HomeMy WebLinkAbout2026-05-12; City Council; 07; Confirming the Declaration of a Local Emergency Condition Resulting from a Partial Pipe Collapse on the North Batiquitos Interceptor Sewer in the Ponto Area and AuthoriziCA Review TL
Meeting Date: May 12, 2026
To: Mayor and City Council
From: Geoff Patnoe, City Manager
Staff Contact: Amanda Flesse, Utilities Director
amanda.flesse@carlsbadca.gov, 442-372-6030
Keri Martinez, Utilities Principal Engineer
keri.martinez@carlsbadca.gov, 442-200-7376
Subject: Confirming the Declaration of a Local Emergency Condition Resulting
from a Partial Pipe Collapse on the North Batiquitos Interceptor Sewer in
the Ponto Area and Authorizing Repair Using Emergency Construction
Procurement Procedures
District: 3
Recommended Action
Adopt a resolution confirming the declaration of a local emergency condition resulting from a
partial pipe collapse on the North Batiquitos Interceptor Sewer in the Ponto area and
authorizing the City Manager to direct the repair work to be performed using emergency
construction procurement procedures.
Executive Summary
During a routine closed-circuit television inspection of the city’s main sewer pipelines in April
2026, the city’s asset management consultant identified damage to a segment of the North
Batiquitos Interceptor Sewer in the Ponto area, at the location identified in Exhibit 3. The
damage on the 27-inch diameter pipe presents an imminent danger of leaking sewage into the
surrounding soil and/or of a complete pipe failure that could result in a sewage spill into the
surrounding environment.
The City Manager declared the existence of a local emergency condition resulting from the
partially collapsed sewer pipe on April 30, 2026, authorizing staff to immediately proceed with
the necessary steps to repair the pipe. Staff are now asking the City Council to confirm the
declaration and authorize the City Manager to continue with the repairs using emergency
construction procurement procedures, as allowed under California Public Contract Code
Sections 22035 and 22050 and Carlsbad Municipal Code Sections 3.28.110(A) and 3.28.120.
The emergency declaration exempts the repair from formal bidding requirements. It requires
confirmation by a four-fifths vote of the City Council.
May 12, 2026 Item #7 Page 1 of 16
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Explanation & Analysis
Overview
The North Batiquitos Interceptor Sewer is a 5.2-mile long, 27-inch diameter sewer pipeline that
transports sewage from the city’s southernmost sewer basin to the Encina Water Pollution
Control Facility, the treatment plant.
The pipeline repair site is located approximately 3/4-mile south of the Encina treatment plant.
The damage to the sewer pipe is in the upper part of the pipeline and classified as a partial pipe
collapse. The damage created an opening in the pipe that is exposed to the surrounding soil,
posing an imminent danger of leaking sewage under high sewer flow conditions, and/or soil
entering the opening in a heavy storm, causing a risk of blockage. This condition could result in
sewage spilling into the surrounding environment.
The pipe repair work requires:
•A temporary sewer bypass system
•Potential draining of groundwater
•Excavation to remove and replace the damaged pipe segment
This pipeline extends through the North County Transit District’s right-of-way. It is also located
within the city‘s Habitat Management Plan preserve known as the Poinsettia Station Vernal
Pool Preserve, which provides habitat for seven federally listed plant and animal species.
The site is not readily accessible by a public road. Instead, access to the repair site is accessed
through the gated Waters End residential community and via the adjacent city sewer lift station
at the southwest corner of that community, just north of Poinsettia Road.
The Waters End pedestrian trail, a city designated trail, runs alongside the sewer line about 35
feet to the east. Crews will need to cross the trail to access the site, and to install the bypass
piping. About 1,000 feet of the trail will be temporarily unavailable for public use during the
repair work.
As part of the emergency repair work, staff are coordinating with:
•The NCTD, which has the right-of-way on the area along the tracks
•The Encina Wastewater Authority, which operates the Encina wastewater facility
•The Waters End Homeowners Association
•A natural gas distribution company with a pipeline in the area
•Appropriate environmental regulatory agencies
This sewer pipeline is within a city sewer easement, which gives the city access to the site to
maintain infrastructure.
The pipeline extends the entire length of the Poinsettia Station Vernal Pool Preserve, which is
protected by the city’s Habitat Management Plan. The city will retain a qualified biologist with
vernal pool expertise to assist in the necessary preconstruction documentation, notification to
regulatory agencies and onsite monitoring during the work.
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The project includes several measures to minimize temporary impacts to the preserve,
including:
•Minimizing public access to the area
•Designating pathways for equipment
•Installing bypass piping outside of the preserve area
•Removing the upper one foot of soil and setting it aside for later use in habitat
restoration
In addition, the biologist will provide pre- and post-construction documentation and a tribal
monitor will be present to provide cultural resource protection during excavation activities.
Emergency declaration
The emergency repair work requires prompter action to prevent or mitigate the impairment of
health, property or essential public services and the environment than would be possible under
formal bidding procedures. The estimated cost of this emergency repair work exceeds the
formal bidding threshold of $220,000. The formal bidding process takes approximately four to
six months.
Carlsbad Municipal Code Section 3.28.110(A) implements California Public Contract Code
Section 22035, which provides for an exemption from formal bidding procedures for emergency
construction procurements. To use the emergency exemption, Carlsbad Municipal Code Section
3.28.120 and California Public Contract Code Section 22050 allow the City Manager to declare a
local emergency so that staff may then immediately proceed with the repair work without
following the formal bidding procedures. The declaration is subject to confirmation by a four-
fifths vote of the City Council at its next regularly scheduled meeting.
Emergency coastal development permit
The proposed work is within the city’s Local Coastal Zone and qualifies as development that
requires a coastal development permit.
The City Planner issued an emergency coastal development permit for the work on May 1,
2026, in accordance with Carlsbad Municipal Code Section 21.201.190. The Municipal Code
requires the City Planner to report the issuance of the permit to the Executive Director of the
California Coastal Commission and the City Council. The approved permit identifies the nature
of the emergency and work involved and is included as Exhibit 2.
Fiscal Analysis
Sufficient funding is available for the work in the Sewer System Rehabilitation and
Replacement, Capital Improvement Program Project No. 5503, funded by the Sewer
Replacement Fund as shown in the table below. Staff are not requesting an additional
appropriation at this time.
May 12, 2026 Item #7 Page 3 of 16
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Funding available in Sewer System Rehabilitation and Replacement Program,
Capital Improvement Program Project No. 5503
Total appropriation to date $14,426,475
Total expenditures and encumbrances to date -$8,150,403
Total available funding $6,276,072
Costs and funding for North Batiquitos Interceptor Sewer Emergency Repair
Capital Improvement Program Project No. 5503-27
Construction contract (estimated) -$500,000
Construction contingency (estimated) -$100,000
Environmental/Cultural monitoring (estimated) -$121,000
Construction management, inspection, material testing and support
services (estimated) -$120,000
Total estimated construction costs -$841,000
Remaining balance after total estimated construction costs $5,435,072
Additional appropriation needed $0
Next Steps
Upon confirmation of the declaration, staff will initiate the routing of a public works contract
under emergency construction procurement procedures and authorize the contractor to
proceed with performing emergency work once the appropriate permits from required
agencies have been obtained. Before any work begins, a qualified biologist will be retained to
conduct a preconstruction site survey. The biologist will observe and document compliance
with the environmental permits during the repair and habitat restoration work.
Staff will return to the City Council on May 19, 2026, to review the emergency action progress
and the need to continue the declaration of a local emergency condition by a four-fifths vote.
Environmental Evaluation
The proposed action is statutorily exempt from environmental review under the California
Environmental Quality Act, or CEQA, pursuant to California Public Resources Code Section
21080(b)(2) and (4) and CEQA Guidelines Section 15269(b)-(c), which apply to emergency
repairs to publicly owned facilities necessary to maintain services essential to public health,
safety or welfare and other specific actions necessary to prevent or mitigate an emergency. The
statutory exemption covers both the declaration of emergency and the emergency coastal
development permit.
Exhibits
1.City Council resolution
2.Emergency coastal development permit dated May 1, 2026
3.Location map
May 12, 2026 Item #7 Page 4 of 16
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Exhibit 1
RESOLUTION NO. 2026-090 .
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF CARLSBAD,
CALIFORNIA, CONFIRMING THE DECLARATION OF A LOCAL EMERGENCY
CONDITION RESULTING FROM A PARTIAL PIPE COLLAPSE ON THE NORTH
BATIQUITOS INTERCEPTOR SEWER IN THE PONTO AREA AND AUTHORIZING
THE CITY MANAGER TO DIRECT THE REPAIR WORK TO BE PERFORMED USING
EMERGENCY CONSTRUCTION PROCUREMENT PROCEDURES
WHEREAS, during a routine closed-circuit television, or CCTV, inspection of the city’s main sewer
pipelines or interceptors in April 2026, the city’s asset management consultant identified a partial pipe
collapse along the North Batiquitos Interceptor Sewer in the Ponto area; and
WHEREAS, under existing normal pipe flow conditions sewage is being conveyed through the
existing damaged pipe; and
WHEREAS, the partial pipe collapse on a 27-inch diameter vitrified clay pipe presents an imminent
danger of leakage of sewage into the surrounding soil under high sewer flow, and/or soil entering the pipe
break under heavy storm infiltration with a risk of blockage, and/or full pipe failure that could result in a
sewage spill into the surrounding environment; and
WHEREAS, the North Batiquitos Interceptor Sewer in the Ponto area is located within a 15-foot-
wide city sewer easement within the North County Transit District right-of-way, and repair work requires
a right-of-entry permit, safety training and protocols for working near railways; and
WHEREAS, the North Batiquitos Interceptor Sewer is located within a protected habitat
management plan preserve, the Poinsettia Station Vernal Pool Preserve, which includes highly sensitive
and protected habitat and federally listed endangered species requiring minimization of construction
impacts on the preserve and onsite monitoring during all repair activities; and
WHEREAS, the North Batiquitos Interceptor Sewer is located within the City’s Local Coastal Zone
and requires a coastal development permit; and
WHEREAS, a 12-inch diameter high-pressure gas pipeline crosses the North Batiquitos Interceptor
near the repair location and requires field location, protection and onsite monitoring; and
WHEREAS, the partial pipe collapse poses a clear and imminent danger and requires immediate
repair work, including temporarily bypassing the sewer flow; excavating, removing, and replacing the pipe
segment; reconnecting and testing the repair; and restoring the site; and
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WHEREAS, the estimated cost of the repair work exceeds the formal bidding threshold established
by the Public Contract Code and Carlsbad Municipal Code and the formal bidding process would take
approximately four to six months; and
WHEREAS, the repair work requires prompter action than formal bidding allows to permit the
continued conduct of the operation of essential public services and prevent or mitigate the potential
impairment of life, health, property or the environment; and
WHEREAS, the City of Carlsbad follows the procurement processes in the California Public Contract
Code and the Carlsbad Municipal Code; and
WHEREAS, in the case of an emergency, California Public Contract Code Sections 22035 and 22050
and Carlsbad Municipal Code Sections 3.28.110(A) and 3.28.120 allow the City Council by a four-fifths vote
to authorize the repair and replacement of a public facility, take any directly related and immediate action
required by the emergency, and procure the necessary equipment, services and supplies for these
purposes without following formal bidding procedures; and
WHEREAS, as permitted by California Public Contract Code Section 22050, the City Council has
delegated the authority to declare a public emergency and authorize emergency repairs to the City
Manager, subject to review by the City Council by a four-fifths vote at its next regularly scheduled meeting
not later than 14 days afterwards; and
WHEREAS, on April 30, 2026, the City Manager declared a local emergency for an emergency
condition resulting from a partial sewer pipe collapse on the North Batiquitos Interceptor Sewer in the
Ponto Area (Attachment A); and
WHEREAS, the emergency declaration must be confirmed by a four-fifths vote of the City Council
at its next regularly scheduled meeting; and
WHEREAS, staff request that the City Council confirm the declaration of a local emergency
condition and authorize the City Manager to continue with the necessary repair work performed using
emergency procurement procedures; and
WHEREAS, the emergency repair is estimated to cost approximately $500,000, not including
contingency and other construction support costs; and
WHEREAS, sufficient funding is available in the Sewer Rehabilitation and Replacement Program,
Capital Improvement Program Project No. 5503; and
WHEREAS, on May 1, 2026, the Assistant Director of Community Development issued an
emergency coastal development permit CDP 2026-0021 (PUB2026-0009), subject to the authority and
May 12, 2026 Item #7 Page 6 of 16
Docusign Envelope ID: B5E19FFC-613D-80A6-83CB-3C3AD0E6ECEF
requirements under Carlsbad Municipal Code Section 21.201.190 and is reported through the staff report
for City Council information.
NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Carlsbad, California, as
follows:
1.That the above recitations are true and correct.
2.That the City Council has determined that the proposed action is statutorily exempt from
environmental review under the California Environmental Quality Act, or CEQA, pursuant
to California Public Resources Code Section 21080(b)(2) and (4) and CEQA Guidelines
Section 15269(b)-(c), which apply to emergency repairs to publicly owned facilities
necessary to maintain services essential to the public health, safety or welfare and other
specific actions necessary to prevent or mitigate an emergency. The statutory exemption
covers both the declaration of local emergency and the emergency coastal development
permit.
3.That the City Manager’s April 30, 2026, declaration of a local emergency for an emergency
condition resulting from a partial sewer pipe collapse on the North Batiquitos Interceptor
Sewer in the Ponto Area (Attachment A) is confirmed.
4.That the City Manager is authorized to direct the required emergency repairs to be
performed, take any directly related and immediate action required by the emergency, and
procure the necessary equipment, services, and supplies for these purposes, using
emergency procurement procedures.
5.That the City Manager or designee is authorized to sign all other documents necessary for
regulatory compliance, to extend funding opportunities, or to otherwise implement and
finalize the emergency repair work, all of which are subject to review and approval as to
form by the City Attorney’s Office.
6.That the City Manager is directed to return to the City Council at the next regularly
scheduled City Council meeting for a determination by a four-fifths vote whether the
emergency condition continues to exist.
7.That the City Council acknowledges receipt of the emergency coastal development permit
for the emergency repair work that was issued by the Assistant Director of Community
Development on May 1, 2026.
May 12, 2026 Item #7 Page 7 of 16
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PASSED, APPROVED AND ADOPTED at a Regular Meeting of the City Council of the City of
Carlsbad on the 12th day of May, 2026, by the following vote, to wit:
AYES: Blackburn, Bhat-Patel, Acosta, Burkholder, Shin.
NAYS: None.
ABSTAIN: None.
ABSENT: None.
_________________________________________
KEITH BLACKBURN, Mayor
_________________________________________
SHERRY FREISINGER, City Clerk
(SEAL)
May 12, 2026 Item #7 Page 8 of 16
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Attachment A
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May 12, 2026 Item #7 Page 10 of 16
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EMERGENCY COASTAL DEVELOPMENT PERMIT
NOTICE OF DECISION
May 1, 2026
Amanda Flesse, Utilities Director
City of Carlsbad Public Works Division
5950 El Camino Real
Carlsbad, CA 92008
RE: CDP 2026-0021 (PUB2026-0009) – Emergency Repair on North Batiquitos Interceptor Sewer, Ponto Area
– EMERGENCY PERMIT
The Assistant Director of Community Development has completed a review of the request for an Emergency Coastal
Development Permit to address a damaged segment of the North Batiquitos Interceptor Sewer located within the
Ponto area north of Poinsettia Lane and within the North County Transit District right of way. The emergency
condition was identified during routine maintenance closed-circuit television (CCTV) inspection and consists of a
partial collapse at the upper crown of an existing 27-inch vitrified clay pipe, resulting in a void and exposure to
surrounding soils. While no sewage release has occurred, the condition presents a risk of infiltration, blockage,
structural failure, and potential future spill, which could impact public health, nearby infrastructure, and the
surrounding habitat preserve area.
The proposed emergency work is limited to actions necessary to repair the damaged sewer facility and maintain
service. The authorized work includes temporary bypass of sewer flows; site access preparation; trench excavation,
shoring, and dewatering as necessary; removal and replacement of approximately 35 linear feet of damaged pipe
on a like-for-like basis; reconnection to existing pipeline segments; backfilling and compaction; and site restoration.
Construction access will utilize existing utility access points and portions of an adjacent pedestrian trail, which will
be temporarily closed during construction. No expansion of system capacity or upgrades beyond restoration of
existing conditions are proposed. The proposed work is located within the Coastal Zone and within the appealable
jurisdiction of the California Coastal Commission.
The proposed action is statutorily exempt from environmental review under the California Environmental Quality
Act (CEQA) pursuant to Public Resources Code Sections 21080(b) (2) and (4) and CEQA Guidelines Sections 15269(b)
and (c), which apply to emergency repairs to publicly owned service facilities necessary to maintain services essential
to public health, safety, or welfare.
The Assistant Director of Community Development APPROVES this request for an Emergency Coastal Development
Permit based upon the following:
Findings:
1.An emergency exists that meets the requirements of Carlsbad Municipal Code 21.201.190 and requires action
more quickly than permitted by the procedures for minor coastal development permits or for regular permits
and the work can and will be completed within thirty days unless otherwise specified by the terms of the permit;
2.The work proposed will be consistent with the requirements of the certified land use plan.
3.The Emergency Coastal Development Permit authorizes those actions necessary to address the immediate
emergency condition. If subsequent evaluation identifies additional habitat impacts or remediation needs
Exhibit 2
May 12, 2026 Item #7 Page 11 of 16
Docusign Envelope ID: B5E19FFC-613D-80A6-83CB-3C3AD0E6ECEF
CDP 2026-0021 (PUB2026-0009) – Emergency Repair on North Batiquitos Interceptor Sewer, Ponto Area
May 1, 2026
PAGE 2
beyond the scope of the emergency repairs, such work shall be subject to the separate Coastal Development
Permit review, as required by Condition Number 2.
Conditions:
1.The Emergency Coastal Development Permit is granted subject to completion of the emergency repair work
estimated to be within 60 days.
2.Submit a formal application for a regular Coastal Development Permit to the City of Carlsbad within 90 days of
this letter for any follow-up or permanent storm drain repair work beyond the scope of this emergency
authorization.
3.Prior to and during construction, the applicant shall coordinate with appropriate resource agencies and
implement biological monitoring, as necessary, to document site conditions and minimize impacts to sensitive
habitat areas, including the Poinsettia Station Vernal Pool Preserve. The subsequent Coastal Development
Permit application shall include documentation of agency coordination and demonstrate compliance with the
city’s Habitat Management Plan (HMP), as applicable.
CITY OF CARLSBAD
ERIC LARDY, AICP
Assistant Director of Community Development
EL: AA: mh
Attachment: Public Works Department Letter dated May 1, 2026 (Request for Emergency Coastal Development Permit)
c: Paz Gomez, Deputy City Manager
Jeff Murphy, Deputy City Manager
Mike Strong, Director of Community Development
Tim Lyons, Assistant City Attorney
Dave Padilla, Assistant Utilities Director
Michael O’Brien, Public Works Superintendent
Rosanne Humphrey, Senior Program Manager
Keri Martinez, Principal Engineer
Sean Diaz, Utilities Senior Engineer
Robb Efird, Principal Planner
Scott Donnell, Senior Planner
Alex Alegre, Associate Planner
File Copy
Data Entry
May 12, 2026 Item #7 Page 12 of 16
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Public Works Branch
Utilities Department 5950 El Camino Real Carlsbad, CA 92008 442-339-2722 t
May 1, 2026
City of Carlsbad Planning Division
1635 Faraday Avenue
Carlsbad, CA 92008
SUBJECT: Request for Emergency Coastal Development Permit for sewer pipe segment
repair on the North Batiquitos Interceptor Sewer in the Ponto area
Dear City of Carlsbad Planning Division:
This letter is submitted to request an Emergency Coastal Development Permit (CDP) to proceed
with emergency sewer repair work to a damaged sewer pipeline identified during a recent
routine maintenance video inspection.
Nature of the Emergency
Recent CCTV inspection identified damage to the 27-inch North Batiquitos Interceptor Sewer in
the Ponto area which includes a pipe break in the upper crown of the vitrified clay pipe
segment and is classified by the maintenance inspections as a partial “pipe collapse.” The
damage has resulted in a void in the pipe and exposure to the surrounding compacted soil.
Given the location of this void near the top of the pipe above the normal pipe flowline, sewage
is not currently leaking or spilling. However, if the pipe should experience high flow conditions,
such as infiltration occurring during heavy wet weather event, leakage or spilling could occur
and thus presents a potential risk to public safety, nearby infrastructure, and the surrounding
habitat preservation area, in addition to expensive restoration and fines from various
regulatory and environmental resource agencies. Potential blockage from incoming
surrounding soil through the void, and further failure of the pipe is also possible given the
deficiency in pipe’s integrity.
Cause of the Emergency
The specific cause of the pipeline damage is unknown. Video inspection of the entire segment
of the over 50-year old pipeline indicates expected aging and minor surface cracks and of the
pipe, with this one specific location of pipe collapse. The integrity of the remaining 2,700 linear
feet of this 27-inch pipeline to the north is intact, with some expected, required future
maintenance identified.
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May 12, 2026 Item #7 Page 13 of 16
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This single pipe damage suggests the possibility of some point loading or impact to the pipe
above grade. No such event or work has been identified as the cause. The pipeline is located
near North County Transit District (NCTD) railway but is over 70- feet east of the nearest spur,
and thus railway operations do not appear to be a factor. There is a 12-inch high pressure SoCal
gas line which crosses the sewer line near the break area and work on this pipeline could
potentially have caused the break. Neither NCTD nor the utility have found permits associated
with recent work. Cautious excavation of the sewer line needs to occur before any cause could
be determined.
No other conditions have been identified, and it is assumed repair to the pipe segment will
eliminate future emergency conditions.
Location of the Emergency
The repair site is on a 27-inch sewer interceptor pipeline that transports sewage from the City’s
southern sewer shed to the Encina Wastewater Treatment Plant located approximately a mile
north of the repair site. This pipeline extends through the NCTD right of way, approximately 70
feet east of the rail spurs. This sewer pipeline is also located with the city‘s Habitat
Management Preserve are known as the Poinsettia Station Vernal Pool Preserve which provides
habitat for seven federally listed plant and animal species. Access to the location of the repair
work is through the city’s Sand Shell sewer lift station via utility access easements located at the
southwest corner of the Waters End Residential Community. The lift station gates will be used
to access the adjacent pedestrian trail and NCTD ROW and the repair location. The pedestrian
trail will need to be utilized for repair work and associated bypass of sewer flow during repair
work and therefore unavailable to the public.
Proposed Remedial, Protective, or Preventive Work
The scope of emergency repair work will include removal and replacement of an approximate
35 linear feet of 27-inch VCP pipe. Prior to pipe repair work, sewer flow will need to be
diverted from this pipe segment via a sewer bypass system which pumps from an upstream
sewer access hole via a temporary bypass pump/piping system to a downstream sewer access
hole located approximately 450 feet downstream (north). The pipeline is located four to five
feet below grade and trench excavation will extend from the nearest manhole approximately
40 feet to the north allowing for connection of the replacement pipe to the nearest pipe joint.
Trench preparation will include installation of a trench shoring system and potentially
dewatering system to safely and properly install the replacement pipe. If needed, a trench
dewatering system will include an onsite tank for settling sediments from pumped groundwater
prior to discharge to the downstream sewer manhole. Specifics on the sequencing soil removal
during trench excavation will be identified by city staff and qualified biologist in recognition of
vernal pool impacts. A designated access area for equipment will be identified as well as
ingress and egress paths for workers and equipment. An onsite biological and cultural monitors
will be required to document the site prior to and throughout the work being performed to
determine the extents of temporary impacts to the preserve area.
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Staff is coordinating with NCTD, Encina Wastewater Authority, Waters End HOA, SoCAL Gas and
the RWQCB regarding access and potential permitting.
Emergency Circumstances and Justification for Action
City staff is requesting authorization of an emergency CDP to proceed with the repairs. The
damaged pipe requires immediate repair to prevent future sewer leaks and spills resulting in
health, safety and environmental impacts. Delaying repairs could result in more severe impacts,
including sewer spills, sediment blockages, and/or ultimate pipe failure.
Please let me know if additional information or clarification is needed to support this request.
Sincerely,
Amanda L. Flesse, P.E.
Utilities Director
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LOCATION MAP
VICINITY MAP
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PROJECT NAME PROJECT EXHIBIT
NUMBER
PROJECT SITE
5503-27 2
PROJECT SITE
NORTH BATIQUITOS INTERCEPTOR
PONTO SEWER PIPE REPAIR
\\files01v\Departments\Public Works\PW Common\Capital Improvement Program Projects\5503 & 3927 Sewer Line Replacement\5503-27 NBI Ponto Sewer Pipe Repair\Design\CAD\Ponto Sewer Pipe Repair Location Map Exh.dwg
Exhibit 3
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