| CEQA Comments by Mr. Mendoza |
|
Ramon Alviso Mendoza
INITIAL STUDY / ENVIRONMENTAL ASSESSMENT:
HI-DESERT WATER DISTRICT
WATER RECLAMATION FACILITY,
WASTEWATER TREATMENT PLANT AND
SEWER COLLECTION SYSTEM PROJECT
Project Proponent and CEQA Lead Agency:
Hi-Desert Water District
55439 Twentynine Palms Highway
Yucca Valley, California 92284
(760) 365-8333
NEPA Lead Agency:
U.S. BUREAU OF RECLAMATION
27708 Jefferson Avenue, Suite 202
Temecula, California 92590
Preparer:
Tom Dodson & Associates
2150 North Arrowhead Avenue
San Bernardino, California 92405
(909) 882-3612
JUNE 2009
REVIEW PERIOD: June 9, 2009 through July 9, 2009
Chapeter 1 Purpose and Need
1.1 INTRODUCTION
(Omitted, with no comment)
1.2 PURPOSE OF THE ENVIRONMENTAL ASSESSMENT
(Omitted, with no comment)
1.3 PURPOSE AND NEED
The proposed project has five general objectives:
1. Construct a wastewater collection system to reduce the quantity of leachate from septic tank systems flowing into the Warren Valley Groundwater Basin (Basin) used for the District’s potable
water supply.
Ramon: There is no scientific data to show this to be a problem today. Additionally, test data and procedure, location of test and lab reports verifying this have not been produced.
2. Treat wastewater to a level such that percolated effluent will not degrade groundwater quality. The enhancement of groundwater quality is proposed to be achieved by reducing the amount of nitrate rich leachate from septic tanks in the area percolating into the Basin groundwater aquifer.
Ramon: Treated wastewater can attract algae and create percolation problems. No
information regarding control of algae (green or black) is stipulated. Additionally the uncovered treatment of water can attract mosquitoes that can carry West Nile Virus. Such has been reported in the Salton Sea open water area.
3. (Omitted, with no comment)
4. Maximize the total water supply available to the District.
Ramon: Since the district has failed to respond to the EPA Water Survey need, presented to Congress in 2004, the total local water supply is unknown, and approximated total water shown by USGS, done by simulating the water model is only a model.
The Fenner Valley Study and the study done by the Hi-Desert Water District (Dr. Joe Birman/Hydrologist), concerning the water dispute between Big Horn/Desert View Water District, Ames Valley, showed that the USGS model was off by a factor of 10. USGS signed off on the Cadiz Study but has not changed the total water available figure in the Warren Basin shown by Dr. Birman to have the same hydrogeological characteristics as Cadiz/Fenner Valley.
5. Minimize any adverse economic and environmental impacts to the community.
Ramon: Since the local economy is already in a decline, and no way to measure this impact is given, blight and economic impact has not been sufficiently addressed. Re. Dr. Kings comments on the economy of Yucca Valley, in the WalMart CEQA court case where the opponents position was upheld by the court, thus, denying the Super WalMart project.
In addition to these general objectives, specific objectives for the Phase 1 treatment facilities are as
follows:
1. (Omitted, with no comment)
2. (Omitted, with no comment)
The installation of this wastewater system infrastructure is considered essential to the District in
order to continue meeting the public health and safety requirements for water supply within its
service area and to meet the water quality objectives of the Colorado River Basin Regional Water
Quality Control Board (Regional Board or RWQCB).
Ramon: The wastewater treatment system selected by the HDWD is not cost effective for the
Yucca Valley community and better systems that are cost effective have been given, but
have not been looked at by the district in order to change the course of this plan to a more
effective and economical choice.
Chapter 2 PROPOSED ACTION, INCLUDING ALTERNATIVES
2.1 PROPOSED ACTION SUMMARY
(Note: some parts of this have been deleted because there was no comment needed or germaine to
the elements discussed in this section/subsection)
As previously described this project consists of the construction and installation of the following
components. The District intends to initially sewer the central portion of the Town of Yucca Valley to
convey an annual average flow of 2 MGD of wastewater to the WRF currently discharged to septic
tanks. This initial project is referred to as Phase 1. In the future, if the Phase 1 facilities do not
adequately protect groundwater quality, or if the RWQCB requires more areas to be sewered, or if
additional capacity is needed, the collection, treatment and disposal facilities will be expanded to
collect an additional 1 MGD of sewage. The additional facilities are referred to as Phase 2 facilities.
Phase 3 facilities will be designed to collect an additional 1 MGD of wastewater flow for a total
system capacity of 4 MGD. Ultimate build-out in the District’s Yucca Valley service area could be as
high as 6 MGD, but due to the area’s slow rate of growth, this is not forecast to occur until the
distant future. If a wastewater collection system is required in the Yucca Mesa-portion of the
District’s service area in the future, the assumption has been made that a separate treatment
facility will be located within the Yucca Mesa area. The wastewater will be treated to meet Title 22
recycled water standards/requirements and will be delivered to recharge basins operated by the
District to percolate into the Warren Valley Groundwater Basin (Basin).
Ramon: This plan is too subjective as given and commits money and effort that would
require extraordinary financial expenditure and “fair share” revenue that is not yet defined.
The risk is placed upon the customers and by manipulating of all of Yucca Valley residents
not shown in either phase 1, 2 or three areas. For example, the Sky Harbor project, El Cielo
project on the West End and the Mesa are not shown with the risk of being included in the
“fair share” and/or building of another treatment plant that would further complicate the
economic viability of this project.
2.1.1 Location
The proposed project is located within the Town of Yucca Valley in the County of San Bernardino.
The proposed interim wastewater treatment plant facilities will be located approximately 1,000 feet
south of State Route 62 (SR 62) (Twentynine Palms Highway), east of Indio Avenue, north of
Sunnyslope Drive, and west of La Contenta Road (see Figure 2-1).
Ramon: This location is in a water flow area that supplies the Joshua Retreat/Mental Physics
facility that is part of the Warren Basin while being outside of the municipal district of Yucca
Valley. The water storage tanks and pumps (two shut down) in the wash are contaminated
with nitrates. The pump and small storage tank south of the wash is pumping water coming
down from Covington Flats. During a rainfall, the watershed can contaminate the so called
water in storage at the treatment site. This could be validated by a water survey of this
area, rather than relying on static test and simulated flow models.
2.1.2 Environmental Setting
Yucca Valley, San Bernardino County is located in the Morongo Basin portion of the Mojave Desert,
approximately 70 miles east of the City of San Bernardino (refer to Figure 1-1). Access to the region
is by SR 62 which extends west to Interstate 10 and east to the Colorado River and the Arizona
state line from Yucca Valley. The proposed trunk sewer pipeline alignments and wastewater
treatment plant facilities generally occur in alluvial deposits derived from the Little San Bernardino
Mountains to the south. The alluvial fan slopes to the north at a 1-2 percent gradient at a general
elevation of approximately 3,300 feet above sea level. (*!)The Pinto Mountain fault (considered
active) is located about one-quarter mile north of the proposed treatment plant site. No other
geologic hazards are known to occur in the project area. (*2)The only topographic feature within
the project site is an ephemeral desert wash area, vegetated with Joshua tree-creosote scrub,
intermixed with Mormon tea. All water supplies are extracted from the local Warren Valley
Groundwater Basin by Hi-Desert Water District, with supplemental water consisting of State Water
Project (SWP) water imported from the State Aqueduct in Hesperia by agreement with the Mojave
Water Agency (MWA). Water quality issues are managed by the Colorado River Basin Regional
Water Quality Control Board (Regional Board). Project area land uses consist of a mix of open
space, residential, commercial, and limited industrial uses. (*3)A Joshua tree-creosote bush scrub
plant community occurs in the general area, and desert tortoise are also known to inhabit the
general area. At the present time the plant site is open desert with typical human disturbance from
being located near existing residences. The climate in the project area is that of a subtropical
upland desert with annual precipitation less than 10 inches, averaging 6.44 inches. Temperatures
can vary from 0°F in winter to above 110°F in the summer. Mean summer temperature is 88°F and
in winter is 49°F. Air quality in the region is good, but during the summer transported pollutants
from the South Coast Air Basin (SoCAB) can cause ozone concentrations to violate federal and state
standards on rare occasions. The project area is located within the Mojave Desert Air Basin (MDAB
or Basin) and the Mojave Desert Air Quality Management District (MDAQMD) manages air quality for
this Basin. Access to the project site can be obtained from the main area roadway, SR 62
(Twentynine Palms Highway), which traverses east-west through the Town of Yucca Valley to the
north of the treatment plant site. The north-south cross streets are Indio Avenue on the west and
La Contenta Road on the east of the proposed WRF site. The project site can be accessed from La
Contenta off of SR 62, then west on Sunnyslope to the project site.
Ramon: (*1). Faults were found by USGS west of the sewer treatment plant proposed
site
(*2). This is not ephemeral in nature, and contains cats claw and catalpa up
stream and down stream of this “blueline” riparian wash. Re. California Fish
and Game, Rebecca Jones (2008) and Town of Yucca Valley, Hydrogeological
Status, California Regional Water Quality Control Board Technical Advisory
Committee Members David Mahaffey and Ramon Alviso Mendoza--15 January
2009 Basic
(*3). Being located “near existing upstream residences creates the potential
from septic leachate and toxic flow into the area given as suitable to store
treated water for 16 years. How this will occur in a blueline area, with faults is
unknown and needs to be explained.
2.1.3 Project Characteristics
The proposed project is the construction and installation of a wastewater reclamation facility (Hi
Desert WRF) with an initial treatment capacity of 2 MGD and an build-out treatment capacity of 6
MGD. Phased development of the Hi Desert WRF envisions the initial facility size as capable of
processing up to 2 MGD of wastewater; a second phase, Phase 2, would expand the WRF to 3 MGD;
Phase 3 envisions a treatment capacity of 4 MGD; and the build-out WRF would have a treatment
capacity of up to 6 MGD.
Ramon: Should this not require a water survey in order to determine flow characteristics?
To continue with a simulated flow model seems inappropriate. How does this protect ground
water or increase the probability of build out occurring upstream of the proposed site for the
WRF?
The Phase 1 sewer collection system will focus on the urban development in close proximity to State
Highway 62 (Twentynine Palms Highway). The Phase 2 collection system would expand to the
majority of urban development within the existing District service area. Phase 3 would connect
much of the remaining existing residential and commercial development within the Town of Yucca
Valley to the WRF.
Ramon : Given that the Town of Yucca Valley limits impact fees, would this not transfer
burden to the residents and existing homeowners to fund new development?
Infill development within the Town of Yucca Valley is forecast to create an ultimate demand for 6
MGD of treatment capacity. If approved by the community, the 2 MGD capacity WRF would be
installed in the near future, perhaps coming on line in 2012. Implementation of future phases would
be dependent upon the pace of connections dictated by the Regional Board and actual future
growth.
Ramon: Given the risk management of this subjective at best, should not test wells be
installed upstream and downstream from the WRF?
Table 2-1
ANTICIPATED EFFLUENT DISCHARGE LIMITATIONS
FOR THE HI-DESERT WRF
Parameter Value Units
Omitted with no comments
Table 2-2
SUMMARY OF SCREENED TECHNOLOGY
Screening Category Remaining Alternatives
(Omitted, with no comment)
Table 2-3
ALTERNATIVE 1 EXTENDED AERATION SIZING CRITERIA
Parameter Value
(Omitted, with no comment).
Table 2-4
POWER DEMANDS BY PLANT AREA
Equipment Load Drive Type Number on
Standby Power
Headworks Area
(Omitted, with no comment) Table 2-5
PHASE 1 PIPELINES
(Omitted, with no comment)
2.2 CONSTRUCTION SCENARIO
(Omitted, with no comment, including sub sections)
2.3 ALTERNATIVES
2.3.1 No-Action Alternative
The No-Action alternative will result in wastewater treatment facilities not being installed as outlined
….
The No-Action alternative does not contribute to the protection and enhancement of the
District’s water quality as envisioned in both the Regional Water Management Plan (Mojave Water
Agency 2004) and the District’s Strategic Plan (2008). Nitrate contamination in the area would still
be produced and percolate into the local groundwater aquifer in conflict with the Regional Board’s
Basin Plan (2005).
Ramon: the No-Action alternative does support protection and enhancement of the District’s
water quality as envisioned…etc. (2005).
Alternative methods have been explained, offered and in some cases attempts to explain
have been stopped by the HDWD-directors at the regular meetings by agency directors. (re.
comments made by Ramon Alviso Mendoza, David Mahaffey, and William Horne). Comments
and methods have repeatedly been discussed concerning options (presented in public form
20 April 2009, Yucca Room, Town of Yucca Valley) and have been generally educating the
public concerning the alternative proposed to cost under 2% of the projected cost of 1mgd
treatment facility of this proposed project. Evidence of the filmed meeting would verify that
the directors have not been open to hearing the evidence.
The No-Action alternative would result in the fewest direct natural environmental effects of available
alternatives, because no physical changes to the environment within the area of potential impact
would result from construction activities. However, the result of emplementing this alternative is the
continued degradation of groundwater quality due to nitrates in the Warren Valley Groundwater
Basin and possibly in downstream aquifers. Therefore, this alternative is not considered a feasible or
reasonable alternative for consideration by the District.
Ramon: Ramon: the No-Action alternative does support protection and enhancement of the
District’s water quality as envisioned…etc. (2005).
Alternative methods have been given to the HDWD at the regular meetings of the agency’s
directors by Ramon Alviso Mendoza, David Mahaffey, and William Horne. Comments and
methods have repeatedly been discussed options (presented in public form 20 April 2009,
Yucca Room, Town of Yucca Valley) and have been generally educating the public concerning
the alternative proposed to cost under 2% of the projected cost of 1mgd treatment facility of
this proposed project. Evidence of the filmed meeting would verify that the directors have
not been open to hearing the evidence.
So far as a reasonable alternative, less than 2% of the cost seems to be a very reasonable
alternative. This would be called a localized treatment facility that produces pure clean
water, electricity for operations with clean waste charcoal…available locally.
2.3.2 Individual Treatment Systems
The MWH PDR included a discussion of an alternative of installing individual treatment systems.
The text of this discussion, presented above, is repeated here for information. Nitrate removal from
wastewater requires some form of treatment and some form of managing the nitrate after it is
separated from wastewater or chemically modified during treatment. Most of the existing
residences and businesses currently manage their domestic wastewater with underground septic
tank and leach systems or seepage pits. It is from these individual systems that the nitrate is
entering the local groundwater aquifer. There are individual advanced underground wastewater
treatment systems that can be installed, but the effectiveness of such systems in removal of
sufficient nitrate and the process of imposing such systems is beyond the scope of this analysis. The
summary of treatment technologies screened in the PDR are provided in Table 2-2 (Table 3-1 of the
PDR). Tables 3-2 through 3-6 of the PDR (Appendix 1) contain a fatal flaw analysis of the systemwide
treatment alternatives and of specific technologies.
The MWH PDR contained the following conclusion for options related to onsite treatment
technologies. The MWH evaluation concluded: “ Options such as no-flush toilets and gray water
separation would require extensive and disruptive modification of toilets and plumbing in all existing
buildings in the service area.
Ramon: The cost of connection to the sewer treatment and recurring costs within a special
district is forever. A onetime cost of a system realized at less than 2% of the hookup cost
and recurring expenses forever would be more attractive to the rate payers’ already
contacted. It is interesting to note that the HDWD has a waterless urinal.
Decentralized treatment is not cost effective for an area such as Yucca Valley where development
has occurred in single, coherent area. Piping sewage to a neighboring agency would be very
expensive to construct the sewers, and would result in the permanent loss of the water that could
otherwise be used for groundwater recharge. For these reasons, only centralized treatment of
wastewater within the District’s service area is considered a viable alternative.”
Ramon: Ms. Ann Denier has proposed a localized treatment concept. This will reduce threat
of pipeline leaks created from seismic activity. It is far less expensive and can be purchased
in 325K gpd to 1 mgd systems. Given this, Ann estimates doing the entire district for 4.5
million dollars, as opposed to an estimated cost of 300 million dollars for a 1 mgd treatment
and reclamation project, storing for 16 years, discharged treated water in a blueline flood
plane.
2.3.3 Other Alternatives
(Some parts of this sub-section have been omitted because they were not needed to address this
element)
… Only sites that are not directly upstream of domestic water wells and that have sufficient depth of
vadose zone (the area between the ground surface and the groundwater table) were deemed
adequate for siting the WRF. Due to the shallow vadose zone to the west, south and north portions
of the Warren Valley Basin, a site in the east-central portion of the Basin was deemed essential.
Ramon: Please explain how the vadose zone is identified without a water survey or soil test
at depths meeting the defined area: Vadose Zone -- The zone between land surface and the
water table within which the moisture content is less than saturation (except in the capillary
fringe) and pressure is less than atmospheric. Soil pore space also typically contains air or
other gases. The capillary fringe is included in the vadose zone.
(re. http://www.teachmefinance.com/Scientific_Terms/Vadose_Zone.html
Therefore, based on the large acreage of undeveloped area, depth of vadose zone, and lack of wells
immediately downstream, the project site or another site in the immediate vicinity was determined
to be the only location in the Basin available to support the proposed WRF. Since the environmental
variables at the selected site represent those of the surrounding area, the project location was
judged to be representative of the available sites in the Basin. Thus, this alternative will not be
given further consideration.
Ramon: The first site selected was north of state route 62 highway in Paradise Valley, and
relocated to a site south of the state route, parallel with the first site and then moved to the
current location for unknown reasons.
Alternative Treatment Systems
Although the treatment system options would be installed at the same proposed WRF site, there are
minor variations in the amount of area and amount of energy required for each system. The
following comparative evaluation of the treatment system alternatives is abstracted from the PDR.
Minor editing has been included for clarity.
Matrix Comparison of Treatment Alternatives
Each of the four alternatives were compared against each other using weighted criteria. This
method involves three steps:
1. Establish a set of criteria and assign a weight to each criteria based on level of importance to the
District. The total of the criteria weights should be equal to 100%.
2. Score each of the alternatives on a scale of 1 – 10 for each criteria.
3. Multiple each score by the corresponding weights; those produce are then added together to give
a total weighted score for each alternative.
Ramon: there are no criteria for parameters of an assessment in terms of value for each of
each of the subjective methods given. Therefore, the results are not statistically weighted in
terms of a stated value to the community as a whole. Neither qualitative or quantitative
data with metrics for value have been provided for clarification of the subjective terms
explaining this element.
The list of criteria for the matrix evaluation of the treatment alternatives are listed in Table 2-9
along with the criteria weighting.
Table 2-9
CRITERIA WEIGHTING
Criteria Weight
Low Initial Capital Cost 15%
Low O&M Cost 35%
Small Footprint 5%
High Treatment Reliability 15%
Simple O&M 10%
Flexibility for Future 20%
The results of a weighted matrix evaluation of the four alternatives are shown on Table 2-10.
Ramon: How were these values obtained in terms of objective evidence for the weight
assumed?
Table 2-10
MATRIX COMPARISON RESULTS FOR TREATMENT ALTERNATIVES
Treatment Alternative Weighted
Score Dif.
Alternative 1 – Extended Aeration 6.85 98%
Alternative 2A – High Rate MBR 5.90 84%
Alternative 2B – Extended Aeration MBR 7.00 100%
Alternative 3 – Conventional Activated Sludge 5.35 76%
Ramon: Ramon: How were these values obtained in terms of objective evidence for the
weight assumed? Please include method and written procedure approving the test
procedure.
Risk Assessment of Treatment Alternatives
The comparison described above is based on the expected performance requirements, site
conditions, and other assumed factors. In reality, the project faces a number of risks that are not
directly addressed in the comparison. Table 2-11 lists a number of risks, and which alternatives
would be less than impacted by them.
Ramon: What are the quality levels? How tested to determine mean time between system
components failure and system attributes…in order to provide reliability factors to define
risk?
Table 2-11
TREATMENT ALTERNATIVE RISK ASSESSMENT
Risk Likelihood Impact Preferred Alternative(s)
1. Geotechnical Low Medium 2A- High Rate MBR
2B- Ex Aeration MBR
2. Material Cost Increases Medium Low 2A- High Rate MBR
2B- Ex Aeration MBR
3. Low Perc Rate/High Dilution Req Low High None
4. Energy Availability Medium Medium 1- Extended Aeration
5. Vendor Reliability Low High 1- Extended Aeration
6. Emerging Contaminants Medium High 1- Extended Aeration
2B- Ex Aeration MBR
7. Future Treatment Requirements Medium High 2A- High Rate MBR
2B- Ex Aeration MBR
1. Geotechnical Risks – A geotechnical investigation will need to be completed prior to the
construction of a treatment plant. These unknown condition may influent the placement of
the treatment facility on the site. Facilities with a large footprint have a higher risk that
unfavorable geotechnical conditions will impact either the cost of the facilities or even the
ability to built the facilities all together. The high rate and extended aeration MBR alternatives are
the preferred alternative when it comes to the risk associated with geotechnical issues due to the
small footprint of these treatment trains.
2. Material Cost Increases – Facilities with big structures require large quantities of concrete and
rebar for construction. The last decade has shown large relative increases in the cost of both
concrete and steel. Such increases could increase the final bid cost for the project. Therefore,
treatment trains with a small footprint and lower concrete requirement will reduce the risk
associated with material cost increases. These treatment trains would be the high rate and
extended aeration MBR alternatives.
3. Low Percolation Rate/High Dilution Required – One of the treatment processes is the percolation
ponds used to recharge the groundwater basin. The percolation rate of the soils in the area is
currently unknown as well as the amount of dilution water that would be required by the RWQCB.
These two factors govern the size of the recharge basins which may require more land than
previously thought. All treatment processes are subject to the risk of low percolation rates or a high
dilution requirements.
4. Energy Availability – Technologies with greater energy demand have an increased sensitivity to
increases in energy costs. The extended aeration alternative is least subject to this risk, due to the
low energy requirements in comparison with the other alternatives.
5. Vendor Reliability – Technologies with proprietary equipment are susceptible to difficulties with
the vendor which can have a direct impact on the project schedule and success. The extended
aeration alternative is least subject to this risk, since this is a conventional technology without a lot
of proprietary equipment.
6. Emerging Contaminants – Emerging contaminants including NDMA, personal care products and
pharmaceuticals (PCPP) and disinfection by-products, while not currently regulated by RWQCB,
could become regulated. Treatment processes with longer sludge ages provide a better level of
treatment of PCPP. The extended aeration and extended aeration MBR alternatives are the
preferred alternatives when it comes to the risk associated with emerging contaminants due to the
longer sludge age.
7. Future Treatment Requirements – Future regulations may require treatment of wastewater
effluent using reverse osmosis (RO) before recharging groundwater. If such a system is required it
will need to be preceded by micro-filtration. MBRs use micro-filtration, so MBR effluent could go
directly to RO without future treatment. The high rate and extended aeration MBR alternatives are
the preferred alternatives when it comes to the risk associated with future treatment requirements.
All of these treatment systems can meet the water quality objectives for the Hi-Desert WRF. Also,
they all require approximately the same amount of area and the degree of disturbance associated
with the other three alternative treatment systems. Based on the comparative evaluation in the
discussion above, the overall effects of the alternative systems are considered to be comparable.
Thus, none of the alternative treatment systems will be given further consideration in this
document.
Alternative Sewer Collection System Design
The Sewer Collection System Master Plan is provided in Appendix 2 of this document and
summarized in the project description above. The Master Plan assigns the collection system
pipelines to disturbed areas for over 95% of the 407,800 lineal feet of the system required to serve
the District’s proposed wastewater collection service area. Further, a review of all of the pipeline
alignments in the field indicates that no substantial biological or cultural resource occur within the
proposed alignments. Any other alternative system would, of necessity, have to be located outside
of existing disturbed rights-of-way. Therefore, no alternative pipeline alignments are will be given
further consideration in this document.
Ramon: please explain the yellow highlighted elements of this sub section. Methods,
procedure and logic for what is presented here.
Chapter 3 AFFECTED ENVIRONMENT
(Omitted without comment)
3.1 AIR QUALITY
(Omitted without comment)
3.1.1 Federal Clean Air Act
(Omitted without comment)
3.1.2 California Clean Air Act
(Omitted without comment)
3.1.3 Regional Air Quality
Monitoring of air quality in the San Bernardino County portion of the MDAB is the responsibility of
the MDAQMD headquartered in Victorville. Because of the low population density within the
MDAQMD, limited monitoring resources are distributed over a relatively large geographic area. The
heaviest concentration of measurement is in the area of greatest development, the Mojave River
corridor. Air quality monitoring for ozone, the primary ingredient in regional photochemical smog,
nitrogen oxides, sulfur oxides, carbon monoxide, and respirable particulate matter (PM10) is
conducted at the Twentynine Palms monitoring station, which is closest station to the Yucca Valley
project area. Data for 2000-2002 for some parameters are shown on Table 3-2. No violations of the
federal one-hour ozone standard occurred at this station in this period, but days exceeding the
federal eight-hour standard were 4-13. The number of days exceeding the state standard for ozone
ranged from 3-16. No violations of federal standards for PM10 occurred in this period, but the State
PM10 standard of 50 ug/m3 was exceeded on 1-16 days.
As summarized above, ozone and particulates are seen to be occasional air quality concerns in the
Yucca Valley area. Exceedances of the more stringent state standard for Ozone and PM10 have
occurred periodically in the area. Although the magnitude of violations of ozone standards is much
less severe than in the SoCAB, the combination of the downwind location of Yucca Valley, and the
continued growth of upwind communities in Riverside and San Bernardino Counties as a pollution
source area for the project area, suggests that currently observed violations will continue until the
SoCAB meets ambient air quality standards. Violations of particulate standards in the project area
have been linked more to localized soil disturbance and windstorms than the organic particulate
matter from vehicle exhaust found in the more heavily populated areas of southern California.
Violations of particulate standards due to inorganic soil materials are thought to be less unhealthful
than those generated by combustion sources such as industry and motor vehicles. Clean air
attainment planning requirements, however, do not distinguish between organic and inorganic
pollutants. Because of the occasionally high levels of respirable particulate matter (PM10)
associated with strong wind events, substantial portions of the MDAB are designated as a federal
non-attainment airshed for PM10. While "imported" pollutants such as ozone and, to some extent,
particulate matter do on occasion exceed standards, locally generated pollutants such as carbon
monoxide (CO) or nitrogen oxides (NOx) are low within the Yucca Valley area because background
levels never exceed allowable levels and the sources of such emissions within the project area are
limited. The Mojave Desert area experiences very low baseline levels of primary (other than
photochemically reacted) automobile pollution such that the local airshed appears capable of
accommodating identified future growth with very nominal localized air quality concerns. Although
the dispersive capacity of the atmosphere in the desert is limited when cool air pools near the
surface at night during the cooler months, a much larger level of development, such as occurs in
Las Vegas or Phoenix (one plus million people), is needed to create violations of CO or NOx
standards. Comparison of the size of forecast population growth (population of 19,200 people in
Yucca Valley in 2000, with a conservatively high 3% annual growth rate, would increase to 25,804
by 2010) with the scope of development needed to create a significant air quality impact indicates
that this growth is not forecast to generate significant impacts from CO or NOx.
Ramon: Buildout numbers provide for a 6 mgd treatment facility with potentially another
built on the mesa and being considered for Joshua Tree. The JTNP currently is the most
polluted park in the national park system. Please explain how the conclusions of no
significant impacts from CO or NOx was determined?
Table 3-1
STATE OF CALIFORNIA AIR RESOURCES BOARD AMBIENT AIR QUALITY STANDARDS
(Omitted without comment)
Table 3-2
AIR QUALITY DATA
FOR TWENTYNINE PALMS MONITORING STATION
Parameter Days Exceeding
Federal Standard
Days Exceeding
State Standard Maximum Reading
(Omitted without comment)
3.1.5 Air Quality Planning
(Omitted without comment)
3.2 HYDROLOGY AND WATER QUALITY
3.2.1 Regulatory Setting
(Omitted without comment)
3.2.2 Surface Water
The project area encompasses the sewer collection system and the Hi-Desert water reclamation
facility (WRF) site. There are no perennial or permanent water bodies, lakes or streams, within the
project area. There are several ephemeral or intermittent stream channels within the project area.
None of these eight-to-ten ephemeral channels in the project area are formally named on the
United States Geological Survey (USGS) Topographic maps of the project area.
Ramon: The USGS has not tested the Yucca Valley Township and there has not been a water
survey of the town. This could account for no evidence from the given agency. However,
there is evidence of washes that display the physical characteristics of riparian and/or
blueline watershed. Ref. Mahaffey & Mendoza report on the existing hydrogeological status
submitted to the CRWQC-TAC showing watershed from the Joshua Tree National park that
has a greater rainfall than the Morongo Valley, nonetheless, that watershed create plant life
that qualifies as riparian in nature. Additionally the watershed into the east most Warren
Basin minimum water user, The Institute of Mental Physics/Joshua Tree Retreat exhibits
meaningful habitat and watershed though the Yucca Barrier to sustain the riparian stream
running west to east.
The streams originate in the Little San Bernardino Mountains to the south and in the Sawtooth
Mountain ridge that bounds the project area to the north. The largest stream is locally referred to as
“Yucca Wash.” During major precipitation events it collects flows from the tributary “blue line”
stream channels shown on these USGS Topographic Maps (Yucca Valley North and South, and
Joshua Tree North and South, 7.5' Topographic Maps).
Ramon: The origin of water coming out of the Covington Flats and the west end of the JTNP
have already been given to have riparian water shed streams, as evidenced by what remains
of riparian growth in the alluvial fan reseeding into the basin where the water saturated
aquifers exist as defined by USGS reports.
For most of the WRF site and most of the remaining project area, surface runoff occurs as sheet
flow that ultimately enters the alignment of the ephemeral channels. Note the term “blue line”
refers to a stream channel with a defined bed and bank as it is shown on a USGS Topographic Map.
Refer to Figure 2-1.
Ramon, the Army corps of Engineers and the State of California define blueline differently
however San Bernardino County USGS blue-line creeks or through field verification
ordinance. It is also noted that the Town of Yucca Valley also defines blueline consistent
with State of California Fish and Game definition. Therefore, l disagree with the conclusions
of the paragraph in question.
The proposed WRF site contains one surface water feature, a blueline, ephemeral desert wash,
which traverses the western portion of the site. This ephemeral stream originates in the Little San
Bernardino Mountains to the south. The wash flows southwest to northeast across the property and
exits the property where it flows beneath SR 62. From there, this dry desert wash extends to the
northeast until it has a confluence with Yucca Creek Wash and continues to flow east into the
Community of Joshua Tree.
Ramon: in light of previous statements already discussed, this paragraph too is flawed in
content and matter. Additionally this comment is extended to the yellow highlighted
statements below, as either being wrong in or validating the issue of the riparian definition
for the Hi-Desert Morongo Basin Region.
From there Yucca Creek Wash then flows north to dry lakes, which are considered isolated waters of
the United States. The wash receives flows primarily from the upland areas south of the site that
extend to the front of the north facing slopes of the Little San Bernardino Mountains. According to
the biological assessment conducted by Frank Hovore & Associates in July 2004, the wash is
sparsely vegetated by Joshua tree-creosote scrub in the upland areas, desert willow within the wash
bottom, annual wildflower species in the open terraces along the bottom margins, and Mormon tea,
which dominates the overall drainage. For the remainder of the project area, the future sewer lines
will occasionally cross an ephemeral stream channel along its alignment. In most cases these
crossing will occur within existing paved and graded road rights-of-way. Based on the field survey of
the sewer line alignment, no wetlands or riparian habitats are located within the proposed project
area or along the pipeline alignments. Because these stream channels are isolated and ephemeral,
the preliminary finding is that they are not subject to U.S. Army Corps of Engineers (Corps) Clean
Water Act Section 404 jurisdiction, i.e., they are not waters of the United States. On the other hand
the channels appear to be waters of the State of California and are within the jurisdiction of the
California Department of Fish and Game (CDFG). A CDFG 1602 Streambed Alteration Agreement will
need to be obtained for any disturbances of the ephemeral stream channels within the project area.
Finally, it is also probable that the California Regional Water Quality Control Board, Colorado River
Basin (Regional Board) will assert jurisdiction under its Porter-Cologne responsibilities and require
waste discharge requirements for these disturbances.
According to the Town of Yucca Valley General Plan (1995) Exhibit V-3, the WRF project site is
located within a Zone A flood hazard area, which designates areas of 100-year flooding. As
presently envisioned, the WRF will be located to the east of the 100-year flow line, but based on
final engineering the WRF facilities may encroach within this area.
3.2.3 Groundwater
The water supplied to Yucca Valley is extracted from the Warren Valley Groundwater Basin and the
Ames Basin. The District is the principal water purveyor servicing the Yucca Valley area. The District
obtains all of its water supplies from 13 active wells that pump groundwater from the Warren Valley
Groundwater Basin. Fifteen of these wells are generally located along the Yucca Wash or Creek, with
two located on the Mesa to the north. Current estimated production is approximately 3,000 acrefeet
per year (acre-ft/yr). According to the District, it also has rights for up to 800 acreft/ yr from
the adjacent Ames Valley Basin. The District also receives imported water from the Mojave Water
Agency (MWA) and the State Water Project (SWP) to supplement local groundwater supplies. This
water is piped to the project area and recharged into the Warren Valley Basin through a series of
recharge basins in Town of Yucca Valley along Yucca Creek Wash.
Ramon: It is believed that the majority of the water that is consumed for drinking is now
purchased water from local grocery stores or from bottled water sources.
According to a U.S. Geological Survey study, published in 1972 (USGS 1972), the Warren Valley
Groundwater Basin was reported to be small and not exceeding 200 acre-ft/yr of natural recharge.
Ramon: The comparison to the Fenner Valley/Cadiz study and the test well in the Ames
Basin by Dr. Joe Birman has already been discussed as showing the USGS model of the 1972
model to be “very conservative” as explained by Dr. Birman concerning the differences in
geological status and test for hydrological conditions to support claims made in litigation
between the HDWD and the Big Horn/Desert View Water District. The error factor was given
as being off by a factor of 10; hence the 200 acre feet figure would be 2 million acre feet or
enough water for more than 8 million people one year. In other words, 10 years of water
without counting normal recharge. Normal recharge can be verified by a Water Survey, as
recommended by the EPA 2004 to Congress.
Groundwater pumped from wells in the 1950s and 1960s was used chiefly for domestic uses. The
groundwater in storage in 1958 was computed to be 106,000 acre-ft. It was surmised that the
consumptive-use in the basin since 1958, i.e., until 1972, still yielded at least 96,000 acre-ft of
groundwater in storage. Since the late-1990s the District has been importing and recharging
groundwater in recharge basins constructed for this purpose. The imported water has been used to
offset and eliminate any continued cumulative contribution to overdraft of District operations.
Ramon: the issue of overdraft is an assumed condition that has no Water Survey science to
support the conclusion. In fact there is more related data that would conclude that
supporting data is contrary to the conclusions made.
3.2.4 Water Quality
According to the Regional Board’s Water Quality Control Plan (page 2-3), the groundwater resources
in the Warren Valley Groundwater Basin are considered suitable for municipal or domestic water
supply. The Warren Valley Groundwater Basin is part of the Joshua Tree Hydrologic Unit (708.00
Area Code) and is designated as the Warren “Hydrologic Area” (HA) (708.20 Area Code) on the
Colorado River Hydrologic Basin Planning Area Map. Table 2-5 identifies the beneficial uses of
groundwaters in this Basin to support municipal (MUN) and industrial (IND) beneficial uses.
Regarding water quality, the Warren Valley Groundwater Basin was considered to be historically low
in dissolved solids. Concentrations ranged from approximately 120 to 250 mg/L, and averaged
about 160 mg/l, according to data from a 1972 study (USGS 1972). Fluoride concentrations in that
time period ranged from 0.2 to 1.0 mg/L, and averaged 0.4 mg/L. No concentrations of ions in
excess of the limits recommended by the U.S. Public Health Service at that time were reported. A
more recent study (USGS 2002) focused on lithologic and water quality data for the years 1992-
1998. Two monitoring stations were developed in the Warren Groundwater Basin, YV-1 and YV-2.
Dissolved solids for station YV-1, depths of 230-570 feet below-ground surface, ranged from 158-
502 mg/L. Dissolved solids for station YV-2, depths of 300-570 feet below-ground surface, ranged
from 179-309 mg/L. Dissolved nitrogen (NO2 and NO3) levels, expressed as mg/L of N, ranged
from 2-30.3 mg/L for station YV-1 and from 1.09-11.2 mg/L for station YV-2. Concentrations of
nitrate above 10 mg/L are considered unhealthy for routine human consumption, and small babies
may be at risk with even lower concentrations.
Ramon: It is noted that the HDWD did not test for bacteria hetre.-plate count until 2008,
which is known to identify the probable cause of nitrate and can be used to control and
eliminate the nitrates from even blackwater.
In support of the evaluation of potential adverse effects from implementing the proposed Hi-Desert
WRF, the U.S. Geological Survey (refer to Appendix 3) recently collected water quality samples from
the piezometer at the monitoring site (1N/6E-32G01S) and from a production well located on the
Mental Physics property (1N/6E-28N01S). Both are located within the East hydrologic unit of the
Warren Groundwater Basin. The water samples from the wells were analyzed for general chemistry,
nutrients and selected isotopes and pharmaceuticals. The water quality data are presented in Tables
3-3 and 3-4. According to the analysis of water quality presented by the U.S. Geological Survey, All
of the constituents analyzed had concentrations below the U.S. Environmental Protection Agency
(EPA maximum contaminant level (MCL), with the exception of nitrate plus nitrite analyzed in the
February 2009 sample from 1N/6E-28NP1S (the Mental Physics well).
This nitrate plus nitrite concentration was analyzed to be 18.4 mg/L as N; The EPA MCL for nitrate is
10 mg/L. The pharmaceutical results were available only for Well 32G1 (WRF onsite piezometer)
because insufficient volume of water was available from well 28N1. As shown in Table 3-4, none of
the pharmaceuticals analyzed exceeded detection levels.
According to the Town of Yucca Valley General Plan Water Resources Element, there are several
sources for groundwater contamination within the area, including septic tank systems, underground
oil and gas storage tanks, and a District well, which has already been capped and filled.
The Mental Physics site has three wells. The two wells in the Yucca Wash are not in use
because of nitrate contamination. The well nearest to the state highway 62 is being
currently used. The report does indicate that the well in use at Mental Physics exhibited high
amounts of nitrate (1N/6E-28N01S). This well takes water coming from the Covington Flats
Area.
There is no scientific proof that septic tanks are the cause of these nitrates. There is
evidence that water was percolated too fast and caused recharge water to reach septic tanks
in the recharge area (off of Old Women Springs Road. There is also the question of test data
regarding the septic tank systems involved with this finding. There is no mention that the
septic tanks were tested at the Mental Physics site.
3.2.5 Water Quality Planning
The Water Quality Control Plan, or “Basin Plan,” for the Colorado River Basin Region (California
RWQCB 1994) describes the beneficial uses and water quality objectives for both surface and
groundwaters within its jurisdiction. As noted above, the proposed project is generally located in the
Morongo Basin, more specifically in the Joshua Tree Hydrologic Unit (HU) and the Warren [Basin].
Ramon: The Warren Basin extends into the Joshua Tree community, but all of the Warren
Basin is required to be monitored by the HDWD, where samples may be subject to suspect
due to lack of procedure and monitoring are stipulated by the court adjudication on the
Warren Basin. The Joshua Tree community may be receiving contaminated water flowing
across the so-called Yucca Barrier.
Table 3-3
GENERAL CHEMISTRY, NUTRIENTS, AND SELECTED ISOTOPES FOR WELLS 1N/6E-29N1
AND 1N/6E-32G1
(Omitted without comment)
__________
Table 3-3 (page 3 of 3)
(Omitted without comment)
Table 3-4
(Omitted without comment)
3.2.6 Water Supply Planning
(Omitted without comment)
3.3 UTILITIES / SERVICE SYSTEMS
(Omitted without comment)
3.3.1 Domestic Water
(Omitted without comment)
Table 3-5
GROUNDWATER PUMPING RIGHTS IN ACRE-FEET PER YEAR
Party to the Adjudication Pumping Right (AF/Yr)
(Omitted without comment)
Table 3-6
CURRENT AND PLANNED WATER SUPPLIES IN ACRE-FEET
Water Supply Sources 2005 2010 2015 2020 2030
(Omitted without comment)
Table 3-7
ACTUAL AND PROJECTED WATER CONSUMPTION IN ACRE-FEET
2005 2010 2015 2020 2030
(Omitted without comment)
3.3.2 Sewage Treatment
Onsite subsurface septic tank-leach systems are used throughout the Yucca Valley area, for
residential, commercial and industrial operations. There is no regional wastewater treatment facility.
However, due to the effects of these individual systems on nitrates and total dissolved solids levels
in groundwater resources, the District constructed a Nitrate Removal and Blending Plant, which
treats multiple groundwater wells. Operations began in 2002. Some larger commercial or residential
developments may utilize package wastewater treatment systems.
Ramon: The nitrate problem cannot be shown to exist at some wells and the cause has
already been discussed. The problem can be controled by testing for bacteria , total nitrogen
and ammonia.
3.3.3 Solid Waste Disposal
(Omitted without comment)
3.3.4 Natural Gas
(Omitted without comment)
3.3.5 Electric Power
(Omitted without comment)
3.4 LAND USE / PLANNING
3.4.1 Regulatory Setting
(Note that parts of this were omitted, to focus on the element effected by the comment given.)
The proposed project is located within the Town of Yucca Valley in San Bernardino County. The
project area is subject to regional and local planning guidance and regulations. The only federal and
state land use policies or regulations that would potentially affect the project are those for specific
resources (such as for mineral and biological resources).
There are federal endangered species issues, habitat, and blueline exhibited conditions that
are federal responsibilities.
Otherwise, the project area is subject to county-wide and regional planning efforts in regional
growth management and environmental management, particularly for congestion management
(transportation) and solid waste management issues. The project area is also subject to regional
planning efforts, in which regional comprehensive plans for growth management,
mobility/transportation, and air quality management apply. The governing land use documents are
the San Bernardino County General Plan and the Town of Yucca Valley General Plan and associated
Zoning Ordinances and Development Codes. Applicable plans will be described in the following
section, in the context of consistency of the proposed project with these plans.
Consistency with State, Regional and Local Plans
There are currently no adopted Habitat Conservation Plans, Natural Community Conservation Plans,
or other approved local, regional, state habitat conservation plans associated with the proposed
project area. Therefore, no potential exists for conflicts with any such plans from implementing the
proposed project. There are no designated Wild and Scenic Rivers in the project area. The area is
not within a Coastal Zone Management Area.
Therefore, the federal and state plans associated with such designated areas do not apply to the
proposed project.
Ramon: Disagreement on the stated conclusion has already been given. In addition the
Open Space Planning Group locally has given that habitat corridors exists in the project area.
About 75% of the project is within the land planning authority of the Town of Yucca Valley,
with the Mental Physics site under the land use authority of the San Bernardino County. This
dual responsibility for land use decision is a problem for management of the ground water
and raises many questions as to proper water testing and realization of water management
to state and local standards due to lack of a test plan and quality control attributes and
metrics.
3.5 TRANSPORTATION / TRAFFIC
(Omitted without comment)
3.5.2 Local Area Circulation System
(Omitted without comment)
3.6 NATURAL RESOURCES
3.6.1 Regulatory Setting
This section of the document discusses ecological system and natural community issues of concern.
The focus of this section is on biological communities, not individual plants or animal species. This
section also includes information on wildlife corridors and habitat fragmentation. Wildlife corridors
are areas of habitat used by wildlife for seasonal or daily migration. Habitat fragmentation involves
the potential for dividing sensitive habitat (unique natural communities or natural communities of
concern) and thereby lessening its biological value. Habitat areas that have been designated as
critical habitat under the Federal Endangered Species Act are discussed in a following section which
addresses threatened and endangered species, and wetlands and other waters of the United States
and State of California are also discussed in a following section of this document. Wetlands and
other waters are protected under a number of laws and regulations. At the federal level, the Clean
Water Act (33 U.S.C. 1344) is the primary law regulating wetlands and waters. The Clean Water Act
(CAA) regulates the discharge of dredged or fill material into waters of United States, including
wetlands. Water of the United States include navigable waters, interstate waters, territorial seas
and other waters that may be used in interstate or foreign commerce. To classify wetlands for the
purposes of the CAA, a three-parameter approach is used that includes the presence of hydrophytic
(water-loving) vegetation, wetland hydrology, and hydric soils (soils subject to
saturation/inundation). All three parameters must be present, under normal circumstances, for an
area to be designated as a jurisdictional wetland under the CAA. Section 404 of the CAA establishes
a regulatory program that provides that no discharge of dredged or fill material can be permitted if
a practicable alternative exists that is less damaging to the aquatic environment or if the nation=s
waters would be significantly degraded. The Section 404 permit program is run by the U.S. Army
Corps of Engineers (Corps) with participation and some oversight by the federal Environmental
Protection Agency (EPA).
The Executive Order for the Protection of Wetlands (EO 11990) also regulates the activities of
federal agencies with regard to wetlands. Essentially, this EO states that a federal agency, such as
the FRA, cannot undertake or provide assistance for new construction located in wetlands unless the
head of the agency finds: (1) that there is no practicable alternative to construction and (2) the
proposed project includes all practicable measures to minimize harm. At the state level, wetlands
and waters are regulated primarily by the California Department of Fish and Game (CDFG) and the
Colorado River Regional Water Quality Control Board (Regional Board or RWQCB). Sections 1600-
1607 of the Fish and Game Code require any agency that proposes a project that will substantially
divert or obstruct the natural flow of or substantially change the bed or bank of a river, stream, or
lake to notify CDFG before beginning construction. If CDFG determines that the project may
substantially and adversely affect fish or wildlife resources, a Lake or Streambed Alteration
Agreement will be required. CDFG jurisdictional limits are usually defined by the tops of the stream
or lake banks, or the outer edge of riparian vegetation, whichever is wider. The Regional Boards
were established under the Porter-Cologne Water Quality Control Act to oversee water quality. This
is done through the issuance of water quality certifications in compliance with Section 401 of the
Clean Water Act when the area of potential effect is located in waters of the United States. When
only State waters are involved in the discharge of dredged or fill material, the Regional Board can
review and issue waste discharge requirements (WDR) under the Porter-Cologne Act to achieve the
same water quality protection objectives.
Ramon: Disagreement on the conclusions as stated here have already been discussed;
additionally, the issue of habitat now known and the issue of riparian notes that these issues
are arguable under the laws of the Environmental Justice process.
3.6.2 Biological Resources
As part of the work for the General Plan, the Town of Yucca Valley and surrounding areas were
categorized and mapped for Biological Resources Values (Tierra Madre Consultants, 1994). The
proposed WRF project site is considered to be in a High Biological Resource Value area, due to the
fact that it is an undeveloped area vegetated by native scrub and woodland habitat. A blueline,
[and] ephemeral desert wash traverses the western portion of the project site. The wash originates
from the southeast corner of the property and receives flows from the Little San Bernardino
Mountains and alluvial upland areas to the south. The WRF site remains undeveloped at this time.
According to the General Plan (1995), surveys of vacant lands must be completed and project
proposals are reviewed and evaluated to assure minimal impacts to existing habitat and wildlife.
Most of the sewer collection system will be placed in existing paved or graded roadway alignments.
All of the sewer alignments shown on Figure 2-2 were surveyed by biologists and support staff of
Tom Dodson & Associates. Biology surveys of both the 80-acre proposed WRF site and the sewer
pipeline alignments are provided as Appendix 4 to this IS/EA. The following characterizes the
general plant community (ies) and wildlife habitat that occurs within the proposed WRF and sewer
pipeline project areas.
Flora
The project’s general area of potential impact is located within the predominant plant communities
of the Town, Joshua Tree Woodland and Creosote Bush Scrub. The Joshua Tree Woodland is a state
designated Community of Highest Inventory Priority. According to the Biological Assessment
completed for the General Plan (Tierra Madre Consultants ,1994) the Joshua Tree Woodland
community is an open woodland with the Joshua tree ( Yucca brevifolia) as the only tree-like
species, and with numerous shrub species between 3-13 feet tall. These shrubs include: the Mojave
yucca ( Yucca shidigeria), California juniper (Juniperus californica), peachthorn (Lycium cooperia),
boxthorn ( Lycium andersonii), joint-fir (Ephedra spp.), creosote bush (Larrea tridentata), burrobush
( Ambrosia dumosa), goldenbush (Haplopappus spp.), cheesebush (Hymenoclea salsola), and cacti
( Opuntia spp. and Echinocereus spp.). This plant community also contains many annual plants,
perennial grasses, and introduced plants from local landscaping activities. The Creosote Bush Scrub
community also occurs in the general area of the project and is similar to the Joshua Tree
Woodland, but it is dominated by the creosote bush with scattered Joshua Trees. It
is sometimes difficult to distinguish the two.
The Town of Yucca Valley requires developers to salvage native joshua trees and shrubs for
incorporation in project landscaping or to transplant trees to other sites. The Town has a Joshua
Tree Removal permit process. The District would be subject to these requirements. Additionally, San
Bernardino County Ordinance 3175 recommends that all creosote bush rings greater than 10 ft. in
diameter be preserved. Native plants such as cactus are to be salvaged. The proposed WRF site
contains several Joshua Trees, creosote bush, Mojave yucca, cheesebush, annual plant species, and
cacti. A site-specific biological assessment was conducted for this area and is provided as Appendix
4 to this document. The proposed pipeline routes are located primarily along previously disturbed
road rights-of-way. However, in certain areas both the sewer pipelines and pump stations cross
undisturbed areas, including ephemeral stream channels which are described in the surface water
hydrology discussions above (Section 3.2). A site-specific biological assessment was conducted for
the sewer line alignments and is provided as Appendix 4 to this document.
The biological assessments indicated that the plant community at the proposed WRF site is Creosote
Bush Scrub, dominated by the creosote bush ( Larrea tridentata), cheesebush (Hymenoclea salsola),
Joshua trees ( Yucca brevifolia), desert senna (Senna armata), and mormon tea (Ephedra
nevadensis ). Hedgehog cactus (Echinocereus Engelmanii), teddy-bear cholla (O. Bigelovii), pencil
cactus ( O. Ramosissima), buckhorn cholla (O. Acanthocarpa) and beavertail (Opuntia basilaris var.
basilaris ) also occur in the wastewater treatment plant site. The wash area is also dominated by
Creosote Bush Scrub intermixed with Mormon tea. The wash bottom is inhabited by desert willow
( Chilopsis linearis) and a variety of annual wildflower species. Refer to the species list in Appendix 4
which shows all plants identified at the wastewater treatment plant site. The same general list of
plant species were found along the pipeline alignments where these alignments crossed undisturbed
or disturbed natural communities. Refer to the species list in Appendix 4.
Fauna
Several sensitive and one listed (i.e., threatened or endangered) animal species occur within the
Town, as associated with the above plant communities. Those species included in the biological
survey for the General Plan (Tierra Madre Consultants, 1994) included: 42 species of reptiles –
desert spiny and fence lizards, snakes (gopher snake and several types of rattlesnake), and the
threatened desert tortoise and sensitive San Diego horned lizard; 235 species of birds – the
sensitive burrowing owl, loggerhead shrike and LeConte’s thrasher, as well as numerous raptor and
songbird species; 59 mammal species–several types of bats, desert cottontail, jackrabbit, ground
squirrels, kangaroo rats, coyote, raccoon, bobcat, mountain lion, and mule deer. A focused Desert
Tortoise Survey (following the survey protocol established by the USFWS) was conducted by Frank
Hovore & Associates in 2004 as part of the biological survey. No tortoises and no recent or
historical signs of tortoises (burrows, scat, carapaces) were observed on the project site or in its
zone of influence. The Burrowing Owl ( Speotyto cunicularia) and LeConte’s thrasher are federal and
state Species of Special Concern. Due to the use by off-road vehicles throughout the Town and
project area, these species are not expected to be present on the project site. In addition, there was
no evidence of use of the project area by these species. However, cactus wren ( Campylorhynchus
brunneicapillus ), house finch (Carpodacus mexicanus), Gambel’s quail (Callipepla gambeli),
blackthroated sparrow ( Amphispiza bilineata), lark sparrow (Chondestes grammacus), western
meadowlark ( Sturnella neglecta), and mourning dove (Zenaida macroura) bird nests were
encountered in the project area, as well as nesting behavior observed in other bird species. The
State of California prohibits the take of active bird nests (California Fish and Game Code Sections
3503 and 3503.5). Other bird species observed within the project area (both sewer line alignments
and WRF site) include common raven ( Corvus corax), northern mockingbird (Mimus polyglottos),
European starling ( Sturnus vulgaris), Brewer’s sparrow (Spizella breweri), ash-throated flycatcher
( Myiarchus cinerascens), western kingbird (Tyrannus verticalis), and American kestrel (Falco
sparverius ). The most common reptile observed was the side-blotched lizard (Uta stansburiana).
Other reptiles observed onsite were the Great Basin desert whiptail lizards ( Cnemidophorus t.
tigris ), yucca night lizard (Xantusia v. vigilis), and long-nosed leopard lizard (Gambelia wislizenii).
The only snakes observed on the WRF site were two red racers ( Masticophis flagellum piceum).
Wildlife on the WRF site included species observed directly or by indicative sign (scat, tracks,
burrows, nests or calls). Mammals included the kangaroo rat ( Dipodomys sp.), Audubon’s (desert)
cottontail ( Sylvilagus audubonii), antelope ground squirrel (Ammospermophilus lsucurus), Botta’
Pocket Gopher ( Thomomys bottae), and desert woodrat (Neotoma lepida).
As a result of the desert tortoise protocol surveys of the WRF site and the sewer line alignments, no
desert tortoise were identified with project areas of potential effect. Refer to Appendix 4 for a
complete species list and discussions of other sensitive animal species.
3.6.3 Geology and Soils
Regulatory Setting
The key federal law related to these issues is the Historic Sites Act of 1935, which established a
national registry of natural landmarks and protects “outstanding examples of major geological
features.”
Hazards as they relate to public safety are also concerns for project design. Of primary importance
to the project area is that of seismic hazards. The anticipated Maximum Credible Earthquake (MCE)
and location of fault zones are important criteria that drive the design and retrofit of structures. The
state, county and local hazards overlays are used to assess the risks of proposed projects.
Affected Environment
Geologically, the project area and surrounding vicinity are at the boundary of the
Transverse Ranges and the Mojave Desert Geomorphic Provinces. The hills and mountains trend in
an eastwest direction, with the Pinto and Eagle Mountains to the east and the Santa Monica and
Santa Ynez Mountains to the west. The immediate valley in the Town of Yucca Valley is bounded by
the Little San Bernardino Mountains on the south and the Sawtooth Mountains to the north. The
valley floor contains Quaternary alluvial deposits and older superficial sediments, including sand and
gravel eroded from the adjacent highlands. Alluvial soils consist of unconsolidated sand and gravel
with minor amounts of clay and silt, estimated to be 100 feet or less in thickness. Older alluvium
consists of coarse-grained sediments, including cobbles, pebbles and coarse sand. This alluvium
extended to greater than 500-foot depth, particularly in the north and east (General Plan EIR 1995).
The existing fault that represents the greatest local threat in the project area is the Pinto Mountain
Fault, with an estimated maximum Richter magnitude earthquake event of 7.4 and peak ground
acceleration of 0.60 (g), with an estimated duration of strong ground shaking of 31 seconds. The
proposed WRF project is not located within a mapped fault rupture zone or Alquist-Priolo Special
Studies Zone (Seismic Safety Element of the General Plan, Exhibit V-1, 1995). The sewer pipeline
alignments will cross the Pinto Mountain Fault, which is located north of SR 62 and other inferred
faults.
Regional seismicity appears to be dominated by the San Andreas Fault (west of the Morongo Basin)
and the Johnson Valley Fault (the Landers Fault System approximately 3 miles north of Yucca
Valley). Both of these faults run north-south, or northwest-southeast, and pose no direct ground
rupture hazards within the project area. However, the 1992 Landers earthquake on the Johnson
Valley Fault caused “sympathetic ground ruptures” along the Pinto Mountain Fault (Leighton and
Associates, Inc. 1993). This earthquake damaged 40 percent of the District’s subsurface water
distribution lines and over $100 million of other property damage, according to the Seismic Safety
Element of the General Plan (1995). Liquefaction can occur when loose, unconsolidated and
saturated sandy soils are subjected to ground shaking during a seismic event. This causes the soils
to “liquefy.” This is not seen as a general hazard in the in the Yucca Valley area, due to the depth of
200 feet or more to the groundwater table. In addition, soils within the project area are coarse
alluvial soils, i.e., sandy. Expansive soils are not considered to be a concern in the Yucca Valley, as
these would contain significant amounts of clay. The project area is also located in a “low”
susceptibility zone for rockfalls and landslides (General Plan 1995).
Ramon: In addition to the earthquake faults given, USGS reported faults slightly west of the
WTF site. Statements made are assumed conclusions without test or science of the
hydrogeological status.
3.6.4 Mineral Resources
(Omitted without comment)
3.6.5 Visual Resources / Aesthetics
The desert background consists of typical Joshua Tree woodland and creosote bush scrub alluvial
fan areas with varying levels of human disturbance depending on proximity to the Yucca Valley
urban corridor along SR 62. The proposed project site is located in the near vicinity of SR 62 within
an area developed with mixed residential, commercial, and industrial uses. The SR 62 and SR 247
are designated as “eligible” for official Scenic Highway designation. Additionally, the Town of Yucca
Valley has designated some local routes as Scenic Roadways (General Plan 1995, Exhibit III-13).
According to the General Plan, any projects in the above named scenic corridors need to minimize
impacts on scenic values. The proposed wastewater treatment plant design includes a 1,000-foot
setback or more from SR 62. Night lighting occurs throughout the project area. Individual
residences have exterior night lighting on the outskirts of the town and a combination of street
lights and individual residential lighting occurs within the urban area of the town, i.e., closest to SR
62. Scenic views exist to the north and south to surrounding mountain ranges or ridges, but the
project site itself has no significant or unique visual resources. Development in the surrounding area
creates a human-dominated as opposed to a natural landscape visual setting.
Ramon: There has not been a Water Survey conducted in the “human-dominated areas
upstream of the WTF site, leaving questions regarding the dynamics of existing septic
response to watershed, either ephemeral or riparian in nature.
3.7 POPULATION AND HOUSING
The proposed wastewater treatment plant site is currently vacant. There are individual residences to
the north. These include single-family homes. Generally, the project area can support more housing
development, but this may be limited by location within the Pinto Mountain Fault Zone (where no
new housing is encouraged).
The Town of Yucca Valley 2000 U.S. Census population was 17,200 persons. This was less than that
predicted in area planning at that time. The District’s Water Supply Plan of 1990 (John Egan and
Associates) predicted 26,066-30,428 residents by the year 2000 and 30,250-40,131 by the year
2010 for its service area (which included Yucca Water Company service area). These estimates
assumed a 5 percent annual growth prior to the year 2000, then 3 percent. For the purposes of
planning, household sizes of 2.4-2.5 persons per dwelling unit were used. The Town’s General Plan
studies for the Housing Element (1995) indicated that population growth actually started slowing
from 1990-1993 and the District Urban Water Management Plan estimates annual average growth
from 2005 through 2030 to be about 2.3 percent. The Town had 18,336 persons in 1994, and was
anticipated to have 20,000 by the year 2000. Household sizes were estimated to be similar to those
used by the District, or 2.49-2.5 persons per dwelling unit. The District’s 2005 population estimate
was 26,000 persons based on water services within its service area which is
larger than the Town of Yucca Valley. Other trends that were described in the 1990s were: that the
population would shift from older retirees to younger families with children, and that more multifamily
housing would be developed. Trends have changed, due in part to the loss of population
after the 1992 Landers earthquake, and the more recent increase in population due to military
activities at Twentynine Palms and other area facilities. Overall, however, the population has not
shown the substantial growth forecast envisioned in the 1990s. Buildout was given as 24,401 units
in the General Plan (1995), of which the majority would be single-family housing with zero to 10
dwelling units per acre. In 1995, 79 percent of all housing was of the single-family type. At that
time, there were 8,585 units. The District’s service area encompasses more than the Town of Yucca
Valley, which had 5,366 connections in 1990.
The community contains a mixture of retirees and a service economy geared to serve them. Many
retired residents live on fixed incomes and the majority of the community consists of low to
moderate income residents. The WRF project site is located adjacent to commercial uses at the
north end adjacent to SR 62. A few single family residences and one industrial facility are located in
the immediate vicinity of the project site. These surrounding uses are consistent with those found in
the whole community and no particular unique income or ethnic group is known to occur within the
general project vicinity. No community issues related to environmental justice or …
Ramon: [sentence is incomplete]
3.8 CONSTRUCTION
The construction scenario for the project area has been summarized in the project description, but
some aspects are further discussed in the following text. The main activities related to construction,
that will be evaluated in the environmental consequences section of this report, include: site
clearing, grading, excavation and trenching, and installation of treatment facilities and equipment,
temporary lift station, pump stations, sewer pipelines and the operations building. All work will be
conducted within the identified footprint of the proposed facilities or within disturbed road rights-of
way. Temporary traffic management will be required as pipelines are installed within road rights-ofway.
Construction activities will temporarily affect local traffic in these road rights-of-way, but will
not affect traffic over the long term once the facilities are installed.
Ramon: Since the rights-of-way mapping and process is incomplete as of this writing, how
will this be mitigated if the rights-of-way cannot be mitigated or resolved through the
process?
3.9 ENERGY ISSUES
The project is located near existing developed areas and, thus, does not involve any need for
extension of any new energy resources. The wastewater reclamation facilities and pump stations will
require electricity to serve the proposed facilities, possible including night lighting and other support
equipment. Southern California Edison (SCE) provides the electricity to serve the proposed WRF and
related support facilities. There will be energy, primarily petroleum products and perhaps some
electricity, consumed by the construction activities. During operations electricity will be consumed,
and the project will have a back up diesel generator to provide power during an emergency loss of
electrical power.
Ramon: It is noted that the alternatives proposed to the HDWD, include but not limited to
“Localized Treatment” that produces it’s own electricity for treatment of Wastewater that is
dispersed “locally” for greywater applications.
3.10 COASTAL ZONE MANAGEMENT ACT
(Omitted without comment)
3.11 CULTURAL RESOURCES
3.11.1 Regulatory Setting
(Omitted without comment)
3.11.2 Affected Environment
(Omitted without comment)
3.12 WILD AND SCENIC RIVERS
(Omitted without comment)
3.13 ENDANGERED SPECIES
Please refer to the discussion of biological resources, in Section 3.6.1. The site specific biological
surveys resulted in the finding that no state and federal listed species occur at the WRF site or along
any of the sewer pipeline alignments.
Ramon: This has already been discussed, and the reports on this issue are flawed.
3.14 FLOODPLAIN MANAGEMENT AND PROTECTION OF WETLANDS
A blueline, [and] ephemeral desert wash traverses the proposed Hi-Desert property. The
wastewater treatment plant site appears to be located immediately east of this wash. In addition,
the proposed site is located within the 100-year floodplain of this channel, which originates in the
Little San Bernardino Mountains (JTNP) to the south. No wetlands or riparian habitat occur within
the project area of potential impact. The pertinent Federal Emergency Management Agency (FEMA)
map of the project area is provided in Appendix 6.
3.15 FARMLAND PROTECTION
(Omitted without comment)
3.16 COASTAL BARRIER RESOURCES
(Omitted without comment)
3.17 OTHER ENVIRONMENTAL ISSUES
3.17.1 Regulatory Setting
(Omitted without comment)
Table 3-8
SUMMARY OF HAZARDOUS MATERIALS REGULATORY AUTHORITY
Regulatory Agency Jurisdiction Authority
FEDERAL AGENCIES
(Omitted without comment)
STATE AGENCIES
(Omitted without comment)
3.17.2 Hazards and Hazardous Materials
(Omitted without comment)
3.17.3 Noise
3.17.3.1 Regulatory Setting
(Omitted without comment)
Table 3-9
LAND USE COMPATIBILITY FOR COMMUNITY NOISE ENVIRONMENTS
Community Noise Exposure
Ldn or CNEL, dB
Land Use Category
(Omitted without comment)
Table 3-10
FEDERAL NOISE ABATEMENT CRITERIA
Activity
Category
Noise Abatment
Criteria Level - Leq Description of Activity Category
(Omitted without comment)
3.17.3.2 Affected Environment
(Omitted without comment)
3.17.4 Public Services
(Omitted without comment)
3.17.5 Recreation and Section 4(f) Properties
(Omitted without comment)
3.17.6 Airport Hazards
(Omitted without comment)
3.17.7 Environmental Justice
3.17.7.1 Regulatory Setting
All projects involving a federal action (funding, permit, or land) must comply with Executive Order
(EO) 12898, Federal Actions to Address Environmental Justice in Minority Populations and Low-
Income Populations , signed by President Clinton on February 11, 1994. This EO directs federal
agencies to take the appropriate and necessary steps to identify and address disproportionately high
and adverse effects of federal projects on the health or environment of minority and low income
populations to the greatest extent practicable and permitted by law.
Ramon: The current economy and the impact of the WRF project is inappropriate for a
community who has an average income of $30,000.00 annually, is already burdened with
the California Water Project that is not needed, a Nitrate Treatment Plant that has already
cost over 2 milllion dollars and still does not work, hence; this burden too is more than can
be afforded…especially since the whole HDWD customer base can be hooked up to the
alternative proposal given the HDWD in the many public meetings where this was
discussed…including the CRWQC-TAC meetings.
3.17.7.2 Affected Environment
The project site is not located in a neighborhood that suffers from exposure to adverse human
health or environmental conditions. There are no major industrial activities or sites in the area. The
top employers generally are related to the school district, health care services and retail stores.
Yucca Valley is still mostly a community with a lower than normal average annual income, due in
part to retirees and part-time residents (seasonal).
Ramon: Pharmaceuticals may create more hazards to an existing problem for this
community.
3.17.8 Unique Natural Features and Areas
(Omitted without comment)
3.17.9 Sole Source Aquifer
The EPA’s Sole Source Aquifer (SSA) Program was established under Section 1424(e) of the Safe
Drinking Water Act (SDWA). Since 1977, it has been used by communities to help prevent
contamination of groundwater from federally-funded projects. The SSA program allow for EPA
environmental review of any project which is financially assisted by federal grants or federal loan
guarantees. Although nine sole source aquifers have been designated in California, the Warren
Valley Groundwater Basin is not listed among these aquifers as of January 29, 2009. Groundwater
is located several hundred feet beneath the project area of potential impact. The District obtains its
water supply entirely from the Warren Valley Groundwater Basin. Although this Basin is the
District’s sole source of water supply, the aquifer is not designated by the federal EPA as a “sole
source aquifer.”
Ramon: The district also provides potable water exported from the Ames Basin, and most
drinking water, with the exception of low income families, purchase bottle water for drinking.
3.17.10 Site Access and Compatibility
The land use designations on the properties adjacent to the project area of potential impact consist
of a mix of commercial, industrial, and residential uses. Roads to be affected by the WRF project
component include SR 62, Avalon Avenue, and Indio Avenue. Public access exists to all of the
project area of potential impact, although graded dirt, unpaved, roads are common in the area. The
vast majority of the proposed sewage collection system will be installed in these roadways and
access is generally excellent to all of the proposed collection system pipelines. The project site for
the WRF is currently a large area of open space that is considered valuable. This site is along the
SR 62, which is designated as “eligible” for official Scenic Highway designation. The project is
considered compatible with surrounding uses.
Ramon: as previously given, there are earthquake faults in these areas mentioned here, that
are known to the Town of Yucca Valley and the USGS, not appropriately explained in this
document.
3.18 INVASIVE SPECIES
3.18.1 Regulatory Setting
On February 3, 1999, President Clinton signed Executive Order 13112 requiring federal agencies to
combat the introduction or spread of invasive species in the United States. The order defines
invasive species as any species, including its seeds, eggs, spores, or other biological material
capable of propagating that species, that is not native to that ecosystem whose introduction does or
is likely to cause economic or environmental harm or harm to human health. The California noxious
weed list can be used to define the invasive plants that must be considered as part of the analysis
for this project.
Ramon: how will this be dealt with or mitigated?
3.18.2 Affected Environment
Much of the project area has been disturbed, and contains non-native plant and animal species.
The urbanizing portion of Yucca Valley abuts undeveloped desert habitat. Landscaping around
residences is the primary cause of introduced plants (in other locales it might be agricultural
practices). Residential “pets” such as dogs and cats are common. These are of concern, as they
prey on native birds and mammals. Invasive species occur throughout the project area, including
the WRF site. The biological survey contained in Appendix 4 lists the species found in the project
area that fall under this category.
Chapter 4 ENVIRONMENTAL CONSEQUENCES
The proposed project, the construction and installation of a wastewater treatment plant;
approximately 405,800 lineal feet of trunk sewer line of varying diameter (see Table 2-5); and three
pump stations are intended to provide the District’s service area with a wastewater treatment and
collection system that must be installed to protect and enhance groundwater quality.
Implementation of the proposed project will cause both temporary and permanent changes to the
physical environment during construction; however, the addition of the proposed wastewater
system infrastructure is essential to the District to continue meeting the public health and safety
requirements for water quality within its service area. Based upon the existing environmental
conditions outlined above in the “Affected Environment” discussion, this section of the Initial
Study/Environmental Assessment (IS/EA) evaluates the effects of the project on the physical and
human environment. The Environmental Consequences section is presented in the same order as
the issues are presented in the previous discussion. The following issues are evaluated by using the
questions posed for each issue in the standard California Environmental Quality Act (CEQA) Initial
Study Environmental Checklist Form, which is included after the text portion of this document.
Ramon: The alternative plan (Localized Treatment) presented by MITI would not create any
such problems as given here. The HDWD directors choose this system which is most
intrusive, is most subject to earthquake problems that would be much greater an impact on
ground water problems due to line ruptures, and is projected as worst case problems with
drinking water contamination subject to pharmaceuticals that cannot be controlled by the
WRF project.
4.1 AIR QUALITY
a. (Omitted without comment)
Table 4-1
DESIGNATIONS AND CLASSIFICATIONS
Ambient Air Quality
Standards AVAQMD MDAQMD
(Omitted without comment)
Table 4-2
ELECTRICITY GENERATION EMISSIONS
Pollutant Emissions (lbs/day)
CO VOC NOx SOx PM10
(Omitted without comment)
Table 4-3
SUMMARY OF PIPELINE CONSTRUCTION EMISSIONS
Pollutant Emissions (lbs/day)
CO VOC NOx SOx PM10
(Omitted without comment)
Table 4-4
SUMMARY OF TREATMENT PLANT
CONSTRUCTION EMISSIONS BY PHASE
Construction Phase
Pollutant Emissions (lbs/day)
CO VOC NOx SOx PM10
(Omitted without comment)
Mitigation measures to control fugitive dust
4.1-1 The construction site disturbed areas will be watered twice daily for short-term
surface stabilization, and more times if winds are sufficient to loft dust from the
construction site.
4.1-2 Chemical, vegetative or mechanical (compaction or paving) will be used for surface
stabilization upon completion of grading activities, if subsequent site uses are not
proposed.
Ramon: this procedure does not guarantee stablilization. (re. settling of the Gatlin/Wal-Mart
project where there is evidence of Liquefaction and settling that already presents a public
danger in the event of future earthquake events.
4.1-3 Trackout onto paved roads will be minimized, and removed (swept or washed from
paved surfaces) if substantial soil material accumulates on paved surfaces. Cleanup of
project related track-out or spills on paved roads will be removed daily.
4.1-4 Haul trucks will be covered.
4.1-5 Grading and soil movement activities will be minimized when winds exceed 30
miles per hour at the local airport or at an onsite wind monitoring system.
Mitigation measures to control construction equipment and mobile source
emission impacts [sentence is incomplete]
Ramon: Winds can get up to 60 to 80 miles per hour and cannot be mitigated as given.
4.1-6 Efficient scheduling of equipment use, with a phased construction schedule to
reduce the number of units operating simultaneously.
Ramon: What is the maximum and how will this be enforced?
4.1-7 Performing regular engine maintenance on all equipment.
Ramon: how will this be enforced?
4.1-8 Provision of local equipment storage areas so that equipment trips to the sites can
be reduced.
4.1-9 Construction personnel shall be encouraged to ride share to reduce vehicle trips to
construction sites, including incentives for carpooling among construction employees.
Ramon: how will this be enforced? Is there a problem if not enforced?
What would that problem be or expected to cause?
4.1-10 Shut down equipment when not in use for more than 10 minutes.
(parts a and b were not part of this document and the preamble was Omitted without comment)
c. Would the project result in a cumulatively considerable net increase of any criteria
pollutant for which the project region is non-attainment under an applicable federal state
ambient air quality standards (including releasing emissions which exceed quantitative
thresholds for ozone precursors)?
Ramon: how would this be enforced or controlled?
(Additional parts are Omitted without comment)
4.1-11 To the extent feasible, the District shall select landscaping that is fast-growing to
create a windbreak buffer along the periphery of the WRF site. A minimum of two rows
shall be installed at different times and plants shall be installed and grown in stages;
periodically harvested; and replanted to maintain carbon sequestration. Alternatively or
concurrently, the District may install solar power systems to partially or fully offset
operational electricity demand of the WRF. As a final alternative, the District may choose
to purchase annual or permanent carbon credits from the available carbon banks at the
time the facility begins operation.
This measure is considered sufficient to reduce the project’s contributions to GHG emissions to the
maximum extent feasible. It will also assist with creation of a visual buffer between the WRF and
surrounding land uses.
Ramon: There are no fast growing plants (native) suitable for this purpose. Suggest that a
10’ buffer and sound containment wall be constructed instead.
d. Would the project expose sensitive receptors to substantial pollutant concentrations?
(there were no parts a, b, and c. all else was Omitted without comment)
e. Would the project create objectionable odors affecting a substantial number of people?
Use of construction equipment may result in some temporary and localized odors from use of diesel
fuels. In addition, the wastewater treatment facilities and pump stations to be constructed as part of
the proposed wastewater treatment plant and sewer system have the potential to generate odors.
However, as described on page 10 of this document, specific odor control systems will be installed
to control odors from each of the potential odor sources. These odor control systems are standard
systems that are used at all WRFs and they are effective, except during upsets or accidents.
Regardless, due to their distance from the existing residential development, potential offsite impacts
are forecast to be less than significant. There are typical concerns from residents that a wastewater
treatment facility causes significant
There are typical concerns from residents that a wastewater treatment facility causes significant
odor effects. This is most commonly based on the assumption that the plant is handling material
that has natural odors and that these odors will be propagated by the treatment plant operation.
This is an incorrect assumption for ongoing, routine plant operations. When operating properly, such
plants typically have an earthy/musty odor, but not a sick, anaerobic decomposition odor. During
upset conditions, a plant can generate such odors, but the key to odor control is to ensure that
plant operations are managed to eliminate or minimize such upset conditions. The following
mitigation measure shall be implemented to ensure such conditions are minimized and that the local
community is not exposed to adverse odor conditions for any substantial amount of time.
Ramon: These two paragraphs are subjective at best. There is historical data from wherever
similar facilities, (old technology) are constructed or have been constructed to show
objective evidence that much of what is said here cannot be controlled, can create health
problems and is essentially not mitigated unless ther is a fund that is substantial enough and
a process that would move such problems out of the area where the WRF site exists.
4.1-12 The District shall require the installation of odor control facilities as part of the
facility design. These facilities shall be state of the art (odor control to the maximum
extent feasible) and shall control odors to ensure that adjacent properties are not
exposed to significant odor concentrations, except during an emergency/upset condition
at the WRF.
4.1-13 The District shall establish an odor complaint response phone number that shall be
clearly posted on the exterior fence of the treatment plant facility. If odor complaints are
received, the District shall respond within 24 hours to correct the problem, and provide a
response to the complainant within 12 hours of notification identifying what actions were
taken and how long was or will be required to control the odor problem. Sources of odors
shall be corrected in as timely a manner as possible.
Thus, overall project construction and operation is not forecast to create any significant
objectionable odor impacts. With incorporation of the above odor control measures as part of the
project, the potential project odor impacts can be controlled to a less than significant impact.
Ramon: See “buy-out” clause above.
No Project Alternative
Regarding air quality effects, the no project alternative would eliminate all construction and all
operating air pollutant emissions associated with the proposed project. Regarding conformity, the
proposed project can be implemented consistent with the MDAQMD air quality management plans
(AQMPs) and in conformity with the State Implementation Plan (SIP). Because the no project
alternative would not cause any direct emissions in the short-term it would also remain consistent
and in conformity with these plans. However, as nitrate concentrations increase in the future,
treatment of groundwater to remove nitrate would generate emissions from electricity consumption,
and if the Regional Board requires advanced individual treatment units for all existing septic tanks,
the ground disturbance within the community from construction activities would be comparable to
that of the proposed project. Such construction and electricity emissions could be implemented with
comparable mitigation measures to control emissions and remain consistent with the AQMPs and in
conformity with the SIP. Thus, no great benefit for air quality impacts would be achieved. The no
project alternative will not generate any direct emissions so it cannot contribute to existing air
quality violations. Indirectly, future treatment requirements for domestic water supply and
individual advanced treatment systems may indirectly generate emissions. Mitigation measures
comparable to those implemented for the preferred alternative would be sufficient to ensure the
emissions would not contribute substantially to an existing or projected air quality violation or a
cumulatively considerable volume of emissions. Under these assumptions the no project alternative
would also not adversely affect any sensitive receptors.
It is in the area of odors that the no project alternative can eliminate potential adverse effects. The
WRF can be routinely operated without generating noxious odors, but on rare occasions upset
conditions can generate such odors. The only way the no project alternative could generate odors
would again be indirectly, as a result of continuing to rely upon septic tanks. Such systems generate
the same type of anaerobic decomposition odors when they fail. Regardless, a higher potential for
adverse odor effects, although considered less than substantial, will occur at the proposed WRF.
Ramon: The MITI proposal that has been discussed with the HDWD district manager and
staff will eliminate the issues discussed here in this part.
4.2 HYDROLOGY AND WATER QUALITY
(Note: some parts are omitted because they were not relevant to the discussion.)
a. Would the project violate any water quality standards or waste discharge
requirements?
The proposed project operations will discharge effluent from the wastewater treatment plant to the
District’s proposed recharge basins. Therefore, since the proposed project will not discharge
wastewater to surface waters, it has no potential to violate surface water quality standards or waste
discharge requirements.
Ramon: The issue of standing water and potetial mosquito problems have been discussed. Included
was the issue of contamination from pharmaceuticals that could create a health problem in the
Eastern Warner Basin and in the JTWB district.
Mitigation measures to reduce and control erosion and sedimentation
4.2-1 The District shall prepare a Storm Water Pollution Prevention Plan (SWPPP) and a
Water Quality Management Plan (WQMP) that will achieve no net loss of topsoil from the
project sites and prevent runoff from causing erosion on adjacent property during
construction. The SWPPP and WQMP shall be provided to the construction contractor and
the contractor shall implement the SWPPP during all construction activities at the site.
Ramon: The HDWD does not currently have written procedures for testing or a quality
assurance management system with accessed quality attributes, metrics or levels of
acceptance. Hence, there is not at this time, an enforceable way to accomplish this
mitigation measure, in order to say that this mitigation measure can be accomplished.
4.2-2 The SWPPP prepared for the project site shall include a spill response program for
accidental release of water pollutants during construction that shall, at a minimum, meet
the following performance standards: adequate resources shall be maintained on the site
by the contractor to control any release of pollutants; if a spill occurs, the pollutant shall
first be contained, second the spill shall be reported to appropriate authorities, third the
pollutant contaminated material (soil, water, etc.) shall be collected in proper containers,
fourth the pollutant contaminated material shall be delivered to a facility with the
capability to treat or dispose of the contaminated material in accordance with existing
laws and regulations in place at the time of the accidental spill; fifth the area
contaminated by the spill shall be cleaned (remediated) to background conditions, or
alternatively to a level that meets the requirements of existing laws and regulations at
the time of the clean-up and that does not leave any
residual threat to humans or the environment in which the spill occurs.
Ramon: How will this be measured, and enforced without a site monitor assigned full time
during operations. What are the qualifications, procedure and other such methods asked for
here, become part of this project as given?
4.2-3 The District shall prepare the WQMP and include a Spill Prevention Control
Countermeasures Plan that will minimize the potential for release of any hazardous or
toxic chemicals to the environment. This Plan shall include a requirement to retain
material safety data sheets (MSDS) for all hazardous materials or substances at the site
and measures that outline the responses that will be implemented should an accidental
spill of hazardous materials onsite
occur. Based on the list of hazardous materials/substances that will be utilized at the
plant, the District Plan shall identify handling procedures and management options for
any accidental releases to the environment until such accidentally released material is
properly disposed of or treated so that no residual harm remains from the accidental
release.
Implementation of these measures will ensure that the proposed project construction activities and
treatment plant operations will be controlled to a sufficient level to prevent significant degradation
of water quality.
Ramon: How will this be measured, and enforced without a site monitor assigned full time
during operations. What are the qualifications, procedure and other such methods asked for
here, become part of this project as given?
Note…no subpart a.
b. Substantially deplete groundwater supplies or interfere substantially with groundwater
recharge such that there would be a net deficit in aquifer volume or a lowering of the
local groundwater table level (e.g., the production rate of pre-existing nearby wells
would drop to a level which would not support existing land uses or planned uses for
which permits have been granted)?
The proposed WRF will generate a higher quality of wastewater effluent, compared to the existing
situation, that will be returned to the groundwater aquifer in the Warren Valley Basin.
Approximately 80% of the effluent delivered to the WRF will be returned to the aquifer through the
percolation ponds (accounts for plant losses and evaporation from the pond). General estimates of
wastewater discharged from septic tank systems reaching the groundwater aquifer are about 50%,
as some of the septic tank effluent remains in the vadose zone and other portions are evaporated or
transpired into the atmosphere. Thus, the proposed project is not forecast to substantially deplete
groundwater supplies or interfere substantially with groundwater recharge. The project will enhance
such supplies and enhance recharge on the WRF property. No mitigation is required.
Ramon: the intent of this statement is not clear and is subjective at best as it assumes
conditions that may be possible in some cases. Such as the vadose zone and records (re.
effluents from septic tank data—re. Action Pumping records).
There is a great question regarding the “storage” capability of the recharge (loss of water
from the HDWD into the JTWD), mosquitoes in open recharge ponds, and other issues
concerning the proximity of the Salton Sea (noted as having West Nile Virus problems) and
in particular with the statement regarding enhancement of water percolated from the WRF
that can have problems with pharmaceutical contamination and mixing “cocktails” that could
be a health hazard.
c. Would the project substantially alter the existing drainage pattern of the site or area,
including through the
alteration of a stream or river, in a manner which would result in substantial erosion or
siltation onsite or offsite?
The existing drainage system for the project area of impact will effectively remain the same. The
proposed pipeline alignments will cross many stream channels, mostly within existing paved or
graded roadways. At some locations, including the stream channel (wash) located onsite, pipelines
will cross either natural or man-made washes. Based on a field review of the sewer pipeline
alignments, there is no wetland located within any of the channels, and it is anticipated that the
only regulatory permits required will be a 1602 Streambed Alteration Agreement from the California
Department of Fish and Game and waste discharge requirements from the Regional Board. Based
on field review of the washes, the surface flows will continue unaltered after the pipelines are placed
below the ground surface. Some minor modification of the channel that crosses the property may be
required, if the channel segment adjacent to the WRF requires hardening to protect the
WRF site from a 100-year flood hazard. It does not appear that channel modifications on the WRF
site will be required because there appears to be sufficient room to install the WRF without
encroachment on the channel, i.e. any flood protection can be installed within upland areas adjacent
to the channel. However, if channel modifications are required, they will consist of hardening the
channel wall adjacent to the WRF to ensure that it will not be eroded and expose the WRF facilities
to flood hazards.
Regarding potential for erosion and siltation, implementation of the SWPPP will control erosion and
sedimentation potential. Because the washes in Yucca Valley are isolated waters of the United
States, it will probably not require a Corps of Engineers Section 404 Permit or a Section 401
certification from the Regional Board because the surface runoff occurs in an isolated basin, which
has no connection to any waters of the United States. However, as noted above, the Regional Board
may require waste discharge requirements (WDR) for this project based on separate Porter-Cologne
requirements. To address any adverse effects of fill requirements or stream bed alterations within
this wash, the following mitigation measure will be implemented:
4.2-4 The District shall restore any channel crossing locations with a comparable quantity
or quality of habitat to that disturbed or removed during construction of the proposed
project. Because no sensitive riparian or wetland habitat will be affected, the project will
not be required to create such habitat or acquire mitigation bank credits. Channel
restoration in the area of the pipeline crossing is considered adequate by the District to
fully mitigate effects on altering the stream bed on the project site. The District must
acquire a 1602 Streambed
Alteration Agreement and may have to acquire a WDR from the Regional Board, and shall
implement the requirements of the WDR and Agreement as long as it is not less that
identified above.
Implementation of this measure is adequate to reduce any adverse effects to the onsite wash to a
less than significant impact level.
Ramon: Given that this has already been discussed (i.e., riparian area does exist in this
watershed originating from the JTNP alluvial fans and Covington Flats, flowing into the
district and specifically at the WRF site, channel crossings of pipe can liquefy the soil where
the crossing is accomplished and cannot be compacted, which would make the pipe
vulnerable and potentially subject to earthquake breakage, making all of the other mitigation
meaningless.
d. Would the project substantially alter the existing drainage pattern of the site or area,
including through the alteration of the course of a stream or river, or substantially
increase the rate or amount of surface runoff in a manner which would result in flooding
onsite or offsite?
As noted above, the wash on the project site will not be substantially altered and future runoff from
upstream of the site will continue to flow in this wash to the downstream channel. The sewer
pipelines will also cross channels. Where such pipeline crossings occur outside of paved roads, it
may be necessary to obtain regulatory permits from CDFG (1602 Streambed Alteration Agreement)
and the Regional Board (waste discharge requirements, WDR) as outlined under mitigation measure
4.2-4. Regarding runoff from within the WRF, it will be collected in a retention basin and discharged
to the headworks for treatment prior to discharge. Thus, the proposed project is forecast to increase
runoff from the existing site when the plant is installed, but the increased runoff is not forecast to
cause a substantial alteration of the existing drainage pattern because the increase runoff will be
retained and treated within the WRF itself. During construction the modified runoff will require
implementation of the mitigation measures (4.2-1 through 4.2-3) identified above to control
downstream water quality impacts. With implementation of these measures the potential for
significant adverse impacts will be controlled to a less than significant impact level.
Ramon: this element could be determined “functional” and working as to intent…with a Total
Quality Assurance Management, Systematic Process Observation Technique audit, following 3
or 6 Sigma distribution on a Standard Curve, allowing quality parameters to be observed for
management support for the intent of the given structure.
e. Would the project create or contribute runoff water which would exceed the capacity of
existing or planned stormwater drainage systems or provide substantial additional
sources of polluted runoff?
This project will not increase the peak discharge of surface runoff to the existing drainage area or
provide a substantial additional source of polluted runoff. This finding is based on the fact that
runoff from within the treatment plant site will be collected and returned to the plant for treatment
before discharge. No mitigation is proposed.
Ramon: has the return loop for returning water for treatment been cost analyzed? Has the
public water committee looked at this feature? What is the project cost of returning water?
f. Would the project otherwise substantially degrade water quality?
With implementation of the SWPPP and WQMP, the identified BMPs as outlined above, the project
construction activities are not forecast to have any potential to substantially degrade surface water
quality. Over the long-term the data indicates that percolation of the treated effluent or reuse as
recycled water will not cause any substantial degradation within the Warren Valley Groundwater
Basin. The analysis provided in the U.S. Geological Survey technical report in Appendix 3 verifies
this finding is available upon request to the District. No mitigation is required beyond that already
identified for the SWPPP and WQMP. The U.S. Geological Survey modeled the potential for recharge
of the treated effluent into the onsite recharge ponds to assess future impacts to groundwater levels
and groundwater quality under future discharge scenarios. Appendix 3 contains more detailed
information regarding the model, model assumptions and the model runs. The assumptions included
the assumed future effluent flows, effluent water quality, percolation pond sizes and groundwaterlevel
threshold. The model conducted several 16-year simulations of the effects of the proposed
project on the upper/middle aquifers, the lower aquifer and the deep aquifer. Year 2008 pumping
and recharge patters were used in the model-calibration process.
The following model results were reported in the U.S. Geological Survey evaluation. The simulated
future water levels were determined to not reach the water level threshold of 100 feet below the
ground surface (bgs) after 16 years of recharge. Therefore, no new production wells are needed to
control water levels during the 16-year simulation period. However, the simulated rate of water
level rise indicates that the water-level threshold will be exceeded in the future if wastewater
recharge is continued and there is no pumpage from the East hydrogeologic unit. Therefore, wells
will need to be installed in the future to ensure the 100 foot bgs threshold is not exceeded. An
adaptive mitigation measure for this impact is presented below.
The modeling for water quality parameters concluded that the maximum simulated Total Organic
Carbon (TOC) concentration was about 9 mg/L in the upper/middle aquifer; 0.5 mg/L in the lower
aquifer. The maximum nitrate (NO3) concentration was about 35 mg/L in the upper/middle aquifer
and about 2 mg/L in the lower aquifer. The maximum simulated Total Dissolved Solid (TDS)
concentration was about 420 mg/L in layer 1 and about 300 mg/L in layer 2. The NO3 concentration
is approaching the maximum contaminant level (MCL, 45 mg/L for NO3), but it does not exceed the
MCL. The modeled TDS concentration does not exceed the secondary MCL for TDS, which is 500
mg/L. Based on the modeled data, the groundwater quality downstream of the WRF recharge
ponds will
be degraded relative to the existing concentrations, but it is not forecast to exceed public drinking
water standards. Because the public health will be protected by operation of the proposed WRF, the
project is not forecast to cause significant degradation of the existing groundwater quality in the
groundwater aquifer downstream of the WRF site. Adaptive mitigation to ensure that maximum
contaminant levels for public drinking water standards are not exceeded in the groundwater in the
future.
Ramon: This opens up a bit of historical awareness that has been shared with only a few.
Birds of a Feather, so to speak. Right or wrong, our leadership from the County of San
Bernardino and the Municipal Land Use Authorities have let the people down. Agencies at
the State Level and the Federal Level have since 2004 provided the lead, in that Water
Survey need is high in the priority for land use permits. Included in that is real mitigation for
loss of natural resources, impact on needs for power and water, Police and fire protection,
Flood Control, and the loss of open spaces…inclusive of community parks.
Our local government has for 25 years, not responded to quality of life and development that
is harmonious with the earth here in the Morongo Basin. Only a Total Quality Assurance
Management system as previously described will assure compliance and for the public to
watch for compliance…if we are to make quality decisions, rather than inside control of how
the Morongo basin develops in a way that all life experiences quality of the nature we enjoy.
4.2-5 The District shall install one or more monitoring wells downstream of the WRF. The
well(s) shall be monitored for elevation of the groundwater table below the ground
surface (bgs). If the groundwater table downstream of the WRF recharge site
approaches 100 feet bgs, the District shall initiate pumping to control the groundwater
level. The groundwater extracted may be discharged to the surface if the water quality is
acceptable to the regulatory agencies, or it may be further treated and made available to
the District’s domestic water supply system. The performance standard to be achieved is
that the groundwater table downstream of the WRF recharge facilities shall not rise
above the 100 foot bgs threshold.
Ramon: For this to be meaningful, specific locations for the one or more monitoring wells
must be made. The East hydrogeological unit must consider that water recharge from the
Covington Flats area flows East and West of La Contenta/Yucca Mesa roads and is the source
of water for the Joshua Tree Retreat, all the way to the Pinto Basin Wash. The wells in the
Pinto Basin Wash that are part of the USGS report showing nitrate contamination are in all
probability contaminated by water flowing across Yucca Mesa. Meaning that to date, the
HDWD reports do not reflect that tests have shown nitrates coming from the one working
well near highway 62.
The wells are identified as 28L1-2, 28K1 in the Pinto Basin Wash and 28N1 near state route
62 respectively.
In addition, the current plans do not reflect how the “further treated” water will be returned
for treatment or returned to the District’s domestic water supply. That includes provisions
for monitoring the 100 foot bgs threshold. It is assumed that this would become another
cost for the rate payers not yet given.
4.2-6 The District shall install one or more monitoring wells downstream of the WRF. The
well(s) shall be monitored at least annually for all drinking water standards and
compared to maximum contaminant levels (MCLs) for public drinking water standards. If
concentrations approach any MCL, the District shall install additional treatment at the
WRF to modify the treated effluent by lowering or removing the pollutant of concern to a
level that will prevent the MCL from being exceeded. The performance standard to be
achieved is that the groundwater quality shall not be allowed to exceed any MCL for a
domestic or public drinking water supply.
With implementation of these measures, the water quality of the groundwater aquifer affected by
the proposed project will not be degraded to a level of significant adverse impact.
Ramon: Given that the flow model provided by USGS is simulated, and that the model does
not account for West to East flow of water through the Pinto Mountain Fault near the two
wells in the wash, the once a year test is not sufficient for monitoring and to respond in a
timely fashion.
It is also suggested that the County begin to create a Water survey in the East Hydrogeologic
cells immediately in that this issue should have been tested when the EPA suggested that
Water Surveys be done in 2004. It is also suggested that the Town of Yucca Valley also
begin to create Water Surveys in the East Hydrogeologic area in order to determine the
status of that area west of Yucca Mesa.
g. Would the project place housing within a 100-year flood hazard area as mapped on a
federal Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard
delineation map?
The project does not propose new housing but a portion of the WRF project site is within a 100-year
flood hazard area. According to the Yucca Valley General Plan, the wastewater treatment plant site
and pipeline alignment are in a “A” zone, for 100-year flood hazard potential. Based on the current
site design, the treatment plant will be installed outside of or just on the eastern edge of the flood
hazard zone. To ensure no damage from 100-year flood hazards, the proposed treatment plant will
have to be protected from the 100-year flood hazard by elevating the facility above the 100-flood
level or by armoring the facility from exposure to such hazard. Mitigation is provided below to
accomplish this.
4.2-7 The District shall provide a drainage report that defines the 100-year flood
elevation on the site and shall either elevate the treatment plant facilities above this level
with two feet of freeboard or shall provide protection of the site with a boundary levee
that protects the facilities from exposure to flooding from the 100-year flow across the
property. The final treatment plant facility design shall provide a means of re-routing any
storm flows, including the 100 year flow, around the facility and back into the existing
natural channel on the north side of the site without causing significant erosion in the
channel.
Implementation of this measure is adequate to reduce any adverse effects to the treatment facilities
from onsite flood hazards.
Ramon: For this to be effective, Water Surveys and implementation of this mitigation needs
to be before construction of the WRF or at worst case, at least consistent with construction of
the WRF.
h. Would the project place within a 100-year flood hazard area structures which would
impede or redirect flood
flows?
See the analysis provided in 4.2.g above.
Ramon: see the comment made on 4.2.g above.
i. Would the project expose people or structures to a significant risk of loss, injury or
death involving flooding, including flood as a result of the failure of a levee or dam?
Based on the analyses in the three sections preceding this one, the proposed project has no
potential to expose either people or structures to substantial loss or injury related to flooding,
including failure of a levee or dam. No such existing facilities occur within the upstream area of the
proposed project. No mitigation is proposed.
Ramon: This conclusion regarding no mitigation is only acceptable if the previous two section
mitigations begin before or consistent with construction and completed before occupancy and
startup of the WRF. Otherwise, there is a health and safety probability risk to people and
property.
j. Would the project cause or be exposed to inundation by seiche, tsunami, or mudflow?
There are no water bodies or sources of inundation for the project area by seiche or tsunami. As
within any desert environment, storm runoff can incorporate a substantial amount of sediment and
a “flash flood” event can transport large volumes of sand and rocks, which is comparable to a
mudflow. The mitigation required under issue g. above must include a “bulking” factor as part of the
design to protect the treatment plant facilities from damage from such flows.
Ramon: Both seiche conditions and mud flows occur in the desert. Historically, Native
Americans have records of such conditions. Willy Boys mother and father were both killed by
such a condition.
At the least, such conditions can exasperate compacted soil or decomposed granite, such as
has occurred at the Gatlin/WalMart site where structures and the parking lot are are settling.
No Project Alternative
Regarding hydrology and water quality effects, the no project alternative would eliminate all
construction and all operating activities associated with the proposed project. However, the
rationale for installing the WRF is the nitrate contamination caused by historic disposal of
wastewater to subsurface septic tank leach systems. Thus, the no action alternative has a higher
potential to contribute to or cause violation of water quality standards and to continue degrading
water quality than the proposed project. This water quality standard violation is an adverse impact
that would be substantial and non-mitigable, including potentially substantial adverse public health
effects on the resident population of the District’s service area.
Ramon: The project alternative is not the only alternative. This has previously been
discussed…that localized treatment of human solids and liquids can be accomplished costing
4.5 million dollars, rather than this project cost at 300 million dollars plus the cost for
increasing the treatment from 1 mgd to 6 mgd for buildout. Additionally, the entire district
can be treated rather than just 40% of the community should be connected to phase 1 and 2
at 2 mgd (WRF) as proposed with 60% of the community left out but expected to pay “fairshare”
cost. We have no idea how much fair-share is at this time.
This conclusion given here is flawed in view of the options available that have not been
exercised in a timely manner and now in a rush to address the septic prohibition wrongly
given as the problem.
Concerns were reported to Congress by the EPA in 2004 (Water Surveys) as needs before
issuing of landuse permits. In this case by the Town of Yucca Valley. Also HDWD was
alerted to solutions at meetings with the CRWQC board in 2006 providing ideas that have not
been considered for new construction.
The no project alternative would eliminate the modifications at the project site that are exposed to
flood hazards. It is possible to mitigate these effects on the proposed WRF to a less than substantial
level, but the no project alternative would eliminate these impacts from both a direct and indirect
standpoint.
Ramon: Like wise this problem is also long standing even if not identified by the county of
San Bernardino concerning flood control. There is no reason why this issue cannot be
accomplished without this project as it a problem with long standing history.
The no project alternative would also eliminate the exposure of structures to any flood hazards or
mudflows. Neither project alternative would be exposed to seiches or tsunamis.
Ramon: the issue of seiches has been discussed and is part of the flood control needs that
can be done at anytime and is long overdue.
The no project alternative would eliminate the modifications at the project site that could result in
erosion, sedimentation and other pollution. It is possible to mitigate these adverse effects on the
environment to a less than substantial level, but the no project alternative would eliminate these
impacts from both a direct and indirect standpoint at the project site and along the pipeline
alignments.
Ramon: As given this too is not true, and the problem can be resolved anytime that the
Town of Yucca Valley decides to do this. The 1% tax that the town can adopt would raise
sufficient revenue from sales tax anytime the Town of Yucca Valley decides to take this issue
up and do it!
4.3 UTILITIES / SERVICE SYSTEMS
a. Would the project exceed wastewater treatment requirements of the applicable
Regional Water Quality Control Board?
(Note that some parts of this sub-section have been omitted to focus on the part being questioned
or in need of other action.)
As described in the water quality discussion above, the proposed project will be subject to
wastewater discharge requirements from the Colorado River Basin Regional Board, which must be
met or the wastewater treatment facility cannot operate. As further discussed in Section 4.2 above,
the WRF has been specifically designed to meet the anticipated waste discharge requirements. All
effluent from the proposed wastewater treatment facilities will be discharged to the District’s
recharge basins and percolated into the local groundwater aquifer. The analysis of the water quality
impacts to the Warren Basin groundwater resources is also presented in Section 4.2 above and
determined to be a less than significant adverse impact. The non-point source discharges from the
project will be from construction activities and they will be managed under the mitigation measures
already identified in Section 4.2. Through implementation of the SWPPP and WQMP and use of
identified BMPs for this project, no violations of any water quality objectives or wastewater
treatment requirements is forecast to occur from implementing the proposed project. No additional
mitigation is proposed.
Ramon: It is not clear how the Colorado River Basin Regional Board (CRBRB) will maintain
oversight of this discussion. The HDWD does not have a quality assurance element to
normal operations, hence; the reporting of quality assurance attributes that would confirm
this enforceable and timely are not present. For some while, I have suggested and
independent audit and assessment to provide a Total Quality Assurance Management plan
that is systematically reported based upon levels of quality and metrics become part of the
HDWD/Town of Yucca Valley normal management interface, and in this case to include the
CRBRB.
c. Would the project require or result in the construction of new stormwater drainage
facilities or expansion of existing facilities, the construction of which could cause
significant environmental effects?
As described in Section 4.2, stormwater flows within Yucca Valley may be altered by installation of
the sewer pipelines or the proposed WRF. To address potential impacts to stormwater flows during
construction, this document requires mitigation through effective implementation of best
management practices during construction and operation. Once the pipelines are installed beneath
roadways or across channels, no change in stormwater flow is forecast to occur during operation as
a result of installing the sewer collection system. As described in Section 4.2, stormwater flow
generated within the proposed WRF project site would continue to be discharged to the existing
stormwater surface drainage system. No change in offsite downstream drainage facilities will be
required from implementing the proposed project. Temporary stormwater management measures
will be implemented during construction of the pipeline and wastewater treatment facilities. Longterm
modification of the onsite portion of the existing dry wash that crosses the property will be
required, including either rerouting the flows around the facilities or providing for continued flow of
bulked storm flows through the property. No potential exists to require new major public
stormwater facilities to be constructed or expanded downstream of the project site. No significant
impact is forecast to occur and no mitigation is required.
Ramon: Because this CEQA is silent on riparian water flow (re. Gattlin/WalMart) shopping
center, structure and parking lot collapsing due to liquefaction of “compacted” soil, and
because this problem is a time bomb waiting to happen, what has been argued here is
evidence that this issue remains a problem that can only be resolved by a Water Survey to
depths consistent with alluvial fan dynamics for geology suitable for water flow; meaning
hydrogeological status of the area, starting with the East Hydrological Unit of the Warren
Basin/Pinto fault within the EHU..
No Project Alternative
The no project alternative would continue to contribute to water quality degradation in the Warren
Valley Basin and to the potential exceedances of the nitrate standards in the future. The proposed
project would constitute a major step in eliminating this water quality degradation. Thus, the no
project alternative has a more substantial adverse effect on exceeding wastewater treatment
requirements than the proposed project.
Ramon: As already given, there are alternatives that have been ignored such as localized
treatment solutions for eliminating nitrates.
The no project alternative would not include any direct construction of water or wastewater
facilities. As indicated above, the no project alternative indirectly has a potential to cause
construction of new water treatment facilities and perhaps to require the installation of a large
number of advanced individual treatment systems if the preferred alternative is not implemented.
Thus, the no project alternative may also mandate construction of such facilities that could cause
adverse environmental effects. Based on available mitigation, these no project facilities can
probably avoid significant effects, but this could only be determined on a case-by-case evaluation in
the future. Regarding capacity of wastewater treatment providers, the no project alternative has the
same effect as the proposed action because no existing wastewater treatment provider exists within
the District’s service area at this time. The no project alternative would eliminate any need to
construct stormwater drainage facilities at the WRF site. Although the proposed action would not
cause any substantial adverse effects related to stormwater management issues, the no project
alternative would have less impact because it will not require any modification to such facilities.
Regarding sufficient water supplies, the no project alternative would eliminate any direct demand
for local water supplies. However, over the long-term the implementation of the no project
alternative would continue the current path of degrading the Warren Valley Basin aquifer and this
would cause a substantial adverse impact to water supplies for existing and future uses. Therefore,
the no project alternative’s potential effects on water supplies is concluded to be substantial and
more adverse than the proposed action. Under the no project alternative, the wastewater effluent
solids are managed by individual subsurface septic tank/leach systems. Periodically, all septic tanks
must be pumped and the waste is delivered to a landfill for management. Similarly, the solids from
the WRF will be stabilized at the facility, and then disposed of to a landfill, to a composting facility,
or directly to end users. Because of the increased potential for recycling wastewater effluent solids
from the proposed action, it has a lower environmental effect on solids management than the no
project alternative.
Ramon: this is subject to arguments already given.
4.4 LAND USE / PLANNING
a. Would the project physically divide an established community?
(Omitted with no comment)
4.5 TRANSPORTATION / TRAFFIC
a. Would the project cause an increase in traffic which is substantial in relation to the
existing traffic load and capacity of the street system (i.e., result in a substantial increase
in either the number of vehicle trips, the volume to capacity ratio on roads, or congestion
at intersections)?
(Omitted with no comment, including sub elements)
4.6 NATURAL RESOURCES
(Omitted without comment, including all sub-elements, except those remaining with comment.)
4.6-11
f. Would the project conflict with the provisions of an adopted Habitat Conservation Plan,
Natural Community Conservation Plan, or other approved local, regional, or state habitat
conservation plan?
There is currently no adopted Habitat Conservation Plan, Natural Community Conservation Plan, or
other approved local, regional, or state habitat conservation plan associated with the proposed
project site. Therefore, no mitigation measures need to be implemented and the project’s impacts
on such resources will be nonsignificant without mitigation.
Ramon: Please see the Sonaran/JTNP open space group study for the Habitat Conservation
Planning currently ongoing since 2008.
No Project Alternative
The no project alternative would eliminate all potential to disturb listed or sensitive species, and
would also eliminate the permanent loss of up to 30-35 acres of low quality creosote bush scrub
habitat at the WRF site and the pump station locations. Approximately 10 acres of this habitat will
be disturbed as a result of installing the pipelines that will cross stream channels. The stream
channel disturbances and these impacts and requirement to obtain regulatory permits would also be
eliminated under this alternative. Over the long-term the indirect effects of requiring installation of
water treatment units to remove nitrate may cause the permanent loss of several acres of creosote
bush habitat. Mitigation available for the proposed action would be sufficient to control future
indirect adverse effects of the no project alternative to a less than substantial level, comparable to
the proposed project.
The no project alternative would also eliminate any interference with movement of wildlife, conflicts
with local policies protecting biological resources, or conflicts with adopted habitat management
plans. No such plans apply to the project area.
4.6.2 Geology and Soils
a. (Omitted without comment, except to reiterate that comments made in the remaining parts of
this subsection have already been questioned regarding the assumptions that lack science and are
assumed rather than tested.)
• Risk Class IV, Ordinary Risk Tolerance: The vast majority of structures in urban areas;
most commercial and industrial buildings, small hotels and apartment buildings, and
single family residences.
With implementation of the above measure, the proposed project will not subject humans to
potential substantial adverse geologic constraints/effects, including the risk of loss, injury, or death
involving rupture of a known earthquake fault or strong seismic ground shaking. Measures to meet
this seismic mitigation measure include enhanced foundation support; use of higher quality
materials and more steel in the structures; and other similar measures that ensure the proposed
WRF can function after a major seismic event. In addition, the proposed project is not located on
steep slopes and is also not subject to landslides. There is little potential for liquefaction to occur in
the project area, as depth to groundwater has been identified by the U. S. Geological Survey to be
over 100 feet below the ground surface.
The 1995 Town of Yucca Valley Comprehensive General Plan, Seismic Safety Element Exhibit V-1,
identifies two other local faults with identified Alquist-Priolo Special Studies Zones, the Eureka Peak
Fault located west of the project site and the Burnt Mountain Fault, located west of the Eureka Peak
Fault. Although these faults appear not to pose a rupture hazard for the WRF, the sewer collection
system will cross these faults, in addition to the Pinto Mountain Fault. Future pipelines crossing any
of these fault zones may experience damage from rupture associated with future seismic events on
these faults. Mitigation is provided to address the future management of such damage to sewer
pipelines crossing the three faults’ Special Studies Zones.
4.6-13 Any pipelines crossing the Alquist-Priolo Special Studies Zones for the Pinot
Mountain, Eureka Peak and Burt Mountain Faults could be subject to damage due to
ground rupture associated with these faults. Any construction of facilities in or pipelines
crossing this zone is required to have detailed structural engineering studies to ensure
designs that can safely accommodate the anticipated ground movement(s), or to be
immediately repairable following a seismic event along any of the three fault.
With implementation of the above measure, the potential degradation to the environment from fault
rupture damage to the sewer collection pipelines crossing the identified Special Studies Zones can
be controlled to a less than significant impact level.
Ramon: This does not consider the issue with soil that is in a state of liquefaction because
the wash or area in a riparian blue-line underground stream bed.
4.6-16 Soils, where exposed, will be stabilized with hay bales or aggregate cover.
Ramon: Suggest straw bales rather than hay. That would eliminate the rat and rabbit
population that would feast on the Hay.
No Project Alternative
The proposed action would construction and operation the WRF and a sewer collection system. By
eliminating these facilities, the no project alternative eliminates the potential to expose structures
and sewer pipeline to seismic or other geological hazards. This alternative also eliminates any direct
soil erosion or sedimentation effects. Indirectly, future water treatment facilities and individual
advanced subsurface systems will also disturb a substantial amount of land, which can also cause
erosion and sedimentation. Available mitigation can control such impacts to a less than substantial
level.
The no project alternative would have substantially greater impacts due to continued septic tank
failures within shallow soils and soils with subsurface hardpan layers which contribute to such
failures. The potential impacts from the no project alternative due to such soils is considered to be a
substantial adverse impact.
Ramon: There is insufficient science to proclaim the issues given here. At this time, Action
Pumping is finding evidence of nitrate where septic tanks do not exist. Additionally, there is
also nitrate found at the well sites in the HDWD. There is also evidence of bacteria that is
above the acceptable limits coming from tap water, tested as such by independent lab
analsis. USGS, Appendix 3 has reported that Mental Physics was tested at one well that is
no where near a septic tank, found to exhibit high nitrates above limits allowable by the
Health Department and the CRWQCRB acceptable limits.
4.6.3 Mineral Resources
(Omitted without comment)
4.6.4 Visual Resources / Aesthetics
a. Would the project have a substantial adverse effect on a scenic vista?
The sewer collection system pipeline installation will not change land uses, or cause any
aboveground visual impacts. The WRF site will change from open space with desert vegetation to
above ground wastewater treatment facilities and recharge basins. The above ground facilities
proposed would be located within an area that already contains interspersed developed lots, both
residential and industrial. The proposed WRF facilities will be approximately the same height as
surrounding structures and facilities, but will exhibit greater mass. In addition, the above ground
pipe connections will clearly identify the facilities a n(s) industrial in character. Regardless, the WRF
facility will become part of the existing suburban setting. These changes in the visual setting after
development of the WRF will be adverse, but the degree of change at the WRF site and surrounding
area is not considered to substantially adverse. No significant adverse impact to scenic vistas will
occur on an area-wide basis.
Ramon: the structures can be built “Desert Suitable” to maintain thermal mass, reducing the
above grade impact, and to reduce both heating and cooling recurring cost for maintaining
the working comfort of the occupants of the WRF.
b. (Omitted without comment)
c. (Omitted without comment)
d. (Omitted without comment)
4.6-18 A facility lighting plan shall be prepared and shall demonstrate that glare from
operating and safety night lights that may create light and glare affecting adjacent
occupied property are sufficiently shielded to prevent light and glare from spilling into
occupied structures. This plan shall be implemented in conformance with the Town of
Yucca Valley Night Skies Ordinance and it shall be reviewed and approved by the District
staff prior to installation of the night lights.
Ramon: The Wastewater Advisory Group suggested bollard lighting for the normal walking
route at night; possibly even using low voltage lamps. Additionally, shielded lamps sufficient
to light up the site in the event of an emergency could also be added to use when needed.
No Project Alternative
(Omitted without comment)
4.7 POPULATION AND HOUSING
a. Would the project induce substantial population growth in an area, either directly (for
example, by proposing new homes and businesses) or indirectly (for example, through
extension of roads or other infrastructure)?
This project is the construction and installation of wastewater treatment facilities, which are
intended to improve the quality of regional groundwater supplies through the removal of septic
tanks. It is intended only to provide services for existing and planned development. There is a
limited potential for the provision of sewer service to encourage undeveloped parcels to develop
within the Town of Yucca Valley. However, without the proposed project, those parcels could be
developed anyway by installing advanced onsite wastewater septic systems where the proposed
system is designed to remove no less than 50 percent of the nitrogen released in the effluent
(Advanced Treatment, denitrifying systems). Costs for such systems are more expensive than the
cost of hooking up to the District’s WRF system, but they do provide an opportunity for development
that is feasible.
The type and density of development in the District’s service area is controlled by land use
designations established by the agencies having jurisdiction over such issues; in the project area
the Town of Yucca Valley controls land use. As such, this project is considered growth
accommodating, not growth-inducing, in that it will help provide sewer service to development that
is approved or allowed by the agencies having jurisdiction over land use issues. Since an
alternative means of treating sewage (individual advanced treatment, denitrifying systems) is
available that would allow for development of vacant parcels, the proposed sewer system does not
constitute or eliminate an unavoidable cap or constraint on future development.
The potential for growth inducement, discussed in detail in Chapter 6, related to infrastructure
improvements is based on the elimination of some development constraint in place at a given time.
As the discussion above and in Chapter 3 indicates, there are alternative ways to develop parcels of
land within the Town because of the advanced individual subsurface treatment systems, or for large
developments the installation of package treatment systems. Thus, the proposed wastewater
infrastructure collection system is not forecast to result in growth inducement or any growth beyond
that which could occur without the installation of this system. Implementation of the project has no
potential to cause or induce any substantial or significant population growth, directly or indirectly.
Ramon: Localized Treatment can be applied to the entire community for a fraction of the
WTF alternaitive. The extreme cost difference would be a development enhancement, in that
the systems would be shared with others in any localized area or development. For
example, a 325,000 gallon per day system can be increased to about 1 mgd system with less
than substantial cost to do so. These systems are far less expensive to use and to buy into
as development occurs in any localized or new area within the town. This would also reduce
the cost of pipe and amount needed, reducing the size of the feed lines and the treatment
facility; thus reducing risk of damage from seismic activity or events.
b. (Omitted without comment)
c. Would the project displace substantial numbers of people, necessitating the
construction of replacement housing elsewhere?
The project has no potential to impact any existing housing or cause the displacement of people.
No impact is identified and no mitigation is required. The proposed wastewater treatment facilities
have no potential to adversely impact any low income or ethnic communities, i.e., no environmental
justice impacts.
Ramon: This is blatantly untrue! The ethenic groups in the community are amongst the
lowest paid people, inclusive of single mothers with children, disabled and elderly people far
under the average income. They would be forced to move or sell their homes in order to
survive. There are increasing numbers of people and families that have lost their jobs,
increasing the numbers of low income daily. This element could also include the numbers
that are growing who are becoming homeless.
No Project Alternative
The no project alternative would have comparable effects on future growth and no known direct
effects on existing housing resources. In a strange turn of events if this alternative were selected, a
consequence could be a short-term moratorium on development, unless the Regional Board would
accept individual advanced wastewater treatment systems for new development or through retrofit
of existing development. Under this scenario the no project alternative could have a more adverse
effect on both the existing and future local population, and possibly housing if abandoned, than the
proposed action.
Ramon: The Regional Board already has been shown that most people are in compliance with
reasonable cleaning schedules, with lab reports that show compliance with Regional Water
Quality Control standards. Those showing lack of compliance are most often businesses and
institutions such as schools and parks operated by local government or unified school
districts, and other like institutions.
The statement is flawed as reasoned.
4.8 CONSTRUCTION ASPECTS
Construction impacts and related mitigation measures are described in various parts of Section 4 of
this document. Many of the construction impacts addressed in this document are subject to
mitigation and the proposed project can be implemented without any significant adverse short-term
environmental effects. Specifically, air emissions, biological resources, cultural resources, geology
and soil constraints, management of construction hazards, management of construction storm water
runoff, mineral resources, noise, and traffic effects have all been evaluation and determined to not
cause substantial negative environmental effects. Please refer to the discussion of these specific
issues in the pertinent sections of this document.
Ramon: please refer to pertinent section comments and issues where given in this
document.
No Project Alternative
None of the direct construction impacts attributable to the proposed action would occur under the
no project alternative. If it is assumed that implementation of the no project alternative must result
in installation of individual advanced subsurface treatment systems and nitrate treatment facilities,
some more limited indirect construction impacts would occur under this alternative in the future. As
in the case of the proposed action, available mitigation measures are considered sufficient to reduce
potential no project alternative construction effects to a less than substantial level.
Ramon: please refer to pertinent section comments and issues where given in this
document. Specifically where the mitigation is argued as being inadequate or flawed in
concept.
4.9 ENERGY ISSUES
Overall, the project will consume energy during the construction period, with the use of petroleum
based fuels for equipment and vehicles. Electrical energy will be consumed for wastewater
treatment operations and pump stations into the long-term future. An estimated 2.9 million KWhr
of electricity will be required to operate each year, or about 8,000 KWhr per day. According to two
California Energy Commission documents, the “2008 Integrated Energy Policy Report Update” and
the “California Energy Demand 2008-2018 Staff Revised Forecast” adequate energy demand within
the Southern California Edison and Southern California Gas service areas is forecast to grow by
about 1.5% per year between 2008 and 2018. Adequate energy resources are available to serve
the region, based on the assumption that new electricity power generation systems will be installed
at an accelerated rate in accordance with the demand forecasts. Based on these reports, adequate
energy resources can be made available to support forecast growth within the project area, which is
located in both company’s service areas. Thus, adequate electricity resources are assumed to be
available from Southern California Edison to support operation of the WRF. The greenhouse gas
(GHG) emissions related to electricity consumption are presented and determined to be a less than
substantial adverse effect in Sub chapter 4.1. Thus, the proposed WRF use can be served through
existing energy resources, such that energy impacts should be minimal.
Ramon: What is the cost impact of the projected energy demand that is given to be needed?
What will be the delivery and use cost if divided by the current district population?
No Project Alternative
(Omitted because of no argument for the entire Alternative…starting at 4.17 comments are as
given)
4.17 OTHER IMPACT ISSUES
(Omitted without comment)
4.17.6 Environmental Justice
The project site is located within a community that is generally below the economic level of other
communities in the County, due to having a high percentage of retirees and seasonal residents.
However, there are no industries or contaminated sites in or around the project area such that this
project would comprise a new hazard and additional hazard to a particular population. The proposed
project will temporarily impact those residents along the pipeline routes and in the vicinity of the
treatment plant, but it has no potential to adversely impact any low income or ethnic communities
in the long term. The project itself will be an improvement to area services that will benefit the
population.
Ramon: Recently, USGS tested the most southern well at Mental Physics, which is not in the
area of the wells in the Pinto Basin Wash. That well is identified in Appendix 3… “with the
exception of nitrate plus nitrite analyzed in the February 2009 sample from 1N/6E- 28N01S.
The nitrate plus nitrite concentration in the sample collected at 28N1 was 18.4 mg/L as N;
the EPA MCL for nitrate is 10 mg/L. It is given here that this well is being contaminated
from problems outside of the Mental Physics site and the cause needs to be addressed.
No Project Alternative
Due to the type of infrastructure project envisioned by the proposed action, no environmental
justice issue have been raised by implementing proposed action. For the no project alternative no
direct environmental justice issues have been identified. However, if it is assumed that
implementation of the no project alternative may result in continued contamination of groundwater
within the District’s service area by nitrates and other constituents of the septic tank discharges,
then the whole community, including those seniors and low-income residents could be substantially
impacted by being forced to spend substantially more of their dollars for drinking water in the
future.
Ramon: the option provided by Mahaffey Innovative Technology Inc., provides for clean
water, at a substantially reduced cost to the rate payers, meaning that low income families
can benefit from a no project alternative as given here. Thus by employing a no project
alternative, the community can change direction with no impact to the low income residents
of the community.
4.18 INVASIVE SPECIES
(Omitted without comment)
Chapter 5 CEQA CHECKLIST FORM
(Omitted without comment)
End of comments :
|
| Early report Warren Valley Basin #118 |
|
Colorado River Hydrologic Region California’s Groundwater
Warren Valley Groundwater Basin Bulletin
Warren Valley Groundwater Basin
• Groundwater Basin Number: 7-12
• County: San Bernardino
• Surface Area: 17,200 acres (26.9 square miles)
Basin Boundaries and Hydrology
The Warren Valley Basin is located in the northwestern portion of the
Colorado Desert Hydrologic Study Area. This basin includes the waterbearing
sediments beneath the town of Yucca Valley and the surrounding
area. The northern boundary of the basin is the Pinto Mountain fault and the
southern boundary is the bedrock outcrop of the Little San Bernardino
Mountains. The Warren Valley Basin is bounded on the east by a bedrock
constriction called the “Yucca barrier” and on the west by a bedrock
constriction and a topographic divide between Warren Valley and Morongo
Valley. Precipitation in this basin ranges from 8 to 12 inches per year, with
an average rainfall across the basin of about 10 inches (USDA 1999).
Hydrogeologic Information
Water Bearing Formations
The productive water-bearing materials in this basin consist of
unconsolidated to partly consolidated Miocene to Quaternary continental
deposits (Mendez and Christensen 1997). The continental deposits
regionally are interpreted to range up to 10,000 feet in thickness (Moyle
1984); however, wells in Warren Valley Basin reach as deep as 1,610 feet
without encountering bedrock. Geophysical studies suggest that the Warren
Valley Basin may exceed a depth of 2,000 feet (Whitt and Jonker 1998).
The main productive water-bearing deposits are unconfined interbedded
gravels, conglomerates, and silts deposited in alluvial fan systems (Schaefer
1978, BEE 1994). These deposits have an average of about 11 percent
specific yield (Lewis 1972) and well yields up to 4,000 gpm.
Restrictive Structures
The Pinto Mountain fault zone juxtaposes alluvial valley fill material against
consolidated bedrock. Data to evaluate whether this fault is a barrier to water
at the boundary of the Warren Valley Basin is sparse, but the Pinto Mountain
fault is a barrier to groundwater flow toward the east at the Copper Mountain
Valley Basin - Joshua Tree Basin boundary (Mendez and Christensen 1997).
A north-trending basement high causes a sharp change in water level
between the towns of Yucca Valley and Joshua Tree, showing a drop of
about 400 feet to the east (“Yucca barrier” of Lewis 1972).
Recharge Areas
Natural recharge to the basin is mainly from direct percolation of
precipitation and percolation of ephemeral streamflow from Water Canyon in
the north and Covington Canyon in the south (BEE 1994; Mendez and
Christensen 1997; Whitt and Jonker 1998). Lewis (1972) suggests that
annual recharge may not exceed 200 af, but actual recharge amounts are
poorly constrained and quite variable from year to year. Some minor inflow
may come from groundwater moving through fractures in the adjacent
Colorado River Hydrologic Region California’s Groundwater
Warren Valley Groundwater Basin Bulletin 118
Last update 2/27/04
bedrock. Percolation of septic tank effluent also contributes to recharge of
groundwater. State Water Project water delivered via the Morongo Basin
Pipeline provides recharge through spreading grounds near the Yucca Valley
Airport (Hanson 1999).
Groundwater Level Trends
Hydrographs of wells in the Warren Valley Basin show water levels in 1998
above the 1986 levels (Hanson 1999). Most hydrographs show a general
lowering of water levels from 1986 through about 1992 and then recovery of
water levels through 1998. The range in elevation of water levels is up to
220 feet since 1986 (Hanson 1999). Groundwater in the Warren Valley
Basin appears to flow northward from the Little San Bernardino Mountains
to the Pinto Mountain fault and then east toward Twentynine Palms (Lewis
1972; Mendez and Christensen 1997). Groundwater flows eastward across
the “Yucca barrier,” a subsurface structure associated with an eastward
lowering of groundwater water levels into the Joshua Tree Basin (Lewis
1972).
Groundwater Storage
Groundwater Storage Capacity. Lewis (1972) calculated 106,000 af of
groundwater in storage in 1958 using a saturated thickness of 150 feet, a
specific yield of 11percent, and an area of 6,400 acres. Lewis (1972)
assumed that prior to 1948, groundwater levels were probably static. If so,
then this storage value would represent a steady-state basin under natural
conditions. According to Lewis’ maps, additional storage space is available
above the water levels of 1958. A total storage capacity of about 568,000 af
for the Warren Groundwater Basin can be estimated using an area of 17,200
acres, an average specific yield of 11 percent, and an average total thickness
of 300 feet.
Groundwater in Storage. Lewis (1972) calculated 106,000 af of
groundwater in storage in 1958 using 150 feet saturated thickness, 11percent
specific yield, and 6,400 acres. The annual report of the Warren Valley
Basin Watermaster (Hanson 1999) does not determine available storage.
Groundwater Budget (Type-A)
Not enough data exist to compile a detailed groundwater budget for this
basin. For the 1998-1999 water year, total extraction amounted to 2,201 af
which includes 312 af pumped by the Blue Skies Country Club mainly for
irrigation of a golf course (Hanson 1999). HDWD recharges State Water
Project water, which amounted to 2,237 af for water year 1998-1999 (Hanson
1999). An estimate of natural recharge rate for this area was determined to
be about 2.8 percent of precipitation by Whitt and Jonker (1998). Using the
area of the watersheds for the basin, the reported precipitation, and a 2.8
percent recharge rate, the natural recharge for water year 1998-1999 is
estimated to be about 330 af.
Groundwater Quality
Characterization. Water quality data for 1999 from the Hi-Desert Water
District (HDWD 2000) indicates that the average water has calcium-sodium
bicarbonate character. Total dissolved solids concentration ranges from 129
Colorado River Hydrologic Region California’s Groundwater
Warren Valley Groundwater Basin Bulletin 118
Last update 2/27/04
to 269 mg/L, with an average of 196 mg/L (HDWD 2000). Electrical
conductivity ranges from 290 to 450 μmhos/cm and averages about 360
μ mhos/cm (HDWD 1999).
Impairments. Fluoride concentration of groundwater exceeds 1.4 mg/l in
some wells in the Warren Valley Basin (BEE 1994).
Water Quality in Public Supply Wells
Constituent Group 1 Number of
wells sampled 2
Number of wells with a
concentration above an MCL 3
Inorganics – Primary 18 1
Radiological 18 1
Nitrates 18 5
Pesticides 16 0
VOCs and SVOCs 16 0
Inorganics – Secondary 18 3
1 A description of each member in the constituent groups and a generalized
discussion of the relevance of these groups are included in California’s Groundwater
– Bulletin 118 by DWR (2003).
2 Represents distinct number of wells sampled as required under DHS Title 22
program from 1994 through 2000.
3 Each well reported with a concentration above an MCL was confirmed with a
second detection above an MCL. This information is intended as an indicator of the
types of activities that cause contamination in a given basin. It represents the water
quality at the sample location. It does not indicate the water quality delivered to the
consumer. More detailed drinking water quality information can be obtained from the
local water purveyor and its annual Consumer Confidence Report.
Well Production characteristics
Well yields (gal/min)
Municipal/Irrigation Range: 10 - 4,000 Average: 350 (25
wells)
Total depths (ft)
Domestic
Municipal/Irrigation
Active Monitoring Data
Agency Parameter Number of wells
/measurement frequency
Hi Desert WD Groundwater
levels.
17 wells/monthly (Brown 2000).
Hi Desert WD Minerals, organic
and inorganic
chemicals.
11 wells/quarterly (Schwab
2000).
Hi Desert WD Coliform. 11 wells/weekly (Schwab 2000).
U.S. Geological
Survey
Quality 7
U.S. Geological
Survey
Groundwater
levels.
10
Colorado River Hydrologic Region California’s Groundwater
Warren Valley Groundwater Basin Bulletin 118
Last update 2/27/04
Basin Management
Groundwater management: The Hi Desert WD is the court appointed
watermaster for this adjudicated basin. The
Warren Valley Basin Management Plan was
adopted in 1991 (Hanson 1999).
Water agencies
Public Hi Desert WD, Mojave Water Agency.
Private
Selected Bibliography
Akers, J.P. 1986. Geohydrology and Potential for Artificial Recharge in the Western Part of
the U.S. Marine Corps Base, Twentynine Palms, California, 1982-83. U.S. Geological
Survey Water-Resources Investigations Report 84-4119. 18 p.
Bader, J.S. 1963. Effect of Faulting in Alluvium on the Occurrence, Movement, and Quality
of Ground Water in the Twentynine Palms Area, California (abstract). Geological
Society of America Special Paper 73. 22 p.
________. 1966. Records of Water Level and Pumpage in Joshua Tree National Monument,
California. U.S. Geological Survey Open-File Report. 3 p.
Bookman-Edmonston Engineering Inc. (BEE). 1994. Regional Water Management Plan.
Mojave Water Agency, Apple Valley, California. 135 p.
Brown, J. 2000. Hi Desert Water District. Telephone conversation with R.R. Davis
(Department of Water Resources), August 22, 2000.
California Department of Water Resources (CDWR). 1960. Data on Water Wells and Springs
in the Yucca Valley-Twentynine Palms Area, San Bernardino and Riverside Counties,
California. Bulletin 91-2. 163 p.
________. 1984. Twentynine Palms Ground Water Study. Southern District Report. 109 p.
Downing, D.J. 1974. Records of Water Level and Pumpage for 1973 in Joshua Tree National
Monument, California. U.S. Geological Survey Open-File Report. 15 p.
________. 1977. Ground-Water Data for 1974-75 in Joshua Tree National Monument,
California. U.S. Geological Survey Open-File Report 77-80. 34 p.
________. 1978. Ground-Water Data for 1976-77 in Joshua Tree National Monument,
California. U.S. Geological Survey Open-File Report 78-854. 34 p.
Freckleton, J.R. 1982. Ground Water in the Twenty-Nine Palms Indian Reservation and
Vicinity, San Bernardino County, California. U.S. Geological Survey Water-Resources
Investigations Report 82-4060. 46 p.
Hanson, J.C. 1999. Annual Report of the Warren Valley Basin Watermaster for Water Year
1998-99. Yucca Valley, California: Hi Desert Water District.
Hi Desert Water District (HDWD). 1999. 1998 Annual Water Quality Report. April 1999.
Yucca Valley. 2 p.
Hi Desert Water District (HDWD). 2000. WaterNotes: Annual Water Quality Report. June
2000. Yucca Valley. 4 p.
Lewis, R.E. 1972. Ground-Water Resources of the Yucca Valley-Joshua Tree Area, San
Bernardino County, California. U.S. Geological Survey Open-File Report. 51 p.
Mendez, G.O. and A.H. Christensen. 1997. Regional Water Table (1996) and Water-Level
Changes in the Mojave River, the Morongo, and the Fort Irwin Ground-Water Basins,
San Bernardino County, California. U.S. Geological Survey Water-Resources
Investigations Report 97-4160. 34 p.
Miller, G.A. 1968. Test-Drilling and Pumping-Test Data, Joshua Tree National Monument,
California, 1968. U.S. Geological Survey Open-File Report. 13 p.
Colorado River Hydrologic Region California’s Groundwater
Warren Valley Groundwater Basin Bulletin 118
Last update 2/27/04
________. 1970. Records of Water Level and Pumpage for 1969 in Joshua Tree National
Monument, California. U.S. Geological Survey Open-File Report. 17 p.
________. 1971. Records of Water Level and Pumpage for 1970 in Joshua Tree National
Monument, California. U.S. Geological Survey Open-File Report. 16 p.
________. 1972. Records of Water Level and Pumpage for 1971 in Joshua Tree National
Monument, California. U.S. Geological Survey Open-File Report. 17 p.
________. 1973. Records of Water Level and Pumpage for 1972 in Joshua Tree National
Monument, California. U.S. Geological Survey Open-File Report. 17 p.
Moyle, W.R., Jr. 1974. Geohydrologic Map of Southern California. U.S. Geological Survey
Water-Resources Investigations Report 48-73.
________. 1984. Bouguer Gravity Anomaly Map of the Twentynine Palms Marine Corps
Base and Vicinity, California. U.S. Geological Survey Water-Resources Investigations
Report 84-4005.
Schaefer, D.H. 1978. Ground-Water Resources of the Marine Corps Base, Twentynine
Palms, San Bernardino County, California. U.S. Geological Survey Water-Resources
Investigations Report 77-37. 29 p.
Schwab, S. 2000. Hi Desert Water District. Telephone conversation with R.R. Davis
(Department of Water Resources), August 22, 2000.
United States Department of Agriculture (USDA). 1999. California Annual
Precipitation , scale 1:850,000, 1 sheet.
Weir, J.E., Jr., and J.S. Bader. 1963. Ground Water and Related Geology of Joshua Tree
National Monument, California. U.S. Geological Survey Open-File Report. 123 p.
Whitt, A. and K. Jonker. 1998. Groundwater Survey of the Joshua Tree and Copper
Mountain Subbasins, Joshua Tree, California. Consultant’s report prepared by Western
Water Surveys for Joshua Basin Water District.
Errata
Changes made to the basin description will be noted here.
|
| Gov. Arnold Schwarzenegger declares drought |
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SACRAMENTO - Gov. Arnold Schwarzenegger on Wednesday proclaimed a statewide drought after two years of below-average rainfall and other factors. Executive order: (S-06-08)
"For the areas in Northern California that supply most of our water, this March, April and May have been the driest ever in our recorded history," Schwarzenegger stated in his executive order. "As a result, some local governments are rationing water, developments can't proceed and agricultural fields are sitting idle. We must recognize the severity of the crisis we face."
The executive order directed the state's response to unusually dry conditions that are damaging crops, harming water quality and putting areas at risk of fire across California. Many communities already are requiring water conservation or rationing.
The statewide drought declaration is the first since 1991, when Gov. Pete Wilson acted in the fifth year of a drought that lasted into 1992.
The order directs the state Department of Water Resources to speed water transfers to areas with the worst shortages. It also tells state officials to help local water districts with conservation and directs agencies to help farmers suffering losses.
California depends on winter snow accumulation in Northern California's Sierra Nevada for much of its summer water supply. But March, April and May were the driest winter months on record, forcing water use cutbacks by farmers and urban residents alike.
The governor has warned that conditions could be even worse in 2009 if there is another dry winter. Schwarzenegger is expected to use the drought declaration to promote his nearly $12 billion proposal to build more reservoirs and a canal to direct water around the troubled Sacramento-San Joaquin Delta.
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| Water ration looms as reservoir levels plummet |
Northern California reservoir is nearing its lowest point in 3 decades.
By PAT BRENNAN
The Orange County Register
An important California reservoir is nearing its lowest level in 30 years, and other state reservoirs also are very low – more evidence of a gathering water crisis that could lead to mandatory rationing in Southern California by next year, state officials say.
The Oroville Reservoir in Northern California, a major supply reservoir for water that eventually flows into the Southern California region, is down to 38 percent of its capacity, according to the state Department of Water Resources. By Sept. 30, Oroville, about 75 miles north of Sacramento, is expected to hit its lowest level since 1977, and by year's end, the lowest level since records have been kept, said Wendy Martin, the statewide drought coordinator.
The agency's Web site says precipitation statewide was 30 percent of average in April, May and June, the sixth driest of 114 years on record – powerfully affecting the Sierra snow pack, which melts and drains into Oroville. "I think it is unusual to have such a large facility so low, with the number of people who depend on that facility," Martin said.
"One of the concerns that we have as water managers is people not recognizing the severity of the conditions."
Other important reservoirs are down as well, including Shasta, which is at 45 percent.
Lester Snow, the director of Water Resources, will address the Metropolitan Water District board in Los Angeles Tuesday about the low reservoir levels and the need for further conservation.
One topic of discussion might be creation of a "drought water bank," as was done in the early 1990s, which would bring buyers and sellers of water together to balance supplies, said Metropolitan assistant general manager Roger Patterson. Much depends on how much rain the state receives during the coming winter months.
"It's going to be an ongoing story here over the next several months, kind of no matter how it plays out," Patterson said. "Either there is going to be widespread rationing around the state, or we dodge the bullet and it gets wet."
Although the latest low numbers will not trigger any formal alerts, water agencies and state officials have been warning Californians for months about severe shortages to come.
In June, Gov. Arnold Schwarzenegger declared a statewide drought, and a state of emergency in nine central California counties.
In Orange County, water agencies, including the Municipal Water District of Orange County, have been urging residents to reduce their water use.
Tightened supplies are likely to drive up water rates, water agency officials say. And if the coming winter is relatively dry, local water agencies could impose rationing next year, said Karl Seckel, assistant general manager for the Municipal Water District.
"We're laying the groundwork for mandatory rationing in 2009 – meetings, plans are being laid, so if we have to implement it, we can flip the switch and go to mandatory," he said.
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| California Water, a crisis we can't ignore... |
|
Following information from Hi-Desert Water Website
Despite intense media attention and focus by the Governor and legislators, the public is largely unaware of the state’s water problems. The Association of California Water Agencies (ACWA), a coalition of 450 public water agencies, has launched a statewide effort, entitled “California’s Water: A Crisis We Can’t Ignore,” to educate Californians about critical challenges now confronting the state’s water supply and delivery system.
Drawing on successful models for other key public policy issues, the education program will reach the public directly through television, radio and print advertising, as well as through the Internet and community outreach.
ABOUT THE PROBLEM:
Water is essential to California’s quality of life. Our robust economy depends on it. Our families and communities cannot thrive without it. And it is an integral part of California’s physical beauty and diverse environment.
Unfortunately, California’s water system is in a crisis. For the first time in the state’s history, the water supply and delivery system may not be able to meet our growing needs. At the same time, critical environmental resources are in peril. From aging infrastructure to population growth to climate change, we face a complex set of problems that threaten the future of California’s population, economy and environment.
www.calwatercrisis.org
|
| California farmers clash over Delta water "Farmer vs Farmer" |
California farmers' ads clash over Delta water
By Matt Weiser - Sacramento Bee
Published 12:00 am PDT Thursday, September 4, 2008 Story appeared in MAIN NEWS section, Page A1
California's ageless struggle over water has seen battles between man and nature, between cities and farms, and, of course, between rich and poor.
Now it's farmer vs. farmer.
In an advertising slugfest in newspapers and on television in recent weeks, farming interests have waged a war of words over proposals to build a canal to divert water around the Sacramento-San Joaquin Delta. The Delta, hub of the state's water system, is threatened by environmental collapse. This has reduced deliveries to farms in the San Joaquin Valley and cities throughout California. Some view a canal as the solution.The fracas between farmers began last month when Dino Cortopassi, a lifelong Delta farmer and produce packer, bought full-page ads in The Bee and Stockton Record newspapers attacking the canal. He also purchased ads on KCRA-TV in Sacramento.
Cortopassi fears a canal will ruin the Delta environment and its farming economy.
His ads specifically target Gov. Arnold Schwarzenegger, a leading advocate for a canal.
Cortopassi, 71, was a major donor to Schwarzenegger's campaigns. But he recently quit the Republican Party over the matter, and is now registered as an independent."I have served as a catalyst to get this thing where it should be in the public eye," he said. "I will fight to the death to protect the Delta, because I love it."
In response, a coalition of politically active farmers in the San Joaquin Valley last week purchased a full-page ad in The Bee targeting Cortopassi. These farmers depend almost entirely on Delta water, and consider a canal the best fix. "Shame on you, Dino Cortopassi," shouts their ad, which goes on to criticize his "desperate attempt to confuse the issues."
It was signed by Jean Sagouspe, a Los Banos farmer, and purchased by California Westside Farmers State Political Action Committee. Many members of the PAC buy their water from Westlands Water District in Fresno County, the largest agricultural consumer of Delta water. Sagouspe is Westlands' board chairman. He did not respond to a request for comment.
Sarah Woolf, treasurer of the PAC, said Westlands itself is not a member of the PAC.
She said the committee's ad was "not an attack on Dino." Instead, the goal was to rebut his claim that taxpayers will bear the burden of building a canal.
"It's not going to be paid for by taxpayers. It's going to be paid for by water users," said Woolf, also spokeswoman for Westlands Water District. "Westlands will pay their share for it and have stated so publicly many times."
Schwarzenegger, however, is pushing a state water bond that includes nearly $2 billion that could be used for initial studies for a canal. Cortopassi has likely spent more than $200,000 on his ad campaign so far, all of it on his own. His most recent ad – in full color – is in today's Bee.
He claims Schwarzenegger is holding the water bond out as a carrot to San Joaquin Valley legislators to induce them to support a tax increase to balance the overdue state budget.
Schwarzenegger denied that.
"We don't trade water for the budget or vice versa," the governor told the Associated Press.
The tussle highlights the fractious nature of water politics in California, said Barbara O'Connor, a communications professor at California State University, Sacramento, and director of its Institute for the Study of Politics and Media.
She said the ads are not aimed at the general public, but at opinion leaders."There are huge economic interests at stake here, and the public is almost peripheral to that," she said.
Where the two sides stand depends entirely on where they get their water. Both depend on Delta water. But Cortopassi diverts directly from the estuary. Westlands farmers get Delta water under contract with the federal government, which operates one of two major pump and canal systems.
The state operates the other. Both systems have been blamed for killing millions of fish, and are under court order to limit diversions. Cortopassi has much in common with Westlands farmers. He even buys tomatoes from some Westlands growers for his processing business. But that affinity may be eroding amid the water crisis.
To oversimplify the conflict, the more water Westlands farmers take from the Delta, the more it harms Cortopassi."It is farmer against farmer," Cortopassi said. "But I believe we can get together."
He fears a canal will lead to more water diversions, which could make the Delta too salty to directly irrigate crops and support wildlife. Both sides want to capture more water in wet years. This water, often in the form of floods, now flows out to sea as a "surplus" that cannot be harnessed for farms or cities. Cortopassi wants more groundwater storage systems and reservoirs to capture that surplus. Westlands farmers want a canal to capture the surplus and also to separate routine flows from the Delta's environmental problems.
"We all believe it's possible to reach a compromise," Woolf said of her committee. "What it takes to get there, I don't know.

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