Appendix B – Fremont Valley Preservation Project
ES 1.10 (p. 294 of 6840) Provide for absolute control of the approved CUP for the FVPP by Kern County directing AquaHelio which implements the GMMMP” In Draft EIR statement is made that no CUP will be needed. Which is the correct statement?
ES1.12 (p. 294 of 6840) describes Kern County’s receipt of 10% of native water and water bank water – a right in perpetuity (or as long as the project exists) provided at State Water Project (SWP) rates for municipal, agricultural or commercial uses.
ES4.24.5 (p. 312 0f 6840) Describes ASR (Aquifer Storage and Recovery) as use of surplus water Will agreements for delivery of water annually put an undue burden on production of Native groundwater to meet the demands causing lowering of groundwater levels, mining of groundwater, degradation of water quantity and quality? In fact ES2.2.6 states that “In the event of a shortage of supply, the native water shall be delivered in order of priority above from first to fifth.” ES2.2.1 - Es2.2.7 lists priority levels for delivery of water with Edwards Air Force Base (7,500 AFY) and China Lake Naval Air Weapons Station (TBD) as priority one level.
No mention of Rand Water District in ES2.2.3 “local water users, community or water purveyors in the larger area of Kern County, or in the South Lahontan Basin”
ES4.24.23 (p.317) “…mixing water from different sources may cause geochemical reactions in the aquifer that can improve or degrade groundwater quality.”
ES4.24.28 (p. 318) arsenic, iron, manganese, nitrogen, selenium and sulfur have been identified as constituents of concern in water banking projects.
ES4.4.4 (p. 298 of 6840) describes “Put” and “Take” to be managed, according to ES4.1.6, “in such a way as to avoid any long term adverse consequences to the water delivery obligations of AquaHelio and the JPA”
**(p. 506 of 6840) “In regards to native recharge, there is projected large volumes exceeding 300,000 to 500,000 AFY of net deep influx of native infiltration into the migratory groundwater from the potential available supply of 6.0 MAFY over along networks of bedrock structural fabric, jointing, fracture and fault zones that likely accounts for a large percentage of recharge, particularly at depth, which is consistent with adjoining basin understanding and findings.” These elements of subsurface recharge (from the northeast and interties to other basins) are not addressed in Appendix H in discussion of determination of recharge and are not included as part of recharge data. Appendix B goes into much detail to describe the “important recent findings” and “state of conceptual study” to show “These extrabasinal tectonic elements are believed to be capable of capturing and transmitting large volumes of water with a general gradient toward Fremont Valley” (p. 354)
Descriptions of interregional ties and interconnections from Mount Whitney and the Owens Valley, through Indian Wells Valley to El Paso Basin, and through a “funnel” into Fremont Valley – see pp. 360,362,418,434,442,452,465,478,479 of 6840. Supporting documents include work of GD Thyne et al (p. 417) to show flows through subsurface fractures, Dibblee to show depth of basin (p .429), Cheadle et al (p. 442), Monastero et al (p. 446, 449, 452) to show stratigraphy and lithology. Since these are new and conceptual in nature, yet seem to be presented to show that there is a large volume of deep recharge to support the FVPP, we recommend that some studies be developed and implemented to determine the facts of the situation before the project is implemented. Section 220.127.116.11, Groundwater exists in multiple complex aquifer systems states “Understanding of the basin complexity is ongoing and will ultimately define put and takes and native versus imported banked waters.” Other sections of the DEIR do recommend further geologic research. In fact it is stated multiple times that the TAC will be monitoring and testing as the project is implemented. We believe it would be best to do the studies in advance of implementation of the project to protect the Fremont Valley groundwater basin from degradation and irreversible damage. The studies could relate to the development of tracking mechanisms to fingerprint native waters as described in 18.104.22.168 (p. 507). Studies could determine whether the data presented in the SoilWorks section of Appendix B is a ruse or whether it is a reality.
6.4.5 (p. 364) Describes Fremont Valley as “one of the deepest basins in the Mojave and Basin and Range”
6.4.14 (p. 365)states “the basin is considered to be tectonically and seismically active”
6.4.16 (p. 365) states “seismic activity within the FVPP area and exposure to strong ground motion from regional earthquakes are likely over the life of the Project”
In terms of the stated mission to avoid any interruptions to the water delivery obligations, and to use the native groundwater production to meet those obligations when banked water supplies are not available, we believe that it is vitally important to establish the parameters of the native groundwater that is available to avoid mining and degradation of the groundwater resources. Once the project is implemented and participants are dependent upon their deliveries of water, it will be extremely difficult, if not impossible, to stop the process when monitoring shows that mitigation measures must be immediately enforced. How do you stop effects when impacts are already determined to be under way? It is important for the long term sustainability of the project to know the parameters before the investment is made in the water banking proposal for the project.
Notes prepared for Eastern Kern County Resource Conservation District October 17-23, 2013
By President Donna C. Thomas