National Public Lands

941 E Ridgecrest Boulevard

Ridgecrest, California 93555


December 7, 2012


Kern County Planning Department

2700 M Street Suite 100

Bakersfield, California 93301-2323


Attn: Jaymie L. Brauer


Subject:Notice of Preparation of a Draft Environmental Impact Report by Fremont Valley Preservation Project by AquaHelio Resources, L.L.C.


The National Public Lands a 501 C non-profit corporation and myself, a resident of Kern County, are submitting these comments.We have some general and specific comments regarding the process and the product that Kern County is proposing regarding the above project.


General Comments- The project area is made up of 4 sites that are spread out over Fremont Valley.As such, the area is interspersed with private lands, BLM lands, State lands, a competition test area, a railroad, a mining operation, the Tortoise Preserve, California City and private and Rand Water Wells.Although Kern County has tried to do its best at contacting the people that might be affected, I donít believe all the stakeholders have been notified.For instance, the Railroad that runs through that area was notified, but the mining company, Searles Valley in San Bernardino County that uses that railroad exclusively was not. We also did not see the Rand Water District on the notification list.


Although this project will require consent of agencies, not once is it mentioned that Rights of Way (ROW) consent by the BLM will be needed.We realize that under the DRECP Program that this will just be a formality, but it still should be noted.


There are Mono and Inyo County Laws that speak directly to the exporting of water from Inyo County to other water basins except for in the case of an emergency.Banking this water exportation from Inyo and Mono Counties through the LADWP was not mentioned in the Proposed Discretionary Actions/Required Approvals 1.5 page 32.


Specific Comments- Under Figure 1-2, OHV Trail CC10 is not noted.Also looking at the projected site and itís closely to the Honda Track, this will ensure that this track will never be used for the purpose that it was developed for, as the migrant dust will encompass the project site 1.


Fig 1-4, Project Site 3 does not depict the continuation of the Red Rock Randsburg Road, a County Road, between the two parcels.


Fig 1-6 does not depict Anne Road and its needed maintenance.


Fig 1-15 does not adequately show the circulation element around Red Rock State Park†† and Jawbone Station.


Page 25 Under Recharge, what types of metering system will LADWP meter the 200,000 acre-feet of water (lower quality) that they will use for the recharge system?Rightís of Way (ROWís) from BLM (necessitating an EIS) will be needed for the pipelines.


Page 25, Under Recovery, what type of metering system will LADWP meter the 100,000 acre-feet of water that they will use for the recovery system.Again, the pipeline to Edwards AFB will also need ROW (another Federal agency necessitating an EIS).


Page 34 under Potentially affected, we believe because of the more than 40 privately owned wells in that area, that Population and Housing should have been check marked. The Rand Water District has four wells that might be impacted, which might after Randsburg, Red Mountain and Johannesburg.Red Mountain is in San Bernardino County and it could affect water quality in that county along with water quality in Kern County.


Under determination, we are happy that Kern County is looking for an EIR.May we suggest that since it will impact Federal Lands that Kern County look at an EIR/EIS and the notification list be expanded.


Under Air Quality, significant impact was checked.Because of the Valley fever prominent in Kern County, anthrospores in alkali soil for fungal disease, Coccidioidomycosis, needs to be analyzed along with fugitive dust not only for humans but also for the listed tortoises by the recognized Tortoise Preserve.


Under biological resources, have concerns that there may be grazing allotments on BLM lands that are not mentioned in this analysis.


Page 67 under Recreation it states that there will be no impact to Recreation in that area.We have concerns that itís close proximity to Red Rock State Park, Jawbone Canyon, Scenic Highways and Desert Tortoise Preserve, that it will affect recreation in that area.


Under Transportation and traffic page 68.Under d, it should have been check marked significant as there are many blind spots in the roads and the intersections are not always perpendicular.Also, the new construction of Highway14 needs to be consulted with Caltrans to make sure that we donít have a plan that is not correct.


In conclusion we can only add that we hope that we are put on the notification list for the Draft and other stakeholders will be notified, not just persons that are within 500 feet of the project.


In cooperation,


Sophia Anne Merk, Director