4.

0 INTRODUCTION TO THE
ENVIRONMENTAL ANALYSIS AND
ASSUMPTIONS USED
 4.0 INTRODUCTION TO THE ENVIRONMENTAL ANALYSIS AND ASSUMPTIONS USED

The following is an introduction to the project-specific and cumulative environmental impacts

analysis and general assumptions used in the analysis. The reader is referred to the individual
technical sections of this Draft Environmental Impact Report (Draft EIR or DEIR) regarding specific
assumptions and methodology and significance criteria used in the analysis.

ANALYSIS ASSUMPTIONS GENERALLY USED TO EVALUATE THE IMPACTS OF THE PROJECT

BASELINE ENVIRONMENTAL CONDITIONS ASSUMED IN THE DRAFT EIR

Section 15125(a) of the California Environmental Quality Act (CEQA) Guidelines requires that an
EIR include a description of the physical environmental conditions in the vicinity of the project, as
they exist at the time the Notice of Preparation (NOP) is published. The State CEQA Guidelines
also specify that this description of the physical environmental conditions is to serve as the
baseline physical conditions by which a lead agency determines whether impacts of a project
are considered significant.

The environmental setting conditions of the project site and the surrounding area are described
in detail in the technical sections of the DEIR (see Sections 4.1 through 4.14). In general, these
setting discussions describe the setting conditions of the project site and the surrounding area as
they existed when the NOP for the project was released in June 2010. In addition, the DEIR
includes updated setting information since release of the NOP, such as the status of proposed
and approved large-scale development projects in the region (see Approach to the
Cumulative Impact Analysis subsection below).

GENERAL PLAN CONSISTENCY ANALYSIS

As required by CEQA Guidelines Section 15125(d), each technical section of the DEIR (Sections
4.1 through 4.14) has been evaluated for consistency with policies contained in the existing
Imperial County General Plan (January 18, 1993, as amended through January 2008).

PROJECT CONSTRUCTION EFFECTS

The proposed project is a Conditional Use Permit for a geothermal power plant, a wastewater
treatment facility upgrade, and associated well pads, located throughout the project area.
Should the project be approved by the Imperial County Board of Supervisors, the project
proposed for development has to be consistent with the General Plan and Land Use Ordinance
policies and standards. The project would be subject to Imperial County and City of Brawley
review and approval. It is at the time of development that construction impacts would occur.
During the buildout of the project area and associated infrastructure improvements, typical
construction impacts such as dust, equipment noise, water runoff, and increased or disrupted
traffic are anticipated to occur. As a result, this DEIR includes mitigation measures to reduce
these short-term, construction-phase impacts to a level of less than significant.

Construction-phase impacts that could be reduced to a level of less than significant through the
implementation of mitigation measures were identified for aesthetics, air quality, biological
resources, cultural resources, geology and soils, hydrology and water quality, land use and
planning, noise, public services, and climate change. Project construction impacts specific to
each area or environmental analysis are evaluated in the technical sections of the DEIR
(Sections 4.1 through 4.14).

County of Imperial East Brawley Geothermal

March 2011 Draft Environmental Impact Report
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4.0 INTRODUCTION TO THE ENVIRONMENTAL ANALYSIS AND ASSUMPTIONS USED

PROJECT BUILDOUT ASSUMPTIONS

For the environmental analysis, it is assumed that buildout of the site would occur with
development of the project as currently proposed. Two phases of development are proposed.
Project operational impacts, such as traffic, air quality, noise, hydrology, and public services and
utilities, are evaluated in the technical sections of the DEIR (Sections 4.1 through 4.14). Table
4.0-1 includes the name, type of development, associated acreage, and status of other large-
scale proposed and approved development projects in the area. The location of each project is
also described in Table 4.0-1 and shown in Figure 4.0-1. The cumulative setting also assumes
existing projects. For the proposed project, it was determined that due to the distance of other
potential cumulative projects, 12 near-term cumulative development projects are included in
the analysis of the DEIR. The following is a brief description of these cumulative projects.

TABLE 4.0-1
PROPOSED AND APPROVED PROJECTS WITHIN THE CUMULATIVE STUDY AREA
OF THE EAST BRAWLEY GEOTHERMAL DEVELOPMENT PROJECT

Name
# Project Description Status
of Project
Hudson Ranch II LLC This project consists of the development of a 49.9- Mitigated Negative Declaration in
1 (Burrtec) MW geothermal energy facility on a 326-acre site in Process
Niland.
Salton Sea Solar Farm This project consists of the development of a 100-MW Application Submitted
2*
11 solar energy facility on a 640-acre site in Calipatria.
Chocolate Mountain This project consists of the development of a 49.9- Environmental Impact Report in
3 Solar Farm MW photovoltaic solar energy facility on a 320-acre Process
site in Niland.
Frink Road Solar This project consists of the development of a 30.4- Mitigated Negative Declaration in
4 Power MW photovoltaic solar energy facility on a 280-acre Process
site in Niland.
Black Rock Unit #1, 2, This project consists of the development of a 159.0- Environmental Review in Process
5 3 MW geothermal energy facility on a 160-acre site in
Niland.
Energy Source Solar 1, This project consists of the development of an 80-MW Pre-application Phase
6
LLC solar energy facility on a 480-acre site in Niland.
IV Solar This project consists of the development of a 709-MW Completed
7
solar energy facility on a 6,140-acre site in Octotillo.
Salton Sea Solar Farm This project consists of the development of a 49.9- Application Submitted
8* 1 MW solar energy facility on a 320-acre site in
Calipatria.
Superstition Solar 1 This project consists of the development of a 500-MW Joint Environmental Impact
9 photovoltaic solar energy facility on a 5,516-acre site Report/Environmental Impact
in Westmorland. Statement in Process
Keystone Solar Power This project consists of the development of a 6.1-MW Mitigated Negative Declaration in
10 photovoltaic solar energy facility on a 40-acre site in Process
the Mesquite Specific Plan area.
Ormat 21, Wister This project consists of the development of a 49.9- Application Submitted
11 Project MW geothermal energy facility located north of
Niland.
Ram Power This project consists of the development of a Application Submitted
12
geothermal energy facility located near Orita.
13 Casey Water Well Proposal for a water well. Pending
*Projects 2 and 8 are the same project located on two different parcels.

East Brawley Geothermal County of Imperial

Draft Environmental Impact Report March 2011
4.0-2
 Frink Road Solar Power
S
T
111
#
*
Bombay Beach

Chocolate Mountain
#
*
Ormat 21, Wister Project

#
*
IV Solar Company

#
*
T:\_GIS\IMPERIAL_COUNTY\MXD\ORMATTGEOTHERMAL\SURROUNDING PROJECTS_JAN2011.MXD - 2/9/2011 @ 9:01:21 AM

Energy Source Solar 1,LLC Niland

Salton Sea
#
*
Hudson Ranch II
#
*
Salton Sea Solar Farm 1
Black Rock Unit# 1 2 3
#
* Calipatria
#
*
#
*
Salton Sea Solar Farm 11 Salton Sea Solar Farm 11
#
*
S
T
115

S
T
78
Superstition Solar 1 T
S
115

#
*
S
T
111

Westmorland East Brawley Geothermal

Casey- Water Well

#
*
^ Ram Power

#
*
Brawley T
S
78

Legend T
S
86
S
T
111

#
* Surrounding Projects
#
*
Keystone Solar Power

3 Mile Search Radius

Source: ESRI Street Basemap, Imerial County, PMC Imperial

Figure 4.0-1
2 0 2

MILES Cumulative Projects

 4.0 INTRODUCTION TO THE ENVIRONMENTAL ANALYSIS AND ASSUMPTIONS USED

STRUCTURE OF THE ENVIRONMENTAL IMPACT ANALYSIS

Sections 4.1 through 4.14 of this Draft EIR contain a detailed description of current setting
conditions (including the applicable regulatory setting), an evaluation of the direct and indirect
environmental effects resulting from the implementation of the proposed project, identification
of proposed General Plan Update policies, action items, and code sections that mitigate the
environmental effect, additional feasible mitigation measures, and identification of whether
significant environmental effects of the project would remain after application of proposed
policies and action items, and feasible mitigation measures. The individual technical sections of
the Draft EIR include the following information.

Existing Setting

The subsection includes a description of the physical setting conditions associated with the
technical area of discussion, consistent with State CEQA Guidelines Section 15125. As identified
above, the existing setting is based on conditions as they existed when the NOP for the project
was released in June 2010.

Regulatory Framework

This subsection consists of the identification of applicable federal, state, regional, and local
plans, policies, laws, and regulations that apply to the technical area of discussion.

Impacts and Mitigation Measures

The Impacts and Mitigation Measures subsection identifies direct and indirect environmental
effects associated with implementation of the proposed project and identifies ways to mitigate
the environmental effects. Standards of significance are identified and used to determine
whether identified environmental effects are considered significant and require the application
of mitigation measures. Each environmental impact analysis is identified numerically (e.g.,
Impact 4.8.1 Construction Impacts on Surface Water Quality) and is supported by substantial
evidence included in the discussion. In addition to impacts created from the application of the
standards of significance, the DEIR also addresses impacts to the provision of the proposed
General Plan policies that could result in significant environmental effects.

Mitigation measures for the proposed project were developed through a thorough review of the
environmental effects of the project site by consultants with technical expertise as well as by
environmental professionals. The mitigation measures identified consist of performance
standards that identify clear requirements that would avoid or minimize significant
environmental effects (the use of performance standard mitigation is allowed under State CEQA
Guidelines Section 15126.4(a) and is supported by case law Sacramento Old City Association v.
City Council of Sacramento [3d. Dist 1991] 229 Cal.App.3d 1011, 1028 [280 Cal.Rptr. 478]).

APPROACH TO THE CUMULATIVE IMPACT ANALYSIS

Definition of Cumulative Setting

CEQA Guidelines Section 15130 requires that EIRs include an analysis of the cumulative impacts
of a project when the projects effect is considered cumulatively considerable. In general, the
cumulative setting conditions considered in this DEIR are based on the existing land use plans
(General Plan and Land Use Ordinance) provided by Imperial County. The proposed project site
contains approximately 3,066.9 acres on 40 parcels that are currently designated with a variety
County of Imperial East Brawley Geothermal
March 2010 Administrative Draft Environmental Impact Report
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4.0 INTRODUCTION TO THE ENVIRONMENTAL ANALYSIS AND ASSUMPTIONS USED

of agricultural and manufacturing Land Use Ordinance designations, as well as portions of the
City of Brawley. The current General Plan land use for the site includes agricultural and urban
land uses. Additional discussion regarding land use and zoning consistency is included in Section
3.0, Project Description, and Section 4.9, Land Use and Planning, of this DEIR.

Cumulative setting conditions also consider existing, proposed, approved, and reasonably
foreseeable large-scale development projects. For the proposed project, it was determined that
due to the distance of other potential cumulative projects, 12 near-term cumulative
development projects are included in the analysis of the DEIR in the project vicinity, as listed in
Table 4.0-1. This list of large-scale projects is intended to describe large-scale development
activities in the vicinity of the project (cumulative study area) and is not intended to be an all-
inclusive list of projects in the County of Imperial and City of Brawley.

The cumulative setting varies for each environmental issue area, depending upon the resources
affected and any relevant boundaries. For example, some resources such as geology and soils
have relatively site-specific impact potential, while other resource areas such as air quality are
studied on a regional basis, covering the entire air basin within which a proposed project lies.
Each technical section of the DEIR includes a description of the geographic extent of the
applicable cumulative setting, based on the characteristics of the environmental issues under
consideration as set forth in Section 15130(b) of the State CEQA Guidelines.

Consideration of Cumulative Impacts

Each technical section in the Draft EIR includes a description of the cumulative setting
geographic extent based on the characteristics of the environmental issue under consideration
(e.g., consideration of the Salton Sea Air Basin for cumulative air quality analysis) as set forth in
Section 15130(b) of the State CEQA Guidelines. Each section also considers whether the
projects contribution to anticipated significant environmental effects that would occur under
cumulative setting conditions is cumulatively considerable (i.e., a significant effect).

Cumulatively considerable means that the incremental effects of an individual project are
significant when viewed in connection with the effects of past projects, the effects of other
current projects, and the effects of probable future projects (CEQA Guidelines Section
15065(a)(3)). Cumulative impacts can result from individually minor but collectively significant
projects taking place over a period of time (CEQA Guidelines Section 15355(b)). The
determination of whether the projects impact on cumulative conditions is considerable is based
on a number of factors, including consideration of applicable public agency standards,
consultation with public agencies, and expert opinion. Section 5.0, Cumulative Impacts
Summary, provides a summary of the cumulative impacts associated with the proposed project.
Cumulative impacts are based on the projects contribution to development compared with
cumulative baseline conditions.

East Brawley Geothermal County of Imperial

Draft Environmental Impact Report March 2011
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 4.0 INTRODUCTION TO THE ENVIRONMENTAL ANALYSIS AND ASSUMPTIONS USED

REFERENCES

County of Imperial. 1993. Imperial County General Plan. Imperial County, CA. January 18, 1993,
as amended.

County of Imperial East Brawley Geothermal

March 2010 Administrative Draft Environmental Impact Report
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