EXECUTIVE SUMMARY

This Implementation Plan has been developed to ensure that compliance with the objectives of the Mitigation Monitoring, Compliance and Reporting Program (MMCRP) for construction of the Pacific Pipeline. In order to ensure that compliance, this plan describes in detail the actions that will be taken by Aspen Environmental Group and its team of subcontractors (the Aspen team) to ensure that the construction of the Pacific Pipeline takes place in a manner consistent with the conditions of approval by the Lead Agencies, and in compliance with project parameters as described in the Proponent=s Application and summarized in the CEQA/NEPA documents subsequently prepared for the Project. The contract for implementation of the MMCRP was issued to Aspen by the California Public Utilities Commission in August 1996 following a competitive selection process, and is supported by a Memorandum of Understanding with the U.S. Forest Service Angeles National Forest (ANF). Mitigation measures that will be implemented under this program were developed in the Pacific Pipeline Project Final Environmental Impact Report (FEIR, 1993) and the Pacific Pipeline Project Final Environmental Impact Statement/Subsequent Environmental Impact Report (EIS/SEIR, 1996). Those documents also included description of project design and impact-reduction measures to which Pacific Pipeline System, Inc. (PPSI) committed as part of their proposed project; the implementation of those Aapplicant proposed measures@ and project parameters will also be monitored as part of the MMCRP.

Following an Introduction in Section 1, Section 2 of this Implementation Plan describes the purpose and objectives of the MMCRP, the authorities supporting implementation of the Program, and the background to Program adoption. Section 3 of the Plan describes the management structure for Aspen=s team, and defines responsibilities and organization for Aspen and PPSI and its Contractor/Subcontractors. This section also describes the data management system to be used in the field monitoring process, and the proposed Public Access Program that is required by the CPUC.

Also included in this Plan is a summary of the plans and permits that will be submitted by PPSI or issued by responsible agencies. These plans will be reviewed during the pre-construction phase of the project; the review guidelines and deliverables to be provided to the Lead Agencies are discussed in Section 4.

The MMCRP will include comprehensive training and briefing programs, including training of Aspen monitors, supervision of the construction personnel training, and briefings for Agency personnel. Section 5 of this Implementation Plan includes detailed descriptions of training programs and manuals.

The core of this Implementation Plan is contained in Section 6, which (in conjunction with the Appendices) will also serve as the Field Monitoring Manual. This section includes a description of the Pacific Pipeline Project; the roles, responsibilities, and authority of field monitors and expert reviewers in the field; descriptions of agency jurisdictions; guidance on interaction with PPSI and contractor personnel; communication protocols; and instruction on documentation and reporting. Section 6 also defines the compliance evaluation process, including the procedures for determining non-compliance events; dispute resolution process; and variance procedures. Monitoring criteria are presented, along with a general description of the mitigation measures, applicant-proposed measures, and other permits and requirements.

Section 7 defines agency and PPSI contacts and relationships. Several Appendices are included in this Implementation Plan; they include the full text of mitigation measures as they appeared in the FEIR and FEIS/SEIR and later adopted by the lead agencies, performance and effectiveness criteria for each measure, applicant-proposed measures, permit conditions from responsible/cooperating agencies, and other regulatory requirements.

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