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2.7 Comment Letters Received after Deadline TABLE 2-9 COMMENT LETTERS RECEIVED AFTER DEADLINE Commenter Date of Comment Signatory and Title Joe Schumacher Rancho Cucamonga Chamber of Commerce 04/12/2012 Chairman of the Board Larry Witt, Individual 04/26/2012 – NPCA-CBD et al. 05/04/2012 Adam Lazar Tetra Technologies, Inc. via Rutan & Tucker, 05/07/2012 Robert S. Bower Joseph Vanderhorst Metropolitan Water District of Southern California 05/14/2012 Sr. Deputy General Counsel 05/23/2012 (2), Lozeau Drury LLP on behalf of Laborers International Union of Christina Caro 05/25/2012 and North America LaborersLocal Union 783 (4 submissions) Attorney for Local 783 06/22/12 Diane Allison, Individual 05/24/2012 – MC and Lorenzo Hagerty, Individuals 02/24/2012 – Jean Marie Naples, Individual 05/24/2012 – Anthony Nicolau, Individual 05/24/2012 – Danielle Bower, Individual 05/25/2012 – J. Capozzelli, Individual 05/25/2012 – David A. Brunetti, Individual 05/26/2012 – Phyllis Jacoby, Individual undated – Steve Jacoby, Individual undated – Heather Hahn, Individual 05/29/2012 – Benjamin and Jennifer Valentine, Individuals 05/29/2012 – Center for Biological Diversity 05/31/2012 Adam Lazar, Staff Attorney Pam Nelson, Individual 06/01/2012 – Greta Loeffelbein, Individual undated – Anuj Shaw, Individual 06/20/2012 -- The Wildlands Conservancy 06/24/2012 Claudia Sall Cadiz Valley Water Conservation, Recovery, and Storage Project ESA / 210324 Final Environmental Impact Report July 2012 O_OCCC O_RCCC I_Witt Sarah Spano From: Tom Barnes Sent: Thursday, April 26, 2012 9:37 AM To: Sarah Spano Cc: Leslie Moulton Subject: FW: Cadiz Hearing Follow Up Flag: Follow up Flag Status: Flagged From: Larry Witt [mailto:[email protected]] Sent: Thursday, April 26, 2012 7:27 AM To: Customer Service Subject: Message from Larry Witt (Contact Us Form) Message from smwd.com (Contact Us Form) Question Answer Full Name: Larry Witt E-mail: [email protected] Your Questions of When is the hearing on the proposed project for Cadiz water 1 Comments: project? Has it been scheduled? 1 1 O_NPCA-CBD et al 2 O_NPCA-CBD et al 2 CENTER for BIOLOGICAL DIVERSITY Because life is good. Re: Cadiz Water Project Submission of Water Quality Data for Colorado River May 4, 2012 Page 2 of 3 VIA email and U.S. Mail American Rivers (2004) High concentrations of nitrates and fecal matter (13) May 4, 2012 High concentration of perchlorate (14) CCRA (2006): Tom Barnes Impacts of low Colorado water quality on agricultural and municipal users (p.15) ESA 626 Wilshire Boulevard, Ste. 1100 Excessive nutrients (p.17) Los Angeles, CA 90017 Metals incl. hexavalent chromium (p.36), and mercury (p.40) FAX: 213-599-4301 High salinity in Colorado river and its effects (p. 66-68 and 70-71); Email: [email protected] High sedimentation (p.77); sedimentation impacts on drinking water (80) (noting problems during high-sedimentation periods) RE: Cadiz Valley Water Conservation, Recovery, and Storage Project Draft USBR (2004): Environmental Impact Report State Clearinghouse #2011031002 (“Cadiz Project”) Data on high salinity concentrations in lower Colorado River (p.71, 76) Negative economic impacts of high salinity concentrations (p.10) Submission of Water Quality Studies for Colorado River and Impacts to Cadiz Aquifer USGS (2000): High Salinity (p. 1) Dear Mr. Barnes, Southwest Hydrology (2004) The Center and partnering organizations submitted extensive comments on the Draft High concentrations of salinity (p.18) Environmental Impact Report for the Cadiz water project. These comments addressed the need High concentrations of selenium (p.18) for the EIR to assess water quality impacts to the groundwater when Colorado River is stored in the groundwater basin as envisioned by the project. Colorado RWQCB Basin Plan (2006 rev.) General water quality objectives (p.3-1) In order to demonstrate the critical need to study water quality impacts to groundwater Groundwater quality objectives (p.3-7 and 3-8) for the Cadiz project, I am enclosing studies on the water quality of the Colorado River. These studies indicate high levels of salinity and nitrates, sediment, selenium and perchlorate in the Taken together, these studies support our comments that water quality impacts associated Colorado river, which would negatively impact water quality in the existing aquifer if recharged with the Cadiz project are significant and detrimental, must be analyzed in detail in the EIR, and 1 with Colorado water, while raising the necessary treatment level (and treatment cost) of water must be mitigated to a less-than significant effect. that would be eventually exported (or “recovered”) from the project. Subsumed within the larger problem of sediment loads is the added problem of toxic chemicals residing within that sediment, Sincerely, including selenium, mercury and perchlorate. Based on these studies, directly importing Colorado River water into the groundwater aquifer would cause violations of state water quality standards and State Anti-degradation Policy 68-16, and may also create a long-term nuisance to local users of the shared aquifer, who will be forced to use additional filtration on their well water. Adam Lazar Attached references to water quality concerns of Colorado River water and Cadiz groundwater: Attachments Arizona • California • Nevada • New Mexico • Alaska • Oregon • Minnesota • Vermont • Washington • Washington, DC Adam Lazar, Staff Attorney • 351 California St., Suite 600 • San Francisco, CA 94104 Phone: (415) 436-9682 x320 • Fax: (415) 436-9683 • E-mail: [email protected] O_NPCA-CBD et al 2 O_NPCA-CBD et al 2 Re: Cadiz Water Project Submission of Water Quality Data for Colorado River Attachment 1: May 4, 2012 American Rivers, “America’s Most Endangered Rivers of 2004: Colorado River” (2004) Page 3 of 3 Attachments 1. American Rivers, “America’s Most Endangered Rivers of 2004: Colorado River” (2004) 2. Clean Colorado River Alliance, “Recommendations to Address Colorado River Water Quality” (January 2006) 3. Jaqueline García-Hernández, “Water Quality in the Colorado River” (Southwest Hydrology, Jan/Feb 2004, pp. 18-19) 4. United States Bureau of Reclamation, “Quality of Water, Colorado River Basin: Progress Report No. 23,” (2011) 5. United States Geological Service, “Monitoring the Water Quality of the Nation’s Large Rivers: Colorado River NASQAN Program” (February 2000) 6. Colorado River Basin Regional Water Quality Control Board, “Water Quality Control Plan: Colorado River Basin, Region 7” (2006) O_NPCA-CBD et al 2 O_NPCA-CBD et al 2 C OLORADO, UTAH, NEVADA, ARIZONA, CALIFORNIA #1 Colorado River Colorado River continued T HREAT: LOOMING POLLUTION CRISIS wastewater treatment facilities has been cut a crude, unlined impoundment on the river- Summary As much as 20 percent of the river’s water by more than 10 percent, and the current bank, the former Atlas Minerals Corporation While conflict over Colorado River water evaporates from the reservoirs behind the administration proposes slashing site is the fifth largest and single most danger- allocations has grabbed headlines for years, dams each year. Several of the river’s native some 30 percent — half a billion ous uranium tailings pile in the country. An water pollution problems from human waste, wildlife species are extinct, and others nearly dollars — from loan programs for estimated 110,000 gallons of radioactive toxic chemicals, and radioactive material have so. Most years, the river literally evaporates facility upgrades. groundwater seep into the river each day from been largely overlooked and threaten to get shortly after crossing the border into Mexico. A second type of contamina- this site. Uranium is one of the few carcino- much worse. Unless Congress and the federal The once vast and rich delta at the river’s RANDY SHOWSTACK BUREAU OF RECLAMATION tion is an ingredient in rocket gens considered dangerous at any level, and government step in to bolster local cleanup mouth in the Gulf of California has virtually fuel called perchlorate, which levels in the river increase by 1,660 percent in efforts, the drinking water for 25 million disappeared as a result. has been measured in Lake Mead the vicinity of the Atlas site. Americans will remain at risk. The Risk at concentrations as high as 24 Although the precise contribution from the The River parts per billion. Although no Atlas site is unknown, Southern California’s Three major sources of pollution are seeping POLLUTED WATER FROM COL- federal health standard for perchlorate has Metropolitan Water District has measured The Colorado River starts as melting snow in into the Colorado River via contaminated ORADO RIVER WATER IS USED been set, low concentrations can interfere gradually increasing levels of radioactivity in the Rocky Mountains. Covering almost groundwater. Some efforts are being made to TO IRRIGATE CROPS — TRACE with proper thyroid function and disrupt the the river hundreds of miles downstream at its 250,000 square miles, the river basin includes address each of them, but more aggressive and AMOUNTS OF THE TOXIC CHEM- body’s normal hormonal balance. The poten- Lake Havasu intake, where the drinking water portions of seven states and more than 20 better-coordinated action is needed to protect ICALS CAN BE MEASURED IN tial health effects of perchlorate are especially for 16 million people is withdrawn from the Indian nations. Despite the vastness of its the health of the river, the 25 million Ameri- PRODUCE ON SUPERMARKET significant for children because disturbances river. The National Academy of Sciences has cans who drink its water, and the wildlife and SHELVES ACROSS THE COUN- in thyroid levels during development can lead warned that it is “nearly certain that the river’s parks found along it. TRY (BELOW). to lowered IQ, mental retardation, and the course will run across the Moab site sometime Human waste from riverfront boomtowns loss of hearing, speech and motor skills. The in the future,” flooding about a half ton of BOB SCHULZ in California and Arizona contaminates the Las Vegas Valley Water District is unable to radioactive material for every man, woman, river below Hoover Dam.
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