Simbol Calipatria II CUP # SmCP-2 Project Trip Assignment

Transcription

1 Path: L:\SanDiego\HudsonRanch_Geothermal\MAPS\MXDs\Figure_4_14-4_SmCP2_Project_Trip_Assignment.mxd Riverside County Imperial County MEXICO Simbol Calipatria II CUP # SmCP-2 Project Trip Assignment Figure

2 4.14 Transportation and Circulation This page intentionally left blank. Hudson Ranch Power II and Simbol Calipatria II Final EIR

3 4.14 Transportation and Circulation TABLE HIGHWAY SEGMENT OPERATIONS OPENING YEAR (2015) + HR-2 HIGHWAY SEGMENT DAILY VOLUME PEAK HOUR VOLUME V/C LOS INCREASE IN V/C? S? Pound Rd and Hazard Rd 3, A 0.0 No Hazard Rd and McDonald Rd 3, A 0.0 No McDonald Rd and Sinclair Rd 4, A 0.01 No Sinclair Rd and E. Hoober Rd 4, A 0.01 No Source: Fehr and Peers 2012 Key: V/C = Volume to Capacity Ratio LOS = Level of Service Intersection Analysis Table presents the intersection LOS and average vehicle delay results for key study area intersections in Year 2015, with the HR-2 Project. All intersections are assumed to be unsignalized. LOS calculation worksheets for Year HR-2 conditions are provided in Appendix L. As shown on Table , all key study area intersections would operate at LOS B or better and no significant impact would result. TABLE PEAK HOUR INTERSECTION OPERATIONS OPENING YEAR (2015) WITH HR-2 AM PM Change HR-2 Year HR-2 Year 2015 AM PM Intersection Delay LOS Delay LOS Delay LOS Delay LOS Delay S? Delay S? SMCP-2 Hwy 111/ Hazard Rd 9.7 A 9.7 A 10.2 B 10.2 B 0.0 N 0.1 N English Rd/McDonald Rd 9.5 B 9.5 A 9.9 A 9.8 A 0.1 N 0.2 N Hwy 111/ McDonald Rd 9.4 A 3.2 A 3.4 A 3.3 A 0.0 N 0.1 N Hwy 111/ Sinclair Rd 10.9 B 10.9 B 10.3 B 10.2 B 0.0 N 0.1 N HR-2 Project Drwy/McDonald Rd 8.5 A N/A N/A 8.7 A N/A N/A N/A N/A N/A N/A Source: Fehr and Peers 2012 Key: LOS = Level of Service S = Significant NA = Intersection does not exist during this scenario. LOS and Delay information is not available Mitigation Measures: None required. Hudson Ranch Power II and Simbol Calipatria II Final EIR

4 4.14 Transportation and Circulation HR-2 Project Operation, Future Year 2030 This section provides an analysis of Future Year (2030) traffic conditions. Future Year 2030 Roadway Network The following mitigation measures proposed in Hudson Ranch I Geothermal Project Traffic Impact Study were assumed to be in place under Future Year 2030 Base (without Project) conditions: Highway 111/Sinclair Road provide an exclusive westbound left-turn lane; No other roadway network changes were assumed; and Base roadway network. Future Year 2030 Traffic Volumes Future Year 2030 traffic volumes were obtained from the Imperial County Circulation and Scenic Highways Element (Imperial County 2008). Future Year 2030 peak hour intersection turning movements were developed by comparing existing and forecasted Year 2030 ADTs, peak hour approach and departure volumes, and by the application of respective growth factors (Fehr and Peers 2012). Future Year 2030 Base Traffic Operations LOS analyses under Future Year 2030 Base (without Project) traffic conditions were conducted and highway segment and intersection LOS results are discussed separately below. Highway Segment Analysis Future (Year 2030) highway segment operations are presented on Table As shown, all highway segments within the study area would operate at acceptable LOS (LOS A or LOS B) in the Year TABLE HIGHWAY SEGMENT FUTURE (YEAR 2030) HIGHWAY SEGMENT OPERATIONS DAILY VOLUME PEAK HOUR VOLUME V/C LOS Pound Rd and Hazard Rd 18,680 1, B Hazard Rd and McDonald Rd 15,780 1, A Hudson Ranch Power II and Simbol Calipatria II Final EIR

5 4.14 Transportation and Circulation TABLE FUTURE (YEAR 2030) HIGHWAY SEGMENT OPERATIONS HIGHWAY SEGMENT DAILY VOLUME PEAK HOUR VOLUME V/C LOS McDonald Rd and Sinclair Rd 16,080 1, A Sinclair Rd and E. Hoober Rd 14, A Source: Fehr and Peers 2012 Key: V/C = volume to capacity LOS = Level of Service Intersection Analysis Table presents intersection LOS and average vehicle delay results under the Future Year 2030 Base (without project) traffic conditions. All intersections were assumed to be unsignalized. All key study area intersections would operate at acceptable LOS under the Future Year 2030 Base conditions, with the exception of Highway 111/McDonald Road and Highway 111/Sinclair Road. The intersection of Highway 111/McDonald Road is projected to operate at LOS D during the AM and PM peak hours. The intersection of Highway 111/Sinclair Road is projected to operate at LOS E during the AM peak hour. TABLE FUTURE (2030) PEAK HOUR INTERSECTION OPERATIONS AM PM INTERSECTION DELAY (SECONDS) LOS DELAY (SECONDS) LOS State Highway 111/Hazard Rd 19.3 C 22.1 C English Rd/McDonald Rd 10.7 B 10.6 B State Highway 111/McDonald Rd 29.3 D 31.3 D State Highway 111/Sinclair Rd 37.6 E 24.5 C Source: Fehr and Peers 2012 Note: Bold denotes sub-standard LOS. Future Year 2030 Base Plus HR-2 Traffic Volumes The Future Year 2030 Base Plus HR-2 traffic volumes were derived by adding the project trip assignment to the Future Year 2030 Base volumes. Hudson Ranch Power II and Simbol Calipatria II Final EIR

6 4.14 Transportation and Circulation Future Year 2030 Base Plus HR-2 Traffic Operations LOS analyses under Future Year 2030 Base Plus HR-2 traffic conditions were conducted using the methodologies described in Section Highway segment and intersection LOS results are discussed separately below. Highway Segment Analysis With the addition of HR-2 Project traffic, all key highway segments in the study area would operate at LOS B or better under the Future Year 2030 Base Plus HR-2 Project conditions (Table ). No significant impacts would result. TABLE FUTURE (YEAR 2030) + HR-2 HIGHWAY SEGMENT OPERATIONS HIGHWAY SEGMENT DAILY VOLUME PEAK HOUR VOLUME V/C LOS Pound Rd and Hazard Rd 18,690 1, B Hazard Rd and McDonald Rd 15,790 1, B McDonald Rd and Sinclair Rd 16,120 1, B Sinclair Rd and E. Hoober Rd 14,280 1, B Source: Fehr and Peers 2012 Key: V/C = volume to capacity LOS = Level of Service Mitigation Measures: None required. Intersection Analysis Table presents intersection LOS and average vehicle delay results for the key study area intersections under Future Year 2030 Base Plus HR-2 Project conditions. All intersections were assumed to be unsignalized. All key study area intersections would operate at an acceptable LOS under the Future Year 2030 Base Plus HR-2 Project condition, with the exception of Highway 111/McDonald Road and Highway 111/Sinclair Road. As shown on Table , the intersection of Highway 111/McDonald Road would operate at LOS D in both the AM and PM peak hours, with and without the proposed HR-2 Project under future conditions. The addition of HR-2 traffic would not change the intersection level of service nor would it result in a delay of more than 2 seconds. Thus, based on the significance criteria presented in Section , the HR-2 Project would not have a significant impact on future operations of the intersection of Highway 111/McDonald Road. Hudson Ranch Power II and Simbol Calipatria II Final EIR

7 4.14 Transportation and Circulation TABLE FUTURE (YEAR 2030) + HR-2 PEAK HOUR INTERSECTION OPERATIONS AM PM Change Future + HR-2 Future Future + HR-2 Future AM PM Intersection Delay LOS Delay LOS Delay LOS Delay LOS Delay S? Delay S? Hwy 111/ Hazard Rd 19.3 C 19.3 C 22.1 C 22.1 C 0.0 N 0.0 N English Rd/McDonald Rd 10.8 B 10.7 B 10.8 B 10.6 B 0.0 N 0.2 N Hwy 111/ McDonald Rd 30.5 D 29.3 D 32.3 D 31.3 D 1.2 N 1.0 N Hwy 111/ Sinclair Rd 38.3 E 37.6 E 25.0 C 24.5 C 0.7 N 0.5 N HR-2 Project Drwy/McDonald Rd Source: Fehr and Peers 2012 Key: S = Significant Bold denotes sub-standard LOS 8.6 A N/A N/A 9.0 A N/A N/A N/A N/A N/A N/A The intersection of Highway 111/Sinclair Road would operate at LOS E during the AM peak hour with and without the HR-2 Project. Because the addition of the HR-2 traffic would not change the level of service and would not cause a delay of more than 2 seconds; based on the significance criteria presented in Section the HR-2 Project would not have a significant impact on the future operations of Highway 111/Sinclair Road intersection during the AM peak hour. During the PM peak hour, the addition of HR-2 related traffic would not change the level of service at the intersection of Highway 111/Sinclair Road; it would continue to operate at LOS C and would result in a 0.5 second delay. Based on the significance criteria presented in Section , the proposed HR-2 Project would not result in a significant impact to the intersection of Highway 111/Sinclair Road during the PM peak hour because the intersection would continue to operate at an acceptable level of service (LOS C). Thus, the proposed HR-2 Project s impact on future peak hour intersection operations would not be significant. Mitigation Measures: Impact TR-2: None required. The HR-2 Project would not conflict with an applicable congestion management policy. Implementation of the proposed HR-2 Project would not cause key area highway segments or intersections to operate below acceptable levels of service. Therefore, the HR-2 Project is not anticipated to conflict with an applicable congestion management program. No impact would occur. Hudson Ranch Power II and Simbol Calipatria II Final EIR

8 4.14 Transportation and Circulation Mitigation Measures: Impact TR-3: None required. The HR-2 Project would not change air traffic patterns. The proposed HR-2 Project is approximately 4.8 miles from the nearest airport (Calipatria Municipal Airport) and is not within it is located within the airport s planning area/airport influence. Therefore, implementation of the proposed HR-2 Project would not result in a change in air traffic patterns. No impact would occur. Mitigation Measures: Impact TR-4: None required. The HR-2 Project would not increase hazards or incompatible uses. The proposed HR-2 Project would include the installation of new driveway access from McDonald Road and emergency access from English Road. All County ingress/egress roads would be constructed in conformance with Imperial County Public Works Department requirements. Road access would be restricted during construction, and appropriate traffic controls would be in place during any construction within the roadbed or adjacent shoulders of the road to warn and control traffic. Encroachment permits for ingress/egress would be obtained from the Imperial County Public Works Department. Therefore, implementation of the proposed HR-2 Project would not substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment). No impact would occur. Mitigation Measures: Impact TR-5: None required. The HR-2 Project would not result in inadequate emergency access. The proposed HR-2 project would include the installation of new driveway access from McDonald Road and emergency access from English Road. All County ingress/egress roads would be reconstructed in conformance with Imperial County Public Works Department requirements. In addition, the County Fire Department has reviewed the HR-2 site plans submitted with the conditional use permit application and made a preliminary determination that the proposed access is adequate. Therefore, implementation of the proposed HR-2 Project would not result in inadequate emergency access. No impact would occur. Mitigation Measures: Impact TR-6: None required. The HR-2 Project would not conflict with policies, plans, and programs for public transit, bicycles, and pedestrian facilities. Hudson Ranch Power II and Simbol Calipatria II Final EIR

9 4.14 Transportation and Circulation No transit service is provided in the immediate vicinity of the HR-2 Project Site and no bicycle or pedestrian improvements have been made. Therefore, the proposed HR-2 Project would not affect transit services, or bicycle/pedestrian facilities. In addition, there are no such plans applicable to the Project site and given the Project Sites distance from the nearest population center, and the condition of the surrounding roadway network (i.e., unpaved roadways), it is not anticipated that visitors or employees would attempt to walk or bike to the Project site. Therefore, implementation of the proposed HR-2 Project would not conflict with adopted policies, plans, or programs regarding public transit, bicycle, or pedestrian facilities, or otherwise decrease the performance or safety of such facilities. No impact would occur. Mitigation Measures: None required. SMCP-2 PROJECT IMPACTS AND MITIGATION MEASURES Impact TR-1: The proposed SmCP-2 Project would not conflict with an applicable plan, ordinance or policy establishing measures of effectiveness for the performance of the circulation system, taking into account all modes of transportation including mass transit and non-motorized travel and relevant components of the circulation system, including but not limited to intersections, streets, highways and freeways, pedestrian and bicycle paths, and mass transit. A discussion of potential impacts is provided below. Existing Plus SmCP-2 Construction Impact Analysis Trips generated during construction of the proposed SmCP-2 Project are shown on Table Construction trip generation, distribution, and assignment are described in Appendix L. As shown on Table , during construction of the SmCP-2 Project, there would be 120 PCE trips traveling to the SmCp-2 Project site during the AM peak hour; 120 PCE trips traveling from the site during the PM peak hour; and a total of 506 PCE trips over the course of the day. Approximately 10% of all construction trips would be generated from north of the SmCP-2 Project site and the other 90% would be generated from south of the site. All trucks and construction workers exiting the SmCP-2 Project site would be instructed to turn east on McDonald Road to access Highway 111. Traffic entering the SmCP-2 Project site would utilize the same route but in reverse. Construction Phase Intersection Levels of Service For the SmCP-2 Project, intersection levels of service were calculated with the construction traffic from the SmCP-2 to evaluate the operating conditions and Hudson Ranch Power II and Simbol Calipatria II Final EIR

10 4.14 Transportation and Circulation identify potential impacts to the local roadway system. The results of the intersection level of service calculations for Existing + SmCP-2 Construction are presented on Table LOS calculation sheets are included in Appendix L. During the projected construction period of SmCP-2, various activities (both construction and operations) from the following surrounding cumulative projects are projected to occur concurrently and are included in the existing traffic volumes shown on Table : HR-1 Plant Operations; SmCP-1 Operations; HR-2 Construction; HR-2 Operations; and Energy Solar (ES Solar 1) Project Operations. TABLE SMCP-2 CONSTRUCTION INTERSECTION OPERATIONS Existing (1) AM PM Change Ex.+SmCP-2 Ex.+SmCP-2 Construction (1) Existing (1) Construction (1) AM PM Intersection Delay LOS Delay LOS Delay LOS Delay LOS Delay S? Delay S? SMCP Hwy 111/ Hazard Rd 9.8 A 9.8 A 10.3 B 10.3 B 0 N 0 N English Rd/ McDonald Rd 11.1 B 12.5 B 11.4 B 12.8 B 1.4 N 1.4 N Hwy 111/ McDonald Rd 10.3 B 11.7 A 10.8 A 12.3 A 1.4 N 1.5 N Hwy 111/ Sinclair Rd 12.5 B 14.0 B 11.8 B 13.2 B 1.5 N 1.4 N HR-2 Project Drwy/McDonald Rd SmCP-2 Project Drwy/McDonald Road N/A N/A 8.5 A N/A N/A 9.5 A N/A N/A N/A N/A N/A N/A 8.6 A N/A N/A 10.5 B N/A N/A N/A N/A Source: Fehr and Peers 2012 Notes: (1) Includes trips from HR-1 Plant Operations; SmCP-1 Operations; HR-2 Construction; HR-2 Operations; and proposed Energy Solar (ES Solar 1) Project Operations. NA = Intersection does not exist during this scenario. LOS and Delay information is not available. As shown in Table all intersections operate acceptably both with and without the addition of SmCP-2 construction-related traffic and no significant impact would occur. Hudson Ranch Power II and Simbol Calipatria II Final EIR

11 4.14 Transportation and Circulation Mitigation Measures: None required. SmCP-2 Project Opening Year (2015) Impact Analysis This section provides an analysis of the SmCP-2 Project s projected opening year (Year 2015) traffic conditions. Cumulative projects identified to generate trips within the project study area during the Year 2015 include Hudson Ranch I, SmCP-1 and the ES Solar 1 Project. Trips from these projects were assigned to the 2015 roadway network, which assumed no changes from existing network shown on Figure As noted previously, the SmCP-2 Project could not operate without the HR-2 Project. Therefore, the traffic analysis for SmCP-2 also includes trips associated with the HR-2 Project. Intersection Analysis Table presents the intersection LOS and average vehicle delay results for key study area intersections in Year 2015, with the HR-2 and SmCP-2 projects. All intersections are assumed to be unsignalized. LOS calculation worksheets for Year HR-2 + SmCP-2 conditions are provided in Appendix L. As shown on Table , all key study area intersections would operate at LOS B or better and no significant impact would result. TABLE YEAR 2015 PEAK HOUR INTERSECTION LEVEL OF SERVICE WITH HR-2 + SMCP-2 AM PM Change HR-2 + SmCP-2 Year HR-2 + SmCP-2 Year 2015 AM PM Intersection Delay LOS Delay LOS Delay LOS Delay LOS Delay S? Delay S? SMCP-2 Hwy 111/ Hazard Rd 9.8 A 9.7 A 10.3 B 10.2 B 0.1 N 0.1 N English Rd/McDonald Rd 10.3 B 9.5 A 10.6 B 9.8 A 0.8 N 0.8 N Hwy 111/McDonald Rd 9.8 A 9.4 A 10.2 A 9.6 A 0.4 N 0.6 N Hwy 111/ Sinclair Rd 11.6 B 10.9 B 10.9 B 10.2 B 0.7 N 0.7 N HR-2 Project Drwy/McDonald Rd SmCP-2 Project Drwy/McDonald Road 8.5 A N/A N/A 8.7 A N/A N/A N/A N/A N/A N/A 8.6 A N/A N/A 8.9 A N/A N/A N/A N/A N/A N/A Source: Fehr and Peers 2012 Key: LOS = Level of Service S = Significant NA = Intersection does not exist during this scenario. LOS and Delay information is not available. Hudson Ranch Power II and Simbol Calipatria II Final EIR

12 4.14 Transportation and Circulation Mitigation Measures: None required. State Highway Segment Analysis Because the SmCP-2 Project cannot operate without the HR-2 Project, the traffic analysis evaluated opening year highway segment operations with the addition of both HR-2 and SmCP-2 operational traffic. Table presents the State Highway segment operations during the first year of operations for the HR-2 and SmCP-2 Projects (Year 2015). All key study area State Highway segments are projected to operate at an acceptable LOS in Year Under the Opening Year (2015) + HR-2 + SmCP-2 conditions, highway segments would continue to operate at an acceptable LOS (see Table ) and no significant impacts would result. TABLE HIGHWAY SEGMENT OPERATIONS OPENING YEAR (2015) + HR-2 +SMCP-2 HIGHWAY SEGMENT DAILY VOLUME PEAK HOUR VOLUME V/C LOS INCREASE IN V/C? S? Pound Rd and Hazard Rd 3, A 0 No Hazard Rd and McDonald Rd 3, A 0 No McDonald Rd and Sinclair Rd 4, A 0.02 No Sinclair Rd and E. Hoober Rd 4, A 0.02 No Source: Fehr and Peers 2012 Key: V/C = volume to capacity LOS = Level of Service Mitigation Measures: None required. SmCP-2 Project Operation, Future Year 2030 This section provides an analysis of Future Year (2030) traffic conditions. Future Year 2030 Roadway Network The following mitigation measures proposed in Hudson Ranch I Geothermal Project traffic impact study were assumed to be in place under Future Year 2030 Base (without Project) conditions: Highway 111/Sinclair Road provide an exclusive westbound left-turn lane; No other roadway network changes were assumed; and Base roadway network. Hudson Ranch Power II and Simbol Calipatria II Final EIR

13 4.14 Transportation and Circulation Future Year 2030 Traffic Volumes Future Year 2030 traffic volumes were obtained from the Imperial County Circulation and Scenic Highways Element (County of Imperial 2008). Future Year 2030 peak hour intersection turning movements were developed by comparing existing and forecasted Year 2030 ADTs, peak hour approach and departure volumes, and by the application of respective growth factors (Fehr and Peers 2012). Future Year 2030 Base Plus HR-2 and SmCP-2 Traffic Volumes The Future Year 2030 Base Plus HR-2 and SmCP-2 traffic volumes were derived by adding the project trip assignment to the Future Year 2030 Base volumes. Future Year 2030 Base Plus HR-2 Traffic Operations LOS analyses under Future Year 2030 Base Plus HR-2 and SmCP-2 traffic conditions were conducted using the methodologies described in Section Highway segment and intersection LOS results are discussed separately below. Highway Segment Analysis With the addition of HR-2 and SmCP-2 Project traffic, all key highway segments in the study area would continue to operate at acceptable levels of service (LOS B) under the Future Year 2030 Base Plus HR-2 Project conditions (Table ). No significant impacts would result. TABLE HIGHWAY SEGMENT OPERATIONS FUTURE (YEAR 2030) + HR-2 + SMCP-2 HIGHWAY SEGMENT DAILY VOLUME PEAK HOUR VOLUME V/C LOS Pound Rd and Hazard Rd 18,730 1, B Hazard Rd and McDonald Rd 15,830 1, B McDonald Rd and Sinclair Rd 16,500 1, B Sinclair Rd and E. Hoober Rd 14,660 1, B Source: Fehr and Peers 2012 Key: V/C = volume to capacity LOS = Level of Service Mitigation Measures: None required. Hudson Ranch Power II and Simbol Calipatria II Final EIR

14 4.14 Transportation and Circulation Intersection Analysis Table presents intersection LOS and average vehicle delay results for the key study area intersections under Future Year 2030 Base Plus HR-2 and SmCP-2 Project conditions. All intersections were assumed to be unsignalized. All key study area intersections would operate at acceptable LOS under the Future Year 2030 Base Plus and SmCP-2 Project condition, with the exceptions of: Highway 111/McDonald Road during the AM and PM peak hours, which would operate at LOS E and LOS D during the AM and PM peak hours, respectively; and Highway 111/Sinclair Road, which would operate at LOS E during the AM peak hour and LOS D during the PM peak hour. These impacts would be significant. TABLE PEAK HOUR INTERSECTION OPERATIONS FUTURE (YEAR 2030) + HR-2 + SMCP-2 AM PM Change Future + HR-2+ SmCP-2 Future Future + HR-2+ SmCP-2 Future AM PM Intersection Delay LOS Delay LOS Delay LOS Delay LOS Delay S? Delay S? Hwy 111/ Hazard Rd 19.5 C 19.3 C 22.4 C 22.1 C 0.2 N 0.3 N English Rd/ McDonald Rd 11.9 B 10.7 B 11.7 B 10.6 B 1.2 N 1.1 N Hwy 111/ McDonald Rd 43.0 E 29.3 D 49.5 E 31.3 D 13.7 Y 18.2 Y Hwy 111/ Sinclair Rd 45.8 F 37.2 E 29.6 D 24.5 C 8.6 Y 5.1 Y HR-2 Project Drwy/McDonald Rd 8.6 A N/A N/A 9.0 A N/A N/A N/A N/A N/A N/A SmCP-2 Project Drwy/McDonald Road 8.7 A N/A N/A 9.3 A N/A N/A N/A N/A N/A N/A Source: Fehr and Peers 2012 Key: S = Significant impact Bold denotes sub-standard LOS MM TR-1.1: Contribute Fair Share to Future Signalization of Highway 111/McDonald Road Intersection and Highway 111/Sinclair Road Intersection Hudson Ranch Power II, LLC and Simbol, Inc. shall contribute to Caltrans, their portion of the fair-share contribution of 8.0% and 7.4%, as calculated in Appendix H of the Traffic Study, to the improvements prior to the issuance of the Hudson Ranch Power II and Simbol Calipatria II Final EIR

15 4.14 Transportation and Circulation first building permit for each Project. Hudson Ranch Power II, LLC and Simbol Inc., shall enter into an Agreement with Caltrans to provide fair-share contributions to Caltrans for the future signalization of the intersections of Highway 111/McDonald Road and Highway 111/Sinclair Road, prior to the issuance of the first building permit for each Project. Hudson Ranch Power II, LLC and Simbol, Inc. shall also contribute to Caltrans their fair-share contribution to these future improvements prior to the issuance of a building permit. For the purpose of this Agreement, fair-share shall mean a percentage derived by taking the trips generated by the HR-2 Project and those generated by the SmCP-2 Project as a percentage of total trips of all users. Significance after Mitigation: Impact TR-2: Signalization of Highway 111/McDonald Road intersection would cause the intersection to operate at acceptable levels of service (i.e., LOS B in the AM peak hour and LOS B in the PM peak hour) in the future year (2030). Signalization of the intersection of Highway 111/Sinclair Road would cause the intersection to operate at acceptable levels of service (i.e., LOS A in the AM and PM peak hours) in the future year (2030). Therefore, implementation of MM TR-1.1 would reduce impacts to below a level of significance. The SmCP-2 Project would not conflict with an applicable congestion management policy. Implementation of the proposed SmCP-2 Project would not cause key area Highway segments or intersections to operate below acceptable levels of service, with the implementation of MM TR 1.1. Therefore, the SmCP-2 Project is not anticipated to conflict with an applicable congestion management program. No impact would occur. Mitigation Measures: Impact TR-3: None required. The SmCP-2 Project would not change air traffic patterns. The proposed SMCP-2 Project is approximately 4.8 miles from the nearest airport (Calipatria Municipal Airport) and is not located within the airport s planning area/airport influence. Therefore, implementation of the proposed SmCP-2 Project would not result in a change in air traffic patterns. No impact would occur. Mitigation Measures: None required. Hudson Ranch Power II and Simbol Calipatria II Final EIR

16 4.14 Transportation and Circulation Impact TR-4: The SmCP-2 Project would not increase hazards or incompatible uses. The proposed SmCP-2 project would include the installation of new driveway access from McDonald Road and emergency access from English Road. All County ingress/egress roads would be constructed in conformance with Imperial County Public Works Department requirements. Road access would be restricted during construction, and appropriate traffic controls would be in place during any construction within the roadbed or adjacent shoulders of the road to warn and control traffic. Encroachment permits for ingress/egress would be obtained from the Imperial County Public Works Department. Therefore, implementation of the proposed SmCP-2 Project would not substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment). No impact would occur. Mitigation Measures: Impact TR-5: None required. The SmCP-2 Project would not result in inadequate emergency access. The proposed SmCP-2 project would include the installation of new driveway access from McDonald Road and emergency access from English Road. All County ingress/egress roads would be reconstructed in conformance with Imperial County Public Works Department requirements. In addition, the County Fire Department will review the SmCP-2 site plans submitted with the conditional use permit application. A determination that the proposed access is adequate would be obtained prior to the issuance of the commencement of construction. Therefore, implementation of the proposed SmCP-2 Project would not result in inadequate emergency access. No impact would occur. Mitigation Measures: Impact TR-6: None required. The SmCP-2 Project would not conflict with policies, plans, and programs for public transit, bicycles, and pedestrian facilities. No transit service is provided in the immediate vicinity of the SmCP-2 Project Site and no bicycle or pedestrian improvements have been made. Therefore, the proposed SmCP-2 Project would not affect transit services, or bicycle/pedestrian facilities. In addition, there are no such plans applicable to the Project sites and given the Project Sites distance from the nearest population center, and the condition of the surrounding roadway network (i.e., unpaved roadways), it is not anticipated that visitors or employees would attempt to walk or bike to the Project site. Therefore, implementation of the proposed SmCP-2 Project would not conflict with adopted policies, plans, or programs regarding public transit, bicycle, or Hudson Ranch Power II and Simbol Calipatria II Final EIR

17 4.14 Transportation and Circulation pedestrian facilities, or otherwise decrease the performance or safety of such facilities. No impact would occur. Mitigation Measures: None required REFERENCES AirNav Cliff Hatfield Memorial Airport. Online at: Accessed July 15, California Department of Transportation (Caltrans) Guide for the Preparation of Traffic Impact Studies, December County of Imperial County of Imperial General Plan, Circulation and Scenic State Highways Element. El Centro, California Traffic Study and Report Policy. Prepared by the County of Imperial Department of Public Works, March 12, Fehr and Peers Draft Traffic Impact Study for the Hudson Ranch II Geothermal Plant and Simbol Calipatria Plant II, County of Imperial, California. May OurAirports.com Pilot information for O'Connell Brothers Airport. Online at: June 16, Southern California Association of Governments (SCAG) Regional Transportation Plan, adopted May 8, Transportation Research Board State Highway Capacity Manual. December Hudson Ranch Power II and Simbol Calipatria II Final EIR

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19 4.15 Utilities and Services 4.15 UTILITIES AND SERVICES This section describes the existing utility and service systems in the vicinity of the Project sites and identifies the potential physical environmental impacts that would result from provision of services to the proposed Projects. Applicant s Reports and Survey Results The information in this section is based on information obtained from service providers as well as the SB 610 Water Supply Assessment (Appendix I) prepared for the proposed Hudson Ranch Power II Geothermal Plant Project (HR-2) and the Simbol Calipatria Plant II Project (SmCP-2), prepared by Pangea Land Consultants, March 15, This document is contained in Volume II (Technical Appendix) of this EIR. Scoping Issues Addressed During the scoping period for the projects, two public scoping meetings were conducted and written comments were received from agencies and the public. The Imperial Irrigation District (IID) had the following comments related to utilities and services: The Projects water supply requirements can only be provided for under the IID s Interim Water Supply Policy (IWSP); there is no landlord allocation available for industrial purposes. All new non-agricultural water project supply requests are processed in accordance with the IWSP. In order to obtain a water supply from IID, the Project proponents would be required to comply with all applicable IID policies and regulations and may be required to enter into a water supply agreement with IID. Such policies and regulations require that all potential environmental and water supply impacts of the Projects have been adequately assessed, appropriate mitigation has been developed, and appropriate conditions have been adopted in accordance with the relevant land use permitting/approving agencies. The Draft Environmental Impact Report (EIR) should include discussion and analyze of the use of fresh water for cooling given that dry cooling technologies for power plant cooling is encouraged and preferred in the desert region due to the scarcity of water resources. Any new, relocated, upgraded or reconstructed IID facilities required for and by the Projects (which can include, but is not limited to, electrical utility substations, electrical transmission and distribution lines, etc.) need to be included as part of the Projects California Environmental Quality Act (CEQA) and/or National Environmental Policy Act (NEPA) documentation, environmental impact analysis and mitigation. Hudson Ranch Power II and Simbol Calipatria II Final EIR

20 4.15 Utilities and Services EXISTING CONDITIONS REGIONAL SETTING Water Supply The Imperial Valley obtains all of its surface water from the Colorado River and the IID. The IID imports raw water from the Colorado River and then distributes most of the water for agricultural use (97 percent). The remaining water is distributed to Imperial Valley s seven municipalities (Brawley, Calexico, Calipatria, El Centro, Holtville, Imperial, and Westmorland); three unincorporated communities (Heber, Niland, and Seeley); one private water company; and two community water systems that treat the water to potable standards for distribution as domestic water and to industrial users (Pangaea 2012). Table presents the total expected water usage (through the year 2045) for Imperial Valley based on IID projections. As the table shows, the majority of water imported by the IID is used for agriculture. TABLE PROJECTED IMPERIAL VALLEY WATER CONSUMPTION (ACRE-FEET), WATER AVAILABILITY CONSUMPTION BY USE IMPERIAL VALLEY TOTAL (1) ESTIMATED IID SYSTEM LOSS NET TOTAL (2) MUNICIPAL USE OTHER NON- AGRICULTURAL USE AGRICULTURAL USE YEAR AFY AFY AFY AFY AFY AFY ,738, ,000 2,363,800 50,819 54,749 2,258, ,569, ,500 2,236,300 55,877 66,382 2,114, ,649, ,500 2,316,300 61,397 78,015 2,176, ,617, ,500 2,284,300 67,335 85,558 2,131, ,612, ,500 2,279,300 71,233 93,101 2,114, ,612, ,500 2,279,300 75, ,644 2,103, ,612, ,500 2,279,300 83, ,187 2,087, ,612, ,500 2,279,300 92, ,655 2,070,047 Source: Pangaea 2012 Notes: (1) At Imperial Check Dam. (2) Total = Total Imperial Valley less Estimated IID System Loss. Table shows the IID s past water deliveries to the proposed Project sites via the O Lateral canal. Until relatively recently, all the Project lands were owned by the IID. Years showing "0" water deliveries represent years in which IID did not lease out the land for farming (Pangea 2012, p. 10). Hudson Ranch Power II and Simbol Calipatria II Final EIR

21 4.15 Utilities and Services TABLE PAST AGRICULTURAL WATER DELIVERY TO THE PROJECT SITES YEAR O LATERAL GATE WATER DELIVERY (AF) AT DELIVERY GATE O LATERAL GATE O LATERAL GATE O LATERAL GATE TOTAL DELIVERED TO THE PROJECT SITES , * * * * ,174.6 Total 1, , ,021.7 Source: Pangaea 2012 Notes: O refers to the O Lateral. * Reflects years when no farming occurred. Discounting the years (2001, 2003, 2005, and 2006) that no agricultural use occurred and also discounting the year 2004 with only 1.4 acre-feet of delivery, the average water use in years when the property was in agriculture (five years) is 804 acre-feet per year. 30-Year Projections with and without the Proposed Development Non-agricultural water users and other non-residential amenities shall be allowed to use that amount of water needed for reasonable and beneficial use. Tables , and provide a comparison of the Projected County Water Consumption without the proposed Projects, with HR-2, and with both HR-2 and SmCP-2 combined. Hudson Ranch Power II and Simbol Calipatria II Final EIR

22 4.15 Utilities and Services TABLE PROJECTED IMPERIAL VALLEY WATER CONSUMPTION (AF), EXISTING CONDITIONS, NORMAL WATER YEAR YEAR TOTAL DELIVERY INFLOWS TO IID SERVICE AREA (TOTAL IMPERIAL VALLEY) (AF) TOTAL MUNICIPAL USE (AF) TOTAL OTHER NON- AGRICULTURAL USE (AF) TOTAL AGRICULTURAL USE (AF) AMOUNT OF AG WATER USED AT PROJECT SITES (AF) ,363,800 50,819 54,749 2,258, ,236,300 55,877 66,382 2,114, ,316,300 61,397 78,015 2,176, ,284,300 67,335 85,558 2,131, ,279,300 71,233 93,101 2,114, ,279,300 75, ,644 2,103, ,279,300 83, ,187 2,087, ,279,300 92, ,655 2,070, Source: Pangea 2012 TABLE PROJECTED IMPERIAL VALLEY WATER CONSUMPTION (AF), PROPOSED HR-2 PROJECT CONDITIONS, NORMAL WATER YEAR (ACRE-FEET IN IMPERIAL VALLEY) YEAR TOTAL DELIVERY INFLOWS TO IID SERVICE AREA (TOTAL IMPERIAL VALLEY) (AF) TOTAL MUNICIPAL USE (AF) TOTAL OTHER NON-AG USE -PROJECT INCLUDED (AF) TOTAL REMAINING AVAILABLE FOR AG USE (AF) PROJECT COMPLETED; SAME LEVEL OF AG USE CONTINUES (AF) ,363,800 50,819 54,749 2,258, ,236,300 55,877 67,582 2,112, ,316,300 61,397 79,215 2,175, ,284,300 67,335 86,758 2,130, ,279,300 71,233 94,301 2,113, ,279,300 75, ,844 2,101, ,279,300 83, ,387 2,086, ,279,300 92, ,855 2,068, Source: Pangea 2012 Notes: (1) The HR-2 and SmCP-2 Projects are fully operational by 2016, but 2015 is used here for WSA purposes. Hudson Ranch Power II and Simbol Calipatria II Final EIR

23 4.15 Utilities and Services TABLE PROJECTED IMPERIAL VALLEY WATER CONSUMPTION (AF), PROPOSED HR-2 AND SMCP-2 COMBINED PROJECT CONDITIONS, NORMAL WATER YEAR (ACRE-FEET IN IMPERIAL VALLEY) YEAR TOTAL DELIVERY INFLOWS TO IID SERVICE AREA (TOTAL IMPERIAL VALLEY) (AF) TOTAL MUNICIPAL USE (AF) TOTAL OTHER NON-AG USE -PROJECT INCLUDED (AF) TOTAL REMAINING AVAILABLE FOR AG USE (AF) PROJECT COMPLETED; SAME LEVEL OF AG USE CONTINUES (AF) ,363,800 50,819 54,749 2,258, ,236,300 55,877 68,382 2,112, ,316,300 61,397 80,015 2,174, ,284,300 67,335 87,558 2,129, ,279,300 71,233 95,101 2,112, ,279,300 75, ,644 2,101, ,279,300 83, ,187 2,085, ,279,300 92, ,655 2,068, Source: Pangea 2012 Notes: (1) The HR-2 and SmCP-2 Projects are fully operational by 2016, but 2015 is used here for WSA purposes. Water Supply and Use for the Proposed Projects The Water Supply Assessment has determined that, under the terms of the IID Interim Water Supply Policy for Non-Agricultural Projects (IWSP), adopted by the IID Board of Directors, the IWSP designates up to 25,000 acre-feet per year for potential Non-Agricultural Projects within IID s service area (Imperial Unit). The IWSP is to remain in effect pending the approval of policies that would be adopted in association with the Integrated Regional Water Management Plan (IRWMP). The IWSP would be the source of water needed for either the HR-2 alone, or the combined HR-2 and SmCP-2 Projects, unless and until such time as policies and projects based on the IRWMP are implemented. Past agricultural use on the site has averaged 804 acre-feet per year; however, the site has not been in full agricultural production. If the site were in full agricultural production, the annual water use in an SDI year (5.25 acre-feet per acre) would be 1,228 acre-feet. The proposed HR-2 Project proposes the use of 1,200 acre-feet per year of water from the IID. The proposed SmCP-2 Project proposes to use 800 AFY of water from the IID, for a combined total of 2,000 AFY of IID water. No extra industrial water is available in SDI years, except through the IWSP. It is because of IID s IWSP, and eventual successor IRWMP, that the water supply is sufficient to meet the projected demands through 2045 for the Service Area both with and without the proposed Projects. Hudson Ranch Power II and Simbol Calipatria II Final EIR

24 4.15 Utilities and Services Stormwater Rain and storm drainage would be collected in the proposed stormwater retention pond on the south side of the facility. The drainage pond would be designed for a 24-hour, 100-year storm event. Water accumulated in the stormwater detention pond would be allowed to evaporate, seep into the ground, or be pumped into the aerated brine injection well. The collected stormwater runoff in the stormwater retention basin would be sampled and analyzed for quality and compatibility before releasing the stormwater runoff from the stormwater retention basin. Spent Fluid and Wastewater Handling Spent fluid (i.e., brine from which heat energy has been removed) from the secondary clarifiers would be sent to the SmCP-2 process area, via a brine delivery pipeline. Once the brine has been processed, it would be returned to the HR-2 facility, via a brine return pipeline and would be injected directly into the injection wells to replenish the geothermal resource. Wastewater Sanitary wastewater would discharge to a wastewater collection system to be constructed as part of the Projects. Landfill/Solid Waste Disposal Services Non-hazardous waste and debris would be disposed of at local Class III landfills. Hazardous wastes would be recycled or managed and disposed of properly in a licensed Class I or II waste disposal facility authorized to accept the waste. Some hazardous wastes would be recycled, including used oils from equipment maintenance and oil-contaminated materials such as spent oil filters, rags, or other cleanup materials. Used oil would be recycled, and oil- or heavy metal-contaminated materials (e.g., filters) requiring disposal would be disposed of in a Class I waste disposal facility. The Allied Imperial Landfill and Niland Solid Waste Facility receive municipal waste and are located 23 miles south and 4.5 miles northeast of the Project sites, respectively. Table shows the permitted and remaining capacity of the nearby landfills in County of Imperial that would provide waste collection for the proposed Project sites. Hudson Ranch Power II and Simbol Calipatria II Final EIR

25 4.15 Utilities and Services TABLE COUNTY OF IMPERIAL LANDFILLS IN VICINTY OF PROJECT SITES NAME OF LANDFILL LOCATION PERMITTED CAPACITY (cy) (2) REMAINING CAPACITY CLASS APPROXIMATE DISTANCE FROM PROJECT SITES Allied Imperial Landfill Niland Solid Waste Site 104 East Robinson Road County of Imperial 8450 Cuff Road, County of Imperial 4,324,200 1,901,305 cy Class III (1 ) 23 miles south 131,000 44,053 cy Class III (1 ) 4.5 miles northeast South Yuma County Landfill (SYCL) (3 ) South Avenue 1E, Yuma, AZ No limit on Daily tonnage 28,480 cy CERCLA Approved Waste Disposal Facility EPA Federal and State Permit # AZR miles southeast Kettelman Hills Landfill Old Skyline Road Kettleman City, CA 10,700,000 6,000,000 Class I/II (4 ) 345 miles northwest Sources: CalRecycle 2012, CalRecycle 2011a-d; SYCL 2012 Notes: (1) Class III does not accept hazardous Waste, Class II accepts designated waste. (2) Cy = Cubic yards. (3) The SYCL is approved to accept special waste petroleum contaminated soil (PCS), and is therefore approved to accept all manner of nonhazardous soils contaminated with petroleum products. SYCL is not licensed to accept hazardous waste as defined by the U.S. EPA in 40 CFR 261 and ADEQ in ARS , radioactive waste subject to the atomic energy act of 1954, polychlorinated biphenyl (PCB) waste, or used oil waste. It is the generator s responsibility to evaluate the waste and to determine whether or not the waste generated is a listed or characteristic hazardous waste prior to disposal. (4) The Kettleman Hills Landfill is approved to accept hazardous waste REGULATORY SETTING WATER SUPPLY State Department of Water Resources Major responsibilities of the California Department of Water Resources include preparing and updating the California Water Plan to guide development and management of the state s water resources and planning, and designing, constructing, operating, and maintaining the State Water Resources Development System. In addition, the Department of Water Resources cooperates with local agencies on water resources investigations, supports watershed and river restoration programs, encourages water conservation, explores conjunctive use of ground and surface water, facilitates voluntary water transfers, and, when needed, operates a state drought water bank. Hudson Ranch Power II and Simbol Calipatria II Final EIR

26 4.15 Utilities and Services Senate Bill 610 and 221 Senate Bill (SB) 610 (Chapter 643, Statutes of 2001) and SB 221 (Chapter 642, Statutes of 2001) amended State of California law, effective January 1, 2002, to improve the link between information on water supply availability and certain land use decisions made by cities and counties. SB 610 and SB 221 are companion measures that seek to promote more collaborative planning between local water suppliers and cities and counties. Both statutes require detailed information regarding water availability to be provided to city and county decision-makers prior to approval of specified large development projects. Both statutes also require this detailed information to be included in the administrative record that serves as the evidentiary basis for an approval action by the city or county on such projects. Both measures recognize local control and decision making regarding the availability of water for projects and the approval of projects. Water Code Sections require lead agencies to identify the public water system that may supply water for a proposed development project and to request from that public water system a water supply assessment for the proposed Projects. The purpose of the water supply assessment is to demonstrate that the public water system has sufficient water supplies to meet the water demands associated with the proposed Projects in addition to meeting the existing and planned future water demands projected for the next 20 years. A water supply assessment is required for: A proposed residential development of more than 500 dwelling units. A proposed shopping center or business establishment employing more than 1,000 persons or having more than 500,000 square feet of floor space. A proposed commercial office building employing more than 1,000 persons or having more than 250,000 square feet of floor space. A proposed hotel or motel, or both, having more than 500 rooms. A proposed industrial, manufacturing, or processing plant, or industrial park planned to house more than 1,000 persons, occupying more than 40-acres of land, or having more than 650,000 square feet of floor area. A mixed-use development that includes one or more of the uses described above. A development that would demand an amount of water equivalent to or greater than the amount of water required by a 500 dwelling-unit project. For lead agencies with fewer than 5,000 water service connections, any new development that would increase the number of water service connections in the service area by 10 percent or more. Hudson Ranch Power II and Simbol Calipatria II Final EIR

27 4.15 Utilities and Services Imperial Irrigation District Water Planning Efforts Basin management for the Imperial Valley is administered by the Imperial Irrigation District (IID). With more than 3,000 miles of canals and drains, the IID is the largest irrigation district in the Nation (IID 2010). The IID water service area extends from the southern half of the Salton Sea to the U.S. Mexico border. The IID Water Department is responsible for the timely operation and maintenance of the extensive open channel system, and delivers up to 3.1 million AFY of IID s Colorado River entitlement to nearly 500,000-acres of irrigated land. Of the water IID transports, approximately 97% is used for agricultural purposes (IID 2010). Quantification Settlement Agreement (2003) Due to competing interests regarding water rights in Southern California, all major Southern California water agencies, including federal and state agencies, negotiated a Quantification Settlement Agreement (QSA) with IID in October At that time, IID agreed to 35 to 75 years of water conservation, which would result in millions of acre-feet of conserved water for urban uses in southern California. Under the QSA and related transfer agreements, IID agreed to cap of 3.1 million AFY of Colorado River water and a schedule for creating conserved water for transfer and environmental mitigation (Pangaea 2012). The QSA and IID water rights are described in further detail in Appendix I. Strategic Plan (2008) In 2008, the IID Board of Directors adopted the IID Strategic Plan, in part due to increased water demands of proposed geothermal projects and other economic development in the region. The objectives of the IID Strategic Plan were to: Prevent impacts to existing agricultural users of water and protect IID water rights. Define cost-effective projects and equitable cost-sharing agreements with those entities and water users that would receive benefits from proposed water management actions. Identify projects that are consistent with existing agreements on use and management of the Colorado River, including the QSA and IID transfer agreements. Recognize and resolve potential conflicts over use of available water resources. Promote economic development consistent with IID policies, standards, and guidelines for new consumptive uses of water. The IID Strategic Plan also included an objective to develop an Integrated Water Resources Management Plan (IWRMP) by the end of Hudson Ranch Power II and Simbol Calipatria II Final EIR

28 4.15 Utilities and Services Interim Water Supply Policy (2009) Pending adoption of the IWRMP, the IID adopted the Interim Water Supply Policy (IWSP) for Non- Agricultural Projects in 2009 (IID 2009). All non-agricultural projects that require a raw water supply from IID must apply for water service pursuant to the IWSP, which allocates 25,000 AFY for non-agricultural projects within the IID service area. Proposed non-agricultural projects may be required to pay a Reservation Fee, further described below. The reserved water shall be available for other users until such non-agricultural projects are implemented and require the reserved water supply. The IWSP will remain in effect pending adoption of the Integrated Regional Water Management Plan, which is expected to make available up to 50,000 acre-feet per year of water for similar uses. Integrated Regional Water Management Plan Although the IWRMP was originally intended to be completed by 2009 (according to the IID Strategic Plan), as of the publication of this Draft EIR, the IWRMP has not yet been finalized. However, the Draft IWRMP was adopted by the IID Board of Directors on September 23, 2008 and updated November 17, The IRWMP effort is being managed by the Imperial Regional Water Management Group, consisting of elected representatives of the IID, County of Imperial, and local cities. The goal of the plan is to provide a strategic road map that defines a portfolio of water projects, demand management measures and policies intended to deliver a reliable water supply for municipal, commercial and industrial water users over a 37 year planning horizon from 2010 to 2047 (IID 2010). The IWRMP Plan describes the existing district supplies, including the facilities, entitlements and contracts that define what water is available to meet current and future demands and seeks to identify a Water Supply Portfolio of 100,000 acre-feet per year to meet future MCI and environmental water demands through When completed, the IRWMP will include recommendations for implementing various programs and projects including storing Colorado River water in the Salton Sea groundwater basin, developing local groundwater supplies, desalinating irrigation drainwater, reusing wastewater, and developing demand-management programs. Temporary Land Conversion Fallowing Policy (2012) On May 8, 2012, the IID adopted a Temporary Land Conversion Fallowing Policy, which addresses projects that will remove land from agricultural production on a long-term temporary basis. Because water demands for certain non-agricultural projects are typically less than that required for agricultural use; this reduced demand allows additional water to be made available for other users under IID's annual consumptive use cap. This conserved water can then be used to satisfy IID s conserved water transfer obligations and for environmental mitigation purposes. Certain non-agricultural projects temporarily remove land from agricultural production and the number of proposed non-agricultural projects is anticipated to increase as the economy of Imperial County diversifies and develops to address these new business opportunities (IID, 2012). If it appears to IID, that the proposed water usage for a non-agricultural project applying for water supply will require less water than Hudson Ranch Power II and Simbol Calipatria II Final EIR

29 4.15 Utilities and Services the historical water usage associated with the agricultural production on that land, IID will determine, in its sole discretion, that the proposed project is suitable for temporary land conversion fallowing to create conserved water for transfer, or environmental mitigation purposes. In this case, the water supply agreement for a non-agricultural project will include a temporary land conversion fallowing agreement, which requires that the project developer, lessee and landowner return the project land to agricultural production. WASTEWATER Imperial Public Health Department, Environmental Health and Consumer Protection Services The Public Health Department is responsible for issuance of sanitation permits for private on-site sewage disposal systems in the County. Coordination of site design for proposed Projects must occur with the Public Health Department to obtain final permits (County of Imperial Public Health Department 1999). Imperial County Land Use Ordinance, Division 10 Building, Grading and Sewage Regulations Chapter 13, Sanitation Permits, regulates the construction, relocation, and alteration of sewage disposal systems in the unincorporated areas of the County of Imperial. Standards for such systems described in this chapter must be met for a permit to be issued by the Public Health Department. County of Imperial General Plan The County of Imperial General Plan Geothermal/Alternative Energy and Transmission Element and the Water Element contain goals and objectives that relate to efficient use of the water supply. However, the General Plan does not include policies or programs specific to septic system activities or requirements. Table identifies applicable General Plan policies related to water supply and addresses the Projects consistency with the General Plan policies. TABLE HR-2 AND SMCP-2 PROJECTS CONSISTENCY WITH GENERAL PLAN UTILITY GOALS AND OBJECTIVES GENERAL PLAN POLICIES CONSISTENCY ANALYSIS GEOTHERMAL/ALTERNATIVE ENERGY AND TRANSMISSION ELEMENT Goal 3: Geothermal/alternative energy operations will be required to efficiently utilize water. Yes An SB 610 Water Supply Assessment (WSA) has been prepared for the proposed HR-2 and SmCP-2 Projects (Pangaea 2012). During construction the proposed Projects would utilize water from the IID obtained via water supply agreements, at a rate of 50,000 gallons/day. The WSA indicates that the combined operational IID water demands of the proposed HR-2 Project would be 3,940 AFY of water (1,200 AFY from the IID s O Lateral and 2,740 AFY from HR-2 Hudson Ranch Power II and Simbol Calipatria II Final EIR

30 4.15 Utilities and Services TABLE HR-2 AND SMCP-2 PROJECTS CONSISTENCY WITH GENERAL PLAN UTILITY GOALS AND OBJECTIVES GENERAL PLAN POLICIES CONSISTENCY ANALYSIS Plant steam condensate). The SmCP-2 Plant would require 800 AFY of water from the IID s O Lateral and additional water from HR-2 Plant steam condensate for operations. Objective 3.1: Maintain at least the present level of agricultural production while encouraging efficient water use. Yes The combined HR-2 and SmCP-2 Projects would require 2,000 AFY of IID water for operations and at least 2,740 AFY of steam condensate from the HR-2 plant. This water-efficient use of geothermal steam condensate for the required cooling tower makeup water, brine dilution water and process water reduces the proposed Projects reliance on external sources of water. At the time of the publication of the NOP, the agricultural fields on the Project sites site were fallow and not being irrigated The proposed Projects would temporarily convert 100 acres out of approximately 245-acre parcel to nonagricultural uses; the remaining 145 acres would remain available for agricultural use. Objective 3.3: Encourage the efficient utilization of water in geothermal/alternative energy operations, and foster the use of nonirrigation water by these industries. WATER ELEMENT WE Policy 1. Adequate Domestic Water Supply. The efficient regulation of land uses that economize on water consumption enhances equivalent dwelling unit demand for domestic water resources, and that makes available affordable resources for continued urban growth. Yes Yes As described in Goal 3 above, over 50% of the Projects operational water needs would be met from geothermal steam condensate. 1 See response for Goal 3, above. The WSA determined that there would be sufficient water available to meet both Projects demand through the year 2045 (i.e. throughout the 30-year life of each project). As described in Goal 3 above, over 50% of the Projects operational water needs would be met from HR-2 s geothermal steam condensate. This water efficient design reduces the proposed Projects reliance on external sources of water. Sources: County of Imperial 1993, 2006 While this Draft Environmental Impact Report (EIR) analyzes the Projects consistency with the County of Imperial General Plan pursuant to California Environmental Quality Act (CEQA) Guidelines, Section 1 See Tables 3-6 and 3-10 for HR-2 and SmCP-2 Operational Water Needs. Hudson Ranch Power II and Simbol Calipatria II Final EIR

31 4.15 Utilities and Services 15125(d), the County of Imperial Planning Commission will determine the Projects consistency with the General Plan IMPACTS AND MITIGATION MEASURES STANDARDS OF SIGNIFICANCE The impact analysis provided below is based on the following CEQA Guidelines, Appendix G. An impact is considered significant and would require mitigation if: 1. The project would exceed wastewater treatment requirements of the applicable RWQCB. 2. The project would require or result in the construction of new water or wastewater treatment facilities or expansion of existing facilities, the construction of which could cause significant environmental impact. 3. The project would require or result in the construction of new stormwater drainage facilities or expansion of existing facilities, the construction of which could cause significant environmental impact. 4. Sufficient water supplies would not be available to serve the project from existing entitlements and resources, or if it would require new or expanded entitlements. 5. The project would result in a determination by the wastewater treatment provider which serves or may serve the project that it does not have adequate capacity to serve the project s projected demand in addition to the provider s existing commitments. 6. The project would be served by a landfill without sufficient permitted capacity to accommodate the project s solid waste disposal needs. 7. The project would not comply with federal, state, and local statutes and regulations related to solid waste. ENVIRONMENTAL PROTECTION MEASURES Chapter 3 provides a complete list and descriptions of environmental protection measures (EPMs) that Hudson Ranch Power II, LLC and Simbol, Inc. have incorporated into the Projects to avoid or minimize impacts on all resources. The HR-2 EPMs that are proposed to minimize or avoid impacts to utilities and service systems are as follows: HR-2 EPM UTIL-1: Filter Cake Utilization. Filter cake would be recycled for beneficial use in cement and cement admixture. Before any filter cake material to be removed from the plant site, it would be sampled and laboratory-tested. Only when the results demonstrate the material to be Hudson Ranch Power II and Simbol Calipatria II Final EIR

32 4.15 Utilities and Services nonhazardous will it be recycled for beneficial use. Otherwise, it would be transported to an off-site disposal facility authorized to accept the waste. HR-2 EPM UTIL-2: Waste Disposal During Drilling Operations. A containment basin would be located on the drilling pad, and all used mud and cuttings would be contained in this basin until drilling operations are complete. HR-2 EPM UTIL-3: Waste Disposal After Drilling Operations. After drilling operations are complete, the mud and associated drilling liquids would be allowed to evaporate. The solids would be tested for ph, oil and grease, and metals, then removed and disposed of in a waste disposal facility authorized by the California RWQCB CRB to receive and dispose of these materials. HR-2 EPM UTIL-4: Solid Waste Disposal. Solid waste materials (trash) and construction waste would be deposited at an authorized landfill by a disposal contractor. HR-2 EPM UTIL-5: Sanitary Waste Disposal. Portable chemical sanitary facilities would be used by all personnel during construction. These facilities would be maintained by a local contractor. HR-2 EPM WQ-1: Water Conservation. Steam condensate would be used to supply approximately 98% of the cooling tower make-up water, which will minimize water demand from other sources. HR-2 EPM WQ-4: Stormwater Retention Basin and Berm. The plant site will be graded to direct surface water runoff toward a storm water retention basin, which will be surrounded by a berm to prevent overflow. The SmCP-2 EPMs that are proposed to minimize or avoid impacts to utilities and service systems are as follows: SMCP-2 EPM UTIL-1: Construction Wastes. Solid waste materials (trash) and construction waste would be deposited at an authorized landfill by a disposal contractor. Any petroleum hydrocarbon or hazardous wastes or empty containers/drums that may be generated during construction activities would be either recycled or managed as hazardous waste in conformance with applicable waste management and disposal requirements. Portable chemical sanitary facilities would be used by all personnel during construction. These facilities would be maintained by a local contractor. SMCP-2 EPM UTIL-2: Silica Management and Filter Cake Utilization. Iron-silica waste would be evaluated for use as a potential product stream. Before any filter cake material is removed from the plant site, it would be sampled and laboratory-tested. It will subsequently be either managed as a potential product recycled or transported to an off-site disposal facility authorized to accept the waste. Hudson Ranch Power II and Simbol Calipatria II Final EIR

33 4.15 Utilities and Services SMCP-2 WQ-1: Water Conservation. Use of steam condensate from HR-2 to minimize water demand from outside sources when possible. Water would be internally recycled to the extent practical. SMCP-2 EPM WQ 4: Storm Water Retention Basin. The plant site will be graded to direct uncontained surface water runoff toward a storm water retention basin. SMCP-2 EPM WQ 5: Storm Water Retention Basin Berm. The stormwater retention basin would be protected by a berm to prevent off-site flooding into the basin. METHODOLOGY Evaluation of potential water supply impacts of the proposed Projects was based on the water supply assessment prepared by Pangaea (Appendix I) and review of the County of Imperial General Plan and Land Use Ordinance. Evaluation of potential wastewater treatment impacts is based on review of the County of Imperial General Plan and Land Use Ordinance. Evaluation of potential impacts on electrical, natural gas, and telephone services resulting from the proposed Projects is based on consultation with the service providers and a review of California Energy Commission (CEC) policies, state standards, and the County of Imperial General Plan. The analysis focuses on the environmental impact associated with the provision of these services to the proposed Projects. HR-2 IMPACTS AND MITIGATION MEASURES Impact UTL-1: The HR-2 Project would not exceed wastewater treatment requirements of the applicable RWQCB. All wastewater, including aerated brine, cooling tower blowdown water, plant wash water, reject water from the potable water treatment system, stormwater, water from the oil/water separator and sanitary wastewater would be handled to ensure compliance with the wastewater treatment requirements of the RWQCB, CRB. Aerated brine, plant wash water, reject water from the potable water treatment system, and clean water from the oil/water separator would be discharged to the on-site brine pond for temporary storage until these liquids are either processed through the thickener and delivered to the main injection pumps or pumped to the plant aerated brine injection well for subsurface injection The brine pond would be constructed to meet RWQCB surface discharge requirements consistent with the Waste Discharge Order issued by the RWQCB CRB. Groundwater monitoring wells would be constructed adjacent to the brine pond in conformance with RWQCB requirements. Hudson Ranch Power II and Simbol Calipatria II Final EIR

34 4.15 Utilities and Services Sanitary wastewater would be treated to tertiary standards at an on-site treatment facility and injected into the geothermal reservoir via the aerated brine injection well, in conformance with the permit or other requirements of CDOGGR, the RWQCB CRB and the Class V injection well requirements of the Underground Injection Well program. The applicant would not use municipal wastewater treatment services and would not discharge wastewater to land except in conformance with the WDO issued by the RWQCB CRB. Therefore, the Project would not exceed California RWQCB CRB requirements, resulting in a less than significant impact under this criterion. Mitigation Measures: IMPACT UTL-2: None required. The HR-2 Project would result in the construction of a new on-site wastewater treatment facility. However, it would not require construction of new municipal water or wastewater treatment facilities or expansion of existing facilities which could cause significant environmental impact. During construction, the proposed HR-2 Project would need approximately acre-feet of water for geothermal well drilling, plant construction, road grading, and dust control, which would be obtained from IlD's "O" Lateral (or the N Lateral in case of a long outage on the O Lateral). During operations, the primary water source for cooling water would be geothermal steam condensate; however, 1,200 acre-feet per year of water would be obtained from IID's "O" Lateral for brine dilution, supplemental cooling tower water makeup, and other plant uses such as the potable water system. Because this remaining water would be supplied via IID's existing "O" Lateral (or the N Lateral in case of a long outage on the O Lateral) and treated onsite for use as potable water, new or expanded municipal water facilities would not be required for the Project. As discussed above, the Project would treat all wastewater at an on-site wastewater treatment facility and would not use municipal wastewater treatment facilities. Portable restrooms would be maintained during construction and removed after the completion of construction, and bottled potable water would be brought to the Project site during construction for worker consumption. According to EPM UTIL-5, a local contractor would maintain these facilities. Therefore, the project would not require new or expanded municipal wastewater facilities. A less than significant impact would result under this criterion. Mitigation Measures: None required. Hudson Ranch Power II and Simbol Calipatria II Final EIR

35 4.15 Utilities and Services Impact UTL-3: The HR-2 Project would require the construction of new on-site stormwater drainage facilities, however, this Project would not require construction of municipal stormwater and drainage facilities or expansion of existing facilities of which could cause significant environmental impact. As part of the HR-2 Project, the applicant would construct a new on-site stormwater retention basin and berm per HR-2 EPM WQ-4. Stormwater runoff would be collected in the stormwater retention basin; therefore, no new or expanded municipal stormwater drainage facilities would be required for operation of the Project. A less than significant impact would result under this criterion. Mitigation Measures: Impact UTL-4: None required. There would be sufficient water supplies available to serve the HR-2 Project from existing entitlements and resources, and new or expanded entitlements would not be required. A Water Supply Assessment (WSA) was prepared for the proposed Project (Pangaea 2012). The WSA was prepared as a requirement of California law under SB 610 (Chapter 643, Statutes of 2001). According to the WSA, past agricultural use on the shared site has averaged 804 acre-feet per year; however, the site has not been in full agricultural production. If the site were in full agricultural production, the allowed water use in an SDI year (5.25 acre-feet per acre) would be limited to 1,501 acre-feet. The HR-2 Project, combined with the SmCP-2 Project, would use a total of 2,000 AFY of water from IID for industrial purposes (1,200 AFY and 800 AFY, respectively). Although this amount exceeds the amount of water that would be authorized for agricultural purposes in an SDI year, the IID has the authority to enter into water use agreements with industrial applicants through its IWSP. With a water use agreement from the IID through the IWSP, the Project would have enough water reserved for its use from existing sources and would not cause new or expanded municipal water requirements. The HR-2 plant would also use available steam condensate for the required cooling tower makeup water, brine dilution water and process water which would minimize water demand from outside sources. Water would be internally recycled to the extent practical (EPM HR-2 WQ-1). This water efficient design reduces the proposed Project s reliance on external sources of water. Therefore, a less than significant impact is identified under this criterion. Mitigation Measures: None required. Hudson Ranch Power II and Simbol Calipatria II Final EIR

36 4.15 Utilities and Services Impact UTL-5: The HR-2 Project would not result in a determination by the wastewater treatment provider that serves or may serve the Project that it does not have adequate capacity to serve the Project s projected demand in addition to the provider s existing commitments. During construction, portable restrooms would be used per EPM UTIL-5, and no wastewater or sewer facilities would be constructed to serve the operational needs of the proposed Project. As discussed above, during operations, sanitary wastewater would be treated to tertiary standards at an on-site wastewater treatment facility and injected into the geothermal reservoir through the aerated brine injection well, in conformance with the permit or other requirements of CDOGGR, the RWQCB CRB and the Class V injection well requirements of the Underground Injection Well program.. Because the Project would not use municipal wastewater treatment facilities, the Project would have no impact on the capacity of municipal wastewater treatment providers. Therefore, no impact would result under this criterion. Mitigation Measures: Impact UTL-6: None required. The HR-2 Project would be served by landfills with sufficient permitted capacity to accommodate the Project s solid waste disposal needs. The total amount of solid waste to be generated by construction activities has been estimated to be 2,750 tons (2.5 lbs per s.f.) which is similar to that generated for normal commercial construction. Although the number of tons per cubic yard for construction waste varies by material, CalRecycle estimates that there are 2,400 pounds in 1 cubic yard of construction debris (asphalt or concrete, loose) (CalRecycle 2009). Therefore, because 2,750 tons is equivalent to 5.5 million pounds, 5.5 million pounds is roughly equivalent to 1,986 cubic yards (5.5 million / 2,400 = 2,292). The Allied Imperial Landfill and Niland Solid Waste Facility have an estimated 1,901,305 cubic yards and 44,053 cubic yards of remaining capacity, respectively, which would be adequate capacity to serve the Project during construction. The solid contents remaining in each geothermal well pad containment basin, typically consisting of non-hazardous, non-toxic drilling mud and rock cuttings, would be tested as required by the California RWQCB CRB. The solids would then be removed and disposed of in a waste disposal facility authorized by the California RWQCB CRB to accept such wastes (EPM UTIL-2 and UTIL-3). During operations, it is estimated that the HR-2 geothermal facility could produce approximately 25 tons of silica filter cake per day. After the filter cake has been Hudson Ranch Power II and Simbol Calipatria II Final EIR

37 4.15 Utilities and Services tested to determine that it is non-hazardous, it could then be recycled for beneficial use in cement and cement admixture (EPM UTIL-1). Otherwise, it would be transported to an off-site disposal facility authorized to accept Class II waste (if nonhazardous) or Class I waste (if determined hazardous). The small quantities of office waste and general refuse generated during operations would be removed by a local sanitation service. Hazardous wastes that would be generated during operations, in addition to some of the filter cake waste, would include paint, spent solvents, used oil, laboratory waste, brine pond solids and geothermal scale. Hazardous wastes would be either recycled or managed and disposed of properly in licensed Class I or Class II waste disposal facilities, such as the Kettleman Hills Landfill in Kettleman City, California and/or the South Yuma County Landfill (SYCL) in Arizona, that are authorized to accept the waste. According to Edward McGraskey, sales manager at the South Yuma County Landfill, this landfill accepts, on average, 1,200 tons of waste per day, and has at least 50 years of capacity at that rate (McGraskey, E. 2012). Thus, the South Yuma County Landfill alone would be able to accept the silica filter cake waste generated by the HR-2 Project over the life of the project. Because waste would be beneficially recycled to the extent practicable or would be disposed of in landfills with adequate capacity (EPM UTIL-4), there would be a less than significant impact under this criterion. Mitigation Measures: Impact UTL-7: None required. The HR-2 Project would comply with federal, state, and local statutes and regulations related to solid waste. As discussed above, solid waste would be generated during construction and operation. Some construction waste would be recycled prior to the remainder of the waste being disposed of at the local landfill. During Project operations, the filter cake would be sampled and laboratory-tested to ensure that the material is nonhazardous, and then the non-hazardous material would be trucked off-site and recycled for beneficial use. Any hazardous filter cake materials would be delivered to a Class I landfill or a Class II landfill authorized to accept the waste for proper disposal. One truck per day, 20 cubic yards in size, would be required for off-site removal of the filter cake during Project operations. Disposal of solid/hazardous wastes generated during construction and power plant operations would be in compliance with local federal, state, and County regulations. HR-2 EPM UTIL-1 would ensure that filter cakes are recycled for beneficial use in cement or cement admixture only after tests confirm that it is Hudson Ranch Power II and Simbol Calipatria II Final EIR

38 4.15 Utilities and Services nonhazardous. HR-2 EPM UTIL-1, UTIL-3, and UTIL-4 would ensure that all solid waste materials, including mud, cuttings, trash, and construction waste are disposed of in an authorized facility. Therefore, a less than significant impact would result under this criterion. Mitigation Measures: None required. SMCP-2 IMPACTS AND MITIGATION MEASURES Impact UTL-1: The SmCP-2 Project would not exceed wastewater requirements of the applicable RWQCB. All wastewater, including cooling tower blowdown water, plant wash water, potable water system reject water, stormwater and sanitary wastewater would be handled to ensure compliance with the wastewater treatment requirements of the RWQCB, CRB. Plant wash water and water system reject water would be discharged to the on-site brine pond for temporary storage until these liquids are either processed through the HR2 plant thickener and delivered to the main injection pumps or pumped to the HR2 plant aerated brine injection well for subsurface injection. The brine pond would be constructed to meet RWQCB surface discharge requirements consistent with the Waste Discharge Order issued by the RWQCB CRB. Groundwater monitoring wells would be constructed adjacent to the brine pond in conformance with RWQCB requirements. Sanitary wastewater would be treated to tertiary standards at the on-site treatment facility and injected into the geothermal reservoir via the HR2 aerated brine injection well. CP2 would not use municipal wastewater treatment services and would not discharge wastewater to land except in conformance with the WDO issued by the RWQCB CRB. Therefore, the Project would not exceed California RWQCB CRB requirements, resulting in a less than significant impact under this criterion. Mitigation Measures: IMPACT UTL-2: None required. The SmCP-2 Project would not require construction of new municipal water or wastewater treatment facilities or expansion of existing facilities of which could cause significant environmental impact. As discussed under Impact UTL-1, wastewater from the SmCP-2 plant would be treated prior to injection by HR2 for repressurization of the geothermal reservoir. In addition, water obtained from IID's "O" Lateral (or the N Lateral in case of a long outage on the O Lateral) would be treated on site to produce potable water. Because the Project would not use municipal water or wastewater facilities, no Hudson Ranch Power II and Simbol Calipatria II Final EIR

39 4.15 Utilities and Services new or expanded municipal facilities would be required. A less than significant impact would result under this criterion. Mitigation Measures: Impact UTL-3: None required. The SmCP-2 Project would not require or result in the construction of new stormwater drainage facilities or the expansion of existing facilities, the construction of which could cause significant environmental impact. As part of the SmCP-2 Project, the applicant would construct a stormwater retention basin and berm per SmCP-2 EPMs WQ-4 and WQ-5. Stormwater runoff would be collected in the Project s stormwater retention basin; therefore, no new or expanded municipal stormwater drainage facilities would be required for operation of the Project. A less than significant impact would result under this criterion. Mitigation Measures: Impact UTL-4: None required. There would be sufficient water supplies available to serve the SmCP-2 Project from existing entitlements and resources, and new or expanded entitlements would not be required. According to the WSA, past agricultural use on the Project site has averaged 804 acre-feet per year; however, the site has not been in full agricultural production. If the site were in full agricultural production, the annual water use in an SDI year (5.25 acre-feet per acre) would be 1,501 acre-feet. The SmCP-2 Project proposes to use a total of 800 AFY of water from IID for industrial use. The SmCP-2 Project, combined with the HR-2 Project, as discussed under HR-2 Impact UTIL-4, would use a total of 2,000 AFY of water from IID for industrial purposes (800 AFY and 1,200 AFY, respectively). Although this amount exceeds the amount of water that would be authorized for agricultural purposes in an SDI year, the IID has the authority to enter into water use agreements with industrial applicants through its IWSP. With a water use agreement from the IID through the IWSP, the Project would have enough water reserved from existing sources for its use and would not cause new or expanded municipal water requirements. The SmCP-2 plant would also use steam condensate from the HR-2 facility for the required cooling tower makeup water, brine dilution water and process water which would minimize water demand from outside sources when possible. Water would be internally recycled to the extent practical (EPM SmCP-2 WQ-1). This water efficient design reduces the proposed Project s reliance on external sources of water. Therefore, a less than significant impact is identified under this criterion. Hudson Ranch Power II and Simbol Calipatria II Final EIR

40 4.15 Utilities and Services Mitigation Measures: Impact UTL-5: None required. The SmCP-2 Project would not result in a determination by the wastewater treatment provider that serves or may serve the Project that it does not have adequate capacity to serve the Project s projected demand in addition to the provider s existing commitments. As discussed under SmCP-2 Impact UTL-1, wastewater from the SmCP-2 plant would be treated on site prior to injection by HR2 for repressurization of the geothermal reservoir. Because the Project would not use municipal wastewater treatment facilities, the Project would have no impact on the capacity of municipal wastewater treatment providers. Therefore, no impact would result under this criterion. Mitigation Measures: Impact UTL-6: None required. The SmCP-2 Project would be served by landfills with sufficient permitted capacity to accommodate the Project s solid waste disposal needs. The total amount of solid waste to be generated by construction activities associated with the SmCP-2 has been estimated at 1,800 tons (2.5 lbs per s.f. for 33 acres), similar to that generated for normal commercial construction. Although the number of tons per cubic yard for construction waste varies by material, CalRecycle estimates that there are 2,400 pounds in 1 cubic yard of construction debris (asphalt or concrete, loose) (CalRecycle 2009). Therefore, because 1,800 tons is equivalent to 3.6 million pounds, 3.6 million pounds is roughly equivalent to 1,500 cubic yards (3.6 million / 2,400 = 1,500). The Allied Imperial Landfill and Niland Solid Waste Facility have an estimated 1,901,305 cubic yards and 44,053 cubic yards of remaining capacity, respectively, which would be adequate capacity to serve the Project during construction. During operations, it is estimated that the SmCP-2 plant could generate about 64,800 metric tons per year of iron-silica filter cake material at the full 5,200 gallon per minute (gpm) geothermal brine flow rate. After the filter cake has been tested to determine that it is non-hazardous, the iron-silica stream may be converted to a product stream(s) after plant operations begin (EPM UTIL-2). Otherwise, it would be transported to an off-site disposal facility authorized to accept Class II waste (if nonhazardous) or Class I waste (if determined hazardous). The small quantities of office waste and general refuse generated during operations would be removed by a local sanitation service. Hazardous wastes that Hudson Ranch Power II and Simbol Calipatria II Final EIR

41 4.15 Utilities and Services would be generated during operations, in addition to some of the filter cake waste, would include paint, spent solvents, used oil, laboratory waste, brine pond solids and geothermal scale. Hazardous wastes would be either recycled or managed and disposed of properly in licensed Class I or Class II waste disposal facilities, such as the Kettleman Hills Landfill in Kettleman City, California and/or the South Yuma County Landfill (SYCL) in Arizona, that are authorized to accept the waste. According to Edward McGraskey, sales manager at the South Yuma County Landfill, this landfill accepts, on average, 1,200 tons of waste per day, and has at least 50 years of capacity at that rate (McGraskey, E. 2012). Thus, the South Yuma County Landfill alone would be able to accept the silica filter cake waste generated by the SmCP-2 Project over the life of the project. Because waste would be converted to a product stream to the extent practicable, or would be disposed of in landfills with adequate capacity there would be a less than significant impact under this criterion. Mitigation Measures: Impact UTL-7: None required. The SmCP-2 Project would comply with federal, state, and local statutes and regulations related to solid waste. As discussed above, solid waste would be generated during construction and operation. Some construction waste would be recycled prior to the remainder of the waste being disposed of at the local landfill. Disposal of solid/hazardous wastes generated during construction and power plant operations would be in compliance with local federal, state, and County regulations. SmCP-2 EPM UTIL-2 would ensure that the iron-silica filter cake is recycled for beneficial use only after tests confirm that it is nonhazardous. SmCP-2 EPM UTIL-1 would ensure that all solid waste materials, trash, and construction waste are disposed of in an authorized facility. Therefore, a less than significant impact would result under this criterion. Mitigation Measures: None required REFERENCES CalRecycle Facility/Site Summary Details: Kettleman Hills (B18 Nonhaz Codisposal (16-AA-0023) Available online: Accessed June 27, Hudson Ranch Power II and Simbol Calipatria II Final EIR

42 4.15 Utilities and Services. 2011a. Facility/Site Summary Details: Niland Solid Waste Site (13-AA-0009). Available online: Accessed July 28, b. Niland Solid Waste Site (13-AA-0009). Permit - A021 - Solid Waste Facility Permit Available online: Accessed July 28, c. Facility/Site Summary Details: Allied Imperial Landfill (13-AA-0019). Available online: Accessed July 28, d. Documents: Allied Imperial Landfill (13-AA-0019). Available online: Accessed July 28, Construction/Demolition and Inert Debris Tools and Resources. Available online: Accessed June 7, County of Imperial County of Imperial General Plan Geothermal/Alternative Energy and Transmission Element. El Centro, California County of Imperial Public Health Department Sewage System Permitting. Available online at: Accessed May 18, County of Imperial General Plan Water Element. El Centro, California. Imperial Irrigation District (IID) IID Temporary Land Conversion Policy IID Integrated Water Management Plan IID Interim Water Supply Policy for Non-Agricultural Projects. September 29, Page 1. McGraskey E Personal Communication with Edward McGraskey, South Yuma County Landfill and Claire Hodgkins, Planner, Ecology and Environment, August 8, Pangaea Land Consultants, Inc Hudson Ranch Power II Geothermal Project and Simbol Calipatria Plant II, SB 610 Combined Water Supply Assessment. March 15, South Yuma County Landfill (SYCL) A Locally Owned and Operated CERCLA Approved Waste Disposal Facilty EPA Federal and State Permit # AZR Available online: Accessed June 27, Hudson Ranch Power II and Simbol Calipatria II Final EIR

43 4.16 Climate Change and Greenhouse Gases 4.16 CLIMATE CHANGE AND GREENHOUSE GASES This section of the Draft Environmental Impact Report (EIR) analyzes the potential impacts to climate change associated with the Hudson Ranch Power II Geothermal Plant (HR-2) and Simbol Calipatria Plant II (SmCP-2) (proposed Projects). The following subsections discuss existing conditions for the setting in which the proposed Projects are located, including a discussion of the most prevalent recognized greenhouse gases (GHG) as well as applicable guidelines and regulations. Scoping Issues Addressed During the scoping period for the proposed Projects, two public scoping meetings were conducted and written comments were solicited from both agencies and the public. Comment letters received during the scoping period indicated public concerns with respect to potentially significant GHG emissions from the proposed construction and operation of HR-2 and the SmCP-2 Projects. The public requested quantification and evaluation of the proposed Projects GHG emissions from sources, such as power generation facilities, truck and employee traffic, landscaping operational equipment, steam blows, and diesel generators. In response to public comments, GHG emissions estimates, presented in this section, were prepared for all major construction and operational sources. Applicant s Reports and Survey Results Information used in preparing this section and in the evaluation of potential impacts to climate change was derived from GHG estimates for construction and operational processes of the HR-2 and SmCP-2 Projects prepared by Environmental Management Associates (EMA) in March and April 2012 (Appendix C). These documents are contained within the attached CD EXISTING SETTING REGIONAL SETTING The proposed Projects are located in the County of Imperial in southeastern California. The County of Imperial is one of the hottest and driest parts of California, and is located in a region best described as a low latitude desert characterized by hot, dry summers and relatively mild winters. Average annual precipitation is less than 3 inches. Daily average temperature in winter ranges between 65 and 75ºF. During winter months it is not uncommon to record maximum temperatures of up to 80ºF. Summers are extremely hot with daily average temperature ranges between 104 and 115ºF, with maximum temperatures up to 120ºF (ICAPCD 2010). During the summer, due to the presence of the Pacific high-pressure zone off the coast of California, a thermal trough develops over California s southeast desert region. The intensity and orientation of the trough varies from day to day. Although the mountainous terrain surrounding the Imperial Valley inhibits air circulation, the influence of the trough does permit some inter-basin exchange of air with coastal locations Hudson Ranch Power II and Simbol Calipatria II Final EIR

44 4.16 Climate Change and Greenhouse Gases through the mountain passes. Relative humidity in the summer is very low, averaging 30 to 50 percent in the early morning and 10 to 20 percent in the afternoon. During the hottest part of the day, a relative humidity level below 10 percent is common (ICAPCD 2010). However, the effect of extensive agricultural operations in the widely-irrigated Imperial Valley tends to increase local humidity. The prevailing weather conditions promote intense heating during the day in summer, with marked cooling at night. The wind direction follows two seasonal patterns. During the fall, winter, and spring, regional winds tend to come from the northwest. These originating prevailing winds are known to be from the Los Angeles area. During part of the spring and summer, the County of Imperial experiences occasional periods of extremely high wind speeds; wind statistics indicate prevailing winds are from the west-northwest through southwest, and a secondary flow maximum from the southeast is also evident (ICAPCD 2010). Project Sites and Adjacent Areas The site of the proposed Projects is located in a rural area of unincorporated County of Imperial. The County of Imperial is entirely land-locked with no direct access to coastal areas. The proposed power plant site, the individual geothermal wells, and the proposed mineral extraction plant would be located in areas designated and zoned for agricultural use. However, the general climactic conditions of the proposed Project area are arid and naturally inclined towards desertification. Climate Change and Greenhouse Gases Climate change refers to any significant change in measures of climate (e.g., temperature, precipitation, or wind) that lasts for an extended period. Climate change may result for a variety of reasons. Natural factors, such as changes in the sun s intensity or Earth s orbit around the sun, can affect climate change. In addition, natural processes within the climate system, such as changes in ocean circulation and human activities that change the atmosphere s composition and the land surface (e.g., deforestation, reforestation, urbanization, and desertification) can effect change. Global warming is an average increase in the temperature of the atmosphere near the Earth s surface and in the troposphere, which can contribute to changes in global climate patterns. Global warming can occur from a variety of causes, both natural and human. GHG permits solar radiation to pass through the earth s atmosphere but prevent heat from escaping, resulting in the atmospheric warming commonly known as the greenhouse effect. GHGs are produced by both natural and anthropogenic (man-made) means, including industrial activity, energy production, and combustion associated with motor vehicle use. Certain GHGs occur naturally and help regulate the earth s temperature. However, research indicates that, since the advent of the Industrial Revolution, human activity has resulted in an elevation of the concentration of some of these gases in the atmosphere. GHGs include: carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), sulfur hexafluoride (SF6), and other fluorinated gases. Emissions of GHGs are typically expressed in terms of CO2 equivalents (CO2e), where the potential of each gas to increase heating in the atmosphere is expressed as a multiple of the heating potential of CO2. The Hudson Ranch Power II and Simbol Calipatria II Final EIR

45 4.16 Climate Change and Greenhouse Gases California Air Resources Board (CARB) has indicated that almost 90 percent of the total GHG emissions in California are in the form of CO2 (CARB 2008). Converting all GHG source emissions into equivalent units allows for a comparison between all emission sources based on their global warming potential (GWP). The GWPs of CO2, CH4, and SF6 are 1, 23, and 23,000, respectively. For example, a pound of CH4 emitted to the atmosphere has 23 times the relative impact as a pound of CO2. SF6 is one of the most potent GHGs as one pound emitted has the same relative impact as 23,000 pounds of CO2 (or over ten metric tonnes). Potential Effects of Global Climate Change In 2008, Governor Schwarzenegger issued Executive Order S-13-08, directing the California Natural Resources Agency (CNRA) to determine how state agencies can respond to the challenges of global climate change. In response, the CNRA worked with several state agencies to draft the 2009 California Climate Adaptation Strategy (CCAS). The following sections provide a summary of the potential effects of global climate change to the state as discussed in the CCAS. Temperature and Precipitation As GHGs remain in the atmosphere for decades, temperature changes over the next 30 to 40 years are already largely determined by past emissions. By 2050, temperatures are projected to increase by an additional 1.8 to 5.4 degrees Fahrenheit ( F) (CNRA 2009). California would likely continue to have a Mediterranean climate with relatively cool, wet winters and dry, hot summers. However, average temperature increase would be more pronounced during the summer than the winter, and inland areas would experience more pronounced warming than coastal regions. In addition, heat waves would increase in frequency and intensity, spreading over larger areas. Patterns of precipitation are anticipated to change over the course of the century, with the majority of precipitation modeled indicating a small to significant (12 to 35 percent) overall decrease in precipitation by mid-century (CNRA 2009). Due to increasing temperatures, more precipitation would fall as rain than snow. This would affect California s supply of drinking water, now largely produced throughout the year as runoff from melting snow, as well as lead to a potential for more frequent flood events due to a sharp increase in runoff. More frequent flood events would increase stress on local and state infrastructure (e.g., drainage systems, sewer systems, roads) and lead to an increase in property damage. Furthermore, changes in precipitation may lead to increased periods of drought, negatively affecting native ecosystems. Sea-Level Rise and Effects on Oceans Research indicates that sea levels rose by as much as seven inches over the course of the twentieth century, and are anticipated to rise up to 55 inches by the end of this century (CNRA 2009). Furthermore, research indicates that, even if emissions were substantially lowered, sea levels would continue to rise, prompting adaptation as the best means of dealing with this potential impact of global climate change (CNRA 2009). Hudson Ranch Power II and Simbol Calipatria II Final EIR

46 4.16 Climate Change and Greenhouse Gases Sea level rise has the potential to negatively affect coastal wetlands and marshes through inundation. This would not only have a negative effect on these specially adapted habitats, but salt water intrusion into fresh water aquifers located along coastal regions could also potentially damage agricultural activities that rely upon these resources. Furthermore, as coastal wetlands and marshes act to temper storm events, loss of these habitats would result in an increase in storm intensity, depleting beaches and causing a potential increase in property damage. In addition to a rise in sea levels, increasing levels of CO2 in the atmosphere may result in a decrease in the ph of the oceans, leading to acidification. As natural carbon sinks, oceans absorb CO2 from the atmosphere. As the CO2 content of oceans increases, oceans become increasingly acidic. Increased acidity interferes with the ability of ocean dwelling invertebrates to build their shells, negatively affecting shellfish stocks and the other species that rely upon them for food. Effects to Biodiversity and Habitat Climate change may have a negative effect on diverse types of ecosystems. As temperatures increase and precipitation patterns change, plant and animal species adapted to specific conditions could be negatively affected. Both plant and animal species may have to shift their geographic range to adapt to the change in climate. If species are unable to adapt in their existing communities or shift their ranges if appropriate habitat is available, they may face the threat of local extirpation or extinction. Furthermore, shifts in species range increases the likelihood of habitat fragmentation as plant and animal communities become isolated. In addition, ecosystems would become increasingly more vulnerable to encroachment from invasive species. As climactic conditions shift, changes to precipitation and wildfire patterns may emerge. Many species in California are adapted to experience regular fire events. However, increases in temperature may result in an increase in the frequency and intensity of fires, interfering with the ability of native plant species to regerminate between events (CNRA 2009). Similarly, changes to precipitation patterns can lead to increased periods of drought. This would negatively impact native riparian habitats as well as leave affected areas vulnerable to colonization by invasive species. Overall, climate change has the potential for very negative effects to biodiversity. Research indicates that between 20 and 30 percent of species assessed may be at risk of extinction due to climate change within the next century if global mean temperatures increase by more than 2 to 3 degrees Celsius relative to pre-industrial levels. Agriculture and Forestry The State of California hosts some of the most productive agricultural regions on the planet, including the Imperial Valley where the proposed Projects are located. Shifts in climate will impact the ability of perennial crops (e.g., grapes, fruit, nuts) to produce substantial, high-quality yields. Sea level rise, changes in growing season length, reduction in chilling hours, variation in the amount of precipitation, and resulting Hudson Ranch Power II and Simbol Calipatria II Final EIR

47 4.16 Climate Change and Greenhouse Gases effects to water supply will affect crop and livestock productivity which, in turn, will have a direct impact on food supplies. The range of forest lands would likely shift in response to climate change. Temperature rise may make current forest ranges inhospitable, expand insect populations resulting in increased tree mortality, and allow for colonization of invasive, non-native species. In addition, an increase in the occurrence and intensity of wildfire due to climate change would negatively affect forests. Wildfire occurrence statewide could increase from 57 percent to 169 percent by 2085, and by more than 100 percent in most northern California forests (CNRA 2009). Human Health and Social Impacts Climate change may result in increased public health risks. Risks include an increase in mortality and morbidity due to heat-related illness, as well as a rise in respiratory illness due to increased air quality problems exacerbated by higher temperatures. Shifts in plant species habitat resulting from increased temperatures and changes in precipitation may also lead to changes in the timing and duration of allergies, as well as the introduction of new infectious diseases associated with the colonization of new habitat by disease vectors such as non-native animals and insects. Those most at risk to suffering the negative effects of climate-related illness are the elderly, chronically and mentally ill, infants, and the economically disadvantaged. Climate change could have negative consequences to the state s economy. Increased rainfall would result in stress to reservoirs and can cause flooding, resulting in damage to transmission lines, water and wastewater treatment facilities, and flood water control facilities, including culverts and canals. In addition, increased rainfall and flooding, drought, and wildfire would negatively affect highways, airport runways, and railways. Sea level rise has the potential to negatively affect infrastructure such as coastal highways, sea ports, and most of California s major airports, all of which are located on or near coastal plains. The economic cost associated with repair, replacement, or relocation of these facilities would likely be in the tens of billions of dollars. Greenhouse Gas Inventories A statewide GHG inventory for California compiled by CARB for the years 2000 through 2008 is presented in Table GHG emissions are identified in terms of CO2e and expressed in the millions of metric tons. As shown in the table, emissions are largely the product of the combustion of fossil fuels associated with industrial-, transportation-, and energy production-related uses. Hudson Ranch Power II and Simbol Calipatria II Final EIR

48 4.16 Climate Change and Greenhouse Gases TABLE CALIFORNIA GREENHOUSE GAS INVENTORY FOR ACTIVITY GHG EMISSIONS (million metric tons CO 2e) Transportation Electrical Power Generation Commercial And Residential Industrial Recycling And Waste Agriculture Forestry Total Gross Emissions Forestry Net Emissions Total Net Emissions Source: CARB 2010 Notes: Million tonnes of CO2e (based upon IPCC Second Assessment Report s Global Warming Potentials). 1 Reflects use of updated USEPA models for determining emissions from livestock and fertilizers REGULATORY SETTING FEDERAL AND STATE The U.S. Environmental Protection Agency (EPA) has not traditionally regulated the emission of GHGs, as this activity was determined to fall outside the scope of the Clean Air Act (CAA) (42 United States Code [U.S.C.] 85 et seq.) However, in 2007, in Massachusetts v. Environmental Protection Agency (549 U.S. 497), the U.S. Supreme Court ruled that GHGs are pollutants covered under the CAA and that EPA must determine whether emissions of GHGs from new motor vehicles represent a threat to public health. On December 7, 2009, the EPA Administrator signed an Endangerment Finding stating that current and projected concentrations of GHGs threaten the public health and welfare, as well as a Cause of Contribute Finding stating that the combined emissions GHGs from new motor vehicles and motor vehicle engines contribute to GHG pollution that threatens the public health and welfare. The final rule was published in the Federal Register on December 15, While these findings do not impose any requirements on industry, they are a prerequisite to the finalizations of the EPA s proposed GHG emission standards for light-duty vehicles that were jointly proposed by EPA and the Department of Transportation s National Highway Safety Administration on September 15, On March 10, 2009, in response to the fiscal year 2008 Consolidated Appropriations Act (H.R. 2764; Public Law ), EPA proposed a rule that requires mandatory reporting of GHG emissions from large sources in the United States. On September 22, 2009, the Final Mandatory Reporting of Greenhouse Gases Rule was signed, and the Rule was published in the Federal Register on October 30, The rule Hudson Ranch Power II and Simbol Calipatria II Final EIR

49 4.16 Climate Change and Greenhouse Gases became effective on December 29, The rule will collect accurate and comprehensive emissions data to inform future policy decisions. GHG emissions from largest stationary sources are also covered by the federal Prevention of Significant Deterioration (PSD) and Title V Operating Permit Programs. In May 2010, the EPA issued the GHG Tailoring Rule, which establishes an approach to permitting GHG emissions that focuses initially on the largest industrial sources. Currently, new facilities with GHG emissions of at least 100,000 tons per year CO2e and existing facilities with the same emissions levels and making changes that would increase GHG emissions by at least 75,000 tons per year CO2e are required to obtain PSD permits. Facilities that must obtain a PSD permit to cover other regulated pollutants must also address GHG emissions increases of 75,000 tons per year CO2e or more. New and existing sources with GHG emissions above 100,000 tons per year CO2e must also obtain operating permits (USEPA 2010). California Global Solutions Warming Act of 2006 (Assembly Bill 32) AB 32 was signed into law by Governor Schwarzenegger in 2006 and required CARB to adopt statewide limits on GHG emissions by January 1, 2008 that would reduce GHG emissions to 1990 levels by In addition, AB 32 required CARB to: Identify the 1990 statewide level of GHG emissions to serve as the emissions limit to be achieved by 2020 (Health and Safety Code [HSC] 38550); Develop a scoping plan that would identify the best method for reaching the 2020 limit (HSC 38561); Adopt a regulation requiring the mandatory reporting of GHG emissions (HSC 38530); Adopt regulations governing discrete early actions that could be enforceable on or before January 1, 2010 (HSC ); Ensure that early, voluntary reductions receive appropriate credit in the implementation of AB 32 (HSC 38562(b)(3)); Convene an Environmental Justice Advisory Committee to advise the Board in developing the Scoping Plan and any other pertinent matter in implementing AB 32 (HSC 38591); and Appoint an Economic and Technology Advancement Advisory Committee to provide recommendations for technologies, research, and greenhouse gas emission reduction measures (HSC 38591). To meet the requirements of AB 32, in December 2007, CARB approved a 2020 emission limit of 427 million metric tons of CO2e of GHGs and adopted a regulation requiring the largest industrial sources in the state to report and verify their GHG emissions. CARB also identified nine discrete early action measures Hudson Ranch Power II and Simbol Calipatria II Final EIR

50 4.16 Climate Change and Greenhouse Gases that would regulate GHG emissions from landfills, motor vehicle fuels, refrigerants in cars, tire pressure, port operations and other sources including ship electrification at ports and reduction of high GWP gases in consumer products (CARB 2011). In October 2008, CARB released the Climate Change Proposed Scoping Plan (AB 32 Scoping Plan) evaluating GHG impacts and proposing strategies the state would use to reduce GHG emissions as required by AB 32. The AB 32 Scoping Plan was approved by CARB in December 2008 and includes the main strategies the state will use to reduce GHGs. Actions to reduce the emission of GHGs that are included in the AB 32 Scoping Plan include direct regulation of GHG emissions, alternative compliance mechanisms, monetary and non-monetary incentives, voluntary actions, market-based mechanisms such as a cap-and-trade system, and an AB 32 program implementation regulation to fund the program (CARB 2011). Executive Order S-3-05 Governor Schwarzenegger issued Executive Order S on June 1, 2005, mandating a reduction of GHG emissions to year 2000 levels by 2010, 1990 levels by 2020, and levels 80 percent below 1990 levels by The second goal of Executive Order S was included as a part of AB 32; however, the third goal, an emissions reduction target for 2050, remains in effect subject to repeal of the Executive Order. Renewables Portfolio Standard California s Renewables Portfolio Standard (RPS) was established under Senate Bill (SB) 1078 in The RPS requires all retail electric service suppliers to increase procurement of power from eligible renewable energy resources by at least 1 percent of their retail sales annually, until they reach a total of 20 percent by In 2006, SB 1078 was passed to help accelerate the implementation of the RPS by introducing tradable renewable energy credits as an incentive towards accomplishing the objectives of SB On November 17, 2008, Governor Arnold Schwarzenegger signed Executive Order S requiring that "...[a]ll retail sellers of electricity shall serve 33 percent of their load with renewable energy by 2020." The following year, Executive Order S directed the California Air Resources Board, under its AB 32 authority, to enact regulations to achieve the goal of 33 percent renewables by In the ongoing effort to codify the 33 percent by 2020 goal, SBX1-2 was signed by Governor Edmund G. Brown, Jr., in April In his signing comments, Governor Brown noted that "This bill will bring many important benefits to California, including stimulating investment in green technologies in the state, creating tens of thousands of new jobs, improving local air quality, promoting energy independence, and reducing greenhouse gas emissions." This new RPS preempts the California Air Resources Board's 33 percent Renewable Electricity Standard and applies to all electricity retailers in the state including publicly owned utilities, investor-owned utilities, electricity service providers, and community choice aggregators. All of these entities must adopt the new Hudson Ranch Power II and Simbol Calipatria II Final EIR

51 4.16 Climate Change and Greenhouse Gases RPS goals of 20 percent of retails sales from renewables by the end of 2013, 25 percent by the end of 2016, and the 33 percent requirement being met by the end of Senate Bill 97 SB 97 was enacted in 2007 to amend the California Environmental Quality Act (CEQA) to include GHG emissions as CEQA environmental category. The bill directs the Governor s Office of Planning and Research (OPR) to develop draft CEQA guidelines for the mitigation of greenhouse gas emissions or the effects of greenhouse gas emissions" by July 1, 2009, and directs the CNRA to certify and adopt the CEQA guidelines by January 1, On December 30, 2009, the CNRA adopted amendments to the CEQA Guidelines in the California Code of Regulations (CCR). The amendments went into effect on March 18, Senate Bill 1368 SB 1368 was signed into law by Governor Schwarzenegger on September 29, 2006 and prohibits local publicly owned electric utilities, electrical corporations, electric service providers, and community electrical aggregators from entering into long-term financial commitments in baseload generation by power plants unless they comply with a GHG emissions performance standard (EPS) jointly established by the California Energy Commission (CEC) and the California Public Utilities Commission (CPUC). The EPS established a standard for baseload generation owned by, or under long-term contract to, publicly owned utilities of 1,100 pounds CO2 (0.500 metric ton) per megawatt-hour (MWh). LOCAL The Imperial County Air Pollution Control District (ICAPCD) is the local air quality management district with jurisdiction over air quality in the County of Imperial, where the proposed Projects are to be situated. County of Imperial General Plan No specific GHG regulations pertaining to Projects within the County of Imperial have been developed by the County or the ICAPCD. Both entities rely upon the CEQA Guidelines that govern the evaluation of impacts associated with GHG emissions, as well as on guidance provided by OPR in its technical advisory document, CEQA and Climate Change: Addressing Climate Change through California Environmental Quality Act (CEQA) Review, published in October Hudson Ranch Power II and Simbol Calipatria II Final EIR

52 4.16 Climate Change and Greenhouse Gases IMPACTS AND MITIGATION MEASURES STANDARDS OF SIGNIFICANCE The impact analysis provided below is based on significance criteria included in Appendix G of the CEQA Guidelines. An impact is considered significant if the Project would: 1. Generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment. 2. Conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs. THRESHOLDS OF SIGNIFICANCE The ICAPCD has not adopted any regulations or guidelines, including significance thresholds, pertaining to GHG emissions. Pursuant to CEQA Guidelines (Section ), the lead agency for the proposed Projects has the discretion to determine, in the context of the particular HR-2 and SmCP-2 Projects, a model or methodology to quantify GHG emissions, as well as establishing significance thresholds for evaluating potential impacts associated with these emissions. For purposes of this EIR, the threshold of significance used to assess GHG impacts associated with the proposed HR-2 Project is a GHG EPS of metric ton (1,100 pounds) of CO2 per MWh generated at a geothermal power plant. As discussed above, this GHG EPS was established under SB 1368 jointly by the CEC and CPUC to provide a standard for baseload generation owned by, or under long-term contract to, publicly owned utilities. Thus, the generation of more than metric ton CO2 per MWh would represent a significant GHG emissions impact. This significance threshold is consistent with the threshold that has been used to evaluate GHG emission impacts for similar projects within the same general area, and is applicable to all baseload power from new power plants such as the proposed HR-2 (County of Imperial, 2011). The HR-2 Project construction emissions, amortized over a 30-year period, were added to the Project operational emissions for comparison to the CEC and CPUC significant threshold. For purposes of this EIR, the threshold of significance used to assess GHG impacts associated with the proposed SmCP-2 Project is the South Coast Air Quality Management District (SCAQMD) interim significance threshold of 10,000 metric tons CO2e per year for stationary/industrial projects subject to CEQA review. Project construction emissions, amortized over a 30-year period, were added to Project operational emissions for comparison to this proposed threshold (SCAQMD 2008). Hudson Ranch Power II and Simbol Calipatria II Final EIR

53 4.16 Climate Change and Greenhouse Gases ENVIRONMENTAL PROTECTION MEASURES There are several environmental protection measures (EPMs) incorporated into the proposed Projects to minimize or avoid impacts to climate change. Chapter 3 provides a complete list and descriptions of EPMs that Hudson Ranch II LLC and Simbol, Inc. (the applicants) have incorporated into the Projects to avoid or minimize impacts on all resources. HR-2 Geothermal Power Plant Based on the HR-2 Supplemental Project Description (EMA 2012a), the applicant would incorporate the following EPMs as part of the Project construction and operations: During operations, the HR-2 power plant would generate power to service its own electrical load and would not need to purchase electrical energy. Exhaust Emissions Control Program. Specifies detailed list of control measures to minimize exhaust emissions during operation of the Project, including but not limited to fuel use, engine maintenance, and procedures. Operating and Maintenance Equipment Emission Control Program: This program will control operating and maintenance equipment by meeting any applicable road or non-road 2001 emissions standards and maintaining the equipment with manufacturers recommended procedures. SmCP-2 Mineral Extraction Plant EPM AQ-2: Exhaust Emissions Control Program. Specifies detailed list of control measures to minimize exhaust emissions during operation of the Project, including but not limited to fuel use, engine maintenance, and procedures. EPM AQ-7: Operating & Maintenance Equipment Emission Control Program. Would control this equipment by meeting any applicable road or non-road 2001 emissions standards, as amended, and maintaining the equipment with manufacture s recommended procedures. EPM AQ 8: Potential Temporary Emissions Control Program. Would control potential temporary emissions by limiting the operation of temporary sources. Changes to process operations would undergo review for their environmental impact before adoption. METHODOLOGY GHG emissions, represented as CO2e, were estimated for both short-term construction and long-term operational components of the proposed Projects. Calculations were conducted using standard industry models and federal and State of California approved methodologies. For some of the Projects sources, construction and operational emissions for both the HR-2 and SmCP-2 were estimated using the California Emission Estimator Model (CalEEMod) (version ), which can be used to estimate air pollutant Hudson Ranch Power II and Simbol Calipatria II Final EIR

54 4.16 Climate Change and Greenhouse Gases emissions for various land uses, area sources, construction and operational activities, and vehicle travel. Additionally, the CalEEMod emission factors were used for estimating operational GHG emissions associated with annual electrical energy use. Other Project operations and construction activity air pollutant emissions were calculated using the U.S. EPA AP-42 Compilation of Air Pollutant Emission Factors and the GHG emission factors provided in the California Climate Action Registry General Reporting Protocol (version 3.0). In order to best utilize the capabilities of the emission factor methodologies used, the applicant calculated emissions from both Projects activities in multiple CalEEMod models and separate calculations using applicable emission factors. CalEEMod (Version ) was used to estimate annual CO2e emissions from both Projects site preparation and grading, well pad grading, off-road construction equipment and activities, as well as emissions from on-road worker and vendor vehicle trips to and from the proposed Project site. For well site drilling within the HR-2 Project site, the total CO2 emissions were estimated based on the U.S. EPA emission factors. During operations GHG emissions were estimated based on the projected geothermal brine streams to be managed at both facilities, electric power consumption, and combustion operation from diesel-powered start-up/ black-start and emergency generator and fire pumps were estimated based on industry-wide methodologies, such as the USEPA Interim Tier 4 and CARB ATCM Limits and the California Climate Action Registry General Reporting Protocol, Version 3.0 (April 2008). The estimated CO2, CH4, and N2O volumes were then multiplied by their respective GWP values and combined to derive the total amount of CO2e expected to result from construction and operation of the proposed Projects. The significance of potential GHG impacts was determined using thresholds derived from guidance issued by the SCAQMD (selected for the purposes of this analysis in absence of direct guidance from ICAPCD), CEC, and CPUC. GHG Emissions HR-2 Construction Emissions Overall construction of the proposed HR-2 Project would occur over an approximate 28-month period and would include the development of the 52-acres, including the power plant site, three 5-acre well pads and access roads. GHG emissions would be produced by off-road construction equipment, as well as worker and vendor on-road trips. Table shows the estimated GHG emissions for the geothermal power plant site construction, well pad construction, well drilling, and well testing during the proposed HR-2 Project construction period. Appendix C-1 provides a detailed estimation of GHG emissions for the HR-2 Project construction. Hudson Ranch Power II and Simbol Calipatria II Final EIR

55 4.16 Climate Change and Greenhouse Gases TABLE HR 2 GHG CONSTRUCTION EMISSIONS YEAR Source: EMA 2012a ACTIVITY GHG EMISSIONS (METRIC TONNES CO 2e) McDonald Rd asphaltic coating (ARAM) 83 Site Preparation 0.4 Grading 693 Foundation Construction 70 SUBTOTAL Foundation Construction 36 Building, Mechanical & Electrical Work A, B, C 1,841 Well Pad Grading 133 Drill Rig Assembly, Well Drilling and Testing 176 Drill Rig 21,170 SUBTOTAL ,356 Building, Mechanical & Electrical Work C 412 Coating 56 Drill Rig Assembly, Well Drilling and Testing 26 On-site Paving 172 SUBTOTAL TOTAL HR-2 GHG CONSTRUCTION EMISSIONS 24,870 During well drilling, GHG emissions would primarily result from diesel fuel exhaust generated by the rigs used to drill the geothermal wells. The operation of construction equipment and vehicles would also emit GHGs, mainly CO2, from the combustion of fossil fuels. Approximately 21,170 metric tonnes of GHG would be emitted during well drilling, representing approximately 85 percent of the total GHG construction emissions (EMA 2012a). It is assumed that up to four production wells and four injection wells may be required for the HR-2 Project (up to six exploration wells may be integrated into the HR-2 Project), resulting in the development of a total of eight geothermal wells over the 28-month Project construction period. HR-2 Project Operational Emissions Operations of the proposed HR-2 Project would involve three major GHG sources: CO2 in noncondensable gases (NCG) from the Brine Processing Facility (BPF), emissions from the proposed stationary combustion equipment, and worker and vendor vehicle use. Table summarizes the projected operational GHG emissions for the HR-2 Project. Appendix C-2 provides a detailed estimation of GHG emissions for the HR-2 Project operations. Hudson Ranch Power II and Simbol Calipatria II Final EIR

56 4.16 Climate Change and Greenhouse Gases Assuming a design-case concentration of 4,000 mg/kg of CO2 in the brine being processed in the BPF and no delivery to the SmCP-2 plant, annual CO2 emissions from brine processing would be 63,576 metric tonnes per year. The design-case CO2 concentration is used to size equipment and is one-third larger than the nominal or expected case; therefore, actual CO2 emissions during the proposed BPF operations would be lower than the projected value. Additionally, CO2, CH4 and N2O would be emitted into the atmosphere from worker and vendor vehicle use; and from the maintenance, testing and use of operations of two kw start-up/black-start diesel-engine generators, an emergency diesel engine generator, and an emergency diesel fire pump. Table summarizes the main operational GHG sources and expected emissions. TABLE HR-2 GEOTHERMAL PLANT OPERATIONAL ANNUAL GHG EMISSIONS SOURCE ANNUAL GHG EMISSIONS (METRIC TONNES CO 2e) Cooling Tower NCG emissions (1) 63,576 Energy consumption 53 Mobile/ Vehicle Use 141 Water delivery 2,512 Diesel Engine Equipment Testing 191 Diesel Engine Equipment Operations (2) 318 HR-2 Construction Amortized Emissions (30 years) (3) 829 Total HR-2 Operational Emissions 67,620 HR-2 Operational Emissions (lbco2e/h) 17,040 HR-2 Geothermal Plant Net Generation (MW) 49.9 Estimated Emissions per MWh Generated (lbco2e/mw-h) 341 CEC Environmental Performance Standard (lbco2e/mw-h) 1,100 Exceeds CEC EPS? Sources: EMA 2012a, 2012b Notes: (1) Does not include potential transfer of gas stream to SmCP-2 plant. (2) Includes black-start situations. (3) Construction emissions of 24,870 metric tonnes CO2e amortized over 30 years. (4) Note: Assumes up to four plant outages during a year, each requiring continuing well flows at half rate for up to 24 hours. No SmCP-2 Project Construction Emissions The proposed SmCP-2 Project construction would take approximately 21 months, from March 2015 until December Construction activities would initiate with site preparation and grading of the 32.4-acre Hudson Ranch Power II and Simbol Calipatria II Final EIR

57 4.16 Climate Change and Greenhouse Gases SmCP-2 Project site (total acreage disturbed from grading is approximately 291 acres, or approximately nine passes over the SmCP-2 area) 1, followed by the foundation construction, building erection, architectural coating, on-site paving 2, and power line construction. No demolition is expected to be necessary for the SmCP-2 Project. In addition, paving of 200,000 square feet of McDonald Road to county standards would follow construction of the SmCP-2 plant. Paving would occur in parallel with the first months of the SmCP-2 operations. Appendix C-3 provides a detailed estimation of GHG emissions for the SmCP-2 Project construction. GHG emissions from the proposed SmCP-2 construction activities would primarily be associated with combustion from on-site heavy-duty diesel and gasoline powered equipment and offsite vehicle use. The proposed SmCP-2 plant construction would occur simultaneously with the operation of the proposed HR-2 geothermal power plant. Table presents the estimated GHG emissions for construction of the SmCP-2 Project, for both off-road and on-road equipment use during the proposed 21-month mineral extraction plant construction period. TABLE SMCP-2 GHG CONSTRUCTION EMISSIONS YEAR ACTIVITY GHG EMISSIONS (METRIC TONNES CO 2e) Site Preparation 0.33 Grading 370 Foundation Construction 323 Building Erection 522 Power Line Construction 8 Coating 9 SUBTOTAL ,232 Building Erection 990 Power Line Construction 15 Coating 79 On-site Paving 25 McDonald Rd. Paving 203 SUBTOTAL , TOTAL SmCP-2 GHG CONSTRUCTION EMISSIONS 2,544 Source: EMA 2012c 1 Per Attachment A of the report Air Pollutant Emission Estimates for the Simbol Calipatria Plant II, Imperial County, California (Appendix C-3), the SmCP-2 plant would be built on land totaling 32.4 acres, in addition to facilities shared with the HR-2 project. Total acreage of the shared facilities (brine, stormwater, and freshwater ponds) is estimated as 27 acres. Emissions included in the analysis cover the 32.4-acre footprint only. 2 Concrete and/or asphaltic paving would occur on the SmCP-2 on-site roads. Hudson Ranch Power II and Simbol Calipatria II Final EIR

58 4.16 Climate Change and Greenhouse Gases SmCP-2 Project Operational Emissions Operations of the proposed SmCP-2 mineral extraction plant would involve permanent stationary and mobile emission sources associated with the proposed silica management, lithium extraction and purification, lithium carbonate production, zinc and manganese extraction and production, miscellaneous processes, and worker and vendor vehicle use. Operations of the SmCP-2 plant would also involve daily worker and vendor vehicle trips; haul truck trips; water consumption for cooling towers, process water and potable water; chemical processing and packaging; and emergency standby diesel generator and fire pump engines. The proposed lithium carbonate production would process either a maximum of 10,500 metric tonnes per year of CO2 delivered from the HR-2 plant, or alternatively produce lithium carbonate using soda ash. If the first alternative is chosen, a purified CO2 gas stream of about 10,500 metric tonnes per year would be delivered from the HR-2 plant to produce up to 16,000 metric tons per year of lithium carbonate. Under this scenario, approximately 955 metric tonnes per year of CO2 would be discharged into the atmosphere by the SmCP-2 lithium carbonate unit. Table presents the overall GHG emissions for the SmCP-2 Project. Appendix C-5 provides a detailed estimation of GHG emissions for the SmCP-2 Project operations. TABLE SMCP-2 OPERATIONAL CO 2 E EMISSIONS SOURCE ANNUAL GHG EMISSIONS (METRIC TONNES CO 2e) Lithium Carbonate Production (using HR-2 gas stream) 955 Emergency Diesel Engine-Generator #1 371 Emergency Fire Pump Diesel Engine 16 Energy Use (1) 136,348 Mobile / Vehicle Use 1,198 Water Delivery (2) 1,675 Amortized Construction Emissions (30 years) (3) 85 Overall SmCP-2 Operational Emissions Total 140,648 Exceeds SCAQMD Threshold? Source: EMA 2012c, 2012d Notes: (1) Based on a maximum estimated energy consumption of 236,520 MWh/year and the IID Intensity Factor used by CalEEMod of lbs/mw. This value assumes 27 MW connected load over a year (8760 hours). Expected demand is 22.5 MW and an operation factor of 90 to 95 percent of 8,760 hours. (2) These emissions are estimated by CalEEMod and consider the energy required to deliver and treat water required for Project operations. (3) Construction emissions of 2,544 metric tonnes CO2e amortized over 30 years. Yes Hudson Ranch Power II and Simbol Calipatria II Final EIR

59 4.16 Climate Change and Greenhouse Gases HR-2 PROJECT IMPACTS AND MITIGATION MEASURES Impact GHG-1: Emission of GHG over the long-term operation of the proposed HR-2 Project would not result, either directly or indirectly, in levels that would exceed the significance threshold resulting in a significant impact to the environment. Global climate change, by its very nature, is a cumulative global impact resulting from the emission of GHG from countless sources worldwide. In addition, unlike criteria air pollutants and toxic air contaminants that can dissipate within a relatively short period of time, GHGs have long atmospheric lifetimes and can persist long enough to be dispersed globally. The proposed HR-2 Project is anticipated to generate GHG emissions at rate of approximately 341 pounds CO2e per MWh of electricity produced, which would be far below the GHG EPS of 1,100 pounds CO2e per MWh for electrical power production plants. Therefore, GHG emissions from the HR 2 Project would be less than significant. Mitigation Measures: Impact GHG-2: None required. The proposed HR-2 Project would not conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs. As of the date of preparation of this Draft EIR, neither the ICAPCD, nor any other local or regional agency having jurisdiction over the proposed Projects has adopted any plans, policies, or regulations pertaining to emission of GHGs. Therefore, the AB 32 Scoping Plan is the only plan, policy, or regulation identified that is applicable to the proposed Project. The AB 32 Scoping Plan establishes a goal of reducing emission of GHGs to 1990 levels by 2020 and promotes recommended actions for accomplishing this goal. As previously discussed, the proposed HR-2 Project would result in the emission of an estimated 343 pounds CO2e per MWh over the course of the 30-year life of the Project. These estimated emissions would not exceed the emission performance standard of 1,100 pounds of CO2 per MWh established by the CEC under SB This emission performance standard was adopted specifically with the goal of helping to reduce GHG emissions by utilities. Accordingly, while the proposed HR-2 Project would generate emissions of GHGs, these emissions would be unlikely to conflict with the emission reduction goals established in the AB 32 Scoping Report. Furthermore, Action 4 in the Scoping Plan promotes the RPS of 33 percent established by recent legislative approvals Hudson Ranch Power II and Simbol Calipatria II Final EIR

60 4.16 Climate Change and Greenhouse Gases and the California Air Resources Board. As the proposed HR-2 Project proposes geothermal power generation, its implementation would help meet the goals of Action 4. Therefore, any potential impact associated with the proposed Projects would be less than significant. Mitigation Measures: None required. SMCP-2 PROJECT IMPACTS AND MITIGATION MEASURES Impact GHG-1: Emission of GHGs over the long-term operation of the proposed SmCP-2 Project would not result, either directly or indirectly, in levels that would exceed the significance threshold. The proposed SmCP-2 Project is anticipated to generate annual emissions of 140,648 metric tonnes CO2e per year. Direct emissions from the SmCP-2 project would be approximately 4,300 metric tonnes CO2e per year. About 97 percent of the SmCP-2 Project GHG operational emissions would be indirectly emitted as a result of the electricity consumption from the Imperial Irrigation District (IID) grid 3. Thus, estimated direct and indirect annual emissions associated with the SmCP-2 Project would exceed the significance threshold used as a reference for the purposes of this analysis (i.e., SCAQMD interim threshold of 10,000 metric tonnes CO2e per year, for industrial facilities). However, the SmCP-2 Project would also contribute indirectly to reductions of GHG emissions through the expanded use of plug-in hybrid electric vehicles (PHEVs) and electric vehicles (EVs). The proposed SmCP-2 plant would produce lithium carbonate, which is used in the manufacture of lithium-ion batteries for PHEVs and EVs. The expanded use of PHEVs and EVs are expected to result in GHG reductions due to the greater fuel/energy economy of PHEVs and EVs as compared to conventional fossil fueled vehicles. Although the use of EVs would also require the consumption of electricity from the grid and have indirect GHG emissions associated, forecast studies have found that the U.S.-wide GHG emissions from the use of light-vehicle fleet powered by the U.S grid (with the carbon intensity of year 2007) would be lower than GHG emissions from the use of fossil-fueled vehicles, even with implementation of new fuel efficiency standards (e.g., the Corporate Average Fuel Economy- CAFE- 3 CO2 emissions from electricity consumption were estimated using the CalEEMod Electrical Utility Emission Factors of Greenhouse Gases (Environ 2011). This value is based on a 2008 Public Utility Reporting Protocol. This value may change over time, since utilities purchase some of their electricity from a power pool (which includes fossil fuel and renewable generation) for re-sale to customers. To date, the IID electrical utility emission factor for CO2 is 1, pounds of CO2 per MWh; however, this value may change in the future based on the IID purchase power pool mix used. Hudson Ranch Power II and Simbol Calipatria II Final EIR

61 4.16 Climate Change and Greenhouse Gases expected to be implemented in 2016). Assuming the carbon intensity of the 2007 U.S. grid, a conservative forecast has estimated that the countrywide GHG emissions from light-vehicles usage would be reduced by 11% with the adoption of EVs (UC Berkeley 2009). A least-cost technology deployment scenario developed by the International Energy Agency estimates that by 2025, annual sales of 13.2 million PHEVs and 4.6 million EVs would be required to meet the goal of reducing energy-related GHG emissions by 50% from 2005 levels in 2050 (U.S. DOE 2011). Other market studies have estimated that by 2020, the forecasted car sales for EVs would total 700,000 in the West Coast states and 2.7 million in the U.S. (UC Berkeley 2009). The proposed SmCP-2 plant would produce up to 16,000 metric tonnes of lithium carbonate annually (EMA 2012e and Simbol Materials 2012 ). It is estimated that this amount of lithium carbonate could contribute to the production of approximately 1.6 million battery packs per year for use in PHEVs/EVs (EMA 2012e and Simbol Materials 2012). Assuming that all these battery packs would be sold to supply part of the U.S. demand for EVs, the avoided GHG emissions from replacing 1.6 million gasoline-fueled light vehicles with PHEVs/EVs annually is estimated at 2,784,000 metric tonnes CO2e per year (EMA 2012e). Using these assumptions, it can be further estimated that it would take about 800 metric tons of lithium carbonate (approximately 5% of maximum production rate at SmCP-2 plant) to produce 80,000 battery packs per year with resulting GHG reductions of about 140,000 metric tonnes CO2e per year. This value is roughly equivalent to the annual direct and indirect GHG emission increases associated with operation of the proposed SmCP-2 plant. In addition, by combining operations with the HR-2 plant, the SmCP-2 Project would use up to 10,500 metric tonnes per year of CO2 emitted from the proposed geothermal facility 4 ; contributing to a reduction of GHG emissions from the proposed geothermal generation. Considering the potential contribution of the proposed SmCP-2 lithium carbonate production to the reduction of GHG emissions from transportation sources, any potential impact associated with the proposed SmCP-2 Project would be less than significant under this criterion. Mitigation Measures: None required. 4 The SmCP-2 Project design estimates the use of 9,570 metric tonnes of CO2 per year from the HR-2 plant in the lithium carbonate production process (stoichiometric requirement). However, an extra 10 percent of the CO2 gas stream rate (957 metric tonnes) has been estimated by the applicant as necessary to use during plant operations (EMA 2012f). Hudson Ranch Power II and Simbol Calipatria II Final EIR

62 4.16 Climate Change and Greenhouse Gases Impact GHG-2: The proposed SmCP-2 Project would not conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs. As of the date of preparation of this Draft EIR, neither the ICAPCD, nor any other local or regional agency having jurisdiction over the proposed Projects has adopted any plans, policies, or regulations pertaining to emission of GHGs. Therefore, the AB 32 Scoping Plan is the only plan, policy, or regulation identified that is applicable to the proposed Project. The AB 32 Scoping Plan establishes a goal of reducing emission of GHGs to 1990 levels by 2020 and promotes recommended actions for accomplishing this goal. While the SmCP-2 Project would generate emissions of GHGs, primarily indirect emissions associated with energy consumption, these emissions would be unlikely to conflict with the emission reduction goals established in the AB 32 Scoping Report. The SmCP-2 plant would contribute to the state GHG reductions goals through the supply of materials for the manufacture of electric vehicles. Part of the lithium carbonate production at the proposed SmCP-2 plant would likely be used for the manufacture of battery packs for EVs and PHEVs, which could result in avoided GHG emissions from the substitution of fossil-fueled vehicles. The use of advanced transportation technologies, such as EVs and PHEVs, is promoted by the State of California policies to help achieve the state's climate change policies. Further, the proposed SmCP-2 plant would contribute to reducing GHG emissions from the proposed HR-2 plant, which implementation would help meet the goals of Action 4 in the Scoping Plan that requires California utilities to achieve a 20 percent increase in the share of electricity obtained from renewable energy resources, such as geothermal power and the more recent RPS goal of 33 percent established by recent legislative approvals and the California Air Resources Board. Since the SmCP-2 Project would not conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs, no impact has been identified under this criterion. Mitigation Measures: None required REFERENCES California Air Pollution Control Officers Association (CAPCOA) CEQA and Climate Change. January California Air Resources Board (CARB) California Greenhouse Gas Inventory for May Hudson Ranch Power II and Simbol Calipatria II Final EIR

63 4.16 Climate Change and Greenhouse Gases Climate Change Scoping Plan. December California Climate Action Registry Climate Action Registry General Reporting Protocol, Version 3.1. January California Natural Resources Agency (CNRA) California Climate Adaptation Strategy. ENVIRON International Corporation California Emission Estimator Model (CalEEMod). Appendix D: Default Data Tables. February. Environmental Management Associates (EMA). 2012a. Air Pollutant Emission Estimates for Construction of the Hudson Ranch Power II Geothermal Project, Imperial County, California. Prepared for Hudson Ranch Power II LLC. April b.Hudson Ranch Power II Geothermal Project Imperial County, California. Operational Processes and Air Pollutant Emissions. EMA Report No Prepared for Energy Source LLC. April c. Air Pollutant Emission Estimates for the Simbol Calipatria Plant II, Imperial County, California. Prepared for Simbol, Inc. April d. Simbol, Inc. Sm Calipatria Plant II Imperial County, California. Operational Processes and Air Pollutant Emissions. EMA Report No April e. Estimated Greenhouse Gas Emissions Avoided by the Simbol Calipatria Plant II Li2CO3 Production for Electric Automobile Batteries. Memorandum prepared for Simbol, Inc. March 15, f. Personal Communication to Ecology and Environment, Inc. Re: Air Quality questions on SmCP-2 Processes and Air Pollutant Emissions. April 16, Governor s Office of Planning and Research Technical Advisory CEQA and Climate Change: Addressing Climate Change through California Environmental Quality Act (CEQA) Review. June Imperial County Air Pollution Control District (ICAPCD) Final Hour Ozone Modified Air Quality Management Plan. July. Simbol Materials Forecasts of market growth for electric vehicles using lithium-ion batteries. May 16, University of California, Berkeley. (UC Berkeley) Electric Vehicles in the United States. A New Model with Forecasts to Center for Entrepeneurship & Technology (CET). Technical Brief. Number v.2.0. Prepared by Thomas A. Becker and Ikhlaq Sidhu. August. U.S. Department of Energy (U.S. DOE) Critical Materials Strategy. December. Hudson Ranch Power II and Simbol Calipatria II Final EIR

64 4.16 Climate Change and Greenhouse Gases U.S. Environmental Protection Agency (EPA) Emission Facts: Average Carbon Dioxide Emissions Resulting from Gasoline and Diesel Fuel. February Available: Fact Sheet: Proposed Rule Prevention of Significant Deterioration and Title V Greenhouse Gas Tailoring Rule Step 3. Available: Accessed: April 30, Hudson Ranch Power II and Simbol Calipatria II Final EIR

65 4.2 Agriculture and Forest Resources 4.2 AGRICULTURE AND FOREST RESOURCES This section describes potential impacts on agricultural resources that would result from construction and operation of the proposed Projects, including the conversion of farmland to non-agricultural uses, conflicts with existing agricultural operations, and consistency with policies pertaining to agricultural resources, and includes mitigation measures that would reduce these impacts. No forestry resources are present within the Project sites or within the surrounding area and, therefore, this section focuses on issues related to agricultural resources. Scoping Issues Addressed During the scoping period for the Projects, two public scoping meetings were conducted and written comments were received from agencies and the public. No comments pertaining to agriculture were raised during the scoping period. Applicant s Reports and Survey Results Information used in preparing this section and in the evaluation of potential impacts on agricultural resources was derived from a number of sources, including Land Evaluation and Site Assessments (LESA) for the HR-2 Project (Appendix J-1) and the SmCP-2 Project (Appendix J-2) conducted by EMA in March These documents are contained in Volume II (Technical Appendix) of this EIR EXISTING SETTING REGIONAL SETTING The proposed Projects would be located in unincorporated lands in the County of Imperial, approximately 2.3 miles west-southwest of the Town of Niland and 1.5 miles east of the Salton Sea (see Chapter 3, Figure 3-1). Favorable climatic conditions, productive soils, and the availability of water provided by the Imperial Irrigation District (IID) have enabled Imperial County to become a primary producer in the agricultural industry. Irrigated agricultural products grown in the County include a variety of vegetable crops (e.g., lettuce, carrots, onions, tomatoes, cauliflower, and broccoli), as well as livestock feed (e.g., alfalfa, Sudan grass, sugar beets, wheat, Bermuda hay); melons; cotton; and various citrus fruits and nuts. According to the Imperial County Crop and Livestock Report for 2010, the top ten County-wide commodities included cattle, leaf lettuce, alfalfa, head lettuce, onions, broccoli, sugar beets, carrots, cantaloupes, and sudan grass (County of Imperial 2010a). The total harvested acreage in the County for 2010 was 529,334, and the County s gross annual agricultural value totaled $1,598,534,000 (County of Imperial 2010a). Adequate water and productive soils are two resources that are essential to maintaining the existing and future agricultural production in Imperial County. Hudson Ranch Power II and Simbol Calipatria II Final EIR

66 4.2 Agriculture and Forest Resources The Imperial Valley area, including the Project site, depends solely on the Colorado River for surface water delivery. The IID receives approximately 3 million acre-feet per year (AFY) from the Colorado River via the All American Canal. The IID delivers water to the Imperial Valley via three main canals, including the East Highline, Central Main, and Westside Main. The IID operates and maintains more than 1,438 miles of lateral canals and 1,456 miles of drainage ditches that collect surface runoff and subsurface drainage from the valley s farmland (IID 2011a). Approximately 97% of the water imported by the IID to the Imperial Valley is distributed for agricultural use (IID 2011b). Land Evaluation and Assessment Model The Project sites were evaluated using the California Agriculture LESA Model to rate the quality and availability of agricultural resources for the proposed Project sites and to identify whether the proposed Projects would meet the threshold criteria as a significant impact on agricultural resources under California Environmental Quality Act (CEQA) Guidelines. The LESA evaluates land use and site assessment factors to determine whether the Projects would result in a significant agricultural resources impact. The LESA evaluates measures of soil resource quality, project size, water resource availability, surrounding agricultural lands, and surrounding protected resource lands. For a given project, the factors are rated, weighted, and combined, resulting in a Land Evaluation sub-score and a Site Assessment sub-score. The sub-scores are combined to determine a single numeric score. A project s single numeric score becomes the basis for determining a project s potential impact (California Department of Conservation 2011). Conversion of Agricultural Land The California Department of Conservation monitors the conversion of the state s farmland through the Farmland Mapping and Monitoring Program (FMMP). Table summarizes the conversions of agricultural land to non-agricultural uses within Imperial County from 2006 to 2008 and represents the most recent data available at the time of the Draft EIR s publication. Between 2006 and 2008, 593-acres of Prime Farmland, 597-acres of Farmland of Statewide Importance, 85-acres of Unique Farmland, and 927-acres of Farmland of Local Importance were converted to non-agricultural uses (California Department of Conservation 2008a.). This trend in the conversion of agricultural land is expected to continue due to development pressure and other factors. Agricultural Soil Productivity The U.S. Department of Agriculture (USDA) Natural Resource Conservation Service (NRCS) uses two systems to assess a soil s agricultural productivity: the Soil Capability Classification System and the Storie Index Rating System. Under both systems, the prime soil classifications would require the least application of management techniques to produce a consistent and high yield of agricultural products. Common management techniques that have to be used on non-prime soils include fertilization and drainage or leveling of the Project sites. Hudson Ranch Power II and Simbol Calipatria II Final EIR

67 4.2 Agriculture and Forest Resources TABLE COUNTY OF IMPERIAL CHANGE IN AGRICULTURAL LAND USE ( ) LAND USE CATEGORY TOTAL ACREAGE INVENTORIED ACREAGE CHANGES ACRES LOST (-) ACRES GAINED (+) NET ACREAGE CHANGED Prime Farmland 196, ,589 1, Farmland of Statewide Importance 311, ,048 2,243 1, Unique Farmland 2,281 2, Farmland of Local Importance 33,036 32,109 2,444 1, Important Farmland Subtotal 543, ,942 5,807 3,605-2,202 Grazing Land Agricultural Land Subtotal 543, ,942 5,807 3,605-2,202 Urban and Built-up Land 26,897 27, , Other Land 457, , ,273 1,383 Water Area 1,022 1, TOTAL 1,028,567 1,028,509 6,969 6,969 0 Source: California Department of Conservation 2008a Soil Capability Classification System Soils are characterized according to their appearance, depth, consistency, slope, and erosion factors. The soil survey groups the various soil types into eight Soil Capability Classes. These classes are indicated in Table Soils are graded I through VIII, with I denoting the most suitable class and VIII denoting the least suitable class for cultivation. TABLE CLASS SOIL CAPABILITY CLASSIFICATION DESCRIPTION I II III IV V VI VII VIII Soils have few limitations that restrict their use. Soils have moderate limitations that reduce the choice of plants or that require special conservation practices. Soils have severe limitations that reduce the choice of plants or that require special conservation practices or both. Soils have very severe limitations that reduce the choice of plants or that require very careful management or both. Soils are not likely to erode but have other limitations, impractical to remove, that limit their use. Soils have severe limitations that make them generally unsuitable for cultivation. Soils have very severe limitations that make them unsuitable for cultivation. Soils and landforms have limitations that nearly preclude their use for commercial crop production. Source: USDA 1981 Hudson Ranch Power II and Simbol Calipatria II Final EIR

68 4.2 Agriculture and Forest Resources Storie Index Rating System Soils are also rated by the Storie Index, a numerical system expressing the relative degree of suitability or value of a soil for general intensive agriculture use. The index considers a soil s color and texture, the depth of nutrients, presence of stones, and slope, all of which relate to the adequacy of a soil type for use in crop cultivation. The rating does not take into account other factors such as the availability of water for irrigation, the climate, and the distance from markets. Values of the index range from 1 to 100 and are divided into six grades, with an index of 100 and a grade of 1 being the most suitable and a grade of 6 being the least suitable for farming. Soils that have a Storie rating of 10 or below are considered to have a very low agricultural potential. Soils are considered to be prime for high-quality agricultural production if their Storie Index Rating is 80 or greater. Table lists the six NRCS soil grades, ranges in index rating, and definitions for each soil grade. TABLE GRADE STORIE INDEX RATING SYSTEM STORIE INDEX RATING DESCRIPTION 1 - Excellent 80 through 100 Soils are well suited for growing irrigated crops that are climatically suited to the region. 2 - Good 60 through 79 Soils are good agricultural soils, although they may not be as desirable as Grade 1 because of moderately coarse or gravelly surface soil texture; somewhat less permeable subsoil; lower plant=available water holding capacity, fair fertility; less welldrained conditions or slight to moderate flood hazards, all acting separately or in combination. 3 Fair 40 through 59 Soils are only fairly well suited to general agricultural use and are limited in their use because of moderate slopes; moderate soil depths; less permeable subsoil; fine, moderately fine, or gravelly surface soil textures; poor drainage; moderate flood hazards; or fair to poor fertility levels, all acting alone or in combination. 4 - Poor 20 through 39 Soils are poorly suited. They are severely limited in their agricultural potential because of shallow soil depths; less permeable subsoil; steeper slope; or more clayey or gravelly surface soil textures than Grade 3 soils, as well as poor drainage; greater flood hazards; hummocky micro-relief; salinity; or fair to poor fertility levels, all acting alone or in combination. 5 - Very Poor 10 through 19 Soils are very poorly suited for agriculture, are seldom cultivated and are more commonly used for range, pasture, or woodland. 6 - Nonagricultural Less than 10 Soils are not suited for agriculture at all due to very severe to extreme physical limitations, or because of urbanization. Source: USDA 1981 Project Sites The HR-2 and SmCP-2 Project sites would be located on 100-acres of private land within a 245-acre parcel in an unincorporated portion of the County of Imperial; approximately 2.3 miles west-southwest of the Town of Niland and east of the Salton Sea (see Chapter 3, Figure 3-1). The Project sites have a General Plan Land Use Designation of "Agriculture" and are zoned "A-2-R-G (General Agriculture/Rural/Geothermal Hudson Ranch Power II and Simbol Calipatria II Final EIR

69 4.2 Agriculture and Forest Resources Overlay Zone). The 245-acre parcel that the Project sites are located within has been developed for irrigated agriculture (cultivation of alfalfa). At the time of the publication of the NOP, the agricultural fields on the Project sites were fallow and not being irrigated. Adjacent Areas Adjacent properties to the north, east, and south are currently, or are proposed to be IID-managed marshlands. A commercial algae production facility is located south of the Project sites. This facility includes a mobile home which, at the time of the publication of the NOP, served as a residence for the facility caretaker. The commercial algae facility is no longer in operation and is not part of the proposed Projects. The nearest residence is approximately 0.5 miles north-northeast of the Project sites, along English Road. Energy Source (Hudson Ranch Power II, LLC s parent company) owns the home and is allowing the current tenant to remain in the residence until Fall This residence would be demolished prior to the start of construction of either the HR-2 Project or the SmCP-2 Project. The next closest residence is located 1.4 miles north of the Project sites. Important Farmland Categories The California Department of Conservation Farmland Mapping and Monitoring Program (FMMP) produces Important Farmland maps, which are a hybrid of soil resource quality and land use information. USDA soil survey information and the corresponding Important Farmland candidacy recommendations are used to assess local land. The goal of the program is to provide consistent and impartial data to decision makers for use in assessing present status, reviewing trends, and planning for the future of California s agricultural land resources. According to the 2008 FMMP Map for Imperial County indicates that the Project sites contain land designated as Prime Farmland, Farmland of Statewide Importance and Farmland of Local Importance (California Department of Conservation 2008b). Farmland Mapping and Monitoring Program The list below describes each of the categories mapped by the California Department of Conservation Farmland Mapping and Monitoring Program (FMMP) for Imperial County. Prime Farmland Prime Farmland has the best combination of physical and chemical features able to sustain long-term agricultural production. This land has the soil quality, growing season, and moisture supply needed to produce sustained high yields. To be classified as Prime Farmland, this land must have been producing irrigated crops at some time during the four years prior to the mapping date (California Department of Conservation 2008b). Unique Farmland Unique Farmland consists of lesser quality soils used for the production of the state s leading agricultural crops. This land is usually irrigated but may include non-irrigated orchards or vineyards, as found in some Hudson Ranch Power II and Simbol Calipatria II Final EIR

70 4.2 Agriculture and Forest Resources climatic zones in California. The land must have been cultivated at some time during the four years prior to the mapping date (California Department of Conservation 2008b). Farmland of Statewide Importance Farmland of Statewide Importance is similar to Prime Farmland but with minor shortcomings such as greater slopes or with less ability to hold and store moisture. The land must have been used for the production of irrigated crops at some time during the four years prior to the mapping date (California Department of Conservation 2008b). Farmland of Local Importance Farmland of Local Importance is land of importance to the local economy, as defined by each county s board of supervisors and a local advisory committee. In Imperial County, Farmland of Local Importance includes non-irrigated and uncultivated lands with Prime and Statewide soils that do not qualify as Prime, Statewide, or Unique but are currently irrigated crops or pasture or non-irrigated crops; lands that would meet the Prime or Statewide designation and have been improved for irrigation but are now idle; and lands that currently support confined livestock, poultry operations, and aquaculture (California Department of Conservation 2008b). Grazing Land Grazing Land is land on which the existing vegetation, whether grown naturally or through management, is suited for grazing livestock. The minimum mapping unit for this category is 40-acres (California Department of Conservation 2008b). Urban and Built-Up Land Urban and Built-Up Land is occupied by structures with a building density of at least one unit to 1.5-acres, or approximately six structures. Common examples include residential, industrial, commercial, and institutional facilities; cemeteries; airports; golf courses; sanitary landfills; sewage treatment plants; and water control structures (California Department of Conservation 2008b). Other Land Other Land is land that is not included in any other mapping category. Common examples include low-density rural developments; brush; timber; wetland; riparian areas not suitable for livestock grazing, confined livestock, poultry, or aquaculture facilities; strip mines; borrow pits; and water bodies smaller than 40-acres. Vacant and non-agricultural land surrounded on all sides by urban development and greater than 40-acres is mapped as Other Land (California Department of Conservation 2008b). Water The last category in the FMMP is perennial water bodies with an extent of at least 40-acres (California Department of Conservation 2008b.). Hudson Ranch Power II and Simbol Calipatria II Final EIR

71 4.2 Agriculture and Forest Resources Acreage of Important Farmlands for Project Sites Based on a review of the FMMP 2008 Important Farmland Map for Imperial County, the Project sites contains approximately 32 acres of Prime Farmland, 208 acres of Farmland of Statewide Importance, and 5 acres of Farmland of Local Importance. There are no Urban and Built-Up lands or Other Lands within the Project Sites. The site is not subject to the provisions of a Williamson Act contract (Durrett 2011). Table provides the approximate acreage of Important Farmlands on the HR-2 and SmCP-2 Project sites. Figure depicts their location on the Project sites. TABLE IMPORTANT FARMLANDS ON THE HR-2 AND SMCP-2 PROJECT SITES CLASSIFICATION APPROXIMATE ACREAGE (1) Prime Farmland 32 Farmland of Statewide Importance 208 Farmland of Local Importance 5 Urban and Built-Up 0 Other 0 TOTAL 245 Source: California Department of Conservation 2008b. Note: (1) Acreages rounded to the nearest whole number. Production and Soil Characteristics The USDA survey found five soil types present on the Project sites: Imperial silty clay, wet; Imperial- Glenbar silty clay loams, wet, 0 to 2 percent slopes; Indio loam, wet; Meloland very fine sandy loam, wet; and Vint and Indio very fine sandy loams, wet. Two of the soil types are good for agricultural uses, one soil type is fairly well suited to general agricultural use, and one is poorly suited for agricultural uses. Figure depicts the distribution of soil types on-site. Table provides details on the variety of soils found on-site, along with their Capability Class and Storie Index rating. Capability classes and subclasses indicate the suitability of soils for most kinds of field crops. The soils are classed according to their limitations when they are used for field crops, the risk of damage when they are used, and the way they respond to treatment. The grouping does not take into account major and generally expensive land-forming that would change slope, depth, or other characteristics of the soils or possible, but unlikely, major reclamation projects, and does not apply to rice, cranberries, horticultural crops, or other crops that require special management. Hudson Ranch Power II and Simbol Calipatria II Final EIR

72 4.2 Agriculture and Forest Resources TABLE SOIL CAPABILITY CLASSIFICATION AND STORIE INDEX GRADE FOR THE PROJECT SITES MAP SYMBOL MAPPING UNIT LAND CAPABILITY CLASS 1 STORIE INDEX RATING GRADE (2) 114 Imperial silty clay, wet IIIw-6 42 Grade Imperial-Glenbar silty clay loams, wet, 0 to 2% slopes IIIw-6 70 Grade Indio loam (wet) IIw-1 86 Grade Meloland very fine sandy loam, wet IIIw-3 44 Grade Vint and Indio very fine sandy loams, wet IIw Grade 2 Source: EMA 2012 (Appendices J-1 and J-2) Notes: (1) Land Capability Classes are defined as follows: IIlw-6 capability rating indicates soils have severe limitations that reduce the choice of plants or that require special conservation practices or both. The soil contains water that interferes with plant growth or cultivation (in some soils the wetness can be partly corrected by artificial drainage). The soil also has problems or limitations caused by salt or alkali. IIlw-3 capability rating indicates soils that have moderate limitations that reduce the choice of plants or that require moderate conservation practices. The soil contains water that interferes with plant growth or cultivation (in some soils the wetness can be partly corrected by artificial drainage. The soil has problems or limitations of slow or very slow permeability of the subsoil or substratum, caused by a clayey subsoil or a substratum that is semi-consolidated. IIw-3 capability rating indicates soils with soils have moderate limitations that reduce the choice of plants or that require moderate conservation practices. The soil contains water that interferes with plant growth or cultivation (in some soils the wetness can be partly corrected by artificial drainage. The soil has problems or limitations of slow or very slow permeability of the subsoil or substratum is caused by a clayey subsoil or a substratum that is semi-consolidated. IIw-1 capability rating indicates soils have moderate limitations that reduce the choice of plants or that require moderate conservation practices. The soil contains water that interferes with plant growth or cultivation (in some soils the wetness can be partly corrected by artificial drainage). The soil has problems or limitations caused by slope or by actual or potential erosion hazard. (2) The grades for soils are defined in Table 4.2-3, Storie Index Rating System REGULATORY SETTING FEDERAL AND STATE Farmland Protection Policy Act The purpose of the Farmland Protection Policy Act (FPPA) is to minimize the extent to which federal programs contribute to the unnecessary conversion of farmland to non-agricultural uses. The FPPA also stipulates that federal programs be compatible with state, local, and private efforts to protect farmland. The USDA NRCS is charged with overseeing the FPPA. Hudson Ranch Power II and Simbol Calipatria II Final EIR

73 Dewey Rd Brandt Rd English Rd Path: \\prtbhp1\gis\sandiego\hudsonranch_geothermal\maps\mxds\figure_4_2-1_hr2smcp2_fmmpjc.mxd McDonald Rd Hudson Ranch Power II and Simbol Calipatria II Project Sites Schrimpf Rd Simpson Rd Merkley Rd Estelle Rd Sinclair Rd Kalin Rd Hoober Rd Alamo River Riverside County Imperial County MEXICO CA State FMMP Category Prime Farmland Farmland of Statewide Importance Farmland of Local Importance Project Sites Hudson Ranch Power II CUP#G Simbol Calipatria Plant II CUP# Important Farmlands Figure Miles

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75 Brandt Rd Path: \\prtbhp1\gis\sandiego\hudsonranch_geothermal\maps\mxds\figure_4_2-2_h2_ssurgo_soils.mxd Mcdonald Rd Schrimpf Rd 114 Hudson Ranch Power II and Simbol Calipatria II Project Sites English Rd 122 Simpson Rd 114 Merkley Rd Estelle Rd Sinclair Rd Dewey Rd Kalin Rd 114 Alamo River 115 Hoober Rd Riverside County Imperial County MEXICO HR-2 and SmCP-2 Project Sites SSURGO Soil Types Representative Slope: 0-1% FLUVAQUENTS, SALINE IMPERIAL SILTY CLAY, WET IMPERIAL-GLENBAR SILTY CLAY LOAMS, WET INDIO LOAM, WET MELOLAND VERY FINE SANDY LOAM, WET VINT AND INDIO VERY FINE SANDY LOAMS, WET WATER Hudson Ranch Power II CUP #G & Simbol Calipatria II CUP # Soils Map Figure Miles

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77 4.2 Agriculture and Forest Resources California Land Conservation Act (Williamson Act) In 1965, the California State Legislature enacted the California Land Conservation Act, or Williamson Act, to encourage the preservation of the state s agricultural lands and to prevent their premature conversion to non-agricultural uses. In order to preserve agricultural uses, the Williamson Act program established an agricultural preserve contract procedure by which any local jurisdiction within the state taxes landowners at a reduced rate, based on the value of the land for its current use as opposed to its unrestricted market value. In return, the landowners sign a Williamson Act contract with the local jurisdiction, agreeing to keep their land in agricultural production or another approved compatible use for at least a 10-year period. The contract is renewed automatically each year unless the owner files a notice of non-renewal with the county clerk. In addition, a landowner has the option to file for immediate cancellation of the contract as long as the proposed immediate cancelation application is consistent with the cancellation criteria provided in the California Land Conservation Act and those adopted by the applicable county or city. Land that qualifies as Class I and Class II in the Soil Capability Classification System or land that qualifies for a rating of 80 to 100 in the Storie Index Rating are considered to be Prime Farmland under the Williamson Act. On February 23, 2010, the Board of Supervisors of Imperial County Board of Supervisors voted for non-renewal of all existing Williamson Act contracts and denial of any new contracts; this vote discontinued the Williamson Act program for Imperial County (County of Imperial, 2010b). The proposed Project sites are not under any Williamson Act contracts. LOCAL Imperial County Right-To-Farm Ordinance On August 7, 1990, the Imperial County Board of Supervisors adopted the Imperial County Right-to-Farm Ordinance (Ordinance No. 1031) to reduce the loss to the County of its agricultural resources by notifying potential buyers and users of adjacent properties about the potential nuisances associated with agricultural operations. The ordinance requires that real estate transactions that may occur in the vicinity of agricultural operations fully disclose agricultural practices in the area. The ordinance also establishes a County Agricultural Grievance Committee to resolve disputes between those who manage agricultural operations and adjacent property owners (County of Imperial 1996). County of Imperial General Plan Agriculture has been the single most important economic activity of Imperial County throughout its history. Imperial County recognizes the area as one of the finest agricultural areas in the world due to several environmental and cultural factors, including good soils, a year-round growing season, the availability of adequate water transported from the Colorado River, extensive areas committed to agricultural production, a gently sloping topography, and a climate that is well-suited for growing crops and raising livestock. The Agricultural Element in the County of Imperial General Plan demonstrates the long-term commitment by the County to the full promotion, management, use, and development and protection of agricultural production while allowing logical, organized, growth of urban areas (County of Imperial 1996). Hudson Ranch Power II and Simbol Calipatria II Final EIR

78 4.2 Agriculture and Forest Resources The General Plan s Agricultural Element identifies several implementation programs and policies for the preservation of agricultural resources. The Agricultural Element recognizes that Imperial County can and should take additional steps to provide further protection for agricultural operations and, at the same time, provide for logical, organized growth of urban areas. The County must be specific and consistent about which lands will be maintained for the production of food and fiber and for support of the County's economic base. The County s strategy and overall framework for maintaining agriculture includes the following policy directed at the Preservation of Important Farmland: The overall economy of Imperial County is expected to be dependent upon the agricultural industry for the foreseeable future. As such, all agricultural land in Imperial County is considered as Important Farmland, as defined by federal and state agencies, and should be reserved for agricultural uses. Agricultural land may be converted to non-agricultural uses only where a clear and immediate need can be demonstrated, such as requirements for urban housing, commercial facilities, or employment opportunities. All existing agricultural land will be preserved for irrigation agriculture, livestock production, aquaculture, and other agriculture-related uses except for non-agricultural uses identified in this General Plan or in previously adopted City General Plans. Tables identifies applicable County of Imperial General Plan policies related to agricultural resources and addresses the proposed HR-2 and SmCP-2 Projects consistency with these policies. TABLE HR-2 AND SMCP-2 PROJECT CONSISTENCY WITH APPLICABLE GENERAL PLAN AGRICULTURAL GOALS AND OBJECTIVES GENERAL PLAN POLICIES CONSISTENCY ANALYSIS AGRICULTURE ELEMENT Goal 1: All Important Farmland, including the categories of Prime Farmland, Farmland of Statewide Importance, Unique Farmland, and Farmland of Local Importance, as defined by Federal and State agencies, should be reserved for agricultural uses. Objective 1.1: Maintain existing agricultural land uses outside of urbanizing areas and allow only those land uses in agricultural areas that are compatible with agricultural activities. Objective 1.2: Encourage the continuation of irrigation agriculture on Important Farmland. Yes Yes Yes The proposed Projects would temporarily convert land approximately 100 acres of land out of a 245- acre parcel. The 100-acres of land are designated as Prime Farmland, Farmland of Statewide Importance and Farmland of Local Importance to non-agricultural uses, but mitigation is provided to prevent a permanent conversion. The Project uses are compatible with existing surrounding agricultural uses. At the time of the NOP publication the agricultural fields on the Project sites were fallow and not being irrigated. The proposed Projects would be developed on approximately 100-acres of a 245- acre parcel. The 100-acres of land would be temporarily converted to non-agricultural uses, but this temporary conversion reduces the need for IID to fallow irrigated lands elsewhere in the County to meet IID water conservation goals. Hudson Ranch Power II and Simbol Calipatria II Final EIR

79 4.2 Agriculture and Forest Resources TABLE HR-2 AND SMCP-2 PROJECT CONSISTENCY WITH APPLICABLE GENERAL PLAN AGRICULTURAL GOALS AND OBJECTIVES GENERAL PLAN POLICIES CONSISTENCY ANALYSIS Objective 1.3: Conserve Important Farmland for continued farm related (non-urban) use and development while ensuring its proper management and use. Objective 1.4: Discourage the location of development adjacent to productive agricultural lands. Objective 1.5: Direct development to less valuable farmland (i.e., Unique Farmland and Farmland of Local Importance rather than Prime Farmland or Farmland of Statewide Importance) when conversion of agricultural land is justified. Objective 1.6: Recognize and preserve unincorporated areas of the County, outside the city sphere of influence areas, for irrigation agriculture, livestock production, aquaculture, and other special uses. Objective 1.8: Allow conversion of agricultural land to non-agricultural uses only where a clear and an immediate need can be demonstrated, based on population projections and lack of other available land (including land within incorporated cities) for such non-agricultural uses. Such conversion shall also be allowed only where such uses have been identified for non-agricultural use in a city general plan or the County General Plan, and are supported by a study to show lack of alternative sites. No Yes Yes Yes Yes The proposed Projects would be developed on 100-acres of a 245-acre parcel. Approximately 145 acres would remain available for agricultural uses and approximately 100-acres would be temporarily converted to non-agricultural uses and mitigation would be required. At the end of the Projects useful life, disturbed lands on the site would be restored to pre-project conditions and made available for agricultural use. The proposed HR-2 Project would develop a geothermal facility and the SmCP-2 Project would develop a mineral extraction plant on agricultural lands. These types of developments are allowed in the AR-2G (Geothermal Overlay Zone) and the land uses are compatible with surrounding IID managed marshland. It should also be noted that the Project Sites are surrounded by existing or proposed IID managed marshlands on the north, south and east. The proposed Projects would temporarily convert land designated as Prime Farmland and Farmland of Statewide Importance to non-agricultural uses. However, with the issuance of a CUP, the proposed uses would be consistent with County of Imperial s Land Use Ordinance and thus are also consistent with the land use designation of the site. In addition, mitigation is required to prevent permanent conversion of valuable farmland. The proposed Projects would temporarily convert land located in an unincorporated area to nonagricultural uses. However, with issuance of a CUP, the Projects would be an allowable use in an agricultural zone. Consistency with zoning implies consistency with the land use designation of the site. The proposed Projects would be located on agricultural land that is within the Salton Sea Known Geothermal Resource Area (KGRA). The Geothermal/ Alternative Energy and Transmission element of the General Plan controls the location of the geothermal plant and mineral extraction is identified as an activity that may occur during the operational phase of a geothermal power plant (Geothermal Element p. 62). Hudson Ranch Power II and Simbol Calipatria II Final EIR

80 4.2 Agriculture and Forest Resources TABLE HR-2 AND SMCP-2 PROJECT CONSISTENCY WITH APPLICABLE GENERAL PLAN AGRICULTURAL GOALS AND OBJECTIVES GENERAL PLAN POLICIES CONSISTENCY ANALYSIS Goal 2: Adopt policies that prohibit leapfrogging or checkerboard patterns of non- agricultural development in agricultural areas and confine future urbanization to adopted Sphere of Influence area. Objective 2.1: Do not allow the placement of new non-agricultural land uses such that agricultural fields or parcels become isolated or more difficult to economically and conveniently farm. Objective 2.3: Maintain agricultural lands in parcel size configurations that help assure that viable farming units are retained. Objective 2.4: Discourage the parcelization of large holdings. Goal 3: Limit the introduction of conflicting uses into farming areas, including residential development of existing parcels which may create the potential for conflict with continued agricultural use of adjacent property. Objective 3.2: Enforce the provisions of the Imperial County Right-to-Farm Ordinance (No. 1031). Objective 3.3: Enforce the provisions of the State nuisance law (California Code Sub-Section 3482). Objective 3.5: As a general rule, utilize transitional land uses around urban areas as buffers from agricultural uses. Such buffers may include rural residential uses, industrial uses, recreational areas, roads, canals, and open space areas. Yes Yes Yes Yes Yes Yes Yes Yes The Project sites are designated as an agriculture land. The Project sites are located adjacent to agriculture and IID managed marshlands. The Projects include the construction and operation of a geothermal facility and a minerals extraction facility and would not contain a residential component that would induce urbanization adjacent to the Project sites. Furthermore, with the issuance of the CUPs, the Projects would be consistent with the County s Land Use Ordinance. Consistency with the Land Use Ordinance implies consistency with the general plan land use designation. Development of the Project sites would include construction and operation of geothermal and mineral extraction facilities and are surrounded on the north, south and east by existing or planned IID managed marshlands. After the Projects are implemented, the adjacent agricultural fields would remain contiguous to one another and not become isolated. The proposed Projects would temporarily convert approximately 100 acres of a 245-acre parcel from agricultural land to land that is developed with nonagricultural uses. The proposed Project sites are located in the A-2-R zone and a 40-acre minimum lot is required. Approximately 145-acres would be undeveloped which would allow viable farming units. See response to Objective 2.3 above. With approval of CUPs, the proposed Projects are allowable uses in agricultural zones. Additionally, the Projects do not propose any residential development and would not conflict with any agricultural uses in the area. The Imperial County Right-to-Farm Ordinance would be enforced. The provisions of the State nuisance law (now codified as California Code Sub-Section 3479) would be incorporated into the proposed Projects. The proposed Projects include a geothermal facility and a mineral extraction facility. These uses are permitted uses on agricultural land and would be located adjacent to agricultural land. Hudson Ranch Power II and Simbol Calipatria II Final EIR

81 4.2 Agriculture and Forest Resources TABLE HR-2 AND SMCP-2 PROJECT CONSISTENCY WITH APPLICABLE GENERAL PLAN AGRICULTURAL GOALS AND OBJECTIVES GENERAL PLAN POLICIES CONSISTENCY ANALYSIS Objective 3.6: Where a development permit is sought adjacent to agricultural land use, protect agricultural operations by requiring appropriate buffer zones between the agricultural land and new developments, and then keep these zones aesthetically pleasing and free of pests by cleaning them of all garbage and noxious vegetation. Vegetation for the purpose of dust control shall be planted and maintained in an attractive manner. The buffer shall occur on the parcel for which the development permit is sought and shall favor protection of the maximum amount of farmland. Source: County of Imperial 1996 Yes The proposed Projects would temporarily convert land approximately 100 acres of land out of a 245- acre parcel. Approximately 100-acres of the 245- acre parcel would be developed with the proposed Projects and 145-acres would remain undeveloped and available for agricultural uses. The undeveloped area and the roads and nearby canals would provide buffers for the HR-2 and SmCP-2 plants. Adjacent land to the north, south, and east consists of IID managed marshland. In addition, the proposed Projects would maintain the site by managing sanitation and waste during construction and operation of their respective facilities. While this Draft EIR addresses the proposed Project s consistency with the County s General Plan, pursuant to the CEQA Guidelines Section 15125(d), the County of Imperial Planning Commission will determine the Projects consistency with the General Plan IMPACTS AND MITIGATION MEASURES STANDARDS OF SIGNIFICANCE The impact analysis provided below is based on the following CEQA Guidelines, Appendix G. An impact is considered significant if the Project would: Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, as shown on the maps prepared pursuant to the FMMP of the California Resources Agency, to non-agricultural use. Conflict with existing zoning for agricultural use or a Williamson Act contract. Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code [PRC] Section 12220(g)), timberland (as defined by PRC Section 4526), or timberland zoned Timberland Production (as defined by Government Code Section 51104(g)). Result in the loss of forest land or conversion of forest land to non-forest use. Involve other changes in the existing environment, which, due to their location or nature, could result in conversion of farmland to non-agricultural use or conversion of forest land to non-forest use. Hudson Ranch Power II and Simbol Calipatria II Final EIR

82 4.2 Agriculture and Forest Resources ENVIRONMENTAL PROTECTION MEASURES No Environmental Protection Measures (EPMs) were identified to avoid or reduce impacts to agricultural resources. METHODOLOGY Potential impacts on agricultural resources from implementation of the proposed Projects were evaluated taking into consideration the County of Imperial General Plan Agricultural Element, the County of Imperial Zoning Code, and field reconnaissance conducted in the surrounding area. Data provided by the USDA, the Soil Conservation Service, and the FMMP were also reviewed and assessed. The agricultural analysis is based on information gathered from the Imperial County General Plan Agricultural Element. Information and regulations provided by the USDA, Soil Conservation Service, and FMPP were reviewed and evaluated for each Project site in the LESA (see Appendices J-1 and J-2). HR-2 MPACTS AND MITIGATION MEASURES Impact AG-1: The HR-2 Project would convert Prime Farmland, Unique Farmland, and Farmland of Statewide Importance to non-agricultural use. The HR-2 Project would temporarily convert 11-acres of Prime Farmland, 36-acres of Farmland of Statewide Importance, and 5-acres of Farmland of Local Importance (Farmland) to a non-agricultural use (Table 4.2-7). Based on the results of the LESA, conversion of this land for Project use would result in a significant impact. TABLE ESTIMATED IMPORTANT FARMLANDS CONVERSION FOR HR-2 PROJECT AGRICULTURE CLASSIFICATION APPROXIMATE ACREAGE Prime Farmland 11 Farmland of Statewide Importance 36 Farmland of Local Importance 5 Urban and Built-Up 0 Other 0 Total 52 Source: EMA 2012 (See Appendix J-1) As shown in Table 3-1 (Chapter 3, Project Description), the HR-2 Project would require 52-acres of the total Project site and the SmCP-2 Project would require 48-acres; leaving approximately 145-acres available for agricultural production. Hudson Ranch Power II and Simbol Calipatria II Final EIR

83 4.2 Agriculture and Forest Resources A LESA analysis was performed to assess whether the Project s temporary conversion of these important farmlands to non-agricultural use would constitute a significant impact (see Appendix J-1). The LESA Model is an approach used to rate the relative quality of land resources based upon six specific measurable features. Two land evaluation factors are based upon measures of soil resource quality. Four site assessment factors provide measures of a given Project s size, water resource availability, surrounding agricultural lands, and surrounding protected resource lands. Table provides a summary of the LESA analysis. TABLE I. SCORE SHEET SUMMARY Land Evaluation (LE) SUMMARY OF LESA ANALYSIS FOR THE HR-2 PROJECT SITE FACTOR RATING (0-100 POINTS) FACTOR WEIGHTING (TOTAL = 1.00) WEIGHTED FACTOR RATING 1. Land Capability Classification Storie Index Rating SITE ASSESSMENT (SA) LE Subtotal Project Size Water Resource Availability Surrounding Agricultural Lands Protected Resource Lands SA Subtotal TOTAL LESA SCORE (LE +SA) II. LESA MODEL SCORING THRESHOLDS Total LESA Score Scoring Decision 0 to 39 Points Not considered significant 40 to 59 Points Considered significant only if LE and SA subscores are greater than or equal to 20 points 60 to 79 Points Considered significant unless either LE or SA subscore is less 0 than 20 points 80 to 100 Points Considered significant Source: EMA 2012 (See Appendix J-1) Hudson Ranch Power II and Simbol Calipatria II Final EIR

84 4.2 Agriculture and Forest Resources Based on the results of the LESA, conversion of this land for HR-2 Project use would result in total LESA Score of This would be a significant impact and mitigation measures would be required. MM AG-1.1: Loss of Agricultural Land - Non-Prime (Farmland of Statewide Importance and Farmland of Local Importance) Farmland Hudson Ranch Power II, LLC may choose one of the following three methods for mitigation: i. Agricultural Conservation Easements on a "1 to 1" basis on land of equal size, of equal quality farmland, outside of the path of development. The Conservation Easement shall meet the State Department of Conservation s regulations and shall be recorded prior to issuance of any grading or building permits. or ii. Hudson Ranch Power II, LLC shall pay an "Agricultural In-Lieu Mitigation Fee" in the amount of 20% of the fair market value per acre for the total acres of proposed site based on five comparable sales of land used for agricultural purposes as of the effective date of the permit, including program costs on a cost recovery/time and material basis. The Agricultural In-Lieu Mitigation Fee, will be placed in a trust account administered by the Imperial County Agricultural Commissioner's office and will be used for such purposes as the acquisition, stewardship, preservation and enhancement of agricultural lands within Imperial County. or ii. If Hudson Ranch Power II, LLC and the County voluntarily enter into a public benefit agreement that includes an Agricultural Benefit Fee payment that is equal to or greater than the amount that would be due under option ii of this mitigation measure and the public benefit agreement requires that the Agricultural Benefit Fee be used for such purposes as the acquisition, stewardship, preservation and enhancement of agricultural lands within Imperial County, then this mitigation measure may be satisfied by payment of voluntarily agreed to Agricultural Benefit Fee. Timing/Implementation: Prior to the issuance of a grading permit or building permit (whichever comes first).for the project. Enforcement/Monitoring: County of Imperial Planning and Development Services Department. Hudson Ranch Power II and Simbol Calipatria II Final EIR

85 4.2 Agriculture and Forest Resources MM AG-1.2: Loss of Agricultural Land - Prime Farmland i. Hudson Ranch Power II, LLC may choose one of the following three methods for mitigation:agricultural Conservation Easements on a "2 to 1" basis on land of equal size, of equal quality farmland, outside of the path of development. The Conservation Easement shall meet the State Department of Conservation's regulations and shall be recorded prior to issuance of any grading or building permits. or ii. Hudson Ranch Power II, LLC shall pay an "Agricultural In-Lieu Mitigation Fee" in the amount of 30% of the fair market value per acre for the total acres of proposed site based on five comparable sales of land used for agricultural purposes as of the effective date of the permit, including program costs on a cost recovery/time and material basis. The Agricultural In-Lieu Mitigation Fee, will be placed in a trust account administered by the Imperial County Agricultural Commissioner's office and will be used for such purposes as the acquisition, stewardship, preservation and enhancement of agricultural lands within Imperial County. or iii. If Hudson Ranch Power II, LLC and the County voluntarily enter into a public benefit agreement that includes an Agricultural Benefit Fee payment that is equal to or greater than the amount that would be due under option ii of this mitigation measure and the public benefit agreement requires that the Agricultural Benefit Fee be used for such purposes as the acquisition, stewardship, preservation and enhancement of agricultural lands within Imperial County, then this mitigation measure may be satisfied by payment of voluntarily agreed to Agricultural Benefit Fee. Timing/Implementation: Prior to the issuance of a grading permit or building permit (whichever comes first).for the project. Enforcement/Monitoring: County of Imperial Planning and Development Services Department. MM AG-1.3: Reclamation Plan/Site Abandonment Plan Prior to the issuance of the initial grading permit or building permit, Hudson Ranch Power II, LLC shall submit to County of Imperial Reclamation Plan/Site Abandonment Plan to return the property to its current agricultural condition. The Reclamation Plan/Site Abandonment Plan shall include a reclamation cost estimate prepared by a California-licensed general contractor or civil engineer. Hudson Ranch Power II, LLC shall provide financial assurance/bonding in the Hudson Ranch Power II and Simbol Calipatria II Final EIR

86 4.2 Agriculture and Forest Resources amount equal to the reclamation cost estimate to return the land to its current agricultural condition prior to the issuance of the initial grading permit or building permit. Timing/Implementation: Prior to the issuance of the initial grading permit or building permit (whichever comes first). Enforcement/Monitoring: County of Imperial Planning and Development Services Department. Significance after Mitigation: Impact AG-2: With implementation of MM AG-1.1, MM AG-1.2 and MM AG-1.3, Hudson Ranch Power II, LLC would be required both to restore the land to its original agricultural suitability at the end of the Project and while the Project is operating, other comparable agricultural land elsewhere would be protected with easements or through the County s Agricultural Mitigation Program.. Therefore, there would be no net loss of agricultural lands as result of the proposed HR-2 Project and impacts would be less than significant. The HR-2 Project would not conflict with existing zoning for agricultural use or a Williamson Act contract. Pursuant to the County of Imperial General Plan, the Project site is designated for agricultural uses, and the site is zoned A-2-R-G (General Agriculture/Rural/Geothermal Overlay Zone), which provides for agricultural use and other compatible uses. Pursuant to Title 9, Division 5, Chapter 8 of the Land Use Ordinance, electrical generation plants (less than 50-MW), "mining and mineral extraction" and "facilities for the transmission of electrical energy ( kv)" are permitted in the A-2-R-G zone (County of Imperial 1998), subject to the County's approval of a CUP. Project implementation would result in the temporary conversion of agricultural land to non-agricultural uses. However, with the issuance of a CUP, the proposed use would be consistent with the existing A-2-R-G zoning designation of the site. In addition, the Project site is not subject to the provisions of a Williamson Act contract and would not conflict with such a contract. Therefore, the Project would result in no impact under this criterion. Mitigation Measures: Impact AG-3: None required. The HR-2 Project would not conflict with existing zoning for or cause rezoning of forest land (as defined in PRC Section 12220(g)), timberland (as defined by PRC Hudson Ranch Power II and Simbol Calipatria II Final EIR

87 4.2 Agriculture and Forest Resources Section 4526), or timberland zoned Timberland Production (as defined by Government Code Section 51104(g)). No forest or timber land is present in the Project site; therefore, no forest or timber land would be affected by the Project and there would be no impact. Mitigation Measures: Impact AG-4: None required. The HR-2 Project would not result in the loss of forest land or conversion of forest land to non-forest use. As discussed under Impact AG-3 above, no forest land is present in the Project area, and no forest land would be affected by the Project. Therefore, Project implementation would not result in the loss of forest land or conversion of forest land to non-forest use, and no impact would occur. Mitigation Measures: Impact AG-5: None required. The HR-2 Project does not include changes in the existing environment, which, due to their location or nature, that would not result in conversion of neighboring farmland to non-agricultural use. The HR-2 Project site is surrounded primarily by IID-managed marsh and agricultural land. Additionally, the proposed Project does not include a residential or commercial component that would create incompatibility issues with adjacent agricultural operations nor would it develop infrastructure that would attract or encourage development of adjacent farmlands. The County of Imperial General Plan designates the Project site as Agriculture. At the end of the Project s useful life, disturbed lands on the site would be restored to suitability for agricultural use once the wells have been abandoned, the pipelines have been removed, and the well pads have been reclaimed. Further, the provisions of the Imperial County Right-to-Farm Ordinance (No. 1031) and the state nuisance law (California Code Sub-Section 3749) will be enforced. Therefore, the proposed Project would not result in the conversion of farmlands off-site to non-agricultural uses and no impact would occur. Mitigation Measures: None required. SMCP-2 IMPACTS AND MITIGATION MEASURES Impact AG-1: The SmCP-2 Project would convert Prime Farmland, Unique Farmland, and Farmland of Statewide Importance to non-agricultural use. Hudson Ranch Power II and Simbol Calipatria II Final EIR

88 4.2 Agriculture and Forest Resources The proposed SmCP-2 Project would temporarily convert 16-acres of Prime Farmland and 32-acres of Farmland of Statewide Importance to non-agricultural use (Table 4.2-9). Based on the results of the LESA, conversion of this land for project use would result in a significant impact. TABLE ESTIMATED IMPORTANT FARMLANDS CONVERSION FOR SMCP-2 PROJECT AGRICULTURE CLASSIFICATION APPROXIMATE ACREAGE Prime Farmland 16 Farmland of Statewide Importance 32 Farmland of Local Importance 0 Urban and Built-Up 0 Other 0 Subtotal 48 Source: EMA 2012 (See Appendix J-2) As shown in Table 3-1 (Chapter 3, Project Description), the proposed SmCP-2 Project would require 48-acres and the proposed HR-2 Project would require a 52- acres of the total 245-acre parcel; leaving approximately 145-acres undisturbed and available for agricultural production. A LESA analysis was performed to assess whether Project conversion of these important farmlands to non-agricultural use would constitute a significant impact (see Appendix J-2). The LESA Model is an approach used to rate the relative quality of land resources based upon six specific measurable features. Two Land Evaluation Factors are based upon measures of soil resource quality. Four Site Assessment Factors provide measures of a given a Project s size, water resource availability, surrounding agricultural lands, and surrounding protected resource lands. Table provides a summary of the LESA analysis. TABLE SUMMARY OF LESA ANALYSIS FOR THE SMCP-2 PROJECT SITE I. SCORE SHEET SUMMARY Land Evaluation (LE) FACTOR RATING (0-100 POINTS) FACTOR WEIGHTING (TOTAL = 1.00) WEIGHTED FACTOR RATING 1. Land Capability Classification Storie Index Rating LE Subtotal Hudson Ranch Power II and Simbol Calipatria II Final EIR

89 4.2 Agriculture and Forest Resources TABLE SUMMARY OF LESA ANALYSIS FOR THE SMCP-2 PROJECT SITE SITE ASSESSMENT (SA) FACTOR RATING (0-100 POINTS) FACTOR WEIGHTING (TOTAL = 1.00) WEIGHTED FACTOR RATING 1. Project Size Water Resource Availability Surrounding Agricultural Lands Protected Resource Lands II. LESA Model Scoring Thresholds Total LESA Score SA Subtotal TOTAL LESA SCORE (LE +SA) Scoring Decision 0 to 39 Points Not considered significant 40 to 59 Points Considered significant only if LE and SA subscores are greater than or equal to 20 points 60 to 79 Points Considered significant unless either LE or SA subscore is less 0 than 20 points 80 to 100 Points Considered significant Source: EMA 2012 (See Appendix J-2) Based on the results of the LESA, conversion of this land for the SmCP-2 Project use would result in result in total LESA Score of This would be a significant impact and mitigation measures would be required. MM AG-1.1: Loss of Agricultural Land - Non-Prime (Farmland of Statewide Importance and Farmland of Local Importance) Farmland Simbol, Inc. may choose one of the following three methods for mitigation: iii. Agricultural Conservation Easements on a "1 to 1" basis for 32 acres (32 acres x 1 = 32 acres) on land of equal size, of equal quality farmland, outside of the path of development. The Conservation Easement shall meet the State Department of Conservation s regulations and shall be recorded prior to issuance of any grading or building permits. or ii. Simbol, Inc. shall pay an "Agricultural In-Lieu Mitigation Fee" in the amount of 20% of the fair market value per acre for the total acres of proposed site based on five comparable sales of land used for agricultural purposes as of the effective date of the permit, including program costs on a cost recovery/time and material basis. The Agricultural In-Lieu Mitigation Fee, will Hudson Ranch Power II and Simbol Calipatria II Final EIR

90 4.2 Agriculture and Forest Resources be placed in a trust account administered by the Imperial County Agricultural Commissioner's office and will be used for such purposes as the acquisition, stewardship, preservation and enhancement of agricultural lands within Imperial County. or iv. If Simbol, Inc. and the County voluntarily enter into a public benefit agreement that includes an Agricultural Benefit Fee payment that is equal to or greater than the amount that would be due under option ii of this mitigation measure and the public benefit agreement requires that the Agricultural Benefit Fee be used for such purposes as the acquisition, stewardship, preservation and enhancement of agricultural lands within Imperial County, then this mitigation measure may be satisfied by payment of voluntarily agreed to Agricultural Benefit Fee. Timing/Implementation: Prior to the issuance of a grading permit or building permit (whichever comes first).for the project. Enforcement/Monitoring: County of Imperial Planning and Development Services Department. MM AG-1.2: Loss of Agricultural Land - Prime Farmland Simbol, Inc. may choose one of the following three methods for mitigation: i. Agricultural Conservation Easements on a "2 to 1" basis for 32 acres (16 acres x 2 = 32 acres) on land of equal size, of equal quality farmland, outside of the path of development. The Conservation Easement shall meet the State Department of Conservation's regulations and shall be recorded prior to issuance of any grading or building permits. or ii. Simbol, Inc. shall pay an "Agricultural In-Lieu Mitigation Fee" in the amount of 30% of the fair market value per acre for the total acres of proposed site based on five comparable sales of land used for agricultural purposes as of the effective date of the permit, including program costs on a cost recovery/time and material basis. The Agricultural In-Lieu Mitigation Fee, will be placed in a trust account administered by the Imperial County Agricultural Commissioner's office and will be used for such purposes as the acquisition, stewardship, preservation and enhancement of agricultural lands within Imperial County. or iii. If Simbol, Inc. and the County voluntarily enter into a public benefit agreement that includes an Agricultural Benefit Fee payment that is equal to or greater Hudson Ranch Power II and Simbol Calipatria II Final EIR

91 4.2 Agriculture and Forest Resources than the amount that would be due under option ii of this mitigation measure and the public benefit agreement requires that the Agricultural Benefit Fee be used for such purposes as the acquisition, stewardship, preservation and enhancement of agricultural lands within Imperial County, then this mitigation measure may be satisfied by payment of voluntarily agreed to Agricultural Benefit Fee. Timing/Implementation: Prior to the issuance of a grading permit or building permit (whichever comes first).for the project. Enforcement/Monitoring: County of Imperial Planning and Development Services Department. MM AG-1.2: Reclamation Plan/Site Abandonment Plan Prior to the issuance of the initial grading or building permit, Simbol, Inc. shall submit to the County of Imperial a Reclamation Plan/Site Abandonment Plan to return the property to its current agricultural condition prior to the issuance of the initial grading permit The Reclamation Plan/Site Abandonment Plan shall include a reclamation cost estimate prepared by a California-licensed general contractor or civil engineer. Simbol, Inc. shall provide financial assurance/bonding in the amount equal to the reclamation cost estimate to return the land to its current agricultural condition prior to the issuance of the initial grading permit or building permits. Timing/Implementation: Prior to the issuance of the initial grading permit or building permit (whichever comes first). Enforcement/Monitoring: County of Imperial Planning and Development Services Department. Significance after Mitigation: With implementation of MM AG-1.1, MM AG-1-2 and MM AG-1.3, Simbol, Inc. would be required both to restore the land to its original agricultural suitability at the end of the Project and while the Project is operating, other comparable agricultural land elsewhere would be protected with easements or through the County s Agricultural Mitigation Program.. Therefore, there would be no net loss of agricultural land as result of the proposed SmCP-2 Project and impacts would be less than significant. Hudson Ranch Power II and Simbol Calipatria II Final EIR

92 4.2 Agriculture and Forest Resources Impact AG-2: The SmCP-2 Project would not conflict with existing zoning for agricultural use or a Williamson Act contract. Pursuant to the County of Imperial General Plan, the Project site is designated for agricultural uses, and the site is zoned A-2-R-G (General Agriculture/Rural/Geothermal Overlay Zone), which provides for agricultural use and other compatible uses. Pursuant to Title 9, Division 5, Chapter 8 of the Land Use Ordinance, electrical generation plants (less than 50-MW), "mining and mineral extraction" and "facilities for the transmission of electrical energy ( kv)" are permitted in the A-2-R-G zone (County of Imperial 1998), subject to the County's approval of a CUP. Project implementation would result in the temporary conversion of agricultural land to non-agricultural uses. However, with the issuance of a CUP, the proposed use would be consistent with the existing A-2-R-G zoning designation of the site. In addition, the Project site is not subject to the provisions of a Williamson Act contract and there would be no conflict with such a contract. Therefore, the HR-2 Project would result in no impacts under this criterion. Mitigation Measures: Impact AG-3: None required. The SmCP-2 Project would not conflict with existing zoning for, or cause rezoning of, forest land (as defined in PRC Section 12220(g)), timberland (as defined by PRC Section 4526), or timberland zoned Timberland Production (as defined by Government Code Section 51104(g)). No forest or timber land is present in the Project site; therefore, no forest or timber land would be affected by the Project and there would be no impact. Mitigation Measures: Impact AG-4: None required. The SmCP-2 Project would not result in the loss of forest land or conversion of forest land to non-forest use. As discussed for Impact AG-3, no forest land is present in the Project site, and no forest land would be affected by the Project. Therefore, Project implementation would not result in the loss of forest land or conversion of forest land to non-forest use, and no impact would occur. Mitigation Measures: None required. Hudson Ranch Power II and Simbol Calipatria II Final EIR

93 4.2 Agriculture and Forest Resources Impact AG-5: The SmCP-2 Project does not include changes in the existing environment which, due to their location or nature that would result in conversion of neighboring farmland to non-agricultural use. The Project site is surrounded primarily by IID-managed marsh and agricultural land. Additionally, the proposed Project does not include a residential or commercial component that would create incompatibility issues with adjacent agricultural operations or develop infrastructure that would attract or encourage development of adjacent farmlands. The County of Imperial General Plan designates the Project site as Agriculture. At the end of the Project s useful life, disturbed lands on the site would be restored to agricultural use once the mineral extraction facilities have been reclaimed. Further, the provisions of the Imperial County Right-to-Farm Ordinance (No. 1031) and the state nuisance law (California Code Sub-Section 3482) will be enforced. Therefore, the proposed Project would not result in the conversion of farmlands off-site to non-agricultural uses and no impact would occur. Mitigation Measures: None required REFERENCES California Department of Conservation. 2008a. Division of Land Resources Protection. Farmland Conversion Report 2006 to Online at: county_info_results.asp. Accessed May 25, b. Farmland and Monitoring Program (FMMP). Imperial County Important Farmland Online at:ftp://ftp.consrv.ca.gov/pub/dlrp/fmmp/pdf/2008/. Accessed May 11, County of Imperial. 2010a. Crop and Livestock Report for Online at: /Crop_&_Livestock_Reports/Crop_&_Livestock_Report_2010.pdf. Accessed May 16, b. Official Proceedings Regular Meeting of the Board of Supervisors. Item 10a. Actions relating to the Williamson Act. February County of Imperial General Plan Agricultural Element. El Centro, California. Adopted by Board of Supervisors November 9, Revisions adopted by Board of Supervisors, November 19, Durrett, J Personal communication (telephone) between Jack Durrett, Appraisal Supervisor in Commercial/Industrial/Agricultural Sectors Imperial County Assessor s Office, and Roya Compani- Tabrizi, Ecology and Environment, Inc. July 21, Imperial Irrigation District (IID). 2011a. Irrigation. Online at: Hudson Ranch Power II and Simbol Calipatria II Final EIR

94 4.2 Agriculture and Forest Resources Accessed July 25, b. Water. Online at: Accessed July 25, United States Department of Agriculture (USDA) Soil Survey of Imperial County California Imperial Valley Area. Soil Conservation Service in cooperation with the University of California Agricultural Experiment Station and Imperial Irrigation District. Online at: Accessed July 21, Natural Resources Conservation Service. Soil Survey Geographic (SSURGO) database for Imperial County, California, Imperial Valley Area. January 3, Online at: URL: Accessed June Hudson Ranch Power II and Simbol Calipatria II Final EIR

95 4.3 Air Quality 4.3 AIR QUALITY This section of the Draft Environmental Impact Report (EIR) analyzes the potential impacts to air quality associated with the proposed Projects. Emissions estimates were prepared to determine both short-term construction and long-term operational impacts, and calculations were made using standard industry models and federal, state, and locally approved methodologies. The following sections discuss existing air quality for the setting in which the proposed Projects are to be located, as well as applicable air quality standards and regulations; the significance of potential air quality impacts, as determined using appropriate thresholds; and mitigation measures, as necessary, to reduce air quality impacts. Scoping Issues Addressed During the scoping period for the proposed Projects, two public scoping meetings were conducted and written comments were solicited from both agencies and the public. Comment letters received from the public include comments regarding air quality. Concerns were noted about particulate matter emissions; noncondensable gases, diesel particulate and hazardous air pollutant (HAP) emissions; emissions of ozone precursors; and odor nuisance from hydrogen sulfide (H2S) emissions that could occur as a result of the construction and operation of the proposed HR-2 Project. It was requested that the Draft EIR include a description and quantification of Project construction and operational emissions. In addition, a comment was received requesting a health risk assessment be conducted to determine past, present, or future releases of hazardous airborne toxics that may pose a risk to human health or the environment. Applicant s Reports and Survey Results Information used in preparing this section and in the evaluation of potential impacts to air quality resources was derived from air pollutant emission estimates for construction and operational processes of the HR-2 and SmCP-2 Projects prepared by Environmental Management Associates (EMA), in March, April, and June Air quality emissions reports for construction and operation of the proposed HR-2 and SmCP-2 Projects can be found in Appendices C-1, C-2, C-3, C-4, C-5 and C-6 of this EIR. A Health Risk Assessment, prepared by EMA (April 2012) is included as Appendix M. These documents are included in Volume II of this EIR (Technical Appendix) EXISTING SETTING The proposed Projects would be located within the unincorporated area of the Imperial County in southeastern California. Imperial County encompasses the southern half of the Salton Sea Air Basin (SSAB). The proposed Projects would be situated about 2.3 miles west-southwest of the community of Niland, California. Hudson Ranch Power II and Simbol Calipatria II Final EIR

96 4.3 Air Quality CLIMATE Imperial County is one of the hottest and driest parts of California, and is located in a region best described as a low latitude desert characterized by hot, dry summers and relatively mild winters. Average annual precipitation is less than 3 inches. Daily average temperature in winter ranges between 65 and 75ºF. During winter months it is not uncommon to record maximum temperatures of up to 80ºF. Summers are extremely hot with daily average temperature ranges between 104 and 115ºF, with maximum temperatures up to 120ºF (ICAPCD 2010). During the summer, due to the presence of the Pacific high-pressure zone off the coast of California, a thermal trough develops over California s southeast desert region. The intensity and orientation of the trough varies from day to day. Although the mountainous terrain surrounding the Imperial Valley inhibits air circulation, the influence of the trough does permit some inter-basin exchange of air with coastal locations through the mountain passes. Relative humidity in the summer is very low, averaging 30 to 50 percent in the early morning and 10 to 20 percent in the afternoon. During the hottest part of the day, a relative humidity level below 10 percent is common (ICAPCD 2010). However, the effect of extensive agricultural operations in the widely-irrigated Imperial Valley tends to increase local humidity. The prevailing weather conditions promote intense heating during the day in summer, with marked cooling at night. The wind direction follows two seasonal patterns. During the fall, winter, and spring, regional winds tend to come from the northwest. These originating prevailing winds are known to be from the Los Angeles area. During the spring and summer, Imperial County experiences occasional periods of extremely high wind speeds; wind statistics indicate prevailing winds are from the west-northwest through southwest, and a secondary flow maximum from the southeast is also evident (ICAPCD 2010). AMBIENT AIR POLLUTANTS Criteria Air Pollutants The U.S. Environmental Protection Agency (EPA) has established National Ambient Air Quality Standards (NAAQS) for six of the most common pollutants. These pollutants (described as criteria air pollutants ) include ground-level ozone (O3), carbon monoxide (CO), particulate matter, both respirable (less than or equal to 10 microns in diameter) (PM10) and fine (equal to or less than 2.5 microns in diameter) (PM2.5), nitrogen dioxide (NO2), lead (Pb), and sulfur dioxide (SO2). Similarly, the State of California has adopted standards known as the California Ambient Air Quality Standards (CAAQS) for the six federally recognized criteria air pollutants as well as for four additional pollutants: vinyl chloride, visibility reducing particles, H2S, and sulfates. Under the NAAQS, standards are further classified as primary and secondary. Primary ambient air quality standards define emission limits to protect public health, including the health of sensitive populations such as asthmatics, children, and the elderly. The secondary ambient air quality standards define limits to protect public welfare from the adverse effects of a pollutant, including protection against Hudson Ranch Power II and Simbol Calipatria II Final EIR

97 4.3 Air Quality decreased visibility and damage to animals, crops, vegetation, and buildings. The NAAQS and CAAQS are summarized in Table TABLE SUMMARY OF AMBIENT AIR QUALITY STANDARDS NAAQS POLLUTANTS AVERAGING TIME CAAQS 1 PRIMARY SECONDARY Ozone (O3) 2 1 Hour 0.09 ppm (180 µg/m 3 ) Hour ppm (137 µg/m 3 ) ppm ppm Respirable Particulate Matter (PM10) 3 Fine Particulate Matter (PM2.5) 4 24 Hour 50 µg/m µg/m µg/m 3 Annual 20 µg/m Hour µg/m 3 35 µg/m 3 Annual 12 µg/m 3 15 µg/m 3 15 µg/m 3 Carbon Monoxide (CO) 5 1 Hour 20 ppm (23 mg/m 3 ) 35 ppm -- 8 Hour 9.0 ppm (10 mg/m 3 ) 9 ppm -- Nitrogen Dioxide (NO2) 6 1 Hour 0.18 ppm (339 µg/m 3 ) 100 ppb -- Annual ppm (57 µg/m 3 ) 53 ppb 53 ppb Sulfur Dioxide (SO2) 1 Hour 0.25 ppm (655 µg/m 3 ) 75 ppb -- 3 Hour ppm 24 Hour 0.04 ppm (105 µg/m 3 ) Annual Lead (Pb) 8 30 Day Average 1.5 µg/m Month (Rolling Average) µg/m µg/m 3 Visibility Reducing Particles 8 Hour See Note 9. No Federal Standards Sulfates 24 Hour 25 µg/m 3 Hydrogen Sulfide (H2S) 1 Hour 0.03 ppm (42 µg/m 3 ) Vinyl Chloride 24 Hour 0.01 ppm (26 µg/m 3 ) Source: CARB 2012a; EPA 2011 Notes: 1 California standards for ozone, carbon monoxide, sulfur dioxide (1 and 24 hour), nitrogen dioxide, suspended particulate matter PM10, PM2.5, and visibility reducing particles, are values that are not to be exceeded. All others are not to be equaled or exceeded. 2 The 8-hour ozone NAAQS is equal to the annual fourth-highest daily maximum 8-hr concentration, averaged over 3 years. The 1997 ozone NAAQS (0.08 ppm) and related implementation rules remain in place. In 1997, EPA revoked the 1-hour ozone NAAQS (0.12 ppm) in all areas, although some areas have continued obligations under that standard ( anti-backsliding ). 3 The 24-hour PM10 NAAQS is not to be exceeded more than once per year on average over 3 years. 4 The 24-hour PM2.5 NAAQS is attained when 98 percentile, averaged over three years, is equal to or less than the standard. The annual PM2.5 NAAQS is the annual mean, averaged over 3 years. 5 The 1-hour and 8-hour CO NAAQSs are not to be exceeded more than once per year 6 For the 1-hour NO2 NAAQS, the 3-year average of the 98th percentile of the daily maximum 1-hour average at each monitor within an area must not exceed 100 ppb 7 The 1-hour SO2 NAAQS is based on the 3-year average of the annual 99 th percentile of 1-hour daily maximum concentrations. The 3-hour SO2 NAAQS is not to be exceeded more than once per year. The 1971 annual and 24-hour SO2 NAAQSs were revoked in However, these NAAQSs remain in effect until one year after an area is designated for the 1-hour NAAQS, except in areas designated nonattainment for the 1971 NAAQS, where the 1971 Hudson Ranch Power II and Simbol Calipatria II Final EIR

98 4.3 Air Quality TABLE SUMMARY OF AMBIENT AIR QUALITY STANDARDS NAAQS POLLUTANTS AVERAGING TIME CAAQS 1 PRIMARY SECONDARY NAAQSs remain in effect until implementation plans to attain or maintain the 1-hour NAAQS are approved. 8 CARB gas identified lead and vinyl chloride as toxic air contaminants with no threshold level of exposure for adverse health effects determined. The Rolling 3-month average lead NAAQS is not to be exceeded. The 1978 lead NAAQS (1.5 µg/m 3 as a quarterly average) remains in effect until one year after an area is designated for the 2008 NAAQS, except that in areas designated nonattainment for the 1978, the 1978 NAAQS remains in effect until implementation plans to attain or maintain the 2008 NAAQS are approved. 9 Extinction coefficient of 0.23 per kilometer visibility of ten miles or more ( miles or more for Lake Tahoe) due to particles when relative humidity is less than 70 percent. Key: CAAQS = California Ambient Air Quality Standards NAAQS = National Ambient Air Quality Standards ppb = parts per billion ppm = parts per million µg/m 3 = micrograms per cubic meter Air basins with individual criteria air pollutant levels below the NAAQS or CAAQS are designated as being in attainment for each pollutant. If an individual criteria air pollutant level exceeds the NAAQS or CAAQS, the air basin is designated as being in nonattainment for that pollutant. If not enough data on a criteria air pollutant is available, the air basin is described as being unclassified. Under the NAAQS, the nonattainment designation can be further qualified as marginal, moderate, serious, severe, or extreme. Also, areas previously designated as a nonattainment for one or more pollutants pursuant to the Clean Air Act (CAA) Amendments of 1990, and subsequently redesignated as an attainment area are subject to the requirement to develop a maintenance plan under section 175A of the CAA, as amended. Table shows the attainment status under both the NAAQS and the CAAQS for each criteria air pollutant in the portion of Imperial County where the proposed Projects would be located. Each criteria pollutant is described in greater detail below. In August 2004, the EPA reclassified the Imperial Valley under the CAA from a moderate to a serious PM10 non-attainment area (69 CFR 48792, August 11, 2004). Also in August 2004, the EPA proposed a rule to find that the Imperial Valley area (which includes the proposed Projects site) had failed to attain the annual and 24-hour PM10 standards by the serious area deadline of December 31, 2001 (ICAPCD 2009). The major sources of particulate matter in Imperial County are fugitive windblown dust, with other contributions from entrained road dust, farming, and construction activities (ICAPCD 2009). TABLE AIR QUALITY STANDARD ATTAINMENT STATUS PROJECT AREA WITHIN IMPERIAL COUNTY POLLUTANT CAAQS NAAQS Ozone (O3) Nonattainment Nonattainment - Moderate Carbon Monoxide (CO) Attainment Unclassified/Attainment Respirable Particulate Matter (PM10) Nonattainment Nonattainment - Serious Fine Particulate Matter (PM2.5) Unclassified Attainment (1) Nitrogen Dioxide (NO2) Attainment Unclassified/Attainment Hudson Ranch Power II and Simbol Calipatria II Final EIR

99 4.3 Air Quality TABLE AIR QUALITY STANDARD ATTAINMENT STATUS PROJECT AREA WITHIN IMPERIAL COUNTY POLLUTANT CAAQS NAAQS Lead (Pb) Attainment Attainment Sulfur Dioxide (SO2) Attainment Attainment Sulfates Attainment No Federal Standards Vinyl Chloride Hydrogen Sulfide (H2S) Visibility Reducing Particles Unclassified Unclassified Unclassified Source: EPA 2012a, CARB 2011a Notes: (1) The proposed Projects would not be located in those portions of Imperial County designated by the EPA as nonattainment for PM2.5. Ozone (O 3 ) Ozone is a key component of smog and is generated when ozone precursors such as reactive organic gases (ROG) and oxides of nitrogen (NOx) react with sunlight in the atmosphere. Because sunlight is required to produce ozone, levels tend to increase during the summer months when days are longer. Common sources of ROGs include paint, household cleaning products, dry cleaning chemicals, and aerosols. NOX is generally a component of automobile exhaust. Health effects associated with ozone exposure include respiratory tract irritation, coughing, nausea, eye irritation, and decreased pulmonary function. Carbon Monoxide (CO) CO is an odorless, colorless gas produced by the incomplete combustion of fuel. The primary sources of CO are automobiles and other ground-based vehicles that use fossil fuels. The health effects associated with CO exposure are related to its interaction with hemoglobin in the blood stream. At high concentrations, CO can reduce the amount of oxygen in the blood, cause heart difficulties in people with chronic heart disease, and impaired mental function. Respirable Particulate Matter (PM 10 ) and Fine Particulate Matter (PM 2.5 ) Particulate matter is a mixture of extremely small solid and liquid particles of various chemicals and other materials. Typical sources include dust from construction activities, automobile tires, automobile exhaust, factories, and wild fires. Both PM10 and PM2.5 are small enough to be inhaled into the lungs. Inhalation of particulate matter can have negative health consequences, including decreased lung function, chronic bronchitis, and aggravation of asthma symptoms. Hudson Ranch Power II and Simbol Calipatria II Final EIR

100 4.3 Air Quality Nitrogen Dioxide (NO 2 ) NO2 is a reddish brown, odorless gas that is one of several gases collectively known as NOx. NO2 is also a key component of fine particulate matter. Typical sources of NO2 include exhaust from automobiles, as well as off-road equipment, factories, and power plants. Health effects associated with NO2 include nose, throat, and lung irritation, coughing, and chest pain. NO2 can also exacerbate respiratory symptoms in people with asthma. Lead (Pb) Lead is a naturally occurring metal used in a variety of industrial and commercial applications. As leaded gasoline has been phased out of use, lead emissions have dropped dramatically, and current primary sources are mining, smelting, and refining activities and aircraft that use leaded aircraft fuel (EPA 2012b). Lead exposure has been associated with learning disabilities and behavioral problems in children, kidney damage, and negative effects on the nervous and cardiovascular systems. Sulfur Dioxide (SO 2 ) SO2 is one of several highly reactive gasses known as oxides of sulfur (SOx) and is formed by burning fuel containing sulfur. Typical sources include emissions from burning coal or oil at power plants and factories. Typical health effects associated with exposure to sulfur dioxide include respiratory illness and exacerbation of respiratory symptoms in people with asthma. Sulfates Sulfates are the fully oxidized ionic form of sulfur produced when sulfur dioxide is fully oxidized in the atmosphere. Sulfates are produced by emissions from automobiles, power plants, and industrial activity, and contribute to general atmospheric haziness. Typical health effects associated with exposure to sulfates include respiratory illness and an increased risk of cardio-pulmonary disease. Vinyl Chloride Vinyl chloride is an artificially created colorless gas with a mild, slightly sweet odor. The gas is used in the manufacture of vinyl products, including polyvinyl chloride (PVC) plastic. Vinyl chloride emissions are produced from the vinyl manufacturing process as well as from the breakdown of vinyl products in landfills and hazardous waste sites. The health effects associated with vinyl chloride include dizziness, headaches, and drowsiness from shortterm exposure, and liver damage and cancer resulting from long-term exposure. Hudson Ranch Power II and Simbol Calipatria II Final EIR

101 4.3 Air Quality Hydrogen Sulfide (H 2 S) H2S is a naturally occurring, colorless gas that at low concentrations produces a distinctive rotten egg odor. At higher concentrations, olfactory fatigue prevents detection of odor. The gas is produced through the bacteriological breakdown of organic materials as well as during oil and gas production and geothermal power generation. Health effects associated with H2S include exposure to a disagreeable odor, coughing, irritation to eyes, and impairment of the respiratory system. Visibility Reducing Particles Visibility reducing particles are particulate matter composed of many different substances that are suspended in the atmosphere and contribute to haze and diminished visibility. Table provides a summary of the common sources and health effects of each criteria air pollutant. TABLE SUMMARY OF COMMON SOURCES AND EFFECTS OF CRITERIA POLLUTANTS CRITERIA AIR POLLUTANT COMMON SOURCES EFFECTS Ozone (O3) Paints, aerosols, secondary formation in the atmosphere Respiratory tract irritation, coughing, nausea, eye irritation, decreased pulmonary function Carbon Monoxide (CO) Automobiles and ground-based vehicles Reduction in oxygen in the blood, cardiovascular difficulties, impaired mental function Respirable Particulate Matter (PM10) Fine Particulate Matter (PM2.5) Nitrogen Dioxide (NO2) Lead (Pb) Sulfur Dioxide (SO2) Construction activities, automobile tires, automobile exhaust, factories, and wild fires Construction activities, automobile tires, automobile exhaust, factories, and wild fires Automobiles, off-road equipment, factories, and power plants Mining, smelting and refining, leaded aircraft fuel Power plants, factories burning fossil fuels (e.g., coal and oil) Decreased lung function, chronic bronchitis, aggravated asthma symptoms Decreased lung function, chronic bronchitis, aggravated asthma symptoms Nose, throat, and lung irritation, coughing, chest pain, aggravated asthma symptoms Learning disabilities, behavioral problems in children, kidney damage, nervous and cardiovascular system problems Respiratory illness, aggravated asthma symptoms Sulfates Automobiles, power plants, industrial activity Respiratory illness, cardio-pulmonary disease Vinyl Chloride Hydrogen Sulfide (H2S) Visibility Reducing Particles Sources: CARB 2009 Manufacturing, breakdown of vinyl products in landfills and hazardous waste sites Bacteriological breakdown of organic materials, geothermal activity Construction activities, automobile tires, automobile exhaust, factories, and wild fires Dizziness, headaches, drowsiness, liver damage, cancer Coughing, irritation to eyes, respiratory system impairment Decreased lung function, chronic bronchitis, aggravated asthma symptoms Hudson Ranch Power II and Simbol Calipatria II Final EIR

102 4.3 Air Quality Toxic Air Contaminants/Hazardous Air Pollutants Toxic air contaminants (TACs) are designated in the State of California as a wide range of pollutants that may cause or contribute to an increase in deaths or in serious illness, or which may pose a present or potential hazard to human health (CARB 2010a). Health effects associated with TACs, including cancer, are typically the result of acute or repeated exposure to these pollutants. On a federal level, the EPA has designated a list of hazardous air pollutants (HAPs) that "may reasonably be anticipated to result in an increase in mortality or an increase in serious irreversible or incapacitating reversible illness." (EPA 2010).Currently, both the EPA and the State of California have recognized nearly 200 different contaminants as TACs and/or HAPs. CARB has identified ten specific pollutants as posing the greatest risk to human health based on ambient background levels in the state. The potential TACs and/or HAPs of most concern associated with the proposed Projects are benzene, hydrochloric acid (HCl) vapors, and diesel particulate matter (DPM). Benzene Benzene is a colorless, flammable liquid with a pleasant, sweet odor that evaporates quickly when exposed to air. Benzene is produced naturally through geothermal processes, as a component of petroleum and natural gas, and as a byproduct of burning wood and other plant matter. Anthropomorphic sources of benzene include use as an ingredient in solvents and as an additive to gasoline. Hydrochloric Acid (HCl) HCl is a colorless liquid with a pungent odor, or a colorless to slightly yellow gas, commonly used in the chemical, mining, water treatment, waste management, and food industries, among others. HCl is one of the most corrosive of the non-oxidizing acids in contact with copper alloys, and is handled in dilute solutions. It is soluble in benzene, alcohol, and ether; it is insoluble in hydrocarbons, and incompatible or reactive with metals, hydroxides, amines, and alkalis. HCl fumes have an acid, penetrating odor. Inhalation of the spray mist may produce severe irritation of the respiratory tract, characterized by coughing, choking, or shortness of breath. Severe over-exposure can result in death. Inflammation of the eye is characterized by redness, watering, and itching. Skin inflammation is characterized by itching, scaling, reddening, or, occasionally, blistering (Sciencelab 2010). Diesel Particulate Matter (DPM) DPM is produced by the combustion of diesel fuel and is composed of a mixture of various gases and fine particulate matter (i.e., soot). The California Air Resources Board (CARB) recognized the particulate matter in DPM as a TAC in 1998 based on its potential to cause cancer and contribute to other adverse health effects (CARB 2011b). Hudson Ranch Power II and Simbol Calipatria II Final EIR

103 4.3 Air Quality Other Substances of Concern Ammonia Ammonia is another substance of concern for the proposed Projects. Ammonia is listed neither as a criteria air pollutant, TAC, or HAP 1. Ammonia is a widely-used strongly alkaline chemical which can be volatile. The proposed Projects would produce ammonia from the geothermal reservoir by operation of the geothermal wells and subsequent use of geothermal brine. No storage of ammonia would be involved as a result of the Projects operations. Ammonia vapors cause irritation of the eyes and the respiratory tract. Higher concentrations cause conjunctivitis, laryngitis, and pulmonary edema, possibly accompanied by a feeling of suffocation (Cal/EPA 1999). Ammonia also is responsible for neutralizing a large fraction of acidic gases promoting the formation of atmospheric particles. The EPA recommends monitoring of ammonia gas for identifying when PM2.5 formation in an area that is limited by ammonia or nitric acid (EPA 2007). However, under ICAPCD Rule 101, ammonia is not listed as a precursor or a secondary pollutant. Further, similar geothermal projects analyzed in Southern California have recognized that although these reactions could occur, there is not sufficient evidence to demonstrate that the concurrence of all conditions necessary for particulate formation from geothermal wells operations is supported by meteorological and other data (CEC 2003). ODORS Odors are generally considered a nuisance rather than a health hazard and can lead to discomfort and distress among the general public. Investigations involving nuisance odors are governed by the perception of the receptor. A person s perception of odor is related to the human olfactory system, which can vary from person to person; therefore, the ability to identify and qualify odors is a complex and subjective issue. In addition, regular exposure to odor may cause desensitization, resulting in odor fatigue, whereby once recognized odors go unnoticed unless there is a change in the odor s intensity. Odors produced as a result of geothermal energy production can include the sulfurous, rotten egg smell characteristic of H2S emissions. Similarly, the combustion of diesel fuel to power construction or operations of combustion equipment can produce odors due to the sulfur content of diesel fuel. Additionally, the geothermal brine would also contain ammonia, which is a colorless gas with a characteristic pungent odor. BACKGROUND CONCENTRATIONS The Imperial County Air Pollution Control District (ICAPCD) and CARB maintain a network of seven ambient air quality monitoring stations in Imperial County. Five of these stations (Niland, Brawley, Westmorland, El Centro, and Calexico-Grant Street) are operated by the ICAPCD and two stations 1 CARB has listed ammonia as Category IIb, or Substance not identified as Toxic Air Contaminant known to be emitted in California, with one or more health values under development by the Office of Environmental Health Hazard Assessment for review by the Scientific Review Panel (CARB 2010b). Hudson Ranch Power II and Simbol Calipatria II Final EIR

104 4.3 Air Quality (Calexico-Ethel Street and Calexico-East) are operated by CARB. The purpose of the monitoring network is to measure air pollutant levels in air. As indicated previously, the air basin is currently designated as being in nonattainment for ozone and PM10 with respect to NAAQS and CAAQS. In addition, certain areas within the SSAB (but not the area where the proposed Projects are to be located) are designated as being in nonattainment for PM2.5 with respect to NAAQS. The closest monitoring station to the proposed Project site is located at 7711 English Road in the Town of Niland, approximately 0.57 miles north of the boundary of the Projects site. While both ozone and PM10 are measured at the Niland air monitoring station; none of the other criteria pollutants are monitored at this station. The Brawley monitoring station, located at 220 Main Street, approximately 26 miles south of the proposed Project site, monitors PM2.5 in addition to ozone and PM10. Table shows a summary of the monitoring data for these pollutants for years 2006 through REGULATORY SETTING FEDERAL AND STATE Federal Clean Air Act and California Clean Air Act The Clean Air Act of 1970 (CAA) (42 United States Code [U.S.C.] ) (last amended by the Clean Air Act Amendments of 1990 [104 Stat. 2468, P.L ]), defines the EPA s role in managing air quality in the United States. Under the CAA, the EPA promulgated the NAAQS (40 CFR Part 50), setting limits on the acceptable ambient air concentrations for each of the federally identified criteria air pollutants. Similar to the CAA, the California Clean Air Act of 1988 (CCAA) (Stats. 1988, Ch. 1568) requires all air quality planning regions to achieve and maintain the CAAQS by the earliest date practicable. The CCAA also requires that air quality regions that have failed to meet the CAAQS work with the CARB to prepare State Implementation Plans (SIPs) demonstrating when and how the CAAQS will be met. California Air Resources Board (CARB) The CARB, a part of the California Environmental Protection Agency (Cal/EPA), is responsible for interpreting and implementing state statutes that manage air pollution. CARB gathers air quality data for the State of California, ensures the quality of these data, designs and implements air models, sets ambient air quality standards for the state, compiles the state s emissions inventories, and performs air quality and emissions inventory special studies. CARB is responsible for monitoring the regulatory activity of California s 35 local and regional air pollution control districts. These districts regulate stationary emissions sources (i.e., industrial pollution sources), issue air quality permits, develop local air quality plans, and ensure that industries under their jurisdiction adhere to air quality mandates. Hudson Ranch Power II and Simbol Calipatria II Final EIR

105 4.3 Air Quality TABLE MONITORING STATION Niland (English Road) Brawley (Main Street) Source: CARB 2012b BACKGROUND AIR QUALITY DATA OZONE (O3) POLLUTANT MONITORING YEAR Maximum Concentration 1-Hr. Period (ppm) Maximum Concentration 8-Hr. Period (ppm) Number of Days National Standard Exceeded (8-Hr. Period) Number of Days State Standard Exceeded (8-Hr. Period) RESPIRABLE PARTICULATE MATTER (PM10) 1 Maximum Concentration 24-Hr. Period (µg/m 3 ) Based on method to compare with National Standard Number of Days National Standard Exceeded (24-Hr. Period) Maximum Concentration 24-Hr. Period (µg/m 3 ) Based on method to compare with State Standard Number of Days State Standard Exceeded (24-Hr. Period) OZONE (O3) Maximum Concentration 1-Hr. Period (ppm) NA NA Maximum Concentration 8-Hr. Period (ppm) NA NA Number of Days National Standard Exceeded (8-Hr. Period) NA NA Number of Days State Standard Exceeded (8-Hr. Period) NA NA RESPIRABLE PARTICULATE MATTER (PM10) 1 Maximum Concentration 24-Hr. Period (µg/m 3 ) Based on method to compare with National Standard Number of Days National Standard Exceeded (24-Hr. Period) Maximum Concentration 24-Hr. Period (µg/m 3 ) Based on method to compare with State Standard Number of Days State Standard Exceeded (24-Hr. Period) FINE PARTICULATE MATTER (PM 2.5) Maximum Concentration 24-Hr. Period (µg/m3) Number of Days National Standard Exceeded (24-Hr. Period) 2 * * 0 * * Notes: 1 National maximum concentrations calculated for standard conditions and state maximum concentrations calculated for local conditions. Standard conditions are corrected for local temperature and atmospheric pressure. 2 Fractional number of days of National and State Standard Exceedance, as reported by CARB, have been rounded to next highest whole number. Key: * = Insufficient data available Hudson Ranch Power II and Simbol Calipatria II Final EIR

106 4.3 Air Quality LOCAL Imperial County Air Pollution Control District (ICAPCD) The ICAPCD is the local air pollution control agency for Imperial County, which includes the southern half of the SSAB. The ICAPCD has primary responsibility for ensuring that state and federal air quality standards are attained and maintained within the ICAPCD s jurisdiction. To that end, the ICAPCD is responsible for preparing clean air plans, issuing construction and operation permits, monitoring ambient air quality, and promulgating rules and regulations governing air quality within Imperial County. The ICAPCD has also produced California Environmental Quality Act (CEQA) guidelines that include significance thresholds for determining potential impacts to air quality from operational and construction related gas emissions. Rules and regulations promulgated by the ICAPCD applicable to the proposed Projects include the following: ICAPCD Rule 207.C.1, New and Modified Stationary Source Review (best available control technologies [BACT]), requires that any new or modified emissions unit that has a potential to emit 25 pounds per day or more of any nonattainment pollutant or its precursors, or 55 pounds per day of H2S, must include best available control technology (BACT) as a part of the Projects. ICAPCD Rule 207.C.2, New and Modified Stationary Source Review (Offsets), requires the purchase of offsets for facility emissions of criteria air pollutants in excess of 137 pounds a day. ICAPCD Rule 400, Nuisances, forbids the emission of air contaminants or other materials that would cause a nuisance to the public, including non-agricultural related odors. ICAPCD Regulation VIII, Rule 801 (Construction and Earthmoving Activities) requires the implementation of a dust management control plan for all non-residential projects of five acres or more. ICAPCD Rule 900, Major Stationary Source Permits, Rule 900 implements the requirements of Title V of the federal CAA as amended in 1990 for permits to operate. Title V provides for the establishment of operating permit programs for sources which emit regulated air pollutants, including attainment and nonattainment pollutants. Imperial County 2009 PM10 State Implementation Plan Based on the fact that six Imperial County monitoring stations were in violation of the PM10 24-hour standard during , in December, 2007, the EPA issued a final rule action requiring the state to submit an air quality plan demonstrating that Imperial County will attain the PM10 standard as expeditiously as practicable. In August, 2009, the ICAPCD Board adopted the Imperial County 2009 PM10 State Implementation Plan (SIP). Efforts coordinated by Imperial County also include the 2005 amendments of the District s Regulation VIII Best Available Control Methods (BACM), adopted in advance of the PM10 SIP for the purposes of accelerating BACM implementation and of meeting the requirements and schedule of the County s Natural Event Action Plan. Hudson Ranch Power II and Simbol Calipatria II Final EIR

107 4.3 Air Quality The 2009 Imperial County PM10 SIP addresses the following elements, required under the CAA of areas classified to be in serious nonattainment of the NAAQS: Best available emission inventories; A plan that enables attainment of the PM10 federal air quality standards; Annual reductions in PM10 or PM10 precursor emissions that are not less than 5 percent from the date of SIP submission until attainment; Best available control measures and best available control technologies for significant sources and major stationary sources 2 of PM10, to be implemented no later than 4 years after reclassification of the area as serious; Transportation conformity and quantitative milestones; and Contingency measures to be implemented (without the need for additional rulemaking actions) in the event that the control measure regulations incorporated in the plan cannot be successfully implemented or fail to give the expected emissions reductions. Imperial County Hour Ozone Modified Air Quality Management Plan In December, 2009, the EPA promulgated a clean data finding for Imperial County, indicating that the County s air quality now complies with the hour ozone ambient air quality standard. This action suspended certain CAA requirements that Imperial County would have had to address as a moderate ozone nonattainment area. In July, 2010, the ICAPCD adopted the 2009 Ozone Air Quality Attainment Plan (AQAP) and the 2009 Reasonably Available Control Technology (RACT) SIP to fulfill CAA requirements that were not suspended by the clean data finding and to fulfill RACT requirements for moderate nonattainment areas. County of Imperial General Plan The County of Imperial General Plan consists of nine elements including Land Use, Housing, Circulation and Scenic Highways, Noise, Seismic and Public Safety, Agricultural, Conservation and Open Space, Geothermal and Transmission, and Water. The Land Use, Conservation and Open Space, and Geothermal and Transmission elements include policies for protecting air quality that are applicable to the proposed Projects. Table includes an analysis of the proposed Projects consistency with the applicable policies. 2 A major stationary source is defined in a serious nonattainment area for PM10 as any source that has the potential to emit 70 tons per year of PM10 or PM10 precursors. Hudson Ranch Power II and Simbol Calipatria II Final EIR

108 4.3 Air Quality TABLE HR-2 AND SMCP-2 PROJECTS CONSISTENCY WITH APPLICABLE GENERAL PLAN AIR QUALITY GOALS AND OBJECTIVES GENERAL PLAN POLICIES CONSISTENCY ANALYSIS LAND USE ELEMENT (LUE) LUE Objective 9.6: Incorporate the strategies of the Imperial County Air Quality Attainment Plan (AQAP) in land use planning decisions and as amended. LU Objective 9.7: Implement a review procedure for land use planning and discretionary project review which includes the Imperial County Air Pollution Control District. CONSERVATION AND OPEN SPACE ELEMENT (COSE) COSE Goal 9: The County shall actively seek to improve and maintain the quality of air in the region. COSE Objective 9.1: Ensure that all facilities shall comply with current federal and state requirements for attainment of air quality objectives. COSE Objective 9.2: Cooperate with all federal and state agencies in the effort to attain air quality objectives. Yes Yes Yes Yes Yes The AQAP includes the rules and regulations promulgated by the ICAPCD that are applicable to land use projects in Imperial County. The proposed Projects will each require an Authority to Construct and a Permit to Operate issued by the ICAPCD. Accordingly, the proposed Projects must comply with applicable ICAPCD rules and regulations, either through project design or inclusion of mitigation, to qualify for the necessary permits to implement construction and operation. As the air pollution control district for the County, the ICAPCD must review all projects subject to environmental documentation. This review may entail the required inclusion of mitigation or other measures to reduce project emissions to levels acceptable per ICAPCD rules and regulations. The ICAPCD will review the proposed Projects as part of the CEQA process. The ICAPCD seeks to improve and maintain the quality of air in Imperial County through issuance of air quality management plans, rules, and regulations that reflect both state and federal requirements for meeting air quality objectives. The proposed Projects must comply with the requirements of these plans, rules, and regulations to gain approval from the County. The proposed Projects will obtain Authorities to Construct and Permits to Operate from the ICAPCD. Issuance of these permits will be evidence of compliance with current federal and state requirements for attainment of air quality objectives. The ICAPCD seeks to improve and maintain the quality of air in Imperial County through issuance of air quality management plans, rules, and regulations that reflect both state and federal requirements for meeting air quality objectives. The proposed Projects must comply with the requirements of these plans, rules, and regulations to gain approval from the County. Hudson Ranch Power II and Simbol Calipatria II Final EIR

109 4.3 Air Quality TABLE HR-2 AND SMCP-2 PROJECTS CONSISTENCY WITH APPLICABLE GENERAL PLAN AIR QUALITY GOALS AND OBJECTIVES GENERAL PLAN POLICIES CONSISTENCY ANALYSIS Geothermal and Transmission Element (GTE) Objective 9.7: Assure that geothermal and transmission line development complies with Imperial County Air Pollution Control District s regulations and mitigation measures. Source: County of Imperial 1993, 2006, and Yes As the air pollution control district for the County, the ICAPCD must review all projects subject to environmental documentation. This review may entail the required inclusion of mitigation or other measures to reduce each project s emissions to levels acceptable per ICAPCD rules and regulations. Furthermore, the ICAPCD is responsible for issuing permits for construction and operation of the proposed Projects. Accordingly, the proposed Projects must comply with applicable ICAPCD rules and regulations, either through Projects design or inclusion of mitigation, to qualify for the necessary permits to implement construction and operation IMPACTS AND MITIGATION MEASURES SIGNIFICANCE CRITERIA The impact analysis provided below is based on the following State CEQA Guidelines Appendix G. An impact is considered significant if the project would: 1. Conflict with or obstruct implementation of the applicable air quality plan. 2. Violate any air quality standard or contribute substantially to an existing or projected air quality violation. 3. Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors). 4. Expose sensitive receptors to substantial pollutant concentrations. 5. Create objectionable odors affecting a substantial number of people. ICAPCD THRESHOLDS OF SIGNIFICANCE While final determination of whether or not a project is significant relies on the responsibility of the lead agency pursuant to Section 15064(b) of the State CEQA Guidelines, the ICAPCD recommends the use of air pollution thresholds as guidance in determining whether a project could result in a significant air quality impact (Table 4.3-6). If the lead agency finds that a project has the potential to exceed these air pollution thresholds, the project s impact would be considered significant. Hudson Ranch Power II and Simbol Calipatria II Final EIR

110 4.3 Air Quality TABLE ICAPCD RECOMMENDED THRESHOLDS OF SIGNIFICANCE CRITERIA POLLUTANT OPERATIONS (POUNDS/DAY) CONSTRUCTION (POUNDS/DAY) NOx ROG PM SOx CO Source: ICAPCD For construction emissions, the ICAPCD CEQA Handbook (2007) recommends conducting initial analyses based on a qualitative approach and the implementation of effective and comprehensive mitigation measures. Projects exceeding the construction thresholds are required to submit a detailed emissions analysis, and implement standard, discretionary, and enhanced mitigation measures for construction equipment and fugitive PM10. In addition, a health risk assessment is recommended if a project would have the potential to emit pollutants and is located in close proximity to sensitive receptors. Because the operational phase of a project has the potential of creating long term impacts on air quality, the ICAPCD recommends that projects whose operational emissions are expected to exceed the thresholds of significance be deemed to have a potentially significant adverse impact on air quality. For industrial development, the ICAPCD recommends operational thresholds (as listed in Table 4.3-6) be used only to determine significance of the impact from mobile source emissions attracted to the stationary source. Thresholds in Table would not be used to determine significance for the air emissions associated with the stationary source, including off-road mobile emissions produced within the stationary source; since those sources are already subject to mitigation according to ICAPCD Rules 207 and 201. However, the ICAPCD CEQA Guidance also states that the Lead Agency has the authority to request a comprehensive air quality analysis or an EIR to address the impact of all sources regardless of the recommended operational thresholds. For the purposes of this analysis, air pollutant emissions from stationary sources associated with the proposed Projects operations are compared with the ICAPCD Rule 207 Standards, as defined in Subsection C.1, and Offset Requirements, as defined in Subsection C.2 (refer to Section 4.3.2, Regulatory Setting, for emission limits). These standards are applicable as threshold of significance for operational stationary sources only. The ICAPCD has not adopted a specific threshold of significance for TACs, but ICAPCD recommends it be consulted on any project with the potential to emit toxic or hazardous air pollutants. A health risk assessment may be also required to determine the potential level of risk associated with the operation and if emissions would exceed a certain magnitude, especially those located in close proximity to already existing industrial type operations and/or have the potential to emit TACs. Hudson Ranch Power II and Simbol Calipatria II Final EIR

111 4.3 Air Quality Consistent with the California Air Pollution Control Officers Association (CAPCOA) guidance for performing analysis and risk assessments related to TACs (CAPCOA 2009), for acute (short-term), non-cancerous health effects and chronic (long-term) non-cancerous health effects, impacts are considered significant if the proposed Projects would result in emissions that pose an acute or chronic health risk with a health hazard index (HHI) of 1 or greater. The acute HHI is the ratio of the average short term ambient concentration of an acutely toxic substance or substances, divided by the acute reference response level set by the California Office of Health Hazard Assessment (OEHHA). Similarly, the chronic HHI is the ratio of the average annual ambient concentration of a chronic toxic substance divided by the chronic reference exposure level set by the OEHHA (CAPCOA 2009). For potentially carcinogenic effects associated with TAC emissions, impacts are considered significant if the Projects would pose a lifetime cancer risk of greater than one in one million (Cal/EPA 2003). ENVIRONMENTAL PROTECTION MEASURES Chapter 3 provides a complete list and description of Environmental Protection Measures (EPMs) that Hudson Ranch Power II, LLC and Simbol, Inc. have incorporated into their respective projects to avoid or minimize impacts on all resources. The HR-2 EPMs that are proposed to minimize or avoid impacts to air quality resources are as follows: HR-2 Construction Environmental Protection Measures EPM AQ-1: Fugitive Dust Suppression Plan. This plan will provide a detailed list of control measures to reduce fugitive emissions from construction and operational activities, including, but not limited to, watering of unpaved roads, vehicle speed limits, windbreaks, transport container covers, and cleaning and sweeping procedures. EPM AQ-2: Well Drilling Compliance Program. This program will require contractors to obtain Imperial County Air Pollution Control District permits to minimize air emissions. EPM AQ-3: Exhaust Emissions Control Program. This plan will provide a detailed list of control measures to minimize exhaust emissions during project construction, including, but not limited to, fuel use, engine maintenance, and procedures. EPM AQ-4: Well Flow Testing Program. This program uses design features such as well test units to minimize the release of particulate matter and metals. This program includes flow rate and duration limits. EPM AQ-9: Air Quality Protection. Fugitive dust generation during construction and use of on-site plant roads and the well sites will be minimized by watering, as necessary. To further reduce fugitive dust emissions, vehicle traffic on plant roads and well sites will be kept below 15 miles per hour. Hudson Ranch Power II and Simbol Calipatria II Final EIR

112 4.3 Air Quality HR-2 Plant Operations Environmental Protection Measures EPM AQ-5: Cooling Tower Emission Program. This program incorporates the Biox hydrogen sulfide abatement program to minimize hydrogen sulfide emissions from both the vent gas and the portion of condenser condensate being used as cooling tower makeup. EPM AQ-6: Dilution Water Heater Emission Program. This program uses design measures to control and minimize dilution water heater emissions. EPM AQ-7: Filter Cake Fugitive Emissions Control Plan. This plan incorporates handling procedures to control the potential fugitive emissions of particulate matter, including direct loading and tarping. EPM AQ-8: Operating and Maintenance Equipment Emission Control Program. This program will control air pollutant emissions from operating and maintenance equipment by meeting any applicable road or non-road emissions standards and maintaining the equipment with manufacturers recommended procedures. EPM AQ-9: Air Quality Protection. Fugitive dust generation during construction and use of on-site plant roads and the well sites will be minimized by watering, as necessary. To further reduce fugitive dust emissions, vehicle traffic on plant roads and well sites will be kept below 15 miles per hour. The SmCP-2 EPMs that are proposed to minimize or avoid impacts to air quality resources are included as follows: SmCP-2 Construction Environmental Protection Measures EPM AQ -1: Air Quality Protection. An application would be submitted to the ICAPCD for an Authority to Construct permit for the site construction activities and any operational equipment or emission sources requiring a permit. The Plan specifies a detailed list of control measures to reduce fugitive emissions from operational and maintenance activities, including but not limited to watering of unpaved roads, vehicle speed limits, windbreaks, transport container covers, cleaning and sweeping procedures. The Project would comply with the ICAPCD permit conditions of approval to limit emissions from the Project activities. EPM AQ-9: Fugitive Dust Suppression Plan. Specifies detailed list of control measures to reduce fugitive emissions from operational and maintenance activities included but not limited to watering of unpaved roads, vehicle speed limits, windbreaks, transport container covers, cleaning and sweeping procedures. SmCP-2 Plant Operations Environmental Protection Measures EPM AQ-2: Exhaust Emissions Control Program. SmCP-2 Specifies detailed list of control measures to minimize exhaust emissions during operation of the project, including but not limited to fuel use, engine maintenance, and procedures. Hudson Ranch Power II and Simbol Calipatria II Final EIR

113 4.3 Air Quality EPM AQ 3: Cooling Tower Emission Program. Maintain low total dissolved solids content of the circulating cooling tower, and utilize high efficiency drift eliminators to minimize particulate emissions. EPM AQ 4: Process Equipment Emission Control. Process equipment emission control includes: Mist eliminators for water vapor during venting Filter press operations will be conducted in enclosures to control particulates Off-gas vapor scrubbers from the HCl production process Baghouse dust collectors or the equivalent will be used to minimize these emissions from dry reagent transfer and making systems The Lithium Production and Packaging Buildings air will be filtered and a negative pressure will be maintained to prevent fugitive dust emissions. EPM AQ 5: Filter Cake Storage Fugitive Emissions Control. Incorporates handling procedures to control the potential fugitive emissions of particulate matter, including direct loading into storage containers, and tarping. EPM AQ 6: Emergency Generators/Fire Pump Emission Control Program. Emergency generators will meet all current regulatory emission standards. The sulfur content of fuel used will meet the current California Air Resources Board (CARB) standards. Maintenance and testing operation of each emergency generator will not exceed 50 hours per year. EPM AQ 7: Operating & Maintenance Equipment Emission Control Program. Would control this equipment by meeting any applicable road or non-road 2001 emissions standards, as amended, and maintaining the equipment with manufacture s recommended procedures. EPM AQ 8: Potential Emissions Control Program. Would control potential temporary emissions by limiting the operation of temporary sources. Changes to process operations will undergo review for their environmental impact before adoption. ADDITIONAL AIR QUALITY MODELING ASSUMPTIONS In addition to the EPMs, the following practices were included as assumptions of the air pollutant emissions estimations described in Appendix C. HR-2 Project construction: Dust Control during Asphalt Paving. The unpaved portion of McDonald Road between Highway 111 and English Road will be coated with an asphaltic dust palliative (ARAM or equivalent) at the beginning of the HR-2 Project construction. This coating has been determined by the ICAPCD to be an equivalent fugitive dust control measure to actual asphalt paving. Hudson Ranch Power II and Simbol Calipatria II Final EIR

114 4.3 Air Quality Diesel Engines with Certified NOx Emissions. The HR-2 Project will require the grading contractor to use construction equipment using diesel engines with certified NOx emissions rated as Tier 3 or better. Reduction of Fugitive Dust Emissions. During grading, the HR-2 Project would be watering actively disturbed onsite areas at least three times a day as necessary to reduce fugitive dust emissions. HR-2 Project Operations: Power during Operations. During operations, the HR-2 power plant would generate power to service its own electrical load and would not need to purchase electrical energy. Non-Condensable Gas Removal and Emission Abatement Systems. The Turbine Generator Facility (TGF) would include non-condensable gas removal and emission abatement systems. The abatement system is expected to remove at least 95 percent of the hydrogen sulfide (H2S) in the non-condensable gases. Additionally, particle emissions from the cooling towers would be minimized by using high efficiency drift eliminators. Generators That Meet Pollutant Emission Limits. The two proposed standby/ black start diesel engine generators, one emergency generator and one emergency fire pump engine would each meet the applicable EPA and CARB air pollutant emission limits. Each engine would be tested for less than 50 hours per year. Exhaust Emissions Control Program. Specifies detailed list of control measures to minimize exhaust emissions during operation of the Project, including but not limited to fuel use, engine maintenance, and procedures. SmCP-2 Project construction: Diesel Engines with Certified NOx Emissions. The SmCP-2 applicant will require the grading contractor to use construction equipment using diesel engines with certified NOx emissions rated as Tier 3 or better. Reduction of Fugitive Dust Emissions. During grading, the SmCP-2 Project would be watering actively disturbed onsite areas at least three times a day as necessary to reduce fugitive dust emissions. METHODOLOGY Air pollutant emissions for both construction and operations of the proposed Projects were estimated using a combination of methods. For some of the Projects sources, construction and operational emissions for both the HR-2 and SmCP-2 were estimated using the California Emission Estimator Model (CalEEMod) (version ), which can be used to estimate air pollutant emissions for various land uses, area sources, construction and operational activities, and vehicle travel. Additionally, the CalEEMod emission factors were used for estimating operational emissions associated with annual electrical energy use and water consumption. Hudson Ranch Power II and Simbol Calipatria II Final EIR

115 4.3 Air Quality For other Projects operations and construction activities, air pollutant emissions were calculated using the U.S. EPA AP-42 Compilation of Air Pollutant Emission Factors, the CARB area-wide source methodologies (for land preparation emissions), and the GHG emission factors provided in the California Climate Action Registry General Reporting Protocol (version 3.0). In order to best utilize the capabilities of the CalEEMod and the other emission factor methodologies used, the applicants calculated emissions from both Projects activities in multiple CalEEMod models and separate calculations using applicable emission factors. Given that the version of CalEEMod used for estimating construction emissions had incorrect emission factors for NOx, ROG and TOG emissions for Tier 2 and Tier 3 engines, the applicants generated corrected Tier 3 mitigated emissions for construction equipment as part of each of the air emissions reports (Appendix C). Furthermore, the applicants conducted an assessment of the potential health risks from air toxics which may be emitted by the proposed Projects. This assessment has been prepared consistent with the methodology described in the OEHHA Air Toxics Hot Spots Program Guidance for Preparation of Health Risk Assessments (Cal/EPA 2003). Results from this assessment have been compared with recommended limits established by OEHHA for maximum acute hazard and risk, the maximum chronic non-cancer risk, and Cal/EPA for the maximum cancer risk. Because the SmCP-2 plant would be dependent on the geothermal brine produced by the HR-2 geothermal flash plant, it would not be constructed or could not operate without the HR-2 geothermal operations. However, the HR-2 Project could operate without SmCP-2. Therefore, the air quality and air toxics health risk analyses presented as follows considered (a) construction and operations of HR-2 only; and (b) the combined construction and operation impacts of HR-2 and SmCP-2. OVERVIEW OF CONSTRUCTION AND OPERATIONAL EMISSIONS HR-2 Construction Emissions The HR-2 Project construction would take approximately 28 months to complete (i.e., from July 2013 until June 2015). Construction activities would initiate with application of an asphaltic dust palliative (ARAM or equivalent) on an unpaved portion of McDonald Road that provides access into the proposed HR-2 plant site 3, then following with the site preparation, grading, foundation construction, building erection, architectural coating, onsite paving, well site grading, drill rig assembly, well drilling and testing. Emissions from the proposed construction activities would include combustion emissions from onsite heavy-duty diesel and gasoline powered equipment and offsite vehicle use, ROG from coating, and fugitive dust from earthmoving and offsite traffic in paved and unpaved roads 4. Additionally, construction of the HR-2 Project would also involve the release of hydrogen sulfide (H2S) during well drilling and testing operations. H2S 3 During construction, the HR-2 Project would apply the ARAM dust palliative. Paving of McDonald Road in full would be an activity covered by the Simbol Calipatria Plant I (SmCP-1) Project. However, in the event the SmCP-1 would not be approved; it has been assumed that the HR-2 project will include paving emissions as part of the air quality analysis. 4 Concrete and/or asphaltic paving would be applied on the HR-2 Project onsite roads. Hudson Ranch Power II and Simbol Calipatria II Final EIR

116 4.3 Air Quality emissions during drilling and flow testing would occur on a short term basis at each well location and would be conducted under a permit from the ICAPCD. Table presents a summary of the estimated daily emissions for each year of construction, based on the anticipated construction schedule, phasing of the proposed activities, and implementation of the proposed EPMs. It is anticipated that certain construction activities, such as building erection, would overlap for at least one month with the well pad site grading, drill rig assembly, well drilling and testing. Detailed emissions estimates are included in Appendix C. TABLE SUMMARY OF HR-2 DAILY CONSTRUCTION AIR POLLUTANT EMISSIONS MAXIMUM DAILY EMISSIONS (LB/DAY) YEAR EMISSIONS/THRESHOLD ROG NOX CO SO 2 PM 10 PM Construction Emissions ICAPCD Threshold NA 150 NA Exceeds Threshold? No No No NA No NA 2014 Construction and Well Drilling Emissions ICAPCD Threshold NA 150 NA Exceeds Threshold? No No No NA No NA 2015 Construction and Well Drilling Emissions ICAPCD Threshold NA 150 NA Exceeds Threshold? No No No NA No NA Source: EMA 2012a Note: Geothermal well drilling would occur in years 2014 and 2015 and emissions sources associated with this activity would include drill rig; off-road equipment used during well assembly, drill and well testing; and worker and vendor vehicle use. HR-2 Operational Emissions Operations of the proposed HR-2 geothermal power plant would involve stationary and mobile emission sources associated with the proposed Brine Processing Facility (BPF), the Turbine-Generator Facility (TGF), common and ancillary facilities, a new overhead interconnection line, a water conveyance system, and worker and vendor vehicle use. Operational emissions associated with the HR-2 facility would include combustion emissions from onsite equipment and offsite traffic; noncondensable gases (NCG) from the geothermal brine containing H2S, ROG, benzene, ammonia, and traces of other substances (methane, nitrogen, hydrogen, and argon); HCl vapors from storage tanks; particulate emissions from the cooling tower operations and traffic on unpaved roads; and the use of architectural coating and consumer products during maintenance. Benzene, H2S, and ammonia, contained in naturally occurring gases produced with the geothermal fluids, would be emitted from the geothermal plant. HCl, used to chemically stabilize the geothermal brine once the steam and NCG are removed, would be emitted during the filling of the HCl storage tank. DPM would be emitted during testing, maintenance, and operation of standby/ black start and emergency diesel Hudson Ranch Power II and Simbol Calipatria II Final EIR

117 4.3 Air Quality engines. During plant startup and outages, produced steam would be diverted to a rock muffler for venting of the steam, H2S, benzene, and other NCGs to the atmosphere. All NCGs produced by the geothermal production wells which are not retained in the geothermal brine and injected into the geothermal reservoir would be delivered to the cooling tower, either from the condenser (dissolved in the condensate used as the cooling tower makeup water), or from the condenser NCG removal system (which would be pressurized and vented to the cooling tower H2S abatement system). The applicant would abate the produced H2S by using oxidizing process also known as Biox process, which is expected to remove at least 95 percent of the H2S in the condenser off-gas and at least 98 percent in the portion of the condensate used as cooling tower makeup water. The produced benzene would be emitted through the cooling tower unabated, while an estimated of 95 percent of the ammonia in the brine would remain dissolved in the cooling tower water and be injected into the geothermal reservoir. Operations of the cooling tower would require the use of cooling makeup water, which during the cooler months would consist entirely of steam condensate with a low total dissolved solids (TDS) concentration. The TDS concentration is expected to increase during higher temperature summer months, due to the use of canal water from the IID O Lateral as supplemental cooling tower makeup water. The applicant would use high efficiency cooling tower drift eliminators to limit the emission of water droplets ( drift ) which lead to aerosols that form when the emitted cooling tower liquid drift evaporates as particulates. Summaries of emissions of criteria air pollutants, TACs and HAPs, and other gases from operations of the HR-2 geothermal power plant are provided in Tables and The HR-2 operational summary presents emissions during normal operations of the BPF and the TGF at the maximum operating rate (with abatement of H2S emissions in the cooling tower); emissions from testing of emergency and standby diesel engines; and emissions during startup and outages. TABLE HR-2 FACILITY OPERATIONAL CRITERIA AIR POLLUTANT EMISSIONS DAILY OPERATIONAL EMISSIONS (LB/DAY) SOURCE ROG NOX CO SO2 PM10 PM2.5 NORMAL OPERATION (MOBILE SOURCES ATTRACTED TO STATIONARY SOURCE) Mobile sources ICAPCD Operational Threshold (CEQA Handbook) NA Exceeds Threshold? No No No No No NA NORMAL OPERATION (STATIONARY SOURCE) Area sources (1) Energy consumption (2) Off-road equipment Fugitive Dust Cooling Tower Standby/ Black Start Diesel Engine Generator Testing Emergency Standby Diesel Generator Testing Emergency Standby Fire Pump Testing Total ICAPCD Rule 207 Standards (Section C.2) NA Exceeds Threshold? No No No No No NA Hudson Ranch Power II and Simbol Calipatria II Final EIR

118 4.3 Air Quality TABLE HR-2 FACILITY OPERATIONAL CRITERIA AIR POLLUTANT EMISSIONS DAILY OPERATIONAL EMISSIONS (LB/DAY) SOURCE ROG NOX CO SO2 PM10 PM2.5 OUTAGES AND STARTUP (3) Standby/ Black Start Diesel Engine Generators (4) Rock Muffler (5) Total ICAPCD Rule 207 Offset Requirements (Section C.2.a) NA Exceeds Threshold? No Yes Yes (6) No No NA Source: EMA 2012b Key: ROG: Reactive organic gases NOx: Nitrogen oxides CO: Carbon monoxide SO2: Sulfur dioxide PM10: Particulate matter less than 10 microns in aerodynamic diameter. PM2.5: Respirable particulate matter less than 2.5 microns in aerodynamic diameter NA: Not applicable Notes: (1) The CalEEMod model used by the applicant for estimating the HR-2 Project operational emissions defines an area source as ROG emissions from area coating reapplication. (2) The CalEEMod model used by the applicant for estimating the HR-2 Project operational emissions defines energy consumption as the energy associated with General Heavy Industry land use (natural gas). (3) It is anticipated that during outages and startup, emissions from mobile sources would be equivalent to those estimated for normal operations. (4) The emission values presented in Appendix C-2 for the operation of Standby/ Black Start Engines were reported for each engine. Corrected values are for both engines. (5) The applicant estimates that during outages ROG and other NCGs would be emitted from the rock muffler. Benzene is also listed as a ROG. (6) Pursuant Section C.2.g of Rule 207 and provided that the HR-2 Project would be located in an attainment area for Carbon Monoxide, the HR-2 applicant has prepared a Technical Report to demonstrate that Carbon Monoxide emission increases will not cause or contribute to a violation of the AAQS (See Appendix C-5). TABLE HR-2 NON CONDENSABLE AND OTHER GASES OPERATIONAL EMISSIONS OPERATIONAL EMISSIONS (LB/DAY) DESCRIPTION H 2S Benzene NH 3 HCl Cooling Tower NCGs (Abated) HCl Storage Tanks (Abated) Total Outages and Startup Rock Muffler (1) , Source: EMA 2012b Key: H2S: Hydrogen Sulfide NH3: Ammonia HCl: Hydrochloric Acid ROC: Reactive Organic Compounds Notes: (1) During startup, emissions from HCl storage tanks may occur. HCl emissions from tanks would be equivalent to those estimated for normal operations. Hudson Ranch Power II and Simbol Calipatria II Final EIR

119 4.3 Air Quality There is also the potential for the release of criteria air pollutants, TAC and HAPs, and other gases emissions into the atmosphere as a result of the HR-2 plant start-up and outages (e.g., during a plant trip or load rejection). During these special operational circumstances, produced steam would be diverted to a rock muffler for venting of the steam, causing the release of unabated H2S, ROG, benzene, ammonia and other NCG into the atmosphere. If the plant outage is expected to be short, approximately one to two hours or less, the geothermal wells would be kept flowing at approximately full flow so that the plant could be quickly restored to full operation. If the plant outage is expected to last more than 24 to 48 hours, the wells would be immediately reduced to their minimum stable flow rate. If the plant outage is expected to last more than 48 hours, the wells would be shut-in as quickly as safe. The applicant has conservatively assumed that no more than four plant outages would occur during a year, each requiring continuing well flows at half rate for up to 24 hours. Table provides a summary of the daily rock muffler NCG potential emissions. Two 2,500-kW standby/ black start diesel engine-generators would be installed to provide electrical energy to re-start power plant operations following plant trips or shutdowns. During a plant start-up, operation of both proposed standby/ black start diesel engine generators would be necessary to provide electrical energy to the BFP and TGF until the steam turbine-generator is capable of providing the power plant s required electrical energy. The applicant has conservatively assumed that no more than two cold (i.e., when the geothermal wells have been completely shut-in) and two warm starts would occur each year, requiring the operation of both diesel engine generators for 36 and 12 hours, respectively. Emissions from these operations of the standby/ black start diesel engine generators are included in Table SmCP-2 Construction Emissions The SmCP-2 Project construction would take approximately 21 months, from March 2015 until December Construction activities would initiate with site preparation and grading of the 32.4-acre site, following with the foundation construction, building erection, architectural coating, onsite paving 5, and power line construction. During March to May 2015, SmCP-2 construction activities would overlap with the proposed HR-2 building erection, coating, and onsite paving. Project paving of 200,000 square feet of McDonald Road to County standards would follow construction of the SmCP-2 plant 6. No demolition is expected to be necessary for the SmCP-2. Emissions from the proposed SmCP-2 construction activities would include combustion emissions from onsite heavy-duty diesel and gasoline powered equipment and offsite vehicle use, ROG from coating and paving, and fugitive dust from earthmoving and offsite traffic in paved and unpaved roads. The proposed SmCP-2 plant operations would occur simultaneously with the proposed HR-2 geothermal power plant operations. 5 Concrete and/or asphaltic paving would occur on the SmCP-2 onsite roads. 6 Paving of McDonald Road in full would be an activity covered by the Simbol Calipatria Plant I (SmCP-1) Project. However, in the event the SmCP-1 would not be approved; it has been assumed that the HR-2 project include paving emissions as part of the air quality analysis. Hudson Ranch Power II and Simbol Calipatria II Final EIR

120 4.3 Air Quality Table summarizes the estimated daily emissions per year of construction, based on the anticipated construction schedule, phasing of the proposed activities, and implementation of proposed EPMs. It is anticipated that certain construction activities, such as building erection and coating, would overlap for at least one month with the proposed power line construction and onsite paving. Additionally, emissions from the SmCP-2 construction activities during the year 2015 would overlap with the proposed HR-2 building erection, coating, onsite paving and geothermal power plant operations. Construction emissions for the SmCP-2 project have been estimated by the applicant based on the methods indicated in Appendix C. TABLE SUMMARY OF SMCP- 2 DAILY CONSTRUCTION AIR POLLUTANT EMISSIONS PERIOD 2015 (March) 2015 (Apr-May) 2015 (Jun-Dec) 2016 MAXIMUM DAILY EMISSIONS (LB/DAY) EMISSIONS/THRESHOLD ROG NOx CO SO 2 PM 10 PM 2.5 SmCP-2 Construction < 0.1 < < HR-2 Construction Combined ICAPCD Threshold NA 150 NA Exceeds Threshold? No No No NA No NA SmCP-2 Construction HR-2 Construction Combined ICAPCD Threshold NA 150 NA Exceeds Threshold? No Yes No NA No NA SmCP-2 Construction ICAPCD Threshold NA 150 NA Exceeds Threshold? No No No NA No NA SmCP-2 Construction ICAPCD Threshold NA 150 NA Exceeds Threshold? No No No NA No NA Source: EMA 2012a, EMA 2012c Key: ROG: Reactive organic gases NOx: Nitrogen oxides CO: Carbon monoxide SO2: Sulfur dioxide PM10: Particulate matter less than 10 microns in aerodynamic diameter. PM2.5: Respirable particulate matter less than 2.5 microns in aerodynamic diameter NA: Not applicable SmCP-2 Operational Emissions Operations of the proposed SmCP-2 mineral extraction plant would involve stationary and mobile emission sources associated with the proposed silica management, lithium extraction and purification, lithium carbonate production, zinc and manganese extraction and production, miscellaneous processes, and worker and vendor vehicle use. Operations of the SmCP-2 plant would occur simultaneously with operations of the HR-2 Project and involve daily worker and vendor vehicle trips; haul truck trips; water Hudson Ranch Power II and Simbol Calipatria II Final EIR

121 4.3 Air Quality consumption for cooling towers, process water and potable water; chemical processing and packaging; and emergency standby diesel generator and fire pump engines. Operational emissions associated with the SmCP-2 facility would include: Particulates emissions from drying, transfer, and packaging lithium and zinc products; loading and unloading of calcium oxide, flocculants, salt, and soda ash reagent storage and discharge systems; operations of the cooling tower; and worker/vehicle use on roads. HCl vapor emissions produced by the HCl synthesis process from the hydrogen and chlorine gases produced by the process of converting lithium chloride to lithium hydroxide; Emissions of benzene, H2S, and ammonia from the CO2 stream delivered from the HR-2 plant to the SmCP-2 facility; H2S emitted from the gas space in the sodium hydrosulfide (NaHS) tank during the filling of the NaHS; and Combustion emissions, including DPM, from maintenance, testing and emergency operations of the emergency diesel engine-generator and emergency diesel fire pump engine, and worker/vendor vehicle use. Summaries of emissions of criteria air pollutants, TAC or HAPs, and other gases from operations of the SmCP-2 mineral extraction plant are provided in Tables and Since the SmCP-2 Project would occur only if the HR-2 Project is approved, these tables provide the combined emissions from operations. The SmCP-2 operational emissions summary assumes normal operations of the silica, lithium, zinc and manganese units at the maximum operating rate; daily reagent deliveries equal or exceed the daily consumption of each reagent; and testing of emergency engines, all on the same day, for no more than one hour each. The applicant would implement operational EPMs, such as the use of emergency engines that meet BACT requirements for NOx emissions, and the use of low sulfur fuel in stationary combustion sources. TABLE SMCP-2 CRITERIA AIR POLLUTANT OPERATIONAL EMISSIONS OPERATIONAL EMISSIONS (LB/DAY) SOURCE ROG NOx CO SO 2 PM 10 PM 2.5 NORMAL OPERATIONS (MOBILE SOURCES ATTRACTED TO THE STATIONARY SOURCE) Mobile sources ICAPCD Operational Threshold (CEQA Handbook) NA Exceeds Threshold? No No No No No NA NORMAL OPERATIONS (STATIONARY SOURCE) Off-road equipment Product Drying, Transfer, and Packaging Reagent Storage Systems Loading and Unloading Cooling Tower Hudson Ranch Power II and Simbol Calipatria II Final EIR

122 4.3 Air Quality TABLE SMCP-2 CRITERIA AIR POLLUTANT OPERATIONAL EMISSIONS OPERATIONAL EMISSIONS (LB/DAY) SOURCE ROG NOx CO SO 2 PM 10 PM 2.5 Emergency Standby Diesel Engine-Generator # Emergency Standby Fire Pump Diesel Engine Total HR-2 Normal Operations Total Combined SmCP-2 / HR-2 Operations Total ICAPCD Rule 207 Standards (Section C.2) NA Exceeds Threshold? No No No No No NA Source: EMA 2012d Key: ROG: Reactive organic gases CO: Carbon monoxide NOx: Nitrogen oxides SO2: Sulfur dioxide PM10: Particulate matter less than 10 microns in aerodynamic diameter. PM2.5: Respirable particulate matter less than 2.5 microns in aerodynamic diameter NA: Not Applicable TABLE SMCP-2 HAZARDOUS AIR POLLUTANT AND OTHER GASES OPERATIONAL EMISSIONS OPERATIONAL EMISSIONS (TONS PER YEAR) SmCP-2 Operations SOURCE DPM Benzene HCl H 2S NH 3 HCl Synthesis with Scrubber HCl Storage Tank with Scrubber Noncondensable Gas Emissions Emergency Diesel Engine-Generator Emergency Standby Fire Pump Total HR-2 Normal Operations Total SmCP-2 / HR-2 Combined Operations Total Source: EMA 2012d Key: DPM: Diesel Particulate Matter HCl: Hydrochloric Acid Health Risk Assessment H2S: Hydrogen Sulfide NH3: Ammonia A health risk assessment (HRA) was conducted to determine potential effects related to the emission of TACs from the operations of the proposed HR-2 and SmCP-2 facilities. The HRA accounts for the inhalation health risks associated with fugitive emissions from stationary combustion equipment and chemical storage, transfer, and processing facilities. The risk assessment process involved: hazard identification, exposure assessment, dose-response assessment, and risk characterization. Hudson Ranch Power II and Simbol Calipatria II Final EIR

123 4.3 Air Quality The HRA evaluated the health risks at existing sensitive receptors sites (e.g., residences, schools, hospitals, daycare, and eldercare facilities) and other receptor sites (i.e., commercial and industrial sites) in proximity to the HR-2 and SmCP-2 plants were identified. Impacts were evaluated at residences and commercial/industrial sites within a two-mile radius from the facilities. In addition risks were evaluated at the four closest residences in the Community of Niland and three residences located along State Highway 111. No schools, hospitals, daycare, and eldercare sensitive receptors were identified within the two-mile radius. However, three schools in the Community of Niland (outside the two-mile radius) were included in the assessment. The receptor locations considered in the analysis three schools, ten residences, and six commercial/industrial sites. An estimation of how different level of exposure to a chemical can impact the likelihood and severity of health effects was performed in the HRA to evaluate potential cancer and non-cancer 7 effects. Acute (short-term) exposure levels were based on the maximum predicted downwind concentrations of TACs/HAPs emitted by each facility. For this assessment, cancer risk was expressed as the maximum number of new cases of cancer projected to occur in a population of one million people due to exposure to a TAC over a 70-year lifetime. Non-cancer risk was determined by comparing the average modeled level of exposure to a chemical to the level of exposure that is not expected to cause any adverse effects over a certain period of time. Non-cancer risk is often represented by the acute (short-term) and chronic (long term) hazard quotient 8 and hazard index 9 (Cal/EPA 2003). The highest acute and chronic non-cancer risks, and the cancer risk estimates from HRA results were summarized. Impacts associated with the HR-2 Project only are presented in Tables to Impacts associated with the combined SmCP-2 and HR-2 operations are presented in Tables to The detailed HRA is included as Appendix M. TABLE HIGHEST ACUTE NON-CANCER RISK BY THE HR-2 PROJECT (NORMAL OPERATIONS) AFFECTED ORGAN ACUTE HAZARD QUOTIENT (1) ACUTE HAZARD OEHHA SIGNIFICANT RECEPTOR SYSTEM H 2S BENZENE HCL INDEX THRESHOLD EFFECT? Niland Head Start Nervous No Storage Yard Workers Nervous No Algae Farm Caretaker Residence Nervous No 7 Non-cancer effects, such as asthma, nervous system disorders, birth defects, and developmental problems in children, typically become more severe as exposure to a chemical increases. 8 Hazard Quotient (HQ) is defined by Cal/EPA as the estimated ground level concentration divided by the reference exposure level for a single substance and a particular end point. The Acute HQ is obtained dividing the one hour maximum concentration of a substance by the acute Reference Exposure Level for the substance. The Chronic HQ is calculated dividing the annual concentration by the chronic Reference Exposure Level for the substance. 9 Hazard Index (HI) is defined as the sum of individual acute or chronic hazard quotients for each substance affecting a particular toxicological point. Hudson Ranch Power II and Simbol Calipatria II Final EIR

124 4.3 Air Quality TABLE HIGHEST ACUTE NON-CANCER RISK BY THE HR-2 PROJECT (NORMAL OPERATIONS) AFFECTED ORGAN ACUTE HAZARD QUOTIENT (1) ACUTE HAZARD OEHHA SIGNIFICANT RECEPTOR SYSTEM H 2S BENZENE HCL INDEX THRESHOLD EFFECT? SW Duck Ponds Nervous No Workers Source: EMA 2012e Notes: (1) Acute exposure period for Benzene is 6 hours. For H2S and HCl the acute exposure period is 1-hour. TABLE HIGHEST ACUTE NON-CANCER RISK BY THE HR-2 PROJECT (STARTUP AND OUTAGES) AFFECTED ACUTE HAZARD QUOTIENT ACUTE RECEPTOR ORGAN SYSTEM H 2S BENZENE HCL HAZARD INDEX OEHHA THRESHOLD SIGNIFICANT EFFECT? Niland Head Start Nervous < No Storage Yard Workers Nervous < No Algae Farm Caretaker Nervous < No Residence (1) SW Duck Ponds Nervous < No Workers Source: EMA 2012e Notes: (1) Acute exposure period for Benzene is 6 hours. For H2S and HCl the acute exposure period is 1-hour. TABLE HIGHEST CHRONIC NON-CANCER RISK BY THE HR-2 PROJECT (NORMAL OPERATIONS) CHRONIC HAZARD QUOTIENT CHRONIC DIESEL HAZARD OEHHA SIGNIFICAN RECEPTOR H 2S BENZENE HCL PM INDEX THRESHOLD T EFFECT? Publica High School < No Algae Farm Caretaker No Residence SW Duck Ponds < No Workers (1) Source: EMA 2012e TABLE CANCER RISK FOR THE HR-2 PROJECT (NORMAL OPERATIONS) CANCER RISK TOTAL RECEPTOR BENZENE DIESEL PM CANCER RISK OEHHA THRESHOLD SIGNIFICANT EFFECT? Publica High School 2.52 x x10-8 1x10-6 No Algae Farm Caretaker 2.49 x x x10-7 1x10-6 No Residence SW Duck Ponds Workers ( 1.28 x x x10-8 1x10-6 No Source: EMA 2012e Hudson Ranch Power II and Simbol Calipatria II Final EIR

125 4.3 Air Quality TABLE HIGHEST ACUTE NON-CANCER RISK BY THE COMBINED SMCP-2 AND HR-2 OPERATIONS (HR-2 OUTAGES) AFFECTED ORGAN ACUTE HAZARD QUOTIENT (1) ACUTE HAZARD OEHHA SIGNIFICANT RECEPTOR SYSTEM H 2S BENZENE HCL INDEX THRESHOLD EFFECT? Niland Head Start Nervous 0.15 <0.001 < No S Storage Yard Nervous 0.52 <0.001 < No Algae Farm Caretaker Nervous 0.57 <0.001 < No Residence SW Duck Ponds Nervous 0.28 <0.001 < No Workers Source: EMA 2012e Notes: (1) Acute exposure period for Benzene is 6 hours. For H2S and HCl the acute exposure period is 1-hour. TABLE HIGHEST CHRONIC NON-CANCER RISK BY THE COMBINED SMCP-2 AND HR-2 OPERATIONS (NORMAL CONDITIONS) AFFECTED CHRONIC HAZARD QUOTIENT CHRONIC ORGAN DIESEL HAZARD OEHHA SIGNIFICANT RECEPTOR SYSTEM H 2S BENZENE HCL PM INDEX THRESHOLD EFFECT? Publica High Respiratory < No School Algae Farm Respiratory < No Caretaker Residence (1) SW Duck Ponds Workers Respiratory < No Source: EMA 2012e Notes: (1) As of the date of publication of this DEIR, the algae farm identified in the HRA is no longer in operation. TABLE CANCER RISK FOR THE COMBINED SMCP-2 AND HR-2 OPERATIONS (NORMAL CONDITIONS) CANCER RISK TOTAL DIESEL CANCER OEHHA SIGNIFICANT RECEPTOR BENZENE PM RISK THRESHOLD EFFECT? Publica High School 2.92 x x x10-8 1x10-6 No Algae Farm Caretaker Residence (1) 5.10x x x10-7 1x10-6 No SW Duck Ponds Workers 2.59 x x x10-8 1x10-6 No Source: EMA 2012e Notes: (1) As of the date of publication of this DEIR, the algae farm identified in the HRA is no longer in operation. Hudson Ranch Power II and Simbol Calipatria II Final EIR

126 4.3 Air Quality HR-2 PROJECT IMPACTS AND MITIGATION MEASURES Impact AQ-1: The HR-2 Project would not conflict with or obstruct implementation of the applicable air quality plan. As shown in Table 4.3-5, the HR-2 Project would be consistent with the Imperial County General Plan Air Quality Goals and Objectives. Additionally, the ICAPCD Hour Ozone Modified Air Quality Management Plan (AQMP) and the 2009 Imperial County State Implementation Plan (SIP) for Particulate Matter less than 10 Microns in Aerodynamic Diameter outline long-term strategies designed to bring regional air quality into compliance with NAAQS and CAAQS. The parameters of the Ozone AQMP and the PM10 SIP are established according to forecasted air pollution emissions within Imperial County, based on existing land uses and growth projections. Both ICAPCD plans account for the operation of industrial facilities, including geothermal power generation plants. The emissions associated with construction and operations of the HR-2 Project would represent less than 1 percent of the regional emissions inventory included in both applicable ICAPCD air quality plans 10. Construction of the HR-2 facilities would cover an overall period of 28 months with a temporary increase of NOx, ROG, and PM10 emissions; however, it is not expected that these temporary emissions would contribute a significant burden on the regional ozone or PM10 emissions inventories. Although contributing to regional emissions, projected operational emissions from the HR-2 plant would also account for less than 1 percent of the total emissions inventory included in the Ozone AQMP and the PM10 SIP. Therefore, the proposed HR-2 Project would not conflict with or obstruct implementation of the applicable air quality plan, resulting in a less than significant impact under this criterion. Mitigation Measures: Impact AQ-2: None required. Estimated construction emissions from the proposed HR-2 Project would not violate an air quality standard and/or contribute substantially to an existing or projected air quality violation. However, the combined NOx emissions from the HR-2 and SmCP-2 Projects would exceed the ICAPCD NOx construction 10 A comparison of the HR-2 Ozone precursors (NOx and ROG) emissions with the Imperial County Summer Planning Inventing Inventory reported in the Hour Ozone AQMP results in a maximum of 0.3 percent during construction and 0.04 percent during operations. Moreover, the HR-2 PM10 emissions would account for a 0.25 percent of the projected Imperial County PM2.5 emissions inventory with the implementation of Regulation VIII. Hudson Ranch Power II and Simbol Calipatria II Final EIR

127 4.3 Air Quality significance threshold during April and May 2015, when construction for both projects is anticipated to overlap. Estimated HR-2 Project operational emissions would not exceed the operational significance thresholds for mobile sources or for stationary sources. However, start-up conditions would result in an exceedance of ICAPCD offset requirements for NOx and CO daily emissions. Estimated HR-2 Project construction emissions would not exceed the construction significance thresholds. To control potential increases in emissions of ozone precursors during construction, the HR-2 applicant would implement an Exhaust Emissions Control Program (EPM AQ-3), a Well Drilling Compliance Control Program (EPM AQ-2), and the use of diesel engines with certified NOx Emissions rated as Tier 3 or better during grading (EPM AQ-11). Additionally, construction particulate matter emissions would be controlled through the implementation of a Fugitive Dust Suppression Plan (EPM AQ-1) and Air Quality Protection Measures (EPM AQ-9), in compliance with the requirements of ICAPCD Regulation VIII. The applicant would also implement a well flow testing program (EPM AQ-4) and apply a dust palliative coating to cover the unpaved portion of McDonald Road that provides access to the Project site (EPM AQ-10). Construction impacts to ambient air quality would be less than significant. However, for approximately two months during the first year of construction of the SmCP-2 Project (2015) some of the proposed SmCP-2 Project construction activities would overlap with the late stages of construction of the HR-2 Project. As shown in Table , combined NOx emissions from the two Projects would exceed the ICAPCD NOx construction significance threshold during April and May 2015, based on the current SmCP-2 and HR-2 construction schedules. Therefore, impacts to ambient air quality during this overlapping construction period would be potentially significant unless mitigation is incorporated. During normal operation, estimated HR-2 Project operational emissions would not exceed the operational significance thresholds for mobile sources or the Rule 207 C.2 offset significance thresholds for stationary sources. To limit air pollutant emissions from the HR-2 Project, each of the stationary diesel engines would meet the applicable California Air Resources Board (CARB) stationary compression ignition engine exhaust emission standards and the applicable CARB Airborne Toxic Control Measure (ATCM) for Stationary Compression Ignition Engines DPM standards. Particulate emissions from the cooling towers would be minimized by maintaining a low total dissolved solids (TDS) concentration in the circulating water and by controlling cooling tower drift losses to not more than percent of the total circulation rate using high efficiency drift eliminators. Hydrogen sulfide emissions from the cooling tower would also be minimized by using the Biox Hudson Ranch Power II and Simbol Calipatria II Final EIR

128 4.3 Air Quality hydrogen sulfide abatement program (EPM AQ-5). Each of these actions would be evaluated by the ICAPCD in order to determine compliance with the District s BACT requirements. Compliance with BACT requirements during normal operations would ensure that operation of the proposed HR-2 Project sources does not interfere with the attainment of ambient air quality standards. Thus, impacts on ambient air quality from normal operations would be less than significant. During start-up conditions associated with HR-2 Project operations, NOx and CO daily emissions would exceed the Rule 207 C.2 offset requirement limits of 137 pounds per day. The primary sources of this temporary increase of emissions would be the proposed two stand-by/ black start diesel engine generators. Rule 207 Section C.2 requires emissions offsets for sources with non-attainment pollutant emissions that exceed 137 pounds per day. Pursuant Rule 207, Section C.2.g, Hudson Ranch II Power LLC has prepared a Carbon Monoxide Air Quality Impact Analysis (EMA 2012f), which demonstrates that the proposed HR-2 facility would not cause or contribute to a violation of the carbon monoxide AAQS (Appendix C-5). Therefore, offsets would be required for the NOx emissions in excess of 137 pounds per day but, pursuant to Rule 207 C.2.g, Rule 207 C.2 offsets for the carbon monoxide emissions would not be required. Therefore, impacts to ambient air quality during start-up operations would be potentially significant unless mitigation is incorporated. As indicated earlier, the ICAPCD recommends the CEQA Handbook operational thresholds not be used to determine significance for the air emissions associated with the stationary source, including off-road mobile emissions produced within the stationary source; since those sources are already subject to mitigation according to ICAPCD Rules 207 and 201. Rule 201 describes the permit requirements applicable to the construction and operation of any article, machine, Equipment, or other contrivance that emits or controls air contaminants. Thus, during air permit review, ICAPCD will determine the appropriate offset requirements applicable to the Project s stationary source NOx emissions. Mitigation Measure AQ-2.1 requires the purchase of NOx emissions, in compliance with Rule 207 C.2. MM AQ-2.1: NOx Controls During HR-2/SmCP-2 Concurrent Construction During the period of concurrent construction with the SmCP-2 Project, the HR-2 Project will undertake one or more of the following to reduce the estimated NOx emissions from the two Projects to less than 100 pounds per day: The Permittee shall comply with all applicable standard mitigation measures for construction combustion equipment for the reduction of excess NOx emissions as Hudson Ranch Power II and Simbol Calipatria II Final EIR

129 4.3 Air Quality identified in the air quality analysis and as contained in the Imperial County CEQA Air Quality Handbook and associated regulations: 1. Utilize all Tier 3 or Tier 4 construction equipment. 2. Prohibit idling of equipment not in use; for equipment in use reduce idling time to a maximum of 5 minutes. 3. Where feasible replace fossil fuel burning equipment with electrically driven equivalents provided they are not powered via a portable generator. 4. Register all portable engines 50 horse power or greater with the ICAPCD. Permittee shall also apply enhanced measures to assure reduced levels of NOx are maintained during the construction phase of the project. 1. Submit to the Air District prior to any earthmoving activity a complete list of all construction equipment to be utilized during the construction phase identifying Make, Model, Year, and estimated hours of usage. 2. In the event NOx emissions are calculated to exceed ICAPCD thresholds for construction, the Permittee shall provide for off-site mitigation or comply with Policy Number 5. Policy Number 5 allows a project to pay in-lieu impact fees utilizing the most current Carl Moyer Cost Effective methodology to reduce excess NOx emissions. Minimize concurrent construction activities with the SmCP-2 Project construction activities; Incorporate the following mitigation measures from the Imperial County Air Pollution Control District into the proposed Project s Exhaust Emission Control Program for reducing NOx emissions from construction combustion equipment. a. Use of alternative fueled or catalyst-equipped diesel construction equipment, including all off-road and portable diesel-powered equipment. b. Minimize idling time either by shutting equipment off when not in use or reducing the time of idling to 5 minutes as a maximum. c. Limit, to the extent feasible, the hours of operation of heavy duty equipment and/or the amount of equipment in use. Hudson Ranch Power II and Simbol Calipatria II Final EIR

130 4.3 Air Quality d. Replace fossil fueled equipment with electrically driven equivalents (provided they are not run via portable generator set); Pursuant to ICAPCD Policy Number 5, the applicant may pay an in-lieu impact fee as determined by ICAPCD using the formula provided in ICAPCD Policy No. 5 to reduce NOx emissions. Detailed emissions calculations shall be provided to ICAPCD as necessary to support calculation of the fee. Require construction contractors to use Tier 4 construction equipment during site preparation and grading activities. Prior to site preparation activities, the HR-2 Project will submit to the Imperial County Planning and Development Services evidence of the actions proposed to be undertaken to limit NOx emissions from the two Projects during construction to ensure that maximum daily NOx emissions resulting from the proposed combined construction activities will remain below 100 pounds per day. Timing/Implementation: March Enforcement/Monitoring: Imperial County Planning and Development Services/ ICAPCD. Significance after Mitigation: MM AQ-2.2: Implementation of MM AQ-2.1 and adherence to ICAPCD regulations and proposed EPMs during the overlapping construction of the HR-2 Project and the SmCP-2 Project would result in levels of NOx emissions below the ICAPCD thresholds of significance for construction. Therefore, implementation of MM AQ 2.1 would reduce impacts to below the level of significance. Emissions Offsets To address potentially significant operational emissions at the HR-2 site during startup, Hudson Ranch Power II, LLC shall purchase NOx offsets for the daily NOx exceedances over the ICAPCD Rule 207 C.2.a threshold for stationary sources. The applicant shall purchase NOx offset credits for the amount required by the ICAPCD as part of the Authority to Construct conditions, and provide documentation of the purchased offsets to the ICAPCD prior to the issuance of the Permit to Operate. Timing/Implementation: Prior the issuance of the Permit to Operate. Enforcement/Monitoring: Imperial County Planning and Development Services/ ICAPCD. Hudson Ranch Power II and Simbol Calipatria II Final EIR

131 4.3 Air Quality Significance after Mitigation: Impact AQ-3: Compliance with the requirement of Rule 207 ensures that the operation of the proposed HR-2 stationary sources does not interfere with the attainment of Ambient Air Quality Standards. Through the purchase of offsets, NOx and other air pollutant emissions from the HR-2 Project are not expected to violate an air quality standard and/or contribute substantially to an existing or projected air quality violation. Therefore, this impact would be less than significant after mitigation. The HR-2 Project could result in a cumulatively considerable net increase of a criteria air pollutant for which the Project region is non-attainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone). During the first year of construction of the SmCP-2 Project (2015), the proposed site preparation and grading activities would overlap with the late stage of construction of the HR-2 Project. As shown in Table , NOx emissions would exceed the ICAPCD thresholds during April and May This would be a potentially significant impact without mitigation. After completion of the HR-2 construction period, emissions from the development of the SmCP-2 Project would not exceed the ICAPCD thresholds of significance for construction. In order to reduce the potential to exceed the NOx significance thresholds during construction, MM AQ-2.1 requires the implementation of some combination of controls during the period of concurrent construction, such as minimizing overlapping activities, NOx controls, or the use of Tier 4 construction equipment to ensure that calculated NOx emissions are below the ICAPCD construction significance level of 100 pounds per day. With implementation of MM AQ-2.1, adherence to ICAPCD regulations and EPMs, impacts from the combined SmCP-2/HR-2 construction period would be less than significant after mitigation. During the operational phase, the combined emissions from the normal operation of the SmCP-2 and HR-2 plants would not exceed the ICAPCD Rule 207 C.2 standards. Therefore, impacts during operations would be less than significant. The proposed HR-2 Project would be located in a non-attainment area for ozone and PM10 under federal and state standards. Estimated HR-2 Project construction emissions for ozone precursors and PM10 would not exceed the construction significance thresholds. During normal operation, estimated HR-2 Project operational emissions would not exceed the operational significance thresholds for mobile sources or the Rule 207 C.2 offset significance thresholds for stationary sources. Pursuant Rule 207 Hudson Ranch Power II and Simbol Calipatria II Final EIR

132 4.3 Air Quality Section C.1, the HR-2 Project would apply BACT to ensure that air pollutant emissions from operation of the diesel engines and cooling tower sources would not interfere with the attainment of ozone and PM10 standards. Further, during plant startup conditions, NOx emissions in excess of the limits established in Rule 207 C.1 for offsets (137 pounds per day) would need to be offset through the purchase of credits in the amount determined by ICAPCD. This impact would be potentially significant unless mitigation is incorporated. Implementation of MM AQ -2.1 ensures that the applicable provisions of Rule 207 are implemented prior initiating operations of the HR-2 Project under the Permit to Operate. Therefore, this impact is less than significant after mitigation. More details concerning the potential cumulative impacts on air quality as a result of the implementation of the HR-2 Project are provided in Chapter 5, Cumulative analysis. Impact AQ-4: The HR-2 Project would not expose sensitive receptors to substantial pollutant concentrations. Sensitive receptors include residences, schools, hospitals, and other sensitive uses. Land use conflicts can arise when these receptors are located next to major sources of air pollutants. The HR-2 Project area is a rural, agricultural area. The nearest residential receptor is located approximately 0.3 miles south-east of the Project site boundary on W Shrimp Road and is an algae farm caretaker residence that could be occupied during the proposed construction and operation 11. The next closest residence is located 0.5 miles north-east of the Project site (along English Road), which is owned by Energy Source (Hudson Ranch Power II, LLC s parent company). This residence would be vacated in fall 2012 and demolished prior to start of construction of the HR-2 Project. The next closest residence is located 1.4 miles north-west of the HR-2 Project site. The nearest population center is the Town of Niland, located 2.3 miles from the proposed Project site and at least 3.0 miles from the center of the plant site. Other sensitive receptors located within 2.5 miles from the proposed HR-2 Project site include educational centers such as the Grace Smith Elementary School, the Publica High School, Niland Head Start, and ten residences. Other non-sensitive (commercial/industrial) receptors include six industrial or commercial areas, and 11 The risk assessment prepared for the HR-2 Project (Appendix M) included additional an algae farm caretaker residence as part of the sensitive receptors identified for analysis. As of the date of publication of this DEIR, the algae farm was being sold and not in operation; however, the new property owner will be processing permits to allow this facility to re-open. For this reason, the caretaker residence is considered a sensitive receptor. Hudson Ranch Power II and Simbol Calipatria II Final EIR

133 4.3 Air Quality three other areas (defined as locations with the potential to attract the public for the short, but not the long, term). Operations of the proposed HR-2 facilities would involve the potential release of NCGs containing H2S, benzene, ammonia, and traces of other gases (methane, nitrogen, hydrogen, and argon), in addition to combustion emissions from the maintenance, testing and emergency operations of diesel-powered engines and fire pumps. As shown in Tables to , HRA results indicate that the cancer risks for the HR-2 operations would not exceed the OEHHA recommended threshold of one in one million. The maximum acute (short-term) and chronic (long term) hazard indices were both well below the recommended significance levels. Thus, operation of the HR-2 Project would not expose sensitive receptors to a significant health risk; therefore, this impact is less than significant. Mitigation Measures: Impact AQ-5: None required. The HR-2 Project would not create objectionable odors affecting a substantial number of people. Existing population in the proposed HR-2 Project area is sparse, and does not represent a substantial number of people in the closest vicinity of the proposed facilities. The nearest residence is located south-west of the Project site boundary on W Shrimp Road and is an algae farm caretaker residence. Another residence, located 0.5 miles north-east of the Project site (along English Road) is owned by Energy Source (Hudson Ranch Power II, LLC s parent company) and the residence would be vacated in fall 2012 and demolished prior to start of construction of the HR-2 Project. The next closest residence is located 1.4 miles northwest of the HR-2 Project site. The closest population center is the Town of Niland, located 2.3 miles from the proposed Project site. The HR-2 construction activities would include the use of diesel-fueled construction equipment, which emits a distinctive odor that may be offensive to some individuals. Odors generated by diesel exhaust would be reduced by the use of either low sulfur or ultra-low sulfur fuel, as required in California. Paving and surface coating activities during project construction would also generate odors associated with organic compounds in these materials. Additionally, construction of the HR-2 Project would also involve the release of H2S during well drilling and testing operations, which has a distinctive odor. H2S emissions during drilling and flow testing would be temporary at each well location and conducted under a permit from the ICAPCD. Hudson Ranch Power II and Simbol Calipatria II Final EIR

134 4.3 Air Quality Operations of the HR-2 plant would involve the release of NCGs containing H2S and ammonia, in addition to combustion emissions from the maintenance, testing and emergency operations of diesel-powered engines (generator and standby fire pump). All these sources would generate distinctive odors that may be offensive to some individuals. The HR-2 Project applicant would use ultra-low sulfur fuel at all stationary combustion equipment, in addition to emission capture and control for H2S. Odor from H2S emissions has been identified as major issue of public concern. The HR-2 Project applicant would be required to comply with the requirements of ICAPCD Rule 207, Section C.1.c regarding implementation of BACT during geothermal power plant operations. Additionally, H2S monitoring would be required by the ICAPCD as part of the Conditions of Approval of the HR-2 Project Permit to Operate (Soucier 2012). Projected 1-hour H2S concentrations at the closest residence during HR-2 Project normal operations reported as part of the HRA resulted in a maximum value of 1.42 μg/m 3, far below the existing statewide CAAQS for H2S of 0.03 ppm (42 μg/m 3 ). Concentrations at the other residences modeled were all less than 0.4 μg/m 3. The maximum modeled 1-hour concentration of 24.1 μg/m 3, at the nearby algae farm caretaker residence, would occur only during the occasional plant outages, and would also be below the CAAQS for H2S (42 μg/m 3 ). The H2S CAAQS protects against nuisance odor for the general public and the standard was adopted based on odor threshold of perception measured (CARB 2000) 12. The HRA used an EPA-approved air dispersion model to determine ground level concentrations of H2S using local meteorological data (Appendix M). The HRA shows that the projected H2S concentrations would be below the nuisance odor threshold for even the closest receptors (algae farm caretaker residence) based on prevailing wind patterns. Neither the ammonia nor DPM emissions are expected to create objectionable odors affecting a substantial number of people because the emissions are relatively small and the very low population density in the immediate vicinity of the Project In the event H2S, ammonia or DPM odors were perceived as offensive by the public, complaints would be filed through the existing ICAPCD complaint procedure for investigation by the ICAPCD. 12 The H2S CAAQS was adopted based on rounding the geometric mean odor threshold of ppm measured in adults (CARB 2000). Hudson Ranch Power II and Simbol Calipatria II Final EIR

135 4.3 Air Quality Since the HR-2 Project would be located in a low population density area, and Project primary odor sources (i.e., H2S) would be controlled to result in concentrations below the odor perception threshold at closest sensitive receptors; the Project would result in a less than significant impact under this criterion. Mitigation Measures: None required. SMCP-2 PROJECT IMPACTS AND MITIGATION MEASURES Impact AQ-1: The SmCP-2 Project would not conflict with or obstruct implementation of the applicable air quality plan. As shown in Table 4.3-5, the SmCP-2 Project would be consistent with the Imperial County General Plan Air Quality Goals and Objectives. Additionally, the ICAPCD Hour Ozone Modified Air Quality Management Plan (AQMP) and the 2009 Imperial County State Implementation Plan (SIP) for Particulate Matter less than 10 Microns in Aerodynamic Diameter outline long-term strategies designed to bring regional air quality into compliance with NAAQS and CAAQS. The parameters of the Ozone AQMP and the PM10 SIP are established according to forecasted air pollution emissions within Imperial County, based on existing land uses and growth projections. The emissions associated with the construction and operations of the SmCP-2 Project would represent less than 1 percent of the regional emissions inventory included in both applicable ICAPCD air quality plans 13. Construction of the SmCP-2 facilities would cover an overall period of 21 months with temporary increases of NOx, ROG, and PM10 emissions during construction (which would overlap with the last three months of construction of the HR-2 Project); however, it is not expected that these temporary emissions would contribute a significant burden on the regional ozone or PM10 emissions inventories. Although contributing to regional emissions, projected operational emissions from the SmCP-2 plant in combined operations with the HR-2 geothermal facility would be less than 1 percent of the total emissions inventory included in the Ozone AQMP and the PM10 SIP. Therefore, construction and operation of the proposed 13 A comparison of the SmCP-2 Ozone precursors (NOx and ROG) emissions with the Imperial County Summer Planning Inventing Inventory reported in the Hour Ozone AQMP results in a maximum of 0.03 percent during construction and 0.01 percent during operations. Moreover, the SmCP-2 PM10 emissions would account for a 0.18 percent of the projected Imperial County PM2.5 emissions inventory with the implementation of Regulation VIII. Hudson Ranch Power II and Simbol Calipatria II Final EIR

136 4.3 Air Quality SmCP-2 Project would not conflict with or obstruct implementation of the applicable air quality plans, resulting in a less than significant impact under this criterion. Mitigation Measures: Impact AQ-2: None required. Estimated construction emissions from the proposed SmCP-2 Project would not violate an air quality standard and/or contribute substantially to an existing or projected air quality violation. However, the combined NOx emissions from the HR-2 and SmCP-2 Projects would exceed the ICAPCD NOx construction significance threshold during April and May 2015, when construction for both projects is anticipated to overlap. Estimated HR-2 Project operational emissions, as well as combined emissions from the normal operations of the both Projects, would not exceed the operational significance thresholds for mobile sources or for stationary sources. Estimated SmCP-2 Project construction emissions would not exceed the ICAPCD construction significance thresholds. To control potential increases in emissions of PM10 and ozone precursors during construction, the SmCP-2 Project would implement fugitive dust and exhaust emission controls, including an Exhaust Emissions Control Program (EPM AQ-2), a Potential Temporary Emissions Control Program to limit the operation of temporary sources (EPM AQ-8) and the use of diesel engines with certified NOx Emissions rated as Tier 3 or better during grading (EPM AQ-10). Construction particulate matter would be controlled through the implementation of a Fugitive Dust Suppression Plan (EPM AQ-1) and watering on actively disturbed areas (EPM AQ-11), in compliance with the requirements of ICAPCD Regulation VIII. Construction impacts to ambient air quality from the SmCP-2 Project alone would be less than significant. However, during the first year of construction of the SmCP-2 Project (2015) some of the proposed SmCP-2 Project construction activities would overlap with the late stages of construction of the HR-2 Project. As shown in Table , combined NOx emissions from the two Projects would exceed the ICAPCD construction significance thresholds during April and May 2015, based on the current SmCP-2 and HR-2 construction schedules. Therefore, impacts to ambient air quality during this overlapping construction period would be potentially significant unless mitigation is incorporated. During normal operation, estimated the SmCP-2 Project operational emissions would not exceed the operational significance thresholds for mobile sources or the Rule 207 C.2 offset significance thresholds for stationary sources. During the operational phase, the combined emissions from the normal operations of both the Hudson Ranch Power II and Simbol Calipatria II Final EIR

137 4.3 Air Quality SmCP-2 Project and the HR-2 Project would also not exceed the operational significance thresholds for mobile sources or the Rule 207 C.2 offset significance thresholds for stationary sources. To minimize air pollutant emissions during operations, the SmCP-2 Project would implement an Exhaust Emissions Control Program (EPM AQ-2); a Cooling Tower Emission Program (EPM AQ-3); a Process Equipment Emission Control Program (EPM AQ-4); a Filter Cake Storage Fugitive Emissions Control Program (EPM AQ-5); an Operating & Maintenance Equipment Emission Control Program (EPM AQ-7); and a Potential Emissions Control Program (EPM AQ-8). MM AQ-2.1: NOx Controls During HR-2/SmCP-2 Concurrent Construction During the period of concurrent construction with the SmCP-2 Project, the HR-2 Project will undertake one or more of the following to reduce the estimated NOx emissions from the two Projects to less than 100 pounds per day: The Permittee shall comply with all applicable standard mitigation measures for construction combustion equipment for the reduction of excess NOx emissions as identified in the air quality analysis and as contained in the Imperial County CEQA Air Quality Handbook and associated regulations: 5. Utilize all Tier 3 or Tier 4 construction equipment. 6. Prohibit idling of equipment not in use; for equipment in use reduce idling time to a maximum of 5 minutes. 7. Where feasible replace fossil fuel burning equipment with electrically driven equivalents provided they are not powered via a portable generator. 8. Register all portable engines 50 horse power or greater with the ICAPCD. Permittee shall also apply enhanced measures to assure reduced levels of NOx are maintained during the construction phase of the project. 3. Submit to the Air District prior to any earthmoving activity a complete list of all construction equipment to be utilized during the construction phase identifying Make, Model, Year, and estimated hours of usage. 4. In the event NOx emissions are calculated to exceed ICAPCD thresholds for construction, the Permittee shall provide for off-site mitigation or comply with Policy Number 5. Policy Number 5 allows a project to pay in-lieu impact fees utilizing the most current Carl Moyer Cost Effective methodology to reduce excess NOx emissions. Hudson Ranch Power II and Simbol Calipatria II Final EIR

138 4.3 Air Quality Minimize concurrent construction activities with the SmCP-2 Project construction activities; Incorporate the following mitigation measures from the Imperial County Air Pollution Control District into the proposed Project s Exhaust Emission Control Program for reducing NOx emissions from construction combustion equipment. a. Use of alternative fueled or catalyst-equipped diesel construction equipment, including all off-road and portable diesel-powered equipment. b. Minimize idling time either by shutting equipment off when not in use or reducing the time of idling to 5 minutes as a maximum. c. Limit, to the extent feasible, the hours of operation of heavy duty equipment and/or the amount of equipment in use. d. Replace fossil fueled equipment with electrically driven equivalents (provided they are not run via portable generator set); Pursuant to ICAPCD Policy Number 5, the applicant may pay an in-lieu impact fee as determined by ICAPCD using the formula provided in ICAPCD Policy No. 5 to reduce NOx emissions. Detailed emissions calculations shall be provided to ICAPCD as necessary to support calculation of the fee. Require construction contractors to use Tier 4 construction equipment during site preparation and grading activities. Prior to site preparation activities, the HR-2 Project will submit to the Imperial County Planning and Development Services evidence of the actions proposed to be undertaken to limit NOx emissions from the two Projects during construction to ensure that maximum daily NOx emissions resulting from the proposed combined construction activities will remain below 100 pounds per day. Timing/Implementation: March Enforcement/Monitoring: Imperial County Planning and Development Services/ ICAPCD. Hudson Ranch Power II and Simbol Calipatria II Final EIR

139 4.3 Air Quality Significance after Mitigation: Impact AQ-3: Implementation of MM AQ-2.1 and adherence to ICAPCD regulations and proposed EPMs during the overlapping construction of the HR-2 Project and the SmCP-2 Project would result in levels of NOx emissions below the ICAPCD thresholds of significance for construction. Therefore, implementation of MM AQ 2.1 would reduce impacts to below the level of significance. The SmCP-2 Project would not result in a cumulatively considerable net increase of any criteria pollutant for which the Project region is non-attainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors). During the first year of construction of the SmCP-2 Project (2015), the proposed site preparation and grading activities would overlap with the late stage of construction of the HR-2 Project. As shown in Table , NOx emissions would temporarily exceed the ICAPCD thresholds during April and May This would be a potentially significant impact without mitigation. After completion of the HR-2 construction period, emissions from the development of the SmCP-2 Project would not exceed the ICAPCD thresholds of significance for construction. In order to reduce the potential to temporarily exceed the NOx significance thresholds during construction, MM AQ-2.1 requires the implementation of some combination of controls during the period of concurrent construction, such as minimizing overlapping activities, NOx controls, or the use of Tier 4 construction equipment to ensure that calculated NOx emissions are below the ICAPCD construction significance level of 100 pounds per day. With implementation of MM AQ-2.1 and adherence to ICAPCD regulations and EPMs, impacts from the combined SmCP-2/HR-2 construction period would be less than significant after mitigation. During the operational phase, the combined emissions from the normal operation of the SmCP-2 and HR-2 plants would not exceed the ICAPCD Rule 207 C.2 standards. Therefore, impacts during operations would be less than significant. Impact AQ-4: The SmCP-2 Project would not expose sensitive receptors to substantial pollutant concentrations. Sensitive receptors include residences, schools, hospitals, and other sensitive uses. Land use conflicts can arise when these receptors are located next to major sources of air pollutants. The Project area is a rural, agricultural area. The nearest Hudson Ranch Power II and Simbol Calipatria II Final EIR

140 4.3 Air Quality residence is approximately 0.3 miles south-east of the Project site boundary on W Shrimp Road and is an algae farm caretaker residence 14. Another residence is located 0.5 miles north-east of the Project site, along English Road. This residence is owned by Energy Source (Hudson Ranch Power II, LLC s parent company) and would be vacated in fall 2012 and demolished prior to start of construction of the SmCP-2 Project. The next closest residence is located 1.4 miles north-west of the Project site. The nearest population center is the Town of Niland, located 2.3 miles from the proposed Project site. Other sensitive receptors located within 2.5 miles from the proposed SmCP-2 site include educational centers such as the Grace Smith Elementary School, the Publica High School, Niland Head Start, and ten residences. Other non-sensitive (commercial/industrial) receptors include six industrial or commercial areas, and three other areas (defined as locations with the potential to attract the public for the short, but not the long, term). Combined operations of the proposed SmCP-2 and HR-2 facilities would involve the potential release of NCGs containing H2S, benzene, ammonia, and other trace gases; DPM emissions from the maintenance, testing and emergency operations of diesel-powered engines and fire pumps; H2S emitted from the gas space in the sodium hydrosulfide (NaHS) tank during the filling of the tank with NaHS; and HCl vapors produced by the HCl synthesis process from the hydrogen and chlorine gases produced by the process of converting lithium chloride to lithium hydroxide and HCl storage tank(s). The results of the HRA are shown in Tables to above. Appendix M contains additional details for this analysis. The applicant has incorporated emissions controls in the design of each facility in order to minimize combustion and process emissions during operations of the proposed mineral extraction plant. The combined cancer risks for the combined SmCP-2 and HR-2 operations even during outages of the HR-2 Project- would not exceed the OEHHA recommended threshold of one in one million. The maximum acute (short-term) and chronic (long-term) hazard indices were both well below the recommended significance levels. Based on the results of the HRA, construction and operation of the SmCP-2 Project in combination with the HR-2 Project would not expose sensitive receptors to a significant health risk; therefore, this impact is less than significant. 14 The risk assessment prepared for the SmCP-2 Project (Appendix M) included additional an algae farm caretaker residence as part of the sensitive receptors identified for analysis. As of the date of publication of this DEIR, the algae farm was being sold and not in operation; however, the new property owner will be processing permits to allow this facility to re-open. For this reason, the caretaker residence is considered a sensitive receptor. Hudson Ranch Power II and Simbol Calipatria II Final EIR

141 4.3 Air Quality Mitigation Measures: Impact AQ-5: None required. The SmCP-2 Project would not create objectionable odors affecting a substantial number of people. Existing population in the proposed SmCP-2 project area is sparse, and does not represent a substantial number of people in the closest vicinity of the proposed facilities. The nearest residence is located south-west of the Project site boundary on W Shrimp Road and is an algae farm caretaker residence. Another residence, located 0.5 miles north-east of the Project site (along English Road) is owned by Energy Source (Hudson Ranch Power II, LLC s parent company) and the residence would be vacated in fall 2012 and demolished prior to start of construction of the HR-2 Project. The next closest residence is located 1.4 miles northwest of the SmCP-2 Project site. The closest population center is the Town of Niland, located 2.3 miles from the proposed Project site.. The SmCP-2 construction activities would include the use of diesel-fueled construction equipment, which emits a distinctive odor that may be offensive to some individuals. Odors generated by diesel exhaust would be reduced by the use of either low sulfur or ultra-low sulfur fuel, as required in the state of California. Paving of McDonald Road and onsite roads, and surface coating activities during construction would also generate odors associated with organic compounds in these materials. Combined operations of the proposed SmCP-2 and HR-2 facilities would involve the potential release of NCGs containing H2S and ammonia; combustion emissions from the maintenance, testing and emergency operations of dieselpowered engines and fire pumps; and HCl vapors produced by the HCl synthesis process from the hydrogen and chlorine gases produced by the process of converting lithium chloride to lithium hydroxide and HCl storage tank(s). All these sources would generate distinctive odors that may be offensive to individuals. The applicant would use ultra-low sulfur fuel at all stationary combustion equipment, in addition to emission capture and control for H2S and HCl. Projected 1-hour H2S concentrations for the combined SmCP-2 Project and HR-2 Project normal operations reported in the HRA resulted in a maximum value of 11.3 μg/m 3 at the closest residence, far below the existing statewide CAAQS for H2S of 0.03 ppm (42 μg/m 3 ). Concentrations at the other residences modeled were all less than 0.54 μg/m 3. The maximum modeled 1-hour concentration of 24.1 μg/m 3, at the nearby algae farm caretaker residence, would occur only during the occasional HR-2 plant outages, and would also be below the CAAQS for H2S (42 μg/m 3 ). The H2S CAAQS protects against nuisance odor for the general public Hudson Ranch Power II and Simbol Calipatria II Final EIR

142 4.3 Air Quality (CARB 2000) 15. Implementation of both the SmCP-2 and the HR-2 Projects would result in H2S concentrations below the nuisance odor threshold for the closest receptors identified. Neither the ammonia nor DPM emissions are expected to create objectionable odors affecting a substantial number of people because the emissions are relatively small and the very low population density in the immediate vicinity of the Project. In the event H2S, ammonia or DPM odors were perceived as offensive by the public, complaints would be filed through the existing ICAPCD complaint procedure for investigation by the ICAPCD. Since both the SmCP-2 and HR-2 Projects would be located in a low population density area and Project primary odor sources (e.g., H2S) would be controlled to result in concentrations below the odor perception threshold at closest sensitive receptors; the Project would result in a less than significant impact under this criterion. Mitigation Measures: None required REFERENCES California Air Resources Board (CARB). 2012a. Ambient Air Quality Standards. Last Updated: February 9, Accessed April 11, b. iadam: Air Quality Data Statistics. Air Quality Summaries for Imperial County, Niland and Brawley Monitoring Stations. Accessed April 17, a State Area Designations: Maps for Ozone, PM2.5, PM10, Carbon Monoxide, Nitrogen Dioxide, Sulfur Dioxide, Sulfates, Lead, Hydrogen Sulfide, and Visibility Reducing Particles. Last Updated June 23, Accessed April 11, b. Diesel & Health Research. Background on Diesel Health Effects. Accessed: June 4, a. Toxic Air Contaminant Identification Reports. Last Updated: March Accessed: June 4, b. Toxic Air Contaminant (TAC) Identification List. Last updated: August Accessed: May 14, 2012, 15 The H2S CAAQS was adopted based on rounding the geometric mean odor threshold of ppm measured in adults (CARB 2000). Hudson Ranch Power II and Simbol Calipatria II Final EIR

143 4.3 Air Quality Air Pollution Sources, Effects and Control: Fact Sheet. Last updated: December 2, Accessed April 11, Hydrogen Sulfide: Evaluation of Current California Air Quality Standards with Respect to Protection of Children. Prepared by the California Office of Environmental Health Hazard Assessment. September. California Association of Air Pollution Control Officers (CAPCOA) Health Risk Assessments for Proposed Land Use Projects. CAPCOA Guidance Documents. Prepared by CAPCOA Planning Managers. July. California Energy Commission (CEC) Salton Sea Unit #6 Power Project. Application for Certification (02-AFC-2). December. California Environmental Protection Agency (Cal/EPA) Air Toxics Hot Spots Program Risk Assessment Guidelines: Air Toxics Hot Spots Program Guidance Manual for Preparation of Risk Assessments. Prepared by the Office of Environmental Health Hazard Assessment (OEHHA). August Determination of Acute Reference Exposure Levels for Airborne Toxicants. Appendix C: Acute Toxicity Summaries. Prepared by the Office of Environmental Health Hazard Assessment (OEHHA). March. County of Imperial County of Imperial General Plan. Conservation and Open Space Element. Prepared by the Imperial County Planning and Development Services Department County of Imperial General Plan. Geothermal/Alternative Energy and Transmission Element. Prepared by the Imperial County Planning and Development Services Department. October Revised. County of Imperial General Plan, Land Use Element. Prepared by the Imperial County Planning and Development Services Department. January. Environmental Management Associates (EMA). 2012a. Air Pollutant Emission Estimates for Construction of the Hudson Ranch Power II Geothermal Project, Imperial County, California. Prepared for Hudson Ranch Power II LLC. April b.Hudson Ranch Power II Geothermal Project Imperial County, California. Operational Processes and Air Pollutant Emissions. EMA Report No Prepared for Energy Source LLC. April c. Air Pollutant Emission Estimates for the Simbol Calipatria Plant II, Imperial County, California. Prepared for Simbol, Inc. April d. Simbol, Inc. Sm Calipatria Plant II Imperial County, California. Operational Processes and Air Pollutant Emissions. EMA Report No April. Hudson Ranch Power II and Simbol Calipatria II Final EIR

144 4.3 Air Quality. 2012e. Hudson Ranch Power II Geothermal Project and Simbol Inc. Sm Calipatria Plant II. Assessment of Potential Air Toxics Health Risks. EMA Report No April f. Carbon Monoxide Air Quality Impact Analysis. Hudson Ranch Power II LLC Hudson Ranch II Geothermal Project Imperial County, California. EMA Report No June. Imperial County Air Pollution Control District (ICAPCD) CEQA Air Quality Handbook. Guidelines for the Implementation of the California Environmental Quality Act of 1970, as amended. November Imperial County State Implementation Plan for Particulate Matter Less than 10 Microns in Aerodynamic Diameter. Final. Prepared by ENVIRON. August Final Hour Ozone Modified Air Quality Management Plan. July. Sciencelab Hydrochloric Acid Data Sheet (MSDS). Available: Last Updated November Accessed: April Soucier, Monica Air Pollution Control Division Manager. Imperial County Air Pollution Control District (ICAPCD). El Centro, CA. Personal Communication (Electronic mail). U.S. Environmental Protection Agency (EPA) National Ambient Air Quality Standards (NAAQS). Last Updated: November 08, Accessed April 11, a. The Green Book Non-Attainment Areas. Accessed April 11, b. Learn about Lead. Last updated: May Accessed: May 16, About Air Toxics. What are toxic air pollutants? Last updated: August, Accessed: June 4, Policies for Addressing PM2.5 Precursor Emissions. Presentation prepared by EPA Office of Air Quality Planning and Standards. June. Hudson Ranch Power II and Simbol Calipatria II Final EIR

145 4.4 Biological and Natural Resources 4.4 BIOLOGICAL AND NATURAL RESOURCES This section assesses the impacts of the proposed Projects on biological and natural resources. This section also describes and summarizes applicable plans, policies, and regulations for biological and natural resources. Scoping Issues Addressed During the scoping period for the proposed Projects, two public scoping meetings were conducted and written comments were received from agencies and the public. The following issues related to biological and natural resources were raised by the Imperial Irrigation District (IID) and the California Department of Fish and Game (CDFG) are addressed in this section: The Draft Environmental Impact Report (EIR) should address impacts on IID s drains. One-third of the water delivered to agricultural users is discharged into the IID s drainage system. Reduction in field drainage due to land use conversion has an incremental impact on both drain water quality and the volume of water in the drain and the habitat (flora and fauna) bordering the drainage path to the Salton Sea. Reduction in field drainage also affects the elevation of the Salton Sea, the shoreline habitat, and exposed acreage that in turn may have air quality issues. Additionally, certain drains that drain directly to the Salton Sea have been identified as desert pupfish habitat (Cyprinodon macularius) and thus require additional protections under state and federal Endangered Species Acts (ESAs). IID Water facilities that could be impacted are the O Lateral and the N Drain. Any construction or operation on IID property or within its existing and proposed right-of-way (ROW) or easements would require an encroachment permit. The following issues related to biological and natural resources were raised by the California Department of Fish and Game and are addressed in this section: The proposed Project site is located in potential habitat for the Western Burrowing Owl (Athene cunicularia). This species is designated as California Species of Special Concern. Section of the California Environmental Quality Act (CEQA) requires the lead agency to treat sensitive species as though they were listed, if the species meets the criteria for listing described in the section. The Department believes that the proposed Project could further the decline of the above sensitive species. This species must be treated as though it were listed and appropriate avoidance, mitigation, and compensation for impacts need to be identified. Hudson Ranch Power II and Simbol Calipatria II Final EIR

146 4.4 Biological and Natural Resources Unavoidable impacts to the Western Burrowing Owl should be mitigated through acquisition and protection, in perpetuity, of high quality biological habitat. In addition, surveys and mitigation should be consistent with the 1995 Department Staff Report on Burrowing Owl Mitigation. The Department opposes the elimination of watercourses and/or their channelization or conversion to subsurface drains. All wetlands and watercourses, whether intermittent or perennial, must be retained and provided with substantial setbacks which preserve the riparian and aquatic values and maintain their value to on-site and off-site wildlife populations. The Department is emphasizing in comment letters on projects with impacts to lakes or streambeds that alternatives and mitigation measures must be addressed in CEQA certified documents prior to submittal of an application of a Streambed Alteration Agreement (SAA). Any information which is supplied to the Department after the CEQA process is complete will not have been subject to the public review requirements of CEQA. In order for the Department to process a SAA agreement, the CEQA-certified documents must include an analysis of the impacts of the proposed Project on the lake or streambed, an analysis of the biological resources present on the site, copies of biological studies conducted on the site, biological survey methodology, and a discussion of any alternative, avoidance, or mitigation measures which will reduce the impacts of the proposed development to a level of insignificance. In addition, a discussion of potential adverse impacts from any increased runoff, sedimentation, soil erosion, and/or pollutants on streams and watercourses on or near the Project site, with mitigation measures proposed to alleviate such impacts must be included in the CEQA certified documents. Applicant s Reports and Survey Results Information used in preparing this section and in the evaluation of potential impacts on biological and natural resources was supported by field data provided in the 2010 and 2011 Biological Resources Technical Reports prepared between July 2010 and December 2011 and are contained in Appendix D. Specifically, Barrett's Biological Surveys (Barrett s) prepared the following reports: Biological Resources Technical Report (dated July 2010), which included focused western burrowing owl surveys of the proposed geothermal well pads and internal access routes for HR-2 (Appendix D-1). The burrowing owl surveys were completed by Barrett's on July 3rd, July 4th and July 5th 2010; A Biological Resources Technical Report (dated December 2011), which addressed biological resources within the southern 80 acres of the Hudson Ranch 2 Project area (i.e. southern 80-acres of APN ). This report also included focused western burrowing owl surveys completed on December 23rd and December 24th, 2011 (Appendix D-2); A Biological Resources Technical Report (dated October 2011), which included general biological surveys, a focused burrowing owl survey and a preliminary U.S. Waters jurisdictional delineation Hudson Ranch Power II and Simbol Calipatria II Final EIR

147 4.4 Biological and Natural Resources were conducted in the fall, 2011 within the road right-of-way along McDonald Road, between Highway 111 and English Road (Appendix D-3). A focused western burrowing owl survey was completed on September 21, The survey area also included the possible turn lane areas north and south of McDonald Road along Highway 111 These documents are contained in Volume II (Technical Appendix) of this EIR EXISTING SETTING REGIONAL SETTING The HR-2 and SmCP-2 Project sites are located within the Colorado Desert ecoregion, an area with vegetation and habitat that has adapted to an arid sub-tropical climate (U.S. Forest Service [USFS] 1998). Elevations within this ecoregion range from 230 feet below sea level at the Salton Sea to 2,200 feet above sea level at the boundary with the Peninsular Ranges. Vegetation in the ecoregion is supported by an average annual precipitation of approximately 5.5 inches (USFS 1998). Average high temperatures recorded at El Centro range from 70 degrees Fahrenheit ( F) in January to 107 F in July. Average low temperatures range from 40 F in January to 75 F in July (Western Regional Climate Center 2011). The County of Imperial is located on the Pacific Flyway for migratory waterfowl, shorebirds, and songbirds. Although this area is considered to be part of the Colorado Desert, approximately 500,000-acres of the Colorado Desert in the County of Imperial, including the Project sites, have been converted to agricultural use (Barrett 2010). The irrigation system in the Imperial Valley attracts many bird species that are typically found in agricultural areas, including waterfowl, gulls, herons, cranes, ibises, egrets, doves, quail, sparrows, juncos, and finches. Some raptor species forage in this area as well, particularly the western burrowing owl (Athene cunicularia hypugea), which also uses burrows in many of the irrigation canals and drains. Small mammals occupy habitat along the canals and drains. Some of the common species include western harvest mouse (Reithrodontomys megalotis), house mouse (Mus musculus), Norway rat (Rattus norvegicus), valley pocket gopher (Thomomys bottae), brush rabbit (Sylvilagus bachmani), striped skunk (Mephitis mephitis), raccoon (Procyon lotor), and muskrat (Ondatra zibethicus). Surrounding desert areas provide habitat for these species as well as larger mammalian species such as black-tailed jackrabbit (Lepus californicus), mule deer (Odocoileus hemionus), wild burro (Equus asinus), gray fox (Urocyon cinereoargenteus), coyote (Canis latrans), bobcat (Lynx rufus), and mountain lion (Puma concolor). Reptiles typically associated with the Colorado Desert may occur in Imperial Valley agricultural areas. Some common species include Sonoran gopher snake (Pituophis catenifer affinis), western diamondbacked rattlesnake (Crotalus atrox), Marcy s checkered gartersnake (Thamnophis marcianus marcianus), and Great Plains toad (Anaxyrus cognatus). Hudson Ranch Power II and Simbol Calipatria II Final EIR

148 4.4 Biological and Natural Resources Project Sites Habitat on the Project sites primarily consists of agricultural land. In the past, portions of the Project site were used to grow alfalfa. At the time of the publication of the NOP, the agricultural fields on the Project sites were fallow and not being irrigated; the ground had been disked with little to no vegetation or it was bare ground interspersed with non-native annual grasses. Multiple irrigation canals and drains are located just north and south of the Project site. The O Drain is located north of the Project sites and north of McDonald Road. The O Lateral is located immediately north of the Project sites and the N Drain is located immediately south of the Project Sites. The N Drain empties into the O Drain just west of the Project sites. There are small patches of ruderal vegetation (plant species first to colonize disturbed land) found along and within IID s O Lateral and N Drain on the north and south ends of the Project site, as well as within dry canals running in a north-south direction between the O Lateral and the N Drain. Plants found within these areas include salt cedar (Tamarix sp.), quail bush (Atriplex sp.), and a few small patches of cattails (Typha sp.). While cattails are considered hydrophytic vegetation (one indicator of wetland habitat), the few small patches of cattails in the Project sites are associated with manmade canals. Man-made canals are not considered wetlands because wetland hydrology would no longer exist if irrigation were to be terminated (U.S. Army Corps of Engineers [USACE] 1987). Wildlife species abundance and diversity are closely linked with habitat types present, though abundance and distribution may vary by season. In the Project area, where the dominant habitat is sparsely vegetated fallow agricultural lands and canals and drains, several wildlife species use this landscape for foraging, including burrowing owl (Athene cunicularia), red-winged blackbird (Agelaius phoeniceus), savannah sparrow (Passerculus sandwichensis), meadowlark (Sturnella neglecta), killdeer (Charadrius vociferus), great white egret (Casmerodius albus), mourning doves (Zenaida macroura), and cattle egret (Bubulcus ibis), among others. Small mammals have been observed either on or near the Project site, including cottontail (Sylvilagus audubonii), raccoon, round-tailed ground squirrel (Spermophilus tereticaudus), striped skunk, and muskrat. The Project sites have been used for agriculture during recent years. Accordingly, the presence of special status plant species (i.e., species listed as threatened or endangered pursuant to either the state or federal ESAs, those designated as species of special concern, and/or those on various non-government organization watch lists owing to various sources of concern for the species conservation status) is highly unlikely. However, several special status species could occur in the Project area. Although a search of the California Natural Diversity Database (CNDDB) did not show any special status plants within 5 miles of the Project sites, a review of the Biological Resources Technical Report County of Imperial for the Hudson Ranch Power II, LLC Geothermal Flash Power Project (Appendix D-1), the Biological Resources Technical Report, County of Imperial, California for the Hudson Ranch II Southern 80- acres (Appendix D-2), and the Biological Resources Technical Report, for the McDonald Road Paving (Hwy Hudson Ranch Power II and Simbol Calipatria II Final EIR

149 4.4 Biological and Natural Resources 111 to English Road) (Appendix D-3), showed 14 special status species potentially occurring on the Project site. Table lists the special status wildlife species that have the potential to occur within the proposed HR-2 and SmCP-2 Project sites and their federal and/or state status. This list was identified in the 2010 and Biological Resources Technical Reports and verified by a search of the CNDDB. Special Status Wildlife Species with Potential to Occur at the Project Site Amphibians and Reptiles Couch s spadefoot toad (Scaphiopus couchii) SC Couch s spadefoot toad is a California species of special concern found in southeast California, east of the Algodones Dunes and north to San Bernardino County. This species is typically observed in deserts and arid regions of grassland, prairie, mesquite, creosote bush, thorn forest, and sandy washes that are able to maintain temporary rain pools that last at least seven days for breeding and metamorphosis (CaliforniaHerps.com 2011). It is typically observed at elevations from sea level to 5,900 feet above sea level. Couch s spadefoot toad has not been observed within the Project site. The nearest known occurrence of Couch s spadefoot toad was an observation made 4.1 miles from the Project sites in 2007 (California Natural Diversity Database 2012) (Figure 4.4-1). Habitat conditions for the species do not occur on-site. Therefore, this species has a low potential of occurring in the Project site. Sonoran desert toad (Bufo alvarius) SC The Sonoran desert toad also is a California species of special concern. It is thought to have been extirpated and no specimens have been collected or observed in California since Historical observations were in desert lowland washes, irrigation ditches, temporary pools, and in upland areas. While limited Sonoran desert toad habitat conditions exist on-site, the last recorded observation of this species was in 1916, 2.9 miles from the Project site (CNDDB 2012) (Figure 4.4-1). Therefore, this species has a low potential to occur in the Project sites if it has not been extirpated. San Sebastian leopard frog (Rana yavapaiensis) SC The San Sebastian leopard frog is a California species of special concern. This frog historically ranged from San Felipe Creek east to the lower Colorado River Valley. Isolated populations may remain in the Imperial Valley and the San Felipe Creek drainage, but it is likely that it has been extirpated from the California portion of its range (CaliforniaHerps.com 2011). This species was observed in slackwater aquatic habitats, such as in the San Sebastian Marsh, approximately 30 years ago, but has not been reported in that area since (CaliforniaHerps.com 2011). On-site aquatic habitat is limited and the last observation of this species was in 1940 at a location 3.4 miles from the Project site 3.4 miles from the Project site (CNDDB 2012) (Figure 4.4-1). Based on limited habitat and no sightings of this species in the past 70 years, this species has a low potential to occur in the Project sites if it has not already been extirpated. Hudson Ranch Power II and Simbol Calipatria II Final EIR

150 4.4 Biological and Natural Resources TABLE SPECIAL STATUS WILDLIFE SPECIES POTENTIALLY OCCURRING IN THE PROJECT AREA COMMON NAME (SCIENTIFIC NAME) STATUS 1 IN THE PROJECT AREA 2 POTENTIAL TO OCCUR PROJECT IMPACTS AMPHIBIANS AND REPTILES Couch s spadefoot toad (Scaphiopus couchii) SC Low Less than significant Sonoran desert toad (Bufo alvarius) SC Low Less than significant San Sebastian leopard frog (Rana yavapaiensis) SC Low Less than significant FISH Desert pupfish (Cyprinodon macularius) FE, SE Low Less than significant Razorback sucker (Xyrauchen texanus) FE, SE Low Less than significant BIRDS Yuma clapper rail (Rallus longirostris yumanensis) FE, ST Low; No suitable habitat on-site No Impact California black rail (Laterallus jamaicensis corturniculus) ST Low; No suitable habitat on-site No Impact Burrowing owl (Athene cunicularia) SC High; Observed in 2011 Less than significant with mitigation Merlin (Falco columbarius) SC Moderate Less than significant Crissal thrasher (Toxostoma crissale) SC Low, Scarce suitable habitat Less than significant Gull-billed tern (Sterna nilotica) SC Low; No suitable habitat on-site No Impact Black skimmer (Rynchops niger) SC Low; No suitable habitat on-site No Impact Yellow warbler (Dendroica petechia brewsteri) SC Low; No suitable habitat on-site No Impact MAMMALS American badger (Taxidea taxus) SC Low Less than significant with mitigation Sources: CNDDB 2012; Barrett 2010 Notes: 1 FE = Federal endangered; SE = State endangered; ST = State threatened; SC = California species of special concern. 2 Potential for occurrence ranking is based on the following criteria: High = Recent or historical record of the species occurring within the Project sites or within 1 mile of the Project sites and/or the habitat requirements for the species occur within Project site Moderate = either a recent or historical record exists of the species within 1 mile of the Project sites or the habitat requirements for the species occur within the Project site Low = No recent or historical records exist of species occurring within the Project sitesor within 1 mile of Project site, and/or the habitats needed to support the species on the site are of poor quality Hudson Ranch Power II and Simbol Calipatria II Final EIR

151 Path: \\prtbhp1\gis\sandiego\hudsonranch_geothermal\maps\mxds\figure_4_4-1_h2_cnddb_speciesjc.mxd Salton Sea Hudson Ranch Power II and Simbol Calipatria II Project Sites 111 Riverside County 5 miles 115 Imperial County MEXICO HR-2 and SmCP-2 Project Sites CNDDB Query Results AMERICAN BADGER CALIFORNIA BLACK RAIL COUCH S SPADEFOOT CRISSAL THRASHER SONORAN DESERT TOAD YUMA CLAPPER RAIL YUMA HISPID COTTON RAT BLACK SKIMMER BURROWING OWL DESERT PUPFISH GULL-BILLED TERN SAN SEBASTIAN LEOPARD FROG MERLIN RAZORBACK SUCKER YELLOW WARBLER T&E Species Hudson Ranch Power II CUP #G & Simbol Calipatria II CUP # Recorded Occurrences of Special-Status Species within a Five-Mile Radius of the Project Sites Figure Miles

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153 4.4 Biological and Natural Resources Fish Desert pupfish (Cyprinodon macularius) FE, SE The desert pupfish is a federally listed and state-listed endangered species. The desert pupfish range includes the basin of the lower Colorado and Gila rivers, from southern Arizona to southeastern California and eastern Baja California, and the Sonoyta River of northern Sonora, Mexico (Sutton 1999). Desert pupfish are observed throughout the Salton Basin, inhabiting springs, seeps, and slow-moving streams. Desert pupfish populations are remnants of those that inhabited ancient Lake Cahuilla. The range of this species has been dramatically reduced by habitat modifications and the introduction of exotic fishes. Desert pupfish have been recorded in a few saline pools along the Salton Sea s edge, some irrigation drains flowing into the Salton Sea, and portions of the Salt and San Felipe creeks, which are both tributaries to the western side of the Salton Sea and not in the Project area. Desert pupfish have not been observed within the Project area. The nearest known occurrence of this species is an observation 1.5 miles from the Project site that was recorded in 2006 (CNDDB 2012) (Figure 4.4-1). The Supplement to the IID Water Conservation and Transfer Project EIR/EIS for the Managed Marsh Complex (IID 2008), notes that pupfish are found in the lowest reaches of the O Drain, from the Salton Sea to the first check structure, which is located about 2,000 feet upstream of the Salton Sea (IID, 2008). It also noted that pupfish do not occur in the O Drain immediately adjacent to the Project site, which is located (approximately one mile) above the first check structure (IID 2008, p )). Therefore, this species has a moderate potential to occur in the Project area. Razorback sucker (Xyrauchen texanus) FE, SE The razorback sucker is a federally listed and state-listed endangered species. It is one of the largest suckers in North America, growing up to 13 pounds and more than 3 feet long. It is known to occur in the lower Colorado River watershed, but only in Lake Mojave, upstream in Lake Mead and the Grand Canyon, and downstream sporadically on the mainstem and associated impoundments and canals (U.S. Fish and Wildlife Service [USFWS] 1991). This species was observed 4.4 miles from the Project site in 1974 (CNDDB 2012) (Figure 4.4-1). However, this fish is restricted to aquatic habitat with at least intermittent connection to the Colorado River without barriers. Because of the distance of the Project site from the Colorado River and the number of check dams in irrigation canals of the Imperial Valley, the potential for this species to occur in the Project sites is low. Birds Yuma clapper rail (Rallus longirostris yumanensis) FE, ST The Yuma clapper rail is federally listed as endangered and state-listed as threatened. This freshwater marsh bird typically inhabits mosaics of vegetated areas interspersed with shallow open water areas (USFWS 2011). Yuma clapper rails have not been observed within the Project sites. The nearest known occurrence of Yuma clapper rail is a 2006 observation located 1.1 miles from the Project site (CNDDB 2012) (Figure 4.4-1). Yuma clapper rail utilize habitat in freshwater marshes dominated by cattail or bulrush Hudson Ranch Power II and Simbol Calipatria II Final EIR

154 4.4 Biological and Natural Resources (USFWS 2011). A few small patches of cattail exist on-site, but because this habitat is limited and there is no visible surface water in the cattail habitat, it is unlikely that Yuma clapper rail would utilize this habitat (Roberts 2011). Because ideal habitat conditions for this species do not occur on-site and marsh habitat is extremely limited, this species has a low potential of occurring in the Project sites. California black rail (Laterallus jamaicensis corturniculus) ST The California black rail is a state-listed threatened (ST) species. It is found throughout the San Francisco Bay Area, from the Sacramento and San Joaquin river deltas to the coast, to Baja California, the Salton Sea, and the lower Colorado River. At the Salton Sea and along the lower Colorado River, north of Yuma, this species typically inhabits saltwater, brackish, and freshwater marshes (California Department of Fish and Game [CDFG] 2012a). The California black rail has not been observed in the Project area. The nearest known occurrence of a California black rail was an observation 4.4 miles from the Project site in 2006 (CNDDB 2012) (Figure 4.4-1). Marsh habitat is extremely limited in the Project site and consists of a few small patches of cattails with no visible water in the cattail habitat. Therefore, this species has a low potential to occur in the Project site. Western burrowing owl (Athene cunicularia) SC The Western burrowing owl is listed as a California species of special concern and is found throughout the state. Historically, this species occurred in pasturelands and grasslands throughout California, but in recent times it has been found in agricultural and desert areas with open vegetation communities. According to the CNDDB, the nearest known occurrence of western burrowing owl was a 2006 observation 1.7 miles from the Project site (CNDDB 2012) (Figure 4.4-1). However, suitable habitat exists for burrowing owls in the Project site, and owls and active burrows have been recently observed on-site (Appendix D). Therefore, the Western burrowing owl has a high potential to occur in the Project site. The technical surveys found 22 burrowing owls and 17 active burrows in the HR-2 and SmCP-2 Project site. Table lists the number of active burrows and burrowing owls found in the HR-2 and SmCP-2 Project sites. Figures and show the locations of active burrows, inactive burrows and the number of burrowing owls found during the surveys (Appendix D). TABLE RESULTS OF BURROWING OWL SURVEYS AREA TYPE PROPERTY BUFFER TOTAL HR-2 Site Individuals Burrows Additional 80 Acres Individuals Subtotal Burrows Individuals Burrows Hudson Ranch Power II and Simbol Calipatria II Final EIR

155 4.4 Biological and Natural Resources TABLE RESULTS OF BURROWING OWL SURVEYS AREA TYPE PROPERTY BUFFER TOTAL McDonald Road Paving Individuals Burrows TOTAL Individuals Burrows Sources: Barrett, 2010; 2011a; 2011b Merlin (Falco columbarius) SC Merlin is a California species of special concern. Although this species is seldom found in open deserts, its range extends throughout most of the western half of the state at elevations below 3,900 feet. It is a rare winter migrant in desert habitats (CDFG.2012a. However, it is probably more common in the Salton Sea area than it is in other parts of the desert because the Merlin typically frequent shorelines during the winter to catch shorebirds as prey. This species has not been observed within the Project area. The nearest known occurrence of Merlin was a 2007 observation 3.6 miles from the Project site (CNDDB 2012) (Figure 4.4-1). Although this species remains a rare inhabitant of the Colorado Desert, it has a moderate potential to occur because of the Project site s proximity to the Salton Sea and the suitable foraging habitat that exists on-site. Crissal thrasher (Toxostoma crissale) SC The Crissal thrasher is a California species of special concern. This species typically inhabits dense thickets of shrubs or low trees in desert riparian and desert wash habitats (CDFG 2012a). It has not been documented in the Project area The nearest known occurrence of Crissal thrasher was an observation 1.8 miles from the Project site recorded in 1969 (CNDDB 2012) (Figure 4.4-1). Suitable habitat does not exist in the Project sites. Therefore, the Crissal thrasher has a low potential to occur. Gull-billed tern (Sterna nilotica) SC The gull-billed tern is a California species of special concern. This summer resident of the United States is typically observed in salt marshes, estuaries, lagoons, and open coastal areas while foraging over marshes, pastures, farms, and plowed fields (CDFG 2012a.). This species has not been documented in the Project area. The nearest known occurrence of a gull-billed tern was an observation 3.6 miles from the Project site that was recorded in 1998 (CNDDB 2012) (Figure 4.4-1). While gull-billed terns will sometimes forage plowed fields and agricultural lands, the Project site does not contain sufficient marsh habitat for foraging. Therefore, this species has a low potential to occur. Hudson Ranch Power II and Simbol Calipatria II Final EIR

156 4.4 Biological and Natural Resources Black skimmer (Rynchops niger) SC The black skimmer is a California species of special concern. This species is a fairly common summer resident of the Salton Sea that forages on small fishes and crustaceans in shallow water. Roosting takes place on sandy beaches or gravel bars and this species is unlikely to wander far from the Salton Sea (CDFG 2012a.). Observations have not been recorded in the Project area. The nearest known occurrence of black skimmer was an observation 3 miles from the Project site that was recorded in A more recent occurrence of a black skimmer is a 1998 observation 3.6 miles from the Project site (CNDDB 2012) (Figure 4.4-1). Because this species does not wander far from the Salton Sea, this species has a low potential to occur in the Project sites. Yellow warbler (Dendroica petechia brewsteri) SC The yellow warbler is a California species of special concern. This species is commonly found in riparian deciduous habitats in summer and, when migrating, uses woodland, forest, and shrub habitats as cover (CDFG 2012a.). This species has not been observed within the Project area. The nearest known occurrence of a yellow warbler is an observation 2.3 miles from the Project site that was recorded in 1952 (CNDDB 2012) (Figure 4.4-1). Suitable habitat does not exist in the Project area and the species has not been observed within 5 miles of the Project site since Therefore, this species has a low potential to occur. Mammals American badger (Taxidea taxus) SC American badger is a California species of special concern. This species is an uncommon but permanent resident of much of California and is most abundant in the drier, open stages of most shrub, forest, and herbaceous habitats (CDFG 2012a.). The badger frequently uses new and old burrows for cover. American badgers have not been documented in the Project area. The nearest known occurrence of American badger is an observation 1.8 miles from the Project site that was recorded in 1937 (CNDDB 2012) (Figure 4.4-1). Because suitable habitat does not exist in the Project area and the species has not been observed within 5 miles of the Project site since 1937, this species has a low potential to occur in the Project site. Adjacent Areas The Salton Sea is a vital link in the Pacific Flyway as birds migrate along this coastal corridor. The Sonny Bono Salton Sea National Wildlife Refuge, located 2.75 miles southwest of the Project site, on the southeastern shore of the Salton Sea, helps support the bird population. The Salton Basin is important to migratory bird species because the area provides ample food sources during migrations. The Salton Sea also provides habitat for several species of fish including the introduced tilapia (Tilapia spp.) and the native desert pupfish, which is now federally listed and state-listed as endangered. Surface water resources are limited in the vicinity of the Project site. Hudson Ranch Power II and Simbol Calipatria II Final EIR

157 MATCH LINE MATCH LINE English Rd Path: \\prtbhp1\gis\sandiego\hudsonranch_geothermal\maps\mxds\figure_4.4-2 Results on Burrowing Owl Surveys_jc.mxd Hudson Ranch I Power Plant McDonald Rd O Drain O Lateral 1,0 1,0 1,2 1,1 1,2 1,2 1,2 1,2 1,1 1,1 1,0 1,1 1,1 1,1 1,2 1,1 1,1 Schrimpf Rd N Drain 1,0 1,0 1,1 1,3 1,2 1,2 N Lateral Burrowing Owl Survey Area and 500 Buffer Riverside County Imperial County MEXICO Burrowing Owl Survey Area 500 ft Buffer HR I Power Plant Proposed IID Substation 0,0 # of Burrows, # of Owls Innactive Burrowing Owl Burrow Burrowing Owl Burrow Burrowing Owl and Burrow Source: Barrett s Biological Surveys, December 2011 & Barrett s Biological Surveys, July 2010 Hudson Ranch Power II CUP #G & Simbol Calipatria II CUP # Results of Burrowing Owl Surveys- HR-2 & SmCP-2 Projects Figure Miles

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159 English Rd Path: \\Prtbhp1\gis\SanDiego\HudsonRanch_Geothermal\MAPS\MXDs\Figure_4.4-3 McDonaldRoad_Biological_Resources_jc.mxd MATCH LINE 1,0 1,1 1,1 1,0 1,1 1,2 1,2 1,1 1,1 O Drain O Lateral 1,2 McDonald Rd 1,1 1,1 1,2 1, ,1 1,3 1,2 1,2 N Drain N Lateral Schrimpf Rd MATCH LINE Burrowing Owl Survey Area and 500 Buffer Riverside County Burrowing Owl Survey Area 0,0 # of Burrows, # of Owls Innactive Burrowing Owl Burrow Hudson Ranch Power II CUP #G & Simbol Calipatria II CUP # Figure Imperial County MEXICO 500 ft Buffer Burrowing Owl Burrow Burrowing Owl and Burrow Source: Barrett s Biological Surveys, December 2011 & Barrett s Biological Surveys, July 2010 Results of Burrowing Owl Surveys- Proposed McDonald Road Paving Miles

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161 4.4 Biological and Natural Resources Irrigation drains in the region can provide surface water that desert pupfish inhabit. However, they are largely limited to the lower reaches (below the first check structure) of 29 agricultural drains directly connected to the Salton Sea (IID, 2008, p ) REGULATORY SETTING FEDERAL AND STATE Endangered Species Act The ESA, as amended, Section 7 (a)(2), directs that each federal agency shall, in coordination with the Secretary of the Interior, ensure that any action authorized, funded, or carried out by such agency is not likely to jeopardize the continued existence of any endangered species or threatened species or result in the destruction or adverse modification of critical habitat for any endangered or threatened species. The ESA specifically prohibits "take" (i.e., to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to engage in any such conduct) without a permit. The USFWS determines and maintains a list of protected species and is the regulatory agency responsible for implementation and enforcement of the ESA. If a proposed plan has the potential to affect a listed species or designated critical habitat, formal consultation is required, except when the USFWS concurs, in writing, that a proposed plan "is not likely to adversely affect" listed species or designated critical habitat (50 Code of Federal Regulations [CFR] Sections and ). During the Section 7 consultation process, the federal lead agency makes a determination as to whether a proposed plan is likely to jeopardize the continued existence of a listed species or destroy or adversely modify designated critical habitat. The lead agency seeks concurrence from the USFWS. The consultation concludes with a biological opinion and an incidental take statement issued by the USFWS. Migratory Bird Treaty Act The Migratory Bird Treaty Act (MBTA) (16 United States Code [U.S.C.] ) is administered by the USFWS. The Act prohibits the taking, killing, possession, and transportation of migratory birds, their eggs, and nests. Section 3513 of the California Department of Fish and Game (CDFG) Code adopts the MBTA s provisions. The MBTA has no provision for allowing unauthorized take. However, the USFWS focuses enforcement on take occurrences where all reasonable, prudent, and effective take-avoidance measures were not identified and implemented. Almost all migratory bird species are protected by the MBTA (836 species in all), with the exception of non-native species and certain game birds. Hudson Ranch Power II and Simbol Calipatria II Final EIR

162 4.4 Biological and Natural Resources Bald and Golden Eagle Protection Act The Bald and Golden Eagle Protection Act (BGEPA) makes it illegal to take bald eagles (Haliaeetus leucocephalus) or golden eagles (Aquila chrysaetos) or to trade in eagle parts, eggs, or feathers. Take has also been broadly interpreted to include altering or disturbing nesting habitat. The USFWS has new regulations (Federal Register (FR) 74: , September 11, 2009) that may eventually allow renewable energy projects to receive bald or golden eagle take permits for programmatic actions that are consistent with the USFWS goal of stable or increasing eagle breeding populations (USFWS 2010). Development of an Avian and Bat Protection Plan can demonstrate that a project is consistent with achieving USFWS goals. The USFWS is concerned by the decreasing golden eagle population trends shown in long-term studies; therefore, until further data shows that golden eagle populations can withstand additional take, the USFWS will only consider BGEPA take permit issuance for safety emergencies and projects that result in net benefits to golden eagles (USFWS 2010). United States Fish and Wildlife Service Eagle Permits, 50 CFR Part This section of the CFR requires a federal programmatic permit for the incidental take of bald or golden eagles where the take cannot practicably be avoided in the course of an otherwise lawful activity. The regulations have not yet been implemented, but permits may be required in the near future. Section 404 of the Clean Water Act The objective of the Clean Water Act (CWA) is to restore and maintain the chemical, physical, and biological integrity of the nation's waters by preventing pollution from point and nonpoint sources, providing assistance to publicly owned treatment works for the improvement of wastewater treatment, and maintaining the integrity of wetlands. The U.S. Environmental Protection Agency (EPA) is the regulatory agency that is responsible for the implementation and enforcement of the CWA. Section 404 of the CWA is the most significant federal program affecting the protection of wetlands and waters of the United States. This program regulates the discharge of dredged and fill material into waters of the United States and the conversion of wetlands. The basic premise of the Section 404 program is that no discharge of dredged or fill material can be permitted if the discharge would result in significant degradation of the nation's waters and wetlands. Another federal mandate regulating wetlands is Executive Order 11990, Protection of Wetlands, which requires federal agencies not only to minimize the destruction of wetlands but also to initiate action to enhance their natural functional values. Section 401 of the Clean Water Act The CWA, through Section 401, provides a way for states to control the degree of impact of discharges on state waters (including wetlands). The CWA requires that any applicant wishing to receive a federal license or permit to conduct an activity that might result in a discharge to navigable waters must obtain a Section 401 certification. States are integrating Section 401 into their overall water quality protection programs, which include protecting the physical, chemical, and biological health of state waters. Section 401 Hudson Ranch Power II and Simbol Calipatria II Final EIR

163 4.4 Biological and Natural Resources certification is granted by states, except in cases where states issue a waiver for the certification requirement California Endangered Species Act The California Endangered Species Act (CESA) establishes legal protection for state-designated threatened and endangered plants and wildlife. The protection is administered under the authority of the CDFG. The CDFG also identifies species of special concern as those that may become listed as threatened or endangered due to loss of habitat, limited distributions, and diminishing population sizes, or because the species is deemed to have scientific, recreational, or educational value. The CDFG recognizes that plants on California Native Plant Society (CNPS) Lists 1A, 1B, and 2, and some of the plants on Lists 3 and 4 qualify for listing under Sections 2062 and 2067 of the CESA. The CESA is only triggered when use of non-federal lands are required by and become part of a proposed plan. California Department of Fish and Game Code, Sections 3511 and 5050 Sections 3511 and 5050 of the CDFG Code prohibit the take and possession of birds and reptiles listed as fully protected. The fully protected classification was California's initial effort in the 1960s (pre-esa) to identify and provide additional protection to those animals that were rare or faced possible extinction. The CDFG Code sections dealing with fully protected species state that these species may not be taken or possessed at any time and no provision of this Code or any other law shall be construed to authorize the issuance of permits or licenses to take any fully protected" species, although take may be authorized for necessary scientific research. In 2003, the Code sections dealing with fully protected species were amended to allow the CDFG to authorize take resulting from recovery activities for state-listed species. The administering agency is the CDFG. California Food and Agriculture Code, Sections The California Commissioner of Agriculture is granted the authority to regulate and manage non-native invasive weeds. LOCAL County of Imperial General Plan The County of Imperial General Plan outlines the goals and policies for managing natural resources within County of Imperial. Table identifies applicable policies related to biological and natural resources and addresses the HR-2 and SmCP-2 Projects consistency with the General Plan. Hudson Ranch Power II and Simbol Calipatria II Final EIR

164 4.4 Biological and Natural Resources TABLE HR-2 AND SMCP-2 PROJECTS CONSISTENCY WITH THE GENERAL PLAN S BIOLOGICAL AND NATURAL RESOURCE POLICIES GENERAL PLAN POLICIES CONSISTENCY ANALYSIS LAND USE ELEMENT (LU) LU Agriculture Policy: The General Plan covers the unincorporated area of the County and is not sitespecific; however, a majority of the privately owned land is located in the area identified by the General Plan as Agriculture, which is also the predominant area where burrowing owls create habitats, typically in the brims and banks of agricultural fields. Program: Prior to approval of development of existing agricultural land, either in the form of one parcel or numerous adjoining parcels totaling 10-acres or more in size, a biological survey shall be prepared to mitigate potential impacts. The survey must be prepared in accordance with United States Fish and Wildlife Service (USFWS) and California Department of Fish and Game (CDFG) regulations, or as amended. CONSERVATION AND OPEN SPACE ELEMENT (COSE) COSE Goal 2: The County will preserve the integrity, function, productivity, and long-term viability of environmentally sensitive habitats and plant and animal species. COSE Objective 2.1: Conserve wetlands, fresh water marshes, and riparian vegetation. COSE Objective 2.2: Protect significant fish, wildlife, plant species, and their habitats. COSE Objective 2.3: Protect unique, rare, and endangered plants and animals and their habitats. COSE Objective 2.4: Use the EIR process to identify, conserve and enhance unique vegetation and wildlife resources. Sources: County of Imperial 1993, 2008 Yes Focused biological surveys were conducted at the HR-2 and SmC-2 Project sites for burrowing owls, and a general reconnaissance of the site was conducted for special status species. The surveys were conducted in accordance with USFWS and CDFG regulations. No special status species other than burrowing owls were documented on the HR- 2 and SmCP-2 Project sites. Mitigation measures have been incorporated into the Projects to reduce impacts on Western Burrowing owls and American Badgers to below a level of significance including avoidance, pre-construction surveys and worker training. See response to the LU Agriculture Policy, above. No wetlands or freshwater marshes have been identified on the Project sites; however, there are a few small patches of cattails within the manmade canals. See response to the LU Agriculture Policy, above. See response to the LU Agriculture Policy, above. See response to the LU Agriculture Policy, above. While this Draft EIR analyzes the Projects consistency with the County of Imperial General Plan pursuant to California Environmental Quality Act (CEQA) Guidelines, Section 15125(d), the County of Imperial Planning Commission will determine the Projects consistency with the General Plan. Hudson Ranch Power II and Simbol Calipatria II Final EIR

165 4.4 Biological and Natural Resources IMPACTS AND MITIGATION MEASURES STANDARDS OF SIGNIFICANCE The impact analysis provided below is based on the following CEQA Guidelines, Appendix G. An impact is considered significant if the project would: 1. Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the CDFG or USFWS. 2. Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, and regulations or by the CDFG or USFWS. 3. Have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the CWA (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means. 4. Interfere substantially with the movement of any native resident or migratory fish or wildlife species, or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites. 5. Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance. 6. Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan. ENVIRONMENTAL PROTECTION MEASURES Chapter 3 provides a complete list and description of environmental protection measures (EPMs) that the applicants have incorporated into their respective Projects to avoid or minimize impacts on all resources. The following EPMs are included as part of the proposed HR-2 Project to minimize or avoid biological, natural resource, and water quality impacts: HR-2 EPM BR-1 Bird Flight diverters: Flight diverters will be installed on interconnection lines to limit bird mortality associated with new transmission lines in bird flyways. Flight diverters make transmission lines more visible to birds. HR-2 EPM BR-2: Avoidance of Drainages. Off-site drainages and riparian areas will be avoided to reduce impacts on sensitive habitats. Hudson Ranch Power II and Simbol Calipatria II Final EIR

166 4.4 Biological and Natural Resources HR-2 EPM BR-3: Placement of Facilities. Facilities will be placed on developed/disturbed lands to avoid additional impact on sensitive habitats. HR-2 EPM BR-4: Protection of Fish, Wildlife and Botanical Resources. Direct impacts on wildlife habitat and botanical resources will be minimized by clearing only the area required for site construction. Brush control will be conducted in a manner that will minimize adverse effects on resident wildlife. Fish habitat will be protected through prevention of erosion. HR-2 EPM WQ-4: Stormwater Pond Berm: The storm water pond will be surrounded by a berm to prevent flooding. HR-2 EPM WQ-5: Casing Shallow Portions of Production and Injection Wells: Casing the shallow portions of the production and injection wells will minimize the potential release of both construction-related drilling fluids and production-related geothermal brines to the shallow groundwater aquifer. HR-2 EPM WQ-6: Protective Pipeline Design and Detailed Inspection Routine: Production pipelines will be alloy-clad steel pipe. Injection pipelines will be constructed of concrete-lined carbon steel. Both will be routinely inspected to prevent potential releases. HR-2 EPM WQ-7: Production Wellheads: Piping at each production wellhead will be equipped with remotely operated electrical emergency shutoff valves and manual alloy isolation valves to prevent potential releases. HR-2 EPM WQ-8: Surface and Groundwater Quality Protection: Cemented concentric steel and alloy casing will prevent produced fluids from polluting surface water and groundwater. Only nontoxic, non-hazardous drilling mud will be utilized during drilling operations. HR-2 EPM WQ-9: Surface and Groundwater Quality Protection: Waste drilling mud and drill cuttings will be stored in the lined containment basin. Any runoff from the site will be discharged into the containment basin. HR-2 EPM NOI-1: Prevention of Noise: To abate noise pollution, mufflers will be utilized on engine-driven equipment during both construction and development operations. The following EPMs are included as part of the proposed SmCP-2 Project to minimize or avoid biological and natural resource impacts: SMCP-2 EPM BR-1: Protection of Fish, Wildlife and Botanical Resources. Direct impacts on wildlife habitat and botanical resources will be minimized by clearing only the area required for site construction. Brush control will be conducted in a manner that will minimize adverse effects on resident wildlife. Fish habitat will be protected through prevention of erosion. Baseline Hudson Ranch Power II and Simbol Calipatria II Final EIR

167 4.4 Biological and Natural Resources biological resources and burrowing owl surveys of the areas of potential surface disturbance for the Project were prepared. SMCP-2 EPM BR-2: Placement of Facilities. Facilities will be placed on developed/disturbed lands to avoid additional impact on sensitive habitats. SMCP-2 EPM BR-3: Avoidance of Drainages. Drainages and riparian areas will be avoided wherever practicable to reduce impacts on sensitive habitats. SMCP-2 EPM WQ-3: Stormwater Retention Basin. The plant site will be graded to direct uncontained surface water runoff toward a storm water retention basin. SMCP-2 EPM WQ-4: Stormwater Retention Basin Berm. The storm water retention basin will be protected by a berm to prevent off-site flooding into the basin. SMCP-2 EPM NOI-1: Prevention of Excessive Noise. The maximum projected noise sources during project construction would be from heavy construction equipment -- projected to be 83 dba at 50 feet. Similarly, the maximum projected noise source during operations would be the cooling tower projected to be 86 dba at 5 feet. To abate noise pollution, mufflers will be utilized on engine-driven equipment during both construction and plant operations. METHODOLOGY This impact assessment is based on the Project description (Chapter 3.0), information described in the existing setting, and the standards of significance described above. Aerial photography was reviewed for potential habitat for the special status species identified from literature and database searches. The CNDDB was queried in 2012 for a list of special status plant and wildlife species that have been documented to occur within 5 miles of the Project site (CNDDB 2012). A database search was performed for special-status species within the Niland, California, USGS 7.5-minute quadrangle (USGS 1957) and the surrounding quadrangles in May Each species was ranked as having either a high, moderate, or low potential to occur. The potential for occurrence ranking was based on the following criteria: High: There is a recent or historical record of the species occurring within the Project site or within 1 mile of the Project site, and the habitat requirements strongly associated with the species occur within the Project site. Moderate: There is a recent or historical record of the species occurring within 1 mile of the Project site, or the habitat requirements associated with the species occur within the Project site. Low: There is no recent or historical record of the species occurring within the Project site or within 1 mile of the Project site, and/or the habitats needed to support the species on the site are of poor quality. Hudson Ranch Power II and Simbol Calipatria II Final EIR

168 4.4 Biological and Natural Resources Locations of special status species occurrences recorded in the CNDDB as being within a 5-mile radius of the Project site are shown on Figure The CNPS electronic online inventory was also searched in May 2011 for rare or endangered plants that may occur within the Project site and in the surrounding vicinity (CNPS 2011). This query was performed for CNPS Lists 1A, 1B, and 2 special status plants: List 1A: Species presumed extinct in California. List 1B: Species considered rare or endangered in California and elsewhere. List 2: Species considered rare or endangered in California, but are more common elsewhere. Table above presents the results of the CNDDB queries for special status species that have the potential to occur within the Project site and surrounding vicinities. In addition, the USFWS/Carlsbad Sensitive Species List, field guides, and personal contacts were utilized to further ascertain the potential for special status species at the Project site. Three biological surveys of vegetation and animals and focused western burrowing owl surveys were completed by Marie Barrett, biologist, and Glenna Westbrook, field assistant, in July 2010, October 2011, and December Additionally, a reconnaissance-level survey was conducted by Jon Goin, Ecology and Environment, Inc. biologist, on April 21, The analysis of impacts on biological resources presented in this section is based on previous biological investigations and reports as well as on available literature and maps from federal, state, and local agencies, the Project description (Chapter 3 of this EIR), existing plans for the proposed HR-2 and SmCP-2 Projects, and the CDFG Staff Reports on Burrowing Owl Mitigation (1995 and 2012), and the standards of significance described above. The assessment includes impacts within the Project sites. A conservative approach to biological resources was used to draft the biological resources analysis. This conservative approach assumed that all natural resources within the Project sites could be removed or otherwise negatively modified by activities allowed under the proposed HR-2 and SmCP-2 Projects design plans, unless otherwise avoided. Project components were considered in order to evaluate and assess potential impacts on biological resources. Construction of the proposed HR-2 and SmCP-2 Projects has the potential to directly or indirectly affect biological resources as well as contribute to cumulative impacts. Potential impacts on biological resources can be temporary, long-term, or permanent, depending on the effect of Projects activities on individual resources. Hudson Ranch Power II and Simbol Calipatria II Final EIR

169 4.4 Biological and Natural Resources HR-2 IMPACTS AND MITIGATION MEASURES Impact BIO-1: Impact BIO-1a: MM BIO 1.1-1: Implementation of the HR-2 Project could result in the loss of individuals or essential habitat for the western burrowing owl, a California species of special concern, and the American badger, a California species of special concern. It would not result in the loss of individuals or essential habitat for the desert pupfish, a federally listed and state-listed endangered species, nor would it result in a substantial loss of foraging habitat for the merlin, a California species of special concern. Western Burrowing Owl: The HR-2 Project site supports nesting and foraging habitat for the western burrowing owl. Twenty-two individuals and 17 active burrows were found in the HR-2 and SmCP-2 Project sites and buffer area (Table 4.4-2), (Figure 4.4-2) and 16 individuals and 13 active burrows were found in the McDonald Road Paving area and buffer (Figure 4.4-3) during the surveys. A total of 38 individuals and 30 active burrows were found during the three surveys. If nesting owls are present within 250 feet of a work site during ground-disturbing construction activities, construction noise could result in nest abandonment. These impacts would be considered potentially significant. Avoidance of Occupied Burrows Occupied burrows shall not be disturbed during the nesting season (February 1 through August 31) unless a qualified biologist approved by CDFG verifies through non-invasive methods that either: (1) the birds have not begun egglaying and incubation; or (2) that juveniles from the occupied burrows are foraging independently and are capable of independent survival. If occupied burrows are to be impacted by project-related activities, additional mitigation measures shall be applied (Mitigation Measures BIO through 1.1-5). Timing/Implementation: Prior to and during construction. Enforcement/Monitoring: County of Imperial Planning and Development Services Department and CDFG. MM BIO 1.1-2: Pre-Construction Surveys Pre-construction surveys shall be conducted to identify any burrowing owls present on-site prior to ground-disturbing activities. All occupied burrows identified on-site shall be flagged for passive relocation (MM BIO 1.1-5). A preconstruction survey is valid for 30 days. If ground disturbing activities do not commence within 30 days of the completion of the burrowing owl survey, an additional survey may be required. Hudson Ranch Power II and Simbol Calipatria II Final EIR

170 4.4 Biological and Natural Resources Timing/Implementation: Prior to construction. Enforcement/Monitoring: County of Imperial Planning and Development Services Department and CDFG. MM BIO1.1-3: Preparation of a Burrowing Owl Mitigation Plan If pre-construction surveys determine that burrowing owls are on-site, a burrowing owl mitigation plan shall be prepared by a qualified biologist describing recommended site specific shelter-in-place measures, worker training, and/or other measures to ensure that project construction does not result in adverse impacts to the burrowing owl. Timing/Implementation: Prior to construction. Enforcement/Monitoring: County of Imperial Planning and Development Services Department and CDFG. MM BIO 1.1-4: Activities During Nesting Season All occupied burrows identified off-site within 160 feet of construction activities outside of nesting season (September through January) and within 250 feet of construction activities during nesting season (February 1 through August 31) shall be buffered by hay bales, fencing (e.g. sheltering in place) or as directed by a qualified biologist and the CDFGCDFG.. Timing/Implementation: During construction. Enforcement/Monitoring: County of Imperial Planning and Development Services Department and CDFG. MM BIO 1.1-5: Passive Relocation Techniques Owls present on the construction site (as identified during pre-construction surveys MM BIO 1.1-2) shall be moved away from the disturbance area using passive relocation techniques. Prior to commencement of relocation, a management plan shall be prepared and approved by CDFG. Relocation shall be completed between September 1 and January 31 (outside of breeding season). If it is not possible to complete relocation during this time period, refer to Mitigation Measure A minimum of one or more weeks is required to relocate the owls and allow them to acclimate to alternate burrows. Passive relocation techniques will follow Hudson Ranch Power II and Simbol Calipatria II Final EIR

171 4.4 Biological and Natural Resources the CDFG Staff Report on Burrowing Owl Mitigation Guidelines (2012CDFG 2012b.) and include the following measures: Passive relocation will be conducted during the non-breeding season. Artificial burrows must be established within 100m of original burrow and adjacent foraging habitat surrounding the artificial burrow must be suitable and protected. Install one-way doors in burrow opening to temporarily or permanently evict burrowing owls and prevent burrow re-occupation. Leave doors in place for 48 hours to ensure owls have left the burrow. Allow one or more weeks for owls to acclimate to off-site burrows (refer to Mitigation Measure below). Daily monitoring shall be required for the passive relocation period. Once owls have relocated off-site, collapse existing burrows to prevent reoccupation. Prior to burrow excavation, flexible plastic pipe shall be inserted into the tunnels to allow escape of any remaining owls during excavation. Excavation shall be conducted by hand whenever possible. Photographs of the excavation and closure of the burrow will be taken to demonstrate success and sufficiency. Impacted site will continually be made inhospitable to burrowing owls and fossorial mammals until construction is complete. Destruction of burrows shall occur only pursuant to a management plan approved by CDFG. Burrowing owls should not be excluded from burrows until: a Burrowing Owl Exclusion Plan is developed by a qualified biologist and approved by DFG; the permanent loss of burrow(s) and habitat is mitigated; site monitoring is conducted prior to, during, and after excavation to ensure take is avoided; and excluded burrowing owls are documented using artificial or natural burrows on an adjoining mitigation site. Timing/Implementation: Prior to construction. Enforcement/Monitoring: County of Imperial Planning and Development Services Department and CDFG. Hudson Ranch Power II and Simbol Calipatria II Final EIR

172 4.4 Biological and Natural Resources MM BIO 1.1-6: Worker Training Training for all construction personnel shall be conducted prior to the commencement of ground disturbing activities. Training shall include: (1) description of burrowing owl; (2) biology; (3) regulations (CDFG/USFWS); (4) contact information and standard operating procedure for when an owl is identified on-site by construction personnel. All construction personnel shall have access to this information in a printed form (e.g. brochure or flyer posted in construction trailers, informational wallet card distributed to construction personnel, or other form). Timing/Implementation: Prior to construction. Enforcement/Monitoring: County of Imperial Planning and Development Services Department and CDFG. MM BIO 1.1-7: Mitigation Plan for Burrows Destruction of occupied burrows shall be mitigated through enhancement of existing unsuitable burrows (through enlargement or debris clearing) or creation of new burrows (by installation of artificial burrows) at a ratio of 2:1 on protected lands (mitigation lands). Prior to the destruction of burrows and/or the passive relocation of owls (Mitigation Measure 1.1-5), a MMRP shall be created and approved by the CDFG. The MMRP shall include: A specific site (mitigation lands) where owl burrows will be created and/or enhanced which is a minimum of 50 meters from the impacted area. A minimum of 6.5 acres of foraging habitat per displaced owl or pair of owls to be conserved in conjunction with the creation and enhancement of burrows. A conservation easement or other protection for the mitigation lands which will ensure that the created burrows, foraging habitat (and their associated owl population) will be conserved in-perpetuity Specific success criteria and management directives to ensure the Hudson Ranch Power II and Simbol Calipatria II Final EIR

173 4.4 Biological and Natural Resources success of the burrow creation and enhancement (Example: 40% occupancy by passively relocated burrowing owls). Compatibility with any passive relocation plan (See Mitigation Measure 1.1-5) approved by the wildlife agencies. Annual reporting requirements. Timing/Implementation: Prior to construction. Enforcement/Monitoring: County of Imperial Planning and Development Services Department and CDFG. Significance after Mitigation: Impact BIO-1b: MM BIO-1.2: Upon implementation of mitigation measures MM BIO through MM BIO and environmental protection measures EPM BR-1 and EPM BR-4 western burrowing owls and their burrows would be avoided or mitigated. Therefore, impacts would be less than significant under this criterion. American Badger: Implementation of the proposed HR-2 Project could result in the loss of individuals or essential habitat for the American badger, a California species of special concern. If burrows are present within 160 feet of a work site during ground-disturbing construction activities, construction noise may result in burrow abandonment. These impacts would be considered potentially significant. Avoidance of American Badger Burrows Any American badger burrows found during pre-construction burrowing owl surveys should be avoided whenever possible. When destruction of occupied burrows is unavoidable, hand-excavation is an option if occupied dens cannot be avoided, but alternatives shall be considered due to potential danger to biologists. Dens shall be hand excavated only before or after the breeding season (February 1 May 30). Any relocation of American badger shall occur only pursuant to a management plan approved by CDFG. Timing/Implementation: During construction and operation. Enforcement/Monitoring: County of Imperial Planning and Development Services Department. Significance after Mitigation: Upon implementation of mitigation measure MM BIO-1.2 and environmental protection measures EPM BR-4 and EPM NOI-1, impacts on the American badger Hudson Ranch Power II and Simbol Calipatria II Final EIR

174 4.4 Biological and Natural Resources would be less than significant because the burrows of American badgers, if present, would be avoided or the badgers would be passively relocated off the construction site. Impact BIO-1c: Desert Pupfish: Implementation of the proposed HR-2 Project would not result in the loss of individuals or essential habitat for desert pupfish, a federally listed and state-listed endangered species. Desert pupfish are known to occur within the lower-most reaches of several drains directly connected (i.e., not pumped) to the south Salton Sea (IID 2008). There are no pupfish near the Project site; the nearest known occurrence of this species is an observation 1.5 miles from the Project site; this was recorded in 2006 (CNDDB 2012) (Figure 4.4-1). The proposed HR-2 Project would require an average of 50,000 gallons of water per day for well drilling and construction and up to 1,200 acre-feet per year (AFY) during operations; the water would be obtained from the IID O lateral canal. The total average annual irrigated acreage (approx. 520,000 acres) of the Imperial unit uses 5.25 AFY of water per acre, which equals 2,730,000 AFY water. The water use from the HR-2 Project would be.04% (1200 AFY / 2,730,000 AFY x100 =.04%). The water use would not significantly reduce the amount of field drainage and return flow of water to the Salton Sea through the N and O drains. Therefore, no impacts to desert pupfish would occur under this criterion. Mitigation Measures: Impact BIO-1d: Mitigation Measures: None required. Merlin: Implementation of the HR-2 Project would not result in a substantial loss of foraging habitat for the merlin, a California species of special concern. This species has been documented within four miles of the Project site and often migrates and forages over large areas. However, merlin are an infrequent species in desert areas, and the 52 acres of the Project site that would be temporarily converted from agricultural land and developed with the HR-2 geothermal power plant facilities represent a fraction of available foraging habitat in the region. Moreover, approximately 145 acres of the Project site will remain undisturbed and suitable for foraging by the merlin, however infrequently. With implementation of environmental protection measures HR-2 EPM BR-1, HR-2 EPM BR-4, and HR-2 EPM NOI-1, this impact is considered less than significant. None required. Hudson Ranch Power II and Simbol Calipatria II Final EIR

175 4.4 Biological and Natural Resources Impact BIO-2: Implementation of the HR-2 Project would not result in a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, and regulations or by the CDFG or USFWS. During construction, off-site drainages and riparian areas would be avoided to prevent impacting sensitive habitats. Upon implementation of HR-2 EPMs BR-2, BR-4, HAZ-3, WQ-1 through WQ-4, WQ-8, and WQ-9, there would be no impact. Mitigation Measures: Impact BIO-3: Mitigation Measures: Impact BIO-4: None required. Implementation of the HR-2 Project would not result in a substantial adverse effect on federally protected wetlands as defined by Section 404 of the CWA (including but not limited to marsh, vernal pool, and coastal wet lands) through direct removal, filling, hydrological interruption, or other means. No wetlands or freshwater marshes have been identified on the project site. Manmade canals are not considered wetlands because wetland hydrology would no longer exist if irrigation were to be terminated (U.S. Army Corps of Engineers [USACE] 1987). Upon implementation of environmental protection measures HR-2 EPM s BR-2, BR-3, HAZ-3, WQ-1, WQ-2, WQ-4, WQ-8, and WQ-9, there would be no impact. None required. Implementation of the HR-2 Project would not substantially interfere with movement of any native fish or wildlife species or with established native resident or migratory wildlife corridors or impede the use of native wildlife nursery sites. Wildlife corridors are narrow strips of habitat linking larger habitats that would otherwise be separated by human or natural barriers such as roads, developed areas, mountains, unsuitable habitats, and water bodies. Wildlife corridors include tracts connecting habitats used by the same population of a species during different seasons as well as tracts that allow individuals to cross between two different populations of a species, thereby enabling genetic exchange between those two populations. Wildlife movement corridors are an important element of resident species home ranges. The Project site is not within an established migratory route for any species, although the lateral canals and drains on the north and south ends of the Project site are used by wildlife as movement corridors. The proposed HR-2 Project would not disrupt the path of these lateral canals and drains and would not block wildlife movement. During Project construction, drainages and riparian areas would be avoided (HR-2 EPM BR-2) and a SWPPP would be implemented. During Project operations stormwater would be collected in a retention basin (HR-2 EPM WQ-3). Hudson Ranch Power II and Simbol Calipatria II Final EIR

176 4.4 Biological and Natural Resources In addition, a berm would prevent off-site flooding into the stormwater retention basin (HR-2 EPM WQ-4). With implementation of HR-2 EPMs BR-1, BR-3, WQ-3 and WQ-4 would protect water quality and reduce accidental release of pollutants that could affect pupfish populations downstream, therefore, this impact is considered less than significant. Mitigation Measures: Impact BIO-5: None required. Implementation of the proposed HR-2 Project would not result in a conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance. There are no adopted tree ordinances or other preservation policies or ordinances for biological resources that would apply to the Project site. Therefore, there would be no impact. Mitigation Measures: Impact BIO-6: None required. Implementation of the proposed HR-2 Project would not conflict with the provisions of an adopted habitat conservation plan, natural community conservation plan, or any adopted biological resources recovery or conservation plan of any federal or state agency. Currently there is no adopted habitat conservation plan, natural community conservation plan, or any other conservation or recovery plan in effect for the Project site, in whole or in part. Therefore, there would be no impact. Mitigation Measures: None required. SMCP-2 IMPACTS AND MITIGATION MEASURES Impact BIO-1: Impact BIO-1a: Implementation of the SmCP-2 Project could result in the loss of individuals or essential habitat for the western burrowing owl, a California species of special concern, and the American badger, a California species of special concern. It would not result in the loss of individuals or essential habitat for the desert pupfish, a federally listed and state-listed endangered species, nor would it result in a substantial loss of foraging habitat for the merlin, a California species of special concern. Western Burrowing Owl: The SmCP-2 Project site supports nesting and foraging habitat for the western burrowing owl. Twenty-two individuals and 17 active burrows were found in the entire HR-2 and SmCP-2 Project site (Table 4.4-2), Hudson Ranch Power II and Simbol Calipatria II Final EIR

177 4.4 Biological and Natural Resources (Figure 4.4-2) and 16 individuals and 13 active burrows were found in the McDonald Road Paving area, (Figure 4.4-3) during the surveys. A total of 38 individuals and 30 active burrows were found during the three surveys. If nesting owls are present within 250 feet of a work site during ground-disturbing construction activities, construction noise could result in nest abandonment. These impacts would be considered potentially significant. MM BIO 1.1-1: Avoidance of Occupied Burrows Occupied burrows shall not be disturbed during the nesting season (February 1 through August 31) unless a qualified biologist approved by CDFG verifies through non-invasive methods that either: (1) the birds have not begun egglaying and incubation; or (2) that juveniles from the occupied burrows are foraging independently and are capable of independent survival. If occupied burrows are to be impacted by Project related activities, additional mitigation measures shall be applied (Mitigation Measures BIO through 1.1-5). Timing/Implementation: Prior to and during construction. Enforcement/Monitoring: County of Imperial Planning and Development Services Department and CDFG. MM BIO 1.1-2: Pre-construction surveys Pre-construction surveys shall be conducted to identify any burrowing owls present on-site prior to ground-disturbing activities. All occupied burrows identified on-site shall be flagged for passive relocation (MM BIO 1.1-5). A preconstruction survey is valid for 30 days. If ground disturbing activities do not commence within 30 days of the completion of the burrowing owl survey, an additional survey may be required. Timing/Implementation: Prior to construction. Enforcement/Monitoring: County of Imperial Planning and Development Services Department and CDFG. MM BIO1.1-3: Preparation of a Burrowing Owl Mitigation Plan If pre-construction surveys determine that burrowing owls are on-site, a burrowing owl mitigation plan shall be prepared by a qualified biologist describing recommended site specific shelter-in-place measures, worker training, and/or other measures to ensure that Project construction does not result in adverse impacts to the burrowing owl. Hudson Ranch Power II and Simbol Calipatria II Final EIR

178 4.4 Biological and Natural Resources Timing/Implementation: Prior to construction. Enforcement/Monitoring: County of Imperial Planning and Development Services Department and CDFG. MM BIO 1.1-4: Activities During Nesting Season All occupied burrows identified off-site within 160 feet of construction activities outside of nesting season (September through January) and 250 feet of construction activities during nesting season (February 1 through August 31) shall be buffered by hay bales, fencing (e.g. sheltering in place) or as directed by a qualified biologist and the wildlife agencies. Timing/Implementation: During construction. Enforcement/Monitoring: County of Imperial Planning and Development Services Department and CDFG. MM BIO 1.1-5: Passive Relocation Techniques Owls present on the construction site (as identified during pre-construction surveys MM BIO 1.1-2) shall be moved away from the disturbance area using passive relocation techniques. Prior to commencement of relocation, a management plan shall be prepared and approved by CDFG. Relocation shall be completed between September 1 and January 31 (outside of breeding season). If it is not possible to complete relocation during this time period, refer to Mitigation Measure A minimum of one or more weeks is required to relocate the owls and allow them to acclimate to alternate burrows. Passive relocation techniques will follow the CDFG Staff Report on Burrowing Owl Mitigation Guidelines (CDFG 2012b.) and include the following measures: Passive relocation will be conducted during the non-breeding season. Artificial burrows must be established within 100m of original burrow and adjacent foraging habitat surrounding the artificial burrow must be suitable and protected. Install one-way doors in burrow opening to temporarily or permanently evict burrowing owls and prevent burrow re-occupation. Leave doors in place for 48 hours to ensure owls have left the burrow. Hudson Ranch Power II and Simbol Calipatria II Final EIR

179 4.4 Biological and Natural Resources Allow one or more weeks for owls to acclimate to off-site burrows (refer to Mitigation Measure below). Daily monitoring shall be required for the passive relocation period. Once owls have relocated off-site, collapse existing burrows to prevent reoccupation. Prior to burrow excavation, flexible plastic pipe shall be inserted into the tunnels to allow escape of any remaining owls during excavation. Excavation shall be conducted by hand whenever possible. Photographs of the excavation and closure of the burrow will be taken to demonstrate success and sufficiency. Impacted site will continually be made inhospitable to burrowing owls and fossorial mammals until construction is complete. Destruction of burrows shall occur only pursuant to a management plan approved by CDFG. Burrowing owls should not be excluded from burrows until: a Burrowing Owl Exclusion Plan is developed by a qualified biologist and approved by DFG; the permanent loss of burrow(s) and habitat is mitigated; site monitoring is conducted prior to, during, and after excavation to ensure take is avoided; and excluded burrowing owls are documented using artificial or natural burrows on an adjoining mitigation site. Timing/Implementation: Prior to construction. Enforcement/Monitoring: County of Imperial Planning and Development Services Department and CDFG. MM BIO 1.1-6: Worker Training Training for all construction personnel shall be conducted prior to the commencement of ground disturbing activities. Training shall include: (1) description of burrowing owl; (2) biology; (3) regulations (CDFG/USFWS); (4) contact information and SOP for when an owl is identified on-site by construction personnel. All construction personnel shall have access to this information in a printed form (e.g. brochure or flyer posted in construction trailers, informational wallet card distributed to construction personnel, or other form). Timing/Implementation: Prior to construction. Enforcement/Monitoring: County of Imperial Planning and Development Services Department and CDFG. Hudson Ranch Power II and Simbol Calipatria II Final EIR

180 4.4 Biological and Natural Resources MM BIO 1.1-7: Mitigation Plan for Burrows Destruction of occupied burrows shall be mitigated through enhancement of existing unsuitable burrows (through enlargement or debris clearing) or creation of new burrows (by installation of artificial burrows) at a ratio of 2:1 on protected lands (mitigation lands). Prior to the destruction of burrows and/or the passive relocation of owls (Mitigation Measure 1.1-5), a MMRP shall be created and approved by the CDFG. The MMRP shall include: A specific site (mitigation lands) where owl burrows will be created and/or enhanced which is a minimum of 50 meters from the impacted area. A minimum of 6.5 acres of foraging habitat per displaced owl or pair of owls to be conserved in conjunction with the creation and enhancement of burrows. A conservation easement or other protection for the mitigation lands which will ensure that the created burrows, foraging habitat (and their associated owl population) will be conserved in-perpetuity Specific success criteria and management directives to ensure the success of the burrow creation and enhancement (Example: 40% occupancy by passively relocated burrowing owls). Compatibility with any passive relocation plan (See Mitigation Measure 1.1-5) approved by the wildlife agencies. Annual reporting requirements. Timing/Implementation: Prior to construction. Enforcement/Monitoring: County of Imperial Planning and Development Services Significance after Mitigation: Impact BIO-1b: Upon implementation of SmCP-2 mitigation measures MM BIO through MM BIO and EPMs BR-1 and BR-3, western burrowing owls and their burrows would be avoided or mitigated. Therefore, impacts would be less than significant under this criterion. American Badger: Implementation of the SmCP-2 Project could result in the loss of individuals or essential habitat for the American badger, a California species of special concern. If burrows are present within 160 feet of a work site during Hudson Ranch Power II and Simbol Calipatria II Final EIR

181 4.4 Biological and Natural Resources ground-disturbing construction activities, construction noise may result in burrow abandonment. These impacts would be considered potentially significant. MM BIO-1.2: Avoidance of American Badger Burrows Any American badger burrows found during pre-construction burrowing owl surveys should be avoided whenever possible. When destruction of occupied burrows is unavoidable, hand-excavation is an option if occupied dens cannot be avoided, but alternatives shall be considered due to potential danger to biologists. Dens shall be hand excavated only before or after the breeding season (February 1 May 30). Any relocation of American badger shall occur only pursuant to a management plan approved by CDFG. Timing/Implementation: During construction and operation. Enforcement/Monitoring: County of Imperial Planning and Development Services Department. Significance after Mitigation: Impact BIO-1c: Upon implementation of mitigation measure MM BIO-1.2 and environmental protection measures SmCP-2 EPMs BR-1 and NOI-1, impacts on the American badger would be less than significant because the burrows of American badgers, if present, would be avoided or the badgers would be passively relocated off the construction site. Desert Pupfish: Implementation of the SmCP-2 Project would not result in the loss of individuals or essential habitat for desert pupfish, a federally listed and statelisted endangered species. Desert pupfish are known to occur within the lower-most reaches of several drains directly connected (i.e., not pumped) to the south Salton Sea (IID 2008). There are no pupfish near the Project site; the nearest known occurrence of this species is an observation 1.5 miles from the Project site; this was recorded in 2006 (CNDDB 2012) (Figure 4.4-1). The proposed SmCP-2 Project would require an average of 50,000 gallons of water per day for construction and up to 800 acre-feet per year (AFY) during operations; the water would be obtained from the IID O lateral canal. The total average annual irrigated acreage (approx. 520,000 acres) of the Imperial unit uses 5.25 AFY of water per acre, which equals 2,730,000 AFY water. The water use from the SmCP-2 Project would be.02% (800 AFY / 2,730,000 AFY x100 =.03%). Hudson Ranch Power II and Simbol Calipatria II Final EIR

182 4.4 Biological and Natural Resources The water use would not significantly reduce the amount of field drainage and return flow of water to the Salton Sea through the N and O drains. Therefore, no impacts to desert pupfish would occur under this criterion. Mitigation Measures: Impact BIO-1d: None required. Merlin: Implementation of the SmCP-2 Project would not result in the loss of foraging habitat for the merlin, a California species of special concern. This species has been documented within four miles of the Project site and often migrates and forages over large areas. However, merlin are an infrequent species in desert areas and the 48 acres of the Project site that would be temporarily converted from agricultural land and developed with SmCP-2 facilities represent a fraction of available foraging habitat in the region. Moreover, approximately 145 acres of the Project site will remain undisturbed and suitable for foraging by the merlin, however infrequently. With the implementation of SmCP-2 EPMs BR-1 and BR-2 and EPM NOI-1,, this impact is considered less than significant. Mitigation Measures: Impact BIO-2: None required. Implementation of the SmCP-2 Project would not result in a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, and regulations or by the CDFG or USFWS. During construction, off-site drainages and riparian areas would be avoided to prevent impacting sensitive habitats. Upon the implementation of EPMs BR-1 through BR-3, EPM GEO-1, EPM UTIL-1, EPM WQ-1 through WQ-4, there would be no impact. Mitigation Measures: Impact BIO-3: Mitigation Measures: None required. Implementation of the SmCP-2 Project would not result in a substantial adverse effect on federally protected wetlands as defined by Section 404 of the CWA (including but not limited to marsh, vernal pool, and coastal wetlands) through direct removal, filling, hydrological interruption, or other means. No wetlands or freshwater marshes have been identified on the project site. Manmade canals are not considered wetlands because wetland hydrology would no longer exist if irrigation were to be terminated (U.S. Army Corps of Engineers [USACE] 1987). Upon the implementation of EPMs BR-1 through BR-3, GEO-1, UTIL-1, WQ-1 through WQ-4, there would be no impact. None required. Hudson Ranch Power II and Simbol Calipatria II Final EIR

183 4.4 Biological and Natural Resources Impact BIO-4: Implementation of the SmCP-2 Project site could substantially interfere with movement of any native fish or wildlife species or with established native resident or migratory wildlife corridors or impede the use of native wildlife nursery sites. Wildlife corridors are narrow strips of habitat linking larger habitats that would otherwise be separated by human or natural barriers such as roads, developed areas, mountains, unsuitable habitats, and water bodies. Wildlife corridors include tracts connecting habitats used by the same population of a species during different seasons as well as tracts that allow individuals to cross between two different populations of a species, thereby enabling genetic exchange between those two populations. Wildlife movement corridors are an important element of resident species home ranges. The Project site is not within an established migratory route for any species, although the lateral canals and drains on the north and south ends of the Project site are used by wildlife as movement corridors. The proposed HR-2 Project would not disrupt the path of these lateral canals and drains and would not block wildlife movement. During Project construction, drainages and riparian areas would be avoided (SmCP-2 EPM BR-3) and a SWPPP would be implemented. During Project operations water retention basin would collect stormwater (SmCP-2 EPM WQ- 3). In addition, a berm would prevent off-site flooding into the stormwater retention basin (SmCP-2 EPM WQ-4). With implementation of environmental protection measures SmCP-2 EPMs BR-1, BR-3, WQ-3 and WQ-4 would protect water quality and reduce accidental release of pollutants that could affect pupfish populations downstream, therefore, this impact is considered less than significant. Mitigation Measures: Impact BIO-5: None required. Implementation of the proposed SmCP-2 Project would not result in a conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance. There are no adopted tree ordinances or other preservation policies or ordinances for biological resources that would apply to the Project site. Therefore, there would be no impact. Mitigation Measures: None required. Hudson Ranch Power II and Simbol Calipatria II Final EIR

184 4.4 Biological and Natural Resources Impact BIO-6: Implementation of the proposed SmCP-2 Project would not conflict with the provisions of an adopted habitat conservation plan, natural community conservation plan, or any adopted biological resources recovery or conservation plan of any federal or state agency. Currently there is no adopted habitat conservation plan, natural community conservation plan, or any other conservation or recovery plan in effect for the Project site, in whole or in part. Therefore, there would be no impact. Mitigation Measures: None required REFERENCES Barrett Biological Surveys (Barrett). 2011a. Biological Resources Technical Report, Hudson Ranch 2 Southern 80 Acres, County of Imperial, California. December b. Biological Resources Technical Report, McDonald Road Paving (Hwy 111 to English Road), County of Imperial, California. Hudson Ranch Power II LLC Geothermal Project. October Biological Resources Technical Report, Hudson Ranch Power II LLC Geothermal Project, County of Imperial, California. July California Department of Fish and Game (CDFG). 2012a. California Wildlife Habitat Relationships (CWHR) CDFG Accounts and Range Maps. Available online: Accessed May 1, b. CDFG Staff Report on Burrowing Owl Mitigation Guidelines. March 7. Available online: Accessed May 11, CaliforniaHerps.com A Guide to Reptiles and Amphibians of California. Available online: Accessed May 25, California Native Plant Society (CNPS) Inventory of Rare and Endangered Plants (online edition, v8-01a). California Native Plant Society. Sacramento, CA. Available online: Accessed May 27, California Natural Diversity Database (CNDDB) Rare Find 4. Available online: Accessed May 1, County of Imperial County of Imperial General Plan Land Use Element. El Centro, California. Hudson Ranch Power II and Simbol Calipatria II Final EIR

185 4.4 Biological and Natural Resources County of Imperial General Plan Conservation and Open Space Element. El Centro, California. Imperial Irrigation District (IID) Draft Supplement to the IID Water Conservation and Transfer Project EIR/EIS for the Managed Marsh Complex Prepared for Imperial Irrigation District. January. Roberts, Carol United States Fish and Wildlife Service, Division Chief of Coachella and Imperial Valleys for the Carlsbad Office, April 28, Sutton, R The Desert Pupfish of the Salton Sea: A Synthesis. Prepared for the Salton Sea Authority, La Quinta, California by the Bureau of Land Reclamation, Denver, Colorado. United States Army Corps of Engineers (USACE) Technical Report Y-87-1: Corps of Engineers Wetlands Delineation Manual. Environmental Laboratory, Department of the Army, Waterways Experiment Station, Corps of Engineers, Vicksburg, Mississippi. January 1987 Final Report. United States Fish and Wildlife Service (USFWS) Endangered Species Program. Available online: Accessed May 27, Federal Laws that Protect Bald Eagles. Bald and Golden Eagle Protection Act. Available online: Accessed May 27, Endangered and threatened wildlife and plants: The razorback sucker,(xyrauchen texanus). Determined to be an endangered species. Federal Register 56(205): United States Forest Service (USFS) Ecological Subregions of California Section and Subsection Descriptions, Colorado Desert Region. Available online: Accessed May 6, Western Regional Climate Center (WRCC) Brawley 2 SW. Available online: Accessed May 6, Hudson Ranch Power II and Simbol Calipatria II Final EIR

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187 4.5 Cultural and Paleontological Resources 4.5 CULTURAL AND PALEONTOLOGICAL RESOURCES This section describes the cultural and paleontological resources at the Project sites and general vicinity. Cultural resources include prehistoric and historic archaeological sites, archaeological districts, historic buildings and structures, and isolated occurrences of artifacts. Paleontological resources include vertebrate, invertebrate, and plant fossils. Scoping Issues Addressed During the scoping period for the Projects, two public scoping meetings were conducted and written comments were received regarding concerns about potential impacts on cultural or paleontological resources. Both letters were from the Native American Heritage Commission (NAHC). The NAHC recommends: Early consultation with local tribes in the project area to avoid unanticipated discoveries of cultural resources or burial sites during project excavation activities. Early consultation with culturally affiliated tribes that may have knowledge of the religious and cultural significance of the historic properties in the Area of Potential Effect (APE). A list of interested Native American tribe contacts was included as an attachment to the letter. Contacting the California Historic Resource Information System (CHRIS)/California Office of Historic Preservation for pertinent archaeological data within or near the APE. Avoiding all significant cultural resources that could be affected by the proposed Projects and including in the Environmental Impact Report (EIR), the processes to be followed if archaeological resources or human remains are accidently unearthed during construction of the proposed Projects. Applicant s Reports and Survey Results Information used in preparing this section and in evaluating potential impacts on cultural resources was derived from surveys conducted by ASM Affiliates in August 2010 and in December 2012 (Appendices E-1 and E-2). In addition, a paleontological resources study was prepared by the San Diego Natural History Museum in 2011 (Appendix F). These documents are contained in Volume II (Technical Appendix) of this EIR. Due to the confidential nature of the location of cultural and paleontological resources, information regarding locations of these resources has been removed and is not included in the appendix. Hudson Ranch Power II and Simbol Calipatria II Final EIR

188 4.5 Cultural and Paleontological Resources EXISTING SETTING REGIONAL SETTING The HR-2 and SmCP-2 Project sites are located in the Salton Trough physiographic province and are underlain by geologic units composed of quaternary lake deposits of ancient Lake Cahuilla. These lakebed deposits have yielded paleontological fossils of freshwater shell beds, fish, seeds, pollen, diatoms, foraminifera, sponges, and wood from numerous localities in Imperial Valley. Vertebrate fossils such as birds, horses, bighorn sheep and reptiles also have been recovered from the area. The consequence of the area s rich paleontological resources is high paleontological sensitivity of the Project site (Demere and Ekdale 2011). Much of the ground surface of the western portion of the Salton Trough in Imperial County is covered by a veneer of recent sediments varying in thickness from 0 to 20 feet. These sediments include eolian sand, as found in active sand dunes, and alluvial sand and gravel. These sediments are thought to be entirely of Holocene age and, while not considered sensitive for fossils (Demere and Ekdale 2011), may contain cultural resources. The prehistoric era for Imperial Valley was influenced by the oscillating cycle of infilling and shrinking of ancient Lake Cahuilla, a large lake that once filled much of the valley. The lake was formed from overflow of the Colorado River as silt built up in the southern Colorado River delta and created a dam that blocked the regular draining of the river. The lake was re-filled through similar processes a number of times during the Holocene, with the water level dropping via evaporation after infilling episodes. Prehistoric human populations were drawn to the shores of the lake, and many prehistoric archaeological sites in the region can be attributed to the maximum lake level and receding shorelines. Approximately 5 miles southwest of the Project area is Obsidian Butte, a Quaternary period volcanic formation. This formation became a regionally important prehistoric resource for the manufacture of flaked stone tools. Obsidian Butte and the shorelines of ancient Lake Cahuilla have influenced the archaeology of the Project site area. The Colorado Desert has a documented cultural history that spans more than 12,000 years. This cultural history is divided into five major periods: PaleoIndian (San Dieguito) (12,000 to 7,000 before present [B.P.]). Archaic (Pinto and Amargosa) (7,000 to 1,500 B.P.). Late Prehistoric (Patayan) (1,500 to 300 B.P.). Ethnohistoric Tipai (Kumeyaay) and Cahuilla (300 B.P. to present). Historic Euro-American (300 B.P. to present). Hudson Ranch Power II and Simbol Calipatria II Final EIR

189 4.5 Cultural and Paleontological Resources PaleoIndian Although the PaleoIndian period has been documented in adjacent areas such as San Diego County, the Mojave Desert, and Baja California, there is no local evidence for a PaleoIndian occupation in the Imperial Valley. It is commonly accepted that the Colorado Desert areas must have also witnessed human occupation during this time; however, physical evidence of this has been elusive (Laylander 2010). Archaic Traces of Archaic period occupation are found in the Imperial Valley in the form of diagnostic projectile points. It has been speculated that some of the non-ceramic-bearing sites that do not have diagnostic lithic artifacts may represent Archaic occupation; however, this has not been substantiated with empirical evidence. The largest number of sites that have been recorded date to the Late Prehistoric and Ethnohistoric periods (Laylander 2010). Late Prehistoric Most of the Late Prehistoric and Ethnohistoric period sites appear to be associated with the maximum stands of ancient Lake Cahuilla. The lake was more than 100 miles long, 35 miles wide, and more than 300 feet deep. The height of the Colorado River delta that formed a natural dam at the south end of the lake determined the maximum shoreline of Lake Cahuilla and created a variety of wetland habitats that may have attracted Native Americans from the surrounding areas to fish, hunt migratory waterfowl, and gather marsh plants such as cattail and bulrush roots. Eventually, siltation on the north side of the Colorado River Delta enabled the river to reestablish a route back to the Gulf of California. Each time this happened, Lake Cahuilla receded from the maximum shoreline to the bottom of the Salton Trough at elevations lower than 200 feet below sea level. After each infilling, Native Americans likely followed the receding shoreline to establish temporary fish camps and to use the emerging vegetation that colonized the drying lake bed. Some Archaic period Lake Cahuilla human occupation is known, but most archaeological sites date to the last four phases of Lake Cahuilla infilling that occurred during the past 1,000 years. The final phase of inundation and recession occurred at the transition from the Late Prehistoric to the Ethnohistoric period between A.D and 1700 (Laylander 1997; Shaefer 1994). Ethnohistoric The ethnographic pattern refers to a culture as it was observed during the historic period, primarily during the first half of the twentieth century, or to traditional culture as remembered during that period. During the Ethnohistoric period, the Imperial Valley was used by the Kumeyaay (Kamia, Tipai), the Cahuilla, Quechan, and the Halchidhoma. The Kumeyaay were the most notable presence in the Project area. Hudson Ranch Power II and Simbol Calipatria II Final EIR

190 4.5 Cultural and Paleontological Resources The desert manifestation of the Kumeyaay group is seen as the Kamia. The Kamia are the focus of this discussion because of their specific adaptation to the wetlands of the Colorado River Valley and the prominence of ancient Lake Cahuilla in the Kamia origin myth. This adaptation is likely analogous to the Lake Cahuilla archaeological land-use patterns of the Imperial Valley. The home base of the Kamia included areas along the New and Alamo rivers as well as springs and walk-in wells in the Imperial Valley. During the Ethnohistoric period, the Kamia were politically and militarily allied with the Quechan-Mohave alliance in opposition to the Cocopah and Halchidhoma (Laylander 2010). The built environment of the Kamia included rectangular semi-subterranean structures of post-and-beam construction with thatch and earthen roofs. They also built ramadas, lean-tos, and conical sweat houses. House pits lined with sandstone slabs may represent individual household units. The Kamia built their dwellings some distance apart, on or adjacent to arable alluvial terraces and as close as possible to running water, wells, or sloughs. There were no permanent villages, and residential moves depended on the availability of floodwater farming areas and the seasonal ripening of wild plants (Laylander 2010). The Kamia practiced a mixed economy of horticulture and hunting and gathering. Mesquite (Prosopis pubescens) was the most important wild staple crop, just as with other groups in the Colorado Desert. Acorns were either obtained directly in the Peninsular Ranges or through trade with the Kumeyaay in exchange for cultigens, especially watermelons. The Kamia also procured baked and dried agave cakes from the Kumeyaay but otherwise did not participate in the early spring agave harvest (Laylander 2010). Historic Euro-American The Historic Euro-American period in Imperial Valley begins with the and Anza expeditions. These brought Spanish colonists from Sonora to coastal California via a route across the Colorado Desert at Yuma west to the foot of the Peninsular Ranges, then north and up San Felipe Creek to Borrego Valley, and from there northwest to the coast. The first detailed historic accounts of nearby Native Americans living at San Sebastian Marsh and Borrego Springs were made at this time. The Anza expedition opened what would become a branch of the Southern Immigrant Trail that brought Euro- Americans through the area during the Gold Rush and after (Laylander 2010). Travel and transportation are two major themes of historical development for Imperial Valley. Historic activities in Imperial Valley were minimal but included the U.S. Army Corps of Topographic Engineers scientific and topographic survey in 1853 for a proposed transcontinental railroad route. The U.S. General Land Office conducted surveys in 1856 that recorded the locations of several historic trails. The Southern Pacific Railroad line was constructed in 1877, and in the early twentieth century, State Route 111 was constructed near the Project site (Laylander 2010). One of the surveyors who worked on the topographic survey, William Blake, recognized the fertility of the Salton Basin. In 1853, Blake proposed diverting Colorado River water into Imperial Valley for irrigation. During Blake s survey of the area, he observed that the Colorado River had flooded the Salton Trough through the New and Alamo rivers in the past. Construction of the Imperial Canal began in August 1900, Hudson Ranch Power II and Simbol Calipatria II Final EIR

191 4.5 Cultural and Paleontological Resources and construction of the Central Main Canal began in By 1903, more than 100,000 acres of Imperial Valley were irrigated. Construction of various canals and drains progressed through time. These canals and drains are still in active use today and are the impetus for the agricultural success of Imperial Valley. The East Highland Canal was completed in 1914 and the Coachella Canal was completed by These features shaped the modern-day economy in the Imperial Valley. Water shortages in Imperial Valley were prevalent from 1902 through 1904 due to silting of the main intake canal. To overcome the silting problems, the California Development Company excavated a new channel without constructing a head gate to control the flow of water. In 1905, winter flooding caused the Colorado River to break its banks, overflowing through the New and Alamo River channels, flooding the Imperial Valley and creating the Salton Sea. The California Development Company declared bankruptcy, a result of litigation arising from the 1905 river break. The residents of Imperial Valley voted in favor of establishing the Imperial Irrigation District (IID) for the purpose of acquiring the rights and properties of the California Development Company and its Mexican subsidiaries. Once established, the IID held more than 570,000 acres of water stock. The IID proceeded to acquire the 13 water companies in Imperial Valley. In 1923 and 1927, one of the early projects the IID undertook was to close the Low Line Canal that was seeping and flooding arable lands in the southeastern end of the Salton Sea. To replace this, irrigation laterals were constructed at half-mile intervals from the newly enlarged East Highline Canal. Transportation was also an important theme in the historical development of Imperial Valley. The Southern Pacific Railroad constructed a rail line across the Salton Basin. Salt mining from salt marsh or beds of dry salt was one of the early industrial uses of Imperial Valley. In 1884, the New Liverpool Salt Company began to commercially extract the pure 6- to 12-inch-thick salt crust. Salt reserves covered more than 1,000 acres at the north end of the Salton Basin. In 1942, the Desert Training Center was opened and included areas of southern California and western Arizona. These areas were targeted for military training exercises during World War II and were under the command of George S. Patton, Jr. The Desert Training Center s purpose was to condition troops to desert warfare conditions and tactics in preparation for the North African Campaign. Project Sites The Project sites were surveyed for paleontological resources on June 22, During the survey, exposures of Lake Cahuilla sediments were observed along the banks of the drain, northeast of the intersection of English Road and Schrimpf Road. Small fossil shells of freshwater snails were observed in these sediments. Records research at the Colorado Desert District Stout Research Center, Anza-Borrego Desert State Park, and the Department of Paleontology, San Diego Natural History Museum revealed that there are no recorded fossil-collecting localities within the Project sites; however, several localities from Lake Cahuilla sedimentary deposits were discovered during construction of the Southern California Gas Line 6914 Loop Imperial Valley Project between Brawley and Calipatria. These documented occurrences, Hudson Ranch Power II and Simbol Calipatria II Final EIR

192 4.5 Cultural and Paleontological Resources as well as those discovered during paleontological monitoring of the State Route 78/111 Brawley Bypass Project, underscore the high paleontological resource potential of the area (Demere and Ekdale 2011). The area in which the Projects would be located consisted of irrigated agricultural land since the early twentieth century (Environmental Management Associates, Inc. 2009). The earliest historic map noted during previous research on the Project site dates to 1943 and clearly shows the IID laterals and drains in place to facilitate agricultural development (Environmental Management Associates, Inc. 2009). A cultural resources field survey of the Project sites on July 20 and 21, 2010 recorded 14 isolated artifacts dating to the historic period, one isolate dating to the prehistoric period, and three historic period sites (see Table 4.5-1). A cultural resources field survey conducted on January found no archaeological sites or isolates in the survey area. TABLE CULTURAL RESOURCES DOCUMENTED WITHIN THE PROJECT SITES RESOURCE NAME PERIOD DESCRIPTION CALIFORNIA REGISTER OF HISTORIC RESOURCES (CRHR) ELIGIBILITY HUD-I-1 Historic Isolate 1 metal disk/blade fragment Not Eligible HUD-I-2 Historic Isolate 1 ceramic whiteware lid sherd Not Eligible HUD-I-3 Historic Isolate - 2 milk glass jar fragments Not Eligible HUD-I-4 Historic Isolate 1 whiteware sherd Not Eligible HUD-I-5 Historic Isolate 1 clear glass fragment and 1 whiteware fragment HUD-I-7 Historic Isolate 1 lip and neck machine-made bottle fragment and one clear with brown tint machine-made whole medicine bottle HUD-I-8 Historic Isolate 1 sanitary can and whole brown machine-made medicine bottle Not Eligible Not Eligible Not Eligible HUD-I-9 Historic Isolate 1 whiteware sherd Not Eligible HUD-I-10 Historic Isolate 1 shaped wooden handle Not Eligible HUD-I-11 Historic Isolate 1 amethyst glass fragment Not Eligible HUD-I-12 Historic Isolate 1 large ceramic porcelain sherd (possible plumbing piece) and 1 roofing shingle HUD-I-13 Historic Isolate 1 metal fragment with a metal bolt and 1 clear glass fragment Not Eligible Not Eligible HUD-I-14 Historic Isolate 2 whiteware fragments Not Eligible HUD-I-15 Prehistoric Isolate 1 large Chione sp. shell Not Eligible Hudson Ranch Power II and Simbol Calipatria II Final EIR

193 4.5 Cultural and Paleontological Resources TABLE CULTURAL RESOURCES DOCUMENTED WITHIN THE PROJECT SITES RESOURCE NAME PERIOD DESCRIPTION CALIFORNIA REGISTER OF HISTORIC RESOURCES (CRHR) ELIGIBILITY HUD-I-18 Historic Isolate 1 sanitary can Not Eligible HUD-1 Historic Site small historic period refuse scatter Not Eligible O Lateral Historic Site approximately 1-mile section of the O lateral canal N Drain Historic Site approximately 0.25-mile section of the N drain Source: Schaefer, Gunderman, and Laylander 2010 Not Eligible Not Eligible The Project sites are bounded by the N Drain and O Lateral which are IID irrigation features. Although these features illustrate the beginnings of the agricultural industry that has shaped Imperial Valley, the N Drain and O Lateral have been found to be ineligible for listing on the California Register of Historic Resources (CRHR) due to modern upgrades. These irrigation features were also recorded as cultural resources during the survey. None of the cultural resources recorded as part of the Project surveys have been found to meet the CRHR eligibility criteria and are not, therefore, historic resources as defined by CEQA REGULATORY SETTING FEDERAL AND STATE There are no applicable federal regulations regarding cultural or paleontological resources. State of California Public Resources Code (PRC) Sections These sections are statutes that pertain to the protection of historical resources (b) and (e). These sections require a landowner on whose property Native American human remains are found to limit further development activity in the vicinity until conferring with the most likely descendants (as identified by the NAHC) to consider treatment options These sections pertain to the establishment and authorities of the NAHC and also prohibit the acquisition or possession of Native American artifacts or human remains taken from a Native American grave or cairn, except in accordance with an agreement reached with the NAHC, and provide for Native American remains and associated grave artifacts to be repatriated These sections establish the Native American Historic Resource Protection Act, which makes it a misdemeanor crime for the unlawful and malicious excavation, removal, or destruction of Native American archaeological or historical sites on public or private lands. Hudson Ranch Power II and Simbol Calipatria II Final EIR

194 4.5 Cultural and Paleontological Resources This section of the California Environmental Quality Act (CEQA) provides for protection of archaeological resources by directing the lead agency on any project undertaken, assisted, or permitted by the state to include in its environmental impact report for the Projects a determination of the Projects effect on unique archaeological resources. It enables a lead agency to require an applicant to make reasonable efforts to preserve or mitigate impacts on any affected unique archaeological resource and sets requirements for an applicant to provide payment to cover the costs of mitigation This section of CEQA establishes that an adverse effect on a historical resource qualifies as a significant effect on the environment Protects paleontological resources from knowing and willful excavation, removal, destruction, injury, and defacement if the resource is on public land or there is public authority jurisdiction Requires reasonable mitigation for impacts on paleontological resources that occur as a result of development. Government Code Sections 6254 (r).this section establishes the California Public Records Act, which protects Native American graves, cemeteries and sacred places maintained by the NAHC by protecting records of such resources from public disclosure , These sections allow city and county legislative bodies to acquire property for the preservation or development of a historic landmark and allow local legislative bodies to enact ordinances to provide special conditions or regulations for the protection or enhancement of places or objects of special historical or aesthetic interest or value This section provides for notices of projects being considered for construction to be sent to California Native American tribes that are on the contact list maintained by the NAHC. Health and Safety Code (HSC) Sections These HSC sections are statutes that pertain to the disturbance and removal of human remains, felony offenses related to human remains, and depositing human remains outside of a cemetery These HSC sections establish the California Native American Grave Protection and Repatriation Act that is consistent with and facilitates implementation of the federal Native American Graves Protection and Repatriation Act. Senate Concurrent Resolutions Number 43 (1996). This resolution requires that all state agencies cooperate with programs of archaeological survey and excavation and preserve known archaeological resources whenever this is reasonable. Hudson Ranch Power II and Simbol Calipatria II Final EIR

195 4.5 Cultural and Paleontological Resources Number 87 (1978). This resolution provides for the identification and protection of traditional Native American resource-gathering sites on state land. California Code of Regulations (CCR), Title 14, Section 1427 This section prohibits any person from collecting or removing any object or thing of archeological or historical interest or value. This section further provides that no person shall injure, disfigure, deface or destroy the physical site, location or context in which the object or thing of archeological or historical interest or value is found. Administrative Code, Title 14, Section 4307 This section states that no person shall remove, injure, deface, or destroy any object of paleontological, archaeological, or historical interest or value. Administrative Code, Title 14, Division 3, Chapter 1, Sections 4307 & 4309 This regulation addresses paleontological resources in two sections. Section 4307 states that no person shall destroy, disturb, mutilate, or remove earth, sand, gravel, oil, minerals, rocks, features of caves, or paleontological features. Section 4309 stipulates that the Department of Parks and Recreation may grant a permit to remove, treat, disturb, or destroy plants or animals or geological, historical, archaeological, or paleontological materials. California Penal Code, Section The California Penal Code, Section 622.5, states Every person, not the owner thereof, who willfully injures, disfigures, or destroys any monument, work of art, or useful or ornamental improvement within the limits of any village, town, or city, or any shade tree or ornamental plant growing therein, whether situated upon private ground or on any street, sidewalk, or public park or place, is guilty of a misdemeanor. California Environmental Quality Act (CEQA) Guidelines CEQA requires that the potential effects of a project on archaeological resources be considered by a lead agency in the environmental evaluation of projects subject to CEQA. If a project may affect an archaeological resource, CEQA requires that the lead agency shall first determine if the archaeological resource is an historical resource. CEQA Guidelines Section (a) defines a historical resource as: A resource listed in, or determined to be eligible by the State Historical Resources Commission, for listing in the California Register of Historical Resources (CRHR). A resource included in a local register of historical resources, as defined in... the Public Resources Code or identified as significant in an historical resource survey meeting the requirements of the Public Resources Code, shall be presumed to be historically or culturally significant. Hudson Ranch Power II and Simbol Calipatria II Final EIR

196 4.5 Cultural and Paleontological Resources Any... building, structure,... site... which a lead agency determines to be historically significant or significant in the... annals of California... provided the lead agency s determination is supported by substantial evidence in light of the whole record. Generally, a resource shall be considered by the lead agency to be historically significant if the resource meets the criteria for listing on the California Register of Historical Resources. Under CEQA Guidelines Section (a)(3), even if a resource is not included on any local, state or federal register, or identified in a qualifying historical resources survey, a lead agency may still determine that a resource is an historical resource for the purposes of CEQA. A lead agency shall consider a resource to be historically significant if it finds that the resource meets the criteria for listing in the CRHR. If a lead agency determines that the archaeological site is an historical resource, CEQA Guidelines, section (b)(3) applies. Public agencies should, whenever feasible, seek to avoid damaging effects on any historical resource of an archaeological nature. (CEQA Guidelines, (b)(3).) Preservation in place is the preferred manner of mitigating impacts to archaeological sites. (CEQA Guidelines, (b)(3)(A).) Preservation in place may be accomplished by planning construction to avoid an archaeological site; incorporating the site within open space; covering the site with soil and developing facilities without foundations (such as tennis courts and parking lots); or deeding the site into a permanent conservation easement. (CEQA Guidelines, (b)(3)(B).) When data recovery through excavation is the only feasible mitigation, a data recovery plan shall be prepared and adopted prior to any excavation being undertaken. (CEQA Guidelines, (b)(3)(C)) Even if an archaeological site does not meet the definition of a historical resource, the lead agency may determine that the resource is a unique archaeological resource. (CEQA Guidelines, (c)(3).) As defined in Public Resources Code Section (g) unique archaeological resource is an archaeological artifact, object, or site about which it can be clearly demonstrated that, without merely adding to the current body of knowledge, there is a high probability that it meets any of the following criteria: 1. Contains information needed to answer important scientific research questions and that there is a demonstrable public interest in that information. 2. Has a special and particular quality such as being the oldest of its type or the best available example of its type. 3. Is directly associated with a scientifically recognized important prehistoric or historic event or person. If a project would cause damage to a unique archaeological resource, the lead agency may require reasonable efforts to be made to permit any or all of these resources to be preserved in place or left in an undisturbed state. Hudson Ranch Power II and Simbol Calipatria II Final EIR

197 4.5 Cultural and Paleontological Resources LOCAL County of Imperial General Plan The County of Imperial General Plan (General Plan) provides goals, objectives, and policies for the identification and protection of significant cultural resources. Specifically, the Conservation and Open Space Element of the General Plan calls for the protection of cultural resources and scientific sites. The General Plan does not specify any requirements for paleontological resources. Paleontological resources, however, are often considered a subcategory of cultural resources. The Conservation and Open Space Element of the General Plan contains requirements for cultural resources that involve the identification and documentation of significant historic and prehistoric resources and the preservation of representative and worthy examples. The Conservation and Open Space Element also recognizes the value of historic and prehistoric resources and the need to assess current and proposed land uses for impacts upon these resources. The County does not have specific guidelines for addressing impacts on paleontological resources but instead relies on standard practices employed in other jurisdictions such as the Bureau of Land Management and/or the County of Riverside. The Bureau of Land Management (BLM), as well as other agencies (e.g., Department of Planning, County of Riverside), employ a three-tiered scale of paleontological resource potential that consists of the following categories: no, low, and high. Table identifies applicable General Plan policies related to cultural resources and addresses the HR-2 and SmCP-2 Projects consistency with these policies. TABLE HR-2 AND SMCP-2 PROJECTS CONSISTENCY WITH SIGNIFICANT CULTURAL RESOURCES GOALS, OBJECTIVES, AND POLICIES OF THE GENERAL PLAN GENERAL PLAN POLICIES CONSISTENCY ANALYSIS CONSERVATION AND OPEN SPACE ELEMENT (COSE) Preservation of Cultural Resources, COSE Goal 3: Important prehistoric and historic resources shall be preserved to advance scientific knowledge and maintain the traditional historic element of the Imperial Valley landscape. COSE Objective 3.1: Protect and preserve sites of archaeological, ecological, historical, and scientific value, and/or cultural significance. Source: County of Imperial 1993 Yes, with mitigation Yes, with mitigation Cultural resources investigations have been conducted for the proposed Project site. The proposed Projects are in compliance with this policy through incorporation of identified mitigation measures. Cultural resources investigations have been conducted for the proposed Project site. The proposed Projects are in compliance with this policy through incorporation of identified mitigation measures. While this Draft EIR analyzes the Projects consistency with the County of Imperial General Plan pursuant to CEQA Guidelines, Section 15125(d), the County of Imperial Planning Commission will determine the Projects consistency with the General Plan. Hudson Ranch Power II and Simbol Calipatria II Final EIR

198 4.5 Cultural and Paleontological Resources IMPACTS AND MITIGATION MEASURES STANDARDS OF SIGNIFICANCE The impact analysis provided below is based on the following CEQA Guidelines, Appendix G. An impact is considered significant if the project would: 1. Cause a substantial adverse change in the significance of a historical resource as defined in Section Cause a substantial adverse change in the significance of an archaeological resource pursuant to Section Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature. 4. Disturb any human remains, including those interred outside of formal cemeteries. ENVIRONMENTAL PROTECTION MEASURES No environmental protection measures (EPMs) have been incorporated into the proposed Projects to minimize or avoid impacts on cultural resources. METHODOLOGY Cultural Resources ASM Affiliates, Inc. performed archival and archaeological survey investigations for the Project sites in 2010 and The archival research did not yield any previously recorded cultural resources within the Project sites or within a half-mile radius of the Project sites. A total of 18 cultural resources were recorded during the walking survey. The cultural resources recorded included three historic period sites, 14 historic period isolates, and one prehistoric period isolate. The location of the Project sites within the recessional shoreline areas of ancient Lake Cahuilla and the location of nearby Obsidian Butte suggest the potential for prehistoric Native American cultural resources, while the history of agricultural development on the Project sites and surrounding area suggest a potential for historic period resources. Both historic and prehistoric resources were the focus of the field surveys. Under CEQA, cultural resources are evaluated against a set of criteria as listed in Section above. Only cultural resources that meet one or more of these criteria are considered to be historic resources for management purposes. A cultural resource that is also considered an historic resource would require preservation and protection from development impacts or mitigation to reduce the impact of a development project to a level that would be considered less than significant. Impacts of the Projects to historic resources are considered below. Hudson Ranch Power II and Simbol Calipatria II Final EIR

199 4.5 Cultural and Paleontological Resources Paleontological Resources By knowing the geology of a particular area and the fossil-yield potential of formations that occur in that area, it is possible to predict where fossils will or will not be encountered. In recognition of the direct relationship between paleontological resources and the geologic formations within which they are found, relevant published and unpublished geologic reports and published and unpublished paleontological reports on the Project area were reviewed. In addition, records were searched through the Colorado Desert District Stout Research Center at Anza-Borrego Desert State Park and the Department of Paleontology at the San Diego Natural History Museum. A walking field survey of the Project sites was conducted on June 22, 2011 by San Diego Natural History Museum personnel to field check the results of the literature and record reviews and to directly evaluate the paleontological resource sensitivity of the geologic units that could be affected by the proposed Projects. This work primarily focused on the northern and southern portions of the Project sites and involved inspection for bedrock outcrops, geologic contacts, and the presence of paleontological resources (i.e., fossils). HR-2 IMPACTS AND MITIGATION MEASURES Impact CUL-1: The HR-2 Project would not result in a substantial adverse change in the significance of a historical resource that is either listed or eligible for listing in the National Register, the California Register or a local register of historic resources. However, the HR-2 Project could impact previously unrecorded prehistoric and historic resources. Ground disturbing activities associated with the proposed Project during construction would have the potential to cause substantial adverse changes to resources that escaped detection on the survey and/or buried prehistoric and historic resources. If such resources are encountered during construction and those resources meet the eligibility criteria of the CRHR, the impact would cause a substantial adverse change in the significance of a historical or archaeological resource. This would be a potentially significant impact to cultural resources. Although no historical resources (resources that meet the criteria for listing on the CRHR) were identified within the boundaries of the proposed Project, it is possible that subsurface historical resources are present that have not yet been identified. Although unlikely, Project-related ground-disturbing activities could uncover previously unknown prehistoric and historic resources within Project boundaries. MM CUL-1.1: Cultural Resources Construction Monitor Hudson Ranch Power II, LLC shall retain the services of a consultant who meets or exceeds the Secretary of the Interior Professional Qualifications Standards as Hudson Ranch Power II and Simbol Calipatria II Final EIR

200 4.5 Cultural and Paleontological Resources an archaeologist. The cultural resources monitor shall be present during all excavation or other earth-moving activities within the Project site in Holocene-aged deposits. The applicant shall immediately notify the Imperial County Planning and Development Services Department if any undocumented and/or buried prehistoric or historic resource is uncovered. All construction must stop in the vicinity of the find until the find can be evaluated for its eligibility for listing in the CRHR. The cultural resources monitor shall have the authority to halt construction activity in the immediate vicinity of the encountered historic resource for a sufficient interval of time to allow avoidance or recovery of the encountered historic resources and shall also have the authority to redirect construction equipment in the event that any cultural resource is inadvertently encountered. All cultural resources are assumed to be eligible for the CRHR until determined otherwise by the monitor. Work will not resume in the area of the discovery until authorized by the monitor. Timing/Implementation: Credentials of the proposed consultant are to be submitted to Imperial County Planning and Development Department prior to issuance of a grading permit and subject to approval by the County. Enforcement/Monitoring: Imperial County Planning and Development Services Department. MM CUL-1.2: Evaluate Significance of Unanticipated Discoveries The cultural resources monitor will evaluate the significance of the unanticipated discovery in conjunction with designated Native American representatives in order to provide proper management recommendations. If testing and evaluation of the site is recommended, the cultural resources consultant will prepare a research design, schedule, and budget for review and approval. During evaluation and testing, the local Native American tribes shall be notified in advance so that a tribal monitor can be present and assist with the work being conducted. At the completion of the monitoring program, the cultural resources consultant will prepare a report that describes the results of the monitoring efforts, the personnel used, the dates of performance, and findings, if any. If cultural resources are recovered, they shall be cleaned, catalogued, analyzed, and curated at an approved repository. Timing/Implementation: Implemented if unanticipated discoveries are found during monitoring. Enforcement/Monitoring: Imperial County Planning and Development Services Department. Hudson Ranch Power II and Simbol Calipatria II Final EIR

201 4.5 Cultural and Paleontological Resources MM CUL-1.3: Native American Construction Monitor The local Native American tribes shall be given the opportunity to provide one or more certified cultural monitors for the Project during all excavation or earthmoving within the Project site in Holocene-aged deposits. The applicant shall give the tribe s Preservation Officer (PO) or other designated representative two weeks notice and shall provide a copy of such notice to the County Planning and Development Services Department. The notice shall include information regarding the scope of the proposed activity and the beginning and ending dates of the activity. The tribe has the authority and discretion to provide one or more monitors as determined necessary by the tribe. Upon arrival at the job site, the tribal monitor(s) shall provide the Project superintendent with a current cultural monitor certification document. The tribal monitor(s) shall fully comply with all safety requirements established by the superintendent for the Project site at all times. Timing/Implementation: The Native American tribe will be notified two weeks prior to commencement of ground disturbing activities. Implemented if human remains are found during monitoring. Enforcement/Monitoring: Imperial County Planning and Development Services Department. MM CUL-1.4: Unanticipated Discoveries Historic Treatment Plan If an unanticipated discovery is found to meet the eligibility criteria for listing on the CRHR, then the resource must either be protected in place and the Project altered to preserve the resource, or data recovery excavations must be conducted to mitigate the impact of the resource. The cultural resources consultant shall prepare a Historic Properties Treatment Plan (HPTP) for submittal to the County of Imperial for approval. The HPTP shall detail how much excavation is required and what excavation methods and other analytical tests would be required to mitigate the impact on the resource if avoidance or preservation in place is not feasible. The HPTP shall provide for reasonable efforts to be made to permit the resource to be preserved in place or left in an undisturbed state. Methods of accomplishing this may include capping or covering the resource with a layer of soil. To the extent that a resource cannot feasibly be preserved in place or not left in an undisturbed state, excavation as mitigation shall be restricted to those parts of resource that would be damaged or destroyed by the Project. Excavation as mitigation shall not be required for a unique archaeological resource if the treatment plan determines that testing or studies already completed have Hudson Ranch Power II and Simbol Calipatria II Final EIR

202 4.5 Cultural and Paleontological Resources adequately recovered the scientifically consequential information from and about the resource. After data recovery excavations are complete, a technical report detailing the results of the excavation and analysis results shall be prepared by the cultural resources consultant. All artifacts and documentation pertaining to the data recovery effort shall be cleaned, catalogued, analyzed, and curated at an approved repository. The HPTP shall require communication and consultation with Native American tribes that attach cultural significance to the Project area with regard to their perspectives and wishes for the treatment of the resources. Timing/Implementation: Implemented if unanticipated discoveries are found during monitoring of ground disturbing activities. Enforcement/Monitoring: Imperial County Planning and Development Services Department. Significance after Mitigation: Impact CUL-2: Implementation of MM CUL-1.1 through MM CUL-1.4 would avoid damaging previously unrecorded historical resources through professional monitoring and avoidance, preservation or data recovery, and therefore would reduce impacts on cultural resources to less than significant. Implementation of the HR-2 Project could result in impacts on previously unrecorded archaeological resources. If these resources meet the eligibility criteria of the CRHR, the impact would cause a substantial adverse change in the significance of an archaeological resource. This would be a potentially significant impact on cultural resources. Although no eligible archaeological resources were identified within the boundaries of the proposed Project, it is possible that subsurface archaeological resources are present that have not yet been identified. Although unlikely, Project-related ground-disturbing activities could uncover previously unknown archaeological resources within Project boundaries. Mitigation Measures: Significance after Mitigation: Impact CUL-3: See mitigation measures MM CUL-1.1 through MM CUL-1.4. If unanticipated archaeological resources are discovered during Project construction, MM CUL-1.1 through MM CUL-1.4 shall be sufficient to reduce the impact to a level that is less than significant. Implementation of the HR-2 Project could result in impacts on a unique paleontological resource or site or a unique geologic feature. This would be a Hudson Ranch Power II and Simbol Calipatria II Final EIR

203 4.5 Cultural and Paleontological Resources potentially significant impact on a paleontological resource or unique geologic feature. Previously undisturbed Lake Cahuilla sediments underlie the entire Project area and contain proven and significant paleontological resources that likely will be negatively impacted by the proposed construction activities associated with the Project. These construction activities include excavation to construct containment basins, access roads, well pads, surface water drainage ditches, and related storm water pollution prevention structures. Although most of the Project site has been tilled, potentially disturbing paleontological remains within the plow zone, disturbance is likely to go below the plow zone in some areas. In addition, drilling operations for the proposed geothermal exploration and production wells would extend to a depth of approximately 9,000 feet and would penetrate not only Lake Cahuilla sediments but also older and more deeply buried geologic deposits with high paleontological resource potential (e.g., Brawley Formation, Borrego Formation, and Imperial Group). Near surface excavation operations typically involve large-scale earthmoving equipment (e.g., bulldozers, scrapers, excavators, and/or back hoes) and generally generate spoil materials that are large enough to contain identifiable fossil remains. In contrast, well-drilling typically involves small-diameter drill bits and generally produce finely pulverized spoils that are often saturated with circulating drilling mud. MM CUL-3.1: Paleontological Construction Monitoring A paleontological mitigation plan shall be prepared by a qualified paleontologist. The paleontological mitigation plan can be implemented before and/or during construction; however, the latter is more common on most construction projects. The paleontological mitigation plan shall include the following elements: A qualified paleontologist shall attend the pre-construction meeting to consult with the grading and excavation contractors concerning excavation schedules, paleontological field techniques, and safety issues. A qualified paleontologist is defined as an individual with an MS or Ph.D. in paleontology or geology that also is familiar with paleontological procedures and techniques, is knowledgeable in the geology and paleontology of the Project area, and has worked as a paleontological mitigation project supervisor in the area for at least one year. Ground-disturbing construction activities shall be monitored by a qualified paleontologist to assess, document, and recover unique fossils. A Hudson Ranch Power II and Simbol Calipatria II Final EIR

204 4.5 Cultural and Paleontological Resources paleontological monitor shall be on-site on a full-time basis during the original cutting of previously undisturbed deposits of high paleontological resource potential (e.g., Lake Cahuilla sediments) to inspect exposures for contained fossils. A paleontological monitor is defined as an individual who has experience in the collection and salvage of fossil materials. The paleontological monitor should work under the direction of a qualified paleontologist. If paleontological resources are discovered during ground-disturbing activities, the qualified paleontologist (or paleontological monitor) shall recover them. In most cases, this fossil salvage can be completed in a short period of time; however, some fossil specimens (such as a complete large mammal skeleton) may require an extended salvage period. In these instances, the paleontologist (or paleontological monitor) shall have the authority to temporarily direct, divert, or halt grading to allow sufficient time for the recovery of fossil remains. Paleontological resources of scientific value shall be identified and curated into an established, accredited, professional museum repository in the region with permanent retrievable paleontological storage. Timing/Implementation: Paleontological Mitigation Plan to be submitted to Imperial County Planning and Development Services for review and approval prior to the issuance of the first grading permit. Enforcement/Monitoring: Hudson Power II LLC. would be responsible for the implementation of this measure. Imperial County Planning and Development Services Department would be responsible for ensuring compliance. Significance after Mitigation: Impact CUL-4: If paleontological resources are discovered during Project construction, implementation of MM CUL-3.1 would reduce the impact to a level that is less than significant by ensuring proper assessment, documentation, and recovery and curation of unique fossils. Implementation of the HR-2 Project could result in impacts on human remains, including those interred outside of formal cemeteries. Ground-disturbing activities could disturb buried human remains. Although no archaeological resources were identified within the boundaries of the proposed Project, it is possible that subsurface human remains are present that have not yet been identified. Although unlikely, Project-related ground-disturbing Hudson Ranch Power II and Simbol Calipatria II Final EIR

205 4.5 Cultural and Paleontological Resources activities could uncover previously unknown human remains within Project boundaries. This would be a potentially significant impact on human remains. MM CUL-4.1: Identification of Human Remains If human remains are encountered, State Health & Safety Code Section and CEQA Guidelines Section (e) state that no further disturbance can occur within the vicinity of the discovery until the county coroner has made a determination of origin and disposition pursuant to PRC Section The cultural resources monitor or construction contractor shall protect discovered human remains remaining in the ground from additional disturbance. The monitor or construction contractor shall immediately notify the county coroner of the find. The county coroner shall determine if the remains are of recent origin and if an investigation of the cause of death is required (Health and Safety Code, ). If the remains are determined to be Native American and historic or prehistoric, the coroner shall notify the NAHC so that a most likely descendent can be identified as required under California Public Resources Code section With the permission of the landowner or his/her authorized representative, the most likely descendent may inspect the site of the discovery. The most likely descendent may recommend scientific removal and nondestructive analysis of human remains and items associated with Native American burials or may simply request that the remains be removed and repatriated in a respectful manner. If the most likely descendent and the land owner cannot reach an agreement on the disposition of the remains, the NAHC may help in negotiations. If the county coroner determines that the human remains are not Native American and not evidence of a crime, Project personnel shall coordinate with a qualified archaeologist(s) to develop an appropriate treatment plan. This may include contacting the next-of-kin to solicit input on subsequent disposition of the remains. If there is no next-of-kin, or recommendations by the next-of-kin are considered unacceptable by the landowner, the landowner will reinter the remains with appropriate dignity in a location outside the Project site and where they would be unlikely to be disturbed in the future. Timing/Implementation: Implemented if human remains are found during monitoring of ground-disturbing activities. Enforcement/Monitoring: Hudson Ranch Power II, LLC and/or landowner would be responsible for the implementation of this measure Imperial County Planning and Development Services Department would be responsible for ensuring compliance. Hudson Ranch Power II and Simbol Calipatria II Final EIR

206 4.5 Cultural and Paleontological Resources Significance after Mitigation: If unanticipated human remains are discovered during Project construction, MM CUL-4.1 shall be sufficient to reduce the impact to a level that is less than significant. SMCP-2 IMPACTS AND MITIGATION MEASURES Impact CUL-1: The SmCP-2 Project would not result in a substantial adverse change in the significance of a historical resource that is either listed or eligible for listing in the National Register, the California Register, or a local register of historic resources. However, the Project could impact previously unrecorded prehistoric and historic resources. Ground disturbing activities associated with the proposed Project during construction would have the potential to cause substantial adverse changes to resources that escaped detection on the survey and/or buried prehistoric and historic resources. If such resources are encountered during construction, those resources meet the eligibility criteria of the CRHR, the impact would cause a substantial adverse change in the significance of a historical or archaeological resource. This would be a potentially significant impact to cultural resources. Although no historical resources that meet the criteria for listing on the CRHR were identified within the boundaries of the proposed Project, it is possible that subsurface historical resources are present that have not yet been identified. Although unlikely, Project-related ground-disturbing activities could uncover previously unknown prehistoric and historic resources within Project boundaries. MM CUL-1.1: Cultural Resources Construction Monitor Simbol, Inc. shall retain the services of a consultant who meets or exceeds the Secretary of the Interior Professional Qualifications Standards as an archaeologist. The cultural resources monitor shall be present during all excavation or other earth-moving activities within the Project site in Holocene-aged deposits. The applicant shall immediately notify the Imperial County Planning and Development Services Department if any undocumented and/or buried prehistoric or historic resource is uncovered. All construction must stop in the vicinity of the find until the find can be evaluated for its eligibility for listing in the CRHR. The cultural resources monitor shall have the authority to halt construction activity in the immediate vicinity of the encountered historic resource for a sufficient interval of time to allow avoidance or recovery of the encountered historic resources and shall also have the authority to redirect construction equipment in the event that any cultural resource is inadvertently encountered. All cultural resources are Hudson Ranch Power II and Simbol Calipatria II Final EIR

207 4.5 Cultural and Paleontological Resources assumed to be eligible for the CRHR until determined otherwise by the monitor. Work will not resume in the area of the discovery until authorized by the monitor. Timing/Implementation: Credentials of the proposed consultant are to be submitted to Imperial County prior to issuance of a grading permit and subject to approval by the County. Enforcement/Monitoring: Imperial County Planning and Development Services Department. MM CUL-1.2: Evaluate Significance of Unanticipated Discoveries The cultural resources monitor will evaluate the significance of the unanticipated discovery in conjunction with designated Native American representatives in order to provide proper management recommendations. If testing and evaluation of the site is recommended, the cultural resources consultant will prepare a research design, schedule, and budget for review and approval. During evaluation and testing, the local Native American tribes shall be notified in advance so that a tribal monitor can be present and assist with the work being conducted. At the completion of the monitoring program, the cultural resources consultant will prepare a report that describes the results of the monitoring efforts, the personnel used, the dates of performance, and findings, if any. If cultural resources are recovered, they shall be cleaned, catalogued, analyzed, and curated at an approved repository. Timing/Implementation: Implemented if unanticipated discoveries are found during monitoring. Enforcement/Monitoring: Imperial County Planning and Development Services Department. MM CUL-1.3: Native American Construction Monitor The local Native American tribes shall be given the opportunity to provide one or more certified cultural monitors for the Project during all excavation or earthmoving within the Project site in Holocene-aged deposits. The applicant shall give the tribe s Preservation Officer (PO) or other designated representative at least 24 hours notice and shall provide a copy of such notice to the County Planning and Development Services Department. The notice shall include information regarding the scope of the proposed activity, the number of monitors proposed, and the beginning and ending dates and times that the monitors will be needed. The tribe Hudson Ranch Power II and Simbol Calipatria II Final EIR

208 4.5 Cultural and Paleontological Resources has the authority and discretion to provide one or more monitors as determined necessary by the tribe. Upon arrival at the job site, the tribal monitor(s) shall provide the Project superintendent with a current cultural monitor certification document. The tribal monitor(s) shall fully comply with all safety requirements established by the superintendent for the Project site at all times. Timing/Implementation: The Native American tribe will be notified two weeks prior to commencement of ground disturbing activities. Enforcement/Monitoring: Imperial County Planning and Development Services Department. MM CUL-1.4: Unanticipated Discoveries Historic Treatment Plan If an unanticipated discovery is found to meet the eligibility criteria for listing on the CRHR, then the resource must either be protected in place and the Project altered to preserve the resource, or data recovery excavations must be conducted to mitigate the impact of the resource. The cultural resources consultant shall prepare a Historic Properties Treatment Plan (HPTP) for submittal to County of Imperial for approval. The HPTP shall detail how much excavation is required and what excavation methods and other analytical tests would be required to mitigate the impact on the resource if avoidance or preservation in place is not feasible. The HPTP shall provide for reasonable efforts to be made to permit the resource to be preserved in place or left in an undisturbed state. Methods of accomplishing this may include capping or covering the resource with a layer of soil. To the extent that resource cannot feasibly be preserved in place or not left in an undisturbed state, excavation as mitigation shall be restricted to those parts of resource that would be damaged or destroyed by the Project. Excavation as mitigation shall not be required for a unique archaeological resource if the treatment plan determines that testing or studies already completed have adequately recovered the scientifically consequential information from and about the resource. After data recovery excavations are complete, a technical report detailing the results of the excavation and analysis results shall be prepared by the cultural resources consultant. All artifacts and documentation pertaining to the data recovery effort shall be cleaned, catalogued, analyzed, and curated at an approved repository. The HPTP shall require communication and consultation with Native American tribes that attach cultural significance to the Project area with regard to their perspectives and wishes for the treatment of the resources. Hudson Ranch Power II and Simbol Calipatria II Final EIR

209 4.5 Cultural and Paleontological Resources Timing/Implementation: Implemented if unanticipated discoveries are found during monitoring. Enforcement/Monitoring: Imperial County Planning and Development Services Department. Significance after Mitigation: Impact CUL-2: Implementation of MM CUL-1.1 through MM CUL-1.4 would avoid damaging previously unrecorded historical resources through professional monitoring and avoidance, preservation or data recovery, and therefore would reduce impacts on cultural resources to less than significant. Implementation of the SmCP-2 Project could result in impacts on previously unrecorded archaeological resources. If these resources meet the eligibility criteria of the CRHR, the impact would cause a substantial adverse change in the significance of an archaeological resource. This would be a potentially significant impact on cultural resources. Although no eligible archaeological resources were identified within the boundaries of the proposed Project, it is possible that subsurface archaeological resources are present that have not yet been identified. Although unlikely, Project-related ground-disturbing activities could uncover previously unknown archaeological resources within Project boundaries. Mitigation Measures: Significance after Mitigation: Impact CUL-3: See mitigation measures MM CUL-1.1 through MM CUL-1.4. If unanticipated archaeological resources are discovered during Project construction, MM CUL-1.1 through MM CUL-1.4 shall be sufficient to reduce the impact to a level that is less than significant. Implementation of the SmCP-2 Project could result in impacts on a unique paleontological resource or site or a unique geologic feature. This would be a potentially significant impact on a paleontological resource or unique geologic feature. Previously undisturbed Lake Cahuilla sediments underlie the entire Project site and contain proven and significant paleontological resources that likely will be negatively impacted by the proposed construction activities associated with the Project. These construction activities include excavation to construct containment basins, access roads, surface water drainage ditches, and related storm water pollution prevention structures. Although most of the Project site has been tilled, Hudson Ranch Power II and Simbol Calipatria II Final EIR

210 4.5 Cultural and Paleontological Resources potentially disturbing paleontological remains within the plow zone, disturbance is likely to go below the plow zone in some areas. Near surface excavation operations typically involve large-scale earthmoving equipment (e.g., bulldozers, scrapers, excavators, and/or back hoes) and generally generate spoil materials that are large enough to contain identifiable fossil remains. MM CUL-3.1: Paleontological Construction Monitoring A paleontological mitigation plan shall be prepared by a qualified paleontologist. The paleontological mitigation plan can be implemented before and/or during construction; however, the latter is more common on most construction projects. The paleontological mitigation plan shall include the following elements: A qualified paleontologist shall attend the pre-construction meeting to consult with the grading and excavation contractors concerning excavation schedules, paleontological field techniques, and safety issues. A qualified paleontologist is defined as an individual with an MS or Ph.D. in paleontology or geology that also is familiar with paleontological procedures and techniques, is knowledgeable in the geology and paleontology of Project area, and has worked as a paleontological mitigation Project supervisor in the area for at least one year. Ground-disturbing construction activities shall be monitored by a qualified paleontologist to assess, document, and recover unique fossils. A paleontological monitor shall be on-site on a full-time basis during the original cutting of previously undisturbed deposits of high paleontological resource potential (e.g., Lake Cahuilla sediments) to inspect exposures for contained fossils. A paleontological monitor is defined as an individual who has experience in the collection and salvage of fossil materials. The paleontological monitor should work under the direction of a qualified paleontologist. If paleontological resources are discovered during ground-disturbing activities, the qualified paleontologist (or paleontological monitor) shall recover them. In most cases, this fossil salvage can be completed in a short period of time; however, some fossil specimens (such as a complete large mammal skeleton) may require an extended salvage period. The paleontological monitor shall have the authority to temporarily direct, divert, or halt grading to allow sufficient time for the recovery of fossil remains. Paleontological resources of scientific value shall be identified and curated into an established, accredited, Hudson Ranch Power II and Simbol Calipatria II Final EIR

211 4.5 Cultural and Paleontological Resources professional museum repository in the region with permanent retrievable paleontological storage. Timing/Implementation: Paleontological Mitigation Plan to be submitted to Imperial County Planning and Development Services for review and approval prior to issuance of the first grading permits. Enforcement/Monitoring: Simbol, Inc. would be responsible for the implementation of this measure. Imperial County Planning and Development Services Department would be responsible for ensuring compliance. Significance after Mitigation: Impact CUL-4: If paleontological resources are discovered during Project construction, implementation of MM CUL-3.1 would reduce the impact to a level that is less than significant by ensuring proper assessment, documentation, and recovery of unique fossils. Implementation of the SmCP-2 Project could result in impacts on human remains, including those interred outside of formal cemeteries. Ground-disturbing activities could disturb buried human remains. Although no archaeological resources were identified within the boundaries of the proposed Project, it is possible that subsurface human remains are present that have not yet been identified. Although unlikely, Project-related ground-disturbing activities could uncover previously unknown human remains within Project boundaries. This would be a potentially significant impact on human remains. MM CUL-4.1: Identification of Human Remains If human remains are encountered, State Health & Safety Code Section and CEQA Guidelines Section (e) state that no further disturbance can occur within the vicinity of the discovery until the county coroner has made a determination of origin and disposition pursuant to PRC Section The cultural resources monitor or construction contractor shall protect discovered human remains remaining in the ground from additional disturbance. The monitor or construction contractor shall immediately notify the county coroner of the find. The county coroner shall determine if the remains are of recent origin and if an investigation of the cause of death is required (Health and Safety Code, ). If the remains are determined to be Native American and historic or prehistoric, the coroner shall notify the NAHC so that a most likely descendent can be identified as required under California Public Resources Code section With the permission of the landowner or his/her authorized representative, the most likely Hudson Ranch Power II and Simbol Calipatria II Final EIR

212 4.5 Cultural and Paleontological Resources descendent may inspect the site of the discovery. The most likely descendent may recommend scientific removal and nondestructive analysis of human remains and items associated with Native American burials or may simply request that the remains be removed and repatriated in a respectful manner. If the most likely descendent and the land owner cannot reach an agreement on the disposition of the remains, the NAHC may help in negotiations. If the county coroner determines that the human remains are not Native American and not evidence of a crime, Project personnel shall coordinate with a qualified archaeologist(s) to develop an appropriate treatment plan. This may include contacting the next-of-kin to solicit input on subsequent disposition of the remains. If there is no next-of-kin, or recommendations by the next-of-kin are considered unacceptable by the landowner, the landowner will reinter the remains with appropriate dignity in a location outside the Project site and where they would be unlikely to be disturbed in the future. Timing/Implementation: Implemented if human remains are found during monitoring of ground-disturbing activities. Enforcement/Monitoring: Simbol Inc., and/or landowner would be responsible for the implementation of this measure. Imperial County Planning and Development Services Department would be responsible for ensuring compliance. Significance after Mitigation: If unanticipated human remains are discovered during Project construction, MM CUL-4.1 shall be sufficient to reduce the impact to a level that is less than significant REFERENCES County of Imperial County of Imperial General Plan Conservation and Open Space Element. Edited by P. a. D. Services. El Centro: Imperial County. Deméré, T.A., and E.G. Ekdale HRII Paleontology Assessment Report San Diego: Department of PaleoServices, San Diego Natural History Museum. Environmental Management Associates, Inc Phase I Environmental Site Assessment Property Area of Interest North 1/2 of Section 19, T11S R14E, SBB&M Imperial County, California. Brea, CA: Environmental Management Associates, Inc. Laylander, D A Class I Cultural Resources Inventory for the West Chocolate Mountains Geothermal Leasing Project, Imperial County, California. Encinitas, CA: ASM Affiliates, Inc. Hudson Ranch Power II and Simbol Calipatria II Final EIR

213 4.5 Cultural and Paleontological Resources The Last Days of Lake Cahuilla: The Elmore Site. Pacific Coast Archaeological Society Quarterly 33 (1-2): Schaefer, J., S. Gunderman, and D. Laylander Cultural Resource Study for the Hudson Ranch II Project, Imperial County, CA. Carlsbad, CA: ASM Affiliates, Inc. Shaefer, J The Challenge of Archaeological Research in the Colorado Desert: Recent Approaches and Discoveries. Journal of California and Great Basin Anthropology 16: Hudson Ranch Power II and Simbol Calipatria II Final EIR

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215 4.6 Geology, Soils, and Mineral Resources 4.6 GEOLOGY, SOILS, AND MINERAL RESOURCES This section describes the geology and soil conditions and mineral resources at the Project sites and the general vicinity. This section also analyzes issues that could occur with implementation of the Project (e.g., exposure of people and property to potential geologic, seismic, and other natural hazards such as earthquakes, liquefaction, soil expansion, landform alteration, and erosion). Scoping Issues Addressed During the scoping period for the Projects, two public scoping meetings were conducted and written comments were received from agencies and the public. No comments related to geology, soils, and mineral resources were received. Applicant s Reports and Survey Results Information used in preparing this section and in the evaluation of potential impacts to geology, soils, and mineral resources was derived from a number of sources, including a geotechnical report for the Hudson Ranch Power II Geothermal Flash Plant prepared on May 9, 2011 (Appendix G-1), a geotechnical report for equipment pad grading prepared by Landmark Consultants Inc. on January 31, 2011 (Appendix G-2), a percolation test report prepared by Landmark Consultants Inc. on January 28, 2011 (Appendix G-3), and These documents are contained in within Volume II (Technical Appendix) of this EIR EXISTING SETTING REGIONAL SETTING The Project sites are located in the Imperial Valley portion of the Salton Trough physiographic province. The Salton Trough is a topographic and geologic structural depression resulting from large-scale regional faulting. The trough is bounded on the northeast by the San Andreas Fault and Chocolate Mountains and on the southwest by the Peninsular Range and faults of the San Jacinto fault zone. Figure depicts the sites location relative to regional faults and physiographic features (Landmark Consultants, Inc. 2011a). The Salton Trough is a broad northwest-trending basin that represents the northward extension of the Gulf of California. The Imperial Valley is located in the southeastern half of the Salton Trough and is bounded by uplifted lacustrine sediments along the San Andreas Fault zone to the north, alluvial fans of the Chocolate Mountains to the east, dunes of the Sand Hills to the south, and the Salton Sea to the west. Tectonic activity that formed the trough continues at a high rate, as evidenced by deformed young sedimentary deposits and high levels of seismicity (Landmark Consultants, Inc. 2011a). The Imperial Valley is directly underlain by lacustrine deposits derived from the periodic flooding of the Colorado River that formed Lake Cahuilla. These deposits are typically less than 100 feet thick, consisting of interbedded, lenticular, and tabular silt, sand, and clay layers. Although modern in age at the surface, Hudson Ranch Power II and Simbol Calipatria II Final EIR

216 4.6 Geology, Soils, and Mineral Resources these lake/playa sediments increase in age with depth and may be late Pleistocene in age (40,000 years or less) (Maloney 1986). According to Van de Kamp (1973), the Lake Cahuilla sediments come from two sources. The first source was the Colorado River, which flowed intermittently into the southern portion of the Salton Trough and deposited sand and mud in deltaic, fluvial, and lacustrine environments. The second source was the sediments derived from the basin. A recent study by Li et al. (2007) dating various layers of calcareous tufa (a carbonate coral-like rock that encrusts boulders in freshwater lakes) at Travertine Rock, near Salton City, found evidence of at least 30 basin filling lakes in the Salton Trough in the last 20,000 years. Evidence of these inundations and subsequent desiccations are chronicled in the sediments of the Lake Cahuilla beds. Older deposits consist of Miocene to Pleistocene non-marine and marine sediments deposited during Gulf of California transgressions onto the continent. Basement rock consisting of Mesozoic granite and Paleozoic metamorphic rocks are estimated to exist at depths between 15,000 and 20,000 feet (Landmark Consultants, Inc. 2011a). Project Sites The Project sites are located in an unincorporated area of County of Imperial, approximately 2.3 miles west-southwest of the Town of Niland, California. It is located within the Salton Sea Known Geothermal Resource Area (KGRA) of the County of Imperial. The Project sites lies at an elevation of approximately 210 feet below mean sea level (MSL) in the Imperial Valley region of the California low desert. The surrounding properties lie on terrain which is flat (planar), part of a large agricultural valley, which was previously an ancient lake bed covered with fresh water to an elevation of 43± feet above MSL. Faults and Seismicity The proposed Project sites are located in the seismically active Salton Trough, near the southern terminus of the San Andreas Fault system and, therefore, have a high potential for strong earthquake shaking. Seismicity in the area of the Salton Trough (and Salton Sea) primarily results from movement along northwest-trending transform fault systems and oceanic-type spreading centers. Since 1987, 70 earthquakes with a magnitude greater than 5.0 have been reported within 100 miles of the Project sites. It is generally accepted that a maximum credible earthquake in this area would be in the range of magnitude 7.4 to 7.9 along the San Andreas Fault system, which is located approximately 14 miles northwest of the Project sites. Other significant seismicity includes a possible maximum credible earthquake of magnitude 6.4 on the Brawley seismic zone approximately 2.6 miles west southwest of the Project sites (Landmark Consultants, Inc. 2011a, Table 1). The Project sites do not lie within any of the state of California s Alquist-Priolo earthquake fault zones (Landmark Consultants, Inc. 2011a). No fault structures are mapped on or adjacent to the proposed geothermal power plant sites, and additional fault hazard mitigation or investigation is not considered necessary (see Figure 4.6-1). Hudson Ranch Power II and Simbol Calipatria II Final EIR

217 Path: L:\SanDiego\HudsonRanch_Geothermal\MAPS\MXDs\Figure_4_6-1_Faults_Map.mxd Riverside County Imperial County MEXICO Hudson Ranch Power II CUP #G & Simbol Calipatria II CUP # Faults Map Figure 4.6-1

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219 4.6 Geology, Soils, and Mineral Resources Liquefaction Liquefaction occurs when granular soil below the water table is subjected to vibratory motions, such as those produced by earthquakes. With strong ground shaking, an increase in pore water pressure develops because the soil tends to reduce in volume. If the increase in pore water pressure is sufficient to reduce the vertical effective stress (suspending the soil particles in water), the soil strength decreases and the soil behaves as a liquid (similar to quicksand). Liquefaction can produce excessive settlement, ground rupture, lateral spreading, or failure of shallow bearing foundations. Four conditions are generally required for liquefaction to occur: (1) the soil must be saturated (relatively shallow groundwater); (2) the soil must be loosely packed (low to medium relative density); (3) the soil must be relatively cohesionless (not clayey); and (4) ground shaking of sufficient intensity must occur to function as a trigger mechanism. All of these conditions exist to some degree at the Project sites (Landmark Consultants, Inc. 2011a). Landslides Landslides occur when slopes become unstable and collapse. Landslides are typically caused by natural factors such as fractured or weak bedrock, heavy rainfall, erosion, earthquake activity, and fire, but also by human alteration of topography and water content. A landslide at the proposed Project sites is unlikely because of the regional planar topography. No ancient landslides are shown on geologic maps of the region and no indications of landslides were observed by Landmark Consultants, Inc. during their sites investigation (Landmark Consultants, Inc. 2011a). Subsidence Subsidence is a process characterized by the downward displacement or settling of the ground surface. Ground subsidence in the Imperial Valley may result for a number of causes, including groundwater withdrawal for irrigation, regional tectonic processes, withdrawal of geothermal fluids, and injection of fluids at a lower temperature than the field temperature. Subsidence of the ground surface due to natural causes occurs over a wide-spread area of the Imperial Valley. The Salton Sea Anomaly Master EIR (County of Imperial 1981) reports that because of the possibility of increased subsidence related to geothermal development, a monitoring program was developed to gather baseline data on natural subsidence. Data collected from 1972 to 1974 indicate that natural subsidence was greatest (up to -13 centimeters) in the area of the Salton Sea. As reported in Division 17 of the County of Imperial Land Use Ordinance, the County requires geothermal developers in the existing subsidence network to participate in identifying localized subsidence (County of Imperial 1999). Seiches Seiches are defined as oscillations of enclosed and semi-enclosed bodies of water such as bays, lakes, or reservoirs, due to strong ground motion from seismic events, wind stress, volcanic eruptions, and local basin reflections of tsunami. Seiches can result in the creation of long-period waves that can cause water to overtop containment features or cause seiche run-up on adjacent land masses, similar to tsunami run-up. The most likely location for a significant seiche to occur is the Salton Sea. While there have been a number Hudson Ranch Power II and Simbol Calipatria II Final EIR

220 4.6 Geology, Soils, and Mineral Resources of seismic events since the formation of the Salton Sea, no significant seiches have occurred to date. However, a seiche could occur in the Salton Sea under the appropriate seismic conditions. The Salton Sea is proximal to the San Andreas and San Jacinto faults and would be subject to significant seismic ground shaking that could generate a seiche (County of Imperial 2003). Flooding The proposed Projects would not expose people or structures to a significant risk of loss, injury, or death involving flooding as a result of the failure of a levee or dam. The Project sites are located on flat terrain that has little or no potential for inundation by seiche, tsunami, or mudflow. Volcanic Activity The Imperial Valley portion of the Salton Trough physiographic province is a volcanically active area, containing four volcanic domes, several clusters of hot springs, mudpots (mud volcanoes), and small geysers. These features appear to be an on-land manifestation of the East Pacific Rise, a crustal spreading center that has been overridden by the North American continent. The four volcanic domes, from north to south, are Mullet Island, Red Island, Rock Hill, and Obsidian Butte. Although all are the result of late Pleistocene volcanism, they differ from one another in form and composition (Imperial County 1981). The Project sites are located in proximity to Obsidian Butte and Red Hill, but the risk of volcanic hazards is considered to be low (Landmark Consultants, Inc. 2011a). Soils Figure (Soils Map) identifies the soil types present at and in the vicinity of the Project sites. Landmark Consultant s geotechnical investigations indicated that the Project sites are underlain by clays of high expansion potential. Dust generation also is possible if grading occurs in dry weather. Characteristics of the soil types present at the Project sites are summarized in Table As shown on Table 4.6-1, soils on the Project sites also have a high corrosive potential. Subsurface soils encountered during the field exploration conducted for the geotechnical investigation consisted of approximately 17 feet of near-surface fat clays. Medium dense silty sands and silts were encountered from 17 to 20 feet below ground surface (bgs). Stiff clays were encountered at a depth of 24 to 98 feet bgs. A thin, medium-dense silty sand layer was encountered at 97 to 99 feet bgs. Stiff to very stiff clay was encountered from 99 to 100 feet bgs, the maximum depth of exploration. Groundwater Groundwater was not noted during the subsurface investigations for the proposed Projects and equipment pad, but was encountered at approximately 10 feet bgs, which is typical for groundwater in the vicinity of the Project sites (Landmark Consultants, Inc. 2011a). A detailed discussion on water quality is presented in Section 4.8, Hydrology and Water Quality. Hudson Ranch Power II and Simbol Calipatria II Final EIR

221 4.6 Geology, Soils, and Mineral Resources TABLE SOIL UNITS AND UNIT CHARACTERISTICS AT THE PROPOSED PROJECT SITES COMPLEX/ UNIT ID NUMBER COMPLEX OR UNIT NAME/ASSOCIATION PARENT MATERIAL/ COMPOSITION/SLOPE SHRINK/ SWELL POTENTIAL CORROSION POTENTIAL CONCRETE UNCOATED STEEL 114 Imperial Silty Clay, Wet/MCC and VIGG Clayey alluvium and/or clayey lacustrine deposits from mixed sources:85% Imperial, wet; 4% Glenbar, wet; 4% Meloland, wet; 4% Holtville; 3% Niland/0-2% High Moderate High 115 Imperial-Glenbar Silty Clay Loams, Wet/MCC and VIGG Clayey alluvium and/or clayey lacustrine deposits from mixed sources:40% Glenbar, wet; 40% Imperial, wet; 10% Holtville; 10% Meloland/0-2% Moderate - High Moderate High 116 Imperial - Glenbar Silty Clay Loams, Wet/MCC and VIGG Clayey alluvium and/or clayey lacustrine deposits from mixed sources: 40% Glenbar, wet; 40% Imperial, wet; 10% Holtville; 10% Meloland/0-2% Moderate - High Moderate High 122 Meloland Very Fine Sandy Loam, Wet/MCC and VIGG 144 Vint and Indio Very Fine Sandy Loams, Wet/MCC and VIGG Source: NRCS 2008 Key: MCC = Myoma-Carsitas-Carrizo VIGG = Vint-Imperial-Glenbar-Gilman Alluvium and/or eolian deposits from mixed sources:85% Meloland, wet; 3% Imperial; 3% Indio; 3% Holtville; 3% Glenbar; 3% Vint/0-2% Alluvium and/or eolian deposits from mixed sources:50% Vint, wet; 40% Indio, wet; 5% Rositas; 5% Meloland/0-2% Low - High Moderate High Low - High Moderate High Mineral Resources The Salton Sea Anomaly Master EIR reported that the only known commercially exploitable mineral resources within the Salton Sea KGRA are pumice in the Red Island dome area and sand and gravel deposits on the eastern and northern margins of the KGRA (County of Imperial 1981, p ). Pumice was formerly extracted from Red Island, but mining operations were discontinued when the area was inundated by rising sea levels. Sand and gravel deposits in Salton Sea KGRA have not been commercially exploited (County of Imperial 1981, p ). With respect to mineral and fossil collecting localities, the Master EIR reports pumice and obsidian localities in Obsidian Butte and Rock Hill, but no known fossil deposits. Because of its tectonic setting, the area is considered a unique geomorphic feature. Within the Salton Sea KGRA, the geothermal brine has been found to be very high in minerals such as sodium, lithium, manganese, zinc and lead, among others. Imperial County s Geothermal/Alternative Energy and Transmission Element notes that it is feasible to extract minerals from the geothermal fluids Hudson Ranch Power II and Simbol Calipatria II Final EIR

222 4.6 Geology, Soils, and Mineral Resources and because geothermal brines of the Salton Sea KGRA have a greater concentration of valuable minerals, this area's resource is being developed (Imperial County, 2006). Currently, the flashed-steam technical design has the greatest potential for mineral recovery in the Salton Sea area. Adjacent Areas The Project sites are surrounded by flat-lying agricultural fields, a commercial algae farm and IID managed marshlands that have approximately the same elevation as the sites. Agricultural irrigation canals and drainage ditches are located along the northern and southern perimeters of the Project sites REGULATORY SETTING FEDERAL AND STATE Alquist-Priolo Earthquake Fault Zoning Act The legislature of the State of California passed the Alquist-Priolo Geologic Hazards Zone Act in 1972, renamed the Alquist-Priolo Earthquake Fault Zoning Act in The intent of the legislation was to limit the hazards of fault surface rupture to occupied structures. Active faults are those with evidence of displacement within the past 11,000 years (Holocene period). Faults with evidence of displacement during the Pleistocene period (11,000 to 2,000,000 years before present [B.P]) are generally considered potentially active. In 1974, the California Division of Mines and Geology (currently known as the California Geological Survey) began establishing special study zones along known active faults, termed earthquake fault zones. Starting in 1976, the California Division of Mines and Geology initiated the Fault Evaluation and Zoning Program to study faults identified in the Alquist-Priolo Earthquake Fault Zoning Act as sufficiently active and well defined to be considered for further evaluation. Fault Evaluation Reports were prepared for each earthquake fault zone summarizing data on fault location, age of activity, orientation, and probable magnitude of displacement. The Project sites are not within any Alquist-Priolo Earthquake Fault Zone. Seismic Hazards Mapping Act The Seismic Hazards Mapping Act addresses non-surface fault rupture earthquake hazards, including liquefaction and seismically induced landslides. Passed by the State Legislature in 1990, this law was codified in the California Public Resources Code (PRC) as Division 2, Chapter 7.8A, and became operative in April County of Imperial is not identified as having any seismic hazards zones according to the United States Geological Survey (USGS). California Building Code The State of California provides minimum standards for building design through the California Building Code. The County has adopted the 2010 California Building Code (CBC). The CBC is based on the Uniform Building, which is used widely throughout the United States (generally adopted on a state-by-state or district-by-district basis) and has been modified for conditions in California. Hudson Ranch Power II and Simbol Calipatria II Final EIR

223 4.6 Geology, Soils, and Mineral Resources Regional Water Quality Control Board The Regional Water Quality Control Board (RWQCB) issues permits for activities that could cause impacts to surface waters and groundwater in the vicinity of any Project sites, including construction activities. The National Pollutant Discharge Elimination System (NPDES) storm water permitting program, under Section 402(p) of the federal Clean Water Act (CWA), is administered by the RWQCB on behalf of the U.S. Environmental Protection Agency (EPA). The proposed Project sites fall under the jurisdiction of the California Colorado River Basin (CRB) RWQCB. Permits issued to control pollution (i.e., waste discharge requirements and NPDES permits) must implement California CRB RWQCB requirements (i.e., water quality standards), taking into consideration beneficial uses to be protected. LOCAL County of Imperial General Plan The County of Imperial General Plan Conservation and Open Space Element provides goals, objectives, and policies related to geology, soils, and seismicity. Table identifies applicable General Plan policies related to geology, soils, and seismicity, and addresses the Projects consistency with General Plan policies. TABLE HR-2 AND SMCP-2 PROJECTS CONSISTENCY WITH GEOLOGY, SOILS, AND SEISMICITY POLICIES OF THE GENERAL PLAN GENERAL PLAN POLICIES CONSISTENCY ANALYSIS SEISMIC AND PUBLIC SAFETY ELEMENT (SPSE) SPSE Policy 2: Monitor, evaluate, and analyze existing seismic and geological data as it pertains to County of Imperial to determine future regulations and programs. SPSE Policy 4: Ensure that no structure for human occupancy, other than one-story wood frame structures, shall be permitted within 50 feet of an active fault trace as designated on maps compiled by the State Geologist under the Alquist-Priolo Geologist Hazards Zone Act. Yes Yes Geotechnical reports have been prepared by Landmark Consultants, Inc. for the proposed HR-2 Project (see Appendix G). The report s recommended measures address potential geologic or seismic hazards have been incorporated into this Draft EIR. A geotechnical report will also be prepared for the SmCP-2 Project, which will identify recommended measures for the proposed mineral extraction plant facilities. The Project sites are not located within 50 feet of an active fault trace. Development facilities will be built in accordance with the applicable 2010 California Building Code requirements. Building permits will be obtained for the Projects from the County prior to commencement of construction. No humanoccupied structures will be placed across the trace of an active fault, and no human-occupied structure will be placed within 50 feet of the trace of an active fault or within a seismic special studies zone without a geologic report, satisfactory to the State Geologist, Hudson Ranch Power II and Simbol Calipatria II Final EIR

224 4.6 Geology, Soils, and Mineral Resources TABLE HR-2 AND SMCP-2 PROJECTS CONSISTENCY WITH GEOLOGY, SOILS, AND SEISMICITY POLICIES OF THE GENERAL PLAN GENERAL PLAN POLICIES CONSISTENCY ANALYSIS SPSE Objective 4.2: Control and prevent soil erosion when possible. Yes demonstrating that no undue hazard will be created by the construction or placement of the structure. The proposed Projects will adopt relevant California CRB RWQCB best management practices (BMPs), as necessary, to prevent soil erosion. While this Draft EIR analyzes the Projects consistency with the County of Imperial General Plan pursuant to California Environmental Quality Act (CEQA) Guidelines, Section 15125(d), the County of Imperial Planning Commission will make a determination as to the Projects consistency with the General Plan IMPACTS AND MITIGATION MEASURES STANDARDS OF SIGNIFICANCE Based on the criteria derived from Appendix G of the CEQA Guidelines, impacts related to geology, soils, and mineral resources are considered to be significant if implementation of the proposed Projects would result in any of the following: 1. Exposure of people or structures to potential substantial adverse impacts, including the risk of loss, injury, or death involving the following: a) rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault; b) strong seismic ground shaking; c) seismically related ground failure, including liquefaction; and/or d) landslides. 2. Substantial soil erosion or the loss of topsoil. 3. The project being situated on a geologic unit or unstable soil, or a location that would become unstable as a result of the project, with the potential for an on- or off-site landslide, lateral spreading, liquefaction, or collapse. 4. The project being situated on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), thereby creating substantial risks to life or property. Hudson Ranch Power II and Simbol Calipatria II Final EIR

225 4.6 Geology, Soils, and Mineral Resources 5. The project being situated on soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water. 6. The loss of availability of a known mineral resource that would be of value to the region and the residents of the state. 7. The loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan. ENVIRONMENTAL PROTECTION MEASURES Chapter 3 provides a complete list and descriptions of environmental protection measures (EPMs) that Hudson Ranch Power II, LLC and Simbol, Inc. have incorporated into the Projects to avoid or minimize impacts to minimize or avoid impacts to geology, soils and minerals. The following EPMs are included as part of the proposed HR-2 Project to minimize or avoid impacts on geology, soils, and mineral resources: HR-2 EPM GEO-1: Seismic Impacts. Development facilities will be built in accordance with the applicable 2010 California Building Code requirements. Building permits will be obtained for the Project from the County before beginning power plant construction. No human-occupied structure will be placed across the trace of an active fault, and no human-occupied structure will be placed within 50 feet of the trace of an active fault or within a seismic special studies zone without a geologic report, satisfactory to the State Geologist, demonstrating that no undue hazard will be created by the construction or placement of the structure. HR-2 EPM GEO-2: Soil Erosion. Where fill is needed in the construction of well pads, construction sites, or access roads, it will be provided from off-site sources. Runoff will be channeled to energy dissipaters, as necessary, to minimize erosion. In addition, the Project will adopt relevant California CRB RWQCB best management practices (BMPs), if necessary, to further prevent soil erosion. HR-2 EPM AQ-1: Fugitive Dust Suppression Plan. This plan will provide a detailed list of control measures to reduce fugitive emissions from construction and operational activities, including, but not limited to, watering of unpaved roads, vehicle speed limits, windbreaks, transport container covers, and cleaning and sweeping procedures. The following EPMs are included as part of the proposed SmCP-2 Project to minimize or avoid impacts on geology, soils, and mineral resources: SmCP-2 EPM GEO 1: Seismic Impacts. Facilities will be built in accordance with the applicable 2010 California Building Code requirements. Building permits would be obtained for the Project from the County prior to commencement of plant construction. No human-occupied structures Hudson Ranch Power II and Simbol Calipatria II Final EIR

226 4.6 Geology, Soils, and Mineral Resources would be placed across the trace of an active fault, and no human-occupied structure would be placed within fifty feet of the trace of an active fault or within a seismic special studies zone without a geologic report, satisfactory to the State Geologist, demonstrating that no undue hazard would be created by the construction or placement of the structure. SmCP-2 EPM GEO 2: Prevention of Soil Erosion. Where fill is needed in the construction of the SmCP-2 plant site or access road it will be provided. Runoff will be channeled to the storm water retention basin to minimize erosion. In addition, the Project will adopt relevant CRB RWQCB best management practices (BMP), if necessary, to further prevent soil erosion. A Drainage and Grading Plan will be prepared identifying the BMP that will be implemented. The Drainage and Grading Plan will be submitted to the Imperial County Department of Public Works (ICDPW) for review and approval prior to site construction. SmCP-2 EPM AQ-9: Fugitive Dust Suppression Plan. Fugitive dust generated during construction and use of the plant access road will be minimized by watering as necessary. To further reduce fugitive dust emissions, vehicle traffic on plant roads will be kept below 15 miles per hour. The Project will comply with any requirements concerning emissions of air pollutants from plant facilities and internal combustion emission sources. METHODOLOGY Evaluation of potential geologic and soil impacts of the proposed Projects was based on the Geotechnical Investigations prepared by Landmark Consultants, Inc. (Appendices G-1, G-2 and G-3) and the County of Imperial General Plan Seismic and Public Safety Element. The Project sites will not be impacted by geologic hazards involving landslides and volcanic activity. The Project sites are relatively flat and not located immediately adjacent to steep areas susceptible to landslide. HR-2 IMPACTS AND MITIGATION MEASURES Impact GEO-1a: The HR-2 Project would not expose people or structures to substantial adverse impacts, including the risk of loss, injury, or death involving rupture of a known earthquake fault. Ground rupture is generally considered most likely to occur along pre-existing faults. The existence of active fault-related features and historic ground rupture has been documented in the County. The Project site does not lie within a State of California Alquist-Priolo Earthquake Fault Zone (Land Mark Consultants, 2011a). Surface fault rupture at the Project site is considered to be unlikely. The proposed HR-2 Project would be required to comply with the 2010 California Building Code standards as adopted by the County. Adherence to these standards would reduce the potential for structural damage to facilities and corollary indirect impacts associated with seismic-related ground rupture, to the extent feasible. Hudson Ranch Power II and Simbol Calipatria II Final EIR

227 4.6 Geology, Soils, and Mineral Resources Because the proposed Project site does not contain any known earthquake fault lines, impacts associated with fault rupture on the proposed Project site are considered less than significant. Mitigation Measures: Impact GEO-1b: None required. The HR-2 Project would not expose people or structures to substantial adverse impacts, including the risk of loss, injury, or death involving strong seismic groundshaking. The HR-2 Project site has the potential to experience ground shaking during earthquakes along the Brawley and Imperial faults. The Brawley seismic zone is approximately 2.6 miles west-southwest of the Project site. The nearest Alquist- Priolo-defined Type A fault is the Coachella Valley fault (San Andreas Fault System), located approximately 18 miles northwest of the Project site (Landmark Consultants Inc. 2011a). Based on the proximity of mapped strands of these known faults, the potential for moderate to strong ground shaking at the site resulting from seismic activity in the region is likely. The geotechnical study calculated the site coefficients and adjusted the maximum considered earthquake spectral response acceleration parameters for the proposed Project (Landmark Consultants, Inc. 2011a, Table 2). The site soils are classified as Site Class D (stiff soil profile). Because of the potential for structural damage to facilities, site structures will be designed in accordance with the latest edition of the California Building Code for Seismic Zone 4 for a "Maximum Considered Earthquake," as adopted by the County and with the appropriate site coefficients (HR-2 EPM GEO-1). Adherence to these standards would ensure that the potential for structural damage to facilities and corollary indirect impacts associated with seismic-related ground shaking would be less than significant. Mitigation Measures: Impact GEO-1c: None required. The HR-2 Project site could experience seismic-related ground failure, including liquefaction. Evaluation of liquefaction potential at the site indicates that the 2.5-foot-thick, isolated, interbedded layer of silt at a depth between 17 to 19.5 feet bgs may liquefy under seismically induced ground shaking, potentially resulting in an estimated 0.5 inch of deep-seated settlement (Landmark Consultants, Inc. 2011a). The risk of seismically induced liquefaction impacts are considered potentially significant because of underlying saturated sandy substrata at the site and mitigation is required. Hudson Ranch Power II and Simbol Calipatria II Final EIR

228 4.6 Geology, Soils, and Mineral Resources MM GEO-1.1: Liquefaction Mitigation Liquefaction settlements shall be mitigated by one of the following methods: (1) Structural flat-plate mats, either conventionally reinforced or tied with posttensioned tendons; (2) Deep foundations (drilled piers or auger cast piles) founded at a minimum depth of 25 feet; or (3) Soil improvement by soil-cement mixing or soil replacement to create nonliquefying soils (20-foot minimum depth). Timing/Implementation: Prior to approval of initial grading or building permits (whichever comes first) permits. Enforcement/Monitoring: Imperial County Department of Public Works. Significance after Mitigation: Impact GEO-1d: Implementation of MM GEO-1.1 would reduce the potential for structural damage to facilities and corollary indirect impacts associated with seismically induced liquefaction. Upon implementation of MM GEO-1.1, Project impacts related to seismically induced liquefaction would be less than significant. The HR-2 Project would not expose people or structures to substantial adverse impacts, including the risk of loss, injury, or death involving landslides. The HR-2 Project site and the surrounding terrain are flat. Furthermore, no ancient landslides are shown on geologic maps of the region, and no indications of landslides were observed during the May 2011 site investigation by Landmark Consultants, Inc. (Landmark Consultants, Inc. 2011a), therefore, impacts related to landslides would be less than significant. Mitigation Measures: Impact GEO-2: None required. HR-2 Project construction would require excavation and grading that may result in soil erosion and loss of topsoil. Hudson Ranch Power II, LLC would obtain fill from off-site sources if needed for construction of well pads, construction sites, or access roads. Runoff will be channeled to energy dissipaters, as necessary, to minimize erosion and relevant California CRB RWQCB best management practices (BMPs), would be adopted as necessary to further prevent soil erosion (HR-2 EPM GEO-2). In addition, a Hudson Ranch Power II and Simbol Calipatria II Final EIR

229 4.6 Geology, Soils, and Mineral Resources fugitive dust plan would be implemented to reduce dust and fugitive emissions from construction and other operational activities (HR-2 EPM AQ-1). Dust potential at the HR-2 site would be moderate to high during dry periods. Temporary (during construction) and permanent (after construction) erosion control will be required for all disturbed areas. The construction phase of the HR-2 Project would involve grading the site, excavation to prepare the site for building foundations, and trenching to install necessary infrastructure. Soil disturbance and stockpiling could be subject to erosion from both wind and water. Therefore, impacts related to soil erosion and loss of topsoil would be potentially significant and mitigation is required. MM GEO-2.1: Reduce Soil Erosion Erosion potential shall be managed by implementing standard industry methods such as BMPs for dust suppression and for preventing surface water runoff and erosion impacts that are in place at the time of grading plan approval. Because the site is more than 5-acres, compliance with storm water NPDES criteria is required, including preparation of a Storm Water Pollution Prevention Plan (SWPPP) and the inclusion of BMPs to control erosion and the off-site transport of soils. The recently adopted State General Permit for construction imposes more minimum BMPs and requirements than were previously required only as elements of the SWPPP or were suggested by guidance. Additionally, erosion control shall be accomplished, in part, through compliance with Imperial County Air Pollution Control District (ICAPCD) Regulation VIII requirements (see Section 4.3, Air Quality). Compliance with these procedures shall ensure that potential erosion is controlled during the construction process. Additional information on the Project s storm water NPDES permitting requirements, as well as SWPPP requirements, is available in Section 4.8, Hydrology and Water Quality. Timing/Implementation: Prior to issuance of grading permits. Enforcement/Monitoring: Imperial County Public Works Department or local engineers. Significance after Mitigation: Impact GEO-3: Implementation of mitigation measures MM GEO-1.2 and HR- 2 EPM AQ-1 and HR- 2 EPM GEO-2 would reduce impacts to less than significant. The HR-2 Project site could be subject to instability from geothermal related subsidence. Hudson Ranch Power II and Simbol Calipatria II Final EIR

230 4.6 Geology, Soils, and Mineral Resources The withdraw of geothermal fluids at the Project site and the reinjection of spent brine at a lower temperature than the ground field could cause localized subsidence. Since the HR-2 Project would reinject spent geothermal fluids into geothermal resource via injection wells, at a rate to be approved by the CDOGGR, subsidence due to geothermal fluid withdrawal is expected to reduce the potential for localized differential settlement. This impact is considered to be potentially significant. The conditional use permit for the HR-2 Project would require annual monitoring of subsidence to determine the baseline and subsidence elevations at the project site in the context of the Imperial Valley monitoring data that is coordinated by the Imperial County Public Works Department. Should the natural subsidence and any project-induced subsidence be identified as severe enough to result in off-site impacts, the County would then require that further actions be considered to mitigate subsidence impacts to an appropriate level such that impacts are avoided. Such measures include, but are not limited to, increasing the injection volume into the geothermal resource, deeper injection wells, and grading of areas affected by the subsidence, reduction or total cessation of geothermal activities. MM GEO-1.1: Subsidence Monitoring Hudson Ranch Power II, LLC shall participate in the County's subsidence detection program, consistent with the California Division of Oil, Gas, and Geothermal Resources (CDOGGR) found in Section 1971 of Title 14 of the California Code of Regulations (CCR), and in connection therewith, submit a plan for Public Works Department approval, showing proposed locations of benchmark monuments. Monuments shall connect with the County's geothermal subsidence detection network. Benchmarks installed shall conform to County standards. Surveying shall be performed to National Geodetic Survey standards and all field surveying procedures shall conform with such standards. Hudson Ranch Power II, LLC shall perform surveying on an annual basis as required by the Director of Public Works, except the Director may require such surveying at shorter intervals if he deems it necessary. All work shall be performed under the supervision of a person licensed to practice surveying in California. All field surveying data (such as forms and instrument checks), along with an adjustment of said data and analysis, all in conformity with the National Geodetic Survey standards, shall be submitted for review and approval to the Department of Public Works within two months of completion of field work. If the Department of Public Works determines good cause exists to require additional surveying and analysis or additional subsurface data, the County Hudson Ranch Power II and Simbol Calipatria II Final EIR

231 4.6 Geology, Soils, and Mineral Resources reserves the right to require such work to be accomplished at the expense of the Permittee. The County further reserves the right, with Hudson Ranch Power II, LLC's input, to designate the consultant or firm to accomplish the work. Proprietary information shall not be released to the public. Should subsidence be identified as severe enough to result in off-site impacts, the County shall require that further actions be considered to mitigate subsidence impacts to an appropriate level such that impacts are avoided. Such measures include, but are not limited to, increasing the injection volume into the geothermal resource and grading of irrigated areas affected by the subsidence by Hudson Ranch Power II, LLC. Timing/Implementation: Hudson Ranch Power II, LLC shall submit a seismic and subsidence monitoring plan to the Imperial County Public Works Department for review and approval prior to commencement of grading. After start of commercial operation the Hudson Ranch Power II, LLC shall submit to the County an annual report outlining the seismic and subsidence monitoring performed during the previous year as required by the above referenced requirements. Enforcement/Monitoring: CDOGGR, Imperial County Public Works Department or local engineers. Significance after Mitigation: Impact GEO-4: Implementation of MM GEO-3.1 would reduce impacts from localized subsidence to below a level of significance through annual monitoring efforts and implementation of corrective actions if detected. The HR-2 Project site contains expansive clay soils (as defined in Table 18-1-B of the Uniform Building Code [1994] 1 ), thereby creating substantial risks to life or property. Newly constructed facilities could be damaged by differential settlement due to soil expansion and contraction because foundations have the tendency to rise during the wet season and shrink during the dry season. Movements can vary under the structures which, in turn, create new stresses on various sections of the foundation. These variations in ground settlement can lead to structural failure and damage to infrastructure. Impacts associated with expansive soils are considered potentially significant and mitigation is required. 1 California Building Code. Hudson Ranch Power II and Simbol Calipatria II Final EIR

232 4.6 Geology, Soils, and Mineral Resources MM GEO-4.1: Remove/Replace Expansive Soil The upper 3 feet of clays within the building foundation areas, extending five (5) feet beyond all exterior wall/column lines, shall be replaced with imported nonexpansive granular fill to mitigate the expansion forces and eliminate the need for special foundation designs. Design and construction of site improvements (concrete flatwork, curbs, housekeeping slabs, etc.) shall include provisions to mitigate clay soil movement. Additionally, the weak clay subgrade soil requires thickened structural sections for pavements. Imported fill soil shall be non-expansive, granular soil meeting the Unified Soil Classification System classifications of SM, SP-SM or SW-SM, with a maximum rock size of 3 inches and 5% to 35% passing the No. 200 sieve. A geotechnical engineer shall approve imported fill soil sources before hauling material to the site. To reduce settlement in the power plant structures, compressible clays shall be strengthened by soil improvement (soil mixing or replacement with sand/cement) or by using deep foundation system-like auger casts or driven piles. Timing/Implementation: Prior to issuance of initial grading or building permits (whichever comes first). Enforcement/Monitoring: Imperial County Department of Public Works and Department of Planning and Development Services. Significance after Mitigation: Impact GEO-5: Implementation of MM GEO-4.1 will reduce expansive soil impacts to less than significant because the expansive soils would be removed and replaced with nonexpansive soils or a licensed geotechnical engineer would design the facilities to withstand expansive soils. The HR-2 Project would be situated on soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water. Portable chemical toilets would be provided on-site during construction and waste pumped and transported by licensed contractors to a sanitary water treatment plant. Sanitary waste generated during operations would be discharged to a sanitary water treatment plant that would be constructed on the HR-2 Project site. Liquids generated by the waste water treatment plant would be injected into the geothermal reservoir. Sludge generated by the waste water treatment plant would be pumped by licensed contractors as needed and transported to a sanitary water treatment plant. All sanitary waste would be addressed per requirements of the Hudson Ranch Power II and Simbol Calipatria II Final EIR

233 4.6 Geology, Soils, and Mineral Resources Imperial County Public Health Department, Section of Environmental Health & Consumer Protection Services. The proposed wastewater treatment system would not require an on-site leach field or percolation that would release effluent into the soil or surface water. Therefore, this impact is considered less than significant impact. Mitigation Measures: Impact GEO-6: None required. The HR-2 Project would not result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state. Other than the geothermal resources being developed in the Project vicinity, there are no known mineral resources within the immediate vicinity of the Project site. The only known commercially exploitable mineral resources in the Salton Sea KGRA are pumice in the Red Island dome area. However, within the Salton Sea KGRA, geothermal brine has been found to be very high in minerals such as sodium, lithium, manganese, zinc and lead, among others. Minerals can be extracted from the geothermal fluids. Geothermal flashed-steam technology has the greatest potential for mineral recovery within the Salton Sea KGRA. The proposed HR-2 Project would not result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state. In fact, the proposed HR-2 Project would facilitate the utilization of a previously untapped source of minerals. This would be a beneficial impact. Mitigation Measures: Impact GEO-7: None required. The HR-2 Project would not result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan. There are no known mineral recovery sites in the vicinity of the HR-2 Project. As, such, the proposed HR-2 Project would not result in the loss of availability of a locally important resource recovery site. No impacts would occur. Mitigation Measures: None required. SMCP-2 IMPACTS AND MITIGATION MEASURES Impact GEO-1a: The SmCP-2 Project would not expose people or structures to substantial adverse impacts, including the risk of loss, injury, or death involving rupture of a known earthquake fault. Hudson Ranch Power II and Simbol Calipatria II Final EIR

234 4.6 Geology, Soils, and Mineral Resources Ground rupture is generally considered most likely to occur along pre-existing faults. The existence of active fault-related features and historic ground rupture has been documented in the County. According to the geotechnical investigation prepared by Landmark Consultants, Inc. (2011), the SmCP-2 Project site does not lie within a State of California Alquist-Priolo Earthquake Fault Zone. Surface fault rupture at the Project site is considered to be unlikely. The proposed SmCP-2 Project would be required to comply with the California Building Code standards as adopted by the County. Adherence to these standards would reduce the potential for structural damage to facilities and corollary indirect impacts associated with seismic-related ground rupture, to the extent feasible. Because the proposed Project site does not contain any known earthquake fault lines, impacts associated with fault rupture on the Project site are considered less than significant. Mitigation Measures: Impact GEO-1b: None required. The SmCP-2 Project would not expose people or structures to substantial adverse impacts, including the risk of loss, injury, or death involving strong seismic groundshaking. The SmCP-2 Project site has the potential to experience ground shaking during earthquakes along the Brawley and Imperial faults. The Brawley seismic zone is approximately 2.6 miles west-southwest of the Project site (Land Mark Consultants, Inc., 2011a). The nearest Alquist-Priolo-defined Type A fault is the Coachella Valley fault (San Andreas Fault System), located approximately 18 miles northwest of the Project site (Landmark Consultants Inc. 2011a). Based on the proximity of mapped strands of these known faults, the potential for moderate to strong ground shaking at the site resulting from seismic activity in the region is likely. The geotechnical study calculated the site coefficients and adjusted maximum considered earthquake spectral response acceleration parameters for the Project (Landmark Consultants, Inc. 2011a, Table 2). The site soils are classified as Site Class D (stiff soil profile). Because of the potential for structural damage to facilities, site structures shall be designed in accordance with the latest edition of the California Building Code for Seismic Zone 4 for a "Maximum Considered Earthquake," as adopted by the County and with the appropriate site coefficients (SMCP-2 EPM GEO-4). Adherence to these standards would ensure that the potential for structural damage to facilities and corollary indirect impacts associated with seismic-related ground shaking would be less than significant. Hudson Ranch Power II and Simbol Calipatria II Final EIR

235 4.6 Geology, Soils, and Mineral Resources Mitigation Measures: Impact GEO-1c: None required. The SmCP-2 Project site could experience seismically related ground failure, including liquefaction. Evaluation of liquefaction potential at the SmCP-2 Project site indicates that 2.5- foot-thick, isolated, interbedded layer of silt at a depth between 17 to 19.5 feet bgs may liquefy under seismically induced ground shaking, potentially resulting in an estimated 0.5 inch of deep seated settlement (Landmark Consultants, Inc. May 2011a). The risk of seismically induced liquefaction impacts are considered potentially significant because of underlying saturated sandy substrata at the site and mitigation is required. MM GEO-3.1: Prepare Geotechnical Investigation and Incorporate Results into Project Design A registered professional civil/geotechnical engineer shall prepare a geotechnical investigation for the SmCP-2 Project that includes comprehensive subsurface exploration, appropriate laboratory testing, and detailed evaluation of potential constraints to critical Project structures, including liquefaction, subsidence and expansive soils. The geotechnical investigation shall also include specific recommendations to address issues identified in the geotechnical investigation of the Project site to meet State and County seismic building code requirements. The recommendations shall be incorporated into the design of the structures. Timing/Implementation: Prior to approval of grading plans. Enforcement/Monitoring: Imperial County Department of Public Works and Department of Planning and Development Services. Significance after Mitigation: Impact GEO-1d: Implementation of MM GEO-1.1 would reduce the potential for structural damage to facilities and corollary indirect impacts associated with seismically induced liquefaction. Upon implementation of MM GEO-1.1, Project impacts related to seismically induced liquefaction would be less than significant. The SmCP-2 Project would not expose people or structures to substantial adverse impacts, including the risk of loss, injury, or death involving landslides. The SmCP-2 Project site and the surrounding terrain are flat. Furthermore, no ancient landslides are shown on geologic maps of the region, and no indications of landslides were observed during the May 2011 site investigation by Landmark Hudson Ranch Power II and Simbol Calipatria II Final EIR

236 4.6 Geology, Soils, and Mineral Resources Consultants, Inc. therefore, impacts related to landslides would be less than significant. Mitigation Measures: Impact GEO-2: None required. SmCP-2 Project construction would require excavation and grading that may result in soil erosion and loss of topsoil. Dust potential at the SmCP-2 site would be moderate to high during dry periods. Temporary (during construction) and permanent (after construction) erosion control will be required for all disturbed areas. The construction phase of the SmCP-2 Project would involve grading the site, excavation to prepare the site for building foundations, and trenching to install necessary infrastructure. Soil disturbance and stockpiling could be subject to erosion from both wind and water. Therefore, impacts related to soil erosion and loss of topsoil would be potentially significant and mitigation is required. MM GEO-2.1: Reduce Soil Erosion Erosion potential shall be managed by implementing standard industry methods such as BMPs for dust suppression and for preventing surface water runoff and erosion impacts during grading. Because the site is more than 5-acres, compliance with storm water NPDES criteria is required, including preparation of a Storm Water Pollution Prevention Plan (SWPPP) and the inclusion of BMPs to control erosion and the off-site transport of soils. The recently adopted State General Permit for construction imposes more minimum BMPs and requirements than were previously required only as elements of the SWPPP or were suggested by guidance. Additionally, erosion control shall be accomplished, in part, through compliance with Imperial County Air Pollution Control District (ICAPCD) Regulation VIII requirements (see Section 4.3, Air Quality). Compliance with these procedures shall ensure that potential erosion is controlled during the construction process. Additional information on the Project s storm water NPDES permitting requirements, as well as SWPPP requirements, is available in Section 4.8, Hydrology and Water Quality. Timing/Implementation: Prior to issuance of grading permits. Enforcement/Monitoring: Imperial County Public Works Department or local engineers. Hudson Ranch Power II and Simbol Calipatria II Final EIR

237 4.6 Geology, Soils, and Mineral Resources Significance after Mitigation: Impact GEO-3: Implementation of mitigation measures MM GEO-1.2 and SmCP-2 EPM AQ-9 and SmCP-2 EPM GEO-2 would reduce impacts to less than significant. The SmCP-2 Project could be situated on a geologic unit or unstable soil, or a location that would become unstable as a result of the Project. Appropriate engineering and/or construction specifications would be based on the findings of a geotechnical investigation conducted at the proposed site and these measures would be incorporated into the SmCP-2 Project design. Potential impacts of geologic hazards (lateral spreading, subsidence, or a collapse associated with unstable geologic units or soils) would be potentially significant. MM GEO-1.1: Significance after Mitigation: Impact GEO-4: Prepare Geotechnical Investigation and Incorporate Results into Project Design (see full text under Impact GEO-1). Implementation of MM GEO-1.1 would ensure that impacts from off-site landslide, lateral spreading, subsidence, or collapse an on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse, and expansive soils would remain less than significant. The SmCP-2 Project site contains expansive clay soils as defined in Table 18-1-B of the Uniform Building Code (1994), thereby creating substantial risks to life or property. Newly constructed facilities could be damaged by differential settlement due to soil expansion and contraction as foundations have the tendency to rise during the wet season and shrink during the dry season. Movements can vary under the structures which, in turn, create new stresses on various sections of the foundation. These variations in ground settlement can lead to structural failure and damage to infrastructure. Impacts associated with expansive soils are considered potentially significant and mitigation is required. MM GEO-1.1: Significance after Mitigation: Prepare Geotechnical Investigation and Incorporate Results into Project Design (see full text under Impact GEO-1) Implementation of MM GEO-3.1 would reduce expansive soil impacts to less than significant. Hudson Ranch Power II and Simbol Calipatria II Final EIR

238 4.6 Geology, Soils, and Mineral Resources Impact GEO-5: The SmCP-2 Project would be situated on soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water. Portable chemical toilets would be provided on-site during construction and waste pumped and transported by licensed contractors to a sanitary water treatment plant. Sanitary waste generated during operations would be discharged to a sanitary water treatment plant that would be constructed on the SmCP-2 Project site. Liquids generated by the waste water treatment plant would be sent to the HR-2 facility to be injected into the geothermal reservoir. Sludge generated by the waste water treatment plant would be pumped by licensed contractors as needed and transported to a sanitary water treatment plant. All sanitary waste would be addressed per requirements of the Imperial County Public Health Department, Section of Environmental Health & Consumer Protection Services. The proposed wastewater treatment system would not require an on-site leach field or percolation that would release effluent into the soil or surface water. Therefore, this impact is considered less than significant impact. Mitigation Measures: Impact GEO-6: None required. The SmCP-2 Project would not result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state. Other than the geothermal resources being developed in the Project vicinity, there are no known mineral resources within the immediate vicinity of the Project site. The only known commercially exploitable mineral resources in the Salton Sea KGRA are pumice in the Red Island dome area. However, within the Salton Sea KGRA, geothermal brine has been found to be very high in minerals such as sodium, lithium, manganese, zinc and lead, among others. Minerals can be extracted from the geothermal fluids. Geothermal flashed-steam technology has the greatest potential for mineral recovery within the Salton Sea KGRA. The proposed SmCP-2 Project would not result in the loss of availability of a known mineral resource. In fact, the proposed SmCP-2 Project would enable the utilization of a previously untapped source of minerals. Therefore, the proposed SmCP-2 Project would have a beneficial impact on mineral resources. Mitigation Measures: Impact GEO-7: None required. The SmCP-2 Project would not result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan. Hudson Ranch Power II and Simbol Calipatria II Final EIR

239 4.6 Geology, Soils, and Mineral Resources There are no known mineral recovery sites in the SmCP-2 Project vicinity. Therefore no impact would occur. Mitigation Measures: None required REFERENCES County of Imperial County of Imperial General Plan, Geothermal/Alternative Energy and Transmission Element Imperial County General Plan. Seismic and Public Safety Element Imperial County Land Use Ordinance, Title 9, Division 17-Geothermal Projects. Online at: Accessed May 12, Final Master Environmental Impact Report for Development of the Salton Sea Anomaly and Final Environmental Impact Report for Magma Power Plant #3 (SCH ). Prepared by Westec. Landmark Consultants, Inc. 2011a. Geotechnical Report: Hudson Ranch 2 Geothermal Plant West of English Road and South of McDonald Road Niland, CA - LCI Report No. LEll101. May b. Percolation Test Hudson Ranch 2 Geothermal Plant, McDonald Road 0.5 mile west of English Road, Calipatria, CA. Prepared for Energy Source. January c. Geotechnical Report Hudson Ranch 2 Equipment Pad, McDonald Road 0.75 mile west of English Road, Calipatria, CA. Prepared for Energy Source. January Li, H.C., C.F. You, T.L. Ku, X.M. Xu, H.P. Buchheim, N.J. Wau, R.M. Wang, and M.L. Shen Isotope and geochemical evidence of palaeoclimate changes in the Salton Basin, California during the past 20 yrk: 2 87 SR/ 86 ratio in lake tufa as an indicator of connection between the Colorado River and Salton Basin. Palaeography, Palaeoclimatology, Palaeoecology. Volume 259(2008): February 28. Maloney, N.J Coastal Landforms of Holocene Lake Cahuilla, Northeast Salton Basin, California. In Guptil P.D., R.W. Ruff, and E.M. Gath, editors, Geology of the Imperial Valley, California. Annual Field Trip Guidebook No. 14, South Coast Geological Society. pp Natural Resources Conservation Service (NRCS) Soil Unit Descriptions. Soil Survey Area: Imperial County, California, Imperial Valley Area. Survey Area Data: Version 5, July 25, Van de Kamp, P.C Holocene Continental Sedimentation in the Salton Basin, California, a Reconnaissance. Geol. Soc. Am. Bull. 84, Hudson Ranch Power II and Simbol Calipatria II Final EIR

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241 4.7 Hazardous Materials and Public Health 4.7 HAZARDOUS MATERIALS AND PUBLIC HEALTH This section contains a description of the environmental and regulatory settings with respect to hazardous materials and public health and safety. Hazards associated with seismic conditions are addressed in Section 4.6, Geology, Soils, and Mineral Resources. Potential flooding and water quality hazards are addressed in Section 4.8, Water Quality and Hydrology. Public health risks associated with air emissions are addressed in Section 4.3, Air Quality. The issues considered in this section include exposure to chemical contaminants and hazardous wastes and the potential for encountering hazardous contaminants on the surface or subsurface during construction and operation of the proposed Projects. Scoping Issues Addressed During the scoping period for the Projects, two public scoping meetings were conducted and written comments were received regarding potential threats to human health and the environment. One letter was received from the Department of Toxic Substances Control (DTSC) and the other letter was from March Air Force Base on behalf of the U.S. Marine Corps Air Station (MCAS) Yuma. The DTSC recommends the following: Identify whether conditions within the Project sites may pose a threat to human health or the environment. Search standard regulatory databases to identify any existing environmental contamination issues within the project area. Identify the mechanism that would initiate any required investigation and/or remediation for any site within the proposed project area that may be contaminated and the government agency that would provide appropriate regulatory oversight. Include the findings of any investigations conducted at the site, including any Phase I or II Environmental Site Assessment, and a summary of any sampling results in which hazardous materials were found above regulatory standards. Investigate the presence of hazardous chemicals, mercury, asbestos-containing materials, or leadbased paints or products for any structures that are demolished. Sample any imported soils to ensure they are free of contaminants. Evaluate on-site soils and groundwater for agriculture-related contaminant residuals, including pesticides, chemicals, and organic waste. Identify any hazardous wastes that may be generated by operation of the proposed Projects or handled, stored, or used by the projects. Hudson Ranch Power II and Simbol Calipatria II Final EIR

242 4.7 Hazardous Materials and Public Health MCAS Yuma indicated that the proposed Project sites are located beneath two military low-level routes, Visual Route (VR)-1211 and VR-288. The site may experience noise, vibrations, and interference during the overflight of low-flying military aircraft that operate in this area. Lt. Colonel Nichols, a pilot stationed at March Air Reserve Base, on behalf of MCAS Yuma, indicated that the proposed Projects are positioned directly beneath VR-1211; however, given that the Sonny Bono Salton Sea National Wildlife Refuge is located 2.75 miles southwest and the Wister Waterfowl Management Area is located 1.8 miles north of the Project sites, he stated that pilots flying in the Projects vicinity would reposition their flight paths, thereby avoiding the sites. Lt. Nichols also stated that the proposed Projects would not become an issue for Marine Corps Air Station Yuma as long as structures associated with the Projects are less than 300 feet tall (Nichols 2011). Applicants Reports and Survey Results Information used in preparing this section and in the evaluation of potential impacts on the environment and public health was derived from a number of sources, including a Geotechnical Report prepared by Landmark Consultants, Inc. in 2012 (Appendix G), a Phase I Environmental Site Assessment for the Hudson Ranch II Geothermal Project, conducted by Environmental Management Associates in August 2009 (Appendix H-1), an Agency Database Record Search conducted by Environmental Management Associates for the Simbol Calipatria Plant II Project in and March 2012 (Appendix H-2), and a Water Supply Assessment (WSA) prepared by Pangaea Land Consultants, Inc. in March 2012 (Appendix I). These documents are contained in Volume II (Technical Appendix) of this EIR EXISTING SETTING REGIONAL SETTING The proposed Projects would be located in the unincorporated County of Imperial, which is situated in the southeasternmost portion of the State of California. The County encompasses an approximately 4,597 square-mile area and is bordered by Riverside County to the north, the State of Arizona on the east, Mexico to the south, and San Diego County to the west. Approximately 12% (347,941-acres) of the land area in County of Imperial has been designated by the United States Geological Survey (USGS) as a Known Geothermal Resource Area (KGRA). In recent years, a number of solar and geothermal energy projects have been proposed for development in the County. According to the Imperial County Geothermal/Alternative Energy and Transmission Element, approximately 1,790 megawatts (MW) of renewable energy development is anticipated to come from geothermal resources located throughout the County by the year 2015 (County of Imperial 2006). Project Sites The HR-2 and SmCP-2 Project sites would be located on 100-acres of private land within a 245-acre parcel located in the unincorporated area of the County of Imperial and within the Salton Sea KGRA Zone. The Hudson Ranch Power II and Simbol Calipatria II Final EIR

243 4.7 Hazardous Materials and Public Health proposed Project sites are located approximately 2.3 miles west southwest of the Town of Niland, California, and 1.1 miles directly east of the existing Hudson Ranch I Geothermal Plant (see Chapter 3, Project Description, Figure 3-1). The proposed Project sites are located between McDonald Road and Schrimpf Road, just west of English Road (see Chapter 3, Project Description, Figure 3-2). At the time of the publication of the NOP and the Draft EIR, the agricultural fields on the Project sites were fallow and not being irrigated. Contaminated Sites The primary reason for defining potentially hazardous sites is to protect health and safety and to minimize the public s exposure to hazardous materials during Project construction and waste handling. Exposure can occur during normal use, handling, storage, transportation, and disposal of hazardous materials. Exposure may also occur due to hazardous compounds existing in the environment, such as fuels in underground storage tanks, pipelines, or areas where chemicals have leaked into the soil or groundwater. If encountered, contaminated soil may qualify as hazardous waste, thus requiring handling and disposal according to local, state, and federal regulations. The list of Hazardous Waste and Substances Sites and Sites with Land Use Restrictions revealed that there are no land use restrictions for the proposed Project sites and there are six contaminated sites within 7 miles of the Project sites, as shown in Table TABLE HAZARDOUS WASTE GENERATOR FACILITIES IN THE VICINITY OF THE PROPOSED PROJECT SITES SITE NAME ADDRESS CITY COUNTY OF IMPERIAL, CALIFORNIA SITE/FACILITY TYPE CLEANUP STATUS DISTANCE FROM PROPOSED PROJECT SITES CalEnergy Leathers Facility 342 W Sinclair Rd Calipatria Tiered Permit Site Active 1.6 miles CalEnergy Elmore Facility 786 W Sinclair Calipatria Tiered Permit Site Active 1.6 miles CalEnergy Central Services 480 W Sinclair Rd Calipatria Tiered Permit Site Active 2.2 miles CalEnergy - Vulcan/Del Ranch(Hoch) Facilities CalEnergy Units 1&2/Units 3&4/5 Facilities Chocolate Mountain Naval Aerial Gunnery Range 7001 Gentry Rd Calipatria Tiered Permit Site Active 4.7 miles 6920 Lack Rd Calipatria Tiered Permit Site Active 6.4 miles Naval Weapons Range, East of Salton Sea Source: California Department of Toxic Substances Control Niland State Response Certified as of 12/18/ miles Hazardous Waste Disposal Any hazardous waste generated during construction would be collected in hazardous waste accumulation containers near the point of generation and moved daily to the general contractor's 90-day hazardous Hudson Ranch Power II and Simbol Calipatria II Final EIR

244 4.7 Hazardous Materials and Public Health waste storage area located onsite. The accumulated waste would be transported by an authorized waste transporter to an off-site waste management facility authorized to accept the waste. Hazardous waste would be recycled or managed and disposed of properly in a licensed Class I waste disposal facility authorized to accept the waste. Geothermal Energy Hazards The development of geothermal energy may introduce hazardous material into the environment during exploration and production drilling, storage, and use. Impacts to human health and safety from geothermal development could include the introduction of hazardous materials into the environment and accidents/risks inherent in industrial facilities during exploration, construction, operation, and decommissioning. Common impacts on health and safety/hazards associated with geothermal energy development are summarized in Table TABLE COMMON IMPACTS TO HEALTH AND SAFETY/HAZARDS FROM GEOTHERMAL ENERGY DEVELOPMENT PROJECT PHASE ACTIVITY IMPACT Site Evaluation/ Exploration Construction Operation and Maintenance Surveying and well drilling. Access road and well pad construction. Staging equipment. Vehicular traffic. Drilling. Construction of injection wells and sump pits. Construction of the geothermal power plant. Construction of pipelines. Transformer, power house, and cooling tower. Spills involving hazardous materials, such as petroleum, oils, and lubricants. Accidents inherent in drilling operations. Exposure to drilling mud and geothermal fluid or steam during exploration and development drilling activities. Exposure to hydrogen sulfide contained in geothermal fluid or steam during exploration and development phases. Spills involving hazardous materials used and stored at facilities, such as petroleum, oil, lubricants, paints, solvents, and herbicides. Exposure of individuals to electrical fires or wildfires. Vehicular accidents due to increased traffic on local roads. Accidents inherent in drilling operations. Exposure of individuals to: Geothermal fluid or steam during system failures, maintenance activities, or well blowouts. Hydrogen sulfide contained in geothermal steam emissions. Spills involving hazardous materials used, such as petroleum, oils, lubricants, paints, solvents, and herbicides. Electrical fires and wildfires caused by project activities. Electric shock involved in maintenance of transmission lines and substations. Vehicular accidents due to increased traffic on local roads. Hudson Ranch Power II and Simbol Calipatria II Final EIR

245 4.7 Hazardous Materials and Public Health TABLE COMMON IMPACTS TO HEALTH AND SAFETY/HAZARDS FROM GEOTHERMAL ENERGY DEVELOPMENT PROJECT PHASE ACTIVITY IMPACT Decommissioning Vehicular traffic. Staging equipment. Facility removal. Breaking up concrete pads and foundations. Removing access roads that are not maintained for other uses. Recontouring the surface. Revegetation. Exposure of individuals to: Heat and hydrogen sulfide from geothermal fluid or steam during well capping. Hazardous materials used during dismantling structures and reclamation of a site, such as petroleum, oils, and lubricants. Electrical fires or wildfires. Vehicular accidents. A variety of potential accidents inherent to demolition activities. Sensitive Receptors Sensitive receptors that may be susceptible to health and safety impacts resulting from the construction and operation of renewable energy facilities generally include on-site workers and the young and elderly sectors of the population. The Town of Niland is approximately 2.3 miles south southwest of the Project sites. The nearest residence is approximately 0.5 miles north-northeast of the Project sites, along English Road. EnergySource, LLC (Hudson Ranch Power II LLC s parent company) owns the home and and is allowing the current tenant to remain in the residence until Fall This residence would be demolished prior to the start of construction of either the HR-2 or SmCP-2 Project. The next closest residence is located 1.4 miles northwest of the Project sites. The closest school is the Grace Smith Elementary School which is located 2.6 miles to the northeast. A commercial algae production facility is located south of the Project sites. This facility includes a mobile home which, at the time of the publication of the NOP, served as a residence for the facility caretaker. The commercial algae facility is no longer in operation and is not part of the proposed Projects. Aircraft and Military Operations The Calipatria Municipal Airport, otherwise known as the Cliff Hatfield Memorial Airport, is the closest public airport to the Project sites, located approximately 4.8 miles to the southeast. This airport has a single 3,423-foot asphalt-paved runway. According to the Imperial County Airport Compatibility Plan, Compatibility Zone C (Common Traffic Pattern Zone) is located approximately 3.7 miles south-southeast of the Projects intersection of English Road and Wilkinson Road. Zone C is characterized by limited risk to aircraft flying at or below 1,000 feet above ground level, as well as limited noise intrusion (Imperial County Airport Land Use Compatibility Plan [ALUCP] 1996). The closest private airport is located 16 miles south of the Project sites. Military bases were established in the Imperial Valley desert area during the World War II and are still in use today. The Chocolate Mountain Aerial Gunnery Range is located along the western boundary of the West Chocolate Mountains and is 6.8 miles east of the Project sites. Navy Special Warfare conducts Hudson Ranch Power II and Simbol Calipatria II Final EIR

246 4.7 Hazardous Materials and Public Health readiness training on and around the range. Marine Corps Air Station Yuma operates low-flying military aircraft in the vicinity of the Project sites. The airports and military facilities near the proposed Project sites are listed in Table TABLE AIRPORTS AND MILITARY FACILITIES NEAR THE PROPOSED PROJECT SITES AIRPORT NAME Cliff Hatfield Memorial (aka Calipatria Municipal Airport) TYPE OF AIRPORT DISTANCE FROM PROJECT SITES (MILES) DIRECTION FROM PROJECT SITES Public 4.8 Southwest Brawley Municipal Airport Public 14.0 South O'Connell Brothers Airport Private 16.3 South Imperial County Airport Public 25.5 South El Centro Naval Air Facility Military 27.3 Southwest Douthitt Strip Private 27.4 South Holtville Airport Public 28.7 Southeast Marine Corps Air Station Yuma Military 65.0 Southeast Source: AirNav 2011; OurAirports.com 2011 Industrial/Technological Hazards Pipeline and Power Line Crossings Proposed Projects are not known to be located in close proximity to underground pipelines, however, an existing above-ground 230-kV IID transmission line crosses the Project sites in a north to south direction. Prior to commencement of any grading activities, Hudson Ranch Power II, LLC and Simbol, Inc. would be required by law to contact the appropriate Underground Service Alert organization to identify the location of any underground utilities. Overhead lines that would be near or immediately adjacent to the site would be identified by Hudson Ranch Power II, LLC and Simbol, Inc., and it is not anticipated that there would be a power outage associated with the construction of the transmission line. Emergency Evacuation Routes The County of Imperial Emergency Operations Plan does not designate specific evacuation routes (Imperial Office of Emergency Services 2007). The Project sites do not bisect any major routes of travel. State Route 111 is 1.4 miles east of the site and it connects to Interstate 10 to the north and Interstate 8 to the south, providing alternative route options for exiting the area. Construction and operation activities for the proposed Projects would not require lane or roadway closures for equipment delivery. Hudson Ranch Power II and Simbol Calipatria II Final EIR

247 4.7 Hazardous Materials and Public Health Fire Hazards Wildland fires result from either natural or man-made causes that occur in brush, grasslands, or fallow agricultural areas that are capable of causing widespread damage to neighboring lands, in addition to threatening the lives and personal property of persons residing in wildfire-prone areas. According to the Imperial California Department of Forestry And Fire Protection maps the Project sites are classified as a low risk fire zone (CalFire 2007). The proposed HR-2 and SmCP-2 would have separate fire-protection systems that would consist of underground fire mains, surface distribution equipment such as yard hydrants and hose houses, monitors around the cooling towers, and automatic sprinklers. The freshwater storage pond(s) on the Project sites would provide firewater to the respective Project plant sites REGULATORY SETTING Hazardous materials handling and hazardous waste management are subject to numerous laws and regulations at all levels of government; laws and regulations related to health and safety are regulated by federal and state agencies. The laws that may apply to the proposed Projects are summarized below. FEDERAL AND STATE Resource Conservation and Recovery Act Resource Conservation and Recovery Act and Hazardous and Solid Waste Act Resource Conservation and Recovery Act of 1976 (RCRA) established a program administered by the Environmental Protection Agency (EPA) for the regulation of the generation, transportation, treatment, storage, and disposal of hazardous waste. RCRA was amended in 1984 by the Hazardous and Solid Waste Act (HSWA) which affirmed and extended the cradle to grave system of regulating hazardous wastes. The use of certain techniques for the disposal of some hazardous wastes was specifically prohibited by HSWA. Superfund Amendments and Reauthorization Act The Superfund Amendments and Reauthorization Act (SARA) amended CERCLA, established a nationwide emergency planning and response program, and imposed reporting requirements for businesses that store, handle, or produce significant quantities of extremely hazardous materials. SARA requires states to implement a comprehensive system to inform local agencies and the public when a significant quantity of such materials is stored or handled at a facility. Additionally, SARA identifies requirements for planning, reporting, and notification, with regards to hazardous materials. SARA Title III contains the Emergency Planning and Community Right-to-Know Act (EPCRA). Occupational Safety and Health Administration The Occupational Safety and Health Administration (OSHA) administers Occupational Safety and Health Standards (29 Code of Federal Regulations [CFR] 1910 and 1926), which (1) provide regulations for safety Hudson Ranch Power II and Simbol Calipatria II Final EIR

248 4.7 Hazardous Materials and Public Health in the workplace; (2) regulate construction safety; and (3) require a Hazard Communication Plan to include identification and inventorying of all hazardous materials for which material safety data sheets would be maintained, as well as employee training in safe handling of said materials. Occupational Safety and Health Administration, Electrical Safety Standards Title 29 CFR, Part , Sub-Part S: Design Safety Standards for Electrical Systems, and : Electrical Safety-Related Work Practices Standard (1990) provides a description of concepts and principles associated with electrical hazards and basic electrical safety for individuals. OSHA s electrical standards for construction recommend following general industry electrical standards whenever possible for hazards that are not addressed by industry-specific standards. The standards address concerns that relate to electrical hazards and exposures to dangers such as electrical shock, electrocution, burns, fires, and explosions. OSHA s electrical standards help minimize these potential hazards by specifying safety aspects in the design and use of electrical equipment and systems. Hazardous Materials Communications, Emergency Response Information, Training Requirements, and Security Plans, 49 CFR This Regulation requires that the suppliers of hazardous materials prepare and implement security plans in accordance with U.S. Department of Transportation regulations. Hazardous Materials Transportation Act The Hazardous Materials Transportation Act (HMTA) of 1975 primary objective is to provide adequate protection again the risks to life and property inherent in the transportation of hazardous materials in commerce. HMTA empowers the US DOT to regulate the transportation of hazardous materials by rail, aircraft, vessel, and public highway. Amendments of 1976 and 1990 substantially revise existing provisions and add new requirement for chemical that the DOT has determined pose unreasonable risks to health, safety and property during transport activities. Hazardous materials regulations are subdivided into Procedures and/or Policies, Material Designations, Packaging Requirements, and Operational Rules. This regulation is relevant to the Projects since materials to be transported to and from the Project sites would include fuels, transformer oil and other chemical substances that are regulated by DOT. Pollution Prevention Act The Pollution Prevention Act, 42 U.S.C et seq., established, as national policy, that, wherever feasible, source reduction must be used as the primary method of preventing pollution. Source reduction is defined as reducing the amount of any hazardous substance, pollutant, or contaminant released into the environment, and it can involve substituting materials and changing processes to avoid the use of hazardous substances altogether. Other requirements of the Act include recycling pollutants that cannot be disposed of in an environmentally safe manner, treating pollution that cannot be prevented or recycled in an environmentally safe manner, and disposing of pollutants or releasing them into the environment only as a last resort. Hudson Ranch Power II and Simbol Calipatria II Final EIR

249 4.7 Hazardous Materials and Public Health Emergency Planning and Community Right-to-Know Act The Emergency Planning and Community Right-to-Know Act (EPCRA), 40 C.F.R is also known as Title III of the SARA and is augmented by Executive Order (Federal Compliance with Right-to- Know Laws and Pollution Prevention Requirements). EPCRA has four major sections, each providing different requirements for facilities, communities, and states, and each covering a different group of chemicals. These sections include Emergency Planning (Sections ), Emergency Notification (Section 304), Community Right-to-Know (Sections ), and Toxic Release Inventory Reporting (Section 313). EPCRA establishes programs to provide the public with information on the hazardous and toxic chemicals in their communities and requires emergency planning and notification programs to protect the public in the event of a release of extremely hazardous substances. It further requires specified facilities to prepare an annual report listing the amount of certain chemicals treated or recycled on-site, transferred off-site, or released into the environment. Hazardous Materials Release Response Plans and Inventory Act of 1985 The Hazardous Material Release Response Plans and Inventory Act, also known as the Business Plan Act, requires businesses using hazardous materials to prepare a plan that describes their facilities, inventories, emergency response plans, and training programs. Hazardous materials are defined as raw or unused materials that are part of a process or manufacturing step and are not considered to be hazardous waste. Health concerns pertaining to the release of hazardous materials, however, are similar to those relating to hazardous waste. Under this Act, Hudson Ranch Power II, LLC and Simbol, Inc. would be required to prepare a Hazardous Materials Business Plan for construction and operation of the Project. Hazardous Waste Control Act The Hazardous Waste Control Act created the state hazardous waste management program, which is similar to, but more stringent than, the RCRA program requirements. The Act is implemented by regulations contained in CCR Title 22, Division 4 and 5, which describe the requirements pertaining to the following aspects of proper management of hazardous waste: Identification and classification. Generation and transportation. Design and permitting of recycling, treatment, storage, and disposal facilities. Treatment standards. Operation of facilities and staff training. Closure of facilities and liability requirements. Hudson Ranch Power II and Simbol Calipatria II Final EIR

250 4.7 Hazardous Materials and Public Health The regulations list more than 800 materials that may be hazardous and establish criteria for the identification, packaging, and disposal of such waste. Under the Hazardous Waste Control Act and CCR Title 22, the generator of hazardous waste must complete a manifest that accompanies the waste from the generator to the transporter to the ultimate disposal location. Copies of the manifest must be filed with the DTSC. The DTSC operates programs to protect California from exposures to hazardous wastes. Emergency Services Act The state developed an emergency response plan to coordinate emergency services provided by federal, state, and local agencies. This plan is administered by the California Emergency Management Agency (CEMA), who coordinates with CalEPA, California Department of Transportation (CalTrans), California Highway Patrol, regional water quality control boards, air quality management districts, and county disaster response offices to provide a rapid response to emergencies including incidents involving hazardous material or hazardous waste. California Law, Government Code Every operator of a subsurface installation, except the Department of Transportation, shall become a member of, participate in, and share in the costs of, a regional notification center. Operators of subsurface installations who are members of, participate in, and share in, the costs of a regional notification center, including, but not limited to, the South Shore Utility Coordinating Council, the Underground Service Alert--Northern California or the Underground Service Alert--Southern California are in compliance with this section and Section (Underground Service Alert, 2012). LOCAL County of Imperial Operational Area Emergency Operations Plan The County of Imperial Operational Area Emergency Operations Plan provides a comprehensive, single source of guidance and procedures for the County to prepare for and respond to significant or catastrophic natural, environmental, or conflict-related risks that produce situations requiring coordinated response (County of Imperial Office of Emergency Services 2007). County of Imperial Multi-Jurisdictional Hazard Mitigation Plan The County of Imperial Multi-Jurisdictional Hazard Mitigation Plan (MHMP) was developed in 2007 by the County of Imperial to create a safer community. The County of Imperial MHMP represents the County s commitment to reducing risks from natural and other hazards and serves as a guide for decision-makers as they commit resources to reducing the impacts of natural and other hazards, with the exception of flood hazards which are covered by a separate multi-jurisdictional Flood Management Plan. The County of Imperial MHMP serves as a basis for the State Office of Emergency Service (OES) to provide technical assistance and to prioritize project funding. Included in this MHMP are the cities of Brawley, Calexico, Calipatria, El Centro, Holtville, Imperial, and Westmorland, with participation and input from the Imperial Hudson Ranch Power II and Simbol Calipatria II Final EIR

251 4.7 Hazardous Materials and Public Health Irrigation District, Imperial County School District, and the Salton Community Services District (County of Imperial 2007). County of Imperial General Plan The Seismic and Public Safety Element of the County of Imperial General Plan is focused on reducing loss of life, injury, and property damage that might result from a disaster or accident. This Element identifies goals and policies that would minimize the risks associated with natural and human-made hazards. In addition, the Element specifies land use planning procedures that should be implemented to avoid hazardous situations (County of Imperial 1993). The County of Imperial General Plan provides goals, objectives, and policies related to geology, soils, and seismicity. The Seismic and Public Safety Element identifies goals and policies that would minimize the risks associated with natural and human-made hazards. Table identifies applicable General Plan policies related to hazardous materials and public health and addresses the HR-2 and SmCP-2 Projects consistency with these policies. TABLE HR-2 AND SMCP-2 PROJECTS CONSISTENCY WITH GENERAL PLAN HAZARDOUS MATERIALS AND PUBLIC HEALTH GOALS AND OBJECTIVES GENERAL PLAN POLICIES CONSISTENCY ANALYSIS SEISMIC AND PUBLIC SAFETY ELEMENT Land Use Planning and Public Safety, Goal 1: Include public health and safety considerations in land use planning. Emergency Preparedness, Goal 2: Minimize potential hazards to public health, safety, and welfare, and prevent the loss of life and damage to health and property resulting from both natural and human-related causes. Control Hazardous Materials, Goal 3: Protect the public from exposure to hazardous materials and wastes. Yes Yes Yes The proposed HR-2 and SmCP-2 Projects include health and safety measures such as lighting of the facility, fire suppression, and secondary containment that would be utilized in the event of accidental releases of hazardous and acutely hazardous materials. See response for Goal 1, above. During Construction of the HR-2 and SmCP-2 Projects, environmental monitoring and regular routine visual inspections of the development site would be made in conjunction with County of Imperial building Inspection(s) of the site. During operation of the HR-2 and SmCP-2 Projects, Job Hazard Analyses (JHAs) for would be prepared to identify any additional hazards associated with a job or task prior to performance. This would provide an opportunity to evaluate whether additional measures must be taken to minimize impacts from potential hazards. In addition, both the HR-2 and SmCP-2 Projects would comply with California Occupational Safety and Hudson Ranch Power II and Simbol Calipatria II Final EIR

252 4.7 Hazardous Materials and Public Health TABLE HR-2 AND SMCP-2 PROJECTS CONSISTENCY WITH GENERAL PLAN HAZARDOUS MATERIALS AND PUBLIC HEALTH GOALS AND OBJECTIVES GENERAL PLAN POLICIES CONSISTENCY ANALYSIS SEISMIC AND PUBLIC SAFETY ELEMENT Objective 3.2: Minimize the possibility of hazardous materials/waste spills. Objective 3.4: Adopt and implement ordinances, policies, and guidelines that assure the safety of County ground and surface waters from toxic or hazardous materials and wastes. Source: County of Imperial 1993 Yes Yes Health Administration (CALOSHA) Regulations and Standards. These requirements address numerous worker safety issues including emergency action/evacuation, personal protective equipment, first aid, blood borne pathogens, cranes and hoists, vehicle/traffic, chemical exposures. See response for Goal 3, above. See response for Goal 3, above. While this Draft EIR analyzes the Projects consistency with the County of Imperial General Plan, pursuant to California Environmental Quality Act (CEQA) Guidelines, Section 15125(d), the County of Imperial Planning Commission will determine the Projects consistency with the General Plan IMPACTS AND MITIGATION MEASURES STANDARDS OF SIGNIFICANCE The impact analysis provided below is based on the following CEQA Guidelines, as listed in Appendix G. Impacts of hazardous materials and risk of upset would be significant if the Projects would: 1. Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials. 2. Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment. 3. Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within 0.25 miles of an existing or proposed school. 4. Be located on a site that is included on a list of hazardous materials sites compiled pursuant to Government Code Section and, as a result, create a significant hazard to the public or the environment. Hudson Ranch Power II and Simbol Calipatria II Final EIR

253 4.7 Hazardous Materials and Public Health 5. Result in a safety hazard for people residing or working in the project area located within an airport land use plan or, where such a plan has not been adopted, within 2 miles of a public airport or public use airport. 6. Result in a safety hazard for people residing or working in the project area that is within the vicinity of a private airstrip. 7. Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan. 8. Expose people or structures to a significant risk of loss, injury, or death involving wildland fires, including wildlands that are adjacent to urbanized areas or where residences are intermixed with wildlands. Environmental Protection Measures Chapter 3 provides a complete list and description of environmental protection measures (EPMs) that Hudson Ranch Power II, LLC and Simbol, Inc. have incorporated into their respective projects to avoid or minimize impacts on all resources. The HR-2 EPMs that are proposed to minimize or avoid hazards and health and safety impacts are as follows: HR-2 EPM HAZ-1: Fire Suppression System. This system would reduce impacts from fires occurring at the site which, in turn, would reduce potential harm to workers. The system would include hand-cart carbon dioxide extinguishers, fire hydrants/hose stations, a sprinkler system, and smoke detectors. Personnel would be allowed to smoke only in designated areas. Well sites, construction sites, and access roads would be cleared of all vegetation. The cleared areas would be maintained during drilling, construction, and operations. Water that is used for drilling would also be available for fire-fighting. HR-2 EPM HAZ-2: Adherence to Applicable California Occupational Safety and Health Administration Regulations and Standards (training, written procedures, inspections, design, medical surveillance and monitoring). Will prevent or minimize potential impacts by the development of procedures, training, physical inspections and the prescription of some minimum standards to design adequate systems. These requirements address numerous worker safety issues including emergency action/evacuation, fire prevention, confined space entry, fall protection, hearing conservation, respiratory protection, personal protective equipment, lock-out/tag-out, electrical safety, excavation and trenching, hazard communication, ergonomics, first aid, blood borne pathogens, cranes and hoists, vehicle/traffic, chemical exposures. Hudson Ranch Power II and Simbol Calipatria II Final EIR

254 4.7 Hazardous Materials and Public Health HR-2 EPM HAZ-3: Adherence to Guidance by the State of California, CDOGGR, Publication No. M10. Will minimize risks associated with hydrogen sulfide and geothermal steam during drilling and well construction. HR-2 EPM HAZ-4: Job Hazard Analyses (JHAs) for Each Job or Task. Will identify any additional hazards associated with a job or task prior to performing that job or task. This will provide an opportunity to evaluate whether additional measures must be taken to minimize impacts from these potential hazards. HR-2 EPM HAZ-5: Safety Showers and Eyewash Stations. Will provide a means flushing skin and eyes in cases of chemical splashing, particularly as it pertains to corrosive materials. By providing an immediately available wash station, the contact time and possible injury by these chemicals can be minimized. HR-2 EPM HAZ 6: Secondary Containment. Curbs, berms, and concrete pits would be used where accidental releases of hazardous and acutely hazardous materials could occur. Containment areas would be drained to appropriate collection areas or neutralization tanks for recycling or offsite disposal. Traffic barriers would protect piping and tanks from potential traffic hazards. HR-2 EPM UTIL-1: Construction Wastes. Solid waste materials (trash) and construction waste would be deposited at an authorized landfill by a disposal contractor. Any petroleum hydrocarbon or hazardous wastes or empty containers/drums that may be generated during construction activities would be either recycled or managed as hazardous waste in conformance with applicable waste management and disposal requirements. Portable chemical sanitary facilities would be used by all personnel during construction. These facilities would be maintained by a local contractor. HR-2 EPM UTIL-1: Filter Cake Utilization. Filter cake would be recycled for beneficial use in cement and cement admixture. Before any filter cake material is removed from the plant site, it would be sampled and laboratory-tested. Only when the results demonstrate the material is nonhazardous would material be recycled for beneficial use. Otherwise, it would be transported to an off-site disposal facility authorized to accept the waste. HR-2 EPM WQ-3: Brine Pond Monitoring Wells. Potential release from the brine ponds to groundwater would be assessed with a system of monitoring wells placed around the periphery of the ponds. HR-2 EPM WQ-4: Storm Water Pond Berm. The storm water retention pond would be surrounded by a berm to prevent flooding. HR-2 EPM WQ-5: Casing Shallow Portions of Production and Injection Wells. Casing the shallow portions of the production and injection wells would minimize the potential release of both Hudson Ranch Power II and Simbol Calipatria II Final EIR

255 4.7 Hazardous Materials and Public Health construction-related drilling fluids and production-related geothermal brines to the shallow groundwater aquifer. HR-2 EPM WQ-6: Protective Pipeline Design and Detailed Inspection Routine. Production pipelines would be alloy-clad steel pipe. Injection pipelines would be constructed of concrete-lined carbon steel. Both would be routinely inspected to prevent potential releases. HR-2 EPM WQ-7: Production Wellheads. Piping at each production wellhead would be equipped with both remotely operated electrical emergency shutoff valves and manual alloy isolation valves to prevent potential releases. The SmCP-2 EPMs that are proposed to minimize or avoid impacts to hazards and health and safety impacts are as follows: SmCP-2 EPM HAZ-1: Protection of Public Health and Safety. In addition to the emergency contingency plans, public health and safety would be protected through instructions to work crews and contractors regarding compliance with regulations. SmCP-2 EPM HAZ 2: Adherence to Applicable California Occupational Safety and Health Administration Regulations and Standards. Implementation of Standards safety training, written procedures, inspections, design, medical surveillance, and monitoring would prevent or minimize potential impacts from plant operations. These requirements address numerous worker safety issues including emergency action/evacuation, fire prevention, confined space entry, fall protection, hearing conservation, respiratory protection, personal protective equipment, lock-out/tag-out, electrical safety, excavation and trenching, hazard communication, ergonomics, first aid, blood borne pathogens, cranes and hoists, vehicle/traffic, chemical exposures. SmCP-2 EPM HAZ 3: Job Hazard Analyses (JHAs) for Each Job or Task. JHAs would identify any additional hazards associated with a job or task prior to performing that job or task. This would provide an opportunity to evaluate whether additional measures must be taken to minimize impacts from these potential hazards. SmCP-2 EPM HAZ 4: Safety Showers and Eyewash Stations. These provide a means for flushing skin and eyes in cases of chemical splashing, particularly as it pertains to corrosive materials. By providing an immediately available wash station, the contact time and possible injury by these chemicals can be minimized. SmCP-2 EPM HAZ 5: Protective Pipeline Design and Detailed Inspection Routine. Brine delivery pipelines would be constructed of appropriate materials to prevent accidental releases. The pipelines would be routinely inspected to prevent potential releases. SmCP-2 EPM HAZ 6: Secondary Containment. Curbed areas would be used where accidental releases of hazardous materials could occur. Containment areas would be drained to appropriate Hudson Ranch Power II and Simbol Calipatria II Final EIR

256 4.7 Hazardous Materials and Public Health collection areas or neutralization tanks for recycling or offsite disposal. Traffic barriers would protect piping and tanks from potential traffic hazards. SmCP-2 EPM HAZ 7: Fire Suppression System. The use of fire extinguishers, fire hydrants/hose stations, sprinkler systems if needed, and smoke detectors would reduce impacts from fires occurring at the site which, in turn, would reduce potential harm to workers. SmCP-2 EPM UTIL-1: Construction Wastes. Solid waste materials (trash) and construction waste would be deposited at an authorized landfill by a disposal contractor. Any petroleum hydrocarbon or hazardous wastes or empty containers/drums that may be generated during construction activities would be either recycled or managed as hazardous waste in conformance with applicable waste management and disposal requirements. Portable chemical sanitary facilities would be used by all personnel during construction. These facilities would be maintained by a local contractor. METHODOLOGY County of Imperial maps were reviewed to determine the Projects proximity to schools and airports. In addition, the potential risk of fire based on local hazard maps was considered, and local agency resources were researched related to relevant emergency response plans and airport land use plans. Emergency Plans and Hazard Management Plans and evacuation routes for the County were reviewed. To aid in evaluation of impacts from Project-related contamination, sites with known and potential contamination were researched by reviewing online environmental databases and identifying land uses associated with hazardous material use. This section analyzes the impacts associated with the proposed Projects and the risk of upset to potential hazardous substances and/or waste contamination that may exist on the Project sites. This analysis is primarily based upon information obtained from the County of Imperial General Plan, Geotechnical Report (Appendix G), Phase I Environmental Site Assessment prepared for the Hudson Ranch II Geothermal Project (Appendix H-1), an Agency Database Record Search prepared for the Simbol Calipatria Plant II Project (Appendix H-2), and a WSA (Appendix I). HR-2 IMPACTS AND MITIGATION MEASURES Impact HAZ-1: The HR-2 Project would not create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials. The HR-2 Project would involve the transport, handling, use and disposal of hazardous materials including unleaded gasoline, diesel fuel, oils, lubricants (e.g., motor oils, transmission fluids, and hydraulic fluids), paints, adhesives, solvents and other substances. Hudson Ranch Power II and Simbol Calipatria II Final EIR

257 4.7 Hazardous Materials and Public Health Transport Hazardous Materials During construction and operations of the HR-2 Project, hazardous materials would be transported to and from the Project site. Traffic barriers would protect piping and tanks from potential traffic hazards. Hudson Ranch II LLC would be required to follow all applicable federal, state, and local laws and regulations. Transportation would be subject to licensing and inspection by the California Highway Patrol. Use of Hazardous Materials During construction and operation the HR-2 Project, hazardous materials would be stored in chemical storage containers. Secondary containment would be provided in all petroleum hydrocarbon and hazardous material storage areas. In general, all areas where hazardous materials are stored would have concrete ponds, be bermed or have curbs in order to prevent accidental releases (HR-2 EPM HAZ-6). Hudson Ranch II LLC would develop and implement a Stormwater Pollution Prevention Plans (SWPPP) and a Hazardous Materials Business Plan (HMBP) that would include procedures for the following: Hazardous materials handling, use, and storage; Emergency Response; Spill Prevention Control and Countermeasure (SPCC) Plan; Employee training; and Reporting and record keeping. All personnel working with chemicals would be trained in proper handling and emergency response to chemical spills or accidental releases. Adherence to Applicable California Occupational Safety and Health Administration Regulations and Standards (HR-2 EPM HAZ 2); Job Hazard Analyses (JHAs) for Each Job or Task (HR-2 EPM HAZ 3); Safety Showers and Eyewash Stations (HR-2 EPM HAZ 4); and Protective Pipeline Design and Detailed Inspection Routine (HR-2 EPM HAZ 5) would ensure the proper storage, handling of hazardous materials and would protect the workforce during construction and operation of the proposed Project. Disposal of Hazardous Materials Small quantities of hazardous wastes would be generated over the course of construction. These may include paint, spent solvents, and spent welding materials. During normal operations, less than 5 percent of the filter cake is projected to be characterized as hazardous waste as a result of elevated concentrations of heavy metals. Hudson Ranch Power II and Simbol Calipatria II Final EIR

258 4.7 Hazardous Materials and Public Health Any hazardous wastes generated would be collected in hazardous waste accumulation containers near the point of generation and moved daily to the contractor's 90-day hazardous waste storage area located on-site. The accumulated waste would subsequently be delivered to an authorized waste management facility. Hazardous wastes would be recycled or managed and disposed of properly in waste disposal facility authorized to accept the waste (HR- 2 EPM UTIL-1). The storage, containment, handling, and use of these chemicals would be managed in accordance with applicable laws, ordinances, regulations, and standards. Compliance with applicable manufacturer specifications as well as federal and state regulations regarding hazardous materials/wastes is designed to ensure safety during the use, transport, storage, and disposal of hazardous materials. With the implementation of HR-2 EPMs HAZ-2 through HAZ-6 and UTIL-1, Impact HAZ-1 would be less than significant. Mitigation Measures: Impact HAZ-2: None required. The HR-2 Project would not create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment. Hazards to the public or the environment could occur due to upset or accident involving the release of hazardous materials used, stored, or transported as part of the proposed Project. During construction, there could be accidental release or spills of hazardous materials (e.g., petroleum, oil, lubricants, paints, solvents, and herbicides). As discussed in Impact HAZ-1 above, multiple precautions would be implemented to ensure worker safety (EPMs HR-2 HAZ-2 through HAZ-5). During operations, upset conditions could result in a release of hydrogen sulfide contained in geothermal fluid or steam or an overflow of brine from multiple locations. To prevent a brine release, the brine that overflows the clarifiers or the thickener would be directed to the brine pond for temporary containment after which it would be processed for reinjection. All hazardous materials would be stored in chemical storage facilities designed for the characteristics of the chemicals to be stored. Diesel tanks with dual wall containment would be used for back up generators. Each area would have secondary containment equivalent to 110% of the volume of the material it stores. Therefore, if there was an accidental spill or release, these materials should be contained within the secondary containment area (HR-2 EPM HAZ-6). Hudson Ranch Power II and Simbol Calipatria II Final EIR

259 4.7 Hazardous Materials and Public Health While there is the potential for a significant hazard to the public or the environment following reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment, compliance with federal regulations, and those required by the State of California and County of Imperial and implementation of Simbol, Inc. s Emergency Response Plan (ERP) and Hazardous Materials Business Plan (HMBP) would help prevent upset conditions, ensure spills would be avoided, and immediately address spills or upset conditions if they occurred. All personnel working with chemicals would be trained in proper handling and emergency response to chemical spills or accidental releases. The potential for upset and accidents involving the release of hazardous materials into the environment would be reduced through implementation SmCP-2 EPMs HAZ-2 through HAZ-6. Therefore, Impact HAZ-2 would be less than significant with no mitigation required. Mitigation Measures: Impact HAZ-3: None required. The HR-2 Project would not emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within 0.25 miles of an existing or proposed school. There are no schools located with 0.25 miles of the HR-2 Project site. Therefore, no impact to existing or proposed schools is anticipated from the construction and operation and maintenance of the Project. Mitigation Measures: Impact HAZ-4: None required. The HR-2 Project would not be located on a site that is included on a list of hazardous materials sites compiled pursuant to Government Code Section The proposed Project components would not be located close to known hazardous waste sites or non-contaminated permitted facilities, including gas stations, underground storage tanks, and land disposal sites. Hudson Ranch Power II, LLC has conducted a Phase 1 environmental site assessment (Appendix H-1) and no recognized environmental conditions were identified on or within 1 mile of the proposed Project site (see Table 4.7-1). Prior to commencement of any grading activities, Hudson Ranch Power II, LLC would be required, by law, to use an Underground Service Alert organization to identify the location of underground utilities and pipelines. Therefore, no impact would result under this criterion. Hudson Ranch Power II and Simbol Calipatria II Final EIR

260 4.7 Hazardous Materials and Public Health Impact HAZ-5: The Project would not be located within an airport land use plan or, where such a plan has not been adopted, within 2 miles of a public airport or public use airport, and the Project would not result in a safety hazard for people residing or working in the Project area. The Calipatria Municipal Airport is the airport closest to the Project site and is located approximately 4.8 miles south of the site. The Project site is not located within the boundaries of an airport land use plan or within 2 miles of a public airport; thus, Project implementation would not introduce any aviation safety hazards for individuals working or residing in the Project area. Therefore, no impact would result under this criterion. Mitigation Measures: Impact HAZ-6: None required. The HR-2 Project is not located within the vicinity of a private airstrip, and the Project would not result in a safety hazard for people residing or working in the Project area. The nearest private airport, O Connell Brothers Airport, is located 16.1 miles south of the Project site; thus, Project implementation would not introduce any aviation safety hazards within the vicinity of the O Connell Brothers Airport for individuals working or residing in the Project area. Therefore, no impact would occur under this criterion. Mitigation Measures: Impact HAZ-7: None required. The HR-2 Project would not impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan. During well drilling, construction and operation activities that include equipment delivery and transport of large equipment including drill rigs would not interfere with emergency routes nor necessitate lane closures. Hudson Ranch Power II, LLC would implement best management practices (BMPs), such as the use of flaggers, identification of detours, and communications with stakeholders. Therefore, no impact would occur to emergency response plans and evacuation routes. Mitigation Measures: Impact HAZ-8: None required. The HR-2 Project would not expose people or structures to a significant risk of loss, injury, or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands. Hudson Ranch Power II and Simbol Calipatria II Final EIR

261 4.7 Hazardous Materials and Public Health The proposed Project would be constructed in a very low fire hazard area. Construction areas for the proposed Project would be grubbed of vegetation and graded prior to the staging of equipment, which would lessen the potential for a construction vehicle to start a fire. The risk of fire danger from the Project would be related to the combustion of native materials due to smoking, refueling, and operating vehicles and other equipment off roadways. Brushing activities for vegetation control and removal during construction and electrical arcing from power lines can create a fire hazard. During construction and operation, the HR-2 Project would implement fire suppression measures (HR-2 EPM HAZ-1) that would reduce the risk of fires that could be caused by the combustion of native materials due to smoking, refueling, or operating vehicles and other equipment off roadways. Well sites, construction sites, and access roads would be cleared of all vegetation. The cleared areas would be maintained during drilling, construction and operations. Water used for drilling would also be available for fire-fighting to further reduce impacts from fires occurring at the Project site, thereby reducing potential harm to workers. The fire protection system for the proposed Project would consist of an underground fire main and surface distribution equipment such as yard hydrants and hose houses, monitors around the perimeter of the cooling tower, automatic sprinklers for the turbine generator and auxiliary equipment. The Imperial County Fire Department and the Niland Fire Department would also be consulted as appropriate to review and approve the proposed firefighting water and freshwater pond facilities. With the implementation of HR-2 EPM HAZ-1 potential impacts from wildland fires would be less than significant. Mitigation Measures: None required. SMCP-2 IMPACTS AND MITIGATION MEASURES Impact HAZ-1: The SmCP-2 Project would not create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials. The SmCP-2 Project would involve the transport, handling, use and disposal of hazardous materials including unleaded gasoline, diesel fuel, oils, lubricants (e.g., motor oils, transmission fluids, and hydraulic fluids), paints, adhesives, solvents and other substances. Hudson Ranch Power II and Simbol Calipatria II Final EIR

262 4.7 Hazardous Materials and Public Health Transport Hazardous Materials During all phases of the SmCP-2 Project, moderate quantities of hazardous materials, including fuel and chemicals, would be transported to the Project site. Petroleum hydrocarbon fuels, chemical reagents, water treatment chemicals, and smaller quantities of other potentially hazardous chemicals would be transported to the plant site during operations. The Project would also generate hazardous material products, including hydrochloric acid, and hazardous wastes. These materials would be transported to and from the Project site by licensed hazardous material carriers and hazardous waste transporters. During plant operations, the proposed SmCP-2 Project would include truck deliveries of reagent chemicals, cooling tower treatment chemicals, consumptive media, product packaging materials, and fuel. It also includes the outgoing shipping of products and wastes. Multiple products would be packaged for off-site truck shipment to market. Products would be transported by freight truck on existing roadways to shipping distribution point(s) in the San Diego or greater Los Angeles areas. Hazardous material carriers and hazardous waste transporters are required by law to adhere to applicable local, state and federal regulations regarding proper truck signage indicating the materials being transported, carrying a shipping/waste manifest of the types and concentrations of materials being transported and other appropriate measures. Simbol, Inc. would communicate with the locally responsible emergency response agencies prior to the shipment of any bulk hazardous materials to or from the Project site. Hazardous material carriers are also responsible for their loads, reporting spills, and initiating appropriate emergency responses to releases of any transported hazardous materials from the point of origin up to the destination of the hazardous material delivery. Use of Hazardous Materials During construction and operation the SmCP-2 Project, hazardous materials would be stored in chemical storage containers. Secondary containment would be provided in all petroleum hydrocarbon and hazardous material storage areas. In general, all areas where hazardous materials are stored would have concrete ponds, be bermed or have curbs in order to prevent accidental releases. Containment areas would also be drained to appropriate collection areas or neutralization tanks for recycling or for off-site disposal (SMCP-2 EPM HAZ-6). A Hazardous Waste Permit, in compliance with Chapters 14 and 20 of CCR Title 22 would be obtained from the Department of Toxic Substance Control, for the containment areas. Hudson Ranch Power II and Simbol Calipatria II Final EIR

263 4.7 Hazardous Materials and Public Health Simbol, Inc would develop and implement a Stormwater Pollution Prevention Plans (SWPPP) and a Hazardous Materials Business Plan (HMBP) that would include procedures for the following: Hazardous materials handling, use, and storage; Emergency Response; Spill Prevention Control and Countermeasure (SPCC) Plan; Employee training; and Reporting and record keeping. All personnel working with chemicals would be trained in proper handling and emergency response to chemical spills or accidental releases. Adherence to Applicable California Occupational Safety and Health Administration Regulations and Standards (SmCP-2 EPM HAZ 2); Job Hazard Analyses (JHAs) for Each Job or Task (SmCP-2 EPM HAZ 3); Safety Showers and Eyewash Stations (SmCP-2 EPM HAZ 4); and Protective Pipeline Design and Detailed Inspection Routine (SmCP-2 EPM HAZ 5) would ensure the proper storage, handling of hazardous materials and would protect the workforce during construction and operation of the proposed Project. Disposal of Hazardous Materials Hazardous materials expected to be used during construction include paints, oil and lubricants, solvents, and welding materials. Used oil will be recycled, and oil or heavy metal contaminated materials (e.g., filters) requiring disposal will be transported to an off-site waste disposal facility authorized to accept the waste. Scale from pipe and equipment cleaning operations will be disposed of in a similar manner. After plant operations begins, most of the iron-silica stream may be converted to a product stream(s); however, a portion of the iron-silica material will be managed as hazardous waste. Similarly, the lead sulfide waste extracted from the brine stream will also be initially managed as hazardous waste. Any hazardous wastes generated would be collected in hazardous waste accumulation containers near the point of generation and moved daily to the contractor's 90-day hazardous waste storage area located on-site. The accumulated waste would subsequently be delivered to an authorized waste management facility. Hazardous wastes would be recycled or managed and disposed of properly in waste disposal facility authorized to accept the waste (SMCP-2 EPM UTIL-1). The storage, containment, handling, and use of these chemicals would be managed in accordance with applicable laws, ordinances, regulations, and standards. Compliance with applicable manufacturer specifications as well as federal and state regulations regarding hazardous materials/wastes is designed to ensure safety during the use, transport, storage, and disposal of hazardous materials. Hudson Ranch Power II and Simbol Calipatria II Final EIR

264 4.7 Hazardous Materials and Public Health With the implementation of SMCP-2 EPMs HAZ-2 through HAZ-5 and UTIL-1 Impact HAZ-1 would be less than significant. Mitigation Measures: Impact HAZ-2: None required. The SmCP-2 Project would not create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment. Hazards to the public or the environment could occur due to upset or accident involving the release of hazardous materials used, stored, or transported as part of the proposed Project. During construction, there could be accidental release or spills of hazardous materials (e.g., petroleum, oil, lubricants, paints, solvents, and herbicides). As discussed in Impact HAZ-1, multiple precautions would be implemented to ensure worker safety (EPMs HR-2 HAZ-2 through HAZ-5). During operations, upset conditions could result in a release of hydrogen sulfide contained in geothermal fluid or steam or an overflow of brine from multiple locations. To prevent a brine release, the brine that overflows the clarifiers or the thickener would be directed to the brine pond for temporary containment after which it would be processed for reinjection. All hazardous materials would be stored in chemical storage facilities designed for the characteristics of the chemicals to be stored. Diesel tanks with dual wall containment would be used for back up generators. Each area would have secondary containment equivalent to 110% of the volume of the material it stores. Therefore, if there was an accidental spill or release, these materials should be contained within the secondary containment area (HR-2 HAZ-6). While there is the potential for a significant hazard to the public or the environment following reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment, compliance with federal regulations, and those required by the State of California and County of Imperial and implementation of Simbol, Inc. s Emergency Response Plan (ERP) and Hazardous Materials Business Plan (HMBP) would help prevent upset conditions, ensure spills would be avoided, and immediately address spills or upset conditions if they occurred. All personnel working with chemicals would be trained in proper handling and emergency response to chemical spills or accidental releases. The potential for upset and accidents involving the release of hazardous materials into the environment would be reduced through implementation SmCP-2 EPMs HAZ-2 through HAZ-6. Therefore, Impact HAZ-2 would be less than significant with no mitigation required. Hudson Ranch Power II and Simbol Calipatria II Final EIR

265 4.7 Hazardous Materials and Public Health Mitigation Measures: Impact HAZ-3: None required. The SmCP-2 Project would not emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within 0.25 miles of an existing or proposed school. There are no schools located with 0.25 miles of the HR-2 Project site. Therefore, no impact to existing or proposed schools is anticipated from the construction and operation and maintenance of the Project. Mitigation Measures: Impact HAZ-4: None required. The SmCP-2 Project would not be located on a site that is included on a list of hazardous materials sites compiled pursuant to Government Code Section The proposed Project components would not be located near known hazardous waste sites or non-contaminated permitted facilities, including gas stations, underground storage tanks, and land disposal sites. Simbol, Inc. has conducted a Phase 1 environmental site assessment (Appendix H-2) and no recognized environmental conditions were identified within 1 mile of the proposed Project site (see Table 4.7-1). Prior to commencement of any grading activities, Simbol, Inc. would be required, by law, to use an Underground Service Alert organization to identify the location of underground utilities. Therefore, no impact would result under this criterion. Impact HAZ-5: The SmCP-2 Project would not be located within an airport land use plan or, where such a plan has not been adopted, within 2 miles of a public airport or public use airport, and the Project would not result in a safety hazard for people residing or working in the Project area. The Calipatria Municipal Airport is the closest airport to the Project site and is located approximately 4.8 miles south of the site. The Project site is not located within the boundaries of an airport land use plan or within 2 miles of a public airport; thus, Project implementation would not introduce any aviation safety hazards for individuals working or residing in the Project area. Therefore, no impact would occur under this criterion. Mitigation Measures: Impact HAZ-6: None required. The SmCP-2 Project is not located within the vicinity of a private airstrip, and the Project would not result in a safety hazard for people residing or working in the Project area. Hudson Ranch Power II and Simbol Calipatria II Final EIR

266 4.7 Hazardous Materials and Public Health The nearest private airport, O Connell Brothers Airport, is located 16.1 miles south of the Project site; thus, Project implementation would not introduce any aviation safety hazards within the vicinity of the O Connell Brothers Airport for individuals working or residing in the Project area. Therefore, no impact would occur under this criterion. Mitigation Measures: Impact HAZ-7: None required. The SmCP-2 Project would not impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan. During construction and operation activities that include equipment delivery and transport of large equipment would not interfere with emergency routes nor necessitate lane closures. Simbol, Inc. would implement best management practices (BMPs), such as the use of flaggers, identification of detours, and communications with stakeholders. Therefore, no impact would occur to emergency response plans and evacuation routes. Mitigation Measures: Impact HAZ-8: None required. The SmCP-2 Project would not expose people or structures to a significant risk of loss, injury, or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands. The proposed Project would be constructed in a very low fire hazard area. Construction areas for the proposed Project would be grubbed of vegetation and graded prior to the staging of equipment, which would lessen the potential for a construction vehicle to start a fire. The risk of fire danger from the Project would be related to the combustion of native materials due to smoking, refueling, and operating vehicles and other equipment off roadways. Brushing activities for vegetation control and removal during construction and electrical arcing from power lines can create a fire hazard. During construction, the SmCP-2 Project would implement Fire Prevention measures (SmCP-2 EPM HAZ-1) that would reduce the risk of fires that could be caused by the combustion of native materials due to smoking, refueling, or operating vehicles and other equipment off roadways. During operation, a Fire Suppression System (SmCP-2 EPM HAZ-7) that would further reduce impacts from fires occurring at the Project site, thereby reducing potential harm to workers. The fire protection system for the proposed Project would consist of an underground fire main and surface distribution equipment such as yard hydrants Hudson Ranch Power II and Simbol Calipatria II Final EIR

267 4.7 Hazardous Materials and Public Health and hose houses, and monitors around the perimeter of the cooling tower. The Imperial County Fire Department and the Niland Fire Department would also be consulted as appropriate to review and approve the proposed firefighting water and freshwater pond facilities. With the implementation of SmCP-2 EPM HAZ-1 and HAZ-7 potential impacts from wildland fires less than significant. Mitigation Measures: None required REFERENCES AirNav Imperial County Airports. Online at: Accessed July 15, California Department of Forestry and Fire Protection (Calfire) Fire Prevention. Imperial County Fhsz Map State Responsibility Area (SRA): Online at: Fhsz_Maps/Fhsz_Maps_Imperial.Php. Accessed July 28, California Department of Toxic Substances Control (DTSC) Envirostor. Project Search Results for Imperial County. Online at: Accessed June County of Imperial Imperial County Multi-Jurisdictional Hazard Mitigation Plan. January General Plan Geothermal Alternative Energy and Transmission Element a. General Plan County Seismic and Public Safety Element. May County of Imperial Airport Land Use Commission Imperial County Airport Land Use Compatibility Plan (ALUCP). Imperial Office of Emergency Services Imperial County Operational Area Emergency Operations Plan (EOP). July Nichols, D Personal communication (telephone) between Lt. Coronel Dan Nichols, C-17 Pilot of 452nd OSS/OSK, March Airforce Base, and Andrea Castillo, Ecology and Environment, Inc. June 15, OurAirports.com Pilot information for O'Connell Brothers Airport. Online at: June 16, Underground Service Alert California Law, Government Code Online at: Accessed May 14, Hudson Ranch Power II and Simbol Calipatria II Final EIR

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269 4.8 Hydrology and Water Quality 4.8 HYDROLOGY AND WATER QUALITY This section discusses the existing hydrologic setting and potential impacts on hydrology and water quality that may occur as a result of construction, operation, and maintenance of the proposed Projects. Scoping Issues Addressed During the scoping period for the Projects, two public scoping meetings were conducted and written comments were received from agencies and the public. Comments pertaining to this resource area were received in three letters: one from the Colorado River Board (CRB), one from the Imperial Irrigation District (IID) and one from the California Department of Fish and Game (CDFG). The following issues related to hydrology and water quality were raised during the scoping period and are addressed in this section: The CRB would like the County to check with the IID regarding any specific requirements IID may have related to the following: Water diverted from IID canals during well drilling and facility construction, and water use during project operation. An Encroachment Permit from IID. The Project s connection to IID s interconnection transmission line/power grid system. IID water facilities O Lateral and N Drain could be impacted. Any construction or operation on IID property or within its existing and proposed right-of way (ROW) or easements will require an encroachment permit. Grading, construction, and de-silting operations will be completed under a construction storm water general permit with erosion-related best management practices (BMPs) in use. It is recommended that downstream flows be monitored for a potential increase in downstream sedimentation with corrective measures to be planned and implemented, if needed. The Projects water supply requirements can only be provided for under the IID s Interim Water Supply Policy; there is no landlord allocation available for industrial purposes. All new nonagricultural water projects supply requests are processed in accordance with the Interim Water Supply Policy. In order to obtain a water supply from IID, Hudson Ranch Power II LLC (applicant) will be required to enter into a water supply agreement with IID and comply with all applicable IID policies and regulations. Such policies and regulations require that all potential environmental and water supply impacts of the proposed projects are adequately assessed, appropriate mitigation developed, and Hudson Ranch Power II and Simbol Calipatria II Final EIR

270 4.8 Hydrology and Water Quality appropriate conditions adopted in accordance with the relevant land use permitting/approving agencies (refer to Section 4.15 Utilities). The Draft EIR should address impacts on IID s drains. One-third of the water delivered to agricultural users is discharged into the IID s drainage system. Reduction in the field drainage from land-use conversion has an incremental impact on both drain water quality and volume of the impacted drain and subsequent drainage path to the Salton Sea. This affects drainage habitat (flora and fauna) and the elevation of the Salton Sea (shoreline habitat and exposed acreage, which in turn may have air quality issues). Additionally, certain drains that run directly to the Salton Sea have been identified as desert pupfish (Cyprinodon macularius) drains that require additional protections under state and federal Endangered Species Acts (ESAs). The following issues related to hydrologic and water resources were raised by the California Department of Fish and Game (CDFG) and are addressed in this section: The Department opposes the elimination of watercourses and/or their channelization or conversion to subsurface drains. All wetlands and watercourses, whether intermittent or perennial, must be retained and provided with substantial setbacks which preserve the riparian and aquatic values and maintain their value to on-site and off-site wildlife populations. The Department is emphasizing in comment letters on projects with impacts to lakes or streambeds that alternatives and mitigation measures must be addressed in CEQA certified documents prior to submittal of an application of a Streambed Alteration Agreement (SAA). Any information which is supplied to the Department after the CEQA process is complete will not have been subject to the public review requirements of CEQA. In order for the Department to process a SAA agreement, the CEQA-certified documents must include an analysis of the impacts of the proposed Project on the lake or streambed, an analysis of the biological resources present on the site, copies of biological studies conducted on the site, biological survey methodology, and a discussion of any alternative, avoidance, or mitigation measures which will reduce the impacts of the proposed development to a level of insignificance. In addition, a discussion of potential adverse impacts from any increased runoff, sedimentation, soil erosion, and/or pollutants on streams and watercourses on or near the Project site, with mitigation measures proposed to alleviate such impacts must be included in the CEQA certified documents. Applicant s Reports and Survey Results Information used in preparing this section and in evaluating potential impacts on water quality resources was derived from a number of sources, including the SB 610 Water Supply Assessment (WSA) prepared for the proposed Hudson Ranch Power II Geothermal Flash Power Plant and the Simbol Calipatria II Plant Project, by Pangaea Land Consultants, Inc. (Pangaea) on March 15, 2012 (Appendix I). Hudson Ranch Power II and Simbol Calipatria II Final EIR

271 4.8 Hydrology and Water Quality EXISTING SETTING REGIONAL SETTING Hydrology The Project site is located within the Salton Sea Transboundary Watershed (U.S. Geological Survey [USGS] Hydrologic Unit Code [HUC] ) and the Brawley hydrologic area of the Imperial hydrologic unit in the Imperial Valley Planning Area (see Figure 4.8-1). Surface water quality is a significant issue within and around the Salton Sea watershed. This watershed has been identified as a Category I impaired watershed under the 1997 California United Watershed Assessment (California Environmental Protection Agency [CalEPA] 2000). Poor surface water quality in the area is generally attributable to agricultural drainage containing high concentrations of nutrients and salts and to the discharge of the highly polluted New and Alamo rivers into the Salton Sea. The area also receives the majority of its irrigation and potable water from the Colorado River through a series of canals diverted from the main branch of the Colorado River. The water quality of the Colorado River is degraded from its headwaters to its mouth by high salinity, carrying an annual average salt load of approximately 9 million tons past Hoover Dam, the uppermost location at which numeric criteria have been established (Colorado River Basin Salinity Control Forum 2011). Groundwater The Project site lies within the Colorado Desert Province. The principal aquifer media in the Colorado Desert province are volcanic rocks, carbonates, and basin-fill sediments. Together, these aquifers are called the Basin and Range aquifer system. The Basin and Range physiographic province is classified at the regional level into hydrographic basins, depending on geologic drainage features such as the drainage boundaries of a large river or stream. Groundwater in the East Salton Sea groundwater basin moves from the recharge areas east of Imperial Valley and the Salton Sea toward the axis of the valley and converges upon the Salton Sea or the New and Alamo rivers (Alward and Shatz 2009). Recharge to the East Salton Sea groundwater basin is highly seasonal and comes primarily from runoff from surrounding mountain ranges. There are no known groundwater wells within the Project site or the immediate vicinity. Data on groundwater in the Project area are limited because there are few wells: groundwater in this part of the Colorado Desert and in the Imperial Valley is generally of poor quality due to high total dissolved solids (TDS) resulting from agricultural runoff, and well yields of clean water are relatively quite low (Alward and Shatz 2009). Historically, there has been little need to investigate and develop the groundwater in the area due to the availability and low cost of imported surface water (Alward and Shatz 2009). Most studies of groundwater conditions in the central area of Imperial Valley focus exclusively on the upper 1,000 feet of water-bearing strata (Alward and Shatz 2009). Studies show that groundwater in the central part of the Imperial Valley generally occurs in two water-bearing zones: (1) a shallow (0 to 300 feet), unconfined aquifer that is bounded at depth by a low permeability clay (aquitard); and (2) an intermediate (300 to 1,500 Hudson Ranch Power II and Simbol Calipatria II Final EIR

272 4.8 Hydrology and Water Quality feet), semi-confined aquifer that is bounded above by the aquitard and at depth by older marine and nonmarine sediments (Alward and Shatz 2009). A third, deeper aquifer has been identified by some authors and may be present at depths of more than 1,500 feet, but it is likely not productive in terms of water supply resources (Alward and Shatz 2009). Project Sites The Project sites are situated in an unincorporated area of County of Imperial approximately 2.3 miles west-southwest of the Town of Niland, California (see Chapter 3, Project Description, Figure 3-1). The Project sites are located on a 245-acre parcel of private land that has been developed for agricultural uses (irrigated agricultural) and surface water has been provided by IID for the agricultural uses on the Project site (see discussion in Section 4.15, Utilities). At the time of publication of the NOP, the agricultural fields were fallow. IID canals flow east to west on the north edges of the fields with the O Lateral south of McDonald Road and the N Lateral south of Schrimpf Road (see Chapter 3, Project Description, Figure 3-3). Local uses of surface waters include supplying extensive irrigation for crops in the Imperial Valley; recreation and wildlife. The IID has implemented an interim water supply policy for non-agricultural projects within its service area that require water supply. The policy designates up to 25,000 acre-feet per year (AFY) for water supply for non-agricultural projects and requires the submission of a water supply application, as well as payment of application, reservation, and development fees based on the requested water quantity (IID 2009). Adjacent Areas Adjacent properties to the north, east, and south contain existing and proposed IID managed marshlands. Irrigated farmland is also located within the area surrounding the Project sites. A commercial algae production facility is located south of the Project sites. This facility includes a mobile home which, at the time of the publication of the NOP, served as a residence for the facility caretaker. The commercial algae facility is no longer in operation and is not part of the proposed Projects. The nearest residence is approximately 0.5 miles north-northeast of the Project site, along English Road. Energy Source (Hudson Ranch Power II, LLC s parent company) owns the home and is allowing the current tenant to remain in the residence until Fall This residence would be demolished prior to the start of construction of either the HR-2 or SmCP-2 Project. The next closest residence is located 1.4 miles northwest of the Project. Hudson Ranch Power II and Simbol Calipatria II Final EIR

273 Path: \\prtbhp1\gis\sandiego\hudsonranch_geothermal\maps\mxds\figure_4_8-1_hydrologic_areas_map_jc.mxd Hudson Ranch Power II and Simbol Calipatria II Project Sites C H O C Iris Wash O L A T E RIVERSIDE COUNTY IMPERIAL COUNTY Salton Sea NILAND East Highline Canal M O U N T A I N S New River AlamoRi ver CALIPATRIA Data Source: Natural Resource Conservation Service (NRCS), 2008 Riverside County Imperial County MEXICO HR-2 and SmCP-2 Project Sites HUC 10 Boundary Brawley Hydrologic Area Cities Hudson Ranch Power II CUP #G & Simbol Calipartria II CUP # Hydrologic Area Figure Miles

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275 4.8 Hydrology and Water Quality The Salton Sea is a significant surface water feature that is located approximately 1.5 miles west and downstream of the Project site. It is one of the world's largest inland seas and is also one of the earth s lowest locations, at 227 feet below sea level (California State Parks 2010). By virtue of its location in the Colorado Desert ecosystem, the Salton Sea receives minimal inflow from rain (average annual precipitation of 5.5 inches per year). The Salton Sea is mainly an agricultural drainage reservoir, a closed system with no outlet; 90% of the entire inflow is commercial agricultural runoff containing high concentrations of phosphates, nitrates, and salts from the Imperial, Coachella, and Mexicali valleys (Salton Sea Authority 2010). Evaporation has caused the Salton Sea s salinity to increase and, as a result, water quality conditions continue to decline and the Salton Sea cannot meet the beneficial uses assigned to it. The Salton Sea National Wildlife Refuge was designated in 1930, but recent bird die-offs suggest that declining water quality is adversely impacting avian populations (CalEPA 2011). Geothermal Resources Plate motion in the Salton Trough along major faults, such as the San Jacinto and Imperial faults, create local geothermal hot spots due to magmatic intrusions in the pull-apart regions (Newmark et al. 1988). Several geothermal energy fields such as the Salton Sea, Cerro Prieto, and Brawley geothermal fields are located at these hot spots. Here, water temperatures at depths of 8,000 feet can exceed 680 degrees Fahrenheit ( F). While several faults penetrate to the surface, most of the tectonically induced faults are located at depth, well below the shallow strata in which most low temperature groundwater is found (Lawrence Livermore 2008). Geothermal fluids below 7,000 feet from the Salton Sea area can vary in TDS from 7,000 milligrams per liter (mg/l) to more than 200,000 mg/l and can contain some suspended solids REGULATORY SETTING FEDERAL AND STATE Federal Water Pollution Control Act (Clean Water Act) The Clean Water Act (CWA), 33 U.S.C , regulates discharges of pollutants into the waters of the United States. It also includes requirements to set water quality standards for all contaminants in surface waters. The CWA makes it unlawful for any person to discharge any pollutant from a point source into navigable waters without first obtaining a permit under its provision. In 1972, Section 404 of the CWA established a program to regulate the discharge of dredged or fill material into waters of the United States. The Rivers and Harbors Act of 1899 defined navigable waters of the United States as those waters that are subject to the ebb and flow of the tides and/or are presently used, or have been used in the past, or maybe susceptible to use to transport interstate or foreign commerce." The CWA built on this definition and defined waters of the United States to include tributaries to navigable waters, interstate wetlands, wetlands that could affect interstate or foreign commerce, and wetlands adjacent to other waters of the United States. Hudson Ranch Power II and Simbol Calipatria II Final EIR

276 4.8 Hydrology and Water Quality Sections 401 and 402 Permitting Section 401(a)(1) of the CWA specifies that any applicant for a federal license or permit to conduct any activity, including, but not limited to, the construction or operation of facilities that may result in any discharge into navigable waters, shall provide the federal licensing or permitting agency a certification from the state in which the discharge originates or will originate, or, if appropriate, from the interstate water pollution control agency having jurisdiction over the navigable water at the point where the discharge originates or will originate, that any such discharge will comply with the applicable provisions of the CWA. Section 402 of the CWA prohibits the discharge of pollutants from point sources to waters of the United States, unless authorized under a National Pollutant Discharge Elimination System (NPDES) permit. NPDES permits can be issued by the U.S. Environmental Protection Agency (EPA) or by agencies in delegated states. The NPDES permit program has been delegated in California to the State Water Resources Control Board (SWRCB). Safe Drinking Water Act The Safe Drinking Water Act, 42 U.S.C. 300f et seq., was originally passed by Congress in 1974 to protect public health by regulating the nation s public drinking water supply. The law was amended in 1986 and 1996 and requires many actions to protect drinking water and its sources, including rivers, lakes, reservoirs, springs, and groundwater wells. This act authorizes the EPA to set national health-based standards for drinking water to protect against both naturally occurring and man-made contaminants that may be found in drinking water. The act also mandates that a groundwater/wellhead protection program be developed by each state in order to protect groundwater resources that are a source of public drinking water. Consolidated Decree (Arizona v. California et al., 547 U.S. 150 [2006]) The Consolidated Decree in Arizona v. California et al., 547 U.S. 150 (2006), includes the determination of allocations of Colorado River water (consistent with those established in the Colorado River Compact), the approval of the construction of the Boulder Canyon Project (per the Boulder Canyon Project Act of 1929), the framework for the operation of federally owned dams on the Colorado River and tributaries, and the definition of the system of water rights that characterizes allocation. The decree states that the consumptive use of water means "diversion from the stream less such return flow thereto as is available for consumptive use in the United States or in satisfaction of the Mexican treaty obligation" and consumptive use "includes all consumptive uses of water of the mainstream, including water drawn from the mainstream by underground pumping." The Colorado River Compact, signed in 1922, is an agreement that apportions Colorado River water among seven states, including the Upper Division states of Colorado, New Mexico, Utah, and Wyoming, and the Lower Division states of Arizona, California, and Nevada. Each division is allocated 7,500,000 AFY. The states within each division negotiated their allotments. Currently, California is allotted 4.4 million AFY. Hudson Ranch Power II and Simbol Calipatria II Final EIR

277 4.8 Hydrology and Water Quality Of this allotment, IID, the water supplier to the Project site, has agreed to cap its Colorado River water use at 3.1 million AFY based on the 2003 Quantification Settlement Agreement (QSA). In 2007, the Department of the Interior implemented an interim set of guidelines, in effect until 2026, for managing water allotments to the Lower Division states during shortages in response to low river flows related to a multi-year drought (Department of the Interior 2007). The guidelines include three levels of shortages contingent on the elevation of Lake Mead, each of which carry a specific allotment reduction to the Lower Division states; however, California retains its 4.4-million AFY allotment in all three scenarios. National Flood Insurance Program The National Flood Insurance Program (NFIP) is administered by FEMA, a component of the U.S. Department of Homeland Security. The NFIP is a federal program enabling property owners in participating communities to purchase insurance protection against losses from flooding. Participation in the NFIP is based on an agreement between local communities and the federal government, which states that if a community adopts and enforces a floodplain management ordinance to reduce future flood risks to new construction in special flood hazard areas, the federal government makes flood insurance available within the community as a financial protection against flood losses. The Federal Emergency Management Agency (FEMA) identifies flood hazard areas throughout the United States and its territories on Flood Hazard Boundary Maps, Flood Insurance Rate Maps, and Flood Boundary and Floodway Maps. Several areas of flood hazards are commonly identified on these maps. One of these areas is the special flood hazard area, or high-risk area, defined as any land that would be inundated by a flood having a 1% chance of occurring in any given year (also referred to as a base flood or 100-year flood). California Porter-Cologne Water Quality Control Act The Porter-Cologne Water Quality Control Act, passed in 1969, regulates surface water and groundwater within the state and also assigns responsibility for implementing CWA Sections 401 through 402 and 303(d) in California. It established the SWRCB and divided the state into nine regions, each overseen by an RWQCB. The SWRCB is the primary state agency responsible for protecting the quality of the state s surface and groundwater supplies, but much of its daily implementation authority is delegated to the nine RWQCBs. The Project sites are located within the jurisdiction of the CRB RWQCB. The regional boards govern the protection of surface waters by assessing the attainment of designated beneficial uses; 23 uses are currently established for surface waters within the state. General Permit for Stormwater Discharges Associated with Construction CWA Section 402 regulates construction-related storm water discharges to surface waters through the NPDES program. In California, the EPA has delegated authority to the SWRCB for administering the NPDES program through the RWQCBs and has developed a General Permit for Stormwater Discharges Associated with Construction Activity (Water Quality Order No DWQ (NPDES No. Hudson Ranch Power II and Simbol Calipatria II Final EIR

278 4.8 Hydrology and Water Quality CAS000002)). Projects that disturb 1 or more acre of soil, or projects that disturb less than 1-acre but are part of a larger common plan of development that, in total, disturbs 1 or more acres are required to obtain this permit from the CRB RWQCB. Construction activities subject to this permit include clearing, grading, and other ground disturbances such as stockpiling or excavation, but do not include regular maintenance activities performed to restore the original line, grade, or capacity of the facility. The General Permit requires the development and implementation of a Stormwater Pollution Prevention Plan (SWPPP). The SWPPP should contain a site map that shows the construction site perimeter, existing and proposed buildings, lots, roadways, storm water collection and discharge points, general topography both before and after construction, and drainage patterns across the proposed plan. The SWPPP must list Best Management Practices (BMPs) the discharger will use to protect storm water runoff and the placement of those BMPs. Additionally, the SWPPP must contain a visual monitoring program, a chemical monitoring program for "non-visible" pollutants, and a sediment monitoring plan if the site discharges directly to a water body included on the 303(d) list for sediment. Section A of the General Permit describes the elements that must be contained in a SWPPP; however, if hazardous materials are maintained on-site, constant monitoring is required regardless of the status of BMPs. Groundwater Protection Areas and Wellhead Protection The California Department of Public Health established the Drinking Water Source Assessment and Protection Program, which provides guidance to local level agencies for protecting the sources surface water and groundwater drinking water supplies. The California Department of Pesticide Regulation s Groundwater Protection Program is charged with identifying areas sensitive to pesticide contamination and develops mitigation measures and regulations to prevent pesticide movement into groundwater systems. California Laws for Conservation of Geothermal Resources The California Division of Oil, Gas, and Geothermal Resources (CDOGGR) is primarily responsible for permitting and regulation of geothermal energy development under Public Resources Code (PRC) Title 14, Division 2, Chapter 4, and the Safe Drinking Water Act (SDWA) on private and state-owned lands within California. The Project site is within the jurisdiction of the District 1 office. Additionally, the geothermal well drilling and injection program will be submitted to the CRB RWQCB and to the public for review and comment. LOCAL Imperial Irrigation District Water Planning Efforts Basin management for the Imperial Valley is administered by the Imperial Irrigation District (IID). With more than 3,000 miles of canals and drains, the IID is the largest irrigation district in the Nation (IID 2010). The IID water service area extends from the southern half of the Salton Sea to the U.S. Mexico border. The IID Water Department is responsible for the timely operation and maintenance of the extensive open channel Hudson Ranch Power II and Simbol Calipatria II Final EIR

279 4.8 Hydrology and Water Quality system, and delivers up to 3.1 million AFY of IID s Colorado River entitlement to nearly 500,000-acres of irrigated land. Of the water IID transports, approximately 97% is used for agricultural purposes (IID 2010). Quantification Settlement Agreement (2003) Due to competing interests regarding water rights in Southern California, all major Southern California water agencies, including federal and state agencies, negotiated a Quantification Settlement Agreement (QSA) with IID in October At that time, IID agreed to 35 to 75 years of water conservation, which would result in millions of acre-feet of conserved water for urban uses in southern California. Under the QSA and related transfer agreements, IID agreed to cap of 3.1 million AFY of Colorado River water and a schedule for creating conserved water for transfer and environmental mitigation (Pangaea 2012). The QSA and IID water rights are described in further detail in Appendix I. Strategic Plan (2008) In 2008, the IID Board of Directors adopted the IID Strategic Plan, in part due to increased water demands of proposed geothermal projects and other economic development in the region. The objectives of the IID Strategic Plan were to: Prevent impacts to existing agricultural users of water and protect IID water rights. Define cost-effective projects and equitable cost-sharing agreements with those entities and water users that would receive benefits from proposed water management actions. Identify projects that are consistent with existing agreements on use and management of the Colorado River, including the QSA and IID transfer agreements. Recognize and resolve potential conflicts over use of available water resources. Promote economic development consistent with IID policies, standards, and guidelines for new consumptive uses of water. The IID Strategic Plan also included an objective to develop an Integrated Water Resources Management Plan (IWRMP) by the end of Interim Water Supply Policy (2009) Pending adoption of the IWRMP, the IID adopted the Interim Water Supply Policy (IWSP) for Non- Agricultural Projects in 2009 (IID 2009). All non-agricultural projects that require a raw water supply from IID must apply for water service pursuant to the IWSP, which allocates 25,000 AFY for non-agricultural projects within the IID service area. Proposed non-agricultural projects may be required to pay a Reservation Fee, further described below. The reserved water shall be available for other users until such non-agricultural projects are implemented and require the reserved water supply. The IWSP will remain in effect pending Hudson Ranch Power II and Simbol Calipatria II Final EIR

280 4.8 Hydrology and Water Quality adoption of the Integrated Regional Water Management Plan, which is expected to make available up to 50,000 acre-feet per year of water for similar uses. Integrated Regional Water Management Plan Although the IWRMP was originally intended to be completed by 2009 (according to the IID Strategic Plan), as of the publication of the NOP, the IWRMP had not yet been finalized. However, the Draft IWRMP was adopted by the IID Board of Directors on September 23, 2008 and updated November 17, The effort is being managed by the Imperial Regional Water Management Group, consisting of elected representatives of the IID, County of Imperial, and local cities. The goal of the plan is to provide a strategic road map that defines a portfolio of water projects, demand management measures and policies intended to deliver a reliable water supply for municipal, commercial and industrial water users over a 37-year planning horizon from 2010 to 2047 (IID 2010). The IWRMP Plan describes the existing district supplies, including the facilities, entitlements and contracts that define what water is available to meet current and future demands and seeks to identify a Water Supply Portfolio of 100,000 acre-feet per year to meet future MCI and environmental water demands through When completed, the IRWMP will include recommendations for implementing various programs and projects including storing Colorado River water in the Salton Sea groundwater basin, developing local groundwater supplies, desalinating irrigation drainwater, reusing wastewater, and developing demand-management programs. Temporary Land Conversion Fallowing Policy (2012) On May 8, 2012, the IID adopted a Temporary Land Conversion Fallowing Policy, which addresses projects that will remove land from agricultural production on a long-term temporary basis. Because water demands for certain non-agricultural projects are typically less than that required for agricultural use; this reduced demand allows additional water to be made available for other users under IID's annual consumptive use cap. This conserved water can then be used to satisfy IID s conserved water transfer obligations and for environmental mitigation purposes. Certain non-agricultural projects temporarily remove land from agricultural production and the number of proposed non-agricultural projects is anticipated to increase as the economy of Imperial County diversifies and develops to address these new business opportunities (IID, 2012). If it appears to IID, that the proposed water usage for a non-agricultural project applying for water supply will require less water than the historical water usage associated with the agricultural production on that land, IID will determine, in its sole discretion, that the proposed project is suitable for temporary land conversion fallowing to create conserved water for transfer, or environmental mitigation purposes. In this case, the water supply agreement for a non-agricultural project will include a temporary land conversion fallowing agreement, which requires that the project developer, lessee and landowner return the project land to agricultural production. Hudson Ranch Power II and Simbol Calipatria II Final EIR

281 4.8 Hydrology and Water Quality County of Imperial Floodplain Management County of Imperial requires that a grading/drainage study be conducted for the proposed Projects to provide for property grading and drainage control, which shall also include prevention of sedimentation or damage to off-site properties. These studies are reviewed by the CRB RWQCB, the IID, and Imperial County Public Works Department. The IID regulates and controls the use of irrigation water throughout the County. County of Imperial General Plan The County of Imperial General Plan Conservation and Open Space Element and the Water Element contain goals, objectives, and policies related to water quality and hydrology. Table identifies applicable General Plan policies related to water quality and hydrology and addresses the SmCP-2 Projects consistency with the General Plan policies. TABLE HR-2 AND SMCP-2 PROJECTS CONSISTENCY WITH GENERAL PLAN WATER AND HYDROLOGY GOALS AND OBJECTIVES GENERAL PLAN POLICIES CONSISTENCY ANALYSIS WATER ELEMENT (WE) WE Policy 1. Adequate Domestic Water Supply. The efficient regulation of land uses that economize on water consumption enhances equivalent dwelling unit demand for domestic water resources, and that makes available affordable resources for continued urban growth. Yes A water supply assessment was prepared for the proposed Projects (Pangaea Land Consultants 2012). The SB 610 Water Supply Assessment determined there is adequate water from the IID available for the proposed Projects water needs. During construction the proposed Projects would utilize water from the IID obtained via water supply agreements, at a rate of 50,000 gallons/day. During operations, the proposed HR-2 Project would require 3,940 AFY. Approximately 98% of the demand for cooling tower make-up water (2,740 AFY) would be provided from HR-2 s steam condensate. The proposed SmCP-2 Project would require 800 AFY of IID water during operations and additional water from steam condensate from HR-2. Both Projects have incorporated water conservation measures that would be implemented during operations. The HR-2 Project would incorporate geothermal steam condensate to supply approximately 98% of the cooling tower make-up water demand (HR-2 WPM WQ-1). The SmCP-2 would also use steam condensate from the HR-2 Project to minimize operational water demand from outside sources when possible SmCP-2 WQ-1). Hudson Ranch Power II and Simbol Calipatria II Final EIR

282 4.8 Hydrology and Water Quality TABLE HR-2 AND SMCP-2 PROJECTS CONSISTENCY WITH GENERAL PLAN WATER AND HYDROLOGY GOALS AND OBJECTIVES GENERAL PLAN POLICIES CONSISTENCY ANALYSIS WE Policy 4. Protection of Water Resources from Hazardous Materials Program: The County of Imperial shall make every reasonable effort to limit or preclude the degradation of all groundwater and surface water resources in the County. WE Policy 4. Protection of Water Resources from Hazardous Materials Goal 4: The County of Imperial will adopt and implement ordinances, policies an guidelines that assure the safety of County ground and surface waters from toxic or hazardous materials and wastes. Yes Yes The proposed HR-2 and SmCP-2 Projects have been designed to include environmental protection measures described in Section 4.8.3, that would limit the contamination and degradation of surface and groundwater resources from construction and operation activities. In addition, both projects will be required to comply with the NPDES construction stormwater pollution prevention program through preparation and implementation of a SWPPP, along with implementation of the required best management practices (MM WQ-1.1). The HR-2 and SmCP-2 Projects are subject to federal and state water quality regulations of the CRB RWQCB. SWPPPs will be required during construction of the proposed Projects. Under MM WQ-1.1, a SWPPP will be prepared for each project, which will include BMPs and recommendations to ensure that potential water quality impacts during construction are avoided and/or minimized. In addition, the HR-2 Project has incorporated into its design, specific EPMs to protect surface and groundwater from toxic or hazardous materials and wastes during operations. These include lining and monitoring the brine pond so that contents would not leach into the soil (HR-2 EPM WQ-2 and WQ-3); providing extra protection and monitoring of well casings and production well-heads (HR-2 EPM WQ-5); conducting routine inspections of pipelines (HR-2 EPM WQ-6); installing emergency shut-off valves and isolation valves on wellheads (HR-2 EPM WQ-7); using only non-hazardous drilling mud and storing waste drill mud and drill cuttings in the lined containment basin (HR-2 EPM WQ-8 and WQ-9); and providing secondary containment where accidental releases of hazardous and acutely hazardous materials could occur (HR-2 EPM HAZ-3). Likewise, the proposed SmCP-2 Project has incorporated into its design, specific EPMs to protect surface and groundwater from toxic or hazardous materials and wastes, including construction of delivery/return pipelines to prevent accidental releases (SMCP-2 EPM HAZ-5); and providing secondary containment where accidental releases of hazardous and acutely hazardous materials could occur (SmCP-2 EPM HAZ-6). Hudson Ranch Power II and Simbol Calipatria II Final EIR

283 4.8 Hydrology and Water Quality TABLE HR-2 AND SMCP-2 PROJECTS CONSISTENCY WITH GENERAL PLAN WATER AND HYDROLOGY GOALS AND OBJECTIVES GENERAL PLAN POLICIES CONSISTENCY ANALYSIS Program: All development proposals brought before the County of Imperial shall be reviewed for potential adverse effects on water quality, and shall be required to implement appropriate mitigation measures for any significant impacts. Yes Potential impacts on water quality and quantity that would result from implementation of the proposed HR- 2 and SmCP-2 projects have been addressed in this EIR (Section 4.8 Hydrology and Water Quality and Section 4.15 Public Utilities, respectively). Implementation of the EPMs identified in Section 4.8.3, along with MM WQ-1.1 (Preparation and Implementation of a SWPPP) would ensure that ground and surface waters would not be degraded and that water quality impacts resulting from construction and operation activities are reduced to below a level of significance. Goal 2: Long-term viability of the Salton Sea, Colorado River, and other surface waters in the County will be protected for sustaining wildlife and a broad range of ecological communities. Yes An SB 610 Water Supply Assessment (WSA) has been prepared for the proposed HR-2 and SmCP-2 projects (Pangaea Land Consultants, 2012). During construction and operations, the proposed Projects would utilize water from the IID, obtained via water supply agreements. The WSA determined that there would be sufficient water available to meet both projects demand through the year 2045 (i.e. throughout the 30-year life of each project). The HR-2 and SmCP-2 Projects are subject to the federal and state water quality regulations of the Colorado River Basin RWQCB. Preparation an implementation of stormwater pollution prevention plan (SWPPP) will be required under MM WQ-1.1. In addition, SmCP-2 would implement a construction phase erosion control plan (SmCP-2 EPM WQ-2) to control run-off during construction. CONSERVATION AND OPEN SPACE ELEMENT (COSE) COSE Goal 8: The County will conserve, protect, and enhance the water resources in the planning area. Yes To control run-off after construction is complete, the Project site would be graded to direct surface water run-off into the proposed storm water retention basin, which would be shared by both Projects (HR-2 EPM WQ-4 and SmCP-2 EPM WQ-3). Additional EPMs, listed in Section 4.8.3, would prevent surface and/or groundwater contamination from drilling, potential pipeline releases and operation of both the geothermal and mineral extraction plant. These measures would reduce adverse surface water quality impacts during construction and operation, and thus would not impact water quality in the Salton Sea. See Response for Policy 4, above. Hudson Ranch Power II and Simbol Calipatria II Final EIR

284 4.8 Hydrology and Water Quality TABLE HR-2 AND SMCP-2 PROJECTS CONSISTENCY WITH GENERAL PLAN WATER AND HYDROLOGY GOALS AND OBJECTIVES GENERAL PLAN POLICIES CONSISTENCY ANALYSIS COSE Objective 8.4: Ensure the use and protection of rivers and other waterways in the County. Ensure proper drainage and provide accommodation for storm water runoff from urban and other developed areas in manners compatible with requirements to provide necessary agricultural drainage. Yes Production and injection pipelines would be routinely inspected. Piping at each production wellhead would have an emergency shutoff valve to prevent potential releases. Cemented concentric steel and alloy casing will prevent produced fluids from polluting surface water and groundwater. Waste drilling mud and drill cuttings will be stored in the lined containment basin. COSE Objective 8.5: Protect and improve water quality and quantity for all water bodies in County of Imperial. Objective 8.6: Eliminate potential surface and groundwater pollution through regulations as well as educational programs. Yes Yes The proposed HR-2 and SmCP-2 Projects sites would be graded to direct surface water runoff toward a storm water retention basin, which will be surrounded by a berm to prevent overflow (HR-2 EPM WQ-4 and SmCP-2 EPM WQ-3). Site drainage for both Projects would be designed to flow toward a stormwater retention pond located on the HR-2 power plant site via ditches, swales, and culverts. The stormwater drainage system would be sized to accommodate 3 inches of precipitation in a 24-hour period (a 100-year storm event) in compliance with applicable local codes and standards. See Response for Policy 4, above. Surface and groundwater quality would be protected by the incorporation of cemented concentric steel and alloy casing that will prevent produced fluids from polluting surface water and groundwater. In addition, only non-toxic, non-hazardous drilling mud will be utilized during drilling operations for the HR-2 Project. Surface and groundwater quality would be protected by implementation of the construction and operational EPMs for the proposed HR-2 and SmCP-2 Projects listed in Section These measures have been incorporated into the design of the Projects and include implementing a construction-phase erosion control plan; lining and monitoring the brine pond so that contents will not leach into the soil; providing extra protection and monitoring of well casings and production well-heads; conducting routine inspections of pipelines; using only non-hazardous drilling mud and storing waste drill mud and drill cuttings in the lined containment basin; providing secondary containment where accidental releases of hazardous and acutely hazardous materials could occur. Hudson Ranch Power II and Simbol Calipatria II Final EIR

285 4.8 Hydrology and Water Quality TABLE HR-2 AND SMCP-2 PROJECTS CONSISTENCY WITH GENERAL PLAN WATER AND HYDROLOGY GOALS AND OBJECTIVES GENERAL PLAN POLICIES CONSISTENCY ANALYSIS Objective 9.2: Reduce risk and damage from flood hazards by appropriate regulations. Sources: County of Imperial 1993a, 1993b6 Yes The Project sites are not located within a 100-year flood hazard area as mapped on a Flood Insurance Rate Map. While this Draft EIR analyzes the Projects consistency with the County of Imperial General Plan pursuant to California Environmental Quality Act (CEQA) Guidelines, Section 15125(d), the County of Imperial Planning Commission will determine the Projects consistency with the General Plan IMPACTS AND MITIGATION MEASURES STANDARDS OF SIGNIFICANCE The impact analysis provided below is based on the following California Environmental Quality Act (CEQA) Guidelines, as listed in Appendix G. The Project would result in a significant impact on hydrology and water quality if the Project would: 1. Violate any water quality standards or waste discharge requirements. 2. 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 that would not support existing land uses or planned uses for which permits have been granted). 3. Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner that would result in substantial erosion or siltation on or off-site. 4. 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 that would result in flooding on- or off-site. 5. Create or contribute to runoff water that would exceed the capacity of existing or planned storm water drainage systems or provide substantial additional sources of polluted runoff. 6. Otherwise substantially degrade water quality. 7. Place housing within a 100-year flood hazard area as mapped on a federal Flood Hazard Boundary Map, Flood Insurance Rate Map, or other flood hazard delineation map. 8. Place structures within a 100-year flood hazard area that would impede or redirect flood flows. Hudson Ranch Power II and Simbol Calipatria II Final EIR

286 4.8 Hydrology and Water Quality 9. Expose people or structures to a significant risk of loss, injury, or death involving flooding, including flooding as a result of the failure of a levee or dam. 10. Expose people or structures to a significant risk of loss, injury, or death involving inundation by seiche, tsunami, or mudflow ENVIRONMENTAL PROTECTION MEASURES Chapter 3 provides a complete list and description of environmental protection measures (EPMs) that Hudson Ranch Power II, LLC and Simbol, Inc. have incorporated into their respective projects to avoid or minimize impacts on all resources. The following EPMs that are included as part of the proposed HR-2 Project to minimize or avoid hydrology and/or water quality impacts: HR-2 EPM WQ-1: Water Conservation: Steam condensate will be used to supply 98% of the cooling tower make-up water, which will minimize water demand from other sources. HR-2 EPM WQ-2: High-Density Polyethylene (HDPE) and Concrete-Lined Brine Pond: The brine pond will be of earth construction and double-lined with an HDPE liner and concrete liner such that the contents will not leach into the soil. HR-2 EPM WQ-3: Brine Pond Monitoring Wells: Potential release from the brine ponds to groundwater will be assessed with a system of monitoring wells placed around the periphery of the ponds. HR-2 EPM WQ-4: Stormwater Retention Basin and Berm: The plant site will be graded to direct surface water runoff toward a storm water retention basin, which will be surrounded by a berm to prevent overflow. HR-2 EPM WQ-5: Casing Shallow Portions of Production and Injection Wells: Casing the shallow portions of the production and injection wells will minimize the potential release of both construction-related drilling fluids and production-related geothermal brines to the shallow groundwater aquifer. HR-2 EPM WQ-6: Protective Pipeline Design and Detailed Inspection Routine: Production pipelines will be alloy-clad steel pipe. Injection pipelines will be constructed of concrete-lined carbon steel. Both will be routinely inspected to prevent potential releases. HR-2 EPM WQ-7: Production Wellheads: Piping at each production wellhead will be equipped with remotely operated electrical emergency shutoff valves and manual alloy isolation valves to prevent potential releases. Hudson Ranch Power II and Simbol Calipatria II Final EIR

287 4.8 Hydrology and Water Quality HR-2 EPM WQ-8: Surface and Groundwater Quality Protection: Cemented concentric steel and alloy casing will prevent produced fluids from polluting surface water and groundwater. Only nontoxic, non-hazardous drilling mud will be utilized during drilling operations. HR-2 EPM WQ-9: Surface and Groundwater Quality Protection: Waste drilling mud and drill cuttings will be stored in the lined containment basin. Any runoff from the site will be discharged into the containment basin. HR-2 EPM HAZ-3: Secondary Containment: Curbs, berms, and concrete pits will be used where accidental releases of hazardous and acutely hazardous materials could occur. Containment areas will be drained to appropriate collection areas or neutralization tanks for recycling or for off-site disposal. Traffic barriers would protect piping and tanks from potential traffic hazards. The following EPMs are included as part of the proposed SmCP-2 Project to minimize or avoid hydrology and/or water quality/water supply impacts: SmCP-2 EPM WQ-1: Water Conservation: Use of steam condensate from HR2 to minimize water demand from outside sources when possible. Water will be internally recycled to the extent practical. SmCP-2 EPM WQ 2: Surface and Ground Water Quality Protection: SmCP-2 will comply with all California Regional Water Quality Control Board, Colorado River Basin Region (CRWQCB) requirements to protect water resources. The Project will also submit additional encroachment permit applications to the IID for roads and activities that may occur in IID rights-of-way, and will comply with the IID permit conditions to protect irrigation channels and water delivery facilities in the area. Required permits would be obtained from the IID for any construction water to be produced from IID canals. The Project will file a Notice of Intent to comply with the requirements of the State Water Resources Control Board s (SWRCB) General Permit for Storm Water Discharges Associated with Construction and Land Disturbance Activities. Any runoff from the plant site will be discharged into the storm water retention basin. SmCP-2 EPM WQ 3: Construction-Phase Erosion Control Plan: An erosion control plan will be used at the SmCP-2 site during the construction phase to control sediment-laden runoff and ensure the integrity of the storm water collection system during construction. The plan will use control measures, as necessary, such as grass-covered swales and ditches, stabilized construction entrances, gravel-covered construction lay- down area, silt fencing, and seeding of the disturbed area. Specifically, runoff from all affected areas will be diverted to the erosion control measures before being discharging off-site. SmCP-2 EPM WQ 4: Storm Water Retention Basin: The SmCP-2 plant site will be graded to direct uncontained surface water runoff toward a storm water retention basin. Hudson Ranch Power II and Simbol Calipatria II Final EIR

288 4.8 Hydrology and Water Quality SmCP-2 EPM HAZ-5: Protective Pipeline Design and Detailed Inspection Routine: Brine delivery/return pipelines will be constructed of appropriate materials to prevent accidental releases. The pipelines will be routinely inspected to prevent potential releases. SmCp-2 EPM HAZ-6: Secondary Containment: Curbed areas will be installed where accidental releases of hazardous materials could occur. Containment areas would be drained to appropriate collection areas or neutralization tanks for recycling or offsite disposal. Traffic barriers would be installed to protect piping and tanks from potential traffic hazards. METHODOLOGY Potential impacts on hydrology and water quality from implementation of the proposed Projects were evaluated based on review of published information and reports regarding regional hydrology, climate, and geology, including an SB 610 Water Supply Assessment prepared for the proposed Projects (Pangaea Land Consultants, Inc. 2012) (Appendix I), and the Geotechnical Investigation (Landmark Consultants, Inc. 2010) (Appendix G). HR-2 IMPACTS AND MITIGATION MEASURES Impact WQ-1: The HR-2 Project could violate water quality standards or waste discharge requirements. Construction and operation activities at the HR-2 Project site could adversely impact water quality in the adjacent Salton Sea, a highly impacted surface water body, from an increase in erosion when ground is disturbed during construction. Surface water quality could be impacted by increased sediment loading associated with land disturbance and the release of drilling fluids, geothermal fluid, or other chemicals during exploration and construction. Disposal of drilling fluids produced during exploration activities may include mud and geothermal residue and may need to be disposed of in appropriate landfills to avoid adverse surface water quality impacts. Groundwater beneath the Project site is generally of poor quality and not used for drinking water supply. The General Plan Water Element Policy 4 requires that an NPDES storm water pollution prevention program (SWPPP) and that required BMPs are incorporated into final Project design to reduce adverse impacts on water quality. Therefore, impacts to water quality during construction would be potentially significant unless mitigation is incorporated. The HR-2 Project also proposes to grade the project site to direct run-off to a storm water retention basin (HR-2 EPM WQ-4), considered part of the Project design features, as a post-construction BMP. The power plant site will drain to a storm water retention basin. The retention basin will be sized to retain 100% of Hudson Ranch Power II and Simbol Calipatria II Final EIR

289 4.8 Hydrology and Water Quality runoff produced in the Project area during a 100-year/24-hour storm (assumed to be a total of 3 inches of rain). To control run-off after construction is complete, the Project site would be graded to direct surface water run-off into the proposed storm water retention basin, which would be shared by both Projects (HR-2 EPM WQ-4). In addition, the HR-2 Project has incorporated into its design, specific EPMs to protect surface and groundwater from toxic or hazardous materials and wastes during operations. These include lining and monitoring the brine pond so that contents would not leach into the soil (HR-2 EPM WQ-2 and WQ-3); providing extra protection and monitoring of well casings and production well-heads (HR-2 EPM WQ-5); conducting routine inspections of pipelines (HR-2 EPM WQ-6); installing emergency shut-off valves and isolation valves on wellheads (HR-2 EPM WQ-7); using only non-hazardous drilling mud and storing waste drill mud and drill cuttings in the lined containment basin (HR-2 EPM WQ-8 and WQ-9); and providing secondary containment where accidental releases of hazardous and acutely hazardous materials could occur (HR-2 EPM HAZ-3). These measures would minimize adverse surface water quality impacts during operation, and thus would not impact water quality in the Salton Sea. Operation impacts would be less than significant. MM WQ 1.1: Implementation of a SWPPP Prior to the issuance of grading permits, Hudson Ranch Power II, LLC shall obtain coverage under the SWRCB s General Permit for Stormwater Discharges Associated with Construction Activity (Water Quality Order No DWQ (NPDES No. CAS000002)). Hudson Ranch Power II, LLC shall prepare a SWPPP to be administered during grading and Project construction. The SWPPP must contain BMPs and construction techniques accepted by the County for use in the Project area at the time of construction that meet the technical standards of the General Construction Permit to ensure that potential water quality impacts (including on- and off-site erosion) during construction phases are minimized, that shall reduce the potential for runoff and the release, mobilization, and exposure of pollutants from the construction area, and that no water quality standards are violated. The SWPPP must address spill prevention and include a countermeasure plan describing measures to ensure proper collection and disposal of all pollutants handled or produced on the site during construction, including sanitary wastes, cement, and petroleum products. Countermeasures may include measures to prevent or clean up spills of hazardous waste and of hazardous materials used for equipment operation, and emergency procedures for responding to spills. BMPs included in the SWPPP must be consistent with the California Stormwater Best Management Practices Handbook for Construction. The SWPPP must be Hudson Ranch Power II and Simbol Calipatria II Final EIR

290 4.8 Hydrology and Water Quality submitted to California RWQCB CRB and Imperial County for review prior to the issuance of grading permits. The SWPP shall identify and specify the pollutants that are likely to be used during construction that could be present in stormwater drainage and non-stormwater discharges, including fuels, lubricants, and other types of materials used for equipment operation and the means of waste disposal. The SWPPP shall specify personnel training requirements and procedures that shall be used to ensure that workers are aware of permit requirements and proper installation methods for BMPs specified in the SWPPP. The SWPPP shall also specify the appropriate personnel responsible for supervisory duties related to implementation of the SWPPP. A copy of the approved SWPPP shall be maintained and available at all times on the construction site. Timing/Implementation: Prior to issuing grading permits. Enforcement/Monitoring: Hudson Ranch Power II, LLC and California RWQCB CRB. Significance after Mitigation: Impact WQ-2: Mitigation measure MM WQ-1.1 requires preparation and implementation of a SWPPP, which would reduce potential construction-phase water quality effects within the Project site. The BMPs that are provided in the SWPPP shall be shown to be effective as required under the adopted changes to Water Quality Order No DWQ (NPDES No. CAS000002) for general construction stormwater permit provisions. With implementation of mitigation measure MM WQ-1.1 and HR-2 EPM WQ-11 EPM WQ-4, impacts from erosion on water quality would be less than significant. The HR-2 Project would not 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. As discussed in Chapter 3 (Project Description), the proposed HR-2 Project would require a small amount of water for geothermal well drilling and dust control during site grading and construction activities. This water would be purchased from the IID and transported to the site by temporary pipeline or by water truck. During operations, the proposed HR-2 Project would require 3,940 AFY. Of this total, 1,200 AFY would be obtained from the IID, and 2,740 AFY would be provided from HR-2 s steam condensate. There are no known groundwater wells within the Project site or the surrounding area and the proposed HR-2 Project would not Hudson Ranch Power II and Simbol Calipatria II Final EIR

291 4.8 Hydrology and Water Quality utilize groundwater as its water supply. Therefore, the proposed HR-2 Project would not deplete groundwater supplies. Surface disturbances, such as vegetation removal and the construction of new impervious surfaces, may occur during the construction of the power plant, thereby resulting in increased potential for erosion and sedimentation. Of the total 245-acre parcel on which the HR-2 Project would be located, permanent disturbance would be limited to 52 acres, or 21 percent of the total parcel. The areas of permanent disturbance, characterized by foundations for buildings, well pads, cooling towers, the freshwater pond and retention basin, the brine collection basin, electrical equipment, roadways, and pipelines, would introduce impermeable or substantially less permeable surfaces than present groundcover. This could affect water infiltration at the Project site. However, the Project site would be graded to direct surface water run-off to a storm water retention basin, sized to retain 3 inches of precipitation in a 24-hour period (100-year storm event). This would allow collected run-off to recharge the groundwater table. In addition, the remainder of the Project site (145 aces) would not be covered with project facilities and these areas would allow for the continued infiltration to groundwater. The proposed increase in impermeable surfaces resulting from implementation of the proposed HR-2 Project would be minimal compared the groundwater recharge area of the Imperial Valley. Therefore, project impacts with regard to groundwater depletion and groundwater interference are considered less than significant. Impact WQ-3: The HR-2 Project would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner that would result in substantial erosion or siltation on- or off-site. The entire project area is fairly level and construction of the proposed Project would not substantially alter the site s existing drainage pattern. The Project site would be graded and facilities installed such that drainage would flow towards a stormwater retention pond located on the power plant site, via ditches, swales and culverts (HR-2 EPM WQ-4). The proposed retention basin would be surrounded by a berm to prevent overflow. The stormwater drainage system would be sized to accommodate 3 inches of precipitation in a 24-hour period (a 100-year storm event) and would be subject to the conditions of a grading permit. In addition, implementation of a SWPPP (MM WQ-1.1), which complies with the requirements of the RWQCB would ensure that construction of the project would not result in substantial erosion or siltation on- or off-site. No structures or well pads are Hudson Ranch Power II and Simbol Calipatria II Final EIR

292 4.8 Hydrology and Water Quality proposed for placement in natural waterways or drainage canals. Therefore, a less than significant impact has been identified for this criteria. Although Project construction could alter surface hydrology, it is unlikely that the existing drainage pattern of the site or area would be substantially altered. There are no stream or river courses on the Project site or within the immediate vicinity. Therefore, no alteration of rivers or streams, on or off the Project site would occur. Mitigation Measures: Impact WQ-4: No additional mitigation required. The HR-2 Project would not 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 that would result in flooding on- or off-site. As described above under Impact WQ-3, the proposed HR-2 Project would not substantially alter the existing drainage pattern of the site or alter the course of a stream or river. The proposed stormwater drainage system would be sized to accommodate 3 inches of precipitation in a 24-hour period (a 100-year storm event). In addition, the proposed retention basin would be surrounded by a berm to prevent overflow. All stormwater generated during the 3-inch storm event would be contained on-site (HR-2 EPM WQ-4). In order to avoid stormwater runoff, the project will be required to prepare and implement a SWPPP (MM WQ-1.1) during construction, along with best management practices to ensure that ground and surface waters would not be degraded and that water quality impacts resulting from construction activities are reduced to below a level of significance. After construction is complete, stormwater would be directed to the stormwater retention basin. A berm would be constructed around the basin to prevent overflow. The HR-2 Project has also incorporated into its design, specific EPMs to avoid and minimize potential spills and the creation of polluted run-off. These include lining and monitoring the brine pond so that contents would not leach into the soil (HR-2 EPM WQ-2 and WQ-3); providing extra protection and monitoring of well casings and production well-heads (HR-2 EPM WQ-5); conducting routine inspections of pipelines (HR-2 EPM WQ-6); installing emergency shut-off valves and isolation valves on wellheads (HR-2 EPM WQ-7); using only non-hazardous drilling mud and storing waste drill mud and drill cuttings in the lined containment basin (HR-2 EPM WQ-8 and WQ-9); and providing secondary containment where accidental releases of hazardous and acutely hazardous materials could occur (HR-2 EPM HAZ-3). Hudson Ranch Power II and Simbol Calipatria II Final EIR

293 4.8 Hydrology and Water Quality Thus, the proposed HR-2 Project would not contribute runoff water that would exceed the capacity of existing or planned storm water drainage systems or provide substantial additional sources of polluted runoff. No significant impact has been identified. Mitigation Measures: Impact WQ-5: None required. The HR-2 Project would not create or contribute to runoff water that would exceed the capacity of existing or planned storm water drainage systems or provide substantial additional sources of polluted runoff. As stated in Impact WQ-3 above, surface disturbance would occur during construction of the HR-2 Project, and new impervious surfaces would be created. Urban/industrial pollutants could also be introduced to an area that in the recent past supported agriculture. Urban runoff typically consists of oils, grease, fuel, antifreeze, byproducts of combustion, and landscaping-related products. Precipitation could transmit these pollutants via stormwater runoff. Because construction of the Project plant site would introduce impervious surfaces and structures, there is the potential for increased runoff. This impact is considered potentially significant. To control run-off after construction is complete, the Project site would be graded to direct surface water run-off into the proposed storm water retention basin, which would be shared by both Projects (HR-2 EPM WQ-4). In addition, the HR-2 Project has incorporated into its design, specific EPMs to avoid runoff during operations. These include lining and monitoring the brine pond so that contents would not leach into the soil (HR-2 EPM WQ-2 and WQ-3); providing extra protection and monitoring of well casings and production well-heads (HR-2 EPM WQ-5); conducting routine inspections of pipelines (HR-2 EPM WQ-6); and providing secondary containment where accidental releases of hazardous materials could occur (HR-2 EPM HAZ-3). These measures would minimize runoff during operations, and thus would not impact water quality in the Salton Sea. Operation impacts would be less than significant. With the implementation of a project SWPPP (MM WQ 1.1), along with the EPMs described above, the Project would not create or contribute runoff water that would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff during construction. Hudson Ranch Power II and Simbol Calipatria II Final EIR

294 4.8 Hydrology and Water Quality MM WQ 1.1: Implementation of a SWPPP See above discussion of MM WQ 1.1 for Impact WQ-1. Timing/Implementation: Prior to issuance of grading permits. Enforcement/Monitoring: CRB RWQCB. Significance after Mitigation: Impact WQ-6: With implementation of the SWPPP and design BMPs as described in the CUP application, EPM HR-2 WQ-2, WQ-3, WQ-4, WQ-5, WQ-6, HAZ-3 and mitigation measure MM WQ 1.1, the Project would not create or contribute runoff water that would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff and impacts to stormwater drainage systems would be less than significant. The HR-2 Project would not otherwise substantially degrade water quality. The Salton Sea, to which surface water runoff from the site would drain, has been designated an impaired water under CWA Section 303(d) due to discharges of primarily agricultural wastes from non-point source runoff. The HR-2 Project would install a storm water retention basin as a design feature to further reduce the potential for impacts to surface water drainage. Although the Project would reduce infiltration into the regional aquifer by eliminating the agricultural discharge by changing the land use type, this is not expected to significantly affect groundwater quality, particularly in an aquifer system already known to have high TDS and total suspended solids (TSS). The Project SWPPP, that would be required as a matter of law and is also identified as MM WQ 1.1, would be prepared and implemented to further avoid and minimize run-off- during construction. In addition, the Project site would be graded to direct surface run-off to a stormwater retention basin (HR-2 EMP WQ-4) to reduce the potential for impacts to surface water drainage during operations. The potential for the Project to substantially further degrade the water quality in the Salton Sea through an increase in non-point source pollutants is negligible, as the untreated runoff from the existing agricultural land use would be changed to regulated and treated industrial water. Therefore, there would be no impact under this criterion. Mitigation Measures: None required. Hudson Ranch Power II and Simbol Calipatria II Final EIR

295 4.8 Hydrology and Water Quality Impact WQ-7: The HR-2 Project would not place housing within a 100-year flood hazard area as mapped on a federal Flood Hazard Boundary Map, Flood Insurance Rate Map, or other flood hazard delineation map. The HR-2 Project site is not located 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. Furthermore, the HR-2 Project does not include the construction of housing units. Therefore, there would be no impact under this criterion. Mitigation Measures: Impact WQ-8: None required. The HR-2 Project would not place structures within a 100-year flood hazard area that would impede or redirect flood flows. The HR-2 Project site is not located 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. It would not place structures within a 100-year flood hazard area such that flood flows would be impeded or redirected. Therefore, there would be no impact under this criterion. Mitigation Measures: Impact WQ-9: None required. The HR-2 Project would not expose people or structures to a significant risk of loss, injury, or death involving flooding, including flooding as a result of the failure of a levee or dam. The HR-2 Project is not located within a within a FEMA-designated 100 year flood zone, and there are no upstream levees or dams which could fail and discharge floodwaters over the Project site. Therefore, the Project would not expose people or structures to a significant risk of loss, injury, or death involving flooding, including flooding as a result of the failure of a levee or dam. Therefore, there would be no impact for this criterion. Mitigation Measures: Impact WQ-10: None required. The HR-2 Project would not expose people or structures to a significant risk of loss, injury, or death involving inundation by seiche, tsunami, or mudflow. The Salton Sea is the closest large body of water, is about 1.5 miles northeast of the project area and the HR-2 Project site and the surrounding area consist of relatively flat ground and there are no dams or levees near the Project site. The project site is not subject to inundation by seiche, tsunami, or mudflow. For this Hudson Ranch Power II and Simbol Calipatria II Final EIR

296 4.8 Hydrology and Water Quality reason, construction and operation of the project would result in risk of exposure of people and structures to a seiche, tsunami, or mudflow.. Therefore, there would be no impact under this criterion. Mitigation Measures: None required. SMCP-2 IMPACTS AND MITIGATION MEASURES Impact WQ-1: The SmCP-2 Project could violate water quality standards or waste discharge requirements. Construction and operation activities at the SmCP-2 Project site could adversely impact water quality in the adjacent Salton Sea, a highly impacted surface water body, from an increase in erosion when ground is disturbed during construction. Surface water quality could be impacted by increased sediment loading associated with land disturbance and the release of chemicals during the mineral extraction process. Groundwater beneath the Project site is generally of poor quality and not used for drinking water supply. The General Plan Water Element Policy 4 requires that an NPDES storm water pollution prevention program (SWPPP) and that required BMPs are incorporated into final Project design to reduce adverse impacts on water quality. An erosion control plan would be used at the SmCP-2 site during the construction phase to control sediment-laden runoff and ensure the integrity of the storm water collection system during construction (SmCP-2 EPM WQ 3). The plan would use control measures, as necessary, such as grass-covered swales and ditches, stabilized construction entrances, gravel-covered construction lay- down area, silt fencing, and seeding of the disturbed area. Specifically, runoff from all affected areas will be diverted to the erosion control measures to prevent discharging off-site. In addition, the proposed SmCP-2 Project would comply with all California Regional Water Quality Control Board, Colorado River Basin Region (CRWQCB) requirements to protect water resources (SmCP-2 EPM WQ 2). The Project will also comply with the IID encroachment permit conditions to protect irrigation channels and water delivery facilities in the area. Therefore, impacts to water quality during construction would be potentially significant unless mitigation is incorporated. To control run-off after construction is complete, the Project site would be graded to direct surface water run-off into the proposed storm water retention basin, which would be shared by both Projects (SmCP-2 EPM WQ-4), considered part of the Project design features, as a post-construction BMP. The retention basin will be Hudson Ranch Power II and Simbol Calipatria II Final EIR

297 4.8 Hydrology and Water Quality sized to retain 100% of runoff produced in the Project area during a 100-year/24- hour storm (assumed to be a total of 3 inches of rain). In addition, the SmCP-2 Project has incorporated into its design, specific EPMs to protect surface and groundwater from toxic or hazardous materials and wastes during operations. These include providing extra protection for, and routine monitoring of, brine delivery/return pipelines (SmCP-2 EPM HAZ-5); and providing secondary containment where accidental releases of hazardous materials could occur (SmCp-2 EPM HAZ-6). Containment areas would be drained to appropriate collection areas or neutralization tanks for recycling or offsite disposal. Traffic barriers would be installed to protect piping and tanks from potential traffic hazards. These measures would minimize adverse surface water quality impacts during operation, and thus would not impact water quality in the Salton Sea. Operation impacts would be less than significant. MM WQ-1.1: Implementation of a SWPPP Prior to the issuance of grading permits, Hudson Ranch Power II, LLC shall obtain coverage under the SWRCB s General Permit for Stormwater Discharges Associated with Construction Activity (Water Quality Order No DWQ (NPDES No. CAS000002)). Simbol, Inc. shall prepare a SWPPP to be administered during grading and Project construction. The SWPPP must contain BMPs and construction techniques accepted by the County for use in the Project area at the time of construction that meet the technical standards of the General Construction Permit to ensure that potential water quality impacts (including onand off-site erosion) during construction phases are minimized, that shall reduce the potential for runoff and the release, mobilization, and exposure of pollutants from the construction area, and that no water quality standards are violated. The SWPPP must address spill prevention and include a countermeasure plan describing measures to ensure proper collection and disposal of all pollutants handled or produced on the site during construction, including sanitary wastes, cement, and petroleum products. Countermeasures may include measures to prevent or clean up spills of hazardous waste and of hazardous materials used for equipment operation, and emergency procedures for responding to spills. BMPs included in the SWPPP must be consistent with the California Stormwater Best Management Practices Handbook for Construction. The SWPPP must be submitted to California RWQCB CRB and Imperial County for review prior to the issuance of grading permits. The SWPP shall identify and specify the pollutants that are likely to be used during construction that could be present in stormwater drainage and non-stormwater discharges, including fuels, lubricants, and other types of materials used for equipment operation and the means of waste disposal. Hudson Ranch Power II and Simbol Calipatria II Final EIR

298 4.8 Hydrology and Water Quality The SWPPP shall specify personnel training requirements and procedures that shall be used to ensure that workers are aware of permit requirements and proper installation methods for BMPs specified in the SWPPP. The SWPPP shall also specify the appropriate personnel responsible for supervisory duties related to implementation of the SWPPP. A copy of the approved SWPPP shall be maintained and available at all times on the construction site. Timing/Implementation: Prior to issuing grading permits, construction planning. Enforcement/Monitoring: Simbol, Inc. and California RWQCB CRB. Significance after Mitigation: Impact WQ-2: Mitigation measure MM WQ 1.1 requires preparation and implementation of a SWPPP, which would reduce potential construction-phase water quality effects within the Project site. The BMPs that are provided in the SWPPP shall be shown to be effective as required under the adopted changes to Water Quality Order No DWQ (NPDES No. CAS000002) for new general construction stormwater permit provisions. With implementation of mitigation measure MM WQ- 1.1 and SmCP-2 EPMs WQ-2 and WQ-3, impacts from erosion and to water quality would be less than significant. The SmCP-2 Project would not 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. As discussed in Chapter 3 (Project Description), the proposed SmCP-2 Project would require a small amount of water for dust control during site grading and other construction activities. This water would be purchased from the IID and transported to the site by temporary pipeline or by water truck. During operations, the proposed SmCP-2 Project would require 800 AFY from IID. Additional water would also be obtained from steam condensate from HR-2. There are no known groundwater wells within the Project site or the surrounding area and the proposed SmCP-2 Project would not utilize groundwater as its water supply. Therefore, the proposed HR-2 Project would not deplete groundwater supplies. Surface disturbances, such as vegetation removal and the construction of new impervious surfaces, may occur during the construction of the mineral extraction plant, thereby resulting in increased potential for erosion and sedimentation. Of the total 245-acre parcel on which the SmCP-2 Project would be located, permanent disturbance would be limited to 48-acres. Given that SmCP-2 could Hudson Ranch Power II and Simbol Calipatria II Final EIR

299 4.8 Hydrology and Water Quality not operate without the proposed HR-2 Project, the total increase in impervious surfaces would be 100-acres (52-acres for HR acres for SmCP-2), or 41 percent of the total parcel. This increase could affect water infiltration at the Project site. The areas of permanent disturbance, characterized by foundations for product handling, production, warehouse and storage building; roadways, pipelines, the cooling tower and other on-site facilities, would introduce impermeable or substantially less permeable surfaces than present groundcover. This could affect water infiltration at the Project site. However, the Project site would be graded to direct surface water run-off to a storm water retention basin, sized to retain 3 inches of precipitation in a 24-hour period (100-year storm event). This would allow collected run-off to recharge the groundwater table. In addition, the remainder of the Project site (145 aces) would not be covered with project facilities and these areas would allow for the continued infiltration to groundwater. The proposed increase in impermeable surfaces resulting from implementation of the proposed SmCP-2 Project would be minimal compared the groundwater recharge area of the Imperial Valley. Therefore, project impacts with regard to groundwater depletion and groundwater interference are considered less than significant. Mitigation Measures: Impact WQ-3: None required. The Project would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner that would result in substantial erosion or siltation on or off-site. Construction of the Project site could result in soil disturbance and cause increased erosion and sedimentation or the release of other pollutants to local waterways, including existing IID drainage canals that course through the Project area. There is a potential for short-term hydrological impacts related to land disturbance during construction of the Project s facilities; however, no permanent structures or well pads are proposed for placement in natural waterways or drainage canals. Surface disturbances, such as vegetation removal and the construction of new impervious surfaces, may occur during the construction of the mineral extraction plant and access roads, power lines, brine supply/return pipelines, and other Project features, thereby resulting in increased potential for erosion and sedimentation. Hudson Ranch Power II and Simbol Calipatria II Final EIR

300 4.8 Hydrology and Water Quality Although construction of these Project elements could alter surface hydrology, it is unlikely that the existing drainage pattern of the site or area would be substantially altered. There are no stream or river courses that would be altered in a manner which would result in substantial erosion or siltation on or off site. Therefore, erosion or siltation impacts on or off-site would be less than significant. Furthermore, the implementation of the Project SWPPP required as a matter of law and as mitigation measure MM WQ 1.1 would further minimize erosion and siltation on site and would prevent the movement of sediment off site. In addition, the SmCP-2 Project would install a storm water retention basin as a design feature to reduce the potential for impacts to surface water drainage (SmCP-2 EPM WQ- 3). Mitigation Measures: Impact WQ-4: None required. The SmCP-2 Project would not 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 that would result in flooding on- or off-site. As described above under Impact WQ-3, the proposed SmCP-2 Project would not substantially alter the existing drainage pattern of the site or alter the course of a stream or river. The proposed stormwater drainage system would be sized to accommodate 3 inches of precipitation in a 24-hour period (a 100-year storm event). In addition, the proposed retention basin would be surrounded by a berm to prevent overflow. All stormwater generated during the 3-inch storm event would be contained on-site (SmCP-2 EPM WQ-4). In order to avoid stormwater runoff, the project will be required to prepare and implement a SWPPP (MM WQ-1.1) during construction, along with best management practices to ensure that ground and surface waters would not be degraded and that water quality impacts resulting from construction activities are reduced to below a level of significance. BMPs included in the SWPPP must be consistent with the California Stormwater Best Management Practices Handbook for Construction. After construction is complete, stormwater would be directed to the stormwater retention basin. A berm would be constructed around the basin to prevent overflow. The SmCP-2 Project has also incorporated into its design, specific EPMs to avoid and minimize the creation of polluted run-off. These include providing extra protection and monitoring of brine delivery/return pipelines and conducting routine inspections of pipelines (SmCP-2 EPM HAZ-5); providing secondary containment Hudson Ranch Power II and Simbol Calipatria II Final EIR

301 4.8 Hydrology and Water Quality where accidental releases of hazardous materials could occur, draining containment areas to appropriate collection areas or neutralization tanks for recycling or offsite disposal, and installing traffic barriers to protect piping and tanks from potential traffic hazards (SmCP-2 HAZ-6). Thus, the proposed HR-2 Project would not contribute runoff water that would exceed the capacity of existing or planned storm water drainage systems or provide substantial additional sources of polluted runoff. No significant impact has been identified. Mitigation Measures: Impact WQ-5: None required The SmCP-2 Project would not create or contribute to runoff water that would exceed the capacity of existing or planned storm water drainage systems or provide substantial additional sources of polluted runoff. As stated in Impact WQ-3 above, surface disturbance would occur during construction of the SmCP-2 Project, and new impervious surfaces would be created. Urban/industrial pollutants could also be introduced to an area that in the recent past supported agriculture. Urban runoff typically consists of oils, grease, fuel, antifreeze, byproducts of combustion, and landscaping-related products. Precipitation could transmit these pollutants via stormwater runoff. Because construction of the Project plant site would introduce impervious surfaces and structures, there is the potential for increased runoff. This impact is considered potentially significant. To control run-off after construction is complete, the Project site would be graded to direct surface water run-off into the proposed storm water retention basin, which would be shared by both Projects (SmCP-2 EPM WQ-4). In addition, the HR-2 Project has incorporated into its design, specific EPMs to avoid and minimize the creation of polluted run-off. These include providing extra protection and monitoring of brine delivery/return pipelines and conducting routine inspections of pipelines (SmCP-2 EPM HAZ-5); providing secondary containment where accidental releases of hazardous materials could occur, draining containment areas to appropriate collection areas or neutralization tanks for recycling or offsite disposal, and installing traffic barriers to protect piping and tanks from potential traffic hazards (SmCP-2 HAZ-6). Operation impacts would be less than significant. With the implementation of a project SWPPP (MM WQ 1.1), along with the EPMs described above, the Project would not create or contribute runoff water that would Hudson Ranch Power II and Simbol Calipatria II Final EIR

302 4.8 Hydrology and Water Quality exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff during construction. MM WQ 1.1: Implementation of a SWPPP See above discussion of MM WQ 1.1 for Impact WQ-1. Timing/Implementation: Prior to issuance of grading permits. Enforcement/Monitoring: CRB RWQCB. Significance after Mitigation: Impact WQ-6: With implementation with the implementation of the SWPPP and design BMPs as described in the CUP application and mitigation measure MM WQ 1.1 impacts to stormwater drainage systems would be less than significant The Project would not otherwise substantially degrade water quality. The Salton Sea, to which surface water runoff from the site would drain, has been designated an impaired water under CWA Section 303(d) due to discharges of primarily agricultural wastes from non-point source runoff. The SmCP-2 Project would install a storm water retention basin as a design feature to further reduce the potential for impacts to surface water drainage. Although the Project would reduce infiltration into the regional aquifer by eliminating the agricultural discharge by changing the land use type, this is not expected to significantly affect groundwater quality, particularly in an aquifer system already known to have high TDS and total suspended solids (TSS). Therefore, the Project is not expected to otherwise substantially degrade water quality and the impact would be less than significant. The Project SWPPP, that would be required as a matter of law and is also identified as MM WQ 1.1, would be prepared and implemented to further avoid and minimize run-off- during construction. In addition, the Project site would be graded to direct surface run-off to a stormwater retention basin (SmCP-2 EMP WQ-4) to reduce the potential for impacts to surface water drainage during operations. The potential for the Project to substantially further degrade the water quality in the Salton Sea through an increase in non-point source pollutants is negligible, as the untreated runoff from the existing agricultural land use would be changed to regulated and treated industrial water. Therefore, there would be no impact under this criterion. Mitigation Measures: None required. Hudson Ranch Power II and Simbol Calipatria II Final EIR

303 4.8 Hydrology and Water Quality Impact WQ-7: The SmCP-2 Project would not place housing within a 100-year flood hazard area as mapped on a federal Flood Hazard Boundary Map, Flood Insurance Rate Map, or other flood hazard delineation map. The SMCP-2 Project site is located outside the 100-year flood hazard area as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard delineation map. Furthermore, the SmCP-2 Project would not construct any housing as part of the project. Therefore, there would be no impact to 100-year flood hazard areas. The SmCP-2 Project site is not located 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. Furthermore, the SmCP-2 Project does not include the construction of housing units. Therefore, there would be no impact under this criterion. Mitigation Measures: Impact WQ-8: None required. The Project would not place structures within a 100-year flood hazard area that would impede or redirect flood flows. The SmCP-2 Project site is not located 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. It would not place structures within a 100-year flood hazard area such that flood flows would be impeded or redirected. Therefore, there would be no impact under this criterion. Mitigation Measures: Impact WQ-9: None required. The Project would not expose people or structures to a significant risk of loss, injury, or death involving flooding, including flooding as a result of the failure of a levee or dam. The SmCP--2 Project is not located within a within a FEMA-designated 100 year flood zone, and there are no upstream levees or dams which could fail and discharge floodwaters over the Project site. Therefore, the Project would not expose people or structures to a significant risk of loss, injury, or death involving flooding, including flooding as a result of the failure of a levee or dam. Therefore, there would be no impact to health or safety as a result of increased flood hazard Mitigation Measures: None required. Hudson Ranch Power II and Simbol Calipatria II Final EIR

304 4.8 Hydrology and Water Quality Impact WQ-10: The SmCP-2 Project would not expose people or structures to a significant risk of loss, injury, or death involving inundation by seiche, tsunami, or mudflow The Salton Sea is the closest large body of water, is about 1.5 miles northeast of the project area and the SmCP-2 Project site and the surrounding area consists of relatively flat ground and there are no dams or levees near the Project site. The project site is not subject to inundation by seiche, tsunami, or mudflow. For this reason, construction and operation of the project would result in risk of exposure of people and structures to a seiche, tsunami, or mudflow. Therefore, there would be no impact under this criterion. Mitigation Measures: None required REFERENCES Alward, R. and R. Shatz Imperial Irrigation District (IID) Appendix B: Desalination/Groundwater Development Feasibility Study, Integrated Water Resources Management Plan, Volume 1. Draft IID Plan. September Bureau of Land Management (BLM) Environmental Assessment and Draft Plan Amendment, Western Colorado Desert Routes of Travel Designation. U.S. Department of the Interior Bureau of Land Management California Desert District, El Centro, California. October California Desert Conservation Area (CDCA) Plan, as Amended. U.S. Department of the Interior Bureau of Land Management Desert District, Riverside, California. California Environmental Protection Agency (CalEPA) Salton Sea Transboundary Watershed California Environmental Protection Agency Regional Water Quality Control Board, Colorado River Basin Region, Staff Report: Water Quality Issues in the Salton Sea Transboundary Watershed. September California State Parks Salton Sea State Recreation Area. Available online: Accessed February 12, Colorado River Basin Salinity Control Forum Water Quality Standards For Salinity Colorado River System. June a. County of Imperial General Plan, Water Element. El Centro, California b. County of Imperial General Plan, Conservation and Open Space Element. El Centro, California. Department of the Interior, Bureau of Reclamation, Colorado River Interim Guidelines for Lower Basin Shortages and the Coordinated Operations for Lake Powell and Lake Mead, December. Hudson Ranch Power II and Simbol Calipatria II Final EIR

305 4.8 Hydrology and Water Quality Federal Emergency Management Agency (FEMA) Mapping Information Platform. Available online: Accessed March 25, Imperial Irrigation District Temporary Land Conversation Fallowing Policy. Adopted by IID Board of Directors, May 8, Water Department. Available online: Accessed February 12, Integrated Water Resources Management Plan, Volume 1. Draft IID Plan. September Water Conservation Plan. El Centro, California. Lawrence Livermore National Laboratory Groundwater Availability within the Salton Sea Basin Newmark, R.L., P.W. Kasameyer, and L.W. Younker Preliminary report on shallow research drilling in the Salton Sea Region. Pangaea Land Consultants, Inc Hudson Ranch Power II Geothermal Project and Simbol Calipatria Plant II, SB 610 Combined Water Supply Assessment. March 15. Salton Sea Authority About the Sea. Available online: Accessed February 12, Hudson Ranch Power II and Simbol Calipatria II Final EIR

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307 4.9 Land Use and Planning 4.9 LAND USE AND PLANNING This section describes the affected environment and regulatory setting for land use and planning resources at the proposed Project sites and vicinity. This section also examines the proposed Projects consistency with applicable plans and policies and describes potential land use and planning impacts that would result from construction and operation of the proposed Projects. Scoping Issues Addressed During the scoping period for the proposed Projects, two public scoping meetings were conducted and written comments were received from agencies and the public. No issues related to land use and planning were raised during the scoping period EXISTING SETTING REGIONAL SETTING The proposed Projects are located in County of Imperial, which is situated in the southeastern most portion of the State of California. The County encompasses an approximately 4,597-square-mile area and is bordered by Riverside County to the north, the State of Arizona on the east, Mexico to the south, and San Diego County to the west. Land uses in the Imperial Valley around the Salton Sea and the Salton Sea Known Geothermal Resource Area (KGRA) reflect the development trends of the County with respect to existing agricultural uses and development of renewable energy projects. In recent years, a number of solar and geothermal energy projects have been proposed for development in the County. This is due, in part, to the 2020 requirements of California s Renewables Portfolio Standard program (California Energy Commission [CEC] 2011) as well as the County s geographic location, which provides for an abundance of solar and geothermal resources. Approximately 12% (347,941 acres) of the land area in County of Imperial has been designated by the United States Geological Survey (USGS) as a KGRA. The County of Imperial has several KGRAs. The County of Imperial Geothermal/Alternative Energy and Transmission Element estimates that approximately 1,790 megawatts (MW) of energy from the County s geothermal resources will be developed by the year 2015 (County of Imperial 2006). Existing Land Use The Project sites are situated in an unincorporated area of County of Imperial approximately 2.3 miles west-southwest of the Town of Niland, California and east of the Salton Sea (see Chapter 3, Project Description, Figure 3-1). The Project sites are located on a 245-acre parcel of private land at 332 West McDonald Road, Calipatria, between McDonald Road and Schrimpf Road, just west of English Road (see Chapter 3, Project Description, Figure 3-2). Primary highway access to the sites is provided from State Route 111 to McDonald Road. Hudson Ranch Power II and Simbol Calipatria II Final EIR

308 4.9 Land Use and Planning According to the California Department of Conservation s Farmland Mapping and Monitoring Program (FMMP), the 245-acre parcel contains Prime Farmland, Farmland of Statewide Importance, and Farmland of Local Importance (California Department of Conservation 2010) (see Section 4.2, Agricultural Resources, for additional details regarding agricultural designations and uses within the Project sites). The IID O Lateral runs along the northern boundary of the parcel, and the N Drain runs along the southern boundary of the parcel. The existing IID 230-kilovolt (kv) transmission line runs east to west along McDonald Road; it then turns southward to bisect the Project sites from north to south. Farmland occupies the remainder of the parcel. Adjacent Areas Neighboring properties immediately north, east, and south of the Project sites are existing and proposed IID managed marshlands (IID 2011). Other land uses located within a 3-mile radius of the Project sites include farmland (alfalfa fields), the Sonny Bono Salton Sea National Wildlife Refuge (2.75 miles to the southwest), the Hudson Ranch I Geothermal Power Plant (1.1 mile to the west), the Alamo River (1.4 miles to the southwest), the Red Hill Marina and Red Hill Marina County Park (1.9 and 2.8 miles to the west), the Leathers Geothermal Power Plant (1.5 miles to the south), and the Brandt Cattle Company (2.75 miles to the southwest). In addition, a vast system of IID canals, check dams, and pipelines carrying water for agricultural irrigation are located throughout the area and near the Project sites. Some of the IID canals possess significant potential for recreational uses, including fishing, picnicking, and bicycle and/or equestrian paths in areas near or adjacent to urban areas in the Imperial Valley. The nearest residence is approximately 0.5 miles north-northeast of the Project sites, along English Road. Energy Source LLC, (Hudson Ranch Power II LLC s parent company) owns the home and is allowing the current tenant to remain in the residence until Fall This residence would be demolished prior to the start of construction of either the HR-2 or SmCP-2 Project. The next closest residence is located 1.4 miles northwest of the Project site. In addition, at the time of the publication of the NOP, a mobile home at the commercial algae production facility served as a residence for the facility caretaker. The commercial algae facility is no longer in operation and is not part of the proposed Projects. The closest public use airport, Cliff Hatfield Memorial Airport (also known as the Calipatria Municipal Airport), is approximately 4.8 miles southeast of the Project sites. For further discussion about airports in the vicinity of the Project sites see Section 4.7, Hazardous Materials and Public Health. Hudson Ranch Power II and Simbol Calipatria II Final EIR

309 4.9 Land Use and Planning REGULATORY SETTING FEDERAL AND STATE California Division of Oil, Gas, and Geothermal Resources The State of California Division of Oil, Gas, and Geothermal Resources (CDOGGR) oversees the drilling, operation, maintenance, and plugging and abandonment of oil, natural gas, and geothermal wells on private and state-owned lands in the State of California (State of California Department of Conservation 2011). The regulatory program s emphasis and objectives focus on the prudent development of oil, natural gas, and geothermal resources in the state through sound engineering practices that protect the environment, prevent pollution, and ensure public safety. LOCAL Imperial County Airport Land Use Compatibility Plan The County of Imperial Airport Land Use Compatibility Plan (ALUCP) sets forth criteria and policies that the County of Imperial Airport Land Use Commission uses in assessing the compatibility of the principal airports in County of Imperial and proposed land use development in the areas surrounding them. The emphasis of the ALUCP is on review of local general and specific plans, zoning ordinances, and other land use documents covering broad geographic areas. Certain individual land use development proposals also may be reviewed by the County of Imperial Airport Land Use Commission as provided for in the policies included in the ALUCP. The ALUCP particularly pertains to the land uses surrounding the following seven airports: Brawley Municipal Airport, Calexico International Airport, Calipatria Municipal Airport (Cliff Hatfield Memorial Airport), Holtville Airport, County of Imperial Airport, Salton Sea Airport, and Naval Air Facility El Centro (Imperial County Airport Land Use Commission and Planning and Building Department 1996). Imperial County Land Use Ordinance, Title 9, Division 5 Zoning Areas Title 9 of the Imperial County Land Use Ordinance specifies permitted and conditional uses for the various zoning designations within unincorporated areas of the County. Development and performance standards included in Title 9 are adopted to protect the health, safety, and general well-being of the public through the orderly regulation of land uses within the County. The parcel on which the two Projects would be located is currently zoned A-2-R-G (General Agriculture/Rural/Geothermal Overlay Zone), which permits all agricultural and grazing uses. Electrical generation plants (less than 50-MW); major geothermal projects; facilities for the transmission of electrical energy ( kv); electrical substations in an electrical transmission system (500-kV/230-kV/161-kV); mining and mineral extraction; and resource extraction and energy development are permitted within the A-2-R-G zone, subject to securing a Conditional Use Permit (County of Imperial, 2008a, 2008b). Hudson Ranch Power II and Simbol Calipatria II Final EIR

310 4.9 Land Use and Planning Imperial County Land Use Ordinance, Title 9, Division 17 Geothermal Projects The purpose of regulations provided in Division 17 of Title 9 is to facilitate the beneficial use of the geothermal resource for the general welfare of the public, to protect the resource from wasteful or detrimental uses, and to protect people, property, and the environment from detriments that might result from the improper use of the resource. Title 9, Division 17, describes general standards for geothermal applicants when applying for Conditional Use Permits both inside and outside of the Geothermal Overlay Zone. The overall goal of these regulations is to integrate, to the extent feasible, County of Imperial s regulations with those of other governmental agencies that regulate geothermal resource exploration and development (County of Imperial 2008c). In addition, the County Land Use Ordinance (Section ) permits electrical generation plants (less than 50-MW) ; geothermal test facilities, intermediate projects, and major exploratory wells ; facilities for the transmission of electrical energy ( kv ), mining and mineral extraction and resource extraction and energy development within the A-2-R-G Geothermal Overlay Zone subject to securing a Conditional Use Permit (County of Imperial 2008b, 2008cb). County of Imperial General Plan County of Imperial General Plan (Land Use Element) The primary purpose of the General Plan s Land Use Element is to identify the goals, policies, and standards that will guide the physical growth of County of Imperial. For development of agricultural lands, goals and objectives of the Land Use Element focus on the preservation of commercial agriculture as a prime economic force and discourage the location of incompatible development adjacent to or within productive agricultural lands (County of Imperial 2008a). The Agricultural Element provides additional policies that guide development of agricultural lands in the County. Policies related to geothermal exploration and development are discussed in the Geothermal/Alternative Energy and Transmission Element. The Imperial County General Plan designates the Project site as "Agriculture" (County of Imperial 2008a), and the site is zoned "A-2-R-G (General Agriculture/ Rural/Geothermal Overlay Zone)" which allows for power plant construction and well drilling and transmission line construction, related geothermal operations, mining and mineral extraction, and resource extraction and energy development with a conditional use permit (County of Imperial 2006, p. 44). The extraction of minerals from the geothermal fluids is included in the description of activities that may occur with the development of geothermal flash plants (County of Imperial 2006, p. 62). Hudson Ranch Power II and Simbol Calipatria II Final EIR

311 4.9 Land Use and Planning County of Imperial General Plan (Geothermal/Alternative Energy and Transmission Element) The Geothermal/Alternative Energy and Transmission Element is an optional component of the General Plan, as permitted by Section of the California Government Code. The purpose of the Geothermal/Alternative Energy and Transmission Element is to provide a comprehensive document that contains the latest knowledge about the geothermal resource, workable development technology, legal requirements, policies (County, state, and federal), and implementation measures. The Geothermal/Alternative Energy and Transmission Element provides a framework for review and approval of geothermal projects in the County (County of Imperial 2006). The County of Imperial General Plan guides local decision-making regarding future land uses, growth, and other planning and policy decisions. Table identifies applicable General Plan policies related to land use and planning and addresses the HR-2 and SmCP-2 Projects consistency with the General Plan policies. TABLE HR-2 AND SMCP-2 PROJECTS CONSISTENCY WITH APPLICABLE GENERAL PLAN LAND USE POLICIES GENERAL PLAN POLICIES, GOALS AND OBJECTIVES CONSISTENCY ANALYSIS GEOTHERMAL-TRANSMISSION ELEMENT Goal 1: The County supports and encourages the full, orderly, and efficient development of geothermal/alternative energy resources while, at the same time, preserving and enhancing, where possible, agricultural, biological, human, and recreational resources. CONSERVATION AND OPEN SPACE ELEMENT Environmental Resources for Future Generations, Goal 1: Environmental resources shall be conserved for future generations by minimizing environmental impacts in all land use decisions. LAND USE ELEMENT Commercial Agriculture, Goal 1: Preserve commercial agriculture as a prime economic force. Objective 1.1: Encourage the continued agricultural use of prime/productive agricultural lands. Yes Yes Yes Yes The proposed HR-2 geothermal flash plant and the SmCP-2 mineral extraction plant would be located on a privately owned parcel, approximately 245 acres in size. This parcel is entirely within a Geothermal Overlay Zone and the Salton Sea KGRA. The proposed Projects would cover approximately 100 acres of the 245-acre parcel. The remaining 145 acres would be available for agricultural operations. The proposed Projects would cover approximately 100 acres of the 245-acre parcel. Therefore, agricultural operations could continue on the remaining 145 acres. The proposed Projects would cover approximately 100 acres of the 245-acre parcel, including 27-acres of Prime Farmland, 68-acres of Farmland of Statewide Importance, and 5- acres of Farmland of Local Importance. However, agricultural operations could continue on the remaining 145 acres. Hudson Ranch Power II and Simbol Calipatria II Final EIR

312 4.9 Land Use and Planning TABLE HR-2 AND SMCP-2 PROJECTS CONSISTENCY WITH APPLICABLE GENERAL PLAN LAND USE POLICIES GENERAL PLAN POLICIES, GOALS AND OBJECTIVES CONSISTENCY ANALYSIS Objective 1.2: Discourage the location of incompatible development adjacent to or within productive agricultural lands. Objective 1.3: Identify compatible agriculture-related uses appropriate for location in agricultural areas. Regional Vision, Objective 3.2: Preserve agriculture and natural resources while promoting diverse economic growth through sound land use planning. Sources: County of Imperial 1993, 2006, 2008a Yes Yes Yes The proposed Projects would be located within the Geothermal Overlay Zone on agricultural land zoned A-2-R-G. The County of Imperial considers land zoned A-2-R-G to be compatible with geothermal development and mineral processing. The County of Imperial identifies land zoned A-2- R-G as compatible with geothermal development and mineral processing. In addition, the proposed Projects would be located within the Geothermal Overlay Zone. The proposed Projects would be constructed on land zoned A-2-R-G, which is agricultural land identified by the County of Imperial as compatible with geothermal development and mineral processing. In addition, the Projects would be entirely within a Geothermal Overlay Zone and the Salton Sea KGRA. The proposed Projects would cover approximately 100 acres of the 245-acre parcel, and the remaining 145 acres would be available for agricultural operations. While this Draft EIR analyzes the Projects consistency with the County of Imperial General Plan pursuant to California Environmental Quality Act (CEQA) Guidelines, Section 15125(d), the County of Imperial Planning Commission will determine the Projects consistency with the General Plan IMPACTS AND MITIGATION MEASURES STANDARDS OF SIGNIFICANCE The impact analysis provided below is based on the following CEQA Guidelines, Appendix G. An impact is considered significant if the Projects would: 1. Physically divide an established community. 2. Conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the Project (including, but not limited to, the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental impact. 3. Conflict with any applicable habitat conservation plan or natural community conservation plan. Hudson Ranch Power II and Simbol Calipatria II Final EIR

313 4.9 Land Use and Planning ENVIRONMENTAL PROTECTION MEASURES No environmental protection measures (EPMs) were identified for land use plans and policies. METHODOLOGY For the purpose of the land use analysis, relevant documents, including the County of Imperial General Plan, the Geothermal/Alternative Energy and Transmission Element of the General Plan, and the Imperial County Land Use Ordinance, were reviewed. In addition, a site visit was conducted to verify existing conditions in the area of the proposed Projects. An evaluation of the proposed Projects consistency with plans and policies is provided in Table and is summarized in Impact LU-2, below. HR-2 IMPACTS AND MITIGATION MEASURES Impact LU-1: The HR-2 Project would not physically divide an established community. The proposed HR-2 Project would include the development of a geothermal power plant, associated wells, and aboveground pipelines on land primarily used for agricultural purposes. The structures associated with the proposed HR-2 Project would be located on the HR-2 Project site and would not result in the division of a community. Therefore, the HR-2 Project would not result in a physical division of any established communities and there would be no impact. Mitigation Measures: Impact LU-2: None required. The HR-2 Project would not conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the HR-2 Project (including, but not limited to, the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental impact. The proposed HR-2 Project is located on land that is designated for agricultural uses and is zoned A-2-R-G (General Agriculture/Rural/Geothermal Overlay Zone) which allows for resource extraction and energy development, power plant construction and well drilling and transmission line construction, related geothermal operations, and resource extraction. Major and intermediate geothermal projects, geothermal test facilities, and major geothermal exploratory wells are permitted within the Geothermal Overlay Zone ( G ) with a conditional use permit. HR-2 Project implementation would result in the temporary conversion of agricultural land to non-agricultural; however, agricultural operations could continue on the remainder of the undeveloped portion of the parcel after Hudson Ranch Power II and Simbol Calipatria II Final EIR

314 4.9 Land Use and Planning construction. Furthermore, at the end of the HR-2 Project s useful life (i.e., 30 years), disturbed lands on the site would be restored to allow agricultural use once the wells have been abandoned, the power plant and pipelines removed, and the plant site and well pads reclaimed. The proposed HR-2 Project would be consistent with the County of Imperial General Plan and the Land Use Ordinance with the issuance of a Conditional Use Permit. Therefore, the HR-2 Project, with a CUP, would be consistent with the Imperial County General Plan and would not conflict with any federal, state, or local land use plans, policies, or regulations, and there would be no land use conflict impacts from the HR-2 Project. Mitigation Measures: Impact LU-3: None required. The HR-2 Project would not conflict with any applicable habitat conservation plan or natural community conservation plan. There are no adopted habitat conservation plans or natural community conservation plans encompassing the HR-2 Project site. As such, there is no potential for the proposed HR-2 Project to conflict with any applicable habitat conservation plan or natural community conservation plans. Therefore, no impacts would result. Mitigation Measures: None required. SMCP-2 IMPACTS AND MITIGATION MEASURES Impact LU-1: The SmCP-2 Project would not physically divide an established community. The proposed SmCP-2 Project would include the development of a mineral extraction plant and associated structures on land primarily used for agricultural purposes. The structures associated with the proposed SmCP-2 Project would be located on the SmCP-2 Project site and would not result in the division of a community. Therefore, the SmCP-2 Project would not result in a physical division of any established communities and there would be no impact. Mitigation Measures: Impact LU-2: None required. The SmCP-2 Project would not conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the SmCP-2 Project (including, but not limited to, the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental impact. Hudson Ranch Power II and Simbol Calipatria II Final EIR

315 4.9 Land Use and Planning The proposed SmCP-2 Project is located on land that is designated for agricultural uses and is zoned A-2-R-G (General Agriculture/Rural/Geothermal Overlay Zone) which allows for mining and mineral extraction and resource extraction and energy development with a conditional use permit. SmCP-2 Project implementation would result in the temporary conversion of agricultural land to non-agricultural uses. However, agricultural operations could continue on the undeveloped portion of the parcel after construction. Furthermore, at the end of the SmCP-2 Project s useful life (i.e., 30 years), disturbed lands on the site would be restored to allow agricultural use once the mineral extraction facilities have been abandoned and the land has been reclaimed. The proposed SmCP-2 Project would be consistent with the County of Imperial General Plan and the Land Use Ordinance with the issuance of a Conditional Use Permit. Therefore, the SmCP-2 Project, with a CUP, would be consistent with the Imperial County General Plan and would not conflict with any federal, state, or local land use plans, policies, or regulations, and there would be no land use conflict impacts from the SmCP-2 Project. Mitigation Measures: Impact LU-3: None required. The SmCP-2 Project would not conflict with any applicable habitat conservation plan or natural community conservation plan. There are no adopted habitat conservation plans or natural community conservation plans encompassing the SmCP-2 Project site. As such, there is no potential for the proposed SmCP-2 Project to conflict with any applicable habitat conservation plan or natural community conservation plans. Therefore, no impacts would occur as result of construction and operation of the proposed SmCP-2 Project. Mitigation Measures: None required REFERENCES California Department of Conservation Division of Oil, Gas and Geothermal Resources (CDOGGR) Home Page. Page 2. Online at: conservation. ca. gov/dog/pages/index. aspx. Accessed May 11, Farmland Mapping and Monitoring Program: Important Farmland Map for Imperial County for 2008 (Map updated June 2010). Online at: ftp://ftp.consrv.ca.gov/pub/dlrp/fmmp /pdf/2008/imp08.pdf. Accessed May 11, Hudson Ranch Power II and Simbol Calipatria II Final EIR

316 4.9 Land Use and Planning California Energy Commission (CEC) California Renewable Energy Overview and Programs. Page 2. Online at: Accessed May 25, County of Imperial. 2008a. Revised. County of Imperial General Plan, Land Use Element. Page 42. Prepared by the County of Imperial Planning and Building Department. Online at: Accessed June 1, b. Imperial County Land Use Ordinance, Title 9, Land Use Code Division 5-Zoning Areas Established. Page 1. Online at: stateid=5&statename=california. Accessed May 15, c. Imperial County Land Use Ordinance, Title 9, Division 17-Geothermal Projects. Page 1. Online at: California. Accessed May 12, Revised. County of Imperial General Plan, Geothermal/Alternative Energy and Transmission Element. Prepared by the Imperial County Planning and Development Services Department. Page 39. Online at: icpds. com/?pid=83http://www. icpds. com/cms /Media/Geothermal-TransmissionElement-(2006). pdf. Accessed June 1, County of Imperial General Plan Conservation and Open Space Element. El Centro, California. Imperial County Airport Land Use Commission and Planning and Building Department Airport Land Use Compatibility Plan. Imperial County Airports. Page 8. Online at: Accessed May 19, Imperial Irrigation District (IID) Managed Marsh. Online at Accessed July 22, Hudson Ranch Power II and Simbol Calipatria II Final EIR

317 5. Cumulative Impacts 5 CUMULATIVE IMPACTS Hudson Ranch Power II and Simbol Calipatria II Final EIR

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319 5. Cumulative Impacts 5 CUMULATIVE IMPACTS This chapter of the Environmental Impact Report (EIR) provides an analysis of the contribution to cumulative environmental effects that could result from the construction and operation of the Hudson Ranch Power II Geothermal Project (HR-2) and the Simbol Calipatria Plant II (SmCP-2) (proposed projects). The HR-2 and SmCP-2 would result in direct impacts that are less than significant for many resource areas; however, the projects may incrementally impact the environment when combined with other past, current, and reasonably foreseeable projects. As required by Section of California Environmental Quality Act (CEQA) Guidelines, the following discussion considers the cumulative impacts for relevant environmental issue areas. 5.1 CEQA REQUIREMENTS FOR CUMULATIVE IMPACT ANALYSIS The following analysis evaluates the potential for the HR-2 and SmCP-2 s environmental impacts to be cumulatively significant. CEQA requires that an environmental impact report contain an assessment of the cumulative impacts that could be contributed to by the proposed HR-2 and SmCP-2 Projects. Cumulative impacts are defined as two or more individual effects which, when considered together, are considerable or... compound or increase other environmental impacts. (CEQA Guidelines, ) Stated another way, A cumulative impact consists of an impact which is created as a result of the combination of the project evaluated in the EIR together with other projects causing related impacts. (CEQA Guidelines, 15130, subd. (a)(1)). Cumulative impacts occurs from a change in the environment which results from the incremental impact of the project when added to other closely related past, present, and reasonably foreseeable future projects. Cumulative impacts can result from individually minor, but collectively significant, projects taking place over a period of time. (CEQA Guidelines, 15355, subd. (b)). In addition, CEQA Guidelines, Section 15130(b), identify three elements that are necessary for an adequate cumulative analysis: 1. Either: a. A list of past, present, and probable future projects producing related or cumulative impacts, including, if necessary, those projects outside the control of the agency; or b. A summary of projections contained in an adopted general plan or related planning document, or in a prior environmental document which has been adopted or certified, which described or Hudson Ranch Power II and Simbol Calipatria II 5-1 Final EIR

320 5. Cumulative Impacts evaluated regional or area-wide conditions contributing to the cumulative impact. Any such planning document shall be referenced and made available to the public at a location specified by the lead agency. 2. A summary of the expected environmental effects to be produced by those projects with specific reference to additional information stating where that information is available; and 3. A reasonable analysis of the cumulative impacts of the relevant projects. An EIR shall examine reasonable, feasible options for mitigating or avoiding the project s contribution to any significant cumulative effects. Where a lead agency is examining a project with an incremental effect that is not cumulatively considerable, a lead agency need not consider that effect significant, but shall briefly describe its basis for concluding that the incremental effect is not cumulatively considerable. 5.2 CUMULATIVE ANALYSIS APPROACH As stated above, CEQA Guidelines require the use of a list of past, present, and probable future projects and/or the use of adopted projections from a general plan, other regional planning document, or a certified EIR. The list approach has been used in this Draft EIR. Some of the cumulative impacts associated with the HR-2 and SmCP-2 are more localized in nature (e.g., noise) and, thus, are analyzed at a project level. Other cumulative impacts are regional in nature (e.g., air quality, greenhouse gases and climate change) and, therefore, are analyzed at a regional level. Because of this variance in impact range, each resource area has been evaluated and an appropriate Cumulative Effects Study Area (CESA) has been defined for each resource. (CEQA Guidelines, 15130, subd. (b)(3).) The analysis of cumulative effects considers a number of variables including geographic limits, temporal limits, and the characteristics of the resource being evaluated. The geographic scope of each analysis is based on the topography surrounding the projects and the natural boundaries of the resource affected, rather than jurisdictional boundaries. The geographic scope of cumulative effects will often extend beyond the scope of the direct effects, but not beyond the scope of the direct and indirect effects of the HR-2 and SmCP-2. In addition, each project identified has its own implementation schedule, which may or may not coincide or overlap with the HR-2 and SmCP-2. However, to be conservative, the cumulative analysis assumes that all projects in the cumulative scenario are built and operating during the operating lifetime of the HR-2 and SmCP-2. A list of existing, approved, proposed, and reasonably foreseeable projects used in this cumulative analysis is provided in Table 5-1; with the project locations are provided on Figure 5-1. Table 5-1 includes all applicable projects known as of May 14, 2012, that have occurred, or are planned or anticipated to occur, within the largest CESA identified for the analysis. Hudson Ranch Power II and Simbol Calipatria II 5-2 Final EIR

321 Path: \\prtbhp1\gis\sandiego\hudsonranch_geothermal\maps\mxds\cumulative_projects_25may2012.mxd Riverside San Diego 55 Salton Sea Hudson Ranch Power II and Simbol Calipatria II Project Sites 86 12, 54 15, 16 38, Imperial Riverside 13 30, , , La Paz 115 Yuma San Diego Imperial , California Arizona , 53, Mexico Hudson Ranch Power II and Simbol Calipatria II Cumulative Projects Map Imperial County Region CA NV AZ Cumulative Project Location BLM West Chocolate Mountains Renewable Energy EIS Evaluation Area (as of May 2012) Note: Cumulative project numbers on map match numbers in Table 5-1. Major Road State/International Boundary County Boundary Figure 5-1 Miles