CHAPTER 4 Cumulative Impacts

Transcription

1 CHAPTER 4 Cumulative Impacts 4.1 Introduction This section of the DEIR is a cumulative impact analysis of the proposed Cluster I Solar Power project in addition to existing, approved, proposed, and reasonably foreseeable projects in the cumulative study area, as required by Section of the State CEQA Guidelines. The following discussion considers the cumulative impacts of the relevant environmental issue areas CEQA Requirements for Cumulative Impact Analysis This EIR analysis evaluates whether the overall long-term impacts of the proposed project would be cumulatively significant. Additionally, it determines if the proposed project would cause a cumulatively considerable contribution to any such cumulatively significant impacts (CEQA Guidelines Sections 15130[a] [b], 15355[b], 15064[h], 15065[c]; Communities for a Better Environment v. California Resources Agency [2002] 103 Cal.App.4th 98, 120). The CEQA requires that an EIR contain an assessment of the cumulative impacts that could be associated with the proposed project. According to CEQA Guidelines Section 15130(a), an EIR shall discuss cumulative impacts of a project when the project s incremental effect is cumulatively considerable. Cumulatively considerable means that the incremental effects of an individual project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects (as defined by Section 15130). As defined in CEQA Guidelines Section 15355, a cumulative impact consists of an impact that is created as a result of the combination of the project evaluated in the EIR together with other projects causing related impacts. A cumulative impact occurs from:... the 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. In addition, CEQA Guidelines Section 15130(b) identifies that the following three elements 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 Imperial County Planning & Development Services Department 4-1 ESA /

2 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 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. 4.2 Cumulative Impact Analysis The following describes the overall approach to the cumulative impact analysis provided below Cumulative Impact Approach This EIR evaluated cumulative impacts of the proposed project and alternatives for each resource area, using the following steps: 1. Define the geographic scope of cumulative impact analysis for each discipline, based on the potential area within which impacts of the proposed project could combine with those of other projects. 2. Evaluate the effects of the proposed project in combination with past and present (existing) projects in the study area. 3. Evaluate the effects of the proposed project with foreseeable future projects that occur within the area of geographic effect defined for each discipline Geographic Scope and Timeframe of the Cumulative Effects Analysis The area of cumulative effect varies by resource. For example, air quality impacts tend to disperse over a large area, while traffic impacts are typically more localized. For this reason, the geographic scope for this analysis must be identified for each resource area. The analysis of cumulative effects considers a number of variables including geographic (spatial) limits, time (temporal) limits, and the characteristics of the resource being evaluated. The geographic scope of each analysis is based on the topography surrounding the project site and the natural boundaries of the resource affected, rather than jurisdictional boundaries. The geographic Imperial County Planning & Development Services Department 4-2 ESA /

3 scope of cumulative effects will often extend beyond the scope of the direct effects of a proposed project, but not beyond the scope of the direct and indirect effects of that proposed project. In addition, each project in a region will have its own implementation schedule, which may or may not coincide or overlap with the construction schedule for the proposed project. This is a consideration for short-term impacts from the proposed project. 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 proposed project. Project Effects in Combination with Past, Present and Foreseeable Future Projects Each discipline evaluates the impacts of the Cluster I project on top of the current baseline; the past, present (existing) and future projects near the project site. The intensity, or severity, of the cumulative effects is determined by the magnitude, geographic extent, duration and frequency of the effects. The magnitude of the effect reflects the relative size or amount of the effect; the geographic extent considers how widespread the effect may be; and the duration and frequency refer to whether the effect is a one-time event, intermittent, or chronic. Reasonably foreseeable projects could contribute to the cumulative effects scenario for the proposed project depending on the extent of each particular resource impact. Cumulative impacts may be intensified by foreseeable future projects that are in the direct vicinity of the project site or by foreseeable future projects throughout the greater desert surrounding the project site. 4.3 Cumulative Projects Table 4-1, located at the end of this chapter, provides a list of cumulative existing and foreseeable future projects within Imperial County. These projects include projects recently constructed existing projects, under construction, approved, but currently not built projects and projects that have submitted a development application at the time of release of the NOP. Figure 4-1 Cumulative Projects identifies the general location of these projects in relation to the proposed Cluster I Solar Power project site. 4.4 Cumulative Setting Impacts and Aesthetics As described in Section 3.1, multiple projects, including several utility-scale solar energy production facilities, are proposed in the project vicinity. These projects would cover thousands of acres within approximately 45 miles of the project sites. These have the potential to result in cumulative impacts to aesthetics when considered together with the proposed project. However, the cumulative study area for projects considered in the visual resources cumulative impact analysis considers a five mile radius within the study area. Views beyond five miles are obstructed by a combination of the flat topography coupled with the Earth s curvature. The short- Imperial County Planning & Development Services Department 4-3 ESA /

4 term visual impacts of the projects would be in the form of general construction activities including grading, use of construction machinery, and installation of the transmission poles and stringing of transmission lines. Longer-term visual impacts of the projects would be in the form of the presence of solar array grids, inverter modules and transformer stations, an electrical distribution and transmission system, operations and maintenance facilities, and, a substation. The proposed project is not located in a designated scenic vista, nor has the County of Imperial General Plan designated the project site as an important visual resource. None of the roadways abutting or surrounding the project site are designated or proposed scenic roadways. No historic structures or significant scenic resources exist on the proposed project sites. Therefore, development of the project would not have a substantial adverse effect under CEQA on a scenic vista or damage scenic resources. Construction of the project would alter the existing visual character of the area and its surroundings as a result of converting agricultural land to a solar energy facility. However, due to the flat topography of the site and surrounding area; location of the project site that is removed from most public views within an area surrounded by existing agriculture land; and, the installation of the perimeter fencing the equipment proposed to be installed on the project site would not be visible from any surrounding view point. In addition, the site would not be visible from any designated scenic resources or scenic highways. Furthermore, the project would require approval of a CUP by the County of Imperial that would allow for the construction and operation of the proposed solar energy facility on a project site zoned for agriculture. As such, with approval of the CUP, the proposed solar energy facility would be consistent with the allowed uses on the agricultural land and would not conflict with the surrounding land uses. Therefore, this issue is considered less than significant under CEQA. The proposed transmission line corridor will be located within a designated utility corridor and the transmission line will be similar to the existing transmission facilities located within this corridor, no impacts to visual resources would occur. Therefore, because the proposed transmission line corridor would be similar to the existing corridor and the project site is designated for such use, implementation of the proposed project would not substantially degrade the existing visual character or quality of the site and its surroundings. Therefore, this issue is considered less than significant under CEQA. Similar to the solar energy facility site, the access road is not visible from any of the public vantage points or designated scenic highways or vistas. As such, the widening and use of this road would not result in a significant impact under CEQA to visual resources. As discussed in Section 3.1, the project would not result in significant impacts to lighting or glare. Any lighting impacts would be minimized through implementation of standard County requirements, as well as implementation of through There would be no significant light sources on the project site; lighting would be provided at substations and other structures only, and would be shielded to prevent spillover. Glare impacts are minimized by the inherent design qualities of the PV panels, which reduces reflectivity and the potential for visual discomfort or impairment. Additional PV panels in the area would not result in a greater intensity of glare due Imperial County Planning & Development Services Department 4-4 ESA /

5 Palm Desert Indio Coachella!(6 10 La Quinta ÄÅ74 ÄÅ111 R i v e r s i d e I!(20 m p e r i a l!(21 ÄÅ79 Ranchita ÄÅ78 S a n D i e g o I m p e r i a l!(66 ÄÅ86 S a l t o n S e a CUP # Midway Solar Farm I (83WI)!(23!(59!(13!(10!(11!(12!(30!(35!( 36!(45!(49!(48!(65!(2!(3b!(54!(19a!(1!(22!(50!(39!(25!(3a!(42!(4!(19b!(8!(40!(41!(40!(43 Brawley!(7!(33!(34!(57!(58 ÄÅ86 ÄÅ111!(44 ÄÅ111!(47!(46 ÄÅ115 CUP # Midway Solar Farm II (97WI) CUP # Calipatria Solar Farm I (70SM)!(9!(16!(15 ÄÅ78!(14!(17 95 Legend!( Cumulative Project Locations!(37!(24!(64 El Centro!(26!(55!(60 56!(51!(61 8!(63!(52 Calexico!(28!(27!(32!(62!(29!(33!(53!(5!(38!(18 Yuma Fortuna Foothills 0 10 Miles SOURCE: Bing Maps; ESA, Minute Cluster I Solar Farm Figure 4-1 Cumulative Project Map

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7 to the panel design and the law of reflectivity, which would not direct any reflected light along the ground surface. Therefore, the project would not add to any cumulative impacts on lighting or glare that might result from implementation of other projects in the cumulative impact scenario. Following implementation of through 3.1-4, cumulative impacts associated with aesthetics would be less than significant. Less than significant Agriculture and Forest Resources The geographic scope for cumulative agricultural and forest impacts is Imperial County as a whole. Imperial County ranks high on the list of California counties with respect to urbanization and loss of farmland. There are approximately 540,942 acres of farmland within Imperial Valley or 4.4 percent of the total farm acreage in California (Department of Conservation data). Of this Imperial County farmland, approximately 311,048 acres are considered Farmland of Statewide Importance, which accounts for approximately 12 percent of the State of California s total Farmland of Statewide Importance acreage of 2,683,574 acres. As described previously in Section 3.2, Agriculture and Forest Resources, reports from the period 1992 to 2004 revealed a trend toward increased conversion in Imperial County. The report covering the period from 1992 to 1994 revealed that the county s rate of conversion dropped 66 percent over the previous reporting period. It dropped again by 47 percent between 1994 and In contrast, for the period , Imperial County moved to the top of the urbanizing county list. This was the first update in which the county s urbanization exceeded 1,000 acres, more than 88 percent of which took place on what had been irrigated farmland (1,047 of 1,186 acres). Housing, water treatment and geothermal facilities, and border-related industrial uses near Calexico were the primary new land uses (DOC 2006). Continued growth in population would likely decrease the amount of agricultural land in Imperial County even further. A list of projects that comprise the cumulative setting is provided in Table 4-1. A total of 66 projects, 28 of which are similar solar projects, covering more than 36,000 acres, are currently proposed in Imperial County. These projects include 51 alternative energy, residential, commercial and industrial projects. These projects, if approved, have the potential to convert agricultural lands to nonagricultural uses. Besides the beneficial aspects of the project relative to renewable resource based energy production, implementation of the project would have favorable impacts on regional agriculture by: Reducing on-site water consumption, thereby making more water available for other farmers; and Preventing urban sprawl on the project site and minimizing the risk of future projects on the site inducing regional population growth. Imperial County Planning & Development Services Department 4-7 ESA /

8 As discussed above, the conversion of the project s Prime Farmland acreage is an extremely small percentage of loss statewide, less than 0.1 percent which is not substantial. The cumulative assessment projects would represent a small percentage (about 1.0%) of the total farm acreage in Imperial Valley. In addition, the Applicant would either procure an agricultural conservation easement on a 1 to 1 basis for Non-Prime or a 2 to 1 basis for Prime farmland, pay an Agricultural In-Lieu Mitigation Fee, or restore the land to its present state upon project conclusion, which would make the land again available for any viable agricultural use. The development of a PV solar power plant would, at a minimum, constitute a temporary conversion of agricultural land for the life of plant operations. As such, the impacts on agricultural and forestry resources of this project when viewed in connection with past, current, and probable future projects would not result in a significant cumulative impact. Mitigation Measure Following implementation of through 3.2-3, cumulative impacts associated with agricultural resources would be less than significant. Less than significant Air Quality The SSAB is used as the geographic scope for the analysis of cumulative air quality impacts due to the geographic factors which are the basis for designating the SSAB, the existence of an AQMP, SIP, and requirements set forth by the ICAPCD, which apply to all cumulative projects within the SSAB. Table 4-1 lists the projects considered for the air quality cumulative impact analysis. Operation of the projects would not result in a long-term air quality impact because of the limited number of staff required during operation and the minimal maintenance work required for the solar energy center. However, potential short-term impacts of the projects would result due to vehicle and dust emissions associated with construction activities. Similar effects would also be realized upon site decommissioning, which would be carried out in conjunction with the projects restoration plan, and subject to applicable ICAPCD standards. In accordance with CEQA Guidelines 15130(b), this analysis of cumulative impacts incorporates a summary of projections. The following three-tiered approach is to assess cumulative air quality impacts. Consistency with the ICAPCD project specific thresholds for construction and operation; Project consistency with existing air quality plans; and Assessment of the cumulative health effects of the pollutants. Project Specific Thresholds. As established previously in Impact 3.3-2, during construction, the project would result in significant and unavoidable emissions of NOx and PM10, even after implementation of mitigation measure. Thus, the project would result in a cumulatively significant impact during short-term construction. Imperial County Planning & Development Services Department 4-8 ESA /

9 During operations, the project would result in minimal emissions and would result in a less than significant cumulative impact. Air Quality Plans. The area in which the project is located, is in nonattainment for ozone and PM10. As such, the ICAPCD is required to prepare and maintain an AQMP to document the strategies and measures to be undertaken to reach attainment of ambient air quality standards. While the ICAPCD does not have direct authority over land use decisions, it was recognized that changes in land use and circulation planning were necessary to maintain clean air. As discussed above in Impact 3.3-1, the project is compliant with the AQMP and PM10 SIP and would not result in a significant impact. Cumulative Health Impacts. The localized significance analysis in Impact demonstrated that during construction and operational activities, no localized significance threshold was expected to be exceeded; therefore, the project would not result in a significant cumulative health impact. Implementation of Mitigation Measure and Mitigation Measure in Section 3.3, Air Quality. The project would result in a cumulatively significant impact during short-term construction, even after mitigation Biological Resources Cumulative projects in the area largely consist of utility-scale solar power generation facilities and related transmission lines (Table 4-1). The geographic scope for considering cumulative impacts to biological resources includes the areas containing biological resources within the Imperial County region. As urbanization pressures increase within Imperial County, impacts to biological resources within the region are increasing on a cumulative level. Because many of the cumulative projects are similar in nature to the proposed project, they would be consistent with the biological mitigation and management measures proposed in Section 3.4. Each of the projects listed in Table 4-1 would be, or has been required to provide mitigation for any impacts to biological resources. The CDFG and the USFWS have established a regulatory scheme that limits impacts to species where a potential impact could occur. Burrowing Owls are protected by the CDFG mitigation guidelines for burrowing owl (1995) and Consortium guidance (1993). The effects of the projects would be rendered less than significant through mitigation requiring compliance with all applicable regulations that protect plant, fish, and animal species, as well as waters of the U.S. and State. Other cumulative projects in the study area would also be required to avoid impacts to special-status species and/or mitigate to the satisfaction of the CDFG and USFWS for the potential loss of habitat. The proposed projects would comply with these and other laws, regulations and guidelines and therefore would not contribute substantially to a cumulative biological resources impact. Similarly, the cumulative actions within the geographic scope of the proposed projects will be required to comply with the legal frameworks set forth Imperial County Planning & Development Services Department 4-9 ESA /

10 above, as well as others. The cumulative actions will be required to mitigate their impacts to a less than significant level. Therefore, the proposed project would not contribute to a significant cumulative biological resources impact. All impacts, with appropriate mitigation, would be reduced to a level below significance. Each component of the proposed Cluster I project (Calipatria I, Midway I and Midway II) was analyzed separately but the impacts and mitigation are addressed within the context of the whole. The proposed project has some potential to result in impacts to burrowing owls, nesting raptors, migratory birds and other sensitive non-migratory bird species. However, with the implementation of the avoidance, minimization and mitigation measures outlined, these impacts would be reduced to a level of less than significant. Compliance with the goals, policies, and implementation measures of the Imperial County General Plan and implementation of through in Section 3.4, Biological Resources. Less than significant Cultural Resources The geographic scope for cumulative impacts to cultural resources includes a one-mile radius from the Project site. This geographic scope of analysis is appropriate because the archaeological, historical, and paleontological resources within this radius are expected to be similar to those in the Project site because of their proximity; similar environments, landforms, and hydrology would result in similar land-use and thus, site types. Similar geology within this vicinity would likely yield fossils of similar sensitivity and quantity. The Project area possesses the potential for significant archaeological and historical resources that, in many cases, have not been well documented or recorded. Thus, there is the potential for ongoing and future development projects in the vicinity to disturb landscapes that may contain known or unknown cultural resources. The potential construction impacts of the proposed Project, in combination with other projects in the area, could contribute to a cumulatively significant impact on archaeological and historical resources. However, this analysis includes several mitigation measures to reduce potential project impacts to archaeological and historical resources during construction of the proposed project. Future projects with potentially significant impacts to archaeological and historical resources would be required to comply with federal, state, and local regulations and ordinances protecting cultural resources through implementation of similar mitigation measures during construction. Therefore, with implementation of regulatory requirements and standard conditions of approval, and through (Section 3.5), the proposed Project would not have a cumulatively considerable contribution to impacts to archaeological and historical resources. Imperial County Planning & Development Services Department 4-10 ESA /

11 Excavation activities associated with the proposed project in conjunction with other projects in the area could contribute to the progressive loss of fossil remains, as-yet unrecorded fossil sites, associated geological and geographic data, and fossil bearing strata. However, the proposed project would have a less than significant impact to paleontological resources with the implementation of Mitigation Measure (Section 3.5), and other projects in the area would be required to comply with existing regulations and undergo CEQA review to assure that any impacts are appropriately evaluated and, if necessary, mitigated. Therefore, with implementation of regulatory requirements, standard conditions of approval, and Mitigation Measure the proposed Project would not have a cumulatively considerable contribution to impacts to paleontological resources. Following implementation of through 3.5-6, cumulative impacts associated with cultural resources would be less than significant. Less than significant Geology, Soils, and Seismicity Cumulative projects in the area largely consist of utility-scale solar power generation facilities. The geographic scope for considering cumulative impacts to geology and soils is somewhat limited to the extent of the project sites because impacts to geology and soils are generally site specific because geologic and seismic hazards can change considerably from site to site. As discussed in the EIR, the project sites as well as those in the region, are in a seismically active area, which includes major fault systems such as the southern terminus of the San Andreas fault, the Brawley Fault Zone, the San Jacinto Fault System, and the Elsinore Fault System. Other projects in the cumulative setting also share similar seismic hazards. However, the nature of these projects do not cause cumulatively significant impacts to geologic and soil resources following a seismic event. Cumulative impacts could occur in a seismic event if a potential hazard, such as a power plant, were located near a populated area. However, no such facilities exist or are planned within the development areas where the proposed project sites are located. All project construction in the region would be required to adhere to CBC requirements for seismic safety and other geologic hazards similar to that of the proposed project. In addition, implementation of site-specific SWPPPs and BMPs would reduce erosion potential from the project sites. Impacts from erosion of loss of top soil for other cumulative projects may require site specific analysis to determine the soils permeability, slope angle and length, extent of groundcover, and human influence on the sites however all those in the cumulative setting would be required to adhere to similar erosion control requirements found in the Imperial County Grading Ordinance, Title 9 Division 10, as would the proposed project. All construction phases of this project, and other foreseeable projects in the area, would be required to implement mitigation measures similar to those above and adhere to all federal, state, Imperial County Planning & Development Services Department 4-11 ESA /

12 and local programs, requirements and policies pertaining to building safety and construction permitting. All projects would be required to adhere to the Imperial County grading ordinance. Therefore, the project, combined with other foreseeable development in the area, would not result in a cumulatively significant impact by exposing people or structures to risk related to geologic hazards, soils, and/or seismic conditions. Compliance with the goals, policies, and implementation measures of the Imperial County Grading Ordinance, CBC and Imperial County General Plan is required. No additional mitigation measures are proposed. Less than significant Greenhouse Gas Emissions The three project sites are currently used for agricultural production. The current activities of the site emit a small amount of GHG emissions associated with the operation of mechanical farm equipment and vehicles. The proposed project would contribute a total of 4,021 metric tons/year tons of CO 2 e due to construction activities, or 134 metric tons/year amortized over the SCAQMD assumed project lifetime of 30-years. This is below both CEQ indicator of 25,000 metric tons and SCAQMD threshold of significance and would result in a less than significant GHG emissions impact under CEQA. During the operational phase of the proposed project, annual CO 2 e produced by the project would be 162 metric tons per year of CO 2 e. This quantity of CO2 is below both the CEQ indicator of 25,000 metric tons and the applied SCAQMD threshold of 3,000 metric tons of CO 2 e per year. Therefore, the project would not result in a long term impact on global climate change. The project would assist in alleviating dependence on fossil fuels and would provide an overall benefit to air quality by providing a clean, renewable energy source. By their nature, GHG emissions impacts are cumulative. Because GHG emission are aggregated across the global atmosphere and cumulatively contribute to climate change, it is not possible to determine the specific impact on global climate change from GHG emissions associated with solar development over the next 20 years. It is possible to predict, however, that increased solar energy generation could cumulatively result in fewer GHG emissions if it offsets electrical generation from new fossil fuel facilities. Therefore, the proposed project in combination with other closely related past, present, and reasonably foreseeable probable future projects would not result in cumulatively significant, under CEQA, impacts on global climate change. Thus, the proposed project will not have a considerable incremental contribution to global climate change. The California Legislature has recently enacted the 33 percent renewable energy portfolio standard that was originally set forth in EO S Thus, the proposed project is Imperial County Planning & Development Services Department 4-12 ESA /

13 consistent with regulations or requirements adopted to implement statewide plans for the reduction or mitigation of GHG emissions. Following implementation of Mitigation Measure and Mitigation Measure 3.7-2, cumulative impacts associated with greenhouse gas emissions would be less than significant. Less than significant Hazards and Hazardous Materials Cumulative projects in the area largely consist of utility-scale solar power generation facilities and solar generation facility operations do not involve the routine transport, use, or disposal of hazardous materials. The geographic scope for considering cumulative impacts created by hazards and hazardous materials is somewhat limited to the extent of the project sites, and each individual project is responsible for mitigating its specific hazards and risks. All projects listed in Table 4-1 must comply with all federal, state and local policies including the Imperial County General Plan. Adherence to these policies would mitigate the site-specific hazards and impacts created by hazardous materials. Additionally, there are no existing impacts related to hazardous materials at any of the three proposed project sites, and therefore the development of the sites would not result in a cumulative contribution to a significant impact. Regarding cumulative impacts associated with wildland fires, the proposed project would convert a total of 1,738 acres from agricultural land to solar PV uses and this conversion would not result in a significant contribution to a cumulative wildfire risk. The proposed land use requires little project activity, little to no introduction of population in undeveloped areas, and would include mitigation to reduce the overall potential for wildfires. The only potential hazard that warranted an impact analysis in section 3.8 is the potential hazard created by the Project s proximity to the Cliff Hatfield Municipal Airport. The project was found to be in compliance with 14 CFR Part 77 and would therefore not create an obstruction to air navigation. All past and future projects are required to consult with the individual ALUCPs and with each airport to ensure that there are no hazards related to development. Airport hazards are handled as a case by case basis. None required. Less than significant. Imperial County Planning & Development Services Department 4-13 ESA /

14 4.4.9 Hydrology and Water Quality Cumulative projects in the area largely consist of utility-scale solar power generation facilities. The projects would limit impacts on hydrology and water quality through the minimization of grading, the implementation of BMPs, and the elevation of PV trackers several feet agl. The majority of the project sites would remain in the existing, pervious state and the solar array areas would have low lying grass to control dust and storm water erosion. Therefore, the proposed projects would not adversely impact surface drainage, groundwater recharge, cause on- or off-site flooding, or alter the course of any creek or stream in the project vicinity. With implementation of the SWPPP and all recommended BMPs, the proposed projects would not result in the violation of water quality standards or substantial erosion or siltation on- or off-site during project construction or operation. Any potentially adverse impacts on hydrology and water quality during construction would be mitigated through adherence to all applicable federal, state, and local regulations and implementation of the recommendations in the site specific drainage study conducted for the proposed project. Therefore, all project-specific impacts are considered less than significant. All other related projects listed in Table 3-4 would be subject to the same federal, state and local regulations regarding drainage plans and flooding potential as the proposed projects. Furthermore, each related project would also be required to devise and implement a SWPPP with BMPs that address erosion and sedimentation control during construction and operational activities. Therefore, the proposed projects, in conjunction with all related projects, would also not adversely impact hydrology and water quality in the project area. With adherence to all applicable regulations and implementation of mitigation, no apparent significant cumulative impacts are anticipated to result from the proposed projects. Compliance with applicable federal and state regulations as well as the goals, policies, and implementation measures of the Imperial County General Plan is required. No additional mitigation measures are proposed. Less than significant Land Use The area influenced by cumulative land use effects related to adjacent parcels and the surrounding planned development areas is discussed in Table 4-1. Several other large solar projects may be developed in the areas surrounding the project sites in the future. Additionally, other related land use projects in the surrounding areas have been included that were: (1) submitted for plan processing; (2) approved by Imperial County; and/or (3) engaged in active construction programs. While the surrounding area is still relatively rural in nature, the proposed project would contribute to a cumulative influence on proposed land uses in and around the project sites. Imperial County Planning & Development Services Department 4-14 ESA /

15 The anticipated project impacts in conjunction with cumulative development in the project area would increase urbanization and result in the loss of open space and temporary loss of agricultural lands within the Calipatria region of the County. Potential land use impacts are sitespecific and require evaluation on a case-by-case basis. This is true with regard to land use compatibility impacts, which are generally a function of the relationship between the interactive effects of a specific development site and those of its immediate environment. However, as discussed above, the proposed project would maintain consistency with the goals and policies of the Imperial County General Plan. With approval of all discretionary requests, the proposed project would be an allowable use that would not conflict with the land use or zoning designations for the sites. In addition, the project would promote Imperial County s renewable energy policies and would be consistent with the County s goal, as stated in its April 20, 2010 proclamation. Therefore, the proposed project would not have a cumulatively considerable impact regarding land use. All related project impacts would be required to undergo environmental review, in accordance with the requirements of CEQA. Each related project would also be required to demonstrate consistency with all applicable planning documents governing their respective project sites, including the Imperial County General Plan, the Imperial County Zoning Ordinance. Should potential impacts be identified, appropriate mitigation would be prescribed that would likely reduce potential impacts to less than significant levels. Therefore, the proposed project, in conjunction with all related project, would not create a cumulatively significant impact with regard to land use. Cumulative impacts would be less than significant and no mitigation is required. None required. Less than significant Noise The geographic scope of potential cumulative noise impacts would be the proposed facility site and its immediate geographic area that could be affected by noise from construction and heard by sensitive receptors. A cumulative impact arises when two or more individual projects, when considered together, are considerable or which compound or increase other environmental impacts. Cumulative impacts can result from individually minor but collectively significant impacts, meaning that the project s incremental effects must be viewed in connection with the effects of past, current, and probable future projects. Notably, any project that would individually have a significant noise impact would also be considered to have a significant cumulative noise impact. Construction of the Proposed Projects combined with other projects in the County could generate noise levels that would affect existing ambient noise conditions in the region. Construction of Imperial County Planning & Development Services Department 4-15 ESA /

16 some projects could occur simultaneously and within the same areas as the proposed projects. This could result in a cumulative increase in noise levels, which could adversely impact sensitive receptors. Construction activities associated with implementation of the project in combination with other projects in the County would all be subject to the County Code. Implementation of Mitigation Measure would reduce construction noise levels to ensure that the proposed project would not result in a cumulatively considerable noise impact. Other projects operating in the area may contribute considerably to unacceptable noise levels resulting from permanent sources, however, future operation of the proposed projects would not result in long-term noise increases. Therefore, cumulative impacts would be less than considerable with mitigation. Following implementation of Mitigation Measure , cumulative impacts associated with noise would be less than significant. Less than significant Public Services Fire Protection Services The geographic scope for fire protection is the service area of the Imperial County Fire Department, which includes residential and nonresidential development in the unincorporated areas of the county. Under cumulative conditions, the fire department would continue to provide fire protection services to Imperial County, including the project site. The Calipatria Fire Department would be the first responders to the Cluster I project site, therefore there the project would create a greater cumulative impact to the areas serviced by this fire facility than it would to any other fire facility in the county. Currently, several projects are approved or under application with the County. In addition to the Cluster I Solar Power project, several projects are proposed in the vicinity of the project site. Table 4-1 provides a list of these projects. The cumulative projects would incrementally increase demand for fire protection services in unincorporated Imperial County. The Cluster I project site, as well as many of the cumulative projects sites, would be in a portion of the county that was previously undeveloped agricultural land. The County of Imperial Service Area Plan states that as development continues to occur, response times may increase due to the potential for simultaneous calls. Therefore, the proposed projects contribution to the demand for fire and emergency medical services would be potentially cumulatively considerable without additional financial support from the project. As discussed in Section 3.12, the applicant would be required to pay a Development Impact Fee assigned by the Imperial County Planning and Development Department while the proposed project is operational in order to mitigate any potential impacts to fire or police protection services resulting from the proposed project. With payment of the required mitigation fee as Imperial County Planning & Development Services Department 4-16 ESA /

17 assessed by the Imperial County Planning Department, any additional fire protection services, facilities or personnel required as a result of the proposed project would be appropriately funded. Therefore, the proposed project would not create a cumulatively considerable impact related to fire protection services. Similar to the proposed project, all of the related projects in Imperial County listed in Table 4-1 would also be required to pay this mitigation fee, if deemed appropriate by the Imperial County Planning and Development Department. These projects would also be required to undergo environmental review, in compliance with the requirements of CEQA. Should potential impacts to public services be identified, appropriate mitigation would be prescribed that would reduce impacts to less than significant levels. Therefore, because the project would not create a significant impact on fire protection services, and the other related projects would also be expected to avoid or mitigate impacts on fire protection services, cumulatively significant impacts are not anticipated and no mitigation is required. None required. Less than significant. Law Enforcement Services The geographic scope for law enforcement would be the service area of the Imperial County Sheriff s Department, which includes incorporated cities and unincorporated areas. Under cumulative conditions, the Sheriff s Department would continue to provide law enforcement services to Imperial County, including the project site. The projected cumulative development in the county would increase both the resident population and the number of nonresidential structures requiring law enforcement protection. The Brawley Sheriff s Substation would be the first responders to the Cluster I project site, therefore there the project would create a greater cumulative impact to the areas serviced by these facilities than it would to any other sheriff facility in the county. Currently, there are several projects that are approved or under application with the County. In addition to the proposed Cluster I Solar Power project, several projects are proposed in the vicinity of the project site. Table 4-1 provides a list of these projects. The proposed project, along with the cumulative projects, would result in slight incremental increases in demand for law enforcement services in unincorporated Imperial County. The Cluster I project site, as well as many of the cumulative projects sites, would be in a portion of the county that was previously undeveloped agricultural land. Based on the nature of the projects and their rural locations, the projects are not likely to attract vandals or other security risks. Therefore, the projects will not dramatically increase the need for law enforcement services Overall increases in development in the county may result in increased demand for law enforcement services under cumulative conditions. The County of Imperial Service Area Plan states that as development continues to occur, response times may increase due to the potential for simultaneous calls. Therefore, the proposed project s contribution to the demand for law Imperial County Planning & Development Services Department 4-17 ESA /

18 enforcement services would be potentially cumulatively considerable. However, the proposed project, as well as all other development occurring in the county, would be required to pay development impact fees in accordance with Ordinance 1418 for the Sheriff s Department. These fees would be used to supplement the fair share of the costs of equipment and services necessitated by each individual development project. Therefore, impacts to law enforcement services would be reduced by the Development Impact Fees on a project-by-project basis. Overall, the proposed projects contribution to law enforcement services would be less than cumulatively significant and no mitigation is required. None required. Less than significant Traffic and Transportation Cumulative projects in the area largely consist of utility-scale solar power generation facilities. The nature of these projects is such that, like the proposed project, they would create some construction traffic, but would have minimal traffic associated with operations and maintenance. The area influenced by cumulative traffic effects related to adjacent parcels and the surrounding planned development areas is discussed in this chapter. Several other large solar projects may be developed in the areas surrounding the project sites in the future. As described above, the proposed project would not result in significant impacts on transportation and traffic. Even during construction, increased traffic associated with personnel and delivery of equipment and materials would not significantly affect road capacity or traffic volumes, given the remote locations of the sites of this project and the low amount of existing traffic. As there are no major existing public roads that extend from the project sites, vehicle travel to this area of Imperial County is minimal and is not projected to increase during construction of the project. Therefore, the proposed project, in conjunction with other related projects in the area would not contribute to cumulative impacts on transportation and traffic. Cumulative impacts would be less than significant. None required. Less than significant Utilities Cumulative projects in the area largely consist of utility-scale solar power generation facilities that are primarily built on agricultural land. Much like the Cluster I project, these sites generally Imperial County Planning & Development Services Department 4-18 ESA /

19 have existing utility infrastructure and require minimal updates and alterations to this infrastructure to meet the needs of the site and comply with development laws. The geographic scope of the cumulative projects impact on utility services would be the area serviced by each utility. Therefore, the area influenced by cumulative impacts to water supply would be the IID water service area, solid waste disposal would be the Allied Waste Management service area, electricity would be the IID energy service area, and telephone would be the AT&T service area. Each of the projects that lie within the utilities service areas are subject to the same Federal, State, and Local laws that regulate water supply, wastewater disposal/recycle, stormwater drainage, and solid waste disposal. Additionally, they are subject to the same water availability, energy availability, and landfill capacity, none of which will be exceeded due to the cumulative development. Therefore, the cumulative impacts to existing utility services are less than significant. Additionally, the cumulative project sites largely consist of agricultural fields which have been graded to slope towards IID drains. Therefore the grading and soil movement needed to build stormwater retention drains to comply with the Water Element of the Imperial County General Plan will be minimal and will not impact areas beyond each project site. The cumulative projects will require little to no new infrastructure construction or development beyond drainage alterations, therefore, the cumulative projects impact to utility services will be less than significant. None required. Less than significant. Imperial County Planning & Development Services Department 4-19 ESA /

20 TABLE 4-1 POTENTIAL CUMULATIVE PROJECTS Map No. Project Name/ Application # Project Location (Imperial County) Owner/ Applicant Summary Project Description Project Type Status Distance (approx) Existing Projects 1 Niland Gas Turbine Plant 2 KN/KS Transmission Line Tubular Pole Replacement Project 1 Northeast of Niland West Chocolate Mountain Evaluation Area 3a F Line West Chocolate Mountain Evaluation Area 3b N-Line West Chocolate Mountain Evaluation Area IID IID IID IID 93 MW simple-cycle power plant on a 22-acre site adjacent to the IID's existing Niland Substation. 230-kV transmission line upgrade (Highline to Mirage). Interconnects to the SCE Mirage Substation. 161-kV transmission line (Midway to Blythe). Interconnects to the Western Area Power Administration (WAPA) Balancing Authority. 92-kV transmission line (Midway to Coachella Valley). Connects to the SCE Mirage Substation. 4 SR 111 Upgrade Imperial County Imperial County Upgrade to 6-lane freeway with interchanges at Jasper Road, McCabe Road, Heber Road and overcrossing at Chick Road from SR-98 to I-8 (post mile R1.2 R7.7). 5 Ormat Continuing Operations CA Geothermal Leases: 2 CACA CACA CACA CACA CACA CACA EUIPH Wind Farm, San Gorgonio Westwinds II LLC, San Gorgonio Wind Plant WPP1993, Wintec Ltd. SR 115 and I-8 San Gorgonio Pass Area, Riverside County ORRESOURCES Geothermal Existing 6.5 miles Transmission Existing 4.5 miles Transmission Existing 4.5 miles Transmission Existing 4.5 miles Transportation Existing 21 miles Geothermal energy development leases. Existing 26 miles Wintec, Ltd. Multiple wind power plants, ranging from 7.5 MW to 43 MW in size. Existing 45 miles Imperial County Planning & Development Services Department 4-20 ESA /