Mitigation Monitoring and Reporting Program

Transcription

1 Air Resources Board Southern California Consolidation Project Mitigation Monitoring and Reporting Program Prepared for: Department of General Services 707 Third Street West Sacramento, California Contact: Joel Griffith On behalf of the Lead Agency California Air Resources Board 1001 I Street Sacramento, California Contact: Deidre Cyprian JUNE 2017

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3 INTRODUCTION The California Environmental Quality Act (CEQA) requires that when a public agency has made findings that mitigation measures are required to avoid or substantially lessen significant adverse environmental impacts identified in a Final EIR, the agency shall adopt a program for monitoring or reporting on the mitigation to ensure the mitigation measures are implemented (14 CCR 15097). This Mitigation Monitoring and Reporting Program (MMRP) has been prepared to ensure the effective implementation of the mitigation measures that the Air Resources Board (ARB) adopted as part of its approval of the Southern California Consolidation Project (project), as set forth in the Final Environmental Impact Report (EIR) for the project. ARB, with assistance from the California Department of General Services (DGS), prepared the Final EIR. ARB, as the designated lead agency for the project, or an authorized assignee, is responsible for enforcing and verifying that each mitigation measure is implemented. As the authorized assignee by ARB, DGS will primarily be responsible for implementation of mitigation measures during the construction phase of the project. The MMRP establishes the framework the ARB, DGS, and others will use to implement the mitigation measures adopted in connection with project approval, and the monitoring/ reporting of such implementation. Monitoring is generally an ongoing or periodic process of project oversight. Reporting generally consists of a written compliance review. This program (1) provides a framework to document implementation of the required mitigation, (2) identifies monitoring/reporting responsibility, (3) establishes the frequency and duration of monitoring/reporting, (4) provides a record of the monitoring/reporting, and (5) ensures compliance with those mitigation measures. identifies the mitigation measures, monitoring/mitigation timing, responsible person/ agency, monitoring procedures, and a record of implementation of the mitigation measures. The numbering of mitigation measures follows the numbering sequence found in the EIR. June

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5 Biological Resources MM-BIO-1. Two pre-construction surveys for burrowing owl shall be completed prior to any site preparation or construction activities to ensure that burrowing owls have not colonized the project site. Following the California Department of Fish and Wildlife (CDFW) protocol provided in the Staff Report on Burrowing Owl Mitigation (March 2012), the first survey shall occur prior to and within 30 days of the first site disturbance, and the second shall occur prior to and within 24 hours of the first ground disturbance. If burrowing owls are detected on site, a burrowing owl mitigation plan shall be prepared following accepted protocol and be approved by CDFW. MM-BIO-2. Site construction activities (such as watering, disking, vegetation clearing, grubbing, and grading) shall be conducted outside of the raptor and songbird nesting season (January 15 through August 31). If it is not feasible to conduct construction activities outside of nesting season, then a qualified biologist shall conduct a pre-construction nesting bird survey no more than 72 hours prior to initiation of construction activities to ensure that nesting birds are not present. If active nests (including nest construction) of native species are identified, the biologist shall establish appropriate construction-free buffers around the nests, and the buffer areas shall be avoided until the nests are no longer active, and the juvenile birds can survive independently from the nests. Typically, established buffers are greater for raptors than songbirds and depend on the species, the nesting stage, and type of construction activity proposed. The buffer shall be no less than 200 feet for raptors and no less than 25 feet for songbirds, or as determined by a qualified biologist based on the observed tolerance behaviors of the bird. In some cases, the buffer may need to be adjusted depending on bird behavior observations made by a qualified biologist. The qualified biologist has authority to temporarily stop work if nesting birds are disturbed. MM-CUL-1. Archaeological monitoring will be implemented for initial disturbance of sediments with the potential to uncover historical or prehistoric archaeological materials. These ground disturbing activities would include site preparation, excavation, grading, drilling, and similar activities. a. Two pre-construction surveys for burrowing owl b. Preparation of a burrowing owl mitigation plan if burrowing owls are detected on-site c. If prepared, provide mitigation plan to CDFW for approval. *The actions contemplated under MM-BIO-1 may be performed concurrently with activities under MM-BIO- 2, and by the same qualified biologist, if the timing for both measures aligns. a. Site construction activities (such as watering, disking, vegetation clearing, grubbing, and grading) shall be conducted outside of the raptor and songbird nesting season (January 15 through August 31). If it is not feasible for such activities to occur outside these time periods, then the project shall comply with the requirements outlined in b through d. b. If construction activities (such as watering, disking, vegetation clearing, grubbing, and grading) occur between January 15 through August 31, then a qualified biologist shall conduct a pre-construction nesting bird survey no more than 72 hours prior to initiation of construction activities. c. If nesting bird surveys are conducted, the results of the survey(s) shall be summarized in a letter report made available to DGS within one week of completion of the surveys. d. If active nests are located pursuant to b, then the biologist shall document monitoring of active nests when construction activities occur within 100 feet of the buffer or at the qualified biologist s discretion. a. Archaeological monitoring during site preparation, excavation, grading, drilling, and similar activities by qualified archaeologist * The actions contemplated under MM-CUL-1, MM- CUL-2, and MM CUL-3 for a qualified archaeologist and MM-CUL-4 for a qualified paleontologist may be performed by the same individual if that individual meets both sets of qualifications, and if timing for the actions aligns. a. The first survey shall occur prior to and within 30 days of the first site disturbance, and the second shall occur prior to and within 24 hours of the first ground disturbance b./c. Prior to construction a. Outside of January 15 through August 31 b. No more than 72 hours prior to initiation of construction activities c. Within one week of completion of nesting bird survey(s) d. At qualified biologist s discretion Cultural Resources a. During initial ground disturbing activities, including site preparation, excavation, grading, drilling, and similar activities. ARB/DGS ARB/DGS ARB/DGS First Survey Second Survey First Survey Second Survey June

6 MM-CUL-2. In the event that cultural resources are exposed during construction activities for the proposed project, all construction work occurring within 100 feet of the find shall immediately stop until a qualified archaeologist, meeting the Secretary of the Interior s Professional Qualification Standards, can evaluate the significance of the find and determine whether or not additional study is warranted. Depending upon the significance of the find, the archaeologist may simply record the find and allow work to continue. If significant archaeological resources are discovered, additional work such as a preparation of an archaeological treatment plan, testing, or data recovery may be warranted. The project archaeologist and ARB shall confer regarding mitigation of the discovered resource(s). If the cultural resource(s) is associated with Native American activities, a representative of the consulting Native American tribe(s), including but not limited to the Soboba Band of Luiseno Indians and San Manuel Band of Mission Indians, shall also confer regarding mitigation and a treatment plan and disposition plan shall be prepared and implemented to protect the identified cultural resources from damage and destruction. The treatment plan shall contain a research design and data recovery program necessary to document the size and content of the discovery such that the resource(s) can be evaluated for significance under CEQA criteria. The research design shall list the sampling procedures appropriate to exhaust the research potential of the cultural resources in accordance with current professional archaeology standards. If the discovered cultural resource(s) is associated with Native American activities, the treatment plan shall require monitoring by the consulting Native American tribe(s) during data recovery The treatment plan shall require that all recovered cultural resources undergo basic field analysis and documentation or laboratory analysis, whichever is appropriate. At the completion of the basic field analysis and documentation or laboratory analysis, any recovered cultural resources shall be processed according to the methods as outlined in items a e in MM-CUL-3. a. Retain qualified archaeologist meeting the a. At least 2 weeks prior to start of ARB/DGS Secretary of the Interior s Professional construction Qualification Standards. b. Immediately upon exposing b. Stop all construction work occurring within 100 cultural resources during feet of a archaeological find and evaluate the construction activities significance of the find, in the event that cultural c. Upon determination of a significant resources are exposed during construction archaeological resources are activities discovered c. If find is determined to be a significant d. If cultural resource finding(s) are archaeological find, prepare archaeological associated with Native American treatment plan, testing, or data recovery activities MM-CUL-3. Treatment and Final Disposition of Cultural Resources Associated with Native American Activities: After consultation with the consulting Native American tribe(s), including but not limited to the Soboba Band of Luiseno Indians and San Manuel Band of Mission Indians, ARB shall relinquish ownership of all cultural resources through one or more of the following methods: a. Human remains, sacred/ceremonial items, and burial goods will be addressed per State Law and MM-CUL-1. b. ARB will accommodate the process for avoidance, preservation in place, or potential reburial of the cultural d. Preparation of a treatment plan and disposition plan in consultation with Native American tribe(s) (if the resource is associated with Native American activities). e. Cultural resources shall be processed according to the methods outlined under MM- CUl-3. a. ARB to consult with Native American Tribe(s), and if needed, relinquish ownership of all cultural resources b. Provide documentation of consultation with Native American Tribe(s) and compliance with State Law, MM-CUL-1, and MM-CUL-3(a-e). c. Archaeologist to prepare a final report to document the significance and treatment findings. d. Curate the cultural resources with an appropriate, federally recognized curation e. At completion of the basic field analysis and documentation a. Relinquish ownership following consultation with the consulting Native American tribe(s) b. Upon determination that cultural resources and/or associated records will not be claimed by any tribe(s). c. Within 30 days of completion of construction-related cultural resources activities d. 90 days after completion of cultural ARB/DGS June

7 resources with the consulting Native American tribe(s), when feasible. If on-site reburial is feasible, it shall include measures and provisions to protect, in perpetuity, the reburial area from any future impacts. Reburial shall not occur until all cataloguing and basic recordation have been completed. c. Where cultural resources are to be curated at a qualified repository, the collections and associated records, including title to, shall be transferred to the Western Science Center, Riverside Metropolitan Museum, or a non-tribally operated third-party local repository that meets the federal standards (36 CFR, Part 79) and be accompanied by payment of the fees necessary for permanent curation. The cultural resources shall be made available to all qualified researchers upon application, including the curation agreement with the aforementioned curation repository. d. For purposes of conflict resolution, if more than one Native American tribe or band is involved with the project and cannot come to an agreement as to the disposition of cultural resources within 30 days, the cultural resources shall be curated at the Western Science Center, Riverside Metropolitan Museum, or a non-tribally operated third-party local repository that meets the federal standards (36 CFR, Part 79). e. The archaeologist shall prepare a final report containing the significance and treatment findings and submit the report to ARB, the EIC, and the consulting Native American tribe(s). f. Where the cultural resources and associated records are not claimed by any tribe(s), ARB shall donate the cultural resources to an appropriate curation facility, or deliver them to the appropriate Native American tribe(s) if that is recommended by ARB. facility, or deliver them to the appropriate Native American tribe(s) resources documentation MM-CUL-4. Before commencing any grading activity on site, ARB or authorized assignee shall retain a qualified paleontologist. The qualified paleontologist shall attend the preconstruction meeting and a qualified monitor shall be on site during rough grading and other significant ground-disturbing activities, including trench excavations and large-diameter (i.e., over 2-feet in diameter) drilling in previously undisturbed older Quaternary alluvial deposits. These deposits are mapped as underlying the project site. Intact deposits are anticipated to be encountered at depths as shallow as 4 feet below ground surface, underlying surface topsoil deposits and disturbed alluvium. In the event that paleontological resources (e.g., fossils) are unearthed during grading, the paleontology monitor will temporarily halt and/or divert grading activity to allow recovery of paleontological resources. The area of discovery will be roped off with a 50-foot radius buffer. Once documentation and collection of the find is completed, the monitor will remove the rope and allow grading to a. Retain a qualified paleontologist b. Paleontologist to attend preconstruction meeting and temporarily halt and/or divert construction activities during rough grading and other significant ground-disturbing activities in previously undisturbed older Quaternary alluvial deposits, including trenching excavation and larger diameter drilling (i.e. over 2-feet in diameter), document and collect paleontological resources in the event they are unearthed during grading c. Paleontologist to prepare a Paleontological Resources Impact Mitigation Program for the proposed project in the event paleontological resources are unearthed, consistent with MMa. At least 2 weeks prior to construction b. During rough grading and other significant ground-disturbing activities in previously undisturbed older Quaternary alluvial deposits, including trenching excavation and larger diameter drilling (i.e. over 2- feet in diameter ), and at the time paleontological resources are unearthed c. Once documentation and collection of the find (if any) is completed ARB/DGS June

8 recommence in the area of the find. The paleontologist shall CUL-4. prepare a Paleontological Resources Impact Mitigation Program for the proposed project, which shall be consistent with the guidelines of the Society of Vertebrate Paleontology (SVP 2010). Greenhouse Gas Emissions MM-GHG-1. Construction Emissions a. Fund or undertake activities that reduce or a. Prior to construction ARB/DGS Before the project s first grading operations, ARB shall directly sequester GHG emissions in a quantity equal to b./c. During construction undertake or fund activities that reduce or sequester GHG the construction-related GHG emissions emissions in a quantity equal to the construction-related GHG generated by the project of 3,687 MT CO2E emissions generated by the project, which is estimated at a total b. Provide quantification of the emissions and 3,687 MT CO2E. The amount of reduced or sequestered GHG credits, supporting technical documentation, emissions is based on directly undertaken or funded activities or and make the report available online the purchase and retiring of offset credits. As part of the Mitigation Monitoring and Reporting Program, ARB shall prepare a report c. DGS approval of proposed methodologies that quantifies the emissions and credits and provide the documented in the report supporting technical documentation. ARB will post the report on ARB s webpage. DGS will approve any proposed methodologies demonstrating that the reductions are valid and oversee the Mitigation Monitoring and Reporting Program during the construction phase. MM-GHG-2. Operational Emissions ARB is committing to achieve zero net increase in GHG emissions (no net increase above existing conditions) for each year through the following options following the recommended loading order of preferred mitigation approaches described below: Additional Design Features The analysis for the energy consumption and emissions for the building above is based on a conservative design scenario described in Chapter 3 that represents a worst-case emissions scenario. The final design of the building to achieve ZNE performance will not be determined until the Design Development Phase, which will not occur until after the EIR is certified. This conservative design scenario uses a combination of efficient building design features, solar PV, and fuel cells to convert natural gas to electricity. However, because the fuel cells result in an estimated 1,577 MT CO2E annually (under conservative estimated scenario assuming 100% load), ARB may consider at the Design Development Phase other design options to achieve ZNE performance and that can reduce or eliminate those emissions. For example, one alternate design option ARB could explore at the Design Development Phase would have the buildings be designed and constructed to achieve ZNE performance as an allelectric facility. This alternate design option would evaluate all feasible implementations of renewable energy on site, including but not limited to solar and geothermal. The facility design would maximize the use of on-site PV (in addition to the existing 3.5 MW system) to generate electricity for the project s electricity needs (a a. Based on final design of project, achieve net zero carbon emissions each year through implementation of either additional design features; EV charging stations; transportation demand management program; direct reduction activities; or carbon credits b. Prepare a report that quantifies the emissions and credits and provides supporting technical documentation related to the chosen net zero carbon emission option. The report will be posted on ARB s webpage. ARB will select the methodologies and self-monitor the Mitigation Monitoring and Reporting Program a. Annually throughout operation b. Prior to beginning of operation and annually thereafter. ARB June

9 community approach to ZNE). If the roof area and land area onsite were determined insufficient for the size of PV system needed, ARB could evaluate several options for meeting the remaining electricity needs. One option could be to acquire additional land in the vicinity to install the needed PV panels. If the option for additional land was not feasible, ARB could consider the alternative of entering into a long-term (20-year minimum) purchase agreement for renewable energy in which the provider is contractually bound to retire the Renewable Energy Credits (RECs) associated with that renewable energy on ARB s behalf (a community approach to ZNE). Under this possible alternate design option, the facility could also incorporate alternate sources of clean energy such as geothermal energy to help meet annual energy needs. By incorporating technical innovation that avoids combustion of natural gas on-site, this design could eliminate the GHG emissions associated with the fuel cells and reduce ARB s annual obligation to reduce, sequester, or offset operational emissions by approximately 1,577 MT CO2E. EV Chargers ARB shall submit building plans that demonstrate it is providing at least 44 Level 2 charging stations, 32 Level 1 charging stations, and 2 DC fast charging stations for use by fleet vehicles, employees and visitors under the existing project design. Under this option, additional infrastructure (raceway and panel capacity) for 139 EV-capable charging spaces will be installed to support future installation of charging stations to meet long term EV charging needs. Implementation of this option has the potential to reduce operations-related GHG emission from the mobile source category by incentivizing the use of zero emission vehicles assuming the full capacity is utilized. The actual amount to be credited annually to offset operational emissions will be calculated based on survey of charger usage. The mitigation shall be quantified and supported by technical documentation in a report submitted as part of the Mitigation Monitoring and Reporting Program, using an approved methodology demonstrating the reductions are valid. ARB will post the report on ARB s webpage. ARB will select the methodologies and self-monitor the Mitigation Monitoring and Reporting Program during the operations phase as described in EIR Section under Approach to Implementation on MM-GHG-2. Transportation Demand Management ARB will implement an aggressive transportation demand management program to reduce VMT resulting from the project. The program will be designed to encourage the use of alternative transportation options to driving alone in a conventional vehicle. ARB will also work with local transit agencies to address potential route additions and appropriate regional stops to facilitate the use June

10 of public transportation for ARB employees. Implementation of this option has the potential to reduce operations-related GHG emissions from the transportation sector. The actual amount to be credited annually to offset operational emissions will be calculated based on survey of usage of these incentives. The mitigation shall be quantified and supported by technical documentation in a report submitted as part of the Mitigation Monitoring and Reporting Program, using an approved methodology demonstrating the reductions are valid. ARB will post the report on ARB s webpage. ARB will select the methodologies and self-monitor the Mitigation Monitoring and Reporting Program during the operations phase as described in EIR Section under Approach to Implementation on MM- GHG-2. Direct Reduction Activities Under this option, ARB will seek to directly undertake or fund feasible and cost-effective activities that reduce or sequester GHG emissions on a ton per ton basis to mitigate any annual operational emissions remaining after undertaking the activities described above. Direct investment opportunities include, but are not limited to, funding building retrofits programs that invest in: cool roofs, solar panels, solar water heaters, smart meters, energy efficient lighting (including, but not limited to, light bulb replacement), energy efficient appliances, energy efficient windows, insulation, water conservation measures, and any other similar retrofit measures associated with green buildings within the geographic area of the South Coast Air Quality Management District. As part of the Mitigation Monitoring and Reporting Program, ARB shall prepare a report that quantifies the emissions and credits and provides supporting technical documentation. ARB will post the report on ARB s webpage. ARB will select the methodologies and self-monitor the Mitigation Monitoring and Reporting Program during the operations phase as described in EIR Section under Approach to Implementation on MM- GHG-2. Carbon Credits If the mitigation measures above do not reduce annual operational emission to net zero, ARB may consider purchasing and retiring offsets from an accredited registry. As part of the Mitigation Monitoring and Reporting Program, ARB shall prepare a report that quantifies the emissions and credits and provides supporting technical documentation. ARB will post the report on ARB s webpage. ARB will select the methodologies and selfmonitor the Mitigation Monitoring and Reporting Program during the operations phase as described in EIR Section under Approach to Implementation on MM-GHG-2. June

11 Noise MM-NOI-1. In order to ensure that noise from on-site operational mechanical equipment does not result in a substantial noise increase, a noise barrier 30 feet in height shall be constructed around the cooling tower. The noise barrier shall completely obstruct the direct line-of-sight between the entire cooling tower and residences at both the first- and second-floor levels to the north. Alternatively, the noise goals (as shown in Table ) may be achieved through other measures such as reconfiguration of the project site, selection of quieter equipment or other modifications (as substantiated by a subsequent analysis conducted and documented by a qualified acoustical specialist). MM-NOI-2. Construction activities shall normally take place during the permitted time and day per Section , General Noise Regulation, Subsection 5, Construction, of the City of Riverside s Municipal Code. Additionally, Caltrans Standard Specification Section (Noise Control) will be followed. Section (Noise Control) requires that that construction activity not exceed 86 dba Lmax at 50 feet from job site activities from 9 pm to 6 am and internal combustion engines be equipped with manufacturer-recommended mufflers (Caltrans 2011). MM-NOI-3. The Air Resources Board (ARB) will ensure that the following occurs throughout construction: The project contractor shall, to the extent feasible, schedule construction activities to avoid the simultaneous operation of construction equipment so as to minimize noise levels resulting from operating several pieces of high noise level emitting equipment. All construction equipment, fixed or mobile, shall be equipped with properly operating and maintained mufflers. Construction noise reduction methods such as shutting off idling equipment, construction of a temporary noise barrier, maximizing the distance between construction a. Qualified acoustical specialist to confirm that design and selected equipment meets noise goals provided in EIR Table and provide final height of required noise barrier. In addition to meeting noise goals, the noise barrier shall obstruct the direct line-of-sight of residences at both the first- and second-floor levels to the north. b. Provide documentation of findings. a. Documentation that requirements have been incorporated into the construction contracts and that the project is in compliance with daily construction limits. Construction shall generally be limited to 7 AM to 7PM on weekdays, and between 8 AM to 5 PM on Saturdays. These limits are not applicable to emergency work, right of way construction, public health, welfare and safety activities, including trash collection, street sweeping, debris and limb removal, removal of downed wires, restoring electrical service, repairing traffic signals, unplugging sewers, vacuuming catch basins, repairing of damaged poles, removal of abandoned vehicles, repairing of water hydrants and mains, gas lines, oil lines, sewers, storm drains, roads, sidewalks, etc., or otherwise exempted by the municipal code. b. To ensure 85 dba Lmax at 50 feet from job site activities from 9 pm to 6 am are met, use of temporary sound wall or noise measuring device. a. Documentation that requirements have been incorporated into the construction contracts. b. Documentation of compliance to be provided during construction a/b. Prior to construction (final design). a. Prior to and during construction. b. During construction a. Prior to construction b. During construction ARB/DGS/Design-Build Entity ARB/DGS/Design-Build Entity ARB/DGS/Design-Build Entity June

12 equipment staging areas and adjacent residences, and use of electric air compressors and similar power tools, rather than diesel equipment, shall be used where feasible. During construction, stationary construction equipment shall be placed such that emitted noise is directed away from or shielded from sensitive receptors. Construction laydown and staging areas shall be located on portions of the site located as far away as feasible from sensitive receptors. The phone number of the job superintendent shall be clearly posted at all construction entrances to allow surrounding property owners to contact the job superintendent if necessary Traffic and Circulation MM-TRAF-1. A right-turn overlap phase shall be added to the westbound approach at Chicago Avenue and University Avenue. This would require prohibiting southbound U-turns at the intersection. Although the City has no jurisdiction over the proposed project, and the City does not have discretionary approval authority, the Air Resources Board and the City shall negotiate a fair share contribution to the City s Development Impact Fee to fund the construction of this improvement at the intersection of Chicago Avenue and University Avenue. MM-TRAF-2. One new westbound left turn lane shall be constructed at the intersection of Iowa Avenue and University Avenue, bringing the total number of westbound left turn lanes at this intersection to two. This would require median modifications, restriping at the intersection, and likely, a signal modification. Although the City has no jurisdiction over the proposed project, and the City does not have discretionary approval authority, the Air Resources Board and the City shall negotiate a fair share contribution to the City s Development Impact Fee to fund the construction of this improvement at the intersection of Iowa Avenue and University Avenue. MM-TRAF-3. One new eastbound right turn lane shall be constructed at the intersection of Canyon Crest Drive and Martin Luther King Boulevard, bringing the total number of eastbound right turn lanes at this intersection to two. Although the City has no jurisdiction over the proposed project, and the City does not have discretionary approval authority, the Air Resources Board and the City shall negotiate a fair share contribution to the City s Development Impact Fee to fund the construction of this improvement at the intersection of Canyon Crest Drive and Martin Luther King Boulevard. MM-TRAF-4. A traffic signal shall be installed at the intersection of I-215 NB Ramp and Martin Luther King Boulevard. It should be noted that the peak hour signal warrant is expected to be satisfied at this location. Although the Air Resources Board shall be Payment of negotiated Development Impact Fee to the City of Riverside Payment of negotiated Development Impact Fee to the City of Riverside Payment of negotiated Development Impact Fee to the City of Riverside Payment of fair share contribution for a traffic signal to the City of Riverside Fair share contribution payment shall be paid to the City of Riverside prior to occupancy. Fair share contribution payment shall be paid to the City of Riverside prior to occupancy. Fair share contribution payment shall be paid to the City of Riverside prior to occupancy. Fair share contribution payment shall be paid to the City of Riverside prior to occupancy. ARB City of Riverside ARB City of Riverside ARB City of Riverside ARB Caltrans/City of Riverside June

13 responsible for funding the installation of a traffic signal at the intersection, the intersection is under the California Department of Transportation (Caltrans) jurisdiction. Although Caltrans has no jurisdiction over the proposed project, and Caltrans does not have discretionary approval authority, the Air Resources Board and Caltrans shall negotiate a fair share contribution to the construction of this improvement at the intersection of I-215 NB Ramp and Martin Luther King Boulevard. June

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