience with dewatering for installation of the Bethel Island sewers and subsequent infiltration problems have caused BIMID to be concerned about this factor . There does not seem to have been any study or consideration given to the effects of flooding a significant area of the island. Therefore, it is BIMID 's positionthat the project as proposed not be approved . In summary, BIMID opposes approval of the project as proposed based upon new data relating to changed circumstances since the last review of the project . These 4 BIMID Comments, page 23 B. FLETi & ASSOCIATES, INC. 1280 Civic Drive, Sufte 210, R'alnut Creek, CA 94596 (415)935-7710 y,R data relate to : . Stability of the existing levee under conditions created to facilitate the construction of the levees for Subdivision 6013 2. Lack of consideration for maintenance of the new levees required to offset the effects of sea level rise and subsidence, and , 3. Lack of consideration of seepage and groundwater migration resulting from the creation of the new may. lagoon. hank you for your consideration. {s.�.. ' Sincerely . '1 Douglas B. Flett `RCE 0 15227 :t 5 BIMID Comments, page 24 D. Walnut Creek, CA 94596 (415) 935 7710 B. FLE'I'T& ASSOCIATES, INC. 1280 Civic Drive, Suite 210, P.O.Box 761 Bethel Plaza, Bethel Island,CA 94511 4151684-3470 SURRIU� .::ENGINEERING C,.Eng.No.26M4 • Gen.Eng.Con.Co.41WW July 2, 1989 U.S. Army Corps of Engineers Sacrarr-tento District Re: Public Notice 6063A Delta Coves, Bethel Island There is new information available since 1978 that is useful in evaluat- ing the impacts of the proposed Delta Coves project. SUBSIDENCE: The problem of subsidence in the Delta is not new. But, there have been studies since 1978 that have given.us new information on causes and rates. The Department of Water Resources published a report in August 1980 entitled "Subsidence of Organic Soils in the Sacramento-San Joa(Tain Delta." Although there was insufficient data for the authors to estimate a sUbside�-�ce rate for Bethel Island, a subsidence rate of 0.5 inches per year due to natu- ral gas removal was reported for the Rio Vista Gas Field, (Table 5) . Figure 2 showed that Bethel Island is adjacent to the active Dutch Slough Gas Field. The Department .of Water Resources published a report in December 1986 entitled "Delta Subsidence Investigation." Included in the recomnendatians was the installation -of c ompaction recorders (extensometers) that could measure E the overall rate of subsidence and differentiate the rate of deep subsidence from .the rate of shallow subsidence. Bethel Island was identified as one of nine sites because of its "proximity to areas where subsidence is of special concern because of past, present, and future gas withdrawal" (page 46) . The instrument was installed on Bethel Island in 1988. Another recocimendation of the report was the use of the Global Positioning System (satellite surveying) to determine land surface elevations throughout the Delta to measure future subsidence rates. BIMID Comments, page 25 - ' Geological Survey published a report entitled "Determination of The U.S.U.S. Geo l mark Elevations at Bethel Island and Vicinity, Contra Costa and San aquin Counties, California, 1987." Conventional spirit leveling surveying ,.r:_':�=y". ': Sing. a benchmark on bedrock near Marsh Creek Reservoir (.T934) was used to tie , ,. several benchmarks in the Bethel Island area. USBR BM on Hotchkiss Tract at `the fish screens of the Contra Costa Canal intake was reported to have an :elevation of 11.14 NGVD Datum of 1929. ......1M The Department of Water Resources published a preliminary report in August 1988 entitled "A GPS Control Survey for the Delta Planning Branch." The '- ults of the initial satellite sur included the elevations of three Y A" y' ���,�,:;_;;;a�• benchmarks in the Bethel Island area. One benchmark is located within the `;'Delta Coves project site. A primary control network of stable benchmarks on r •;.,the perimeter of the Delta, including T934 at Marsh Creek Reservoir was used ;: a basis. The GPS elevation for benchmark "5255" located at the fish screens the Contra Costa Canal intake was reported to have an elevation of 10.17 NGVD Datum of 1929, 1.0 feet lower than previously reported. Another s benchmark' "6055" located on Jersey Island near Jackass Point and adjacent to e north side of Bethel Island was reported to have a GPS elevation of 2.49 ;feet. That is 2.0 feet lower than previously reported by conventional spirit ;..:.;:leveling. There are differences between the results of the two methods of survey- The USGS 'report includes the following guideline: "Until additional data are available surveys referenced to Na- tional Geodetic Survey bench marks in the study area may assume that the published adjusted elevations reflect changes caused by both land subsidence and adjustment procedures. As such, eleva- ``' tions to a new site based on a bench mark with adjusted elevations could be in error by as much as 0.6 ft, but will probably average about 0 The logical conclusion of the foregoing is that subsidence does occur in Bethel Island area, and although it is being studied with sophisticated iques, its rate is yet unknown. Thus, the design of the Delta Coves ;.'project should incorporate the newest information available and include provi- to protect the project's houses as well as the perimeter levee protect- , s?�� ng Bethel Island from future subsidence. The project as presently designed, ,z I =unposed of houses constructed on top of finger levees with minimum pad F"; eleva- } lions of 9.75 ringed with a 3-foot or 5-foot wide setback strip does not lend F. t.,:.... . .VI •�'" '�° ltsel f to future raisin ON � ;- r:..,.. g o y f freeboard. Neither is there an location shown •;:::,.;� :,, gal , � ,,: ong the perimeter levee to provide room for future raising of freeboard. est? :• .,,::.. ._;,,There also should be conservative consideration given as to what benchmark and r E *''.."elevation is used for vertical control for the project construction. 'rig BIMID Comments, page 26 =F; gEp,-LEVEL RISE: A problem that was not even recognized at the time the EIS was written in 1978 is global .warming from the greenhouse effect and the resulting rise in ,t:. sea level . "Delta Levees Investigation, Bulletin 192-82" by the Department of Water Resources, dated December 1982 reported that there was an increase in average 3::; . ocean levels at the Golden Gate, and that a tentative study indicated a 50- " `' year trend of 0.08 inches per-' p year (page 44) . In 1987, a study on future sea level rise prepared for the San Francisco Development Commission re gay Conservation and ported.that int e previous 19 years, there had been an average sealevel rise of 0.0072 feet per year at the t.}` Golden Gate. In October of 1988, U.S. Congressman George Miller sponsored a hearing for the House Subcommittee on Water and Power Resources in San Francisco on �- the greenhouse effect. Dr. Robert W. Buddemeier, University of California, r .: = Lawrence Livermore National Laboratory, presented a paper, "The Impacts of Climate Change on the Sacramento-San Joaquin Delta" which included the follow- `.'....w ing statement: "When we consider sea level rise predictions alone, we see that we Ty canexpect to have to raise and strengthen the levees to withstand water levels of at least 3 feet higher within the next century, and that a significant fraction of that increase in water level will occur within the next few decades. (Implications of Global .� Warming for Natural Resources, Oversight Hearings before the Subca mit ,.ee on Water and Power Resources of the Committee on ' Interior and Insular Affairs, House of Representatives, U.S. Government Printing Office, 1989) The revised Specific Plan for the Bethel Island Area by Contra Costa I + ' County dated June, 1989 assumes a four foot rise in sea level over the next j 100 years for planning purposes. This new information should be considered in the design of a major = project such as Delta Coves. Provisions should be made in the design to allow for raising of freeboard, . not only to protect the project, but Bethel Island + `r - as well . :. SEEPAGE: err. =j ,` BIMID Comments, page 27 In the State of California's Flood Hazard Mitigation Plan, dated August 21, 1986, seepage is identified as a factor that contributes to levee failures (page 7); "Increased moisture from seepage through and under levees, which t reduces the shear strength of soils and thereby contributes to instability of }` the levees." The Plan also recognized that the "Flooding of islands can have ;= several adverse impacts, including. . .increased seepage on islands adjacent to the flooded areas." � . . r: In discussions with other Reclamation District engineers the author has learned of the following experiences: a. A water well in the interior of Bradford Island began flowing artesian when neighboring Webb Tract flooded. b. Lower Jones Tract experienced increased seepage when McDonald Island flooded and vice versa. The seepage disappeared after the neighboring island was pumped dry. C. McDonald Island and Bacon Island experienced increased seepage after Mildred Island flooded. d. The author has noted that within days after Holland Tract flooded on January •18, 1980, during a period of , high rainfall , Contra Costa County Sanitation District No. 15 experienced abnormally high sewer flow (almost five times subsequent average flows) . Since 1980 there .#. i have been other periods of high rainfall that were not accompanied by the high sewer flows. There was one exception during the winter of 1982-83 when sewer flows rose during a period of local flooding on Bethel Island as drainage pumps failed to keep up with runoff and '= many acres were inundated. It is postulated that a pervious sand strata underlays the islands and r:; �'e.• ..,..:,.'is fairly continuous. Thus, when a island floods the sand strata is exposed to ?E;= an increased hydraulic head driving increased quantities of seepage to the unf 1 ooded neighboring island. The increased head beneath the levees would correspondingly decrease their stability. There is the proposed lagoon with ==:,�:•_ = potential that the excavation for the water surface elevated above the existing ground water table may expose a . pervious and continuous underlying sand strata. The exposure of the sand FF strata to the increased hydraulic pressure from the lagoon may raise the water table in ad jacent areas and increase infiltration into the exist- .` r'?rIng sewer system, increase seepage under neighboring island levees with an " . j'i`;acccmpanying rise in potential for piping, decrease existing levee stability y. -x BIMID Comments, page 28 due to the increased uplift pressure, and increase drainage pumping costs to the District. Impacts that cause increased seepage or decreased levee stability may aggravate conditions at critical points in the existing levee system such as levee encroachments where levee cross section is reduced. Seepage and ground water table rise can be controlled by toe ditches, cutoff walls (impervious barriers through the pervious strata) , interception wells, relief wells, subsurface drainage systems, levee berms, etc. Note that the measures employed should avoid lowering the ground water table in de- veloped areas and the accampanyi.ng undesirable side effects. It is reccarmended that testing be done prior to issuing a Corps of Engineers permit. Such testing should include: A seepage analysis and appropriate testing, including possible effects on the existing ground water table adjacent to the project, on the inflow and infiltration rate of the existing sewer system adjacent to the project, on the seep- age rates and levee stability of Hotchkiss and Holland Tracts, and on the inflow and infiltration rate of the sewer system along Sandmound Boulevard on Hotchkiss Tract. A preconstruction monitoring program (including installation of piezometers) to develop baseline data on existing ground water levels and seepage rates and influences of river stage, rainfall , season, irrigation, etc. on neighboring tracts as well as Bethel Island. CONSTRUCTION DEWATERING: Experiences on Bethel Island during the dewatering for construction of the sewer system in 1979 have emphasized. the fragile nature of the peat soil ringing Bethel, Island. Subsequent to the .sewer construction there were several lawsuits over settlement damage to houses. j: Lowering of the ground water table under the existing levees would increase the effective stress on the foundation materials, as well as increase the amount of peat soil subject to oxidation which may consequently increase the subsidence rate. i r. It is recaTMended that before the Corps of Engineers permit is approved, the following be prepared: BIMID Comments, page 29 A dewatering plan, including preconstruction monitoring to develop baseline data, should be prepared prior to lowering of groundwater elevations. This plan would include adequate setbacks. or dewatering techniques between existing struc- tures and the existing levee and proposed excavations based on actual pumping tests. A monitoring and mitigation plan to evaluate possible im- pacts of dewatering; increased seepage, cracking, slope stability, and long-terms settlement during and after con- struction, including the installation of instrumentation such as piezometers, settlement plates, slope inclinometers, and benchmarks. Plans to stabilize and repair detrimental effects should be prepared. Barbara E. Burns, RC"' BIMID Comments, page 30 FLOOD PLAIN VALUES : Construction of the Delta Coves project would subject all existing island residents to a degree of hazard that does not now exist . In case of flooding , c rrent emergency safety and evacua- tion plans are based on the s ow spread of floodwaters over the entire 3 , 500-acre island plai . In the event of a levee break anywhere on the island, the D Ita Coves project surrounded by its perimeter levee section would remove 310 acres from the island flood plain . The remaining acreage would fill faster and thus cut down on the time available to get existing residents to safety . A large percentage of the existing population resides at ground level in mobile home parks and in. homes that were built before FEMA regulations required elevated structures . District flood J fighting procedures will be hampered by loss of time for imple- mentation. The EIS states on page , paragraph 1 . 15 that the proposed Delta Coves project is similar to Discovery Bay . However , Dis- covery Bay development is situated on a mainland, not an island. ' Should flooding occur in Dis overy Bay , flood waters could spread over an extensive flood plai . I i I� LAND USE: I1 Levees constructed afte March 1988 ( SB-34 enactment date) will not be eligible for state subvention monies . A recent letter (April 6., 1989) to the District ' s engineer from the Department of Water Resources confirms thi : "As you know, the Preliminary Procedures state that : ' . . . t e first priority for funding is for ! levee maintenance and rehabi itation up to the Bulletin 192-82 standards ( for geometry) ass ciated with the existing land use at_ the time SB 34 was signed in -o law . '" [emphasis in original ] IIt should be noted that the Contra Costa County Board of Supervisors unanimously votel to deny the lagoon project during the settlement hearings due o their concerns about safety issues . At the settlement hearing the supervisors did go on record as supporting a conve tional planned unit subdivision development . on the project site . i J iBIMID Comments, page 31 I� 1 NAVIGATION: Navigational requirements of tug. and barge access for main- tenance of the project ' s waterside slopes was not considered in the EIS . These requirements impact the ability to maintain the Delta Coves project in the future , especially in emergency situa- tions . In 1985 , the navigational requirements were studied by the District engineers for Reclamation District 800 when mooring lines were established in a portion of Discovery Bay . The crite- ria developed were based on Corps of Engineers Technical Letter No . .1110-2-225 , "Engineering and Design Channel Widths for Navi- gation in Bends , " and discussions with Dutra Construction Compa- ny , the major Delta barge operator . Influences of wind and cur.- rents were considered. The following parameters were develope4.: Length: 200 ' barge and 80 ' tug = 280 ' total Width: 40 ' Draft : 10 ' Minimum channel width for one way traffic without bends of 120 ' Minimum channel width of 140 ' with minimum 300 ' radius bend. Not only are these criteria not met inside the Delta Coves project as proposed, it appears that they may not be met in the stretch of Sandmound Slough leading to the project . The 14m-ted data published by NOAA on the navigation chart for the area shows depths of 6 feet and 8 feet below mean lower low water in Sand- mound Slough near the project entrance . The design depth for the project entrance is 6 . 7 feet at mean lower low water . Maneuvering room in Sandmound Slough is limited by existing boat docks and mid channel islands . Dimensions appear to be on the order of 14_0 feet width with a 300-foot radius bend around the project ' s entrance wing walls . There are three locations inside the protect where it appears to be less than 120 feet between the ends of the proposed boat docks . . If conventional waterborne maintenance equipment does not have sufficient room for access , particularly in an emergency, there should be alternate methods proposed, such as an access road along the top of the slope for land based maintenance equip- ment . BIMID Comments, page 32 The Corps ' EIS states on page 5 , paragraph 1 . 10 , "When the project is completed, about half of the site will be a lagoon and harbor which will become part of Sandmound Slough waterway . " However, the Corps ' notice, sheet 4 of 7 , shows a harbor entrance sign which reads "Private Harbor . " Sandmound Slough waterway is a navigable waterway and the public cannot be barred from a portion of it . i SHORELINE EROSION AND ACCRETION : There are potential erosion problems with the waterside levee slope "benches" as shown on sheet 5 of 7 in the Corps public notice and on the Final Development Plan ( 3024-82 ) . Ac- cording to the public notice diagram, the proposed individual docks are to be constructed over the "bench" area . At low tide or a minus tide the floating dock could come to rest on the "bench" area . over time this contact could erode the bench area if it is constructed as shown . The bench area could also cause damage to boats and docks at low tide, thus encouraging homeowners to excavate and remove rip rap on the levee slope . It is also likely that the square corners on the lagoon fingers as shown in the plan will erode rapidly due to wave wase and tidal action. Preventing erosion and maintaining square corners will increase labor and materials costs . WATER QUALITY : According to the conditions of approval (22 & 23) for Contra Costa County Tentative Subdivision Map No . 6013 (Delta Coves) , lagoon maintenance will be undertaken by BIMID. The original Army Corps ' permit was based on the 1978 EIS which states on page 3 , paragraph 1 . 07 , "A water circulatory i system will be installed which will help provide water quality maintenance . Bethel Island ' s Municipal Improvement District will operate the water circulation system in the lagoons as needed to prevent stagnation. " On page 32 , paragraph 4 . 29 of the EIS it says , "The pumping system will circulate water from Sandmound Slough to all lagoon areas . . . Stagnation will be controlled by scheduled operation of these pumps by Bethel Island Municipal Improvement District . " Further, on pages 49 and 50 of the final BIMID Comments, page 33 1 i EIS in response to comments 6 and 12 regarding the monitoring of water quality, the responsibility was indicated as BIMID ' s . The response to comment 6 says "The responsibility of monitoring . water quality problems within Delta Coves and operation of the pumping facility, will be that of the Bethel Island Municipal Improvement District . " Provisions have to be made to fund BIMID' s initial expendi- tures for water quality monitoring equipment . Funds will also be required to hire and train personnel in water quality management systems and applications prior to the assumption of duties . Lagoon water quality management costs are a major component of the annual budget in reclamation districts which have water quality control responsibilities . A water quality control assess- ment for Delta Coves landowners will be required to fund the ongoing costs of lagoon maintenance by BIMID. The proposed configuration of the lagoon fingers will pose substantial problems for water quality control . Prevailing winds are predominately from the W-WNW in Bethel Island . These winds are persistent in the summer (Draft Environmental Impact Report , Bethel Island Area Specific Plan, January 30 , 1989 , page 21.77219 , figure 24) . Winds blowing persistently from the west-northwest will constantly push debris into the lagoon cul -de-sacs created by fingers as proposed in the plan. The accumulation of debris will create unnecessary additional cleaning and removal opera- tions to prevent accumulation of waterborne debris (including oily residue common to all harbors ) under the docks in the cul -de-sac areas . This water quality control problem could be mitigated by a reconfiguration of the proposed lagoon fingers . Another water quality control problem will be created by the construction of the proposed 15- or 10-foot "benches" in the waterside levee slopes ( "benches" shown on Contra Costa County ' s Final Development Plan are 15 ' , those on sheet 5 of 7 in the Corps public notice are shown as 10 ' ) . At low tides and minus tides these benches will lie in shallow water . A shallow , warm water environment promotes growth of wetland plants as well as algae . Wetland plants such as tules in and around docks and the proposed dock anchor cables will entrap surface scum and algae blooms . This will create a visual and odor problems requiring intensive hand labor maintenance. The 1978 final EIS states on page 50 in the response to BIMID Comments, page 34 Comment 13 : "The developer has indicated that facilities on the docks will be available for oily waste . " Clarification is needed here as there is no indication in the Corps '- Public Notice sheet 5 of 7 ( individual docks) and sheet 6 of 7 (marina . docks ) of separate facilities on the docks for oily wastes . Holding tanks with discharge pumps to house sewer connections are shown on the drawings , but it is doubtful that oily waste would be accepted by Sanitation District 15 or the Oakley-Bethel Island Wastewater Treatment Plant . GENERAL NEEDS AND WELFARE OF THE PEOPLE : Bethel Island Municipal Improvement District requests that a public hearing be held on the island to consider this applica- tion. The Delta Coves project has aroused much public interest and apprehension in the Bethel Island area. A public hearing will help the Army Corps determine whether or not the benefits of the proposal can be balanced against the reasonably foreseeable detriments . The developer will have to obtain permits from BIMID for breaching the island levee , grading , drainage improvements , and construction of the project . The Improvement District was created by an act of the California State Legislature (BIMID Act , Statues of 1960 , Chapter 22 ) to maintain the island' s levee and make and enforce all necessary regulations for reclamation service . In addition, the District has property interest in the levee pro- tecting Bethel Island by virtue of the history of reclamat=on on the island. This interest is independent of any regulatory power conferred by the BIMID Act or other statutes . The District foresees problems in obtaining adequate insur- ance if this project is constructed as proposed with inadequate building setbacks from the waterside on the perimeter levee and lagoon fingers . Recent news articles called attention to disputed insurance coverage in Discovery Bay, a lagoon development in Contra Costa County with houses near the waterside edge of the levee . According to one article (Brentwood News , Tuesday , May 9 , 1989) , slope failure caused extensive damage to a house on Drake' s Drive. When slope failures occur , as they do even in new engineered levees , house foundations are in jeopardy if the houses are situated near the levee ' s waterside edge . BIMID Comments, page 35 These comments contain two engineering reports by independ- ent consultants which discussed the potential flooding hazard of the Stone Road corridor. Both reports found that a break in the existing levee along the corridor would cause major property damage and hazards to life . Consultant Meehan suggested that the potential problem could be mitigated by completely rebuilding the existing levee along Stone Road . Short of this , the District ' s position on this matter is that there is no compelling reason to place existing residents in a potentially hazardous situation, or in fear of a potential hazard. No overriding considerations of economic or social benefit have been shown which would justify approval of the permit without mitigation of this significant hazardous environmental effect . BIMID Comments, page 36 . APPENDIX \ Figures 15a and 16 from the Draft EIE for the ` \ Bethel Island Area Specific Plan, 1989 Soils Engineer's report on cavity in Bethel Island \ . . levee, January 21 , 1980 \ \ Comments on 1978 Drat EIS from State of Cali£or- / \ Sia Resources agency , pages 4 , 5 . and 6 regarding \ ?. potential levee failure concerns . \ \ / \ A \ $ � . � y . ± 2 / \ . \ \ `s ca a) d T•;" 'u �a i s s p N i � G •ct � N � Ct tiJ U N U U 3 n n. •ij.s p �N p N p ire-, 1 0 � U N 0 v� p 1 _ t t t / FRANKS TRACT �I J� (n.a RaaAiia ARA) it s4A� Q . FRANKS TRACT WAI[ MCAWl ARA) v C eEtrn O I JERSEY ISLAND • I 0 o oma. 9 p p � O i (B GhSO 00OJrp�d �r,ag Planning Area Wetlands Figure 16 -�5LODc3C0u0C P ® Permanent Wetlands(Riparian,Marsh;Mixed Wetlands) ® Seasonal Wetlands(Perennial Herbs) JJ A[. D +oo 1600 2400 3200 4000 Ruderal Wetland/Upland(Mostly Peppergrass Dominated) LISA KIRK PO BOX 435 BF_-,T•M I:5I2AN1), CA 94511 925-684-9250 05-23-2206 MEMBERS OFTHE BOARD OF SUPERVISORS CONTR COSTA COUNTY GRADING PERMIT 348984 I WOULD LIKE•1'O•THANK THE BOARDTODAY FOR THE OPPORTUN1.1'Y TO GIVE PUBLIC TESTIMONY ON THE DELTA COVES GRADING:PERMIT. I UNDERSTAND THE BECAUSE OF THE 1989 LAWSUIT TLiDG1,.4ENT, THAT IT PROHIBITS THE COUNTY FROM DENYING T11E ISSUANCE OF THE GRADING PERMIT FOR THE PROJECT. WHICH WOULD EXPLAIN THAT ALTHOUGH I FILED THE APPEAL ON 10-3I-2005, THE GRADING WAS ALLOWED TO PRECEDE IN MARCH OF 2006 AND THIS HEARING WAS NOT SCHEDULEIJ UNTIL MAY OF 2006, THE 16 YEAR OLD JUDUMEN•T HAS ALSO DENIED MY RIGHT ASA CITIZEN, AFFECTED BY THE DEVELOPMENT,TO INCORPORATE MY CONCERNS REGARDING PUBLIC SAFETY. I AM NOT HERE TODAY TO STOP OR HINDER THE DELTA COVES PROJECT, ACTUALLY I THINK, NEW RESIDENTS MOVING TO BETHEL ISLAND, WILL BE A GREAT BENEFIT•1'O THE COMMUNITY IN MANY WAYS. BUT, THE 38 CONDITION THAT FOLLOWED THE LAWSUIT,COULD HAVE NOT FORSEEN THE CHANGES OCCURRING IN THE DELTA AND TFM PROBLEMS ASSOCIATED WITH , DEVELOPMENTS IN THE FLOOD PLAIN. MY CONCERNS ARE 1. THE CHANGE IN THE ARMY CORP POSITION AS IT RELATES TO CONDITION 11. 2. THE COUNTY OVERSIGHT AND PFRAUTTING OF A BREECH STRUCTURE TI2E 3.. THE LACK OF THE CURRENT APPROVAL,FROM BETHEL ISLAND MUNICIPAL DISTRICT IMPROVEMENT DISTRICT AS IT RELATES TO THE COUNTY GRADING ORDINANCE 716-2.606 AND BIMID'S OWN ORDINANCE 9 4. THE LACK OF STUDIES REGARDING THE USE OF DEEP DYNAMIC COMPACTION IN FLOOD PLAINS AND THE 1N•7PACT TO ADTOINTING PROPERTIES AND LEVEES. 5. THE BUILDING OF NEW LEVEE OF FINE TO MEDIUM GRAINED SAND. ARMY COE LETTER PLEASE NOTE A J-UNF 0 1995 TETTER FROM THE US ARMY CORPS OF ENGINEERS, STATING TO MR WEISENBUR.G,"THAT THE COE WILL NOT EVALUATE OF VALIDATE YOUR LEVEE DESIGN". THE DEPARTMENT OF THE ARMY EVALUATION AND DECISION DOCUMENT SIGNED 6-1-1998 PAGE 27 STATE THAT THE COE WILL REVIEW THE PLANS AND DESIGNS TO ENSURE HAVE BEEN DEVELOPED AND REVIEWED BY LICENSED PROFESSIONAL ENGINEERS, ONLY. THE 1989 CONDITION 11 STATES THAT GRADING PLANS SHALL INCORPORATE LIQUEFACTION-RESISTANT DESIGN ACCEPTABLE TO THE CORPS OF ENGINEERS,YET THE 1995 AND 1998 DOCUMENTS FROM THE COE STATES NO EVALUATION OF THE DESIGN, ONLY REVIEW IS TO CONFIRM THAT PLANS AND DESIGN HAVE BEEN DEVELOPED AND REVIEW BY LICENSED ENGINEERS. page 1 S ee�e STEEFEL, LEVITT & WEISS A Professional Corporation Author's Direct Dial:(415)403-3386 E-Mail: jtruxaw@steefel.com May 22, 2006 16860 Chair John M. Gioia and Board Members Contra Costa Board of Supervisors 651 Pine Street Martinez, CA 94553-1229 Re: May 23, 2006 Board Agenda Item D-4: Lisa Kirk Appeal Dear Chair Gioia and Members of the Board of Supervisors: LB/L Duc III Bethel Island LLC ("Duc" herein) respectfully requests that the Board deny the appeal filed by Lisa Kirk in the matter of the Delta Coves Grading Permit for the reasons stated herein together with the reasons set forth in the Staff Report prepared for.this matter. Below we first respond to the appeal as filed by Ms. Kirk on October 31, 2005. Following that, we respond to issues raised by her attorney, Ellison Folk, in a letter to the Board dated May 8, 2006. Kirk Appeal The County issued the grading permit for the Delta Coves project on October 6, 2005. The permit remains in effect and grading operations have been underway since late March. Ms. Kirk filed her appeal on October 31, 2005 pursuant to the provisions of sections 14-4.002 and 14-4.004 of the Ordinance Code of Contra Costa County. Failure to Verify Appeal: Failure to Specify Injury,Not an Aggrieved rieved Person Sections 14-4-002 and 14-4.004 of the County Code provide that "any person aggrieved by an administrative action" shall "file with the clerk of the board a verified written notice of appeal concisely stating the facts of the case and the grounds for his appeal including his special interest and injury." The code defines verification at section 16-4.004: ""Affidavit," "certificate" and "verification" include declarations under penalty of perjury." Ms. Kirk's letter of appeal is not verified and thus is not properly before the Board. Although the code does not specifically define the term "aggrieved", general use of the term requires that to be aggrieved, a person must be able to specify an action that has caused them individual injury. Ms. Kirk makes no attempt in her appeal to explain how she has been injured by the County's decision to issue a grading permit and she provides no special interest or One Embarcadero Center,30th Floor,San Francisco,California 94111-3719•Phone:(415)788-0900•Fax:(415)788-2019 San Francisco,CA Los Angeles,CA Stamford,CT www.steefei.com � f Chair John M. Gioia and Board Members lU UUIU May 22, 2006 l� eelG Page Two STEEF11,EEVITT&WEISS injury supporting her appeal. As such, she is not a "person aggrieved" by the decision. Because her letter of appeal does not satisfy the requirements of section 14-4.004, it must be denied. Vested Right As noted above, the County issued the grading permit in early October and it has remained in effect ever since. Although Ms. Kirk filed this appeal in late October, she apparently made no effort to have the matter heard "at an early regular board meeting" as is required by the Code. In the meantime, Duc has commenced and continues extensive grading operations at the site in full conformance with the conditions of the permit. Duc has a vested right to continue its grading operations. BIMID Approval The staff report responds to Ms. Kirk's BIMID related issues and we concur with staff's responses. The County has issued the grading permit in full compliance with all County regulations and project specific, court ordered conditions of approval. BIMID agreed to accept maintenance of the levees and breach structure to be built pursuant to the grading permit at a pubic meeting held in February 2005. After that meeting, the BIMID Board received and considered the reports and recommendations of its consulting geotechnical engineer, Kevin Tillis, and consented to the work being performed under this permit. By letter dated August 9, 2005 to Kevin Emigh of Contra Costa County Public Works, Mr. Tillis confirmed that mass grading of the site could commence. On August 18, 2005 the BIMID Board accepted a written and oral status report on the grading plans from Mr. Tillis. In his letter, Mr. Tillis explains that "The grading plans are essentially complete and Contra Costa County (County) is close to issuing a pen-nit for grading. ... We conclude that the project plans have sufficient detail for the contractor to proceed with initial grading." Minutes of the meeting reflect that during Mr. Tillis' presentation, he informed the BIMID Board that "The County is ready to issue a grading permit ..." Between August and October, Mr. Tillis continued to review submittals made to the County in furtherance of the grading permit and he consented to its issuance. Minutes of the October 20, 2005 BIMID meeting reflect that at the meeting Mr. Tillis informed BIMID that a grading pen-nit had been issued, that initial clearing had begun and that "The main construction could start in about one month." The minutes reflect that Ms. Kirk was present during this presentation. Mr. Tillis and District Manager Paul Harper were present at an on-site preconstruction meeting held just prior to the commencement of grading operations in mid-March, 2006 and consented to the commencement of grading. Although, as the staff report notes, BIMID approval is not required prior to the issuance of the grading permit, nevertheless, BIMID has been aware of and has reviewed and signed off on the grading plans at all relevant times. r f Chair John M. Gioia and Board Members Lamle May 22, 2006 l� eelG Page Three SiEEEEE,EEVIi1&WEISS Ellison Folk letter Failure to Verify Appeal; Failure to Specify Injury; Failure to Appeal Within 30 Days As noted above, an appeal brought pursuant to section 14-4.002must be filed within 30 days of the action being appealed from and must include "a verified written notice of appeal concisely stating the facts of the case and the grounds for his appeal including his special interest and injury." Ms. Folk's letter, to the extent it would amend Ms. Kirk's appeal, is not verified and fails the first requirement. Similar to Ms. Kirk's letter, it specifies no special injury suffered by the appellant. Additionally, the 30 day requirement clearly, if implicitly, includes a requirement that the appellant state his or her grievances within 30 days of the date of the action. Ms. Folk's letter impermissibly seeks to broaden the appeal beyond the grounds for the appeal provided during the 30 day period by Ms. Kirk. Because her letter is not verified, specifies no special interest or injury and because it seeks.to broaden the scope of the appeal beyond the issues raised within the 30 day post-action period, it should be disregarded by the Board. Alleged Violation of County Code section 716-2.608 Ms.,Folk argues that the issuance of the grading permit violates County Code Section 716-2.608. Section 716-2.608 of the County Code provides that "No person shall excavate, or remove any material from any levee or do any work on levees required for river or local drainage control without prior approval of the local governmental agency responsible for the maintenance of the levee." In this instance, "the local governmental agency responsible for the maintenance of the levee" is BIMID, the Bethel Island Municipal Improvement District. BIMID Consent As explained above, BIMID's consulting engineer and its District Manager have reviewed and signed off on the grading plans. Although Ms. Folk mischaracterizes section 716- 2.608 by stating that the required approval must be in writing, nevertheless the requirement was satisfied in writing when on February 3, 2005, the BIMID Board adopted its resolution 05-02-03 and agreed to maintain the perimeter levees together with the breach structure. Prior to adopting that resolution, the BIMID Board received a written report and a lengthy and detailed oral report from consulting geotechnical engineer Tillis regarding the nature of the levee and breach improvements to be constructed at Delta Coves. Additionally, beginning even before the adoption of Resolution 05-02-03 and continuing up to the day grading operations began at Delta Coves, BIMID, acting variously through its Board, District Manager Harper and consulting geotechnical engineer Tillis, has reviewed and = Chair John M. Gioia and Board Members lU UUIU May 22, 2006 l� eelG Page Four STEEEEE,EEVITT&WEISS approved the grading plans, including levee and breach construction details.' By letter dated August 12, 2005, consulting geotechnical engineer Tillis informed the BIMID Board that "The County will require that BIMID sign the improvement plans because the plans include improvements BIMID will operate and maintain. BIMID does not need to sign the grading plans." Mr. Tillis delivered this letter with additional oral commentary to the BIMID Board at its meeting held August 18, 2005. On March 23; 2006, prior to the commencement of grading operations, a preconstruction meeting was held at the project site with both Mr. Tillis.and Mr. Harper in attendance representing BIMID, as well as appropriate County officials. By their presence at the pre-construction meeting, BIMID informed the County of its consent to the work to be undertaken pursuant to the grading permit. Approval of the Breach. Regarding the breach structure, as noted above, BIMID agreed to maintain the breach structure by resolution adopted in February 2005. Mr. Tillis' August 12, 2005 letter to BIMID states that "We have agreed in concept to the basic elements of the double sheetpile wall breach structure design, although the current plans do not reflect final changes. Details of the breach structures and sequence of construction are important to assure that the existing levee is not damaged during construction. A construction sequence and final plans for the breach structures and levee breach are needed prior to their construction. The construction sequence should include an evaluation of deformation that may occur during construction." After the date of that letter, Mr. Tillis continued to review and approve breach and levee construction details shown on the grading plans up until the County issued the grading permit in October, 2005. CEQA The approval of a grading permit by the County Department of Building Inspection for the Delta Coves project requires the ministerial application of the County grading ordinance to the grading plans and is not a project under CEQA; the issuance of the grading permit does not give rise to any of the CEQA related issues raised. 'Conclusion In conclusion, Ms. Kirk is not an aggrieved persons, she did not verify her appeal and she has not raised any issues that would support any action by the Board to affect Due's vested rights in its grading permit for the Delta Coves project. Ms. Folk seeks improperly to expand the issues on appeal which she cannot do in view of the limited period of time in which an appeal can be brought after the date of the action on appeal. Regardless, BIMID has consented to the Construction of the breach structure and other construction activity that will occur on the levee is detailed in and approved by the approved grading plans. r Chair John M. Gioia and Board Members lU U U l U May 22, 2006 l� eelG Page Five STEEEEE,EEVITT&WEISS grading operations including the construction of the breach. For these reasons, the Board should deny the appeal. Very truly yours, Jo' Tru.xaw JWT/jcc cc: Sylvano Marchesi Carlos Baltodono 16560:6507475.6 RECEIVED h DUC MAY 1 S 2006 HOUSING ER CLK BOARD OF SUPERVISORS PARTNERS,INC. CONTRA COSTA CO. VIA FACSIMILE& U.S. MAIL May 11, 2006 Mr. Silvano Marchesi Contra Costa County 651 Pine Street, 9th Floor Martinez, CA 94553-0095 RE: DELTA COVES -TRACT 6013 — BETHEL ISLAND, CA Dear Mr. Marchesi: As owner of the above referenced property, LBL— Duc III Bethel Island LLC respectfully requests that the County please forward any correspondence or requests for information that is received or submitted regarding Tract 6013. We ask that you notify all pertinent county personnel of this request. Copies of these inquiries should be forwarded to: Michael Cady Duc Housing Partners 14107 Winchester Blvd., Suite H Los Gatos, CA 95032 (408) 866-5511 FAX (408) 866-5501 John Truxaw Steefel Levitt &Weiss One Embarcadero Center, 29th Floor San Francisco, CA 94111 (415) 788-0900 FAX (415) 788-2019 Please call me at (408) 866-5511 x.211 if you have any questions or require-additional information. Sincerely, DUC HOUSING PARTNERS, INC. AS MANAGER OF L�B�L —/CDUC III BETHEL ISLAND LLC Michael B. Cady c: County Clerk Carlos Baltodano, CCC Building Inspection Dennis Barry, CCC Community Development 14107 Winchester Blvd.,Suite H ■ Los Gatos,CA 95032 ■ (408)866-5511 Fax(408)866-5501 www.duchousing.com mG �N N � �r L13 F,Qy � ti e d o U. ccN II.I 431INO o o �= r Q" cr ... r R ----- —=_= d, Ln n.� o la' Itl t7' M O LA Q u N O Y ro t� S CG ?Q Li �n V.) Lei NN V U-IWO x `° a Gr Q �O" Q = c, f o V U V r. D U C HOUSING RECEIVED PARTNERS,INC M AY 11 2006 VIA FA SIMILE& U.5, MAIL CLERK BOARD OF SUPERVISORS CONTRACOSTA CO. May 11, 2006 Mr. Silvano Marchesi Contra Costa County 651 Pine Street, 9th Floor Martinez, CA 94553-0095 RE: DELTA COVES -TRACT 6013 — BETHEL ISLAND, CA Dear Mr. Marchesi: As owner of the above referenced property, LBL — Duc III Bethel Island LLC respectfully requests that the County please forward any correspondence or requests for information that is received or submitted regarding Tract 6013. We ask that you notify all pertinent county personnel of this request. Copies of these inquiries should be forwarded to: Michael Cady Duc Housing Partners 14107 Winchester Blvd., Suite H Los Gatos, CA 95032 (408) 866-5511 FAX(408) 866-5501 John Truxaw SLeefel Levitt& Weiss One Embarcadero Center, 29th Floor San Francisco, CA 94111 (415) 788-0900 FAX (415) 788-2019 Please call me at (408) 866-5511 x,211 if you have any questions or require additional information. Sincerely, DUC HOUSING PARTNERS, INC. AS MANAGER OF LBL— DUC III BETHEL ISLAND LLC Michael B. Cady C: County Clerk Carlos Saltodano, CCC Building Inspection Dennis Barry, CCC Community Development 14107 Winchester Blvd.,Suite H ■ L05 Gatos,CA 95032 ■ (408)866-5511 ■ Fax(408) 866-5501 ■ www.duchousIng.corn N D�JC L'OUQj�j1C, A 14107 Winchester Blvd., Suite H DUC Los Gatos, CA 95032 -5511 HousING PH : 408 / 866 PARTNE'FtS, INC. FX: 408 / 866-5501 Fax Coversheet To: Silvano Marchesi From: Michael Cady County Clerk Carlos Baltodano Dennis Barry Company: Contra Costa County Date & Time: 5/11/06 1:20 PM Fax: (925) 646-1078 Pages: 2 (including cover page) (925) 335-1913 (925) 646-1219 (925) 335-1299 cc: John Truxaw Re: Delta Coves - Tract 6013 (415) 788-2019 El Urgent 0 For Your 0 Per Your 0 Please Reply 0 Please Review Request Recycle Comments: Building InspectionCOntra CarlosBaltodano Department . ' Director of Building Inspection Costa County Administration Building County 651 Pine Street, 3rd Floor, North Wing Martinez, California 94553-1295 (925) 646-4108 FFAC\, FAX (925)646-1219 z/" RECEIVED � �•�"yam`-`�z; MAY t ]. 2006 CLERK BOARD OF SUPERVISORS CONTRA COSTA CO. May 9, 2006 Shute, Mihaly & Weinberger, LLP Attn: Ellison Folk Attorneys at Law 396 Hayes Street San Francisco, CA 94102 Appeal of Grading Permit No. 348984 Dear Ms. Folk: This letter is to confirm that the Board of Supervisors continued the hearing on the above referenced appeal to May 23, 2006 at 1:30 p.m. Sincerely, Carlos Baltodano Director CB:nr cc: Silvano B.Marchesi,Esq.,County Counsel Lisa Kirk,P.O.Box 435,Bethel Island,CA 94511 John Truxaw,Attomey at Law,One Embarcadero Center,30th Floor,San Francisco 94111-3719 Jane Pennington,Clerk of the Board [cb:\grading.kirk2] Postal (Domesticn CERTIFIED MAIL. RECEIPT n =or deliver-y-1-nformation visit our website at nj -- Postage $ Certified Fee Return Reciept Fee Postmark (Endorsement Required) Here ZI Restricted Delivery Fee a (Endorsement Required) X Total Postage&Fwec. � Sent To Ellison Fork street, dpt No:;" SHUTE,MIHALY&WEINBERGER LLP or Po Box No. 396 Hayes Street City,State,ZIP+� San Francisco, CA 94102 :rr I.S. Postal Service,. (DomesticCERTIFIED MAILT. RECEIPT -n For delivery Information visit our website at www.usps.como 0 Postage $ -r Certified Fee O E:3 Postmark Return Reciept Fee Here M (Endorsement Required) C3 Restricted Delivery Fee o3 (Endorsement Required) —0 ra Total Postage&Fees_ C3 Sent To ______ Lisa Kirk orPOox P.O. Box 435 city,§iaie,"zrP+: Bethel Island, CA 94511 9191 :r. J CL = 0 o — Co U- c7 '03 VIS03 VHIN03 6 SUOSIAU3dne go auvos mum Z E OU)1 90 01 8 1 �vw E a.D no (13AI333H N cc us kD C) r-4 as 0 E E 0 0 Ln ce-, Ln 0 w CL U (v rn J4> U C- V) V) cr 4- 0 w CL CO 0 u ru C: 0 CLfd CLis 0 0 Ln u to (3) U) W Z t SO p�Z L t O\A �w o 9 N 06 N '= co p � 0 O M 1 O �f� / �c6 i of N 0 U vo Ck- W r� N Y • N _ 2 7 BOARD OF SUPERVISORS, CONTRA COSTA COUNTY, CALIFORNIA AFFIDAVIT OF MAILING IN THE MATTER OF Grading Permit Appeal Hearing for: Lisa Kirk P.O. Box 435 Bethel Island, CA 94511 Notice of hearing for Tuesday, May 23, 2006 at 1:30 p.m., was mailed this day, Wednesday, May 10, 2006. I declare under penalty of perjury that I am now, and at all times herein mentioned have been, a citizen of the United States, over age 18; and that today I deposited Certified Mail with Contra Costa County Central Service for mailing by the United States Postal Service in Martinez, California, first class postage fully prepaid, a copy of the hearing notice, on the above entitled matter to the following: Lisa Kirk P.O. Box 435 Bethel Island, CA 94511 Ellison Fork SHUTE, MIHALY &WEINBERGER LLP 396 Hayes St. i San Francisco, CA 94102 I declare under penalty of perjury that the foregoing is true and correct, at Martinez, California. Dated: May 10, 2006 Katherine Sinclair, Deputy Clerk Clerk of the Board of Supervisors Contra Johil 0111en ('Jerk,of the Board Costa and COUIlLy Administration Boddin- Counn,Adnifilisnaint 651 Pine Street. Room 106 County (92' ;;;_Dion Martinez, California 945,53-4068 S-E .John Gioia.District I Gavle 11.llilkerna.District 11 Mary N.Piepho,District III V Mark DeSaidnier. District IV Federal 1).Glover, District V 'N! SQA'coiiri'�'i May 10, 2006 Lisa Kirk P.O. Box 435 Bethel Island, CA 94511 RE: CONTINUATION OF THE ADMINISTRATIVE APPEAL OF THE ISSUANCE OF A GRADING PERMIT FOR DELTA COVES DEVELOPMENT PROJECT You are hereby notified that Tuesday, May 23, 2006 at 1:30 p.m. is the date and time set for the hearing of your appeal from the decision of the Building Inspection Department, Contra Costa County, Martinez, California. The hearing will be held in the Board of Supervisors Chambers, Room 107, 651 Pine Street, (comer of Pine and Escobar Streets) Martinez, California. If you challenge this matter in Court, you may be limited to raising only those issues you or someone else raised at the public hearing described in this notice, or in written correspondence delivered to the County at, or prior to,the public hearing. Very truly yours, John Cullen, County Administrator. and Clerk of the Board By Brine Sinclair, Deputy Clerk K Attachment cc: County Counsel Carlos Baltodano, B.I. Dennis Barry, CDD Clerk of the Board of Supervisors Contra .1(11111('1111en Clerk(1i'llic Board and Countv Administration BuildinL, Costa Cnunty Admmianiloi 651 Pine Strect. Room 106 - County (925)3'15-1900 Martinez, California 94553-4068 John Gioia.District I .0- 0,' Mary N.Piepho,District flI -P. Mark DeSafflnier,NM-ici IV Federal 1).Glover, Distrid V Sra cou May 10, 2006 Lisa Kirk P.O. Box 435 Bethel Island, CA 94511 RE: CONTINUATION OF THE ADMINISTRATIVE APPEAL OF THE ISSUANCE OF A GRADING PERMIT FOR DELTA COVES DEVELOPMENT PROJECT You are hereby notified that Tuesday, May 23, 2006 at 1:30 p.m, is the date and time set for the hearing of your appeal from the decision of the Building Inspection Department, Contra Costa County, Martinez, California. The hearing will be held in the Board of Supervisors Chambers, Room 107, 651 Pine Street, (comer of Pine and Escobar Streets)-Martinez, California. If you challenge this matter in Court, you may be limited to raising only those issues you or someone else raised at the public hearing described in this notice, or in written correspondence delivered to the County at, or prior to,the public hearing. Very truly yours, John Cullen., County Administrator and Clerk of the Board By !�nLck h__ Kai herine Sinclair,Deputy Clerk- Attachment cc: County Counsel Carlos Baltodano, B.I. Dennis Barry, CDD BOARD OF SUPERVISORS, CONTRA COSTA COUNTY, CALIFORNIA AFFIDAVIT OF MAILING 1N THE MATTER OF Grading Permit Appeal Hearing for: Lisa Kirk P.O. Box 435 Bethel Island, CA 94511 Notice of hearing for Tuesday, May 23, 2006 at 1:30 p.m., was mailed this day, Wednesday, May 10, 2006. I declare under penalty of perjury that I am now, and at all times herein mentioned have been, a citizen of the United States, over age 18; and that today 1 deposited Certified Mail with Contra Costa County Central Service for mailing by the United States Postal Service in Martinez, California, first class postage fully prepaid, a copy of the hearing notice, on the above entitled matter to the following: Lisa Kirk P.O. Box 435 Bethel Island, CA 94511 Ellison Fork SHUTE, MIHALY & WEINBERGER LLP 396 Hayes St. San Francisco, CA 94102 I declare under pe lty of perjury that the foregoing is true and correct, at Martinez, California. Dated: April , 2006 Katherine Sinclair, Deputy Clerk Clerk of the Board of Supervisors Contra John Cullen Clerk of the Board Costaand County Administration Building County Administrator 651 Pine Street,Room 106 County (925)335-1900 Martinez, California 94553-4068 s John Gioia,District I Gayle R.I.lilkema,District II 1 Mary N.Piepho,District III Mark DeSaulnier,District IV Federal D.Glover, District V Spq.couTl'>K April 28,2006 Lisa Kirk P.O. Box 435 Bethel Island, CA 94511 RE: ADMINISTRATIVE APPEAL OF THE ISSUANCE OF A GRADING PERMIT FOR DELTA COVES DEVELOPMENT PROJECT You are hereby notified that Tuesday,May 9, 2006 at 1:30 p.m. is the date and time set for the hearing of your appeal from the decision of the Building Inspection Department, Contra Costa County, Martinez, California. The hearing will be held in the Board of Supervisors Chambers, Room 107, 651 Pine Street, (corner of Pine and Escobar Streets) Martinez, California. If you challenge this matter in Court, you may be limited to raising only those issues you or someone else raised at the public hearing described in this notice, or in written correspondence delivered to the County at, or prior to,the public hearing. Very truly yours, John Cullen, County Administrator and Clerk of the Board By �h Katheriri�inclair,Deputy Clerk Attachment m County Counsel Carlos Baltodano, B.I. Dennis Barry, CDD 1 Postal r CERTIFIED MAILT. RECEIPT I (Domestic Mail Only; -n For delivery information visit our website at wNw.usps.corrho Postage $ Certified Fee ' Return Reciept Fee Postmark =1 (Endorsement Required) Here =1 Restricted Delivery Fee , :13 (End orsement Requ ad) -q Total Postaae.&Fees Sent Ti Lisa Kirk ti Street,. orPOf P.O. Box 435 °iry"S` Bethel Island, CA 94511 BOARD OF SUPERVISORS, CONTRA COSTA COUNTY, CALIFORNIA AFFIDAVIT OF MAILING IN THE MATTER OF Grading Permit Appeal Hearing for: Lisa Kirk P.O. Box 435 Bethel Island, CA 94511 Notice of hearing for Tuesday, May 9, 2006 at 1:30 p.m., was mailed this day, Friday, April 28, 2006. I declare under penalty of perjury that I am now, and at all times herein mentioned have been, a citizen of the United States, over age 18; and that today I deposited Certified Mail with Contra Costa County Central Service for mailing by the United States Postal Service in Martinez, California, first class postage fully prepaid, a copy of the hearing notice, on the above entitled matter to the following: Lisa Kirk P.O. Box 435 Bethel Island, CA 94511 I declare under penalty of perjury that the foregoing is true and correct, at Martinez, California. Dated: April 28, 2006 Kathenne Sinclair, Deputy Clerk t .TO: BOARD OF SUPERVISORS � Contra t s. Costa FROM: CARLOS BALTODANO, BUILDING INSPECTION .. ;s County DEPARTMENT DIRECTOR ^' c'ouii'�' DATE: May 9, 2006 SUBJECT: HEARING ON AN APPEAL OF THE ADMINISTRATIVE DECISION TO ISSUE A GRADING PERMIT FOR THE DELTA COVES DEVELOPMENT PROJECT. LISA KIRK (APPELLANT) (DISTRICT V). SPECIFIC REQUEST(S)OR RECOMMENDATION(S)& BACKGROUND AND JUSTIFICATION RECOMMENDATIONS A. Open the public hearing, accept public testimony, CLOSE the hearing. B. Deny the appeal by Lisa Kirk of the administrative decision to issue a grading permit for the Delta Coves project. C. Sustain the issuance of the grading permit. CONTINUED ON ATTACHMENT: YES SIGNATURE RECOMMENDATION OF COUNTY ADMINISTRATOR RE-COMMENDATIO19 OF BOARD COMMITTEE APPROVE OTHER SIGNATURE(S): ACTION OF BOARD ON APPROVED AS RECOMMENDED _OTHER VOTE OF SUPERVISORS I HEREBY CERTIFY THAT THIS IS A TRUE AND UNANIMOUS (ABSENT CORRECT COPY OF AN ACTION TAKEN AND AYES: NOES: ENTERED ON THE MINUTES OF THE BOARD OF ABSENT: ABSTAIN: SUPERVISORS ON THE DATE SHOWN Contact: Carlos Baltodano(925)335-1107 ATTESTED JOHN CULLEN,CLERK OF THE BOARD OF SUPERVISORS AND COUNTY ADMINISTRATOR Orig: Building Inspection Department(BID) cc: Lisa Kirk(Appellant) Dennis Barry, Community Development Department Ruben Hernandez,Community Development Department County Counsel BY DEPUTY May 9, 2006 Board of Supervisors Permit#348984 Page 3 agreement to accept and maintain the levee and lagoon. This requirement was met when BIMID passed Resolution No. 05-02-03 on February 3, 2005, which. indicated BIMID's acceptance of maintenance responsibility of the Delta Coves perimeter levee and lagoon. Appeal Point #2: Is the use.of deep dynamic soil compaction technique allowed under the grading permit? Staff Response #2: The judgment in the above-referenced case required the conditions contained in the judgment to be imposed on the project. Condition No. 14, which is contained in the judgment, requires the developer to perform geotechnical work. Condition No. 14 states as follows: "Geotechnical work shall include levee breaching, soil and excavation, dewatering, removal, replacement and compaction of soil, on-site water development, erosion control measures, and design and installation of subsidence measurement." Deep Dynamic Compaction (DDC) is one of the compacting methods to be utilized by the developer and is recognized by. the County as an acceptable method for compacting liquefiable soils (sandy soils). Utilizing DDC was recommended by the project soils engineer and was determined to be consistent with the approved development permit by the Building Inspection Department. _Appeal Point #3: This appeal point is divided into eight separate items (a-h) relating to an August 12, 2005, letter prepared by Hultgren-Tillis Engineers, who are in contract with the County as the geotechnical consultant for the project. A contract with Hultgren-Tillis was approved and executed by the Board of Supervisors on October 26, 2004, as required by condition of approval #13 of the Delta Coves project. Appeal Point #3a: Who is permitting the levee construction and oversight — Contra Costa County? Staff Response #3a: The Building Inspection Department grading permit covers the activities associated with the excavation for the lagoon and the fill placement for the construction of the project levees under the recommendations from the project soils engineer. The oversight of the levees while being built will be observed and monitored by the soils engineer of record, and inspected by the Building Inspections Department. The Army Corps of Engineers and other appropriate agencies and jurisdictions may also have an interest during this project. It is the owners' responsibility to obtain those approvals. Appeal Point #3b: Once mass grading starts under permit 348984, what is the amount of soil to be removed? May 9, 2006 Board of Supervisors Permit#348984 Page 5 activities permitted under the Freedom of Information Act. I only received a date issued statement and no copies of activities permitted under 348984. 1 received this information on 10/31/05. 1 request again a list of activities to be permitted under permit 348984 along with this appeal. l request the right to amend this appeal when the information is forthcoming under the act. Staff Response #3h: The appellant is protesting the issuance of the grading permit based on a BIMID document. The grading permit was issued to the applicant based on a number of documents and submittals including geotechnical reports, grading plans and numerous other related documents all of which are public record. Copies of the grading permit, plans, geotechnical reports and other documents were provided to Ms. Kirk on 10/31/2005. CONCLUSION The County Building Inspection department issued the grading permit only after confirming with the Community Development Department and Public Works Department that the proposed grading plan is consistent with the approved tentative map and development plan and that the grading plan has complied with all relevant conditions of approval, zoning codes and building codes. Staff recommends that the Board of Supervisors uphold the issuance of the grading permit and deny the request to amend the appeal. The judgment in the above-referenced case prohibits the County from denying the issuance of the grading permit for this project. 1 f3 DATE: April 12, 2006 TO: Building Inspection Attn: Pam Christian FROM: Kathy Sinclair - 335' 1902- .Deputy Clerk SUBJECT: THREE(3)HEARINGS: LISA KIRK, GRADING PERMIT APPEAL BOTTOMS-ARNHART,COST CONFIRMATION J.HIGGENBOTHAM,ABATEMENT APPEAL Mr. Mike Silva confirmed the hearings scheduled for Tuesday May 9, 2006 (hearing times listed LelovO ft;,il'c Viowino persons: 9.30 a,ri.: COSI' CONFIRMATION Bearing: Kurt Bottoms & Suzanne Arnhart, . (5 min. estimated time) 104 Willard Avenue (Fiat Art Projector Required) P.ichmond, CA 9:30 a.m.: ABATEMENT APPEAL Hearing: Jack.Higgenbotham (5 min. estimated time) 46 Bayview Avenue Bay Point, CA 1:36 p.m.: GRADING PERMIT APPEAL Hearing: Lisa Kirk—Delta Caves-Bethel Island (30 min. estimated time) P.O. Box 435 Bethel Island,CA Please notify this office in writing whether the Board of Supervisors should hear this appeal on the calendared date. If the appeal is timely and should be heard, please include the names, addresses and zip codes of all parties to be notified in addition to the Appellant. If the appeals are to be heard Tuesday,May 9, 2006 as scheduled, please submit the appropriate material for Board consideration to this office not later than Thursday, April 27, 2006. Thank you, Attachment-Appeal Ce: County Counsel Carlos Baltodano/BI/CCC To Kathy Sinclair/COB/CCC@CCC 03/06/2006 04:38 PM cc Gary Faria bcc Subject Re: Lisa Kirk Appeal HearingEl Thank you Kathy: We'll have to re-schedule this meeting a little later. We will give you another date this week. Carlos. Kathy Sinclair/COB/CCC Kathy Sinclair/COB/CCC �.`'� To Carlos Baltodano/BI/CCC 03/01/2006 09:18 AM CCC @° a. a, cc Subject Lisa Kirk Appeal Hearing Hi Carlos, Reminding you of the scheduled hearing for March 21, 2006 at 1:00 pm. Hard copy memo to follow via inter-office mail. Thank you, - — - -- - -- — ----- -- --— --- — `Z42,/C)�I' Kathy Sinclair Clerk of the Board of SuK.1 hh Jam, 335-1902 Gir(,us i I'z", 0(0 1 a--C�— � .. ...: ...... .. .:,.. ..............x ....... _ ':fin' _ ._. .}......... .............$ ... ....... x ... .. ...... .!. _ �X - W. t.. ?- r .....�. _...... rK61 4:,_ _.. .. .. .. a . . ........ .., ,`l::a - p- •:.r. V¢ _.. . ._. :::_'....... A _ . ,tt -._r9 04 a .n.. .... mai ... .. .. .. ... ..:::.. .. :a9 ^ Vwn 8.. 4z"Ou'-di _. Nr. k.. R-: n' -s DATE: March 1. 2006 TO: Building Inspection Attn: Carlos Baltodano FROM: Kathy Sinclair)k-�- Deputy Clerk SUBJECT: LISA KIRK—GRADING PERMI APPEAL This office is in receipt of the attached Appeal frr Lisa Kirk appealing a Grading Permit No. 348984 for the proposed "Delta Coves" in •he Bethel Island area. The Board of Supervisors has scheduled this appeal hearing on March 21, 2006 at 1:00 p.m. in the Board Chambers. Please notify this office in writing whether the Board of Supervisors should hear this appeal on the calendared date. If the appeal is timely and should be heard, please include the names, addresses and zip codes of all parties to/��e notified in addition to the Appellant. If the appeal is to be heard March 21, 006, as scheduled, please submit the appropriate material for Board consideration to this offic not later than Thursday, March 9, 2006. Thank you, Attachment-Appeal Cc: Coun ounsel 1� S �:�1C�.c.L � �• y � �'`c��- `S V✓-ems-�� } 'L..--_.___.____...�__ � _..______. �._�__-.__ i oj,.-O�? AU-00 4-M o-,—L�LCL��tvjs;f3 �-6- -R&4n 4frn.an car VA A/err i tea- ----- � ------— - ---- - J _ _Co u �-_--_-- - _ -- 1`��(o�� -- cta5 GY4- 4asv ��"����5\�� •C 915\� If�f.4 'tr'- l'r'i L':U 1-0—C I � 1 1005 c fl CLEWi_:I : ,F:v fii , i�'I`OFi$ w�t"Va CJii.A:;C'. :t CoSv vr�wA-", Y\e--:? . a o a -r e-'C:>DV �`� c� �,^cr f 01 b C 4j .n ,p v�`c c'� (J cc7 J CA.�c s .r CANS Lo --z'vv� w eYA cr `J.ter\C, (,. �� o � mss. - _ 3�� 9 16- "� ,N, ; 31I �5gy � 0- C�- Ct`0 Lt r -ci 0--C�Z\ `jam �'sty.r.:k `yet} V7\\ J\ t� �. Ll sGl ` S c,� Cyd v 2 �.�. � � �,� a �.�.�,�.� ��. �•,�,,,_`�-may �•``� � � `S .r � e� � 0. . SHUTE, MIHALY & WEINBERGER LLP ATTORNEYS AT LAW E. CLEMENT SHUTE, JR.• 395 HAYES STREET MADELINE O. STONE MARK I. WEINBERGER (19462005) GABRIEL M.B. ROSS FRAN M. LAYTON SAN FRANCISCO, CALIFORNIA 94 1 02 DEBORAH L. KEETH RACHEL B. HOOPER TELEPHONE: (4 1 5) 552-7272 WINTER KING ELLEN J. GARBER FACSIMILE: (4 15) 552-58 16 KEVIN P. BUNDY TAMARA S. GALANTER ANDREA RUIZ-ESOUIDE ELLISON FOLK WWW.SMWLAW.COM SHERIDAN J. PAUKER RICHARD S. TAYLOR WILLIAM J. WHITE ROBERT S. PERLMUTTER LAUREL L. IMPETT, AICP OSA L. WOLFF CARMEN J. BORG, AICP JANETTE E. SCHUE URBAN PLANNERS MATTHEW D. ZINN CATHERINE C. ENGBERG DAVID NAWI AMY J. BRICKER ANDREW W. SCHWARTZ JENNY K. HARBINE OF COUNSEL 'SENIOR COUNSEL November 17, 2005 LIC:;•r;, _:� Carlos Baltodano, Director Contra Costa County Department of Building Inspection 651 Pine St. p Martinez, CA 94553 Re: Appeal of Grading Permit No. 348984 -- Dear Mr. Baltodano: This firm has been retained by Ms. Lisa Kirk, a resident of Bethel Island, with regard to an appeal that she filed on October 6, 2005 from County staff's approval of grading permit application number 348984 ("application"). The application is for the proposed"Delta Coves" development project on Bethel Island. A copy of Ms. Kirk's appeal letter is attached as Exhibit A, and a copy of the permit application is attached as Exhibit B. I write to request that the County copy me on all written communications with Ms. Kirk regarding her appeal or the Delta Coves project. I understand from Ms. Kirk that the County has not yet set a public hearing for her appeal. Please inform me at your earliest convenience about when the County intends to hold a public hearing on the appeal. Finally, I further request that the County provide me with a copy of any future public notice regarding the Delta Coves project. Very truly yours, SHUTE, MIHALY & WEINBERGER LLP MATTHEW D. ZINN RECEIVED cc: Silvano B. Marchesi, Esq. Lisa Kirk fuc°d- AA-0m DEC 1 9 2005 [P:\LKIRK'\MDZ001 (Appeal Letter 1).wpd] CLERK BOARD GF SUPERVISORS L.CONTRA COSTA CO. 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ADDRESS Z.s �er.2. WORKERS COMP. INSURANCE ON FILE. PHONE NUMBER 40Sr-8GG - 5'S // 3. CALIF. CONTRACTORS LIC. CURRENT. '1♦: CONTRACTOR Vlyvvs� c P,QmxrtxK t+•+c. DOCUMENTATION LICENSE CLASS 1. THREE COPIES OF PLOT PLANS. 2. THREE SETS OF CONSTRUCTION PLANS. PHONE NO. 3. ENERGY COMPL. DATA ON EACH LOT. 4. HEALTH DEPT. WOR SANITARY CLRNC. ENGINEER 5. DRAINAGE FEE AREA. LICENSE 6. GRADING PAD CERT./SOIL REPORT. 7. LENDER ��� =TTT�M) BRIEF DESCRIPTION OF JOB: i NOV ® 7 2005 FOR INTERNAL USE: _ DESCRIPTION `- 3 Z4 OCCUPANCY SQ.FT. 10410 6s P14" 6 da ssti-e ED "r- + C�-�, �v� r �a r�� RECEIV CI 900 bo 11 '111TURE (OWN APPLICANT) DEC 1 g 2005 P NNING DEPT. SIGNATURE DATE: D TE: 1SORS CLERKCBONTRA COSTA CO . . ................... ..................... ............... .:..--_ �.Type.,..B.I�IC,.Vers. 9�02,.B uildin .Combo Su T e. GS Active b s Permit34$984 ;�,:.::. 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HAUL 02 A Coltfomla Corporation Speolallzing In Geotechnical En8lneering ...ii:,'r��;�.•''_ ;:'S'':'`iti' ':-;,:;.,;„ .,...,,.::r"t•,rr-:_�.;7;;f•r,:.�;..r';irr'; ''"•"• � 1. ',r� [fJr,,-.•;;d:-1�.'T'��`+•�•'': I .'a,,'•..:.:;.,;v..,;. r;.:.:{':.:/i. '•Y::��, ,;i{ �,r::. ':s�i�•.�.J,: :�iv::i�ru'..s{';;..in;r:�<a�r.�:�.'r;:.�':•i,:�fS:�}: August 12, 2005 LC' File 156,12 " Bethel Island Municipal Improvement District 3085 Stone Road Bethel Island, California 94511 Attention: Mr.Paul Harper Status Report Delta Coves Subdivision Bethel Island, Callfomia Dear Mr. Harper: INTRODUCTION This letter presents our status report on the Delta Coves project on Bethel Island, California, The project consists of constructing approximately 3 miles of perimeter levee, several miles of peninsulas and placing homes, roadways and other Improvements on the levees and peninsulas. The new levees will be connected to existing levees with double sheetpile wall levee breach structures. After completing the new levees, peninsulas and breach structures, the existing levee will be breached between the two sheetpile structures and the interior of-the site will become tidal. The grading plans dated June 24, 2005 cover mass grading and levee construction, liquefaction remediation, breach structures, slurry wall, residential docks and slope protection. The improvement plans dated June 24, 2005 cover utilities, roadways, drainage, seepage control system, lagoon circulation system and tide gauge. The intent of this letter is to provide BIMID with an overview of the project status and our comments on some of the elements of the project. The grading plans are essentially complete and Contra Costa County(County) is close to issuing a permit for grading. The improvement plans have some elements that need completion including the perimeter storm drain and pump stations but overall the plans are nearly complete. A permit for the improvement plans could be issued by the County within the next couple of months. We will continue to review submittals as they are provided to the County and us. Duc Housing Partners (Duc) Is planning to use Granite Construction Company(Granite)for grading and improvements. We understand that a contact is not yet in-place for Granite to begin work on the project. Granite has provided a schedule for the project The schedule provides for a 2.5-year construction period to build the levee, install Wities and pave the roadways. 2221 Commerce Avenue,Suite A-1 - Concord,California 94520-4987 Phone(925)685-6300 - Fax(925)685-6768 bti/11/'lF7b� 0y'48 9256856768 HULTGREN-TILLIS ENG PAGE 03 Mr. Paul Harper 2 August 12, 2005 COMMENTS For the various elements of the grading and Improvement plans, we have the following comments. 1, Levee Fill and Mass Grading The reports by the designers for the project include recommendations that the peat and organic soil be removed below the footprint of levee. Sand will then be placed and compacted to construct the levees. We have no comments or exceptions for mass grading. 2. Liquefaction The designers have evaluated the potential for liquefaction and developed recommendations for remediation of areas with the potential for liquefaction. We have reviewed the analysis and the plans for remediation. The remediation plan includes removal and compaction of some of the shallow sand deposits. For the thicker deposits, the plan is to•use deep dynamic compaction (DDC) except within 200 feet of existing residences. Within the 200 feet zone, stone columns are planned. We conclude that the remediation plan is a reasonable approach to address liquefaction and reduce the risk of damage to the levees and improvements from earthquake shaking. The specifications on DDC and stone columns have not been provided. We expect that the contractor will provide the specifications and construction sequencing including size and spacing of the stone columns. The contractor should provide the information to the County and for our review prior to proceeding. DDC and other construction activities will cause ground.vibration. We understand that the contractor will monitor vibration during construction. The contractor also plans to perform a survey of existing conditions on adjacent properties prior to construction. The preconstruction survey should include documenting the crest elevations of the BIMID levee along Stone Road. Vibration could cause some settlement of the existing levee. The contractor should submit a vibration-monitoring plan to the County and for our review before starting DDC. 3. Slurry Wall and Dewatering One of the issues for this project is the potential to alter groundwater levels on adjacent properties. The potential impact of seepage Is considerably greater than most other grading projects. During construction, the contractor plans to lower groundwater levels within the project area to allow removal of borrow material and installation of utilities. After the existing levee is breached,the groundwater levels beneath the property will be raised well above existing levels to delta tidal levels. Peat and other marsh deposits underlie some of the adjacent properties. The peat is highly compressible and lowering the groundwater below adjacent properties will increase the.stress in the peat and cause ground settlement and settlement of structures founded on grade. Obviously, this is undesirable. The project will construct a slurry wall to a depth of about 40 feet. The lower portion of the slurry wall will be constructed by slurry trench methods. It will extend through the underlying sand aquifer that starts at existing grade and penetrates into an underlying clay layer. The upper portion of the slung wall will be constructed with low permeability compacted fill.. The slurry wall serves two functions. During site grading the slurry wall will allow dewatering within the site interior without lowering groundwater levels on the opposite side of the wall. Once the Ji.VVVJUf GO HULIUKEN-TILLIS ENG PAGE 04 Mr. Paul Harper 3 August 12, 2005 project is complete and the new lagoon is filled with tidal water, the slurry wall is intended to limit seepage from the site to surrounding properties. We conclude that the planned slurry wall is an acceptable solution to reduce seepage from the development. 4. Seepage Collection System A seepage collection system is planned on the south side of the development along Stone Road. The seepage collection system is intended to collect seepage coming from Taylor Slough that will be cut-off from its historic flow path by the slurry trench. The seepage collection system is intended to maintain groundwater levels near their current levels on adjacent properties. The elements of the seepage control system including a subdrain pipe surrounded with filter gravel, weirs to control groundwater levels within the subdrain pipes and monitoring wells. Data from the monitoring wells will be used to adjust the weirs and monitor the Impacts of the slurry wall on groundwater levels. BIMID has committed to assume maintenance and operation of the system after it is installed and functioning properly. The developer has committed to installing five monitoring wells on adjacent properties as outlined in a letter dated July 28, 2005 (attached) and two wells on SIMID property. The basic elements of the seepage collection system are acceptable to us. The final details and specifications of the slurry wall and seepage collection system need to be submitted to the County and for our review. The construction methods for constructing the slurry wall are important to achieving an adequate barrier to seepage. The operation of the seepage collection system is important to limit impacts to neighboring facilities and properties. 5. Breach Structures We have agreed in concept to the basic elements of the double sheetpife wall breach structure design, although the current plans do not reflect the final changes. Details of the breach structures and sequence of construction are important to assure that the existing levee is not damaged during construction. A construction sequence and final plans for the breach structures and levee breach are needed prior to their construction. The construction sequence should include an evaluation of deformation that may occur during construction. 6. Slope Protectlon We have reviewed the geotechnical engineering aspects of the slope protection.plans and have no comments or exceptions. 7. Residential Docks We have reviewed the geotechnical engineering aspects of the residential docks and have no comments or exceptions. I HULTGREN-TILLIS ENG PAGE 05 Mr. Paul Harper 4 August 12, 2005 8. Perimeter Storm Drain and Pump Stations BIMID has committed to accept operation and maintenance of the perimeter portion of the storm drain system and the 4 (four) pump stations. The County is reviewing the plans on behalf of BIMID. The County will also provide construction oversight of these facilities on behalf of BIMID. The County is reviewing the current plans and will provide comments and/or meet with the designers to discuss the plans. 9. Lagoon Circulation System The lagoon circulation system will be operated and maintained by the homeowners association. We have not reviewed the system on behalf of BIMID. FUTURE BIMID MILESTONES BIMID has a few tasks to complete for the project. Some of the tasks include: 1. Sign Improvement Plans The County will require that BIMID sign the improvement plans because the plans include improvements that BIMID will operate and maintain. BIMID does not need to sign the grading plans. 2. Assessment District BIMID and Duc need to set up an assessment district to address maintenance and funding for the levee, storm drain, pump station and seepage control system. 3. Timing of Acceptance of Maintenance BIMID needs to determine when they will assume maintenance for the various operations they have agreed to maintain. The operation of the seepage control system and pump stations will include the potential for impacts to adjacent properties and present some potential liability for BIMID. The timing for taking on maintenance should include a consideration of this liability. CLOSURE We conclude that the project plans have sufficient detail for the contractor to proceed with initial grading. The project will need submittals from the contractor for some elements of grading. Mass grading Including removal of the peat and organic soil can begin without the submittals although no dewatering should occur. Submittals on DDC, stone columns, slurry wall, and the sequence of construction for the breach structures and levee breach, the seepage collection system and slurry wall will be needed. We can provide BIMID with a final letter with our comments on the final improvement plans after the plans are completed. vol Lzltnn= ey:4N 13156856768 HULTGREN-TILLIS ENG PAGE 06 Mr,,Paul Harper 5 August 12, 2005 If you have any questions, please call. Sincerely, Hultgren-Tillis Engineers QRoFEss a VN Tj N Iqt� �' a No.0�216O m R. Kevin Tillis .313110� rn Geotechnical Engineer * q RKT:EMH:la FOP ceUVOPa Attached: July 28, 2005 letter 10 copies submitted File No. 15612L16.doc order of 10, 000 cubic feet per second. Flood damage was substantial as it was ; however, if the waters had been confined by another parallel dike system, similar to the proposed condition at Bethel Island the rise in flood level would have been much faster and potentially dangerous to life. I believe that with the proposed project a breach of similar magnitude occurring along Stone Road would confine and direct the flood to the area of existing residences. The hazard to life would be particularly serious if the breach happened at night. It follows that this is an impact on public safety attributable to the project. The impact of such an event can and should be analyzed .using current engineering techniques, including probabilistic seismic analysis incorporating current information on local seismicity; an embankment seismic stability analysis for the existing levee ; a am break evaluation; and f oo rou In is were a dam rattrnT --7Tan a levee project, all but the last step would be required by state engineers_ Atiparently such evaluations have not been made for this project. Levee projects that do not have con rol structures are ub ' ec o the same review as dams b cause of a loophole in the regulations, u is oes not relieve other reviewers and parties from responsibility for in a s a e-of-the-art techniques a used to allow 'the impact of the project to be properly understood by the people who wi be affected by it. The Krone December 28 , 1987 and Jones April 14 , 1988 letters dismiss the flood hazard on the basis of misleading and meaningless a,iecdotes and negative evidence. The Jones letter aims to respond to the concern of increased flood hazard arising from earthquake failure of the existing levee system. Having earlier concluded that liquefaction of the existing levees is a potential hazard ("from which the Delta Coves project itself can be isolated") , and agreeing that instantaneous failure of the old levee (the normal mode of failure in the case of liquefaction) would create a situation. in which the "prospects of the residents on Stone Road are dim indeed" , the report dismisses the hazard ( "very low indeed") only because the failure has not occurred in the past! This is not an acceptable method of risk analysis where life and major property damage is at stake. The Krone letter adds the misinformation that "recent studies BIMID Comments, page 16 BROOKSIE C. LA`VSO.N 528 LISA K. KIRK 90-2566n211 P.O. BOX 435 h BETHEL ISLAND,CA 94511 DATE _ l-' f. PAY TOT ORDER DFS �1; `� �yC�JG�LCi\ LLARS I. BAC Brentwood 800-944-8782 Bank.of Agriculture &Commerce 4- b MEMO M' ,:.12 1 1 2.S660i:0 20 1 S 3 1 1011' 0 S 28 v PROFESS:ONA CHECK SYSTEMS : COUNTY OF CONTRA COSTA GENERAL RECEIPT ,DEPT:. l�V A RECEIPT; l.O. S'COPY G 1 '[�9:0., L:... � 3�.:'�: . .: ...�:�3gg6- ',': ,...:;::NOT IS l: : .. :. .. :. .. .... - DOLLARS$ , r :...FOR. L. . CASH::. BA RECEIVED FROM : : ,::: '.'- ...... ,. :.. ... .. ' ,: . . .::...,• . .. : I � . '.'. • . .:...'� .'::` � ';:AMT., . .. ' •'.�.;.: •::.'... . ... :GREG .'.. �.� 'Gr � ...',:-. •.:.�': �: . . ' .. :.: .•.. .::'. - ..PAID ONEY QE44 1 R: • Bbl. D57 .... �' ...:.. ... ,REV.7/89) ( :. ..,... 41-, 05. zz 20 0 .14: 2 8 1'A X 415 7 88'2 0.19 230-3 s,i -] ] : x i-i- i,rr 00(11. oo(' ' SIG lul STEEFEi-, LEVITT&WEISS, A PROFESSIONAL CORPORA.TION One Embarcadero Center.Thirtieth Floor.San Francisco, California 94111-3719. (415)788-0900.Fax: (415)788-2019 FAX TRANSMITTAL SHEET May 22. 2006 FILE 4: 10860 PLEASE DELIVER 1"HE FOLLOWING PAGES TO: FAX: PHONE: I Clerk of the Board 925.335.1913 Contra Costa Board of Supei-visors , I SvIvano Marchesi 925.646.1078 County Counsel - Conti-a Cosu. RECEIVED 3. CarlosBalto.dollo 925.646.1219 MAY 2 2 20061 CLERK BOARD OFSUPERVISORS CONTRA COSTA CO. 6 page(s) Including cover FROM: John W. Truxaw- Message: Originals 0 xill Lx-J will not be se t. Ll vp—K IF YOU HAVE ANY QUESTIONS, PLEASE CALL JODIE CHODAR AT(415)788-0900, EXT.4366 THANK YOU. THE INFORMATION CONTAINED IN THIS FACSIMILE 'IS CONFIDENTIAL AND MAY ALSO CONTAIN PRIVILEGED ATTORNEY-CLIENT INFORIVIATION OR WORK PRODUCT, I HE INFORMATION IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHOM IT 1 P 3 ADDRESSED. IF YOU ARE NOT THE m-TENULD RECIPIENT, OR THE EMPLOYEE OR AGENT RESPONSIBLE TO DELIVER IT TO THE INTENDED RLC ENT, YOU ARE HEREBY NOTIFIED THAT ANY USE, DISSEMINATION, DISTRIBUT1014 OR C('-NPYlNG OF THIS COMMUNICATION IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THE FACSIMILE IN ERROR,PLEASE IMMEDIATELY NOTIFY US By L TELEPHONE,AND RETU N THE OR!GINAL MESSAGE TO US AT THE ADDRESS A130VF VIA THE U.S.POSTAL SERVICE. THANK You. O:: _22. : 006 1. 1: 28 I _1\ 4157882019 1:30:3 .STI .A.I.J. f.1.:1 Oil 0i)fi 51,EEEEL, L[VITT & A Professional Corporation Author's Direct Dial: (415)403.3386 E-Mail: jtruxawCstee`el.com May 22, 2006 16860 Chair Jolui Nf. Gioia and Board Members Contra Costa Board of Supervisors 651 rine Street Martinez, CA 94553-1229 Re: 1`-lav 23, 2006 Board Agenda Item D-4: Lisa Kirk Appeal Dear Chair Gioia and Nlembers of the Board of Supervisors: LB!L. Duc ill Bethel Island LLC ("Due" herein) respectfully requests that the Board deny the appeal tiled by Lisa Kirk in the matter of the Delta Coves `radiing Pel'llllt tc?1'the 1t aS0I15 stated herein together with the reasons set forth its the Staff Report prepared foi this matter. Below we first respond to the appeal as filed by Nis. Kirk on October 31, 2005. Following that, we respond to issues raised by her attorney, Ellison folk, in a letter to the Board dated May S, 2006. Itiirk Appeal The County issued the grading permit for the Delta Coves project on October 67 -2005. The permit remains in effect and grading operations have been underway sitice late March. Ms. Kirk filed her appeal on October 3 1, 2005 pursuant to the provisions of sections 14-4.002 and 14-4.004 of the Ordinance Code of Contra Costa County. Failure to Verify Appeal: Failure to Specif3, Iniury: Not an Nt;gri( t cd I' rson Sections 14-4-(i02 and 14-4.004 of the County Code provide that "aui}` person aggricved by an administrative action' shall "file with the clerk of the board a verified N�Titleti notice of appeal concisely stating the facts of the case and the grounds "or his appeal including his Special interest and injury." The code defines verification at section ?6-4.004: ""Affidavit," "certificate" and "verification" include declarations under penalty of perjury." N.1s. Kirk's letter of appeal is not verified aid thus is not properly before the Board. Althoughthe code does not specifically define the terin "aggrieved", general use of the terra requires that to be aggrieved, a person must be able to specify an action that has caused them individual iniurv. Ms. Kirk makes no attempt in her appeal to explain how she has been injured by the County's decision to issue a grading peri Lit and she provides no special interest or One Embarcadero Center,30th Flow,San Francisco,California 94111-3719•Phare:(415?7188-0900•Fru:015)"1,88-2019 San Francisco,CA los Angeles,CA Stamford,CT ,%r-vm.stertel.cc.-m .14.:28 FAX 41.57.88201.9 2:30:3 S'TT'I'1.'I. 1.1-W1'IT 00:1..006 n Chair,John 1.1. Gioia and Board Nlembers May 22, 2006 Page TwoSi[EfEl,If9lil?�tfflss injury supporting her appeal. As such, she is not a `person aggrieved" by the. decision. Because her letter ofappeal does not satisfy, the requirelnelits:of section 14-4.004, it must be denied. Vested lll�li[ As noted above, the County issued (}ie grading pem)it in early October and.it has remained in effect ever since. Aithough Ms. Kirk filed this appeal in late October, she apparently made. no effort to have the matter heard "at an early regular board meeting" as is required by the Code. In the meantime, Due has commenced and continues extensive grading operations at the site in full conformance with the conditions of the permit. D,uc has a vested right to continue its grading operations. BIMID Ai�proval The staff report responds to INTs. Kink's BIMID related issues and rve concur with staff's responses. 'Fhe County has issued the grading permit in full compliance with all County regulations and project specific. court ordered conditions of approval. BIMID agreed to accept maintenance of the levees and breach structure to be built pursuant.to the grading permit.at a. pubic meeting held in February 2005. After that meeting, the: BIIvIID Board received and considered the reports and recommendations of its consulting geotechnical. engineer, Kevin Tillis, and consented to the work being performed under this permit. By letter dated August.9, 2005 to Kevin Emigh of Contra Costa County Public Works. Mr. Tillis confirmed that mass grading of the site could commence. On August 18. 2005 the BIMID Board accepted a written and oral status report on the grading plans from Mr. Tillis. In his letter, Mr. Tillis explains that "The grading plans are essentially complete and Contra Costa County (County) is close to issuing a permit for grading. ... We conclude that the project plans have sufficient detail for the contractor to proceed with initial grading." Minutes of the meeting reflect that during Mr. Millis' presentation, lie informed the B3iM1D Board that "The County- is ready to tSSUe a gradtng permit " Between August and October, Mr. Tillis coatirued to review sul:nnittals niade to the County in furtherance of the grading permit and he consented to its issuance. Minutes of the October-20, 2005 BIMID meeting reflect that at the meeting Mr. Tillis informed BIMID that a grading permit had been issued, that initial clearing had begun and that "The main construction could start in about one month." The minutes reflect that Ms. Kirk was present during this presentation. Mr. Tillis and District Manwzer Paul Harper wcrc• present at an on-site pr(tconstmcti(itl meeting Heid dust prior to the commencement of grading operat.i�nis in tnid-iMac 2006 and consented :o the commen.ceinent of grading. Although. as the staff report notes, 13IMID approval is not required prior to the issuance of the grading permit, nevertheless. BIMID has been aware of and has reviewed. and signed off on the gradin;; plans at all relevant tiniel. 05;22/2006 14: 29 FAX 4.1 5 7 8820 19 2:30:3 s'I'h:l•:FI-L 1.1:1 1.1-1' �004,'006 a r Chair John M. Gioia and Board Members ����� May 22, 2006 Page Three SitEEEI.,lEVlli&1"SEISS Ellison Folk letter Failure to Verify AlWal: Failure to Specify° Injury: Failure to appeal \kj1hin 30 navy As noted above, an appeal brought pursuant to section 14-4.002 must be filed ti�vithin 30 days of the action being appealed frorn and must include "a verified:NvT1t1en notice of appeal concisely stating the facts of the case; and the grounds for his appeal including his special interest and injury." Nits. Folk's letter, to the extent it «could amend Pvts. .Kirk's appeal, is not verified a.nd fails the first requirement. Similar to Itis. Kirk's letter; it specifies 110 special injury suffered by the appellant. Additionally, the 30 day requirement clearly, if implicitly, includes a requirement that the appellant state his or her grievances vti-ithin 30 days ofthe date of the action. Ms. Folk"s letter imperniissibly seeks to broaden the appeal h gond the grounds for the appeal provided during the 30 day period by Ms. Kirk. Because her letter is not verified, specifies no special interest or injury and because it seeks to broaden the scope of the appeal beyond the issues raised within the 30 day post-action period, it should be disregarded by.the Board. Alleged Violation of County Code section 716-2.608 Ms. Folk argues di rt the issuance of the grading permit violates County CoJe Scction 716-?.608. Section 716-2.608 ol'the County Code provides that "No person shall cxcavake. or remove anv material from any levee or do any work on levees required for river or local drainage control without prior approval of the local. governmental agency responsible for the maintenance of the levee." In this instance, `'the local governmental agency responsible for the maintenance of the levee" is BIMID, the Bethel Island Municipal Improvement District. B11t1ID Consent As explained above. i IMID's consulting engineer and its District VILanage;r have reviewed and signed off on the grading plans. Although Ms. Folk rnischaracterizes section 716- 2.608 by stating that the required approval must be in writing:, nevertheless the requirement was satisfied in writing when on February 3, 2005, the BIN1ID Board adopted its resolution 05-02-03 and agreed to maintain the perimeter levees together with the breach stricture. Prior to adopting that resolution, the BIM iD Board received a written report and a lengthy and detailed oral report from consulting geotechnical engineer Tillis regarding the nature of the levee and breach improvements to be constructed at Delta Coves. Additionally, beginning even before t}mc adoption ot�Resolution 05�-02-03 and continuing Lip to the day grading operations began at Delta Coves. BMW[), acting variously through its Board, District. Manager Harper and consulting; geotechnical engineer Tillis, has reviewed and 0 5,1_2 2/2 0(I 6 I.4 2 5) FAX 4 15 7 8,S 210 15) 2:303 STI-1:11:1. LFIVIVI' Q005,:006 Chair John IVI. Gioia and Board.Members May 22, 2006 Page Four Plif U. 111.1111 kVISS approved the grading plans, including 16vee and breach construction details.' By Jet ler dated August 12. 2005, consulting geotechnical engineer-Tillis informed the BIMID board that "The County will require that. BIMID sign the improvement plans because the plans include improvements BIMID will operate and maintain. BIMID does not need to sign the gnading plans." Mr. Tillis delivered this letter with additional or,-] commentary to the BINIID Board at its meeting held August 18. 2005. On March 23, 2006, prior to the commencement of grading, operations. a preconstruction, mecting was held at the pro.iect site with both N\4r. Lillis and _Mr. Hai-per in attendance representing BIMID, as well as appropriate County officials. By their presence at the pre-construction meeting, BIMID informed tree County of its consent to the work to be Undertaken pursuant to the grading permit. A )roval of the Breach. Regarding the breach structure, as noted above, BIMID agreed to maintain the breach structure by resolution adopted in February 2005. Mr. Tillis' August 12, 2005 letter to 13INIlD states that "We have agreed in concept to the basic elements of the double sheelpile NNall breach structure design., although the current plans do not reflect final changes. Details of the breach structures and sequence of construction are important to assure that the existing levee is not damaged during construction. A construction sequence and final plaits for the breach structures and levee breach are needed prior to their construction. The Const.niction seqiience should include an evaluation of deformation that may occur during construction." After the date of that letter, Mr. 'rinis continued to review and approve breach and-levee construction details shown on the grading plans up until the County issued the grading pemiit in October, 2005. The approval of a grading permit by the County Department of Building.inspection for the Delta Coves project requires the ministerial application of'LlIe County grading ordinance to the grading plans and is not a project under CEQA; the issuance ofthe grading permit does not give rise to any of the CEQA related issues raised. Conclusion In conclusion, Ms. Kirk is not an aggrieved persons, she did not verify her appeal and she has not raised any issues that Nvould support any action by the Board to affect Duc's vested rights in its grading permit for the Delta Coves project. IN- Is. Yolk seeks iniproperiV LO expand the issues on appeal which. she ewinot do in view- of the limited period of time in which an appeal can be brought after the date of the action on appeal. Regardless, BINED has consented to the Construction oft lie breach structure and other construction activity that wi I I occur on the levee is detailed in and approved by the approved grading plans. 05/72:'2006 1.4 30 FAX 41578-90.1.51 82:503 ST11"l-J"E'l, LEN. .1 Fl 006/006 Chair John M. Gioia and Board May 2' 2006 Page Five Uhrff[l.11111111?4 MISS grading operations including the construction of the breach. For tlic,,,e reasons.. the Board should deny, the appeal. ' ,rcry Iruly yours, .1�dtln- Truxaw JWTjCC cc: SN' vatio Marchesi Carlos Bahodono REQUEST TO SPEAK FORM (THREE (3) MINUTE LIMI T) Complete this form and place it in the box near the speakers' rostrum before addressing the Board. Name: — ;'?�C`U � ti �. L(.�1�"�-�U _ Phony:: L Address: ] Z-O City: (Address and phone number are optional; please note that this card will become a public record kept on file with the Clerk of the Board in association with this meeting) am speaking for myself or organization: }Yl" — (' � ld _. 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