BOARD AGENDA MEMORANDUM
Government Code § 84308 Applies: Yes ☐ No ☒
(If “YES” Complete Attachment A - Gov. Code § 84308)
SUBJECT:
Title
Receive the Winter Preparedness Briefing.
End
RECOMMENDATION:
Recommendation
Receive information on the Santa Clara Valley Water District’s preparedness for winter operations.
Body
SUMMARY:
As the agency authorized to provide local flood protection, Santa Clara Valley Water District (Valley Water) works diligently to protect Santa Clara County residents and businesses from the devastating effects of flooding. This report provides information regarding various measures Valley Water has taken to prepare for the Winter season. Specifically, it includes information on the following:
• Weather Forecast
• Board Natural Flood Protection Ends Policies
• Flood Awareness Campaign and Community Outreach, including to known Hot Spots
• Emergency Action Planning
• Monitoring and Flood Forecasting
• Reservoir Management
• Real-time Information, Alerts and Warnings
• Valley Water, Countywide and Regional Emergency Management Systems
• Valley Water Field Response Actions and Capabilities
• Storm Ready Certification
Background
Winter Hazards
Winter brings an additional set of seasonal hazards that threaten both watersheds and water utility operations. Severe and/or extended precipitation can overwhelm engineered and natural channels and has the potential to damage Valley Water's flood protection infrastructure. The resulting flooding can prompt municipalities to initiate evacuations and sheltering and disrupt transportation. Severe storms can also bring high winds and cause land movement that have the potential to impact power, communication, water, and wastewater utility infrastructure.
Weather Forecast
National Weather Service (NWS) seasonal weather models predict a 57% chance of La Niña during the Northern Hemisphere winter (December-February) 2024-25, with a 37% chance of La Niña February-April. La Niña results in cooler sea-surface temperatures that bring dryer and warmer weather overall, with extreme cold spells at times. The forecast for the overall winter is uncertain based on current models. It is uncertain at this time the levels of precipitation that will be produced in the winter season for Santa Clara County.
NWS meteorologists will also be watching how the Arctic Oscillation (AO) and Madden-Julian Oscillation (MJO) fluctuate through the winter season. These and other seasonal and intraseasonal oscillations could bring swings in precipitation amounts, fluctuating snow levels, and/or atmospheric rivers. Medium range forecast capabilities will help to distinguish these events with as much lead time as 10-14 days, though the details may not be worked out until within a few days of any given event. Keep in mind that a season with below-normal rainfall can still produce flooding, especially if much of the rainfall occurs over a short period of time.
Near-term weather forecasts enable Valley Water to anticipate the location and intensity of rainfall to better mobilize response efforts. Valley Water receives weather forecasts from multiple sources, including meteorology consultants and the NWS. Using this data, Valley Water staff makes decisions for flood fighting and for reservoir operations.
Board Natural Flood Protection Ends Policies
Valley Water’s Board of Directors has established Natural Flood Protection (NFP) Goals 3.1, 3.2, and 3.3 to provide flood protection for residents, businesses, and visitors; and to reduce the potential for flood damages. These goals establish the following nine natural flood protection objectives.
1. Prioritize maintenance of existing facilities over construction of new capital projects (Objective 3.1.1)
2. Inspect and maintain facilities on a regular basis (Objective 3.1.2)
3. Perform maintenance using maintenance guidelines updated on a regular basis (Objective 3.1.3)
4. Develop, maintain, and communicate emergency action plans (Objective 3.2.1)
5. Develop, maintain, and communicate flood information to the community (Objective 3.2.2)
6. Provide expertise in flood forecasting and flood warning systems to municipalities (Objective 3.2.3)
7. Provide expertise to encourage public agencies to reduce flood risk and protect floodplain benefits (Objective 3.2.4)
8. Provide equitable, timely, and achievable flood protection for health and safety (Objective 3.3.1)
9. Protect people and property from flooding by applying a comprehensive, integrated watershed management approach that balances environmental quality, sustainability, and cost (Objective 3.3.2)
This memorandum describes how Valley Water staff is working to achieve each of these objectives.
1. Protect Parcels from Flooding (3.3.1 and 3.3.2)
Valley Water’s Watersheds Design and Construction Division plans, manages, and implements capital improvements to comply with the Board’s Ends Policy to protect parcels from flooding. A total of 15 flood protection projects are underway in Fiscal Year 2024-2025 with a total FY25 budget of $132.6 million. This amount is the “Flood Protection” total, comprised of the Watershed Stream Stewardship Fund and the Safe, Clean Water and Natural Flood Protection Fund. Six of these projects are Safe, Clean Water projects, and nine are funded by property taxes. All have the primary objective of providing natural flood protection for residents, businesses, and visitors.
2. Preserve Flood Conveyance Capacity (3.1.1, 3.1.2 and 3.1.3)
Valley Water’s Watersheds Operations and Maintenance Division (Watersheds O&M) performs sediment removal, levee inspection and maintenance, debris removal, vegetation management, and erosion protection and repairs to comply with the Board’s Ends Policy to preserve flood conveyance capacity. Watersheds O&M work that has been accomplished in 2024 through Valley Water’s Stream Maintenance Program includes the following.
• Removal of approximately 10,228 cubic yards of sediment (estimated)*
• Stabilization of approximately 2,070 linear feet of riverbank (estimated)*
• Completion of 1,246 acres of in-stream vegetation control over 148 miles of streams*
*Work continues. Quantities estimated through October 15, 2024.
Valley Water staff continues to respond to calls from throughout the county regarding vegetation concerns. Field crews continue to monitor creek conditions to selectively reposition or remove fallen trees that could potentially block flows in local creeks or cause other hazards.
3. Integrated Watershed Management to preserve floodplain functions (3.3.2)
Valley Water preserves floodplain functionality and other watershed assets and interests from external land-use activities by reviewing and commenting on development proposals for consistency with the Guidelines and Standards for Land Use Near Streams, and by participating in the review of municipal General Plan updates.
Valley Water’s Community Projects Review Unit issues encroachment permits that regulate the third-party use or modification of Valley Water lands along local waterways and provides ordinance enforcement consistent with the Board adopted encroachment remediation program and Board governance policies. Additionally, Valley Water reviews and comments on environmental documents and plans for projects outside Valley Water right-of-way to promote Valley Water’s water resource interests. Through these processes, Valley Water advocates for development setbacks and site layouts that strive to maximize protection of stream and riparian corridors and floodplain function.
4. Reduce flood risks through engagement with other agencies and the public (3.2.4)
Flood Awareness Campaign and Community Outreach
Valley Water delivers multilingual flood preparedness messages throughout Santa Clara County, focusing on flood-prone areas. This year’s campaign features the slogan "Beware. Be Ready. Be Flood Safe.” Materials include the nine Community Rating System (CRS) Santa Clara County Multi-jurisdictional Program for Public Information (PPI) Flood Preparedness messages as well as a call for residents and business owners to visit valleywater.org/floodready </..//../Users/AMYFONS/AppData/Local/Microsoft/Windows/INetCache/Content.Outlook/3VHQ9BKM/valleywater.org/floodready> to locate their address in the FEMA Special Flood Hazard Area (SFHA) map, sign up for emergency alerts, and find sandbag locations.
Postcard, Floodplain Mailer, and Trifold
Our multilingual postcard, featuring the nine PPI Flood Preparedness tips identified in the 2021 PPI, will be delivered to 49,555 homes and businesses in or near flood-prone areas starting November 1, 2024.
The floodplain mailer featuring the full nine multilingual flood preparedness messages, a floodplain manager phone directory by city/county, and a refrigerator magnet with a QR code that links to valleywater.org/floodready </..//../Users/AMYFONS/AppData/Local/Microsoft/Windows/INetCache/Content.Outlook/3VHQ9BKM/valleywater.org/floodready> will be delivered to homes and businesses in the FEMA SFHA on December 15, 2024. This year, the floodplain mailer also includes a centerfold section with an infographic explaining the use and benefits of our stream gauge portal.
A multilingual trifold outlining what to do before, during, and after a flood will be mailed to homes and businesses in the FEMA SFHA on January 15, 2025.
Flood Awareness Media/Digital Campaign
Our annual flood awareness advertising campaign launches in November 2024 and continues through the end of February 2025 or longer if the winter is particularly wet. The campaign is geo-targeted to serve the IP addresses of devices registered to homes in the FEMA SFHA and is supported by geo-fenced ads and social media postings targeted to zip codes in the flood zone.
In early November, a partner toolkit will be distributed to retailers, Public Information Officers, CRS partners, community associations, and elected officials. A flood awareness post will also be shared on our blog and posted to each Board Director's area on Nextdoor.
Flood awareness messages will also be shared through multilingual community newspaper sites.
Hot Spot Outreach
Flyers with our Be Flood Safe calls to action will be mailed to community associations in flooding hot spot locations along with a social media partner toolkit. As needed through the winter season, the IP addresses of residences located in and around hot spots for flooding will be targeted for emergency alert ads. Banners alerting the community about the potential for flooding will be hung at hot spots near creek locations, and supermarket shopping cart ads will be placed in the area.
Multi-Agency Press Conference
We will hold a multi-agency press conference in December 2024 to discuss joint flood preparedness efforts. The event will feature interactive sandbagging and emergency kit assembly stations and will be live-streamed on Facebook.
Staff will also share the details of our flood awareness campaign during the Valley Water Winter Preparedness Workshop for external agencies.
Emergency Starter Kits and Other Outreach Items
Valley Water acquired a limited number of flood emergency starter kits to promote flood readiness and will distribute them throughout the County as part of Valley Water’s booth participation. These emergency starter kits include first aid supplies, a flashlight, a poncho, and an emergency thermal blanket. These popular giveaway items encourage the community to be flood-safe by developing an emergency plan and creating a more comprehensive three-day emergency kit based on their family size and needs.
Community Benefits and Event Outreach
Starting in October, the CRS Program and Office of Government Relations resumed sharing flood preparedness messaging at local community events before the rainy season.
As part of the 2021 PPI flood preparedness outreach efforts, Valley Water's CRS Program distributed emergency pocket-sized first aid kits to all Santa Clara County communities to distribute at public outreach events. The first aid pocket kits are customized with Valley Water's logos and branded "Get Flood Ready." These small kits help standardize local flood-preparedness outreach throughout the County and encourage residents to be prepared before an event occurs.
In addition to the first aid pocket kits, CRS aims to broaden our flood-preparedness outreach to underserved communities by partnering with other community organizations to distribute multilingual flood-preparedness materials.
Education Outreach
Education outreach includes flood awareness and preparedness messaging during the winter season and virtual and in-person visits to schools, libraries, and youth-serving organizations throughout the County. Materials available for educators include the "I Am Ready" and "Estoy Listo" Flood Preparedness Activity Books, created by the US Army Corps of Engineers, stickers, and other flood-preparedness activity books and sheets for students.
Emergency Alerts
Through our flood preparedness outreach efforts and as part of the 2021 PPI, Valley Water encourages residents to sign up for Santa Clara County's official emergency alert and warning system, AlertSCC. AlertSCC is a free, easy, and confidential way for anyone who lives or works in Santa Clara County to get emergency warnings sent directly to their cell phone, mobile device, e-mail, or landline. AlertSCC is one of the most effective ways for local jurisdictions to communicate flood hazards and evacuation orders, but it requires residents to opt into the system.
Valley Water Website, Newsletter, and Social Media Channels
Valley Water's website, valleywater.org/floodready, serves as a one-stop shop for flood-related information, including registering for emergency updates, flood safety tips, and information on sandbag sites and stream and reservoir gauges in the County. The website also prominently displays Valley Water's Flood Watch Tool. Online publications through our news website, valleywaternews.org, will continue to provide registered recipients with timely and immediate flood-hazard messages, and social media messages will be posted frequently through the rainy season.
5. Prepare and Respond Effectively to Flood Emergencies (3.2.1, 3.2.2 and 3.2.3)
Despite all the proactive efforts to remove parcels from flood hazard zones, maintain channel conveyance capacities and floodplain function, and engage the public with flood awareness and safety messages, floods still can and do occur.
Flood emergency preparedness entails the combined efforts of many units at Valley Water, notably the Office of Emergency Services, Security Office, Field Operations, Water Supply Operations and Planning, Hydrology Hydraulics and Geomorphology, Communications, Government Relations, and the Clerk of the Board, among others. Valley Water staff perform field emergency response and recovery activities, while others fulfill positions in the Departmental Operation Centers (DOCs) and Emergency Operations Center (EOC). Other staff are key components to the preparedness planning for flood emergencies.
To ensure the best possible state of readiness to address flooding when it does occur, Valley Water maintains tools, processes, trained staff, and interagency relationships that enable coordinated field response and public information.
Emergency Action Planning
Emergency Action Plans (EAPs) are documents that identify potential emergency conditions at facilities, such as creeks or dams, and specify actions to minimize loss of life and property damage. These documents include the following.
• Actions, in coordination with emergency management authorities, to respond to incidents or emergencies
• Warning and notification messages for responsible downstream emergency management authorities
• Inundation maps to help emergency management authorities identify critical infrastructure and population-at-risk sites
• Roles and responsibilities between responding agencies
The EAPs for dams are created following the Federal Emergency Management Agency guidelines for emergency action planning (FEMA Publication No. P-64). The Anderson Dam EAP also incorporates the guidance of the Federal Energy Regulatory Commission (Chapter 6 Emergency Action Plans of the Engineering Guidelines for the Evaluation of Hydropower Projects), due to Anderson’s small hydropower facility.
The EAPs for creeks have been developed in coordination with the affected jurisdictions where flooding may occur. The Joint EAP with the City of San Jose includes Coyote Creek, Guadalupe River, Ross Creeks, Canoas Creek, Lower Silver Creek and Lake Cunningham. Staff has drafted an update to the Joint EAP to incorporate new flood mitigation measures completed as part of the Anderson Dam Seismic Retrofit Project and expanding its coverage to incorporate Berryessa Creek. EAPs for West Little Llagas Creek and Uvas Creek were developed in coordination with the cities of Gilroy and Morgan Hill. Valley Water also developed an EAP for San Francisquito Creek, which was done in coordination with the City of Palo Alto and the San Francisquito Creek Joint Powers Authority. The EAP for West Valley Watersheds was originally completed in coordination with City of Santa Clara and it includes a response procedure for San Tomas Aquino Creek. Staff is in the process of adding a new procedure to the West Valley Watersheds EAP to include Sunnyvale East and Sunnyvale West channels. The Lower Peninsula Watershed EAP includes the Palo Alto Flood Basin and the Permanente & Hale Creeks. These last three locations include input from the cities of Palo Alto, Mountain View, and Los Altos. An EAP for Lower Penitencia Creek has recently been completed in coordination with the City of Milpitas. Finally, Valley Water staff has developed EAP Quick Guides for most of our EAPs. These are short summary documents that provide quick access to key information for EOC staff and responses.
Monitoring and Flood Forecasting
Valley Water evaluates forecasts of incoming weather systems based on weather reports received from multiple partners, including the National Weather Service (NWS), paid weather consultants, and partnerships with the University of California San Diego and Colorado State University. In addition to standard weather reports, detailed quantitative precipitation forecasts (QPFs) are obtained from these sources to get a picture of a storm event. These QPFs include details such as the amount, duration, location, and timing of storm patterns.
For real-time monitoring, as the rain and flood events unfold, Valley Water operates more than 100 precipitation, reservoir level, and stream gauges. All of Valley Water’s stream and rain gauges are regularly maintained and calibrated. Valley Water also hosts an “X-band” radar unit on the rooftop of the Penitencia Water Treatment Plant. The unit is part of the Bay Area AQPI (Advanced Quantitative Precipitation Information) system. This short range and lower elevation radar supplements our existing rainfall gauge system, and more importantly, provides more precise radar data. During storm events, this X-band radar augments the existing radar operated by the NWS to provide Valley Water with a clearer picture of the storm system
Under Valley Water’s Safe, Clean Water Program Priority F7 Project (Previously C2), Emergency Response Upgrades Project, Valley Water runs an experimental flood forecast and warning system, using automated hydrologic and hydraulic models to determine creek runoff and expected reservoir levels. The models process data from both the QPFs and monitoring sensors mentioned earlier. Valley Water also partners with the California-Nevada River Forecast Center (CNRFC), who forecasts several creeks and reservoirs in our jurisdiction. In addition, Valley Water is leveraging innovative tools that use machine learning to model hydrologic processes. Combined, these flood forecasting resources provide intelligence to decision-makers, emergency responders, and the general public.
Reservoir Management
Valley Water operates ten surface water reservoirs throughout the county. The reservoirs are operated primarily as water supply facilities for conjunctive use in order to capture and store raw water for groundwater recharge or in-lieu groundwater recharge activities. Releases from the reservoirs are made based on water right provisions, recharge operations, dam safety requirements, and environmental compliance.
Currently, all of the reservoirs, with the exception of Vasona, Uvas, and Calero reservoirs, have rule curves that were developed from historic hydrology and provide an incidental benefit of flood risk reduction. The incidental flood risk reduction rule curves balance water supply needs with reducing flood risk, allowing for a high probability of the water being recovered by the end of the season. Vasona is a small reservoir and has no rule curves. Uvas Reservoir does not have an incidental flood risk reduction rule curve to increase the frequency, duration, and magnitude of modest spills for channel habitat improvement. Instead, its natural resource permitting requires pulse flow releases for fish migration, which can decrease reservoir storage. Calero Reservoir’s flood risk reduction rule curve is not presently in effect because the California Department of Water Resources, Division of Safety of Dams (DSOD) seismic restriction limits storage below the curve.
Valley Water operates five dams that are subject to seismic safety restrictions. These are Calero, Almaden, Guadalupe, Coyote, and Anderson dams. DSOD has imposed a seismic safety restriction on Calero Reservoir limiting its storage to 45 percent (%) of capacity. Almaden, Guadalupe, and Coyote reservoirs’ DSOD restrictions are at 93%, 64%, and 53% of their respective capacities.
For Anderson Reservoir’s operation, the Federal Energy Regulatory Commission (FERC) issued a directive on February 20, 2020, to draw down Anderson Reservoir to water surface elevation 488 feet (NAVD 88). The FERC directive was amended on April 4, 2024, by revising the deadpool elevation to 490 feet and allowing for an additional two (2) feet of storage above deadpool to benefit the aquatic resources. The deadpool storage of 3,159 acre-feet constitutes about 3% of the reservoir’s full capacity. Valley Water has been in compliance with the FERC directive that guarantees additional storage buffer in the reservoir, which in turn provides a greatly reduced chance of spilling.
Since February 2019, Lexington Reservoir has been re-operated with a temporary flood risk reduction rule curve (between December 1 and April 1) to significantly reduce the flood risk to the community along Guadalupe River from Tasman Drive to Interstate 880. This temporary flood risk reduction rule curve can impact water supply, and a methodology was developed to comply with the District Act and State Law regarding the use of a facility funded by groundwater charges. In the winters of 2023 and 2024, staff used Forecast Informed Reservoir Operations (FIRO) on Lexington Reservoir. FIRO allows for storing more water in Lexington Reservoir above the flood risk reduction rule curve or drawing down the reservoir below the rule curve depending on the weather forecast. Unless the Board directs otherwise, staff will continue to use a temporary flood risk reduction rule curve and FIRO on Lexington Reservoir during the 2024-2025 storm season.
Real-time Information, Alerts, and Warnings
Valley Water provides precipitation and stream gauge data to the public via multiple websites, such as the surface water monitoring website <https://alert.valleywater.org/>, which utilizes a user-friendly interactive map to allow residents to monitor levels in their own neighborhoods. We also regularly coordinate with the National Weather Service and local jurisdictions during storm events to share information about potential floods.
Valley Water’s website provides access to reservoir levels, precipitation data, stream flow, and flood-safety measures. Valley Water also promotes the County’s emergency alert system AlertSCC <https://emergencymanagement.sccgov.org/AlertSCC>.
Valley Water, Countywide, and Regional Emergency Management Systems
Valley Water maintains facilities, technology, equipment, procedures, trained staff, and inter-agency relationships that enable it to respond to floods and other emergencies. Valley Water emergency management facilities include its district-wide Emergency Operations Center (EOC) and Water Utility/Watersheds Departmental Operations Centers (DOCs). Valley Water maintains a dedicated, primary EOC that is equipped with both high and low-tech communication information storage and display technologies to allow the EOC functions to perform under all hazard scenarios. Valley Water has also incorporated virtual hybrid EOC environments where remote and onsite staff may operate effectively during emergency activations. EOC equipment is regularly inventoried, maintained, and tested to ensure readiness. Valley Water DOC facilities are equipped for emergencies that can be handled within departmental resources and capabilities. EOC position-specific checklists are available to help guide EOC staff in the performance of their Standardized Emergency Management System (SEMS) response functions.
Valley Water EOC staff have participated in multiple trainings as well as internal and multi-agency exercises. Training and exercises are designed and utilized to develop, learn, and test response capabilities under various hazard scenarios. The table below shows some examples of past trainings/exercises for Valley Water EOC response staff. Also included in this table are the recent EOC Activations, which act as valuable training during real-life events that identify best practices and opportunities for improvement:
The training opportunities allow for staff to become more familiar with their roles and build comfort in the tools and processes they will be expected to utilize during emergencies. This has proved true during emergencies such as the COVID-19 Pandemic, wildfires, earthquakes, extended power outages, and PG&E Public Safety Power Shutoff (PSPS) events, as well as drought. The real-life experiences, as well as the exercise opportunities, enabled staff to practice and identify areas of improvement for operational coordination, operational communication, situational awareness, public information and warning, and infrastructure system core capabilities as defined by the National Response Framework. Joint exercises with our response partners help to foster mutual understanding and improve our collective response capabilities.
Each Fall, Valley Water’s Office of Emergency Services hosts a multi-jurisdictional Winter Preparedness Workshop. This year’s event was held on October 24, 2024, and conducted as a hybrid (both in person and through Zoom Webinar). Attendees included emergency managers and public works representatives from our cities, the County, and other local and state agencies. Valley Water staff reviewed the following topics during the workshop.
• Reservoir Operations
• Emergency Services
• Flood Forecast & Warning System
• Public Information
• Sandbag Operations
• Watershed Field Operations
The National Weather Service also provided the winter season outlook regarding the probability of seasonal precipitation, temperatures, and other environmental aspects.
In addition to the Winter Preparedness Workshop, Valley Water emergency management staff, senior executives, and elected officials foster strong interagency emergency preparedness relationships by participating in several important groups, including the Santa Clara County Emergency Managers Association, the Santa Clara County Operational Area Signatories, and the Santa Clara County Emergency Operational Area Council.
Valley Water Field Response Actions and Capabilities
In preparation for a possible flood event, Valley Water can mobilize a field response that:
• maintains a Watersheds 24/7 Hotline;
• deploys Field Information Teams (FIT); and
• maintains a list of known flooding hotspots to expedite on-site arrival of resources and crews that can remove blockages when safe to do so, deploy sandbags, and perform other functions to maximize flood conveyance capacity during a storm.
Valley Water provides filled sandbags at five sites across Santa Clara County: Valley Water’s Winfield site, Palo Alto Airport site, City of San Jose Central Yard, Alviso site, and Morgan Hill site. Typically for winter seasons with average rainfall forecasts, Valley Water stocks 21,600 filled sandbags at these locations by mid-October, restocking those sites as needed. In the event that the availability of filled sandbags cannot meet demand, Valley Water will supply empty bags and sand at those locations.
Additionally, Valley Water provides empty sandbags to municipal and county public works departments to stock an additional 20 sites around the County. Empty sandbags are offered to county public works agencies beginning October 1.
Maps of sandbag locations have been prepared in conjunction with other entities. The site locations are provided through the following link:
<https://www.valleywater.org/floodready/sandbags>.
Valley Water currently has an additional 65,000 empty sandbags and 400 cubic yards of sand in storage to support distribution sites. An additional 100,000 empty sandbags are being ordered for delivery by December 1 to support Valley Water’s sandbag program.
Storm Ready Certification
As a result of Valley Water’s efforts to protect parcels from flooding, preserve flood conveyance capacity, engage the public to reduce flood risks, and maintain capabilities to respond to storm and flood events, Valley Water continues to be recognized by the NWS as Storm Ready. In April 2021, NWS recertified Valley Water as Storm Ready. NWS designation as Storm Ready is a three-year certification. Valley Water will recertify in FY25.
ENVIRONMENTAL JUSTICE AND EQUITY IMPACT:
There are no Environmental Justice impacts associated with this item. The Winter Preparedness Briefing provides information to the Board of Directors regarding work throughout the year, emergency preparedness and response, and community communications and outreach during Winter and Pre-Winter periods. Valley Water acknowledges that disadvantaged communities are disproportionately impacted by the effects of flood. To address these impacts, Valley Water communicates and performs outreach to all communities living in floodplains.
FINANCIAL IMPACT:
There is no financial impact associated with receiving a briefing on winter preparedness.
CEQA:
The recommended action does not constitute a project under CEQA because it does not have the potential for resulting in direct or reasonably foreseeable indirect physical change in the environment.
ATTACHMENTS:
Attachment 1: PowerPoint
*Handout 3.4-A: Flood Postcard
UNCLASSIFIED MANAGER:
Manager
Alexander Gordon, 408-630-2637