letter - l13 letter - l13 page 5 response to comment l13-20 long-term fallowing is defined as...
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Letter - L13 Page 5
Response to Comment L13-20 Long-term fallowing is defined as non-rotational fallowing for greater than 4 years. This change is indicated in this Final EIR/EIS in subsection 3.5 in Section 4.2, Text Revisions.
The maximum acreage that would need to be fallowed to implement the various components of the Proposed Project and alternatives are listed in the table below. In Section 3.5 of the Draft EIR/EIS, impacts to agricultural resources were found to be significant and unavoidable, if non-rotational fallowing is implemented.
Response to Comment L13-20 (continued)
Components of the Proposed Project and Alternatives Maximum Fallowing Acreage* (acres) Proposed Project Water Conservation and Transfer 50,000 HCP 25,000 IOP 9,800 TOTAL 84,800 Alternative 1: No Project Water Conservation and Transfer 0 HCP 0 IOP 0 TOTAL 0 Alternative 2: 130 KAFY On-farm Irrigation System Improvements Only Water Conservation and Transfer 22,000 HCP 25,000 IOP 9,800 TOTAL 56,800 Alternative 3: 230 KAFY All Conservation Measures Water Conservation and Transfer 38,000 HCP 25,000 IOP 9,800 TOTAL 72,800 Alternative 4: 300 KAFY Fallowing Only Water Conservation and Transfer 50,000 HCP 25,000 IOP 9,800 TOTAL 84,800 Table Notes: *The fallowed acreage figures are based on a water conservation rate of 6 AF per acre of fallowed land. Note that the water conservation rate of 5.63 AF per acre of fallowed land that was used in the socioeconomic analysis (Section 3.14, Socioeconomics in the Draft EIR/EIS) is derived from historic water deliveries as estimated by the IIDSS. This value was rounded to 6 AF per acre when used in all other sections of the Draft EIR/EIS. The resulting calculation of the number of acres required to be fallowed is an approximate number which could vary by up to 10 percent depending on the actual acres fallowed and the historic water use of the specific farms fallowed.
Response to Comment L13-21 Please refer to the following Master Responses in Section 3 of the present document: Air Quality—Salton Sea Air Quality Monitoring and Mitigation Plan; Air Quality—Air Quality Issues Associated with Fallowing; Air Quality—Health Effects Associated with Dust Emissions, and Air Quality—Consistency with the State Implementation Plan for PM10.
Response to Comment L13-22 The EIR/EIS does not propose measures to offset the evaporation/transpiration of water because it is not considered to be an environmental impact. Evaporation and transpiration are considered in all of the modeling of the LCR, the IID water service area, and the Salton Sea. Therefore the accounting of reduced inflows and associated make-up water for mitigation takes evaporation losses into account. No feasible measures are available to reduce evaporation and transpiration in the IID water service area, the LCR, or the Salton Sea.
Response to Comment L13-23 Please refer to the following Master Responses in Section 3 in this Final EIR/EIS: Air Quality−−Salton Sea Air Quality Monitoring and Mitigation Plan; Air Quality−−Air Quality Issues Associated with Fallowing; and Air Quality−−Wind Conditions at the Salton Sea.
Response to Comment L13-24 Comment noted.
Letter - L13 Page 6
Response to Comment L13-25 The Environmental Justice section in the Draft EIR/EIS has been substantially revised to address this comment and other comments on this section. The new section is located in this Final EIR/EIS in subsection 3.15 under Section 4.2, Text Revisions.
With regard to the comment on mitigation measures, with the exception of socioeconomic impacts due to fallowing in the Imperial Valley, such measures have been proposed for potential adverse effects due to the Proposed Project, as necessary and applicable. (For information on the air quality and sport fishery mitigation measures in the Salton Sea subregion, refer to the Master Responses on Air Quality Salton Sea Air Quality Monitoring and Mitigation Plan and Recreation Mitigation for Salton Sea Sport Fishery in Section 3 of this Final EIR/EIS). The IID Board will make a decision on mitigation for socioeconomic impacts due to fallowing in the Imperial Valley if and when it approves the Proposed Project or an alternative to the Proposed Project. The groundwater impacts in the Coachella Valley have been determined to be significant and unavoidable. Agricultural resources impacts have also been determined to be significant and unavoidable if permanent/long-term fallowing is employed as a conservation measure in the Proposed Project.
Response to Comment L13-26 Comment noted.
Response to Comment L13-27 See response to Comment L13-10.
Response to Comment L13-28 See response to Comment L13-10.
Response to Comment L13-29 The commenter does not specify how the Draft EIR/EIS fails to adequately address the archaeological and cultural resources impacts of the Proposed Project. We believe the EIR/EIS is a good faith and reasonable effort to identify and assess the impacts to archaeological and cultural resources from implementation of the Project based upon available information and assessment methods. Such impacts are included in the Draft EIR/EIS in Section 3.8, Cultural Resources.
Letter - L14. Community Advisory Commission. Signatory - J.R. Dick Kershaw.
Letter - L14 Page 2
Response to Comment L14-1 The text of Section 3.15 has been revised to address issues related to Environmental Justice. Refer to subsection 3.15 under Section 4.2, Text Revisions of this Final EIR/EIS. With regard to the comment on agricultural tailwater as a beneficial use for the Salton Sea, as described in Section 1.4.3 and Section 220.127.116.11 in the Draft EIR/EIS, IID holds the rights to Colorado River water use in the Imperial Valley in trust for landowners within the IID water service area. The Salton Sea is an agricultural drainage repository that has no legal entitlement to Colorado River water.
Letter - L14 Page 3
Response to Comment L14-2 Comment noted.
Response to Comment L14-3 Comment noted.
Response to Comment L14-4 In response to comments, the text of Section 3.15 has been revised. The changes are indicated in subsection 3.15 in Section 4.2, Text Revisions in this Final EIR/EIS.
Response to Comment L14-5 Please refer to the Master Response on Air Quality Salton Sea Air Quality Monitoring and Mitigation Plan in Section 3 of this Final EIR/EIS.
Response to Comment L14-6 The specific conservation methods to be implemented under the Proposed Project have not been determined. As noted in the Draft EIR/EIS in Section 18.104.22.168, the conservation program could include a potentially broad and varying range of conservation measures to provide maximum flexibility to the IID Board to adopt the program to changing circumstances, methods, and participants over the lengthy Project term. Assumptions were made for modeling purposes that would capture the full range of potential impacts. The impacts of the conservation program ultimately adopted will fall somewhere within this range. As described in the Draft EIR/EIS, depending on the eventual implementation of the water conservation program, there could either be beneficial or adverse impacts to the regional economy. If water is conserved using on-farm and water delivery system improvements, it is anticipated that there would be beneficial effects to regional employment; therefore, there would not be any adverse effects to mitigate. If fallowing is used to conserve all or a portion of the water to be transferred, there would be adverse effects to the regional economy and farm workers as identified in the Draft EIR/EIS.
The IID Board will consider whether to implement socioeconomic mitigation measures when it considers whether to approve the Proposed Project or an alternative to the Proposed Project.
Letter - L14 Page 4
Response to Comment L14-7 The commenter notes that IID should not proceed with the Project unless it is indemnified and protected from unanticipated problems. The EIR/EIS process is designed to identify, to the extent possible, the Project impacts and appropriate mitigation measures. We note that the Implementation Agreement for the HCP is expected to limit liability for unforeseen circumstances pursuant to the "No Surprises Rule" implementing Section 10 of the federal ESA. It is anticipated that the IID Board will evaluate the risks and costs of the Project before committing to proceed and that farmers will evaluate the advantages and disadvantages in the voluntary on-farm program before deciding to participate.
Response to Comment L14-8 The commenter states that mitigation costs should be borne by parties other than IID. It is anticipated that the contribution of other parties toward mitigation costs will be evaluated by the IID Board at the time it considers whether to approve the Project.
Response to Comment L14-9 The EIR/EIS is intended to identify all mitigation measures which should be implemented in connection with the Proposed Project.
It is anticipated that mitigation measures to be implemented by farmers in connection with the on-farm conservation program will be included in the contracts between IID and participating farmers. The comment that these on-farm costs should be included in calculating costs for purposes of exercising any IID termination right or "off-ramp" is noted.
It is anticipated that the IID Board will evaluate the risks and costs of the Project before committing to proceed and that farmers will evaluate the advantages and disadvantages of the voluntar