State Water interconnection Project (SCH No. 2018031010) Draft Environmental Impact Report Review Comments

By Daniel Cormode

1. The City of San Buenaventura has prepared a Notice of Availability to notify responsible and trustee agencies that an Environmental impact Report (EIR) for implementation of the State Water Interconnection Project (SWP) has been prepared and forwarded for review and comment.
2. The EIR is stated to be an “informational document based on facts”[1].
3. The project would enable delivery of State Water Project (SWP) water by wheeling water through the Metropolitan Water District of Southern California (MWD) and Calleguas Municipal Water District (Calleguas) water systems to the City of Ventura. The pipeline facilities (the “interconnection”) would also facilitate direct delivery of SWP water to the United Water Conservation District (United) and direct or in-lieu delivery[2] of SWP to Casitas Municipal Water District (Casitas). In addition the interconnection would allow the City to deliver water to Calleguas during an outage of Calleguas imported water supplies. The interconnection would be a pipeline used to transport water between Calleguas and the City’s distribution systems. 
4. The pipeline would be approximately 7 miles in length or originating in the easterly portion of the City of Ventura and traversing southerly and easterly through unincorporated Ventura County to the southwestern part of the City of Camarillo.
5. The objective of the State Water Interconnection Project (SWP) is stated to: Provide a water supply source to the City to enhance supply reliability; Improve water quality; Allow Casitas and United to receive their State Water Project entitlement; and, Enable the City to deliver water to Calleguas during an imported water supply outage.[3]

A summary and description of the various capital improvement projects which are required as a prerequisite to implementing the capability to receive and distribute State Water in the City of San Buenaventura are provided as supporting information in Table 1 – State Water Capital Improvement Plan Description and Costs below.

1. The following comments are provided regarding the adequacy and completeness of the subject EIR:
   1. The EIR is incomplete. The impact to the environment of the various capital improvement projects identified in Table 1 above which are required as a prerequisite to implementing the capability to receive and distribute State Water in the City of San Buenaventura from the interconnection pipeline are not identified or evaluated.  During the public comment portion of the Ventura Water Commission hearing on the State Water Interconnection Project Draft Environmental Impact Report (EIR), an observation was made that the EIR for the proposed State Water Interconnection Project appeared to be incomplete since it only addressed construction of the pipeline and did not include associated additional water distribution system modifications required to transmit water from the Saticoy facility to west Ventura customers.  Ventura Water staff’s response was “Ventura Water currently has the capability to deliver water from east Ventura to west Ventura,” therefore, proposed waterline and pump station improvements are not required as a prerequisite for delivering State Water from the Saticoy facility to west Ventura.  If Ventura Water staff’s response is correct, then what is the justification for the six unnecessary CIP projects totaling $47,490,000?
   2. No factual or supporting data is provided to support the conclusion that reliability of the water supply will be enhanced.
   3. No factual or supporting data is provided to support the conclusion that water quality will be enhanced.

[1] Handout, Ventura Water State Water Interconnection Project, Public Meeting Review Draft Environmental Impact Report, Slide 3, February 26, 2019

[1] In-lieu delivery means that all the SWP would be delivered to a Ventura Water customer in the Casitas service area, rather than directly delivered to Casitas, and this would offset demand on the Casitas system. Notice of Availability, February 19, 2019.

[1] Handout, Ventura Water State Water Interconnection Project, Public Meeting Review Draft Environmental Impact Report, Slide 6, February 26, 2019

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