By Deb Murphy
Mono County’s comments on the Los Angeles Department of Water and Power’s environmental analysis of de-watering ranch leases leave nothing on the table.
Reviewing final edits to the 19-page document prepared by Bauer Planning and Environmental Services at Oct. 16 Board meeting, the Mono County Supervisors were delighted with the detail. Though the specific requests for analysis outlined in the comments aren’t binding, it’s easy to image LADWP’s far less delighted reaction.
The County’s comments start with criticism of the lack of detail in the official Notice of Preparation and ends by invoking the Public Trust Doctrine, once reserved for the protection of navigable waterways but recently expanded to include lands that may “serve as ecological units…that may serve…as environments which provide food and habitat for birds and marine life.”
The following are some of the highlights not covered in past articles:
- LADWP’s Environmental Impact Review needs two baselines, not just the August 2018 date when the department officially stopped providing irrigation water. The letter asks for a second baseline of 2013 when the department began reducing irrigation water on 6,200 acres of grazing lands.
- Since herds grazed in Mono County during the summer spend the rest of the year in Inyo County, loss of adequate grazing in Mono will seriously impact Inyo’s ranch management plans, required by LADWP. Therefore, the EIR needs to analyze that impact.
- Eighty-two-percent of the developable land in Mono County will be encumbered in the likelihood the Greater Sage Grouse is listed as endangered as a result of loss of habitat on the grazing meadows. That economic impact needs to be covered in the EIR.
- The wetlands created by the ranchers’ spread irrigation for the last 100 to 150 years are still jurisdictional wetlands with all protections intact.
- LADWP is required to conduct tribal consultation per SB52.
- LADWP should come up with accurate estimates on the amount of irrigation water that eventually ends up in the aqueduct system and to analyze the value of irrigation practices that, basically, use Long and Little Round valleys as water storage for projected winter and early spring run-off due to climate change.
- The comments try to tweak LADWP’s memory of past issues: the dust off Owens Lake and the Long Term Water Agreement that kept 187,000 acre-feet of water out of the aqueduct. Bauer asks the department to run different scenarios that could meet the goal of sending more water to Los Angeles while still providing irrigation water for the grazing leases to avoid the future cost of mitigation.
During LADWP’s Q&A session in Mammoth Lakes last month, the anticipated timeline for a final EIR is next fall. There was no estimate on the completion of the draft EIR which kicks off another round of comments.
###LADWP_NOP_Letter signed tr