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Letter - P3Page 31

Response to Comment P3-42The previous Draft EIR/EIS has been revised to reflect this concern.This change is indicated in this Final EIR/EIS in subsection 3.13 underSection 4.2, Text Revisions.

Response to Comment P3-43The second implementation scenario for the Proposed Project (QSAImplementation) includes the more restrictive limit on IID's futurediversions of Colorado River water on IID's Priority 3 diversions. Underthe maximum transfers provided for under the QSA, IID would retain theability to divert in excess of 2.6 MAFY of Colorado River water foragricultural, industrial, and domestic use within the IID water servicearea. This amount is anticipated to be sufficient for continuedagricultural production at Baseline levels.

Response to Comment P3-44Without a specific reference to a part of the Draft EIR/EIS, thiscomment is too general to respond to. Comment noted.

Response to Comment P3-45Refer to response to Comment P3-3.

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Letter - P3Page 32

Response to Comment P3-46Please refer to the following Master Responses in Section 3 of thisFinal EIR/EIS: Air Quality Salton Sea Air Quality Monitoring andMitigation Plan; Air Quality−−Air Quality Issues Associated withFallowing, and Air Quality−−Wind Conditions at the Salton Sea in thisFinal EIR/EIS.

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Letter - P3Page 33

Response to Comment P3-47Please refer to the Master Response on Air Quality Salton Sea AirQuality Monitoring and Mitigation Plan in Section 3 of this FinalEIR/EIS.

Response to Comment P3-48As part of its action approving or not approving the Proposed Project, itis anticipated that the IID Board will consider whether fallowing shouldbe the exclusive conservation measure or one of a number ofconservation measures, whether there should be a limit on the totalamount of fallowing, and whether measures to offset economic impactsare appropriate. The EIR/EIS identifies the maximum acreage thatwould be fallowed if fallowing is the exclusive conservation method, aswell as the magnitude of the socioeconomic impacts of fallowing andother conservation measures.

We also note that the Proposed Project anticipates a flexibleconservation program with varied methods which could change overtime (see response to Comment P3-3). Also, refer to the MasterResponse on Socioeconomics Property Values and Fiscal ImpactEstimates in Section 3 of this Final EIR/EIS.

Response to Comment P3-49Further clarification of the impacts to Imperial County social servicesand revenues are addressed in the Master Response onSocioeconomics Property Values and Fiscal Impact Estimates inSection 3 in this Final EIR/EIS. Also, see response to Comment P3-38.

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Letter - P3Page 34

Response to Comment P3-50Please refer to the Master Response on Other Growth InducementAnalysis in Section 3 of this Final EIR/EIS.

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Letter - P3Page 35

Response to Comment P3-51The Lead Agencies for the Proposed Project will consider publiccomments on the IA EIS and QSA PEIR prior to making a decision onthe Project. Similarly, the Lead Agencies for the IA and QSA willconsider public comments on all three documents, and the responsesto those comments, prior to making a decision on the IA and QSA.

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Letter - P3Page 36

Response to Comment P3-52Comment noted.

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Letter - P3Page 37

Response to Comment P3-53The Draft EIR/EIS considers a range of conservation measures,including fallowing. In Chapter 2 of the Draft EIR/EIS, the LeadAgencies recognize that the IID/SDCWA Transfer Agreement providesthat fallowing would not be a permitted conservation method under IID'scontracts with landowners. Thus, unless the fallowing prohibitionprovisions of the IID/SDCWA Transfer Agreement are waived ormodified, fallowing by landowners could not be used to conserve theprimary amount to be transferred to SDCWA. However, the IID/SDCWATransfer Agreement does not prohibit fallowing by IID (as opposed toindividual landowners) to conserve the primary amount or fallowing byeither IID or landowners to create the discretionary amount.

Response to Comment P3-54Please refer to the Master Response on Socioeconomics Crop TypeAssumptions for Socioeconomic Analysis in Section 3 of the FinalEIR/EIS. It would be speculative to anticipate whether or when newcrops might be introduced to the IID water service area's agriculturalcrop rotation during the 75-year period of the Project, or what thesecrops might be. The modeling assumption used for the economicimpacts analysis assumes that the historic range of crops grown in theregion would continue to be grown into the future.

In addition, the predicted water requirements for agricultural productionin the Imperial Valley will not be compromised by the Proposed Project.Under the maximum transfers provided for under the QSA, IID wouldretain the ability to divert in excess of 2.6 MAFY of Colorado Riverwater for agricultural, industrial, and domestic use within the IID waterservice area. This amount is anticipated to be sufficient for continuedagricultural production at Baseline levels.

Response to Comment P3-55The comment is noted. The purpose of the Draft EIR/EIS is to evaluatethe environmental impacts of the Proposed Project rather than theviability of the water conservation program in the Imperial Valley. Theimpact to farmers of early termination of the transfer program would bedependent on the terms and conditions of the contracts IID signs withfarmers to implement the conservation program.

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Response to Comment P3-56The IID/SDCWA Transfer Agreement has an initial term of 45 years after transfers commence. Once the primary and discretionary amounts are established and fully phased in, IID mustcontinue to conserve and transfer these amounts, and SDCWA must continue to acquire these amounts, for the initial term of 45 years. Thereafter, IID and SDCWA each have an optionto extend the term for an additional 30 years, until 2077. If both IID and SDCWA opt to extend the term of the IID/SDCWA Transfer Agreement, SDCWA and MWD would also need toextend the term of the MWD/SDCWA Exchange Agreement.

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Letter - P3Page 38

Response to Comment P3-57The comment recommends consideration of an additional approach formitigating impacts of a declining Sea elevation on a variety of fish andwildlife species. The recommended approach outlines the potentialbenefits of actively working with freshwater (drain water) discharges tothe Sea to create a network of vegetated channels that would supportfish and wildlife. This approach is consistent with the proposed pupfishand tamarisk scrub habitat conservation strategies. As identified inmeasure Pupfish -3 and the subsequent discussion of its justification,the HCP directs IID to manage the drain channels (including the Newand Alamo Rivers) as they extend over exposed seabed. This isspecifically intended to benefit pupfish, but also would be expected tobenefit other species as well. In addition to the management of thesenew channels for the benefit of pupfish, the conservation strategy fortamarisk scrub in the HCP outlines measures that would require IID tocreate native tree habitat (up to 1,421.5 acres). If the soil characteristicsof the exposed seabed and water quality were appropriate to supportnative trees, these new channels could be used for these plantings. TheHCP IT would determine the locations and specific characteristics ofnative tree habitat. The concepts recommended for inclusion arealready elements of the currently proposed HCP.

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Letter - P3Page 39

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Letter - P3Page 40

Response to Comment P3-58The commenter recommends integrating the managed marsh requiredto be constructed under the HCP with the proposed managed deltaapproach, which is mentioned in Comment P3-57, and locating themanaged marsh on the Seabed. A managed delta approach is notproposed as part of the Proposed Project and therefore is not aconsideration as to where the managed marsh units will be located.However, if the Salton Sea Restoration Project adopts the manageddelta recommendations, there will be an opportunity to integrate theapproaches. In implementing the HCP, the HCP Implementation Teamwill be involved in locating the managed marsh units and couldrecommend installing managed marsh units in areas of exposedseabed if sufficient area is available and soil characteristics areappropriate.

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Letter - P3Page 41

Response to Comment P3-59See responses to Comments P3-12, P3-13, P3-15, P3-57, and P3-58.

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Letter - P3Page 42

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Letter - P3Page 43