FERC/DEIS-D-0238

DRAFT ENVIRONMENTAL IMPACT STATEMENT

FOR HYDROPOWER LICENSE

Eagle Mountain Pumped Storage Hydroelectric Project—FERC Project No. 13123-002

California

Federal Energy Regulatory Commission

Office of Energy Projects

Division of Hydropower Licensing

888 First Street, NE

Washington, DC 20426

Office of

Energy

Projects

December 2010

FEDERAL ENERGY REGULATORY COMMISSION

WASHINGTON, DC 20426

OFFICE OF ENERGY PROJECTS

To the Agency or Individual Addressed:

Reference: Draft Environmental Impact Statement

Attached is the draft environmental impact statement (draft EIS) for the proposed 

Eagle Mountain Pumped Storage Hydroelectric Project (No. 13123-002), which would be 

located in two depleted mining pits in the inactive Eagle Mountain mine in Riverside 

County, California, near the town of Desert Center, California.

This draft EIS documents the view of governmental agencies, non-governmental 

organizations, affected Indian tribes, the public, the license applicant, and Federal Energy 

Regulatory Commission (Commission) staff. It contains staff evaluations of the 

applicant’s proposal and the alternatives for licensing the Eagle Mountain Project.

Before the Commission makes a licensing decision, it will take into account all 

concerns relevant to the public interest. The draft EIS will be part of the record from 

which the Commission will make its decision. The draft EIS was sent to the U.S. 

Environmental Protection Agency and made available to the public on or about

December 23, 2010.

Copies of the draft EIS are available for review in the Commission’s Public 

Reference Branch, Room 2A, located at 888 First Street, N.E., Washington DC 20426. 

The final EIS also may be viewed on the Internet at www.ferc.gov/docsfiling/elibrary.asp. Please call (202) 502-8222 for assistance.

Attachment: Draft Environmental Impact Statement
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COVER SHEET

a. Title: Licensing the Eagle Mountain Pumped Storage Hydroelectric 

Project, FERC Project No. 13123-002

b. Subject: Draft Environmental Impact Statement

c. Lead Agency: Federal Energy Regulatory Commission

d. Abstract: On June 22, 2009, Eagle Crest Energy Company filed an 

application for an original license with the Commission for the 

proposed Eagle Mountain Pumped Storage Hydroelectric Project, 

which would be located on the site of the inactive Eagle Mountain 

mine, in Riverside County, California, near the town of Desert 

Center, California. 

The proposed project would occupy 1,059.26 acres of federal lands 

administered by the U.S. Bureau of Land Management and 

1,162 acres of private lands owned by Kaiser Eagle Mountain, LLC

(Kaiser). 

The estimated annual production from the proposed project would 

be a maximum of 4,308 gigawatt-hours of on-peak generation.

The staff’s recommendation is to license the project as proposed, 

with certain modifications and additional measures recommended 

by the agencies and staff.

e. Contact: Kenneth Hogan

Federal Energy Regulatory Commission

Office of Energy Projects

888 First Street, N.E.

Washington, DC 20426

(202) 502-8434

f. Transmittal: This draft environmental impact statement to license the Eagle 

Mountain Pumped Storage Project is being made available for 

public comment on or about December 23, 2010, as required by the 

National Environmental Policy Act of 19691

 

1 National Environmental Policy Act of 1969, amended (Pub. L. 91-190. 42 U.S.C. 

4321-4347, January 1, 1970, as amended by Pub. L. 94-52, July 3, 1975, Pub. L. 94-83, 

August 9, 1975, and Pub. L. 97-258, §4(b), September 13, 1982).

and the Commission’s 

Regulations Implementing the National Environmental Policy Act 

(18 CFR, Part 380).
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FOREWORD

The Federal Energy Regulatory Commission (Commission), pursuant to the 

Federal Power Act (FPA)2 and the U.S. Department of Energy Organization Act3

That the project...shall be such as in the judgment of the Commission will be best 

adapted to a comprehensive plan for improving or developing a waterway or waterways 

for the use or benefit of interstate or foreign commerce, for the improvement and 

utilization of water-power development, for the adequate protection, mitigation, and 

enhancement of fish and wildlife (including related spawning grounds and habitat), and 

for other beneficial public uses, including irrigation, flood control, water supply, and 

recreational and other purposes referred to in section 4(e)...

is 

authorized to issue licenses for up to 50 years for the construction and operation of nonfederal hydroelectric development subject to its jurisdiction, on the necessary conditions:

4

The Commission may require such other conditions not inconsistent with the FPA 

as may be found necessary to provide for the various public interests to be served by the 

project.5

 Compliance with such conditions during the licensing period is required. The 

Commission’s Rules of Practice and Procedure allow any person objecting to a licensee’s 

compliance or noncompliance with such conditions to file a complaint noting the basis 

for such objection for the Commission’s consideration.6

 

2 16 U.S.C. §791(a)-825r, as amended by the Electric Consumers Protection Act of 

1986, Public Law 99-495 (1986) and the Energy Policy Act of 1992, Public Law 102-486 

(1992).

3 Public Law 95-91, 91 Stat. 556 (1977).

4 16 U.S.C. § 803(a).

5 16 U.S.C. § 803(g).

6 18 C.F.R. §385.206 (2009).
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TABLE OF CONTENTS

LIST OF FIGURES............................................................................................................ ix

LIST OF TABLES.............................................................................................................. xi

ACRONYMS AND ABBREVIATIONS.........................................................................xiii

EXECUTIVE SUMMARY.............................................................................................xvii

1.0 INTRODUCTION.................................................................................................... 1

1.1 APPLICATION............................................................................................. 1

1.2 PURPOSE OF ACTION AND NEED FOR POWER.................................. 3

1.2.1 Purpose of Action ............................................................................ 3

1.2.2 Need for Power................................................................................ 3

1.3 STATUTORY AND REGULATORY REQUIREMENTS ......................... 4

1.3.1 Federal Power Act ........................................................................... 6

1.3.1.1 Section 18 Fishway Prescriptions................................... 6

1.3.1.2 Section 4(e) Conditions .................................................. 6

1.3.1.3 Section 10(j) Recommendations..................................... 6

1.3.2 Clean Water Act .............................................................................. 6

1.3.2.1 Water Quality Certification ............................................ 6

1.3.2.2 California Environmental Quality Act............................ 7

1.3.3 Endangered Species Act.................................................................. 9

1.3.4 Coastal Zone Management Act ....................................................... 9

1.3.5 National Historic Preservation Act................................................ 10

1.4 PUBLIC REVIEW AND CONSULTATION............................................. 10

1.4.1 Scoping .......................................................................................... 10

1.4.2 Interventions.................................................................................. 11

1.4.3 Comments on the License Application ......................................... 12

2.0 PROPOSED ACTION AND ALTERNATIVES................................................... 13

2.1 NO-ACTION ALTERNATIVE.................................................................. 13

2.2 APPLICANT’S PROPOSAL...................................................................... 13

2.2.1 Project Facilities............................................................................ 13

2.2.2 Project Safety................................................................................. 17

2.2.3 Project Operation........................................................................... 17

2.2.4 Proposed Environmental Measures............................................... 18

2.3 STAFF ALTERNATIVE ............................................................................ 25

2.4 ALTERNATIVES CONSIDERED BUT ELIMINATED FROM 

FURTHER ANALYSIS.............................................................................. 27
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3.0 ENVIRONMENTAL ANALYSIS......................................................................... 29

3.1 GENERAL DESCRIPTION OF THE PROJECT AREA .......................... 29

3.2 SCOPE OF CUMULATIVE EFFECTS ANALYSIS ................................ 30

3.2.1 Geographic Scope.......................................................................... 30

3.2.2 Temporal Scope............................................................................. 31

3.3 PROPOSED ACTION AND ACTION ALTERNATIVES ....................... 31

3.3.1 Geologic and Soil Resources......................................................... 32

3.3.1.1 Affected Environment................................................... 32

3.3.1.2 Environmental Effects .................................................. 40

3.3.2 Water Resources............................................................................ 48

3.3.2.1 Affected Environment................................................... 48

3.3.2.2 Environmental Effects .................................................. 60

3.3.2.3 Cumulative Effects ....................................................... 80

3.3.3 Terrestrial Resources..................................................................... 80

3.3.3.1 Affected Environment................................................... 80

3.3.3.2 Environmental Effects .................................................. 99

3.3.3.3 Cumulative Effects ..................................................... 118

3.3.4 Threatened and Endangered Species........................................... 119

3.3.4.1 Affected Environment................................................. 119

3.3.4.2 Environmental Effects ................................................ 123

3.3.4.3 Cumulative Effects ..................................................... 130

3.3.5 Recreation, Land Use, and Aesthetics......................................... 131

3.3.5.1 Affected Environment................................................. 131

3.3.5.2 Environmental Effects ................................................ 146

3.3.5.3 Cumulative Effects ..................................................... 166

3.3.6 Cultural Resources....................................................................... 168

3.3.6.1 Affected Environment................................................. 168

3.3.6.2 Environmental Effects ................................................ 179

3.3.7 Socioeconomics........................................................................... 185

3.3.7.1 Affected Environment................................................. 185

3.3.7.2 Environmental Effects ................................................ 189

3.3.8 Air Quality and Noise.................................................................. 192

3.3.8.1 Affected Environment................................................. 192

3.3.8.2 Environmental Effects ................................................ 200

3.3.8.3 Cumulative Effects ..................................................... 208

3.4 NO-ACTION ALTERNATIVE................................................................ 209
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4.0 DEVELOPMENTAL ANALYSIS ...................................................................... 211

4.1 POWER AND DEVELOPMENTAL BENEFITS OF 

THE PROJECT ......................................................................................... 211

4.2 COMPARISON OF ALTERNATIVES.................................................... 214

4.2.1 No-action Alternative .................................................................. 214

4.2.2 Eagle Crest’s Proposal................................................................. 214

4.2.3 Staff Alternative .......................................................................... 215

4.3 COST OF ENVIRONMENTAL MEASURES......................................... 215

5.0 CONCLUSIONS AND RECOMMENDATIONS............................................... 237

5.1 COMPARISON OF ALTERNATIVES.................................................... 237

5.2 COMPREHENSIVE DEVELOPMENT AND RECOMMENDED 

ALTERNATIVE ....................................................................................... 248

5.3 UNAVOIDABLE ADVERSE EFFECTS................................................. 266

5.4 CONSISTENCY WITH COMPREHENSIVE PLANS............................ 267

6.0 LITERATURE CITED......................................................................................... 269

7.0 LIST OF PREPARERS........................................................................................ 279

8.0 LIST OF RECIPIENTS........................................................................................ 281
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LIST OF FIGURES

Figure 1. Location of Eagle Mountain Pumped Storage Hydroelectric Project........... 2

Figure 2. Transmission line routes................................................................................ 8

Figure 3. Proposed facilities and reservoirs and existing features of the Eagle 

Mountain Project ......................................................................................... 14

Figure 4. Profile of the proposed Eagle Mountain Pumped Storage Project 

underground facilities.................................................................................. 16

Figure 5. Mountains and groundwater basins in the project area ............................... 33

Figure 6. Eagle Mountain Project area geologic map................................................. 35

Figure 7. Existing and proposed wells for groundwater monitoring.......................... 54

Figure 8. Recreation resources in the vicinity of the proposed project .................... 132

Figure 9. Land ownership in the vicinity of the proposed project............................ 134

Figure 10. Proposed phasing of the land fill project................................................... 138

Figure 11. Land use near the applicant’s proposed and State Water Board’s 

recommended substations locations and associated 

transmission routes.................................................................................... 152

Figure 12. Visual resources in the substation and transmission line areas................. 159
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LIST OF TABLES

Table 1. Major statutory and regulatory requirements for the Eagle Mountain 

Hydroelectric Project..................................................................................... 4

Table 2. Summary of flow data (cfs) from USGS Gage No. 10253600 ................... 48

Table 3. Relevant beneficial use definitions for the Colorado River Basin.............. 50

Table 4. Applicable water quality objectives for waters potentially affected by 

the proposed project .................................................................................... 50

Table 5. Applicable groundwater quality objectives for the 

Colorado River Basin .................................................................................. 52

Table 6. Peak flow (cfs) during the probable maximum flood ................................. 63

Table 7. Description of factors that control acid rock drainage ................................ 69

Table 8. Summary of water wells in the Chuckwalla groundwater basin that 

would potentially experience project-induced drawdown in 

excess of 5 feet ............................................................................................ 77

Table 9. Acreage of native habitats and disturbed areas on the 

Eagle Mountain Project............................................................................... 82

Table 10. Potential for special-status species.............................................................. 86

Table 11. Acreage of desert tortoise habitat in the Eagle Mountain Pumped 

Storage Project area................................................................................... 121

Table 12. Archaeological and historic resources within the Eagle Mountain 

Project APE ............................................................................................... 175

Table 13. Population.................................................................................................. 185

Table 14. Riverside County employment by sector, 2006 ........................................ 187

Table 15. Housing accommodations and characteristics........................................... 188

Table 16. Selected California and federal ambient air quality standards.................. 194

Table 17. Project area designations in 2010 under NAAQS and 

California AAQS....................................................................................... 195
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Table 18. South Coast Air Quality Management District thresholds 

(pounds per day)........................................................................................ 197

Table 19. A-weighted decibel scale sound levels of typical noise environments..... 198

Table 20. Estimated annual construction emissions (tons) ....................................... 202

Table 21. Daily construction emissions (pounds) ..................................................... 203

Table 22. Annual operational emissions (tons)......................................................... 204

Table 23. Annual offset electrical generation air emissions (tons)........................... 205

Table 24. Minimum distances and Lmax noise levels (in dBA) at 

sensitive land uses..................................................................................... 206

Table 25. Parameters for the economic analysis of the Eagle Mountain Project...... 213

Table 26. Summary of the annual cost of alternative power and annual project cost 

for the alternatives for the Eagle Mountain Pumped Storage Project....... 214

Table 27. Cost of environmental mitigation and enhancement measures considered 

in assessing the environmental effects of the proposed operation of the 

Eagle Mountain Pumped Storage Project.................................................. 216

Table 28. Comparison of the proposed action and the staff alternative for the 

Eagle Mountain Pumped Storage Project.................................................. 237

Table 29. Summary of key differences in the potential effects of Eagle Crest’s 

proposal and the staff alternative for the route of the proposed 

transmission line........................................................................................ 258
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ACRONYMS AND ABBREVIATIONS

AAQS California Ambient Air Quality Standards

ACEC Areas of Critical Environmental Concern

Advisory Council Advisory Council on Historic Preservation

APE area of potential effects

applicant or Eagle Crest Eagle Crest Energy Company

AQMD Air Quality Management District

Basin Plan Water Quality Control Plan for the Colorado River Basin 

within California

BLM Bureau of Land Management

BMP best management practice

CAISO California Independent System Operator

California DFG California Department of Fish and Game

California GS California Geology Survey

California SHPO California State Historic Preservation Officer

CAMA California-Arizona Maneuver Area

CARB California Air Resources Board

CDCA California Desert Conservation Area

CDNPA California Desert Native Plants Act

CEQA California Environmental Quality Act

cfs cubic feet per second

CH4 methane

CNPS California Native Plant Society

CO carbon monoxide

CO2 carbon dioxide

Commission Federal Energy Regulatory Commission

CRA Metropolitan Water District of Southern California’s 

Colorado River Aqueduct

CWA Clean Water Act

CZMA Coastal Zone Management Act

dBA A-weighted decibel scale

DWMA Desert Wildlife Management Area

Eagle Mountain Project Eagle Mountain Pumped Storage Hydroelectric Project

ECORP ECORP Consulting, Inc.

EIR environmental impact report

EIS environmental impact statement

EPA U.S. Environmental Protection Agency

ESA Endangered Species Act

°F degrees Fahrenheit

FERC Federal Energy Regulatory Commission

Forest Service U.S. Department of Agriculture, Forest Service

FPA Federal Power Act
xiv

FWS U.S. Department of the Interior, Fish and Wildlife Service

gpm gallons per minute

GWh gigawatt-hour

HPMP Historic Properties Management Plan

Interior U.S. Department of the Interior

JTNP Joshua Tree National Park and wilderness area

Kaiser Kaiser Eagle Mountain, LLC

kV kilovolt

kW kilowatt

mg/L milligrams per liter

Ma mega-anum, or million years ago

Metropolitan Water District Metropolitan Water District of Southern California

MOU Memorandum of Understanding

MW megawatt

MWh megawatt-hour

NAAQS National Ambient Air Quality Standards

National Register National Register of Historic Places

NECO Plan Northern and Eastern Colorado Desert Coordinated 

Management Plan

NERC North American Electric Reliability Corporation

NHPA National Historic Preservation Act of 1966

N2O nitrous oxide

NO2 nitrogen dioxide

NOx nitrogen oxides

O3 ozone

OHV off-highway vehicle

PA Programmatic Agreement

Park Service National Park Service, Joshua Tree National Park

Pb lead

PGA peak ground acceleration

PM2.5 particulate matter greater than 2.5 microns in diameter

PM10 particulate matter greater than 10 microns in diameter

PMF probable maximum flood

PSD Prevention of Significant Deterioration

REA ready for environmental analysis

Regional Water Board Regional Water Quality Control Board

ROW right-of-way

SCAQMD South Coast Air Quality Management District

SCE Southern California Edison

SD1 Scoping Document 1

SD2 Scoping Document 2

SIP State Implementation Plan

SO2 sulfur dioxide
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State Water Board State Water Resources Control Board

TCP traditional cultural property

THPO Tribal Historic Preservation Office

USGS U.S. Geological Survey

WEAP Worker Environmental Awareness Program

VOC volatile organic compound

VRM Visual Resource Management
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EXECUTIVE SUMMARY

This draft environmental impact statement (draft EIS) evaluates the environmental 

effects associated with licensing the proposed 1,300-megawatt (MW) Eagle Mountain 

Pumped Storage Hydroelectric Project (Eagle Mountain Project or project), which would 

be located on the site of the inactive Eagle Mountain mine, in Riverside County, 

California, near the town of Desert Center. The project would operate as a closed system 

and is not located on a perennial river. The project would supply system peaking 

capacity and transmission regulating benefits to the regional electrical grid. The 

proposed project would occupy 1,059.26 acres of federal lands administered by the U.S. 

Bureau of Land Management (BLM) and 1,162 acres of private lands owned by Kaiser 

Eagle Mountain, LLC. 

Proposed Action

The project as proposed by Eagle Crest Energy (Eagle Crest or applicant) would 

use reservoirs created from two inactive mining pits near the town of Desert Center, 

California. The project would consist of: (1) an upper and lower reservoir7

Eagle Crest proposes the following measures for the protection and enhancement 

of environmental resources during project construction and/or operation: (1) implement 

the Phase 1 Pre-Design Site Investigation Plan since access to the project site is currently 

limited; (2) implement the Erosion and Sediment Control Plan; (3) develop and 

implement a water management plan; (4) develop a network of groundwater monitoring

wells; (5) develop measures to prevent effects such as subsidence (from increased 

groundwater levels) on the operation of Metropolitan Water District of Southern 

California’s Colorado River Aqueduct (CRA); (6) install a reverse osmosis desalination 

facility to maintain water quality in the reservoirs at the level of the source water; 

(7) implement the Invasive Species Monitoring and Control Plan; (8) implement the 

Revegetation Plan for disturbed areas during construction; (9) construct security and 

game fencing to exclude larger terrestrial wildlife from entering project areas; 

(10) implement the Desert Tortoise Removal and Translocation Plan; (11) implement the 

Raven Monitoring and Control Plan; (12) design, install, and maintain facility lighting to 

with surface 

areas of 191 and 163 acres, respectively; (2) an underground powerhouse with four 

reversible pump-turbine units each rated at 325 MW for a total generating capacity of 

1,300 MW; (3) a 13.5-mile-long transmission line; and (4) groundwater supply facilities. 

Project facilities are described in more detail in section 2.2.1. The project would operate 

as a pumped storage facility that would involve pumping water from the lower reservoir 

to the upper reservoir during periods of low energy demand, and then releasing to the 

lower reservoir to generate electricity during periods of high demand.

 

7 As part of the project’s construction, Eagle Crest would need to install two 

saddle dams at the upper reservoir/mine site.
xviii

limit light pollution; (13) acquire land to mitigate for the desert tortoise habitat that may 

be disturbed by the project; (14) maintain recreational access to areas near the proposed 

project during construction; (15) implement the December 2009 Historic Properties 

Management Plan (HPMP); and (16) limit the effects of project construction and 

operation on air quality and noise. These and other proposed measures are described in 

detail in section 2.2.4.

Alternatives Considered

This draft EIS analyzes the effects of proposed project construction and operation 

and recommends conditions for any license that may be issued for the project. In 

addition to the applicant’s proposal, we consider two alternatives: (1) the applicant’s 

proposal with staff modifications (staff alternative); and (2) no action—whereby the 

project would not be constructed.

Under Eagle Crest’s proposal with staff modifications, the project would operate 

as proposed by Eagle Crest but would also include the following expanded or additional 

measures: (1) construct the project transmission line along the State Water Resources 

Control Board’s (State Water Board’s) recommended route, rather than the applicant’s 

proposed route; (2) connect the project to the grid by terminating the transmission line at 

the State Water Board’s recommended substation location south of Interstate 10 about 

6 miles east of the proposed substation location; (3) monitor water quality and levels of 

the reservoirs, brine ponds, and leakage during project operation; (4) make modifications 

to the stream channel along Eagle Creek, including the reservoirs and water seepage 

areas; (5) prepare a groundwater hydrologic budget report; (6) modify the proposed 

Invasive Species Monitoring and Control Plan to include criteria for success and an 

adaptive management plan if initial efforts are not successful; (7) modify the proposed 

avian protection plan to include measures to reduce avian collisions with the transmission 

line and monitor avian injury and mortality associated with the line; (8) survey for the 

spadefoot toad (a BLM sensitive species and a state of California species of special 

concern) before construction and, if found, implement measures to avoid disturbance to 

this species; (9) modify the current Raven Monitoring and Control Plan to include

monitoring populations of desert tortoise predators before and after construction and 

associated mitigation and control measures; and (10) consult with BLM, participating 

tribes, and the California State Historic Preservation Officer (SHPO) to revise the 

December 2009 HPMP. The recommended staff modifications include, or are based in 

part on, recommendations made by the federal and state resource agencies that have an 

interest in the resources that may be affected by the project’s construction and operation. 

Public Involvement and Areas of Concern

Before filing its license application, Eagle Crest conducted a pre-filing 

consultation process under the traditional licensing process. The intent of the Federal 

Energy Regulatory Commission’s (FERC or Commission) pre-filing process is to initiate 

public involvement early in the project planning process and to encourage citizens, 
xix

governmental entities, tribes, and other interested parties to identify and resolve issues 

before an application is formally filed with the Commission. After the application was 

filed, staff conducted scoping to determine which issues and alternatives should be 

addressed. Scoping Document 1 (SD1) was distributed for comment to interested parties 

on December 17, 2008. Staff held public scoping meetings in Palm Desert, California, on 

January 15 and 16, 2009. In SD1, staff requested clarification of preliminary issues 

concerning the Eagle Mountain Pumped Storage Hydroelectric Project and identification 

of any new issues that need to be addressed in the EIS. A revised scoping document 

(SD2), addressing these comments, was issued on June 5, 2009. On January 11, 2010, 

staff requested conditions and recommendations from state and federal resource agencies 

in response to the notice of ready for environmental analysis.

The primary environmental issues associated with licensing the project are the 

effects of the proposed project’s construction and operation on groundwater, water 

quality, and terrestrial species, including several state sensitive bat species, the BLM 

sensitive dessert bighorn sheep, and the threatened desert tortoise. 

Project Effects

Geology and Soils

Constructing the project would require the movement of about 3 million cubic 

yards of material for the construction of the two saddle dams and liners for the proposed 

reservoirs, additional surface excavation for the proposed water lines, and infrastructure 

associated with the proposed transmission line and substation. Under the applicant’s 

proposal, erosion and sediment transport would be controlled during construction through 

implementation of the proposed Erosion and Sediment Control Plan.

Water Resources

Groundwater levels would be affected by withdrawals that the applicant plans to 

make from a series of proposed wells in the Chuckwalla Basin to fill the reservoirs and 

replace water lost to evaporation. After the reservoirs are filled, high evaporation rates 

would degrade the water quality in the reservoirs and seepage from the reservoirs could 

affect nearby groundwater quality. Changes to the current surface water flow patterns 

during the very rare rainfall events would be affected by the proposed construction of the 

project. The reservoirs and other proposed infrastructure are designed to withstand the 

probable maximum flood inflow from Eagle Creek and smaller watersheds that would 

occasionally reach the proposed reservoirs. Under the applicant’s proposal, groundwater 

withdrawal would be limited to less than the historical levels associated with agricultural 

irrigation. Monitoring wells and other methods would determine the amount of seepage 

from the proposed reservoirs, the water level change due to pumping, water quality 

effects due to project operations, and the potential for subsidence and hydrocompaction 

near existing key infrastructure, including the CRA. A reverse osmosis system would 
xx

remove salts and metals from the reservoirs to help maintain the water quality of the 

reservoirs and counteract degradation associated with evaporation. 

Under the staff alternative, additional monitoring of the reservoirs and brine ponds 

would occur, and our modifications would provide more protection, warning, 

opportunities, and measures to rectify possible negative effects of the proposed project 

that could occur during project operation, including additional measures to protect water 

quality and perform stream channel modifications along Eagle Creek.

Terrestrial Resources

Construction of the proposed project would disturb lands within the footprint of 

the project facilities, including the reservoirs, access roads, substation, transmission lines, 

and other areas. The disturbance associated with filling the project reservoirs has the 

potential to affect bats that roost in rock crevices within the existing mine craters and 

alter migration movement for bighorn sheep. Construction of the transmission line has 

the potential to disturb desert vegetation and associated wildlife habitat that is slow to 

regenerate within the desert ecosystem. This disturbance would be associated with 

grading of access roads, storage areas, and pull sites associated with construction of the 

transmission line and water supply pipeline. Under the applicant’s proposal and the staff 

alternative, site-specific mitigation, monitoring, and compliance programs would be 

implemented during project construction and operation to limit invasive species 

colonization and environmental effects on special-status plant and animal species. 

Specifically, the applicant would implement measures in its Worker Environmental 

Awareness Program, Revegetation Plan, and Invasive Species Monitoring and Control 

Plan to limit potential effects on terrestrial resources. Security fencing is proposed to 

limit access to the majority of the central project area by bighorn sheep, deer, coyotes, 

foxes, and badgers. It is also designed to provide safe access to a project-created source 

of drinking water. Eagle Crest also plans to develop and implement a transmission line 

design plan, based on industry and regulatory standards, to protect raptors from 

electrocution hazards.

Under the staff alternative, the proposed Invasive Species Monitoring and Control 

Plan would be modified to include criteria for success and an adaptive management plan 

if initial efforts do not prove successful. Additionally, the reservoirs and water seepage 

areas would be monitored for invasive plants. The transmission line design plan would 

also be modified to include an avian protection plan that, in addition to the applicant’s 

proposed measures to prevent electrocutions, would also include measures to reduce 

potential for avian collisions with the transmission line and a protocol to monitor and 

report avian injury and mortality associated with the transmission line. Pre-construction 

surveys for the spadefoot toad would occur in all proposed construction areas not 

previously surveyed, and if this species is found, measures to avoid disturbance would be 

followed. 
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Threatened and Endangered Species

Two special-status species have the potential to occur in the project area: 

Coachella Valley milkvetch (Astragalus lentiginosus var. coachellae) and the desert 

tortoise (Gopherus agassizii), but only the desert tortoise has been observed in the project 

area. Construction of the transmission line and water pipeline would occur within desert 

tortoise habitat. The operation of heavy machinery and grading in this area has the 

potential to adversely affect desert tortoise through vehicular collisions, burrow collapse, 

and vegetation removal. In addition, following construction, the transmission line could 

provide nesting and perching habitat for ravens, a desert tortoise predator. Eagle Crest 

would implement measures in its Desert Tortoise Removal and Translocation Plan and 

Raven Monitoring and Control Plan to protect the threatened desert tortoise during 

construction and operation of the project. Additionally, Eagle Crest would purchase and 

protect land to compensate for desert tortoise habitat that would be disturbed during 

construction of the proposed project or lost as a result of the project.

Under the staff alternative, the applicant’s proposed plan to monitor and control 

ravens would be modified to include baseline and post-construction surveys for 

additional desert tortoise predators, including coyotes, wild dogs, and gulls, and would 

include mitigation and control measures for these additional species. 

Recreation, Land Use, and Aesthetics

Construction and operation of the project could adversely affect recreation, land 

use, and aesthetics in the project area through increased nighttime sky lighting, limits to 

some access routes, and inundation of some of the remaining but currently noneconomical ore reserves. Recreation resources in the region are primarily provided and 

managed by the National Park Service (Park Service) and BLM. Much of the land in the 

proposed project area is public land managed by BLM or land associated with the Eagle 

Mountain mine. Under the applicant’s proposal, construction schedules would be 

coordinated with BLM for any temporary road and access closures. A directional 

lighting plan and other measures, including a night sky monitoring program, is proposed 

to limit the effects of the project lighting. Coordination of proposed project construction 

and operation with the possible landfill construction and operation is planned. During 

construction, visual effects would be limited and mitigated by these proposed measures.

Eagle Crest’s proposed 13.5-mile-long transmission line would parallel the 

existing Eagle Mountain Road for about 4.5 miles before crossing the Chuckwalla Valley 

in a southeasterly direction to connect to the proposed interconnection collector 

substation on the western edge of Desert Center. In its draft environmental impact report 

for the Eagle Mountain Project, the State Water Board identified its recommended 

substation location and transmission line route as the environmentally superior 

interconnection alternative for the project. The State Water Board’s recommended 

substation would be located immediately south of Interstate 10 and about 6 miles east of 

the applicant’s proposed substation. The State Water Board’s recommended transmission 
xxii

line route would diverge from the applicant’s proposed line after crossing the CRA. The 

State Water Board’s recommended transmission line route would then parallel the 

existing 160-kilovolt Southern California Edison transmission line for about 10.5 miles 

going southeast to a point just north of the proposed substation, then it would travel south 

about 2 miles to the recommended substation location. Under the staff alternative, the 

proposed transmission line would be designed and constructed following the State Water 

Board’s recommended transmission line route to the substation located south of Interstate 

10 and about 6 miles east of Desert Center. When compared to the proposed 

transmission line route, the staff alternative route would be slightly longer; however, it 

would be largely co-located with existing transmission line structures outside of the 

Desert Wildlife Management Area and, therefore, have less effect on the threatened 

desert tortoise and its habitat. 

Cultural Resources

The cultural history of the project area includes use by Native Americans, during 

early mineral exploration, for military training maneuvers, and for iron ore extraction. 

Construction of the proposed project could affect cultural resources during excavation 

associated with the proposed water pipeline, construction of the proposed substation and 

transmission line, and construction of the proposed reservoirs in the existing inactive 

mining pits and the associated infrastructure, such as the transmission line and substation. 

Under Eagle Crest’s proposal, cultural resources would be protected under 

provisions specified in its HPMP filed with the Commission in December 2009. 

However, the Overview and Executive Summary of the HPMP does not correctly identify 

the Eagle Mountain mine, town site, and associated railroad as a potential historic 

property. Additionally, the HPMP does not appropriately address reporting during 

construction, annual HPMP implementation reporting, curation of recovered 

archaeological materials, cultural resources monitoring requirements and protocols, 

consultation with Native American tribes regarding employee training, and public 

interpretation programs. Under the staff alternative, the HPMP would be revised to 

address these omissions and also include: (1) a detailed discussion of the expanded area 

of potential effects (APE) alternatives, including revised APE maps; (2) a description of 

the sites documented by Schaefer (2010) and located within the expanded APE; 

(3) inclusion of a detailed plan and schedule for National Register of Historic Places 

evaluations; and (4) an assessment of effects and identification of measures to resolve 

adverse effects of project construction, operations, and maintenance on any of sites 

identified within the specific staff recommended transmission line corridor and substation 

location, including documentation of appropriate consultation with the participating 

tribes, BLM, and the California SHPO. Finally the revised HPMP would include a 

measure for handling newly discovered paleontological remains and reporting such 

discoveries to BLM. The anticipated Programmatic Agreement would incorporate the 

revised HPMP.
xxiii

Under the staff alternative, the HPMP would be revised to adequately address 

these measures that would ensure adverse effects on historic properties would be 

addressed over the term of any license issued. 

Socioeconomics

No residences or businesses would be displaced due to the construction and 

operation of the project. Operation of the Eagle Mountain mine, which was, by far, the 

largest employer in the area, ended in the 1983. Under Eagle Crest’s proposal, project 

construction would provide about 100 jobs during the peak construction period and 

would provide tax revenues to county and local governments. Project operation would 

provide about 30 jobs, as well as substantial property tax payments.

Air Quality and Noise

Construction of the proposed project would include emissions from heavy 

equipment and dust and noise production. Under Eagle Crest’s proposal, air quality 

measures, including means to limit dust production and emissions from constructionrelated vehicles and equipment, would be implemented. Noise levels are proposed to be 

limited by compliance with applicable noise ordinances and equipping construction 

machinery with noise reduction measures. 

Conclusions

Based on its analysis, staff recommends licensing the project as proposed by Eagle 

Crest with some staff modifications and additional measures, as described above under 

Alternatives Considered. 

In section 4.2 of the draft EIS, we compare the total project cost to the cost of 

obtaining power from a likely alternative source of power in the region, for each of the 

alternatives identified above. During the first year of operation, under the applicant’s 

proposal, the project would produce power at a cost that is $134,054,460, or about 

$31.12/megawatt-hour (MWh), less than the cost of alternative power. Under the staff 

alternative, the project would produce power at a cost that is $133,163,420, or about 

$30.91/MWh, less than the cost of alternative power. Under the no-action alternative, the 

project would not be constructed and would provide no power.

Staff chose the staff alternative as the preferred alternative because: (1) the 

project would provide a dependable source of electrical energy for the region 

(4,308,000 MWh annually); (2) the 1,300 MW of electric energy generated from a 

renewable resource may offset the use of fossil-fueled, steam-electric generating plants, 

thereby conserving non-renewable resources and reducing atmospheric pollution; 

(3) pumped storage projects store power during off-peak periods that can be provided 

rapidly during on-peak periods and could provide a valuable addition to the stability of 

the regional electrical grid; and (4) the recommended environmental measures proposed 

by Eagle Crest, as modified by staff, would adequately protect and enhance 
xxiv

environmental resources affected by the project. The overall benefits of the staff 

alternative would be worth the additional costs of the proposed and recommended 

environmental measures.
1

DRAFT ENVIRONMENTAL IMPACT STATEMENT

Federal Energy Regulatory Commission

Office of Energy Projects

Division of Hydropower Licensing

Washington, DC

Eagle Mountain Pumped Storage Hydroelectric Project

FERC Project No. 13123-002—California

1.0 INTRODUCTION

1.1 APPLICATION

On June 22, 2009, Eagle Crest Energy Company (Eagle Crest or applicant) filed 

an application for an original license with the Federal Energy Regulatory Commission 

(Commission or FERC). The proposed 1,300-megawatt (MW) Eagle Mountain Pumped 

Storage Hydroelectric Project (Eagle Mountain Project, or project) would be located in 

two depleted, inactive mining pits in the Eagle Mountain mine in Riverside County, 

California, near the town of Desert Center, California (figure 1). The proposed project 

would occupy 1,059.26 acres federal lands administered by the U.S. Bureau of Land 

Management (BLM) and 1,162 acres of private lands owned by Kaiser Eagle Mountain, 

LLC (Kaiser).8

 

8 A land exchange is an exchange of state-owned land for privately owned land or 

for other publicly owned land. As part of a nearby landfill proposal, BLM would 

exchange about 3,500 acres of public land within the area for offsite private lands to 

support the landfill project in the mine area. If the land exchange were not to be 

consummated, the project boundary for the proposed project would include nearly 1,059 

acres of federal land managed by BLM. However, if a land exchange between BLM and 

Kaiser is achieved, the amount of federal lands affected by the proposed project would be 

decreased to 675.63 acres. 

 The proposed project would generate an average of a maximum of 4,308 

gigawatt-hours (GWh) of energy annually. Eagle Crest proposes to construct and operate 

this pumped-storage project to provide system peaking capacity and transmission 

regulating benefits to regional electric utilities. 
2

Figure 1. Location of Eagle Mountain Pumped Storage Hydroelectric Project

(Source: Eagle Crest, 2009a, as modified by staff).
3

1.2 PURPOSE OF ACTION AND NEED FOR POWER

1.2.1 Purpose of Action

The Commission must decide whether to issue a license to Eagle Crest for the 

Eagle Mountain Project and what conditions should be placed on any license issued. In 

deciding whether to issue a license for a hydroelectric project, the Commission must 

determine that the project will be best adapted to a comprehensive plan for improving or 

developing a waterway. In addition to the power and developmental purposes for which 

licenses are issued (such as flood control, irrigation, or water supply), the Commission 

must give equal consideration to: (1) energy conservation; (2) the protection of, 

mitigation of damage to, and enhancement of fish and wildlife resources; (3) the 

protection of recreational opportunities; and (4) the preservation of other aspects of 

environmental quality.

Issuing an original license for the Eagle Mountain Project would allow Eagle Crest

to generate electricity for the term of that license, making electrical power from a 

renewable resource available to its customers.

This draft environmental impact statement (draft EIS) assesses the effects 

associated with the construction and operation of the project and alternatives to the 

proposed project. It also includes recommendations to the Commission on whether to 

issue an original license, and if so, includes the recommended terms and conditions to 

become a part of any license issued. 

In this draft EIS, staff assesses the environmental and economic effects of 

constructing and operating the project: (1) as proposed by the applicant, and (2) with 

staff-recommended measures. Staff also considers the effects of the no-action 

alternative. Important issues addressed are the effects of the proposed project’s 

construction and operation on groundwater, water quality, terrestrial species, and 

recreation activities.

1.2.2 Need for Power

The Eagle Mountain Project would provide hydroelectric generation during the 

daytime to meet part of southern California’s power requirements, resource diversity, and 

capacity needs. The project would then use available nighttime energy to pump water 

back to the upper reservoir for re-use. The project would have an installed capacity of 

1,300 MW and would generate about 4,308 GWh annually, while consuming 5,744 GWh 

annually to pump water back up to the upper reservoir.

The North American Electric Reliability Corporation (NERC) annually forecasts 

electrical supply and demand nationally and regionally for a 10-year period. The Eagle 

Mountain Project would be located on the southern end of the California-Mexico 

subregion of the Western Electricity Coordinating Council region of NERC. According 
4

to NERC’s most recent 2009 forecast, summer peak demands and annual energy 

requirements for the United States’ portion of the California-Mexico subregion are 

projected to grow at annual rates of 0.9 percent and 1.2 percent from 2009 through 2018, 

respectively (NERC, 2009). NERC projects summer and winter resource capacity 

margins (generating capacity in excess of demand) will not drop below target reserve 

levels during the 2009–2018 period. 

As noted above, pumped storage facilities are net energy consumers. The amount 

of energy produced as water passes from the upper reservoir to the lower reservoir 

through the turbines is less than the amount of energy required to operate the plant and to 

pump water back up to the upper reservoir. However, the benefits of pumped storage 

facilities are realized when the price for pumping is much less than the value of 

generation. Typically, there are sources of power such as nuclear, solar and wind 

projects that can provide power at low rates during night-time or low-demand hours, 

compared to rates available during day-time, high-demand hours. Therefore, the pumped 

storage facility can provide power during the day when energy demands are high, and can 

use power from other facilities during the night when energy demand is low. Power 

benefits of pumped storage projects are discussed further in section 4.1, Power and 

Developmental Benefits of the Project. 

Staff concludes that power produced by the Eagle Mountain Project would help to 

provide renewable energy to the California-Mexico subregion in both the short and long 

term and that during overnight hours, the project may serve as a user for power that is 

continually produced by other facilities that might not otherwise be used.

1.3 STATUTORY AND REGULATORY REQUIREMENTS

A license for the Eagle Mountain Project is subject to numerous requirements 

under the Federal Power Act (FPA) and other applicable statutes. Staff summarizes the 

major regulatory requirements in table 1 and describes them below. 

Table 1. Major statutory and regulatory requirements for the Eagle Mountain 

Hydroelectric Project (Source: staff).

Requirement Agency Status

Section 18 of the FPA

(fishway prescriptions)

U.S. Department of the 

Interior, Fish and Wildlife 

Service (FWS)

No section 18 prescriptions 

were filed.

Section 4(e) of the FPA

(land management 

conditions)

U.S. Bureau of Land 

Management 

No section 4(e) conditions 

were filed.

Section 10(j) of the FPA FWS No 10(j) recommendations

were filed.
5

Requirement Agency Status

Clean Water Act—water 

quality certification

State Water Resources 

Control Board (State 

Water Board)

Eagle Crest filed its 

application on September 22, 

2009; it was received by the 

State Water Board on 

September 24, 2009. On 

October 8, 2009, the State 

Water Board determined that 

the application met the 

requirements for a complete 

application. However, on 

September 15, 2010, Eagle 

Crest simultaneously 

withdrew and resubmitted its 

application, and the approval 

is pending. 

Endangered Species Act 

Consultation

FWS The Commission is requesting

concurrence from FWS on its 

findings in a letter issued 

concurrently with this draft 

EIS.

Coastal Zone 

Management Act 

Consistency

California Coastal 

Commission

Eagle Crest filed consistency 

certification on March 26, 

2009; in a letter dated April 

28, 2009, the California 

Coastal Commission agreed 

that the project is outside of, 

and would not affect, a 

California coastal zone.

National Historic 

Preservation Act

California State Historic 

Preservation Officer 

(California SHPO)

Eagle Crest consulted with the 

California SHPO and prepared 

a Historic Properties 

Management Plan (HPMP) to 

address potential adverse 

effects on historic properties 

associated with the project.
6

1.3.1 Federal Power Act

1.3.1.1 Section 18 Fishway Prescriptions

Section 18 of the FPA states that the Commission is to require construction, 

operation, and maintenance by a licensee of such fishways as may be prescribed by the 

Secretary of Commerce or the Secretary of the U.S. Department of the Interior (Interior). 

Neither the Secretary of Commerce nor the Secretary of the Interior filed section 18 

prescriptions or requested that a reservation of authority to prescribe fishways under 

section 18 be included in any license issued for the project.

1.3.1.2 Section 4(e) Conditions

Section 4(e) of the FPA provides that any license issued by the Commission for a 

project within a federal reservation will be subject to and contain such conditions as the 

Secretary of the responsible federal land management agency deems necessary for the 

adequate protection and use of the reservation. BLM, which manages 1,059.26 acres of 

land that would be occupied by the project, did not file section 4(e) conditions. 

1.3.1.3 Section 10(j) Recommendations

Under section 10(j) of the FPA, each hydroelectric license issued by the 

Commission must include conditions based on recommendations provided by federal and 

state fish and wildlife agencies for the protection, mitigation, or enhancement of fish and 

wildlife resources affected by the project. The Commission is required to include these 

conditions unless it determines that they are inconsistent with the purposes and 

requirements of the FPA or other applicable law. Before rejecting or modifying an 

agency recommendation, the Commission is required to attempt to resolve any such 

inconsistency with the agency, giving due weight to the recommendations, expertise, and 

statutory responsibilities of such agency.

No 10(j) recommendations were filed. 

1.3.2 Clean Water Act

1.3.2.1 Water Quality Certification

Under section 401 of the Clean Water Act (CWA), a license applicant must obtain 

certification from the appropriate state pollution control agency verifying compliance 

with the CWA. On September 26, 2008, Eagle Crest applied to the State Water Board for 

401 water quality certification for the Eagle Mountain Project. The State Water Board

received this request on September 26, 2008. Subsequently, on September 22, 2009, 

Eagle Crest simultaneously withdrew and resubmitted its request, which was received by 

the State Water Board on September 24, 2009. However, on September 15, 2010, Eagle 

Crest simultaneously withdrew and resubmitted its request. On October 14, 2010, the 

State Water Board determined that the application was acceptable for processing. The 

water quality certification is due by September 15, 2011. 
7

1.3.2.2 California Environmental Quality Act9

The State Water Board prepared a draft environmental impact report (EIR), dated 

July 2010, to provide the public, governmental and/or responsible agencies, and other 

interested parties with information about the environmental effects of the proposed Eagle 

Mountain Project. The proposed action of developing and operating the pumped storage 

hydroelectric facility requires evaluation of the project under the California 

Environmental Quality Act (CEQA) because it requires discretionary approval by the 

State Water Board (State CEQA Guidelines §15357). The State Water Board is the state 

of California’s lead agency for implementing CEQA (State CEQA Guidelines §15367). 

State CEQA Guidelines §15126.6 require that an EIR describe and evaluate the 

comparative merits of a range of alternatives to the project that could feasibly attain most 

of the objectives of the project but would avoid or substantially lessen significant effects. 

An EIR is not required to consider alternatives that are infeasible; however, State CEQA 

Guidelines §15126.6(b) specify that the EIR evaluate alternatives capable of avoiding or 

substantially lessening significant effects of the project, even if these alternatives could 

impede to some degree attainment of project objectives, or impose additional costs.

The alternatives evaluated in the draft EIR were identified based on a range of 

alternatives that could feasibly accomplish most of the basic project objectives and could 

avoid or substantially lessen one or more significant effects (State CEQA Guidelines 

§15126.6(c)). Alternatives analyzed in the draft EIR included the proposed project, a no 

project alternative, a longer construction period to limit the daily emissions of nitrogen 

oxide, and different transmission line routes and substation locations.

The State Water Board recommended an alternative for the transmission route and 

substation location that is based on its analysis in the draft EIR and is shown in figure 2. 

The State Water Board’s recommended substation would be located immediately south of 

Interstate 10 and about 6 miles east of the applicant’s proposed substation. It would 

diverge from the applicant’s proposed line after crossing the Metropolitan Water District

of Southern California’s Colorado River Aqueduct (CRA) and would then parallel the 

existing 160-kilovolt (kV) Southern California Edison (SCE) transmission line for about

10.5 miles going southeast to a point just north of the proposed substation. The State 

Water Board’s route then would travel south about 2 miles to its recommended

substation. The State Water Board draft EIR states that this route was chosen because it 

would reduce biological, land use, and aesthetics impacts, although short-term air quality 

impacts and visual impacts would be significant and unavoidable. Staff’s analysis of the 

State Water Board’s recommended transmission line and substation location is presented 

in section 3.3, Proposed Action and Action Alternatives, and staff’s recommendations are 

presented in section 5.0, Conclusions and Recommendations.

 

9 Information for this section is from the Eagle Mountain Pumped Storage Project

Draft Environmental Impact Report (State Water Board, 2010).
8

Figure 2. Transmission line routes (Source: Eagle Crest, 2010a, as modified 

by staff).
9

1.3.3 Endangered Species Act

Section 7 of the Endangered Species Act (ESA) requires federal agencies to ensure 

that their actions are not likely to jeopardize the continued existence of endangered or 

threatened species or result in the destruction or adverse modification of the critical 

habitat of such species. Two federally listed species are known to occur in the Eagle 

Mountain Project vicinity: the Coachella Valley milkvetch and desert tortoise. There is 

also critical habitat for the desert tortoise in the proposed project boundary. Staff’s 

analyses of project effects on threatened and endangered species are presented in section 

3.3.4, Threatened and Endangered Species, and our recommendations in section 5.2, 

Comprehensive Development and Recommended Alternative.

Eagle Crest’s Worker Environmental Awareness Program (WEAP) and Desert 

Tortoise Removal and Translocation Plan would protect desert tortoise from 

construction-related effects, and the applicant-proposed compensation would mitigate the

reduction in desert tortoise habitat. The staff-recommended desert tortoise predator 

control plan would also help minimize any potential effects associated with increased 

predation risk. However, implementation of these plans would require transporting 

tortoises, which causes increased stress and could result in mortality. Additionally, 

construction of the staff-recommended substation would permanently reduce available 

habitat within designated critical habitat for desert tortoise. Therefore, staff concludes

that licensing of the Eagle Mountain Project, as proposed with staff-recommended 

measures, may adversely affect the desert tortoise and associated critical habitat. Staff

also concludes the project would not affect Coachella Valley milkvetch because this 

species does not occur in areas of potential project effects. Commission staff requested 

formal consultation with the U.S. Department of the Interior, Fish and Wildlife Service

(FWS) by letter issued December 23, 2010.

1.3.4 Coastal Zone Management Act

Under section 307(c)(3)(A) of the Coastal Zone Management Act (CZMA), 16 

U.S.C. § 1456(3)(A), the Commission cannot issue a license for a project within or 

affecting a state’s coastal zone unless the state CZMA agency concurs with the license 

applicant’s certification of consistency with the state’s CZMA program, or the agency’s 

concurrence is conclusively presumed by its failure to act within 180 days of its receipt of 

the applicant’s certification.

The project is not located within the state-designated Coastal Management Zone, 

and the project would not affect California’s coastal resources. Therefore, the project is 

not subject to the California coastal zone program review, and no consistency 
10

certification is needed for the action. By letter dated April 28, 2009, the California 

Coastal Commission concurred with this conclusion.

10

1.3.5 National Historic Preservation Act

Section 106 of the National Historic Preservation Act of 1966 (NHPA) requires 

that every federal agency “take into account” how each of its undertakings could affect 

historic properties. Historic properties are districts, sites, buildings, structures, traditional 

cultural properties (TCPs), and objects significant in American history, architecture, 

engineering, and culture that are eligible for inclusion in the National Register of Historic 

Places (National Register). 

To meet the requirements of section 106, the Commission intends to execute a 

Programmatic Agreement (PA) for the protection of historic properties from the effects of 

the construction, operation, and maintenance of the Eagle Mountain Project. The terms 

of the PA would ensure that Eagle Crest addresses and treats all historic properties 

identified within the project’s area of potential effects (APE) through the implementation 

of a Historic Properties Management Plan (HPMP) with staff modifications. The 

executed PA would be incorporated into any Order issuing a license. 

1.4 PUBLIC REVIEW AND CONSULTATION

The Commission’s regulations (18 CFR, sections 4.38) require that applicants 

consult with appropriate resource agencies, tribes, and other entities before filing an 

application for a license. This consultation is the first step in complying with the Fish 

and Wildlife Coordination Act, the ESA, the NHPA, and other federal statutes. Pre-filing 

consultation must be complete and documented according to the Commission’s 

regulations.

1.4.1 Scoping

Before preparing this draft EIS, staff conducted scoping to determine what issues 

and alternatives should be addressed. A scoping document (SD1) was distributed to 

interested agencies and others on December 17, 2008. It was noticed in the Federal 

Register on December 24, 2008. Two scoping meetings, both advertised in the Desert 

Sun, were held on January 15 and 16, 2009, in Palm Desert, California, to request oral 

comments on the project. A court reporter recorded all comments and statements made at 

the scoping meetings, and these are part of the Commission’s public record for the 

 

10 This record of the correspondence is from the license application, exhibit E, 

page 1-8.
11

project. In addition to comments provided at the scoping meetings, the following entities 

provided written comments on SD1:

Commenting Entity

Metropolitan Water District of Southern California

Date Filed

February 10, 2009

Kaiser Ventures, LLC February 13, 2009

Citizens for the Chuckwalla Valley February 17, 2009

County Sanitation Districts of Los Angeles County February 17, 2009

Riverside County Fire Department March 5, 2009

U.S. Department of the Interior, Bureau of 

Reclamation

March 24, 2009

A revised scoping document (SD2), addressing these comments, was issued on 

June 5, 2009.

1.4.2 Interventions

On January 14, 2010, the Commission issued a notice that Eagle Crest had filed an 

application to license the Eagle Mountain Project. This notice set March 15, 2010, as the 

deadline for filing protests and motions to intervene. In response to the notice, the 

following entities filed motions to intervene:

Intervenor

Citizens for the Chuckwalla Valley 

Date Filed

March 1, 2010

State Water Resources Control Board March 2, 2010

Metropolitan Water District of Southern 

California11

March 10, 2010

Kaiser Eagle Mountain LLC11 March 10, 2010 

County Sanitation District No. 2 of Los Angeles 

County11

March 12, 2010

 

11 Intervention in opposition.
12

1.4.3 Comments on the License Application

A notice requesting conditions and recommendations was issued on January 11, 

2010, and an errata notice12 was issued on January 14, 2010. The following entities 

commented: 

Commenting Agency and Other Entity

Brendan Hughes

Date Filed

March 1, 2010

Kaiser Eagle Mountain, LLC March 10, 2010

National Parks Conservation Association March 11, 2010

Joshua Tree National Park March 11, 2010

Metropolitan Water District of Southern California March 11, 2010

U.S. Department of the Interior March 12, 2010

Johnney Coon March 12, 2010

County Sanitation District No. 2 of Los Angeles 

County

March 12 and 18, 2010

Timothy Anderson March 13, 2010

U.S. Department of the Interior, Bureau of Land 

Management

August 23, 2010

Eagle Mountain filed reply comments on April 23, 2010.

 

12 The errata corrected the deadline for filing motions to intervene and protests; 

comments, recommendations, terms and conditions, prescriptions; and reply comments. 

It also corrected the paragraph about who may submit comments, a protest, or a motion to 

intervene and provided a procedural schedule.
13

2.0 PROPOSED ACTION AND ALTERNATIVES

2.1 NO-ACTION ALTERNATIVE

The no-action alternative is license denial. Under the no-action alternative, the 

project would not be built, and the environmental resources in the project area would not 

be affected.

2.2 APPLICANT’S PROPOSAL

2.2.1 Project Facilities

The proposed pumped storage project would consist of an upper reservoir, upper 

water conveyance system, powerhouse, a lower reservoir, lower water conveyance 

system, transmission system, water supply system, water treatment system, and 

miscellaneous facilities. Figure 3 shows the project area and proposed layout.

The upper reservoir site would include: (1) a 191-acre reservoir (in the existing 

central mining pit) with a total storage capacity of 20,000 acre-feet and a useable storage 

of 17,700 acre-feet; (2) one 1,300-foot-long, 120-foot-high saddle dam on the south side 

of the reservoir and about 4,000 feet to the northwest, and another 1,100-foot-long, 60-

foot-high saddle dam on the western side of the reservoir; (3) a 100-foot-long spillway 

with a 100-foot-wide by 30-foot-long spillway stilling basin; (4) an upper reservoir 

spillway channel about 4,000 feet long; (5) a 14,000-foot-long section of Eagle Creek 

that would transport upper reservoir spillway flows to the lower reservoir; and (6) an 

upper reservoir inlet/outlet structure.

The upper water conveyance system (figures 3 and 4) would include: (1) a 29-

foot-diameter by 3,963-foot-long upper pressure tunnel; (2) a 33-foot-diameter by 1,348-

foot-long vertical tunnel shaft; (3) a 90-foot-diameter by 165-foot-high underground 

surge tank attached to the vertical tunnel shaft; (4) a 29-foot-diameter by 1,560-foot-long 

lower tunnel; and (5) a manifold that transitions from the lower tunnel to four 15 footdiameter by 500-foot-long penstock tunnels. The powerhouse facility would consist of: 

(1) a 72-foot-wide, 130-foot-high, and 360-foot-long underground powerhouse; (2) four 

reversible pump-turbine units rated at 325 MW each, for a total installed capacity of 

1,300 MW; and (3) a separate 46-foot-wide, 40-foot-high, and a 431-foot-long 

transformer gallery.

The lower reservoir site would include: (1) a 163-acre reservoir (in the existing

eastern mining pit) with a total storage capacity of 21,900 acre-feet and a useable storage 

of 17,700-acre-feet; (2) a reservoir inlet/outlet structure; (3) a 15-foot-wide reservoir 

spillway; and (4) a reservoir spillway discharge channel extending 6,665 feet from the 

spillway to an alluvial fan in the Chuckwalla Valley.

The lower water conveyance system would include: (1) four 17-foot-diameter by 

75-foot-long draft tube tunnels; (2) a manifold that transitions from the draft tube tunnels 

to the tailrace tunnel; and (3) a 33-foot-diameter by 6,835-foot-long tailrace tunnel.
14

Figure 3. Proposed facilities and reservoirs and existing features of the Eagle Mountain Project

(Source: Eagle Crest, 2009a, as modified by staff).
15

Figure 3. Proposed facilities and reservoirs and existing features of the Eagle Mountain Project (con

Eagle Crest, 2009a, as modified by staff). 
16

Figure 4. Profile of the proposed Eagle Mountain Pumped Storage Project underground facilities (So

2009a, as modified by staff). 
17

The transmission system would include: (1) four 6,000-foot-long, 18-kV

underground transmission cables that extend through the powerhouse access tunnel and a 

vertical transmission shaft to the ground surface and then 4,000 feet overhead to a 

switchyard; (3) a 500-foot-wide by 1,100-foot-long switchyard; (4) a 13.5-mile-long, 

double circuit 500-kV transmission line from the switchyard to a new interconnection 

collector substation; and (4) an interconnection collector substation located at the point of 

interconnection with SCE’s planned Devers-Palo Verde No. 2 500-kV transmission line 

at Desert Center.

The water supply system would include: (1) three water supply wells with pumps; 

and (2) a underground water supply pipeline, ranging from 12- to 24-inches in diameter,

totaling 15.3 miles, and extending from the wells to the lower reservoir.

The water treatment system would include: (1) a reverse osmosis system; 

(2) pipelines from the upper and lower reservoirs to the reverse osmosis facility; and 

(3) desalination facilities with piping from the reverse osmosis facilities.

The miscellaneous facilities would include: (1) a 28-foot-wide, 28-foot-high, by 

6,625-foot-long access tunnel to the underground powerhouse (see figure 4); (2) about 6 

miles of permanent construction and access roads; (3) staging, storage, and 

administration areas near the switchyard; and (4) appurtenant facilities. 

2.2.2 Project Safety

As part of the licensing process, the Commission would review the adequacy of 

the proposed project facilities. Special articles would be included in any license issued, 

as appropriate. Commission staff would inspect the licensed project both during and after 

construction. Inspection during construction would concentrate on adherence to 

Commission-approved plans and specifications, special license articles relating to 

construction, and accepted engineering practices and procedures. Operational inspections 

would focus on the continued safety of the structures, identification of unauthorized 

modifications, efficiency and safety of operations, compliance with the terms of the 

license, and proper maintenance. In addition, any license issued would require an 

inspection and evaluation every 5 years by an independent consultant and submittal of the 

consultant’s safety report for Commission review.

2.2.3 Project Operation

The proposed project, configured with the four reversible pump-turbine units and 

tunnels, would use off-peak energy to pump water from the lower reservoir to the upper 

reservoir during periods of low electrical demand and generate peak energy by passing 

the water from the upper to the lower reservoir through the tunnels and generating units 

during periods of high electrical demand. The low demand periods are expected to be 

during weekday nights and throughout the weekend, and the high demand periods are 

expected to be in the daytime during week days, especially during the summer months. 

Eagle Crest hopes to use available power produced by existing and proposed wind and/or 
18

solar projects in the area to provide at least a portion of the pumping power to the project. 

The proposed project would also be able to provide ancillary services to the electric grid, 

including load following, system regulation through spinning and non-spinning reserve,13

The project would normally function as a closed system once one reservoir is 

initially filled. The source of the water for initial filing and replacing water lost to 

evaporation is proposed to be from proposed groundwater wells located more than 10 

miles away in the Chuckwalla Valley, which would be transported to the project via a 

buried pipeline. During normal operations, water would pass back and forth through the 

powerhouse between the two reservoirs and the emergency spillways at the reservoirs 

would be used only during very large and exceedingly rare rainfall events or during 

emergency circumstances.

and immediately available standby generating capacity. 

The proposed energy storage volume would permit operation of the project at full 

capacity for up to 9 to 10 hours each weekday, with up to 12 to 14 hours of pumping each 

weekday night and additional pumping during the weekend to fully recharge the upper 

reservoir. The amount of daily fluctuation in the proposed upper and lower reservoir 

levels would be about 100 to 150 feet. The amount of active storage in the upper 

reservoir would be 17,700 acre-feet. 

2.2.4 Proposed Environmental Measures

Eagle Crest proposes the following mitigation, protection, and enhancement 

measures: 

Geology and Soils Resources

• Implement the Erosion and Sediment Control Plan filed July 7, 2010, that 

describes the erosion and sediment control practices to minimize soil erosion in 

construction areas and prevent sediment transport into stormwater discharges 

away from the construction site (Measure GEO-1).

 

13 Spinning reserve is the on-line reserve capacity that is synchronized to the grid 

system and ready to meet electric demand within 10 minutes of a dispatch instruction by 

the California Independent System Operator (CAISO). Spinning Reserve is needed to 

maintain system frequency stability during emergency operating conditions and 

unforeseen load swings.

Non-spinning reserve is off-line generation capacity that can be ramped to 

capacity and synchronized to the grid within 10 minutes of a dispatch instruction by the 

CAISO and that is capable of maintaining that output for at least 2 hours. Non-spinning

reserve is needed to maintain system frequency stability during emergency conditions.
19

Water Resources

• Develop a groundwater level monitoring network (including existing and new 

monitoring wells) to confirm that wells would be maintained at historical

levels (Measure WS-1).

• Construct two extensometers

14

• During the initial fill pumping period, monitor existing wells on neighboring 

properties whose water production may be impaired by project groundwater 

pumping; if project pumping would adversely affect these wells, replace or 

lower the pumps, deepen the existing well, construct a new well, and/or 

compensate owner for increased pumping costs (Measure WS-3).

—one in the upper Chuckwalla Valley near 

Observation Well 3 (OW-3) and the other in the Orocopia Valley near OW15—to measure potential subsidence that could affect the operation of the 

Metropolitan Water District’s CRA (Measure WS-2).

• Monitor groundwater in the project vicinity by using existing and proposed 

monitoring wells on a quarterly basis for the first 4 years of project pumping

(i.e., initial project pumping period); possibly extend monitoring from 

quarterly to bi-annually or annually, depending on findings and prepare annual 

reports for submittal to the Commission and State Water Board, confirming 

actual drawdown conditions (Measure WS-4).

• To effectively control seepage from the upper and lower reservoirs, an array of 

seepage recovery wells would be installed outside the down-gradient end of 

each of these two reservoirs. A testing program would be initially employed 

during final engineering (prior to project operations) to confirm the assumed 

hydrogeologic conditions (e.g., aquifer characteristics and bedrock fracture 

interconnectedness) and seepage recovery well pumping rates (Measures SR-1 

and SR-2).

• Alternatively, manage seepage from the reservoirs, which if left unimpeded 

could raise groundwater levels by up to 3 feet (implementation of this 

alternative would require confirmation of groundwater level rises and water 

quality of the resulting seepage) (Alternative Measure SR-1A).

• Develop a groundwater level monitoring network (including existing and new 

monitoring wells) to confirm that seepage recovery well pumping would be 

effective at managing groundwater levels beneath the CRA and in the Eagle 

Creek Canyon portion of the proposed landfill, and record groundwater levels, 

water quality, and production at the project seepage recovery wells (Measure

SR-3).

 

14 An extensometer is a device that measures soil subsidence.
20

• Maintain seepage from the upper reservoir below the bottom of the elevation of 

the landfill liner and maintain seepage from the lower reservoir to prevent a 

significant rise in water levels beneath the CRA (Measure SR-4).

• Using the network of groundwater monitoring wells proposed under Measure 

WS-1, monitor groundwater levels on a quarterly basis for the first 4 years of 

project pumping; possibly extend monitoring from quarterly to bi-annually or 

annually, depending on findings (Measure SR-5). Unlike WS-4, this measure 

would focus on assessing seepage conditions in the project vicinity, rather than 

drawdown conditions as a result of project pumping in the Desert Center area.

• Install a reverse osmosis desalination facility and brine disposal lagoon to 

remove salts and metals form reservoir water and maintain total dissolved 

solids concentrations at the level of the source water (Measure GQ-1).

• Implement a monitoring program for groundwater quality to assess and limit 

groundwater effects on surrounding properties by sampling reservoirs, seepage 

recovery wells, and wells upgradient and downgradient of the reservoirs and 

brine disposal lagoon on a quarterly basis for the first 4 years (Measure GQ-2).

• Replace four existing wells located within the proposed reservoir area with 

wells located outside of reservoirs (Measure LF-1).

• Release excess water from the reservoirs during large rainfall events, such as 

the 100-year event and up to and including the probable maximum flood 

(PMF). 

Terrestrial Resources

• Concurrent with final design engineering, develop a comprehensive sitespecific mitigation and monitoring program in consultation with the Biological 

Technical Advisory Team composed of the applicant’s staff, their consultants 

and staff from resources managing agencies (Measure BIO-1).

• Designate a project biologist who would be responsible for implementing and 

overseeing the biological compliance program (Measure BIO-2).

• Implement the WEAP filed October 27, 2009, to ensure that project 

construction and operation would be conducted within a framework of 

safeguarding environmentally sensitive resources (Measure BIO-3).

• Regularly submit reports to the relevant resource agencies, documenting 

project activities, mitigation implemented, and mitigation effectiveness, and 

providing recommendation, as needed (Measure BIO-4)

• During construction in native habitats, restrict surface disturbance to the 

smallest area necessary to complete the construction; design new spur roads 
21

and improvements to existing roads in a way that would preserve existing 

desert wash topography and flow patterns (Measure BIO-5).

• Use pre-construction surveys to identify special-status plant populations and 

species protected by the California Desert Native Plants Act (CDNPA), and 

establish avoidance areas in construction zones for special plant resources. 

Where avoidance is not feasible, salvage and transplant any species that can be 

reasonably transplanted in an approved area (Measure BIO-6). 

• Consult with the County Agricultural Commissioner for direction regarding 

disposal of protected plants (Measure BIO-7).

• Implement the Revegetation Plan filed October 27, 2009, for areas that are 

temporarily disturbed during construction (Measure BIO-8).

• Implement the Invasive Species Monitoring and Control Plan filed October 27, 

2009, to minimize the spread of invasive non-native vegetation (Measure BIO9).

• Implement requirements of the Northern and Eastern Colorado Desert 

Coordinated Management Plan (NECO Plan) to avoid disturbance of 

impoundments and restrict surface flow to impoundments. If avoidance is not 

possible, construct a new impoundment as close as feasible to replicate and 

replace each lost impoundment (Measure BIO-10).

• For construction activities scheduled to occur between February 15 and July 30 

in vegetated habitat, survey all potential nesting sites for active bird nests 

(Measure BIO-11).

• Develop and implement a plan to manage evaporation ponds to minimize their 

attractiveness and access to migratory birds and establish a monitoring 

program to identify bird usage of the evaporation ponds, effectiveness of bird 

deterrents, and water quality. Based on monitoring results, implement adaptive 

management (Measure BIO-12).

• If requested, complete a Phase III survey, including a nesting season survey, 

followed by a winter survey if no burrows or owls are observed during the 

nesting season survey, and a pre-construction survey, to further assess 

burrowing owl use of the project area and potential effects. (With California 

Department of Fish and Game (California DFG) approval, the pre-construction 

survey may obviate the need for the Phase III survey) (Measure BIO-13).

• Limit the construction to September 1 through February 1, if burrowing owls 

are present, to avoid disruption of breeding activities; avoid disruption of 

burrowing owl nesting activities; use a minimum of a 250-foot buffer to avoid 

active nests until fledging has occurred (Measure BIO-14).
22

• Determine through pre-construction surveys if 0.25-mile construction buffers 

would be required during prairie falcon or golden eagle nesting seasons 

(Measure BIO-15).

• Conduct pre-construction surveys for all burrows that might host badger or kit 

fox, avoiding active burrows, where possible, and mark the perimeters of all 

avoidance areas with 3-foot-high and no more than 10-foot-apart, wooden 

stakes. Where avoidance is infeasible, encourage occupants to leave their 

burrows (Measure BIO-16). 

• Conduct pre-construction surveys to determine the existence, location, and 

condition of bat roosts and identify foraging habitat. Based on results of 

surveys, develop a mitigation plan to avoid roosting and foraging effects on 

resident bats, minimize disturbance, or, as an inescapable measure, evict bats 

(Measure BIO-17).

• Construct security fencing around portions of the central project area to 

exclude larger terrestrial wildlife, including bighorn sheep, deer, coyotes, 

foxes, and badger, from entering project areas that pose hazards (Measure

BIO-18).

• Restrict construction and maintenance activities to minimize project effects 

(Measure BIO-19).

• In areas without wildlife exclusion fencing or those areas that have not been 

cleared of tortoises, conduct construction activities only during daylight hours 

(Measure BIO-20).

• Close, temporarily fence, or cover pipeline trenches each day. Conduct 

inspections (by an approved biological monitor) of any open trenches at first

light, midday, and at the end of each day to ensure animal safety (Measure

BIO-21).

• Design, install, and maintain facility lighting to prevent casting of light into 

adjacent native habitat (Measure BIO-22).

• Develop and implement a transmission line design plan that considers adequate 

separation of energized conductors, ground wires, and other metal hardware, 

adequate insulation, and any other measures necessary to protect raptors from 

electrocution hazards and design and construct raptor-friendly transmission

lines in strict accordance with the industry standard guidelines set forth in 

Suggested Practices for Raptor Protection on Power Lines: The State of the 

Art in 2006, by Avian Power Line Interaction Committee, Edison Electric 

Institute, and Raptor Research Foundation (Eagle Crest, 2010b, section 2, 

comment 2-3).
23

Threatened and Endangered Species

• Remove all tortoises from harm’s way during the construction period (Measure

DT-1).

• Ensure that no construction or maintenance that requires surface disturbance in 

unfenced areas on the linear facilities would occur without biological monitors 

(Measure DT-2). 

• Enclose the substation and other hazardous areas with a permanent tortoise 

exclusion fence to keep adjacent tortoises from entering the site (Measure DT3).

• Transport removed tortoises to another part of their home range; move any 

tortoises found in the central project area to a location immediately adjacent to 

its capture site outside the fenced construction area, and implement other 

measures of the Desert Tortoise Removal and Translocation Plan filed October 

27, 2009 (Measures DT-4 and DT-7).

• Implement the Raven Monitoring and Control Plan filed October 27, 2009 

(Measure DT-5).

15

• Purchase about 160 acres of land to compensate for the Category I and 

Category III Desert Tortoise Habitat that would be disturbed (Measure DT-6).

Recreation Resources

• Coordinate construction schedules with BLM and provide posted notices of 

construction activity and any temporary road/access closure (Measure REC-1).

Land Use

• Provide construction access to and from the substation site from the Eagle 

Mountain Road exit and follow the Frontage Road east to the site (Measure

LU-1).

• Two weeks prior to beginning construction, locally post notices stating hours 

of operation for construction near the Desert Center community and along 

State Route 177 (Measure LU-2).

Aesthetic Resources

• Incorporate directional lighting, light hoods, low pressure sodium bulbs or 

LED lighting, and operational devices in final design to allow surface nightlighting in the central site to be turned on as needed for safety. Also, fund 

 

15 Implementation of the Raven Monitoring and Control Plan replaces Measure 

DT-5 as presented in the final license application.
24

night sky monitoring to be conducted after consultation with the National Park 

Service (Park Service) during the post licensing design period (to represent 

baseline conditions) and during construction and a trial operational period 

(AES-1).

• Combine and organize staging areas and areas needed for equipment operation 

and material storage and assembly within construction lands to the extent 

feasible to minimize total footprint needed (AES-2).

• For construction of the water pipeline, reduce, to the extent possible, side cast 

soils to reduce color contrast with the surrounding landscape. Backfill the 

pipeline disturbed zone and revegetate with native vegetation immediately 

following completion of pipeline construction (AES-3).

• Employ visual mitigation in the design of the transmission line to minimize 

visual effects (AES-4).

• Use existing access roads and construction laydown areas to the extent feasible 

and revegetate with native vegetation immediately following construction 

(AES-5).

Cultural Resources

• Implement the project’s revised HPMP (including Measures CLT-1, -2, -3).

Air Quality

• Periodically water or apply suitable surfactant for short-term stabilization of 

disturbed surface areas and storage piles (Measure AQ-1).

• Prevent project-related trackout onto paved surfaces by using a variety of 

construction management strategies (Measure AQ-2).

• Stabilize graded site surfaces upon completion of grading when subsequent 

development is delayed or expected to be delayed by more than 30 days, 

except when precipitation dampens the disturbed surface (Measure AQ-3).

• Limit areas of active surface disturbance (such as grading) to no more than 15 

acres per day (Measure AQ-4).

• Reduce non-essential earth-moving activities during windy conditions, and 

cease clearing, grading, earth-moving, or excavation activities if winds exceed 

25 mph averaged over a 1-hour duration (Measure AQ-5).

• Develop and implement a transportation management plan for employees 

(Measure AQ-6).

• Strictly abide by the applicable state law requirements for diesel truck idling 

(Measure AQ-7).
25

• Use electrical drops in place of temporary electrical generators, and substitute 

low- and zero emitting construction equipment and/or alternative fueled or 

catalyst equipped diesel construction equipment wherever economically 

feasible (Measure AQ-8).

• Obtain proper South Coast Air Quality Management District (SCAQMD) 

permits for electrical generators (Measure AQ-9).

• Properly tune and maintain heavy-duty diesel trucks in accordance with 

manufacturers’ specifications to ensure minimum emissions under normal 

operations (Measure AQ-10).

• Use 2002 model or newer construction equipment, where feasible (Measure

AQ-11).

• Retrofit older off-road construction equipment with appropriate emission 

control devices prior to onsite use, where feasible (Measure AQ-12).

• Work collaboratively on a cost-share basis with the Park Service to complete a 

2-year air monitoring study. 

Noise

• Comply with the County of Riverside General Plan applicable noise ordinance 

codes during construction (Measure NOI-1).

• Equip construction machinery with properly operating and maintained noise 

mufflers and intake silencers (Measure NOI-2).

2.3 STAFF ALTERNATIVE

Under Eagle Crest’s proposal with staff modifications, the project would be 

operated as proposed, but would also include the following:

• Construct the project transmission line along the State Water Board’s 

recommended transmission line route. This route would diverge from the 

applicant’s proposed line after crossing the CRA and would then parallel the 

existing 160-kV SCE transmission line for about 10.5 miles going southeast to 

a point just north of the proposed substation, then it would travel south about 

2 miles to the State Water Board’s recommended substation location.

• Connect the project to the electrical grid by terminating the transmission line at 

the State Water Board’s recommended substation located immediately south of 

Interstate 10 and about 6 miles east of the applicant’s proposed substation.

• Perform channel modifications and other measures to contain flows associated 

with the PMF to the Eagle Creek channel and to direct these flows toward the 

proposed lower reservoir. 
26

• Develop and implement a reservoir-level monitoring plan to ensure that water 

levels are managed properly within operational restraints and help determine 

possible water-level effects on terrestrial resources. 

• Develop and implement a brine pond-level monitoring plan to ensure that the 

ponds are managed properly and help determine if a leak has developed in the 

linings of the ponds.

• Implement a more comprehensive monitoring well placement and monitoring 

program around the proposed brine and solidification ponds to allow for the 

earlier detection of leaks in the lining of the ponds. The monitoring methods 

would be designed to determine if the water levels in the ponds are falling at 

the expected rate based on inflow and evaporation rates and the monitoring 

wells would be placed partly horizontally beneath the ponds. 

• In addition to a comprehensive groundwater monitoring program, develop a 

groundwater hydrologic budget report that incorporates data on pumpage, 

seepage recovery, precipitation, evaporation, and groundwater flow direction. 

• Modify the proposed Invasive Species Monitoring and Control Plan to include 

criteria for success and an adaptive management plan to be implemented if 

initial efforts do not prove successful. Include the reservoirs and water 

seepage areas with other areas to be monitored for invasive plants on an annual 

basis following vegetation establishment.

• Modify the proposed avian protection plan to include measures, in addition to 

Eagle Crest’s proposed design measures for reducing potential electrocution, to 

reduce potential for collision injuries, provide methods for surveying and 

reporting project-related raptor mortality, incorporate a worker education plan 

pertaining to avian–power line interactions, and include procedures for 

managing nesting on power line structures. The modifications to the plan 

should be prepared after consultation with FWS. Conduct pre-construction 

surveys for the spadefoot toad in all areas of proposed construction activity not 

previously surveyed in 2009 or 2010, and implement the same protection 

measures proposed for the central project area.

• Amend the proposed Raven Monitoring and Control Plan to include baseline 

and post-construction survey methods for predators other than just ravens, 

including coyote, wild dogs, and gulls and develop mitigation measures to be 

implemented if increases in population levels are detected, and develop a 

desert tortoise predator control plan, as the Park Service recommends. Include 

a survey schedule that includes initiation of post-construction surveys during 

the second year after project completion, followed by surveys once every 5 

years.

• Consult with BLM, participating tribes, and the California SHPO to revise the 

December 2009 HPMP to include: (1) clarification in the HPMP’s Overview 
27

and Executive Summary that the Eagle Mountain mine, town site, and 

associated railroad are potential historic properties; (2) requirements for annual 

reporting during construction and an annual HPMP implementation report;

(3) a plan to address curation of recovered archaeological materials;

(4) clarification of when cultural resources monitoring and which monitoring 

protocols would be required; (5) a requirement for consultation with Native 

American tribes regarding employee training and public interpretation 

programs; (6) a detailed discussion of the expanded APE alternatives, 

including revised APE maps; (7) a description of the sites documented by 

Schaefer (2010) and located within the expanded APE; (8) inclusion of a 

detailed plan and schedule for National Register evaluations, assessment of 

effects, and identification of measures to resolve adverse effects of project 

construction, operations, and maintenance on any of sites identified within the 

specific Commission staff’s recommended transmission line corridor and 

substation location, including the documentation of appropriate consultation 

with the participating tribes, BLM, and California SHPO; and (9) measures for 

handling newly discovered paleontological resources and the reporting of such 

discoveries to BLM. The anticipated PA would implement the HPMP.

2.4 ALTERNATIVES CONSIDERED BUT ELIMINATED FROM FURTHER 

ANALYSIS

Eagle Crest chose the proposed project location based several factors, including 

the proximity of the two inactive mining pits, which would greatly decrease the cost of 

dam construction, and the elevation difference (about 1,500 feet) between the pits, which

is key for a pumped storage facility. Furthermore, the site is only about 13 miles from a 

major transmission line. Eagle Crest also chose this site because of its proximity to 

existing and proposed renewable energy generation facilities and the Chuckwalla aquifer, 

the proposed source for water. None of the other nearby locations has the combination of 

these attributes, and no other sites were considered for this project. 

Before choosing its proposed reverse osmosis system, Eagle Crest considered 

several other water treatment alternatives, including thermal processes, conventional 

demineralization using IX resin, and electrical demineralization. These other measures 

were determined to be much more costly and impractical for the project. 

Eagle Crest also considered several other transmission alignments, but they were 

determined to be impractical. These alternatives include the following: 

• A connection at the Danvers substation near Palm Springs that would require a 

route of 83 miles and was determined to be very expensive. This transmission 

alignment also would have had right-of-way (ROW) issues and likely would 

have had substantial effects on the natural and human environment, including 

the Aqua Caliente Band of Cahuilla Indians. 
28

• A connection to SCE’s proposed midpoint substation with a route that would 

have been slightly longer than 50 miles and would have crossed both the 

Chuckwalla Valley dune thicket, an area of critical environmental concern and 

also Interstate 10. The length of the route and issues associated with crossing 

these two areas made this route impractical. 

• The addition of the proposed double circuit 500-kV line to the existing 

transmission towers owned by Metropolitan Water District was determined to 

be infeasible due to the size and weight of the proposed lines on the existing 

infrastructure. 

• A location of a possible substation near the intersection of Eagle Mountain 

Road and Interstate 10 was determined to be infeasible due to cultural 

resources concerns and the location of an existing high pressure gas line. 

Eagle Crest considered the possibility of using the Metropolitan Water District’s 

CRA for its water supply, rather than the Chuckwalla aquifer. However, Eagle Crest 

determined that this option was infeasible because of the need to purchase replacement

water (for the CRA water that Eagle Crest would use) from the San Joaquin Valley 

(which also supplies Los Angeles), so water from the heavily regulated and vital CRA 

could be used. This option would have been especially impracticable during drought 

years, and Metropolitan Water District stated that it would not agree to this proposal. 

Finally, quagga mussels are found in the CRA, and these organisms would be 

problematic for the proposed project. 
29

3.0 ENVIRONMENTAL ANALYSIS

In this section, staff presents: (1) a general description of the project vicinity; 

(2) an explanation of the scope of staff’s cumulative effects analysis; and (3) staff’s

analysis of the proposed action and other recommended environmental measures. 

Sections are organized by resource area. Under each resource area, historic and current 

conditions are first described. The existing condition is the baseline against which the 

environmental effects of the proposed action and alternatives are compared, including an 

assessment of the effects of proposed mitigation, protection, and enhancement measures, 

and any potential cumulative effects of the proposed action and alternatives. Staff 

conclusions and recommended measures are discussed in section 5.2, Comprehensive 

Development and Recommended Alternative, of this draft EIS.

16

3.1 GENERAL DESCRIPTION OF THE PROJECT AREA

The proposed project would be located at the edge of the Eagle Mountains in 

southeastern California in Riverside County in the western Sonoran Desert, commonly 

called the “Colorado Desert,” which includes the area between the Colorado River Basin 

and the Coast Ranges south of the Little San Bernardino Mountains and the Mojave 

Desert. The proposed project would be located south and east of Joshua Tree National 

Park and wilderness area (JTNP), just about 2 miles from the closest JTNP boundary (see 

section 3.3.5, Recreation, Land Use, and Aesthetics, for more about the JTNP).

Rainfall amounts are low, ranging from about 3 to 5 inches per year. Winter 

temperatures average about 54°F, and summer temperatures are extreme, commonly 

reaching 110+°F for long periods. The period of extremely warm weather is also 

lengthy, extending from mid-spring through the fall. 

Gently sloping to undulating rocky slopes and valleys are found in the area of the 

proposed project’s linear features (i.e., water pipeline and transmission line). Elevations 

range from about 400 to 2,500 feet. No perennial streams or natural wetlands exist in the 

project vicinity. Drainages in this part of Riverside County are generally limited to highenergy runoff via desert washes that are usually dry. As water from these events quickly 

percolates into the surrounding soil or evaporates, the establishment of wetland 

vegetation is precluded. 

Drainage patterns reflect the local topography. Along the broad rocky slopes, 

drainage is primarily characterized by scattered, well-defined washes and networks of 

numerous narrow runnels. The runnels are several yards wide, sandy to cobbly drainages 

 

16 Unless otherwise indicated, our information is taken from the application for 

license for this project (Eagle Crest, 2009a) and additional information filed by Eagle 

Crest (Eagle Crest, 2010, 2009b–d) and the State Water Board EIR (State Water Board, 

2010). 
30

that carry periodic runoff to a regional drainage. They are often incised, from a half to 

several yards deep, and vegetated along the banks by shrubs and trees. By contrast, the 

more numerous, smaller and shallow runnels are typically only a yard or less wide, 1 to 3 

inches deep, and irregularly vegetated by locally common shrub species. 

Soils generally range from soft sand to coarse-sand loams, with Aeolian patches of 

loose sand and intermittent incipient dunes. Boulders and cobbles are common in the 

upper bajadas and toeslopes, with smaller particles downslope. Desert pavement17

Numerous transmission lines and service roads cross the area south of the project 

site. The CRA extends through the Coxcomb Mountains northeast of the project area and 

continues in a southwesterly direction, passing the eastern portion of the project area as 

an open channel before converting into a tunnel to the Metropolitan Water District’s 

pumping plant. 

is 

intermittently present in the immediate area of the central project area. 

3.2 SCOPE OF CUMULATIVE EFFECTS ANALYSIS

According to the Council on Environmental Quality’s regulations for 

implementing National Environmental Policy Act (40 CFR §1508.7), a cumulative effect 

is the impact on the environment that results from the incremental impact of the action 

when added to other past, present and reasonably foreseeable future actions regardless of 

what agency (federal or non-federal) or person undertakes such actions. Cumulative 

effects can result from individually minor but collectively significant actions taking place 

over time, including hydropower and other land and water development activities.

Based on review of the license application and agency and public comments, staff 

identified water resources, terrestrial resources (including federally listed threatened and 

endangered species), land use, recreation, and air quality as having the potential to be 

cumulatively affected by the proposed project in combination with other past, present, 

and foreseeable future activities. These resources were selected because of the potential 

that they could be cumulatively affected by the development of this project in addition to 

other residential and agricultural groundwater uses, the CRA, the proposed Eagle 

Mountain landfill, proposed solar energy and wind energy developments, and other 

actions that staff identifies in its analysis. 

3.2.1 Geographic Scope

The geographic scope of the analysis defines the physical limits or boundaries of 

the proposed action’s effect on the resources. Because the proposed action would affect 

the resources differently, the geographic scope for each resource may vary.

 

17 Desert pavement, which occurs only in the drier parts of the Sonoran Desert, is a 

surface made up of a closely packed mosaic of stones that accumulate as the finer dust 

and sand particles are blown away by the wind.
31

The geographic scope for water resources would be the Chuckwalla Valley

Aquifer and potentially adjacent, hydrologically connected aquifers, such as the Pinto

Basin Aquifer. This geographic scope was selected because the groundwater to be used

for this project, as well as other reasonably foreseeable projects, would be withdrawn

from the Chuckwalla Valley Aquifer, and staff may determine that cumulatively 

groundwater-level effects may extend to adjacent basins. 

The geographic scope for terrestrial resources would be lands above the 

Chuckwalla Valley Aquifer and Pinto Basin Aquifer, which includes portions of JTNP.

This broad area was identified to address the potential for subsidence related to 

groundwater withdrawal to cumulatively effect terrestrial plants and wildlife. Other 

project effects would also be limited to this geographic area.

The geographic scope for recreation, land use, and aesthetics is the greater 

Chuckwalla Valley from the Coxcomb Mountains to the east, the Chuckwalla Mountains 

to the south and JTNP to the north and west. This area offers the recreation 

opportunities, landscapes, and the visual resources, which are typical of the region, and 

may also be cumulatively affected by other reasonably foreseeable projects.

The geographic scope for other resources, including geological resources and 

soils; terrestrial and threatened and endangered species; cultural; socioeconomics; and air 

quality and noise, would be that portion of the Chuckwalla Valley and Interstate 10

corridor sufficient to encompass all project facilities, as well as construction and 

operation effects.

3.2.2 Temporal Scope

The temporal scope of the cumulative effects analysis in the draft EIS includes

past, present, and future actions and their respective effects on each resource that could 

be cumulatively affected. Based on the potential term of an original license, the temporal 

scope will look 50 years into the future, concentrating on the effect on the resources from 

existing and reasonably foreseeable future actions. The historical discussion will be 

limited, by necessity, to the amount of available information for each resource. Staff 

identified the present resource conditions based on the license application, agency 

comments, and comprehensive plans.

3.3 PROPOSED ACTION AND ACTION ALTERNATIVES

In this section, staff discusses the effect of the project alternatives on 

environmental resources. For each resource, staff first describes the affected 

environment, which is the existing condition and baseline against which staff measures

effects. Staff then discusses and analyzes the specific site-specific and cumulative 

environmental issues. 

Only the resources that would be affected, or about which comments have been 

received, are addressed in detail in this EIS. Staff presents recommendations in section 

5.2, Comprehensive Development and Recommended Alternative. 
32

3.3.1 Geologic and Soil Resources

3.3.1.1 Affected Environment

General Geologic Setting

The proposed project site is located in the northeastern portion of the Eagle 

Mountains near the lower western edge of the Mojave Desert Physiographic Province of 

California, slightly east of the southern limits of the adjacent Transverse Ranges 

Physiographic Province. The Eagle Mountains are bounded on the northeast by the 

Coxcomb Mountains, the southeast by Chuckwalla Valley, and the north by Pinto Basin

(figure 5). To the south are the Orocopia Mountains (west) and the Chuckwalla 

Mountains (east). A broad valley containing Smoketree Wash forms the edge of the 

Eagle Mountains to the west. The Cottonwood Mountains are to the southwest of the 

project area.

The major rock units in the region include Jurassic- to Cretaceous-age plutonic 

intrusive rocks and Paleozoic and Precambrian metamorphic and meta-sedimentary rocks 

(Jennings, 1967). At the Eagle Mountain site, the meta-sedimentary rocks generally 

trend northwest and are surrounded and underlain by intrusive granitic rocks. The metasedimentary rock units have been folded into a northwest-trending anticline, which 

continues into the north-central Eagle Mountains. Iron ore deposits composed of 

magnetite and hematite are typically found along the northeast limb of this anticline. 

Localized outcrops of Tertiary-age volcanic rocks are found in the region, 

principally at the northern end of the Chuckwalla Valley. Younger Pleistocene-age basalt 

is present in the north-central portion of the Eagle Mountains. Deposits of Quaternaryage alluvium fill the Pinto Basin and Chuckwalla Valley, locally reaching depths of 

greater than 2,000 feet (Eagle Crest, 1994). Alluvial deposits include both 

cobbles/gravels and finer grained units that form alluvial fans at the mouths of major 

drainages from the adjacent highlands.

Regional structural trends are reflected in the alignments of faults in and near the 

Eagle Mountain site. East-west trending faults are present at distances of about 5 miles, 

both to the north and south of the site, while northwest-trending faults are present locally 

along the eastern edge of the Eagle Mountains. The latter group of faults includes the 

Bald Eagle Canyon fault zone and several smaller faults that traverse the planned tunnel 

alignments. None of these faults have experienced deformation within the last 11,000 

years as indicated by the unbroken alluvial deposits that overlie them (Eagle Crest, 1994).
33

Figure 5. Mountains and groundwater basins in the project area (Source: Eagle Crest, 2009a, as modified by staff).
34

The proposed project site is cut by a series of northeast-trending dikes.18

Range-front faulting has been recognized to the east of the Eagle Mountain site, 

along the eastern side of the Chuckwalla Valley parallel to the base of the Coxcomb 

Mountains. Vertical displacements along this fault zone may be up to several thousand 

feet, with the western side being displaced downward relative to the eastern side (Eagle 

Crest, 1994). Range-front faults do not appear to be present along the eastern side of the 

Eagle Mountains.

 The 

dikes have near-vertical dips and lie at nearly right angles to the northwest-trending 

faults. Where exposed, dikes that cross the northwest-trending faults are not offset by the 

faults (Eagle Crest, 1994).

Project Area Geology

Bedrock geologic units present at the site can be generally classified as either 

igneous or meta-sedimentary. In general, the younger igneous rocks intruded into the 

older meta-sedimentary rocks, leaving the meta-sediments as remnant roof pendants atop 

the plutonic rock. Areal near-surface exposures of the rock units in the project area are 

shown on figure 6. 

Unconsolidated alluvial deposits are found in several locations within the project 

site area (figure 6). The alluvial deposits include sands, silts, gravels, and debris-flow 

deposits (Eagle Crest, 1994). The most substantial alluvial deposits are found on the 

eastern edge of the site area, where they form a laterally extensive alluvial fan that 

extends and thickens to the east into the Chuckwalla Valley. The thickness of the alluvial 

fan is on the order of a few tens of feet near the mountain front and thickens steadily to 

the east. 

Some of these alluvial deposits are exposed in the east wall of the eastern mining

pit, in an area that would underlie the lower reservoir (Eagle Crest, 1994). Elsewhere 

within the area of the proposed project, alluvial deposits are confined to laterally 

discontinuous, generally thin deposits along the bottoms of the canyons (Eagle Crest, 

1994). These deposits are typically composed of sandy gravel, but may vary locally from 

sand and gravelly sand to gravel and generally range up to 50 feet in thickness. The 

thickest deposits are found near the mouths of canyons. Older alluvial deposits in the 

upper portions of the canyons may be locally cemented (Eagle Crest, 1994). An alluvial 

fan is exposed near the base of the north wall in the eastern mining pit of the inactive 

Eagle Mountain mine (Eagle Crest, 1994). At the base of this feature, and interbedded 

with some of the soils characteristic of the upper portions of the fan, are a series of debris 

flows. In the east wall of the eastern mining pit, debris flow deposits rest directly on 

bedrock (Eagle Crest, 1994). 

 

18 A dike is an intrusive igneous body that normally has a thickness much smaller 

than its other two dimensions.
35

Figure 6. Eagle Mountain Project area geologic map (Source: Eagle Crest, 2009a).
36

Mining byproducts generated by the former Eagle Mountain operations were 

deposited in numerous areas near the site (see figure 6). These byproducts include 

several distinctly different materials, including both bedrock and alluvial overburden, and 

tailings produced as a result of the mining and separation of iron ore bearing rock from 

host rock. The tailings include both fine and coarse varieties. Investigations in 1990 

(Kaiser Steel Resources, Inc., 1990, as cited in Eagle Crest, 1994) indicated that 

recoverable precious metals (e.g., gold, silver, or any of the minerals of the platinum 

group) are not present in the proposed project area. Eagle Crest states that the tailings 

would be suitable for use in project construction.

Soil Resources

General Project Area

The soils within the proposed project area are generally sandy and have developed in a 

mid-latitude, low desert environment at elevations ranging from 1,000 to 2,800 feet 

above mean sea level (msl). Slopes range from nearly level to extremely steep and 

include both north- and south-facing exposures as well as numerous intermediate aspects. 

Vegetation is Sonoran desert shrubland (Eagle Crest, 1994). Soils within the proposed 

project area can be divided into the following mapping units.

In areas of 2 to 5 percent slope, soils are very deep, excessively drained, sand and 

loamy sand horizons formed in alluvial fan deposits at the eastern foot and within valley 

bottoms of the Eagle Mountains. The water erosion hazard of these soils is moderate 

because of minimal vegetative protection. The less-steep soil unit is situated near the east 

side of the eastern mining pit and beneath the proposed lower reservoir spillway, while 

the slightly steeper soil unit is situated in part beneath the proposed desalination and 

staging, storage, and administration areas.

In areas of slopes greater than 15 to 75 percent, there are rock outcrops; shallow, 

excessively drained, very gravelly sand; and very gravelly loamy sand. These soils have 

formed on mountain slopes in colluvial deposits derived from crystalline bedrock. The 

water erosion hazard of these soils is severe because of steep slopes and minimal 

vegetative protection. This soil unit is found in various locations around the project area, 

including between the central and eastern mining pits and near the desalinization area.

Soils in areas of mine dumps and tailings consist of mixed cobbles and soil 

deposited by human activity. These deposits have not been stable long enough to 

develop characteristic soil profiles. This unit is found throughout the project area, 

particularly in areas immediately adjacent to the central and eastern mining pits.

The excavations of the central and eastern mining pits are characterized by 

disturbed rock outcrops or a thin mantle of mixed soil and cobbles deposited by human 

activities.
37

Water Supply and Transmission Line Corridors

Specific areas of the water supply and transmission line corridors have not been 

mapped in detail according to the applicant, although limited soils mapping was 

performed by Kim (1993, as cited in Eagle Crest, 1994) in the Desert Center area, which 

is in the vicinity of the proposed linear feature corridors. The proposed water supply 

corridor extends through a desert basin environment crossed by numerous washes. The 

soils of this area are gravelly loamy sands with particle size decreasing with distance 

from the mountains. The soils have low runoff, with moderately rapid to rapid 

permeability. 

Soils, slopes, and vegetation coverage within the proposed transmission line 

corridor and the BLM utility corridor area are similar to those along the proposed water 

supply corridor. Specifically, soils within the transmission line corridor have developed 

primarily on valley fill alluvium. The soils are excessively drained fine sands, sands, 

gravelly sands, and cobbly sands. In some areas, the soils are deep (5 to 6 feet deep) with 

a moderate water erosion hazard, are found on nearly level to moderately steep slopes, 

and have formed on alluvial fans and valley fill. In other areas, the soils are shallow, are

found on nearly level to steep slopes, have formed on hill and mountainsides, and are 

subject to severe water erosion on steeper slopes.

Geologic Hazards

Potential geologic hazards at the proposed project area include ground rupture 

from active faulting, strong ground motions from earthquakes, landslides or rockfalls 

(induced by earthquake, rainfall and saturation, or other triggers), and liquefaction and 

seismic settlement.

Seismicity

There are numerous active19 and potentially active20

 

19 Active faults (Bryant and Hart, 2007) are defined as faults along which 

seismically induced (tectonic) displacement has occurred in the past 11,000 years (the 

Holocene epoch). The California Division of Safety of Dams criterion for active faults 

(Fraser, 2001) is noted displacement within the last 35,000 years.

faults and fault zones located 

within 100 miles of the proposed project area (Eagle Crest, 1994; Geosyntec, 1996). 

Based on the Fault Activity Map of California, the nearest active faults to the site are the 

Hot Springs fault and the paralleling San Andreas fault (Coachella segment), located 

about 30 miles and 33 miles southwest of the site, respectively.

20 Potentially active faults are defined as faults along which tectonic displacement 

has occurred between 11,000 and 1.6 million years before present (ypb) (the Pleistocene 

epoch). Inactive faults are defined as faults along which tectonic displacement has not 

occurred in the past 1.6 million years (i.e., before the Quaternary period).
38

The Alquist-Priolo Earthquake Zoning Act (Bryant and Hart, 2007) establishes 

zones around “sufficiently active and well-defined” faults in California wherein sitespecific fault location studies are required to mitigate fault surface rupture hazards prior 

to construction intended for human occupancy. The closest “zoned” faults to the project 

area are the Hidden Springs fault, located 29 miles to the southwest, the aforementioned 

Hot Springs fault, and the mid-east portion of the Pinto Mountain fault, located 32.5 

miles to the northwest.

Potentially active faults are also frequently considered in a seismic hazard 

assessment since they can represent active faults that have a greater (more than 11,000 

years) recurrence interval. In addition to the aforementioned faults, potentially active late 

Quaternary faults considered capable of generating significant seismic events include the 

Blue Cut fault, with the nearest segment mapped about 4 miles north of the site; the 

Salton Creek fault, about 23.5 miles to the southwest; and eastern segments of the Pinto 

Mountain fault, located 30.5 miles northwest of the site. In addition to these faultspecific sources, previous investigations of seismic exposure at the project area (Eagle 

Crest, 1994; GeoSyntec, 1996) considered non-specific area sources including the 

Southeast Transverse Ranges, the San Bernardino Mountains, the Eastern Mojave, the 

Sonoran, and the Salton seismo-tectonic zones. 

Locally, six major structural lineaments have been found to trend across the 

proposed reservoir sites or are within 2,000 feet of the proposed project area (GeoSyntec, 

1992, as cited in Eagle Crest, 1994). Three of these are bedrock faults (Fault A, Bald 

Eagle Canyon fault, and eastern mining pit fault), two are intrusive dikes, and the last 

formed from differential erosion along prominent joints in the bedrock (see figure 6). 

Field investigations indicated that the lineaments trend northwest across the site in a 

direction consistent with a pattern of regional faulting believed to have existed since 

Miocene time (i.e., about 5 to 22 million years ago [Ma]) (Proctor, 1993, as cited in Eagle 

Crest, 1994; Shlemon, 1993). Analyses performed as part of these investigations 

indicated that no displacement has occurred along these local faults in the past 40,000 to 

100,000 years (GeoSyntec, 1993). Site mapping indicated that cross-cutting dikes of 

volcanic rock, dated as 124 million years or more in age (GeoSyntec, 1993), are not 

offset by Fault A and the Bald Eagle Canyon fault. This suggests that the most recent 

movement of these faults dates back to at least Mesozoic time (>65 Ma). The 

relationship of the cross-cutting dikes to the eastern mining pit fault is less certain, but the 

fault is readily exposed in the walls of the eastern mining pit beneath up to 270 feet of 

unbroken alluvium, estimated to be more than 100,000 years in age (Proctor, 1993, as 

cited in Eagle Crest, 1994).

Additional northwest-southeast fault segments were mapped; one in the western 

end of the eastern mining pit and another at western end of the proposed landfill footprint 

(GeoSyntec, 1993). Soil stratigraphic age dating of these features was hindered by lack 

of natural soil cover. However, GeoSyntec (1993, 1996) concluded that, due to the 

echelon structure of the northwest-southeast system of site area faults, formation of all 

the northwest-trending faults at the site occurred within a similar geologic age and 
39

tectonic stress regime. Thus, these additional fault segments were also concluded to be at 

least pre-Holocene in age (<10,000 years). However, if the northwest-trending faults are 

collectively considered to be of similar age and origin, significant displacement has not 

occurred on these faults since the formation of the dikes more than 100 million years ago. 

As such, these faults are considered inactive. Further details of the investigations for onsite faults, including information from the Proctor (1993, as cited in Eagle Crest, 1994) 

and Shlemon (1993) studies, are contained in GeoSyntec (1993, 1996).

The California Geology Survey (California GS) provides a database of all known 

historical earthquakes of magnitude greater than 4.0 within the project region for the 

period from 1769 to 2000 (California GS, 2001). As seen in part in figure 6, the project 

site lies on the eastern edge of a region of high historical seismicity in southern 

California. Most seismicity in this area is associated with the San Andreas fault zone 

(southwest and west of the site), the San Jacinto fault zone (south and west of the site), or 

the Brawley fault zone (south of the site). Some seismicity is associated with the Pinto 

Mountain fault to the north of the site. Upon review of recorded seismicity in the region, 

and using the attenuation relationship developed by Sadigh as reported by Joyner and 

Bore (1988), GeoSyntec (1992, as cited in Eagle Crest, 1994) estimated that the strongest 

ground motion at the site from historical events was about 0.15 g,21

Calculations of potential ground motion at the project site during an earthquake 

estimated the highest horizontal peak ground acceleration (PGA)

using mean 

attenuation rates, and 0.27 g using mean plus one standard deviation.

22

Liquefaction

of 0.49 g that results 

from a magnitude 6.75 random event in the Southeast Transverse Ranges. A similar 

PGA of 0.48 g was estimated from a magnitude 7.5 event on the Blue Cut fault (Eagle 

Crest, 1994; GeoSyntec, 1996). Regional probabilistic studies on seismicity (Peterson et 

al., 2008) estimate that the site has a 2 percent probability of exceeding PGAs of between 

0.35 and 0.46 g in the next 50 years. Analysis of probabilistic potential ground motions 

for the project area, based on U.S. Geological Survey (USGS) (Frankel et al., 2002) and 

California GS (2007) databases, indicates that, for return periods of 100 and 475 years, 

PGAs of 0.10 g and 0.19 g, respectively, are estimated.

Liquefaction can occur when loose, saturated granular soils are subjected to strong 

ground motion, such as that induced by earthquakes. The ground vibrations cause a rise 

 

21 1 g is the acceleration due to gravity, where 1 g = 32.2 feet second-2

; used to 

measure the peak ground acceleration during an earthquake.

22 PGA is a parameter used to measure the horizontal force experienced at a given 

location during an earthquake. This force has the potential to cause damage to structures 

depending on its magnitude and on how much horizontal force the structure can 

physically withstand.
40

in pore-water pressure,23

Landslides and Mass Movements

which, if high enough, can cause the soil to lose strength and 

behave as a fluid. Liquefaction can result in settlements, lateral spreading, and other 

disruptions at the ground surface. The sandy sediments associated with the alluvial fan 

and valley floor features in the project area could have the potential for liquefaction and 

seismic settling. Groundwater conditions, which can affect the potential for liquefaction

occurrence during an earthquake, are discussed in the Groundwater section.

In the proposed project area, there are potentially unstable slopes upon hillsides 

and mining pit walls due to their steepness and the nature of the underlying soil and rock 

types. Mass movements such as slope raveling and localized surficial slope failures 

and/or rock falls could occur here. 

To date, USGS and California GS have not published any soil-slip susceptibility 

or landslide inventor maps of the project region; therefore, detailed mapping information 

is not available for evaluating the potential for landslide and mass movement activity in 

the proposed project area.

3.3.1.2 Environmental Effects

This section describes the potential project effects related to geology and soils 

resource issues deriving from construction and/or project operation activities. Prior to 

construction, the applicant proposes to conduct detailed subsurface investigations in the 

project area to support final project configuration and design. The details of these 

proposed site investigations are summarized by the applicant in section 12.6 of its license

application (Eagle Crest, 2009a). In brief, these investigations would primarily involve 

soil/rock exploration boring and detailed geologic mapping efforts to further evaluate 

potential project-related reservoir seepage, hydrocompaction and subsidence, landslides 

and mass movements, liquefaction, and reservoir-triggered seismicity. In its letter filed 

October 27, 2009, Eagle Crest states that the subsurface investigations would be initiated 

within 60 days of licensing and receipt of site access, field work would be completed 

within 4 months of the start of field investigations, and the results would be filed with the 

Commission 6 months after the start of the field investigations.

 

23 Pore-water pressure is the force exerted by groundwater contained within the 

voids, or pores, of a soil or rock substrate. Excessive pore-water pressures can lead to 

soil or rock instabilities.
41

Effects of Project Construction and Operation Related to Seismic Issues 

Earthquakes and Faults

There are no active faults in the proposed project area, based on the findings of 

past site-specific investigations (Geosyntec, 1993, 1996). Therefore, the risk of surface 

rupture at the project area caused by local faulting is considered to be very low as these 

faults were determined to be inactive within the past 40,000 years or more. The project 

facilities would be designed to resist the anticipated ground shaking related to earthquake 

activity in the region. As mentioned above, prior to construction, Eagle Crest proposes to 

conduct subsurface investigations, which would also include a geotechnical study in 

order to modify, if needed, the existing project designs. 

Reservoir-triggered Seismicity

The proposed project would include constructing upper and lower reservoirs, 

which would occupy areas that are crossed by several inactive, northwest-trending faults. 

In general, reservoir impoundment or operation has the potential to activate fault 

movement, and hence produce earthquakes, which is a process defined as reservoirtriggered seismicity. This process occurs when reservoir impoundment alters the stress 

regime within the crust of the earth by increasing shear stress due to the weight of water, 

and reducing the shear strength (i.e., resisting force) by increasing pore-water pressures. 

While these changes are generally insufficient to generate failure in unfractured rock, it is 

possible that faulted rock under significant tectonic strain may be induced to slip by the 

compounding effects of reservoir impoundment (USCOLD, 1997). As such, zones of 

active faulting appear to be the most susceptible to reservoir-triggered seismicity. 

Further, the maximum credible earthquake for an area is not considered to change by 

reservoir filling actions, although the frequency of smaller earthquakes may be increased, 

at least on a temporary basis (FEMA, 2005).

To assess the actual occurrence of reservoir-triggered seismicity in the project area 

once implemented, Eagle Crest proposes to initiate a seismic monitoring program in the 

project area. Eagle Crest proposes to maintain the monitoring program before and after 

reservoir filling to assess whether these actions lead to reservoir-triggered seismicity.

Our Analysis

The proposed project area is crossed by several inactive faults and would be 

situated in a region with recorded seismic activity. The two proposed reservoirs would 

use the two inactive mining pits that were created by the excavation of vast quantities of 

overburden and ore-bearing rock. When either the upper or lower reservoirs are filled to 

maximum operation level, the deepest column of water in each would be less than the 

depth of mining excavation. Total water storage projected for both reservoirs is 

estimated at about 24,200 acre-feet compared to a total storage capacity of 41,900 acre-
42

feet.24

Although the maximum depth of stored water in the reservoirs would characterize 

both reservoirs as being “shallow and small”

 Considering that the weight of water is about 2 (overburden) to 2.5 (ore rock) 

times less than that of the excavated material, the loads applied by the reservoirs at high 

water would be substantially less than that originally imposed prior to mining. As such, 

Eagle Crest reasonably asserts that the reservoir load may tend to restore some of the 

equilibrium lost through the site excavations rather than imposing potentially 

destabilizing stresses that could lead to earthquakes.

25

Based on the potential for naturally caused and reservoir-induced earth movements 

to occur in the project area during the 50-year lifetime of the proposed project, the staff 

sees the benefits associated with Eagle Crest’s proposal to: (1) conduct a thorough 

subsurface investigation in the project area to better characterize existing conditions for 

the purpose of refining the final design of project features (i.e., implementation of a 

Geotechnical Study Plan as proposed in section 12.6 of Eagle Crest’s final license 

application [Eagle Crest, 2009a]), and (2) establish a seismic monitoring program per the 

general recommendations of the International Commission on Large Dams (ICOLD, 

2008) for reservoir projects. Continuing the applicant’s proposed seismic monitoring 

program through the initial operation and life of the project would help determine if there 

is the potential of reservoir-triggered seismicity within the area. 

(Baecher and Keeney, 1982), the initial 

filling of the reservoirs and the planned twice-daily movement of a relatively large mass 

of water could impose stress upon the underlying land surface. This stress could 

potentially trigger land movement, manifested either slowly via gradual earth movement 

or rapidly as a small earthquake. Several fault traces crossing beneath or close to the two 

proposed reservoirs could serve as the focus of these movements, despite the findings that 

these “inactive” faults have not experienced natural seismic activity within the past 

40,000 years. 

Effects of Project Construction and Operation on Liquefaction

The proposed pumped storage reservoirs and associated facilities would be 

constructed on a combination of bedrock and alluvium. As discussed in greater detail in 

the Groundwater section, groundwater levels in the project area are typically hundreds of 

feet below the ground surface, although in the eastern mining pit, the most recent 

 

24 For generation at a pumped storage facility to occur, water storage at both 

reservoirs is normally slightly more than half of the total available storage.

25 “Shallow and small” reservoirs are considered by Baecher and Keeney (1982) to 

have a probability of reservoir-triggered seismicity that is “very near zero” and are 

defined as reservoirs having less than 302 feet of water depth and storing less than about 

973,000 acre-feet of water volume.
43

available groundwater data (CH2M HILL, 1996) indicate a groundwater level that at 

times is about 20 feet below the lowest portions of the pit.

Liquefaction can occur when loose, saturated sandy soils are subjected to 

earthquakes. In its license application, Eagle Crest provides the screening criteria from 

the Southern California Earthquake Center for determination of liquefaction hazards 

(SCEC, 2009) and concludes that a liquefaction assessment is not required. The criteria 

are as follows: 

1. the estimated maximum past, current, and future groundwater levels are 

determined to be deeper than 50 feet below the existing or proposed final site 

grade; 

2. bedrock or other similar material that is considered to be non-liquefiable 

directly underlies the site; 

3. the granular (i.e., sandy) soils underlying the site are all determined to be 

dense to very dense; and 

4. the underlying soils have a clay content greater than 15 percent. 

Eagle Crest further states that geologically mature alluvial fan and plain 

sediments, like those found on the eastern edge of the eastern mining pit, generally have a 

low potential for liquefaction based on their relatively high material density (Youd and 

Perkins, 1978).

To minimize the potential for a liquefaction hazard to occur, Eagle Crest proposes 

to maintain pre-project groundwater levels in areas influenced by reservoir seepage by 

installing a seepage recovery system as described in section 3.3.2, Water Resources, 

under the heading Groundwater. Eagle Crest indicates that the potential for liquefactioninduced settlements would be very low to non-existent because, coupled with

implementation of the recovery system, the project would mostly lie on shallow bedrock, 

dense geologically mature sediments, or properly engineered and compacted fill. 

Our Analysis

The project would include two reservoirs and associated facilities mostly built on 

bedrock with some portions of these structures (e.g., east side of the lower reservoir) built 

on alluvial sediments. Following the SCEC (1999) screening criteria, the proposed 

project fails to satisfy the first three of the four criteria, specifically for those project areas 

near the east side of the eastern mining pit. Groundwater levels beneath the proposed 

lower reservoir are reportedly within 50 feet of the existing ground surface, or bottom of 

the eastern mining pit. Further, the soil densities and the clay content levels in sediments 

underlying portions of the project area are not wholly known. Therefore, a liquefaction 

assessment in the project area and in areas where project-induced groundwater levels 

could rise within 50 feet of the surface (e.g., from reservoir seepage) would provide 
44

needed information to address liquefaction concerns. Collecting data as part of Eagle 

Crest’s subsurface investigations would allow Eagle Crest to perform the liquefaction 

assessment.

Effects of Project Operation on Subsidence and Hydrocompaction

Subsidence of the ground involves the downward settling of the land surface and 

can occur over variable rates, time periods, and spatial area. Common triggers for 

subsidence may be natural or human-made. In alluvial soils, like those found in the 

Upper Chuckwalla Valley, subsidence can occur from substantial lowering of the water 

level in an aquifer. 

Hydrocompaction is a process whereby oversaturation of the subsurface sediments 

by rising groundwater levels cause sediments to consolidate and settle, thereby leading to 

the subsidence of the land surface. This process can be triggered by the rising of the 

water table in alluvial sediments.

Because these processes primarily involve an alteration of groundwater levels, 

discussions of the effects of the project on subsidence and hydrocompaction in the project 

area and the Chuckwalla Valley groundwater basin are found in the Groundwater section.

Effects of Project Construction on Soil Erosion

Infrequent, short-duration, high-intensity rainfall events can mobilize large 

amounts of loose soil and sediment in the project area. Disturbed soils and mine tailings 

within the inactive mine area, as well as other disturbed surfaces such as dirt roads,

supply the source material during runoff events, resulting in surface and channel erosion, 

material transport, and high turbidity in receiving waters. There would be some increases 

in soil erosion resulting from construction of the project, specifically related to 

development of the upper and lower reservoirs, access roads, power line towers, water 

supply pipeline, and surface facilities. Project-related effects on stream channel scour 

potential are addressed in section 3.3.2, Water Resources. 

Eagle Crest prepared an Erosion and Sediment Control Plan as part of its

application (Measure GEO-1). The plan includes best management practices (BMPs) to 

be implemented during the construction process to control and minimize erosion and to 

stabilize disturbed lands after construction. The Erosion and Sediment Control Plan

conceptually describes the erosion and sediment control practices planned for 

implementation during construction of the proposed project. These measures would 

minimize the erosion of soils in construction areas and prevent the transport of sediment 

and storm water discharges from the construction site. The Erosion and Sediment 

Control Plan also includes the development of a storm water pollution and prevention 

plan prior to construction. The storm water pollution and prevention plan would include 

a monitoring and inspection plan with reporting to occur on a routine (unspecified) basis 
45

and after substantial storm events. Eagle Mountain also proposes to revegetate all areas 

disturbed by construction, including the water pipeline and transmission line disturbed 

surfaces, with native plants. 

The following BMPs are included in Eagle Crest’s Erosion and Sediment Control 

Plan, which would be implemented during construction to prevent or minimize erosion: 

(1) preserve existing vegetation where required and when feasible and initiate 

construction immediately following vegetation clearing to minimize the exposure of 

scarified soil to wind and water; (2) use temporary fencing, protective barriers, or other 

similar methods to protect vegetation not required, or authorized to be removed; (3) slope 

roadways and excavations away from washes and clear loose soils and pre-existing 

sediments in areas where haul roads would cross surface washes; (4) install riprap at the 

washes; (5) build small earthen embankments within washes to slow or divert surface 

water; (6) install silt fences in work areas near a wash to prevent sediment from entering 

the wash during rain storms; (7) apply water to disturbed soil areas of the project site, 

under the supervision of a monitor, to ensure excessive runoff does not occur and to 

control wind erosion and dust; and (8) implement complementary sediment controls to 

intercept and filter out soil particles mobilized by surface runoff. Prior to construction, 

Eagle Crest would prepare a storm water pollution prevention plan detailing the BMPs 

that would be implemented at the site, which are subject to updating as dictated by 

changes in construction and construction schedules. A monitoring plan would be 

prepared as part of the stormwater pollution prevention plan, detailing the inspection, 

documentation, and corrective action procedures for the BMPs.

Our Analysis

Although the proposed project site is highly disturbed, with massive quantities of 

mining substrate currently exposed to erosive processes, construction of the upper and 

lower reservoirs, access roads, power line towers, water supply pipeline, and other 

constructed facilities have the potential to further disturb these materials throughout the 

area. Increased amounts of disturbance would increase sediment mobilized during rain 

events, resulting in an elevated sediment load in runoff leaving the project site and, 

ultimately, causing high turbidity and long-term sediment deposition in low gradient

areas. 

Eagle Crest’s Erosion and Sediment Control Plan, including BMP implementation 

and preparation of a storm water pollution and prevention plan and a monitoring plan, 

would address this potential project-related effect by adhering to industry standards. The 

measures outlined in the plan would minimize the potential of soil erosion of disturbed 

surfaces and of sediment transport in and near the construction areas.
46

Effects of Project Construction and Operation on Landslides and Mass 

Movements

Some areas within the central and eastern mining pits have potentially unstable 

slopes because mining has exposed unstable fractures on the pit walls. Consequently, 

slope failures and/or rock falls could be expected in these slopes during project 

construction and operations. 

Eagle Crest proposes to conduct detailed subsurface investigations to support final 

engineering designs and to further assess potential effects on geology and soils resources. 

During these site investigations, which would occur after site access is granted, Eagle 

Crest proposes to conduct geologic mapping to identify conditions of the overburden and 

bedrock exposed in the mine pits that may affect the stability of slopes during reservoirlevel fluctuations. Mapping would identify the degree and orientation of jointing and 

fracturing, faulting, and weathering, and the dimensions of the benches excavated during 

past mining activities. The stability of the cut slopes and benches would also be assessed 

at this time.

During construction activities, Eagle Crest proposes to remove loose and unstable 

rock blocks from slopes lying below an elevation of 5 feet above the proposed maximum 

water level in the reservoirs. Eagle Crest does not propose to modify existing cut slopes 

above these unless there is evidence of potential slope failure that could potentially affect 

project facilities. Eagle Crest also proposes to minimize slope failure potential by 

buttressing the lowermost slopes of each reservoir using mine tailings removed from 

potentially unstable areas above the reservoir water surface. Eagle Crest states that no 

mass soil or rock movements related to site construction could occur that would affect 

off-site facilities (i.e., those facilities existing and/or constructed upon the valley floor).

Our Analysis

Construction-related activities and on-going project operations have the potential 

to trigger slope failures and/or rock falls on unstable slopes within and possibly adjacent 

to the proposed reservoirs, facilities, and along linear features (e.g., roads) where 

construction involves earth moving. Eagle Crest’s proposed subsurface investigations 

would evaluate slope stability prior to the development of final engineering and designs, 

and its proposed measures to remove or grade the identified unstable slopes in the 

reservoirs would minimize slope failure potential. 

Effects of Project Construction and Operation on Active and Inactive Mines

The proposed project would use two of the four main mining pits at the inactive 

Eagle Mountain mine: the eastern mining pit and the central mining pit. The two 

western-most of the four main pits, the north and south Black Eagle pits, are outside the 

proposed central project area and would not be affected by construction and operation of 

the proposed facility, access roads, or transmission line. Located adjacent to the central 
47

project area, but outside of the proposed reservoir areas, are two mine adits26

The California State Lands Commission holds a 100 percent reserved mineral 

interest in a 467-acre parcel of land in the Eagle Mountain mine area, situated near the 

east end of the eastern mining pit (proposed lower reservoir). Geosyntec (1992, as cited 

in Eagle Crest, 1994) estimated that 23.5 million tons of iron-bearing placer (alluvium) 

deposits remain at the east end of the eastern mining pit. This amount is about 7 percent 

of the about 170 million tons of recoverable iron ore reserves estimated to be 

remaining on the entire Eagle Mountain mine (Eagle Crest, 1994; Mine Reclamation 

Corporation, 1997, as cited in Eagle Crest, 2009a). Kaiser held a California State Lands 

Commission-issued lease covering 145 acres of the mineral interest parcel. Since the 

lease expired in 2002, Kaiser applied to exchange the state’s reserved mineral interest on 

the entire 467-acre parcel for a partial interest in a nearby mineral estate owned by 

Kaiser. The U.S. Ninth Circuit Court of Appeals reviewed Eagle Crest’ license 

application, and on November 10, 2009, denied the land exchange between Kaiser and 

BLM.

(Eagle 

Crest, 1994). Eagle Crest does not plan to use or otherwise disturb these features as part 

of the proposed construction. The adits appeared to be stable at the time of previous 

evaluations conducted more than 15 years ago (Eagle Crest, 1994), although natural 

minor collapses are possible in the future.

27

Our Analysis

The project area would be situated upon two inactive mining pits used by Kaiser to 

extract iron ore from the underlying bedrock and alluvial deposits. Eagle Crest does not 

propose to evaluate the project’s potential effects on the structural integrity of the two 

abandoned mining adits adjacent to proposed project area. However, staff concludes that 

the structural integrity of the two mining adits could be potentially affected by projectrelated activities by blasting and other activities proposed during construction. 

Evaluating the potential project effects on these adits, including the potential for adit 

collapse, as part of the Eagle Crest’s proposed subsurface investigations, would help 

clarify this issue and provide an opportunity for Eagle Crest to propose mitigation 

measures, if needed. 

Reclamation of existing rock and ore materials present within the proposed project 

area would not be possible once the project is constructed and is in operation. 

 

26 A mine adit is a horizontal shaft extending into the subsurface.

27 See National Parks v. Kaiser Eagle Mountain, available at 

http://www.ca9.uscourts.gov/datastore/opinions/2009/11/10/05-56814.pdf.
48

3.3.2 Water Resources

3.3.2.1 Affected Environment

Water Quantity

The proposed project is located in the Eagle Mountains and Chuckwalla Valley of 

the arid Sonoran desert of southeastern California. On average, about 3 to 5 inches of 

rainfall occurs annually. August receives the most rainfall, although rainfall is also more 

predominate, but generally lighter, in the winter months of December, January, and 

February. The region’s very low precipitation, high evaporation, and permeable soils 

preclude the existence of perennial streams. In rare large rainfall events, substantial 

runoff occurs in washes, causing flash floods with a great potential for erosion.

Eagle Creek, which is normally a dry wash, flows out of the Eagle Mountains 

generally along the southern side of the proposed central project area. USGS operated a 

gage on Eagle Creek (Gage No. 10253600, Eagle Creek at Eagle Mountain) near the 

project area from October 1, 1960, to September 30, 1966. Records from this gage,

which had a drainage area of 7.71 square miles, are summarized in table 2. Flows were 

recorded at this gage on only 4 days when the gage was operational. The flows at this 

gage, which are representative of streams in the area, indicate a very flashy flow regime 

as shown by the large difference between the daily mean and the peak flow data. The 

total volumes of the 1961 and 1965 flood events were about 40 and 15 acre-feet,

respectively.

Table 2. Summary of flow data (cfs) from USGS Gage No. 10253600 (Source: 

USGS, 2010, as modified by staff).

Water Year Date of Flow Daily Mean Peak Flow

1961 August 23 20 380

1962 None -- --

1963 September 17 0.2 3

1964 November 1 0 2

1965 August 16 7.5 180

1966 None -- --

Under current highly disturbed conditions from the historical mining activities 

near the eastern mining pit, the majority of the flow in Eagle Creek enters the eastern 

mining pit where it accumulates and generally evaporates quickly. Eagle Crest estimates

the total drainage area of Eagle Creek at 11.89 square miles. However, under current 

conditions, about 1.74 square miles currently flow into the central mining pit and about 

2.85 square miles flow directly to the eastern mining pit and water is retained in both 
49

mining pits. The current drainage area of Eagle Creek at the point it flows into the 

eastern mining pit is about 7.3 square miles. Before mining activities altered the drainage 

pattern, Eagle Creek (with a drainage area of 11.89 square miles) discharged into the 

Chuckwalla Valley, with an abrupt change in gradient where the wash emerged from the 

Eagle Mountains. As the flow emerged at high velocities from the channeled wash area,

the sediment bedload was deposited to braided alluvial fan where sheet flow and lower 

velocities occurred. The CRA is buried within the alluvial fan deposits of Eagle Creek to 

the east of the eastern mining pit.

Chuckwalla Valley is a closed watershed with a total drainage area of about 663 

square miles, with two central sinks that form the Palen Dry Lake and Ford Dry Lake. 

During substantial rainfall events, runoff from areas near the project area reaches the 

Palen Dry Lake bed, forming a surface water feature that may persist for several weeks 

until lost by percolation and evaporation.

There are a few intermittent springs in the mountains within the northwest part of 

the Chuckwalla Valley. All of these springs appear to be hydrologically disconnected 

from the Chuckwalla groundwater basin since the springs are located in the mountains 

above the valley floors. 

Water Quality

Water quality in the area is influenced by the site geology, including steep 

mountainous terrain; unconsolidated deposits in the valleys; the disturbed mine area; and 

sparse vegetation. The combined effect of these conditions and the rare, but normally 

intense, short-duration rain events lead to high sediment loads during runoff events. 

Surface water quality has not been monitored during the rare runoff events and access 

limitations have not permitted sampling of the water that sometimes collects at the 

bottom of the existing mining pits. Eagle Crest states that there likely to be a still-active 

wastewater treatment plant with a treatment pond on the southeastern side of the largely 

abandoned town of Eagle Mountain. In the Chuckwalla Valley, wastewater disposal 

occurs primarily though residential septic systems and treatment ponds that allow 

infiltration to groundwater.

Water Quality Standards

Water quality protection in the proposed project area is within the jurisdiction of 

the California Regional Water Quality Control Board, Region 7 (Regional Water Board). 

The Regional Water Board carries out these responsibilities through the Water Quality 

Control Plan for the Colorado River Basin within California (Basin Plan). This Basin 

Plan provides guidelines and regulations for activities that fall within Regional Water 

Board jurisdiction. 

Water quality objectives are based on the water body’s beneficial use 

classification (table 3). Under existing conditions, surface water rarely occurs and there 

is no current use designation. The State Water Board would assign use designations for 
50

the proposed water within the reservoirs and would approve the water quality 

certification for the project. Staff anticipates that the proposed project would receive the 

Hydropower and Industrial use designations from the State Water Board. 

Table 3. Relevant beneficial use definitions for the Colorado River Basin (Source: 

Regional Water Board and State Water Board, 2006).

Category Definition

Hydropower generation Uses of water for hydropower generation

Industrial service supply Uses of water for industrial activities that do not 

depend primarily on water quality including, but not 

limited to, mining, cooling water supply, hydraulic 

conveyance, gravel washing, fire protection, and oil 

well pressurization. 

Several water quality objectives applied to all water bodies within the Regional 

Water Board’s jurisdiction for the Colorado River Basin are relevant to the proposed 

isolated, groundwater fed pumped storage project (table 4). Parameters and the important 

water quality objectives of the proposed project are shown in the table 4.

Table 4. Applicable water quality objectives for waters potentially affected by the 

proposed project (Source: Regional Water Board and State Water Board, 

2006).

Parameter Objective

Aesthetic qualities Free from substances attributable to wastewater of domestic 

or industrial origin or other discharges which adversely affect 

beneficial uses not limited to: settling to form objectionable 

deposits, floating as debris, scum, grease, oil, wax, or other 

matter that may cause nuisances, and producing objectionable 

color, odor, taste, or turbidity.

Toxicity Free of toxic substances in concentrations which are toxic to, 

or which produce detrimental physiological responses in 

human, plant, animal, or indigenous aquatic life. 

Acidity pH 6.0-9.0
51

Parameter Objective

Suspended solids 

and settleable solids

Discharges of wastes or wastewater shall not contain 

suspended solids or settleable solids which increase the 

turbidity of receiving waters, unless it can be demonstrated to 

the satisfaction of the Regional Water Board that alteration in 

turbidity does not adversely affect beneficial uses. 

Total dissolved 

solids

Discharges of wastes or wastewater shall not increase the 

total dissolved solids content of receiving waters, unless it 

can be demonstrated to the satisfaction of the Regional Water 

Board that such an increase in total dissolved solids does not 

adversely affect beneficial uses of receiving waters.

Sediment The suspended sediment load and suspended sediment 

discharge rate to surface waters shall not be altered in such a 

manner as to cause nuisance or adversely affect beneficial 

uses. 

Turbidity Waters shall be free of changes in turbidity that cause 

nuisance or adversely affect beneficial uses.

Groundwater Quality

Eagle Crest states that groundwater quality in the proposed project area is typical 

for desert areas of southern California. The pH ranges from about 7.4 to 8.5; total 

dissolved solids levels at 425–950 milligrams per liter (mg/L) are generally above the 

California maximum containment level of 500 mg/L (CH2M HILL, 1996); and sulfate 

and chloride are generally both below the maximum containment level of 250 mg/L 

(Kaiser Steel Resources, Inc., 1978). Boron, fluoride, and arsenic are commonly higher 

than recommended concentrations for drinking water. Samples from the wells in the 

Pinto and Chuckwalla groundwater basins had concentrations of boron at 600 and 938

micrograms per liter (μg/L) and concentrations of fluoride of 2.4 and 6.2 mg/L (Kaiser 

Steel Resources, Inc., 1978). While high, these concentrations seem typical for arid 

desert valleys in southern California. Human-induced groundwater pollution is low due 

to the undeveloped nature of the Chuckwalla Valley area, the limited infiltration of 

surface water, and the extreme depth to groundwater. 

Establishment of numerical objectives for groundwater quality involves complex 

considerations since the quality can vary with depth of well screening, existing 

groundwater levels, geology, hydrology, and other factors. In general, the stated 

objective of the Regional Water Board is to maintain the existing groundwater quality of 

all non-degraded groundwater basins. Table 5 provides the general groundwater quality 

objectives from the Basin Plan. 
52

Table 5. Applicable groundwater quality objectives for the Colorado River Basin

(Source: Regional Water Board and State Water Board, 2006).

Parameter Objective

Taste and odor Groundwaters for use as domestic or municipal supply 

shall not contain taste or odor-producing substances in 

concentrations that adversely affect beneficial uses as a 

result of human activity.

Bacteriological 

community

In groundwaters designated for use as domestic or 

municipal supply, the concentration of coliform organisms 

shall not exceed the limits specified in California Code of 

Regulations, Title 22, Chapter 15, Article 3. 

Chemical and 

physical quality

Groundwaters designated for use as domestic or municipal 

supply shall not contain concentrations of chemical 

constituents in excess of the limits specified in California 

Code of Regulations, title 22, chapter 15, article 4, 

section 64435, tables 2, 3, and 4 as a result of human 

activity. 

Brines Discharges of water softener regeneration brines, other 

mineralized wastes, and toxic wastes to disposal facilities 

which ultimately discharge in areas where such wastes can 

percolate to groundwaters usable for domestic and 

municipal purposes are prohibited.

Groundwater Resources

General Hydrogeologic Setting

The project area is located in and adjacent to the Eagle Mountains on a bedrock 

ridge along the northwestern margins of the Chuckwalla Watershed (see figure 5). The 

central portions of the watershed contain the Palen and Chuckwalla valleys, with thick 

accumulations of alluvial sediments that comprise the Chuckwalla groundwater basin 

(see figure 5). Most domestic and agricultural areas are located in the western portions of 

the basin near Desert Center, about 10 miles south of the project site. This area has been 

historically referred to as the Upper Chuckwalla Valley, while the Lower Chuckwalla 

Valley includes the valley area situated farther east of Desert Center and along 

Interstate 10.

Of the five groundwater basins surround the Chuckwalla groundwater basin (see 

figure 5), only the Cadiz groundwater basin is hydrologically disconnected from the 

Chuckwalla groundwater basin, because the Cadiz basin is enclosed by surrounding 

mountains. 

The Chuckwalla groundwater basin receives both surface and subsurface inflow 

from the Orocopia groundwater basin to the west and from the Pinto groundwater basin 
53

to the north. The groundwater entering the Chuckwalla groundwater basin from the Pinto 

groundwater basin passes through a gap in the bedrock about 6 miles north of the project 

area. A portion of the Pinto groundwater basin is within the JTNP, which is about 2 

miles from the project area. The Chuckwalla groundwater basin drains east into the Palo 

Verde Mesa and Palo Verde groundwater basins. The Colorado River forms the eastern 

edge of the Palo Verde Valley groundwater basin. A few intermittent springs28

Traversing these basins and surrounding mountains is the CRA, which carries 

water west to highly populated areas of southern California (see figure 5).

exist in 

the area of the northwest Chuckwalla Valley (see figure 5). None of the springs are 

documented as permanent, year-round springs (SCS Engineers, 1990), and all are located 

in the mountains and not in the valley.

Wells

There are more than 60 known wells in the Chuckwalla groundwater basin (Eagle 

Crest, 1994; CH2M HILL, 1996) (figure 7). Other agricultural or domestic wells may be 

present, but their locations are not known due to poor record-keeping, and some older 

wells dating back to the early 1900s may have been destroyed or abandoned. The depth 

of these existing wells range up to 2,000 feet and have pumping capacities up to 3,900 

gallons per minute (gpm), with average pumping rates of 1,800 gpm. In the Desert 

Center area, groundwater wells range up to 900 feet deep; two of these wells are capable 

of producing 2,300 gpm each. In the JTNP, the Park Service owns one well in the Pinto 

groundwater basin (Pinto Well No. 2), and Kaiser owns two additional wells near the 

Park Service well in the southeastern portion of the Pinto groundwater basin. There are 

also a few existing wells in the footprint of the proposed project near the eastern mining 

pit.

Water-bearing Formations

Water-bearing geologic units in the Upper Chuckwalla groundwater basin include 

geologically young (<1.8 Ma) alluvium and continental deposits, which together has a 

maximum thickness of 1,200 and 2,000 feet in the central and eastern portions of the 

basin, respectively (see figure 6). However, California DWR (2003, as cited in Eagle 

Crest, 2009a) considers there to be only 1,200 feet of permeable sediments in the basin. 

These units are primarily composed of semi-consolidated coarse sand and gravel, clay, 

and some interbedded basalts.

 

28 A spring occurs where groundwater flows naturally from the subsurface onto the 

land surface due to the nature and relationship of rocks, the position of the water table, 

and the topography (Neuendorf et al., 2005).
54

Figure 7. Existing and proposed wells for groundwater monitoring (Source: Eagle Crest, 2009a).
55

Well log information was used by Eagle Crest to develop geologic profiles (i.e., 

subsurface cross sections) of the Chuckwalla groundwater basin to show the types of 

sediments and their distribution. The profiles, in addition to geophysical surveys in the 

Upper Chuckwalla groundwater basin, suggest that the bedrock surface beneath the 

alluvial sediments forms a large bowl, where the southern edge of this bowl aligns with a 

narrow east-west trending bedrock ridge. The northern edge of the bowl is composed of 

a similar bedrock feature at the union of the Chuckwalla and Pinto basins. 

The profiles show that coarse-grained sediments are continuous throughout the 

Chuckwalla groundwater basin, and because these sediment layers appear to be 

hydraulically connected, there is only one aquifer in most of the valley. This aquifer 

appears to be unconfined29 based on the geology and measured groundwater levels. This 

aquifer may be semi-confined to confined30

Hydraulic Characteristics

in the central portion of the valley near 

Desert Center where layers of clays have accumulated.

Limited information is available about the detailed hydraulic characteristics of the 

sediments in the Chuckwalla groundwater basin. The key parameters of interest when 

evaluating an aquifer’s ability to store and transmit water are provided and defined 

below:

• Hydraulic conductivity—The ability of the pore spaces or fractures in rock 

sediment to transmit water; typical values for well-sorted sand and gravel are 

from 3 to 180 feet per day.

• Transmissivity—The hydraulic conductivity multiplied by the thickness of the 

aquifer capable of storing water.

• Porosity—The measure of void space between the sediment particles.

• Storativity—Or the storage coefficient, the volume of water an aquifer releases 

from or takes into storage per unit surface area or the aquifer per unit change in 

head. Storativity is equal to the specific yield in unconfined aquifers.

• Specific yield—The percentage of the volume of water a substrate will yield by 

gravity drainage to the volume of the substrate.

 

29 An unconfined aquifer contains continuous layers of permeable materials 

extending from the land surface to the base of the aquifer; also referred to as a water-table 

aquifer.

30 A semi-confined or confined aquifer is overlain by a confining layer, and 

therefore, does not have direct hydraulic connectivity with the land surface or the 

surficial aquifer. The impermeable layer is often composed of impermeable or semiimpermeable clays.
56

Hydraulic conductivity measurements of the Chuckwalla groundwater basin were 

obtained from historical records of aquifer tests for wells in the Desert Center area, the 

upper portions of the basin (east of the project site), near the project area, and in the 

Lower Chuckwalla groundwater basin. The measurements reveal that hydraulic 

conductivities in the upper portions of the basin (36 to 94 feet/day) are about half of those 

measured near Desert Center (111 to 139 feet/day). The bedrock portion of the project 

area near the proposed reservoirs has a much lower hydraulic conductivity because the 

bedrock is essentially impermeable, limiting groundwater movement to occur within 

faults, joints, and fractures. California DWR estimated the average specific yield of the 

Chuckwalla groundwater basin to be 0.10 for the upper 220 feet of saturated sediments 

(California DWR, 1979, as cited in Eagle Crest, 2009a). 

Groundwater Levels 

Eagle Crest developed a partial trend in groundwater levels over the past 50 years 

by combining records from multiple wells in the Chuckwalla groundwater basin. These 

data represent historical water table elevations, extraction levels, and groundwater flow 

direction in the basin. Groundwater levels in the Desert Center area were relatively 

stable until 1981. Between 1981 and 1986, thousands of acres were irrigated for the first 

time to support short-lived agricultural activities that resulted in groundwater level 

declines of about 130 feet. Groundwater levels between 1986 and 2002 have recovered 

by over 100 feet, which is due in part to a large decrease in agricultural pumping. In 

addition, this recovery could be from increased groundwater inflows (from the steep 

gradients caused by or enhanced by the groundwater extraction) from the adjacent 

groundwater basins that contribute inflow. In 2007, groundwater levels were about 17 

feet lower than the groundwater level in 1980.

Current trends in groundwater levels in the eastern portion of the Chuckwalla 

groundwater basin near the outflow to the Palo Verde Mesa groundwater basin are 

conflicting—one well shows a trend similar to the wells near Desert Center while another 

well shows the groundwater level recovering during the overdraft period of the early 

1980s. This apparent conflict in groundwater trends may reflect differences in local use 

and the fact that the groundwater levels in the eastern portion of the groundwater basin 

were rising and were not affected by pumping near Desert Center. Farther east in the 

Palo Verde Mesa groundwater basin, water levels showed little to no effects of pumping 

within the Chuckwalla groundwater basin.

In the Pinto groundwater basin, water levels remained stable until about 1960 

when pumping by Kaiser in the Pinto and Upper Chuckwalla valleys lowered water 

levels by about 15 feet between 1960 and 1981. Thereafter, groundwater levels 

recovered, potentially due to Kaiser’s greatly reduced pumping, even though groundwater 

levels near Desert Center declined in the early 1980s. Recent (2007) measurements show 

that levels have continued to recover and are about 7 feet below the static water level 

measured in 1960, possibly due to withdrawals near Desert Center. These different 
57

groundwater level trends suggest that pumping in the Desert Center area does not 

substantially affect groundwater levels in the Pinto groundwater basin.

Groundwater Flow Direction

Based on 1974 data (California DWR, 1979, as cited in Eagle Crest, 2009a), 

groundwater movement in the Chuckwalla groundwater basin is directed from the north 

and west toward the gap between the Mule and the McCoy mountains at the southeastern 

end of the basin and into the Palo Verde Mesa groundwater basin (see figure 5). More 

recent data near the project site reveal that groundwater movement is both north and 

south from the Eagle Mountains toward Eagle Creek Canyon and then to the east until it 

reaches the basin aquifer, where it is then directed toward the southeast (CH2M HILL, 

1996).

Groundwater Storage and Outflow

The total storage capacity of the Chuckwalla groundwater basin was estimated to 

be between 9.1 million acre-feet and 15 million acre-feet (California DWR, 1979, as cited 

in Eagle Crest, 2009a). The estimated storage for just the northwestern portion of the 

Upper Chuckwalla near the project site is about 1 million acre-feet. This estimate is 

probably very conservative because only 100 feet of saturated sediments were considered 

in the calculation, and there are several hundred feet of saturated sediments remaining. 

Using geologic profiles to assess the saturated thickness and assuming a storage 

coefficient of 0.10, the storage capacity of the entire basin in only the coarse-grained 

sediment portion of the aquifer is estimated to be about 10 million acre-feet, similar to 

California DWR’s 1979 estimate. This is probably another conservative estimate because 

it does not include water in the clay deposits nor does it account for additional water that 

may be present in the confined or partially confined areas of the central portion of 

Chuckwalla groundwater basin. Outflow occurs only as groundwater movement, because 

no surface waters leave the basin. The groundwater basin discharge of the Chuckwalla 

groundwater basin to the Palo Verde Mesa groundwater basin is estimated to be about 

400 acre-feet per year. 

Groundwater Pumping

The amount of groundwater pumped from the Chuckwalla groundwater basin has 

been estimated from recorded data filed with the State Water Board and by the acres and 

types of crops grown multiplied by the evapotranspiration rates of the plants. The 

recorded pumping over the years has been erratic and may be incomplete; estimates 

based on agricultural land usage, or water duties (evaporation plus applied water losses), 

were made between 1986 and 2007. The highest pumping occurred in 1986, at about 

20,778 acre-feet per year, but has decreased substantially since the production of jojoba 

and asparagus ended shortly thereafter. Only about 25 percent of land once devoted to 

agriculture continues to be farmed. More recent endeavors in palm farming have slightly 
58

increased groundwater use in the area from 1,758 acre-feet per year in 2005 to about 

1,800 acre-feet per year in 2007.

Other pumping in the basin occurs for domestic and industrial use. Domestic use 

in the area is estimated at 50 acre-feet per year in Desert Center and 1,200 acre-feet per 

year at the Lake Tamarisk development. Southern California Gas Company uses wells to 

supply about 1 acre-foot per year to its natural gas pumping plant. Farther east in the 

basin are the Chuckwalla Valley and Ironwood State prisons that were opened in 1988 

and 1994, respectively, and are located directly adjacent to each other about 30 miles east 

of Desert Center. The two prisons pumped 2,100 acre-feet per year of groundwater in 

2007 and recharged about 800 acre-feet per year of treated wastewater. However, 

populations at the prisons are projected to be reduced by about 35 percent by 2011 to 

alleviate overcrowding, which would reduce their pumping to about 1,500 acre-feet per 

year.

Groundwater Recharge Sources

The majority of groundwater contained within the Chuckwalla groundwater basin 

is of ancient origin that likely derived from precipitation that was trapped with sediments 

as they deposited upon the valley floor over the past million years (Eagle Crest, 2009d). 

Therefore, the oldest water is typically found at the bottom of the aquifer and the 

youngest water is found closer to the ground surface.

The Chuckwalla groundwater basin is recharged by percolation of runoff from the 

surrounding mountains and from precipitation to the valley floor. Average annual 

precipitation in the basin is about 3 to 5 inches (California DWR, 2003, not seen as cited 

in Eagle Crest, 2009a). There are few measurements to quantify the amount of recharge 

from rain and some studies estimated that only 5 to 10 percent of the rain falling on the 

watershed contributes to the groundwater. The average recharge to the aquifer was 

estimated to be about 5,540 to 5,600 acre-feet per year based on an assumed 10 percent 

infiltration rate.

The Upper Chuckwalla groundwater basin is also recharged by groundwater 

inflow from the north by the Pinto groundwater basin. Inflow from the Pinto 

groundwater basin occurs as outflow through an alluvium-filled gap at the east end of the 

Pinto basin. The perennial yield of the Pinto groundwater basin is estimated at 2,500 

acre-feet per year. Recent estimates using geophysical studies to define the area where 

groundwater leaves the Pinto basin suggest the inflow may be as much as 3,200 acre-feet 

per year.

Groundwater inflow to the Chuckwalla basin from the Orocopia basin is estimated 

to be 1,700 acre-feet per year. Because there are no groundwater withdrawals in this 

basin, this is considered to be all recharge to the Chuckwalla groundwater basin. 

Although not distinguished by groundwater basin, subsequent estimates of recharge from 

upgradient groundwater basins (i.e., Pinto and Orocopia) are about 6,700 acre-feet per 

year (CH2M HILL, 1996). 
59

Perennial Yield

The majority of the groundwater is considered to be of “ancient” origin, estimated 

to have been recharged in the basin between about 2,700 and 32,300 years ago based on 

studies recently conducted in the nearby Joshua Tree aquifer (Nishikawa et al., 2004). 

The current perennial yield, or natural recharge, of the Chuckwalla groundwater basin has 

been estimated as between about 8,900 and 20,000 acre-feet per year. Eagle Crest, at the 

request of the Park Service, which proposes to use closer to 10,600 acre-feet per year in 

its comment letters dated August 11, 2009 and March 10, 2010, refined its perennial yield 

estimate to 12,70031

Fishery Resources 

acre-feet per year (mean from a range of 7,600 and 17,700 acre-feet 

per year) based on the percentage of precipitation falling on the mountainous areas of the 

basin. In its letter filed April 23, 2010, Eagle Crest also states that its estimate compares 

well against a re-calculation of the basin’s perennial yield using a recent USGS method 

that was developed for the nearby Joshua Tree aquifer (Nishikawa et al., 2004).

No perennial streams are present in the project area. Intermittent surface water 

sources in the central project area and vicinity are Eagle Creek (a normally dry wash 

south of the central project area), other smaller unnamed washes, and temporary pools at 

the bottom of mine pits from stormwater runoff. Ephemeral springs within the vicinity of 

the central project area are Buzzard Spring, an unnamed spring near Buzzard Spring, and 

 

31 In its comments (filed October 13, 2010) about the State Water Board draft EIR, 

the Park Service states that a total recharge estimate of between 3,300 and 6,000 acre-feet 

per year should be used for the Chuckwalla groundwater basin. The Park Service states 

that this value is based on results and methods presented in the USGS report (Nishiwawa 

et al., 2004) about recharge rates in the Joshua Tree area—located about 50 miles west of 

the Chuckwalla groundwater basin. The Park Service contends these recharge rates are 

more applicable than methods used by Eagle Crest, i.e., information from studies in the 

Fenner groundwater basin, located 40 miles north of the Chuckwalla groundwater basin, 

immediately north of the Cadiz valley. In another recent comment by the Park Service 

dated July 8, 2010 about the proposed nearby Genesis Solar draft staff assessment and 

EIS (SA/DEIS; a document prepared cooperatively by the Interior, BLM, and the 

California Energy Commission for NEPA and CEQA compliance), the Park Service 

recommended using a total annual recharge value of 10,400 acre-feet per year for the 

Chuckwalla groundwater basin. While the annual recharge to the Chuckwalla 

groundwater basin varies annually and can only be estimated, the 10,600 to 12,700 acrefeet per year range is most commonly accepted because it was developed using published 

data and methods developed from other studies conducted within the basin (e.g., Mann, 

1986; Greystone, 1994, both as cited in State Water Board, 2010) or the general region 

(e.g., URS, 1999; Davisson and Rose, 2000; USGS-WRD 2000, all as cited in State 

Water Board, 2010; Nishikawa et al., 2004).
60

Eagle Tank Spring. All of these water sources are temporary and seasonal and are not 

capable of supporting fish.

The CRA lies at the base of the inactive Eagle Mountain mine site. South of the 

central project area is a forebay (part of the aqueduct system) at the Metropolitan Water 

District’s pumping plant. The CRA diverts water from Lake Havasu on the Colorado 

River, and fish species that may be present in the aqueduct system are the same as those 

found in Lake Havasu and the Colorado River. These species consist primarily of 

introduced game species including largemouth bass, striped bass, catfish (whitehead, 

bullhead, flathead, and channel), threadfin shad, green sunfish, black crappie, warmouth, 

and carp. Native species that may be present in the aqueduct are razorback sucker, 

bonytail chub, and desert pupfish. Although the CRA may support game fish, it is not 

legally accessible to the public and Eagle Crest does not plan to use water from the CRA.

3.3.2.2 Environmental Effects

Water Quantity

Effects of Operation on Water Quantity in the Reservoirs 

Construction of the project and operation would result in changes to the amount of 

flow that reaches Eagle Creek during the rare events that runoff occurs in the area. Under 

current conditions, both existing mining pits retain the stormwater runoff that is directed 

to their locations. Under operational conditions, this stormwater would be added to water 

in the reservoirs, creating a possible excess amount of water in the reservoirs, depending 

on operational conditions and the amount of inflow. 

In its letters filed April 27, 2009, responding to Deficiency no. 5 and AIR no. 4, 

Eagle Crest’s summarizes its plans to release excess water from the reservoirs during 

large rainfall events, such as the 100-year event and up to and including the PMF. These 

measures are summarized below: 

• During stormwater inflow to the lower reservoir, operations would be adjusted

or curtailed to account for higher than normal water in storage. The amount of 

available energy storage space in the lower reservoir would be reduced from 

17,700 acre-feet by the volume of runoff entering the lower reservoir in order 

to avoid spills at the upper reservoir due to pumping. The number of hours of 

on-peak generation would be reduced or curtailed during large (>200 acre-feet) 

runoff events.

• For larger inflow volumes (>200 acre-feet), the lower reservoir spillway would 

be operated to release, by gravity, the extra water in storage. This would be 

accomplished by keeping the water level in the lower reservoir above the 

spillway crest level by about 3 feet (reservoir at elevation 1,098 feet) with 

releases of water from the upper reservoir through the turbines to the lower 

reservoir.
61

• During large inflow events, normal pumped storage operations would be 

interrupted until the excess water is removed from the reservoir system. Eagle 

Crest expects during this type of operation that one of the turbine units would 

be operated at its minimum flow rate (about 1,100 cubic feet per second [cfs]) 

for pre-arranged time periods. The attenuating effects of the reservoir would 

be adequate to maintain outflows close to 460 cfs on a continuous basis, with 

small reservoir storage level fluctuations above the spillway crest.

• These operations would cause the spillway to discharge 460 cfs. With no 

inflow, the reservoir would be drawn down by 1 foot in about 5.2 hours 

(ending with 3 feet of head on the spillway). This drawdown would allow 

minimum generation flow (1,100 cfs) to be released for about 2.7 hours until 

the spillway is discharging 460 cfs once again and then the operating cycle 

would repeat.

Eagle Crest states that this operational procedure after large flood events was 

designed based on a desire to have a relatively small amount of flow reach the alluvial 

fan balanced against the need to restore normal pumped storage operations in a

reasonable amount of time following rare flood events.

Our Analysis

Runoff events in the project area are very rare and normally are of short duration 

with a limited amount of volume, as indicated by the historical gaging on Eagle Creek. 

Eagle Crest estimates that events producing inflows less than 200 acre-feet could be 

stored in the reservoirs to reduce the amount of make-up water needed. The 200 acre-feet 

could be stored in the lower reservoir without overtopping the proposed spillway, so 

normal operations could continue with inflow volumes less than 200 acre-feet. The upper 

reservoir could accommodate about 1,000 acre-feet without overtopping the spillway 

crest. 

Eagle Crest estimated that a 100-year flood event would add about 2,000 acre-feet 

to the reservoir system. It would require about 2 days to remove this water from the two 

reservoirs following Eagle Crest’s proposed operational procedures. With the proposed 

storage capacity of the upper and lower reservoirs, staff’s calculations indicate that 2,000 

acre-feet is about 11 percent of the excess storage that is available in the combined 

reservoirs. A pumped storage facility has the advantage that normally about half of the 

total active storage is available in one or a combination of the reservoirs at any time. 

Even though the estimated runoff during the 100 year event is only 2,000 acre feet, it is 

likely that the majority of this runoff would reach the reservoir system within a few 

hours, but would likely be less than the proposed total pumping or generation capacity 

(11,600 cfs) of the project. However, the exact timing would be a function of travel time 

in natural channels and the effects of attenuation by storage in the reservoirs. So it is 

likely that even with minor operational changes and spillways designed for larger events 

than the 100 year event, no major effects on the project area are likely. 
62

Eagle Crest estimated the PMF event would add an estimated 11,520 acre-feet to

the reservoir system and estimated the recurrence interval of this event as about once 

every 10,000 years. In the event of a PMF type event, operational changes would be 

needed for about 12 days to discharge the excess that would accumulate in the reservoirs. 

The analyses discussed here are based on preliminary designs. The project design 

could change prior to construction, which would affect the parameters used in the 

analyses. To ensure that any design changes would not increase the environmental 

effects of releasing excess water from the reservoirs, the design flood determination 

would be included in the Supporting Design Report, which would be reviewed and 

commented on by the Commission staff prior to start of construction. A likely dam break 

analysis and analysis design of flood conditions would be included in the emergency 

action plan, which would be submitted at least 60 days prior to initial filling of the 

reservoir in accordance with Part 12, Subpart C of the Commission’s regulations. 

Effects of Operation on Water Quantity in Eagle Creek and the Alluvial Fan 

Project construction and operation would result in changes to the amount of flow 

that reaches Eagle Creek and the alluvial fan during the rare flood events. Under current 

conditions, both existing mining pits retain the stormwater runoff, which is directed to 

their locations and limits the amount of flow that reaches Eagle Creek and the alluvial 

fan. Under proposed conditions, some of this stormwater could reach Eagle Creek, 

depending on operational conditions of the project. The addition of this water to Eagle 

Creek could create higher peak flows in Eagle Creek between the upper reservoir and the 

lower reservoir and downstream of the lower reservoir along the proposed overflow 

discharge location. Existing berms and other structures that exist along the lower reaches 

of Eagle Creek appear to have been constructed during the mining operations to direct 

flood water away from the Eagle Mountain town site and other structures.

Eagle Crest’s response to Deficiency no. 6 summarizes its conceptual plans for 

channel modification to contain the PMF within the Eagle Creek channel. Included in 

these conceptual plans are berms and other modifications to direct flood water to the 

lower reservoir and away from other existing or proposed structures during the PMF and 

lesser flood events. However, based on Eagle Crest’s analyses of Eagle Creek, it does 

not currently propose any modifications to contain the PMF within the Eagle Creek 

channel. 

Eagle Crest has also designed the spillway and discharge channel of the lower 

reservoir and proposes an operational plan to limit the release from the lower reservoir to 

460 cfs for a period of 13 days after a PMF event. 

Our Analysis

Eagle Crest estimated that the peak PMF discharge in the Eagle Creek channel is 

17,380 cfs, including 15,320 cfs of unregulated runoff from the main 7.3-square mile 
63

portion of the watershed and 2,050 cfs from spillway operation at the upper reservoir, 

assuming that the upper reservoir is full to its normal pool at the onset of the flood. 

This rate is based on an estimated peak PMF inflow to the upper reservoir of 4,640 

cfs from its 1.7-square mile watershed, which would be attenuated to 2,050 cfs by storage 

above the spillway invert. Table 6 provides the estimated peak PMF flows at two 

locations under existing and proposed conditions. 

Table 6. Peak flow (cfs) during the probable maximum flood (Source: Eagle Crest, 

2009c).

Existing Condition Proposed Condition

Below the upper reservoir 0 2,050

Eagle Creek to lower reservoir 15,320 15,320

Total 15,320 17,370

Because of limited site access, Eagle Crest estimated hydraulic capacity at key 

locations of the Eagle Creek channel using available topographic mapping and aerial 

photos to provide estimated channel slopes and widths and to estimate flow depths and 

velocities at key locations. This analysis then used the two flow rates noted in table 6 for 

existing and proposed conditions in Eagle Creek. Based on the results provided by Eagle 

Crest from this analysis, the existing Eagle Creek channel should be adequate to convey 

PMF flows for existing and proposed conditions due to an increase in flow depth of about 

0.4 foot and a velocity increase of about 0.9 foot per second, or about 5 percent. 

However, staff notes that especially in streams, such as Eagle Creek, substantial 

geomorphological changes are likely during large flood events, which could change the 

location and conveyance capacity of the channel. The flow velocities for Eagle Creek 

calculated by Eagle Crest indicate that during the PMF, velocities would range in the 16 

to 18 feet per second range. Staff’s calculations for smaller flood events indicate a flow 

velocity in Eagle Creek at more than 10 feet per second. Both of these ranges of flow 

velocities are capable of moving a large amount of sediment, gravel, and boulders and 

causing substantial erosion of existing and proposed structures and streambed conditions. 

The average grade of the alluvial fan (which contains the buried CRA) in the 

vicinity of the lower reservoir spillway channel discharge point is about 2 percent. The 

water from the overflow spillway, at a proposed maximum rate of 460 cfs, is proposed to 

be conveyed through a riprap channel then discharged and spread across the alluvial fan 

during and after very large storm events such as the PMF. Calculations by Eagle Crest 

indicate that the flow velocity in the unlined alluvial fan should be about 3 feet per 

second during the PMF. During a PMF type event within the watershed and the 

Chuckwalla Valley, the possible erosion downstream of the lower reservoir as a result of 

a flow of 460 cfs should be insignificant.
64

More detailed analyses would be required during final design of the project. At 

that time, precise topographic mapping would be available and physical reconnaissance 

of the Eagle Creek and the overflow spill path from the lower reservoir could be 

performed. Once this information is collected and the final designs are complete, the 

parameters needed for channel capacity evaluation and design of channel improvements 

and/or armoring could be determined. 

Reservoir Level Monitoring

Operation of the reservoirs would cause water levels to substantially fluctuate on a 

daily basis. During peak electrical demand periods, water would be released from the 

upper reservoir to the lower reservoir, and during low demand periods, water would be 

pumped to the upper reservoir. Fluctuations of the reservoir levels would affect not only 

terrestrial issues but would also create operational and safety issues. Safety measures 

would include ensuring that over-pumping or over-generation does not occur, causing

spillage from the reservoir’s emergency spillways. Safety and compliance associated 

with the water levels of the proposed project would fall under Part 12 of the

Commission’s Division of Dam Safety and Inspections regulations. Eagle Crest did not 

propose a reservoir monitoring program in its license application. 

Our Analysis

Eagle Crest proposes to transfer a maximum of 17,700 acre feet of water between 

the two reservoirs on a daily basis with the proposed hydraulic capacity of 11,600 cfs. 

Under proposed operations, the upper reservoir would fluctuate between a minimum 

water elevation of 2,349 feet and a maximum water level of 2,485 feet. The lower 

reservoir would fluctuate between a minimum level of elevation 925 feet and elevation 

1,092 feet. The average amount of daily fluctuation would probably be less than the total 

variation between the minimum and maximum water levels. The elevation of the 

proposed spillway at the upper reservoir is also at elevation 2,485 and the spillway at the 

lower reservoir is at elevation 1,095 feet, 2 feet above the maximum water surface at the

lower reservoir elevation.

Environmentally, the fluctuation of the reservoirs could have an effect on possible 

acid production from water interaction with the rocks surrounding the proposed 

reservoirs and the potential for water seepage from the reservoirs as discussed later in this 

section. In addition, the fluctuating water levels could affect the potential for invasive 

species occurrence in the reservoir areas, as discussed in section 3.3.3, Terrestrial 

Resources, and the access to water for desert bighorn sheep as discussed in section 3.3.4, 

Threatened and Endangered Species.

Project operations would required a dedicated and redundant system of monitoring 

to ensure that over pumping and over release of water for the proposed project would not 

occur and would need to follow regulations set by the Commission’s Division of Dam 

Safety and Inspections prior to operation of the project. A reservoir monitoring program 
65

to address environmental issues would be less stringent and could include monitoring and 

documentation of reservoir levels at 15 to 30 minute and included in the project operation 

report.

Water Quality

Construction of the proposed project would increase the amount of disturbed soils 

available for mobilization during rain events and could affect sedimentation and turbidity. 

These effects are addressed in section 3.3.1, Geologic and Soil Resources. Operation of 

the proposed project could also result in increased salinity and acid levels in the 

reservoirs as the result of evaporation and the exposure of mining materials to water. 

This could potentially affect multiple water quality parameters within the proposed 

project area, as described in the following section.

Effects of Seepage and Evaporation from the Reservoirs and Brine Ponds on 

Groundwater Quality 

Left untreated, the chemical components of the water lost to evaporation 

(dissolved minerals, nutrients, and other chemicals) would remain in the reservoirs, 

increasing dissolved mineral concentrations and decreasing water quality. Eagle Crest 

estimates evaporation losses from the reservoirs at 1,760 acre-feet per year. In addition, 

an estimated volume of up to 1,600 acre-feet of water per year would seep from the 

project reservoirs. 

To maintain water quality within the reservoirs, Eagle Crest proposes to use a 

reverse osmosis treatment system that would remove water from the reservoir at a rate of 

2,055 gpm (Measure GQ-1). This system would be designed to remove sufficient total 

dissolved solids to maintain the in-reservoir total dissolved solids at the average 

concentration of the source groundwater. The design of the reverse osmosis treatment 

system would comprise several pretreatment elements, including dissolved air flotation, 

automatic backwash screens, and a microfiltration system, to optimize treatment by the 

reverse osmosis process. Treated water would be returned to the lower reservoir, and the 

concentrated brine from the reverse osmosis process would be directed to the proposed 

evaporation ponds. These ponds would cover about 56 acres and Eagle Crest estimates 

the total brine production at about 270 acre feet per year. The proposed design for the 

evaporation ponds divides the total required pond area into six ponds of varying levels of 

salinity and five solidifying ponds. Each evaporation pond would be about 8.3 acres in 

size and each solidifying pond would be about 1.4 acres in size. The discharge from the 

reverse osmosis system would flow into one pond and be directed to another pond while 

the solution remaining in the first pond evaporates. Proposed pond design includes clay 

or membrane liners along the bottom and the 8-foot-high berms to protect against 

seepage. Eagle Crest proposes to use monitoring wells to help identify a potential liner 

failure (Measure GQ-2).
66

Our Analysis

Without treatment, the water quality in the reservoirs would diminish because

salinity levels would increase due to evaporative losses from the reservoirs. Reverse 

osmosis systems are capable of desalinating water and producing mineral-free water. 

Eagle Crest’s current proposed design would operate at a 90 percent recovery rate, the 

final reverse osmosis treatment step would produce 1,560 gpm of permeate to be returned 

to the lower reservoir, and 174 gpm of brine would be sent to the evaporation ponds.

Eagle Mountain’s proposal to treat a sufficient volume of reservoir water to 

maintain water quality comparable to the source water should prevent degradation of

water quality from salinity increases that would occur otherwise. To achieve this goal, 

Eagle Crest’s proposal includes treating 3,315 acre-feet of reservoir water each year. 

According to Eagle Crest, this procedure would result in the production of about 2,500 

tons of dry salt in the brine ponds each year. It is anticipated that the time required to

concentrate dissolved solids in the reservoir to levels considered a degradation of water 

quality would take longer than any reasonable reverse osmosis system downtime scenario 

involving maintenance or repair. Staff also discusses potential effects of salt 

management in section 3.3.5, Recreation, Land Use, and Aesthetics, in the subsection

Land Use. In addition to removing salts from the water, most other contaminants 

(e.g., microbes), nutrients, and minerals would be removed as well. Therefore, 

eutrophication is not expected to occur because the water quality in the reservoirs would 

be maintained. 

The storage of brine in the surface ponds poses some risk to surface and 

groundwater quality. Brine pond leakage could pose a distinct threat to water quality. 

Failure of the pond wall or liner represent possible scenarios related to an accidental 

release of brine to the surrounding environment. 

In the event of a pond wall failure, concentrated brine could wash out of the pond,

resulting in surface flow. This type of a failure would release the brine, with high 

concentrations of salts and other minerals onto the soil, potentially harming vegetation. 

Staff estimates that the brine from a possible pond wall failure would affect a limited area 

and would not reach the CRA, which is buried and about 2.4 miles downgradient from 

the proposed ponds. The concentrated brine would percolate into the soil and eventually

reach the groundwater as a plume after a largely vertical movement through the 

subsurface. However, the infiltration rate would be slow due to the low amount of 

infiltration from other sources, such as rain water. In addition, staff expects that the 

percolation and movement of brine through the soil would be slowed by the effects of 

viscosity, density, and the attachment of brine particles to soil particles. In this area of 

the site, groundwater is about 500 feet below the surface with about 300 feet of alluvial 

deposits over bedrock. 
67

Eagle Crest has not specified the exact type of liner it is proposing, other than 

stating that it would be a clay or membrane liner. With a clay liner and concentrated 

brine, cation exchange32

With proper construction and maintenance performed on the evaporating ponds, 

the risk of such scenarios would be minimized. Because the opportunity to inspect and 

replace the pond liners would occur in association with salt removal (proposed every 10

years), it is anticipated that the ponds would reliably hold the concentrated brine solution 

during this time and that the risk of a wall or liner failure is considered small. Proposed 

monitoring methods for the brine ponds are analyzed under Water Quality Monitoring

below.

might be likely and this interaction could slowly increase the 

permeability of the clay liner. In the event of a pond liner failure, there would probably 

be a somewhat slow, continuous concentrated brine solution leak, which staff expects

would move slowly to the groundwater table. Once the brine plume reaches the bedrock 

or the groundwater table, the plume would begin to move more horizontally 

downgradient where it might be intercepted by a proposed monitoring well. Eagle 

Mountain proposes to install monitoring wells around the brine ponds detect such a 

failure. However, due to the great depth to groundwater and the largely vertical expected 

movement of a possible brine plume, a leak would probably be observed in the 

monitoring well only months or years after the leak began. In addition, once a leak is 

detected in the monitoring wells, a large plume of brine would be moving through the 

unsaturated zone. 

With Eagle Crest’s proposed reverse osmosis system in place, total dissolved 

solids levels in the reservoirs should be nearly the same as the source groundwater. 

Therefore, seepage of reservoir water into the groundwater aquifer would not degrade 

groundwater quality. Additionally, Eagle Crest proposes a series of seepage recovery 

wells to recovery the vast majority of possible seepage water from the reservoirs 

(Measure SR-2). Therefore, water lost by seepage from the reservoirs would not 

contribute to an increase in chemical component concentration in the reservoirs because 

water quality components of the reservoirs would be similar to the groundwater. 

Proposed monitoring methods for the reverse osmosis system and the reservoirs are 

analyzed under Water Quality Monitoring below.

Effects of Project Operations on Acid Production and Water Quality 

The interaction between water stored in the proposed reservoirs and the surrounding 

exposed mine pit material could affect water quality by exposing minerals to surface water 

and oxygen. When the common mineral iron disulfide or pyrite is exposed, it reacts with 

oxygen and water (oxidizes) to form sulfate and acidic conditions. Under these conditions, 

the acidic solution can then interact with the surrounding earthen materials and leach out 

 

32 Cation exchange is the exchange of positively charged ions from the clay with 

the likely negatively charged brine solution. 
68

arsenic, copper, cadmium, silver, zinc, and other heavy metals. Acid rock drainage and 

acid mine drainage are terms that refer to the outflow of this water. 

Quantitative information to determine if acid production would occur during 

project operations does not exist. Eagle Mountain proposes to implement a Phase 1 PreDesign Site Investigation Plan to address this issue prior to final project design and 

construction. Implementation of this plan would involve collecting field samples and 

conducting analyses to determine the site-specific acid production potential and the net 

neutralizing capacity. Once access to the site is granted, Eagle Crest (2009b) states that 

the plan would include the following steps:

1. Obtain samples from each pit from the different the stratigraphic zones. The 

thickness of each unit as exposed in the pit would be measured or estimated 

to determine the percentage contribution of each unit to acid production. 

2. Perform analysis for pyrite, and total sulfur, and sulfate sulfur. 

3. Calculate acid production potential (APP).

5. Determine the neutralization potential (NP).

6. Calculate the net neutralizing potential (NNP): NNP = NP – APP expressed 

as kg calcium carbonate/ton.

Our Analysis

Depending on many site-specific factors, the interaction between proposed project 

water and mine pit materials could result in acid production. Table 7 provides the 

primary, secondary, and tertiary factors that control acid production in mine 

environments (EPA, 1994). Currently, the lack of water is the single biggest factor 

limiting acid production at the project site.

Iron is the most important ore found in the mine pits and the primary minerals of 

this zone are magnetite and pyrite, and the secondary minerals are hematite and geothite 

(Dubois and Brummett, 1968, as cited in Eagle Crest, 1994). Some mineralogy data exist 

for the Eagle Mountain site in historical survey records; however, the quantity of pyrite 

and other sulfide minerals (necessary for acid production) is not well defined. About

170 million tons of iron ore reserves, considered economically recoverable at the time the 

mine was closed, remain at the entire Eagle Mountain mine site (Mine Reclamation 

Corporation, 1997, as cited in Eagle Crest, 2009a). According to Eagle Crest, iron ore 

reserves are magnetite mixed with pyrite, or magnetite and hematite with small amounts 

of pyrite. Eagle Crest (2009b) indicates that the lack of site access precluded it from 

sampling the central and eastern mining pits to calculate the amount of pyrite and acid 

rock drainage potential. Force (2001) reports that the lower ore zone of the central 

mining pit contains 10 to 50 percent platy pyrite, while earlier reports suggest pyrite 

ranges up to 10 percent, averaging 3 to 4 percent (Hadley, 1945). Because materials were 

removed during past mining operations, it is not clear what the composition of the 

remaining material is or the acid producing potential. 
69

Table 7. Description of factors that control acid rock drainage (Source: EPA, 1994).

Factor Type Description

Primary Presence and type of:

• sulfide minerals

Presences of:

• water

• oxygen

• ferric iron

• bacteria to catalyze the oxidation reaction

Secondary Presence and type of:

• minerals that react acid produced, such as calcite and 

dolomite which neutralize the acid, or metals that 

change the character of the resulting effluent

Tertiary • physical characteristics of the material

• physical arrangement of acid producing and acid 

neutralizing materials

• hydrologic regime

The proposed project would exhibit several of the U.S. Environmental Protection 

Agency (EPA) listed conditions that can lead to increased acid production (see table 7). 

Operation of the reservoirs would raise and lower water levels, resulting in a well-mixed 

and oxygenated water column. Mineral composition and the buffering capacity of the 

surrounding materials and the groundwater would dictate the potential for acid rock 

drainage.

The buffering capacity of the surrounding materials and groundwater could offset 

the rate and concentration of acids generated in the reservoirs. The pH of groundwater 

proposed to fill the reservoirs is slightly basic (pH 7.4 to 8.5), which would help to 

neutralize acid production. According to Eagle Crest, historical mineralogy information 

from the site shows no evidence of high concentrations of toxic metals in the site

materials. However, specific measurements of the mineralogy and toxic metal content of 

the material that would come into contact with project waters have not been conducted. 

Without samples to determine the amount of pyrite and other sulfides in the 

inactive mine pits, the extent of acid production is speculative. Implementation of Eagle 

Crest’s proposed Phase 1 Pre-Design Site Investigation Plan would provide the data 

necessary to make quantitative determinations about the proposed project’s effect on this 

aspect of water quality. Existing data suggest that acid generation could be limited due to 

the lack of sulfide minerals on site and buffering capacity of the site material and 

groundwater.
70

Eagle Crest states that the proposed reverse osmosis system would not be designed 

for treating the pH of the water; however, in the event of an observed drop in pH, the 

system could be retrofitted to accommodate buffering agents to treat water returning to 

the lower reservoir. In addition, the permeable membranes in the reverse osmosis system 

would filter any metals, precipitates (solids separated out of solution as a result of a 

chemical reaction), and the microbes involved in the chemical reaction that results in acid 

production. 

Water Quality Monitoring

Any leakage from the reservoirs and brine ponds could adversely affect 

groundwater quality at the Eagle Mountain site and the Chuckwalla groundwater basin,

depending on the water quality, amount of leakage, and infiltration rate. Eagle Crest

proposes a number of surface and groundwater monitoring efforts throughout the 

proposed area to help identify and minimize any adverse effects (Measure GQ-2). It 

specifically identified a number of wells to monitor depth to groundwater and proposes to 

monitor groundwater quality near the proposed reservoirs and brine ponds. Eagle Crest 

proposes to develop a monitoring program using measurements from reservoirs, seepage 

recovery wells, monitoring wells, and brine ponds on a quarterly basis for the first 4 years 

of operation. 

Our Analysis

Monitoring the water quality of the reservoirs and groundwater quality throughout 

the area is necessary to determine the effectiveness of the reverse osmosis system and 

seepage recovery systems. It is also needed to ensure that the brine pond liners are not 

leaking and to provide supporting data related to seepage estimates. Figure 7 shows the 

network of existing and proposed wells that Eagle Crest proposes to use for groundwater 

monitoring. 

Monitoring the water quality of the groundwater seepage would allow for the 

assessment of groundwater quality effects on the aquifer surrounding the project in the 

event of water quality degradation in project waters. Eagle Crest proposes to monitor 

groundwater quality in seepage wells and in monitoring wells upgradient and 

downgradient of the reservoirs. Having these data would allow comparison of 

background water quality with any possible changes due to project operation. Quarterly 

monitoring of the reservoir water quality would ensure that Eagle Crest could determine 

the effectiveness of the reverse osmosis system. This monitoring would also alert Eagle 

Crest to water quality issues before similar water quality levels could be observed at the 

downgradient seepage recovery wells. Sampling could occur at the water supply pipe 

that feeds the reverse osmosis system, prior to the water undergoing any treatment, or the 

water could be sampled directly from the reservoirs. 

It is likely that leakage from the brine ponds would not be measureable until 

months or years after the leakage starts due to the slow movement of the brine through 
71

the estimated 500-foot unsaturated zone above the groundwater table. Under these 

conditions, substantial brine pond leakage could occur before detection by the proposed 

groundwater monitoring wells. Partially horizontal monitoring wells that sample 

transects below the brine ponds and do not extend into the groundwater table could allow 

for early detection of any leakage by monitoring for a change in the moisture vapor 

content. Under typical circumstances, the moisture content in the monitoring well would 

remain low, except as the result of a brine pond leak.

In addition to leakage, an inadvertent sudden release of brine pond water due to a 

breach in a pond wall could pose a threat to water quality. It would be useful for 

evaporation potential to be monitored to ensure that the release of brine into the ponds is 

occurring at the appropriate rates. Also, brine pond water levels could be monitored to 

protect the structural integrity of the pond walls and to prevent brine from overtopping 

the walls. Automatic brine pond-level monitoring devices could be designed to prevent 

the system from releasing brine into the ponds when water levels threaten or exceed the 

pond’s design capacity. 

Water quality protection could be enhanced if Eagle Crest prepared and 

implemented a comprehensive water quality monitoring plan for the reservoirs, seepage 

wells, monitoring wells, and brine ponds. The plan could be developed in consultation 

with the Regional and State Water Boards, and could include location, depth, monitoring 

frequency, methods, reporting practices, and other parameters for the proposed water 

quality monitoring. This plan could also include monitoring of evaporation potential and 

possibly dedicated brine pond monitoring wells. Parameters of interest that could be 

considered for measurement are salinity, total dissolved solids, pH, silica, nitrate as N, 

sulfate, sulfur (total), calcium, magnesium, sodium, neutralization potential, acid-base 

potential, aluminum, arsenic, boron, cadmium, copper, iron, lead, manganese, mercury, 

molybdenum, selenium, and zinc. These parameters are representative of baseline 

parameters of the groundwater in the area. A comprehensive water quality monitoring 

plan could also include steps to be taken in the event of water quality degradation in the 

reservoirs or groundwater. If the project had a detrimental effect on the quality of 

groundwater, the monitoring measures proposed by Eagle Crest, combined with the 

additional measures that could be included in a comprehensive water quality monitoring 

plan, would allow for surface and groundwater quality degradation and effects to be 

identified soon after they developed. Such a comprehensive plan could also identify 

procedures for Eagle Crest to follow to consult with agencies about additional measures 

that could be implemented to address any adverse effects on groundwater quality. 

Groundwater Resources

This section focuses on project-related effects on groundwater quantity, primarily 

as they relate to the potential effects of the project pumping and existing water uses in the 

basin. Project-related effects to groundwater quality from the reservoirs and brine ponds

are presented above under the heading Water Quality. 
72

Effects of Project Operation on Groundwater Availability

Pumping groundwater in excess of annual recharge would potentially result in 

lowering of the water table and reduction of groundwater outflow from the Chuckwalla 

groundwater basin. Eagle Crest developed a groundwater balance for evaluating the 

proposed project’s effect on groundwater supplies. Eagle Crest estimates that over the 

life of the project, initial pumping, in the assumed start year of 2014, would exceed 

recharge by about 4,600 acre-feet per year for the first 4 years, after which recharge 

would be exceeded by about 1,700 acre-feet per year. Total groundwater use by the 

project over a 50-year period is estimated at 96,600 acre-feet. 

Eagle Crest proposes two measures to minimize the effects of project pumping in 

the basin. These include: 

• Groundwater Level Monitoring (Measure WS-1)—establish a groundwater 

level monitoring network, consisting of both existing and new monitoring 

wells, to confirm that project pumping is maintained at levels that are in the 

range of historic pumping and assess changes in groundwater levels throughout 

the basins, beneath the CRA, and in the Pinto groundwater basin, and 

• Neighboring Wells (Measure WS-3)—monitor existing wells on neighboring 

properties to determine, in consultation with the State Water Board, whether 

project pumping during the initial reservoir filling period is adversely affecting 

those wells, and if so, replace or modify those wells and/or compensate the 

well owner for increased pumping costs. This measure was expanded in the 

State Water Board’s EIR (State Water Board, 2010) to additionally state that 

the adjacent, existing wells would be considered adversely affected if and 

when project pumping resulted in lowering water levels in those wells by 5 feet 

or more. This modified measure is herein referred to as Measure MM GW-2.

In its letter filed March 10, 2010, the Park Service recommends that Eagle Crest 

develop and implement a monitoring and mitigation plan to address the potential effects 

on groundwater resources in the upper Chuckwalla Valley and the Pinto groundwater 

basins.

Our Analysis

The Chuckwalla groundwater basin is estimated to contain between 9.1 and 15 

million acre-feet of recoverable water. The effect of groundwater withdrawal by the 

project should not cause the aquifer to approach depletion because project withdrawals 

over 50 years of project operation would exceed recharge by only 96,600 acre-feet or 

about 1 percent of the recoverable water in the Chuckwalla groundwater basin. 

Implementation of Measure WS-1 would effectively monitor groundwater levels in the 

Upper Chuckwalla groundwater basin. The proposed locations of the monitoring wells 

would effectively surround the three proposed pumping wells that would be situated near 

Desert Center. The proposed monitoring wells would also monitor groundwater levels 
73

along the boundaries of the basin to evaluate changes to the adjacent Orocopia Valley, 

Pinto, and Palen Valley groundwater basins. 

Implementation of Measure WS-3 would allow Eagle Crest to use groundwater 

information from active wells on neighboring properties (thereby extending the 

monitoring network in the basin) and assess project-related effects on groundwater levels 

in those other wells. 

If Eagle Crest were to continue implementation of Measure WS-3 beyond the 

initial reservoir filling period, it would allow Eagle Crest to ensure that any longer term 

effects of continuously withdrawing groundwater from the basin during operation of the 

project would be identified. The length of this continuation could be determined through 

consultation with FERC and the State Water Board and would depend on the effects 

observed. The continued implementation of this measure beyond the initial reservoir 

filling period could be managed as part of Measure WS-4, Groundwater Monitoring, 

which is described in more detail below under Regional and Local Groundwater Level 

Effects. The annual reports submitted to both FERC and the State Water Board under 

Measure WS-4 could additionally include monitoring results from the neighboring wells.

Measures WS-3 and MM GW-2 are discussed below under Effects of Project 

Operations on the Regional and Local Groundwater Level and Flow Direction and 

Quality. Both of these measures address the compensation of adjacent well owners who 

experience drawdown in their wells as a direct result of water withdrawals associated 

with the project.

Effects of Reservoir Seepage during Operations

The two proposed reservoirs and other water storage and conveyance features 

have the potential to seep water into the surrounding rock and soil substrates. Jointing 

and fracturing of the underlying bedrock and the general permeability of the rock and 

alluvial deposits could route seeped water from the reservoirs and other unlined structures 

downgradient to the sediments in the adjacent Upper Chuckwalla groundwater basin. 

The eastern side of the lower reservoir would overlie alluvial sediments that have direct 

connectivity with the groundwater basin. 

Eagle Crest proposes to implement several measures to mitigate for seepage into 

the subsurface. These include: 

• Seepage Recovery System from the Lower and Upper Reservoirs (Measures 

SR-1 and SR-2)—construct recovery wells downgradient from each reservoir 

and recover seeped water from the subsurface; 

• Groundwater Monitoring (Measure SR-3)—develop and install a groundwater 

level monitoring network (different monitoring wells from those implemented 

under Measures WS-1 and WS-4) to confirm that seepage recovery well 

pumping is effectively managing groundwater levels in the project area, 

especially beneath the CRA and the proposed landfill; 
74

• Groundwater Level Target (Measure SR-4)—maintain seepage from the upper 

reservoir below the bottom of the bottom liner of the proposed landfill and 

from the lower reservoir to prevent a significant rise in water levels beneath the 

CRA; and 

• Groundwater Monitoring (Measure SR-5)—perform groundwater monitoring 

activities on a quarterly basis for the first 4 years of project pumping, and 

thereafter depending on the findings, and submit annual reports to interested 

parties. 

In addition to the described actions under Measure SR-1, Eagle Crest proposes to 

install one of the seepage recovery wells prior to project construction to perform an 

aquifer test. Eagle Crest proposes to conduct this test during the final engineering design 

to confirm the seepage recovery well pumping capacity and aquifer characteristics. With 

information from the aquifer test, Eagle Crest proposes to re-run the seepage recovery 

groundwater modeling to determine the optimal locations for the remainder of the 

recovery wells. These wells are proposed to capture seepage water from the lower 

reservoir and limit possible groundwater level increases beneath the CRA. Eagle Crest’s 

proposed alternative to Measure SR-1 (i.e., SR-1A) is evaluated below under effects on 

the CRA.

Our Analysis

The proposed reservoirs would occupy two open, former inactive mining pits that 

are underlain by bedrock and alluvium. As such, seepage from filled reservoirs is 

expected. Based on these hydrogeologic conditions in the project area, seepage could 

cause groundwater levels to locally rise, specifically beneath the nearby CRA. The rise 

of groundwater from seepage could potentially pose a subsidence risk from 

hydrocompaction in the project area and vicinity. Up to 1,600 acre-feet of water is 

estimated to potentially seep from the project facilities annually. Groundwater modeling 

results predict that groundwater levels beneath the lower reservoir would rise by about 4 

to 12 feet, while levels in the vicinity of the CRA would increase by 3 to 6 feet. The 

proposed seepage control measures would consist of lining the reservoirs with fine 

tailings, lining the eastern portion (underlain with alluvium) with fine tailings and rollercompacted concrete, and installing a series of groundwater monitoring wells located 

downgradient from each reservoir for seepage monitoring and pump-back recovery. 

Monitoring groundwater levels throughout the groundwater basin area, with emphasis on 

the areas downgradient from the proposed reservoirs and brine disposal pond, would 

allow Eagle Crest to measure direct project effects on local and regional groundwater 

resources. In addition, this information would help to evaluate whether project effects 

would adversely affect groundwater levels beneath the CRA and the proposed landfill 

and provide information to help determine if future mitigation procedures would be 

needed.
75

The construction and mitigation measures proposed for the project are likely to be 

sufficient to control potential reservoir seepage effects on groundwater levels in the 

project area. However, some additional actions could be taken to ensure the protection of 

groundwater supplies. For example, the annual groundwater monitoring reports could be 

submitted to FERC and the State Water Board, along with findings from all groundwater 

monitoring activities conducted for this project (i.e., from Measures WS-1, WS-3, WS-4, 

SR-3, and SR-5). Additionally, data from the seepage recovery wells could be 

summarized and included in the annual groundwater monitoring reports. If Eagle Crest 

developed a groundwater hydrologic budget for the project area that includes 

precipitation, groundwater pumping (from the three proposed supply wells near Desert 

Center), reservoir filling, seepage pumping, possible reservoir surface releases, and 

groundwater monitoring data, this budget could be used quarterly to evaluate 

groundwater conditions in the project area, specifically in those areas close to the 

reservoirs, brine disposal pool, CRA, and landfill. Other relevant data that could be 

included in the groundwater monitoring reports are groundwater levels and flow 

directions. 

Effects of Project Operations on the Regional and Local Groundwater Level and 

Flow Direction and Quality.

The proposed use of groundwater for initially filling the two reservoirs and 

maintaining water volumes during project operation has the potential to affect 

groundwater levels in the Chuckwalla groundwater basin. Depending on the extent of 

change in groundwater levels, changes could also affect the flow duration within the 

Chuckwalla groundwater basin and inflow and outflow from the connected areas of the 

adjacent groundwater basins. 

Eagle Crest proposes several measures to minimize the effects of project 

groundwater pumping on regional and local aquifer levels in the basin. As stated above 

under the topics Effects of Project Operation on Groundwater Availability and Effects of 

Reservoir Seepage during Operations, Eagle Crest proposes to implement Measures WS1, WS-3, SR-3, and SR-5 to monitor groundwater pumping and reservoir seepage rates 

and levels throughout the basin. Additionally, Eagle Crest proposes to implement 

Measures WS-4 and SR-4 to more specifically focus on project effects on local and 

regional groundwater levels and Measure LF-1 to replace four existing wells located 

within the proposed reservoir areas (P-1, MW-4, MW-5, and MW-10; see figure 7). 

These measures would involve monitoring groundwater levels on a quarterly basis for the 

first 4 years of project pumping, and thereafter depending on the findings, and submitting 

annual reports to both FERC and the State Water Board to confirm actual drawdown 

conditions. 

Eagle Crest’s Measure WS-3 involves monitoring existing wells on neighboring 

properties to determine whether project pumping during the initial reservoir filling period 

would adversely affect those wells, and if so, replace or modify those wells and/or 

compensate the well owner for increased pumping costs. This measure was expanded in 
76

the State Water Board’s EIR Measure MM GW-2 to set a threshold of 5 feet or more 

when the adjacent, existing wells would be considered adversely affected.

Our Analysis

The proposed project pumping could cause temporary overdraft of the Chuckwalla 

groundwater basin, causing local and regional groundwater levels to drop and flow 

directions to locally change. Eagle Crest’s groundwater modeling indicates a predicted 

maximum groundwater drawdown of 50 feet near the pumping wells during the initial 4 

years, but the drawdown would level off at about 14 feet thereafter. Drawdown of about 

6 feet would occur at distances of 1 mile from the pumping wells. Along the CRA in the 

Upper Chuckwalla and Orocopia valleys, the modeled drawdown was about 3.6 to 4.3 

feet. Groundwater levels could be lowered by about 3 to 4 feet at the mouth of the Pinto 

groundwater basin, with the amount of drawdown being less than this farther from the 

project area in the interior of the Pinto groundwater basin. Eagle Crest’s modeling also 

estimated that after 50 years of project pumping, inflow from the Pinto groundwater basin 

would decrease by about 30 acre-feet per year compared to pre-project conditions.

Compared to maximum historical drawdown levels (over 100 feet) near Desert 

Center or at the mouth of the Pinto Valley, the maximum drawdown caused by the 

proposed project supply wells would be less than historical conditions, especially in areas 

more than 1 mile from the supply wells. However, the modeled drawdowns could 

potentially exceed maximum historic conditions beneath the CRA by 5 feet in the Upper 

Chuckwalla Valley and by 4 feet in the Orocopia Valley.

Eagle Crest’s proposed Measure WS-3 and its additional components in the State 

Water Board’s Measure MM GW-2 state that in the event that adjacent wells that are 

being monitored under Measure WS-3 experience a drawdown in their respective water 

levels by 5 feet or more, Eagle Crest would compensate the well owners. Based on the 

results of Eagle Crest’s groundwater modeling, as summarized above, numerous wells 

identified in the Chuckwalla groundwater basin would potentially experience drawdown 

in excess of 5 feet, both during the initial reservoir fill period and through project 

operation. The number of existing wells that would be potentially adversely affected by 

project pumping is summarized in table 8. This information was based on a review of 

water well records summarized in Eagle Crest’s final license application and the State 

Water Board’s EIR (State Water Board, 2010). Of the wells listed in table 8, it is not 

known how many are active water production wells intended to provide water for 

domestic, agricultural, and/or industrial purposes. The well records summarized in Eagle 

Crest’s final license application do indicate, however, that the majority of water 

production wells were installed during the brief agricultural boom period of the early 

1980s in the Desert Center area when groundwater levels were substantially lower or 

were operational during that period. These well records also indicate that the majority of 

the monitoring wells were installed after the 1980s.
77

Table 8. Summary of water wells in the Chuckwalla groundwater basin that would 

potentially experience project-induced drawdown in excess of 5 feet

(Source: Eagle Crest, 2009a, as modified by staff).

Project Pumping 

Time Period

Approximate Number of Existing 

Wells that would Potentially 

Experience Drawdown

Total Approximate 

Number of Wells 

that would 

Potentially 

Experience 

>20 feet Drawdown >5 feet

10–20 

feet 5–10 feet

Initial reservoir fill 

period (<4 years)

2 24 36 62

After 50 years of 

project operation

0 2 43 45

Adjacent wells that were active during or have remained active since the 1980s 

would likely not experience adverse production, requiring well modification or 

replacement as a result of the proposed project pumping. Project-induced drawdown, 

either during the initial fill period or during the continued project operation, would not

exceed historical drawdown levels. In the event that groundwater monitoring 

implemented under Measure WS-3 confirms Eagle Crest’s modeling and shows that 

groundwater levels in these wells are being lowered by 5 feet or greater from present 

levels as a result of project pumping, Eagle Crest proposes would be to compensate the 

owner of the affected well(s) for additional pumping costs or provide other mitigation 

measures, such as lowering the well pump or replacing the well. Staff notes that the 

FPA, section 10(c), 16 U.S.C. 803, makes clear that a licensee of a hydropower project 

“shall be liable for all damages occasioned to the property of others by the construction, 

maintenance, or operation of the project works....”

In addition to potential project effects on groundwater levels, the pumpinginduced groundwater depression could locally alter groundwater flow directions. 

Currently, groundwater flow is generally from the west and north and toward the south 

and east (California DWR, 1979, as cited in Eagle Crest, 2009a).

Modeling and detailed analyses have not been performed to investigate the 

possible changes in water chemistry due to the proposed pumping of supply wells for this 

project. However with the projected changes in groundwater levels and flow direction 

and the great depth to groundwater levels and limited natural infiltration, changes in the 

chemical or physical qualities of the groundwater are not expected due to the proposed 

withdrawal rates. In addition, the aquifer is unconfined and changes in the groundwater 

level would not cause a comingling of previously separated aquifers.
78

The local springs in the Eagle Mountains are not hydrologically connected to the 

nearby groundwater basins. As such, project pumping from the Chuckwalla groundwater 

basin would not affect the local, perched groundwater systems that feed these springs.

Implementing Measure WS-4, Groundwater Monitoring, Measure SR-4, 

Groundwater Level Target, and Measure LF-4, Well Replacement, would allow Eagle 

Crest to effectively evaluate groundwater levels and flow directions in the basin to 

confirm that project-induced drawdown and reservoir seepage do not adversely affect 

groundwater conditions in the basin. As stated in greater detail above under Effects of 

Reservoir Seepage during Operations, all groundwater monitoring data would be 

summarized into one annual report for submitted to FERC and the State Water Board.

Effects of Project Operations on Subsidence and Hydrocompaction 

Groundwater pumping from three proposed supply wells in the Desert Center area 

and seepage from the proposed reservoirs have the potential to locally and regionally 

alter groundwater conditions in the project area and nearby groundwater basins. 

Subsidence could potentially occur as a result of project pumping if drawdown levels are 

substantial, typically greater than historical levels, causing the subsurface stratum to 

collapse. Subsidence could also potentially occur as a result of hydrocompaction of 

sediments wetted from reservoir seepage. This process has the potential to occur beneath 

the CRA because portions are located downgradient from the proposed reservoirs. 

Eagle Crest proposes to implement Measure WS-2, Subsidence Monitoring, to 

measure the potential subsidence that could affect operation of the CRA. Two 

extensometers (measuring devices) would be installed along the CRA: one in the Upper 

Chuckwalla Valley (east of the proposed lower reservoir) and the other in the Orocopia 

Valley (southwest of the project area). Eagle Crest developed Measure WS-2 through 

consultation with the Metropolitan Water District, operators of the CRA (Eagle Crest, 

2010b). In the event that data show inelastic subsidence in the project vicinity as a result 

of project pumping, Eagle Crest proposes to eliminate inelastic subsidence by: 

(1) redistributing pumping by constructing additional water supply pumping wells and 

modifying the pumping rates to reduce drawdown; (2) reducing pumping; or (3) by 

artificially increasing recharge in order to better match the net annual groundwater 

withdrawal to the net annual recharge.

Our Analysis

The proposed project would pump groundwater from the Chuckwalla groundwater 

basin to fill and maintain water levels in the proposed reservoirs. Eagle Crest estimates 

through groundwater modeling that drawdown would not exceed historical levels in most 

areas. Along the CRA, project-related withdrawals from the proposed supply well could 

potentially lower groundwater levels by up to an additional 5 feet below their historical 

lows. Because of water seepage from the proposed reservoirs, groundwater levels near 

the CRA could rise by 3 to 6 feet without the proposed seepage recovery wells. 
79

Currently, groundwater levels below the CRA are in excess of 150 feet below ground 

surface. 

There has been no reported evidence of subsidence in the project area (or along the 

CRA) to date; therefore, under proposed conditions, the potential for subsidence caused 

by project water supply pumping is low. 

Project-induced groundwater changes should not lead to subsidence risks in the 

project area or vicinity. However, monitoring of the groundwater conditions and actual 

subsidence levels through the implementation of several measures, namely WS-1, WS-2, 

WS-3, WS-4, SR-1, SR-2, SR-3, SR-4, and SR-5, would help demonstrate that effects are 

as expected or would signal the need for corrective action. Through continued 

consultation with FERC and the State Water Board via the submission of final 

engineering designs and the annual groundwater monitoring reports, it may be 

determined that additional subsidence monitoring actions and/or active mitigation 

measures could be required to mitigate any predicted or measured subsidence risks in the 

project area and vicinity, especially those that could affect the CRA.

Fishery Resources

There are no existing water bodies in the project area capable of supporting fish 

populations. The project reservoirs would be hydraulically disconnected from any 

standing fish populations that could provide a potential source for fish migrating into the 

reservoirs. Eagle Crest proposes to use groundwater sources for the initial filling of, as 

well as subsequent additions to, the reservoirs, and these groundwater sources should not 

introduce fish or other aquatic resources into the reservoirs. It is possible that fish could 

be introduced through other means, including transport by birds; however, these events 

are expected to be extremely rare and unlikely to result in a breeding population. No 

measures have been proposed to ensure that the project does not affect fisheries.

Proposed project features, including the water pipeline, transmission line, and 

access roads, would cross several ephemeral washes. These streams are not federal 

jurisdictional waters under section 404 of the CWA, but do fall under the jurisdiction of 

California DFG. The state of California requires any person, state, or governmental 

agency or public utility to notify California DFG before beginning an activity that would

affect fish and wildlife by (1) substantially diverting, obstructing, or changing the natural 

flow of the bed, bank, or channel of a river, stream, or lake, or (2) using material from or 

depositing material into a streambed. Such actions require a Streambed Alteration 

Agreement (Measure BIO-23).

California DFG can issue a Streambed Alteration Agreement only after the CEQA 

process is complete. Following completion of this process and once Eagle Crest has 

surveyed and staked all project features, Eagle Crest proposes to hold an on-site, preconstruction meeting with California DFG to determine specific locations where 

Streambed Alteration Agreements would be required. To minimize effects of the project 

on ephemeral washes, Eagle Crest proposes to avoid any disturbance within these areas to 
80

the greatest extent possible. In areas where some disturbance is required, the Streambed 

Alteration Agreement would stipulate that all construction in these areas is completed 

while the washes are dry. During water line construction, Eagle Crest proposes to 

recontour wash topography using and implement erosion control measures to prevent 

construction materials from being deposited in the channels. Finally, during 

restoration/revegetation activities along the linear rights-of-way, Eagle Crest proposes to 

recontour and grade disturbed areas to ensure that existing drainage patterns remain 

unaffected. 

Our Analysis

Eagle Crest’s proposal to consult with California DFG following completion of 

the CEQA process and prior to project construction to obtain Streambed Alteration 

Agreements in all areas where the project would affect ephemeral washes is consistent 

with California DFG policies and would adequately protect these areas from potential 

project effects on fisheries and streambeds.

3.3.2.3 Cumulative Effects

Groundwater use in the basin for the proposed project, the proposed landfill, and 

the proposed and potential future solar projects would have the potential to cumulatively 

deplete groundwater in storage by 0.64 to 1.05 percent over the 50 years of the 

withdrawals for the proposed pumped storage project (Eagle Crest, 2010b). This 

conclusion is based on the assumption that the majority of the proposed solar 

developments would use dry cooling technology, which requires substantially less water 

compared with wet cooling technology, due to the need to maintain water efficiency 

standards in the state of California.

The subsidence potential remains low when considering the cumulative effects of 

pumping by the project, the existing groundwater users (e.g., agriculture), the proposed 

landfill, and the proposed and potential future solar projects in the region. 

3.3.3 Terrestrial Resources

3.3.3.1 Affected Environment

Vegetation

The proposed project area lies in the California portion of the western Sonoran 

Desert, commonly called the “Colorado Desert.” This includes the area between the 

Colorado River Basin and the Coast Ranges south of the Little San Bernardino 

Mountains and the Mojave Desert. Rainfall amounts are low, about 3 to 5 inches per 

year. The project area is warmer and slightly wetter than the Mojave Desert and while 

rainfall may occur in the winter months, monsoon rains during the summer account for 

the majority of the rainfall. Winter temperatures average 54 degrees Fahrenheit (°F). 

Ambient, daily summer temperatures are extreme, commonly reaching over 110°F for 
81

long periods with an average of 90°F. This period of hot weather normally extends from 

mid-spring through the fall. As a consequence of these climatic conditions, the 

vegetation is highly drought-adapted, but also contains subtropical elements. In general, 

species richness and density are low due to the low rainfall and high temperatures, 

compared to more moderate environments or other regions of the Sonoran Desert. 

Along the broad alluvial fan traversed by the project’s proposed linear facilities, 

drainage is primarily characterized by scattered, well-defined washes and networks of 

numerous narrow runnels (sheet flow). The former are several-yards-wide, sandy to 

cobbly drainages that carry periodic runoff and are often a half to several yards deep, and 

vegetated along the banks by both shrubs and trees. By contrast, the numerous, shallow 

runnels are typically only a yard or less wide, one-to-few inches deep, and irregularly 

vegetated by locally common shrub species. Where there is greater runoff into these 

runnels, arboreal elements commonly seen in the larger washes are also present, but in a 

stunted form. Sheet flow is evident across alluvial fans where overland flows result from 

a combination of heavy precipitation, low permeability surface conditions, and local 

topography; the substrates there tend to be more gravelly than non-sheeting habitats due 

to the hydrologic transport of materials. 

Two basic native plant communities exist in the proposed project area: Sonoran 

Creosote Bush Scrub and Desert Dry Wash Woodland. Creosote bush and burro bush 

dominate the variations of Sonoran Creosote Bush Scrub that occur in the proposed 

project vicinity. Other common species include brittlebush, white rhatany, several cholla 

species, indigo bush, and ocotillo. Desert Dry Wash Woodland occurs in broad plains of 

contiguous runnels (i.e., sheet flow) with intermittent, well-defined washes. For the 

latter, the wash banks and islands are densely vegetated with aphyllous (no leaves) or 

microphyllous (small leaves) trees, primarily ironwood and blue palo verde, with 

occasional to common smoke tree and catclaw. In the sheeting areas, the tree species are 

dominant elements of the landscape and appear to be homogeneous, forming a desert 

“woodland” (table 9). Other species commonly found in washes, including cheesebush, 

galleta grass, desert lavender, desert peach, chuparosa, and jojoba, grow in the arboreal 

drainages as well as the less distinct runnels.

The central project area (i.e., the area of the proposed reservoirs and power plant) 

is located in the edge of the Eagle Mountains and on the adjacent gently sloping alluvial 

fan. Much of this area has been disturbed by prior iron ore mining activities and the 

related town site. Where vegetation is present, Sonoran Creosote Bush Scrub is the 

dominant vegetation type.

The proposed transmission line would extend south from the central project area 

along the alluvial fan and over one very low mountain near the Metropolitan Water 

District’s pumping plant. The northern 2.8 miles segment of the proposed transmission 

line would lie on Kaiser property, which has not been field surveyed. However, based on 
82

Table 9. Acreage of native habitats and disturbed areas on the Eagle Mountain 

Project (Source: Eagle Crest, 2009a).

Project Element Total Area

Sonoran 

Creosote 

Bush Scrub

Desert Dry 

Wash 

Woodland Disturbed

Central project area 1,101.5 0 0 1,101.5

Transmission line 

(200-foot ROW)

327

(13.5 miles)

167

(6.9 miles)

136

(5.6 miles)

24

(1 mile)

Tower footprint plus 

construction area

(3,600 square feet 

per tower)

4.6–5.7

(54–68 towers)

2.1–3.3

(26–40 

towers)

1.8

(22 towers)

0.4

(4 towers)

Access road

(200-foot ROW)

32.7 17.7 13.6 2.4

Pulling/tensioning 

sites

Currently unknown 

(intended to fall 

within the 

transmission line 

ROW and 

substation site)

Currently 

unknown

Currently 

unknown

Currently 

unknown

Equipment laydown 

sites

Currently unknown Assume 0 Assume 0 Assume 

100%

Proposed 

interconnection 

collector substation

25 25 0 0

Water pipeline

(30-foot ROW)

55.6

(15.3 miles)

20.93

(8.1miles)

0

(0 miles)

34.73

(7.2 miles)

Total project acreage ≥1,219.8 ≥65.7 ≥15.4 ≥1,139

aerial photos and surveys that were completed along the accessible portions of the 

transmission line ROW, about 1 mile of the ROW would be on land disturbed by mining 

and 6.9 miles would be in Sonoran Creosote Bush Scrub. In the south, the proposed 

ROW traverses 5.6 miles of Desert Dry Wash Woodland.

The proposed water pipeline would run southeast on the alluvial fan from the 

central project area, about 4.6 miles along the east edge of the Kaiser Road ROW through 

Sonoran Creosote Bush Scrub vegetation. The proposed water line then would run 

parallel to an existing 161-kV line ROW, initially through about 2 miles of Sonoran 
83

Creosote Bush Scrub vegetation and then through abandoned jojoba fields to State Route

177. A dirt access road is present along this portion of the route between Kaiser Road 

and State Route 177. At State Route 17, the existing ROW splits, with one route running

along State Route 177, mostly through agriculturally developed parcels, but also through 

about 0.3 mile of native Sonoran Creosote Bush Scrub. The other ROW fork runs

southeast along an existing dirt road, primarily through abandoned fields, but also 

through about 1.2 miles of Sonoran Creosote Bush Scrub. The combined acreage of 

native Sonoran Creosote Bush Scrub intersected by the proposed water pipeline ROWs is 

20.9 acres (see table 9).

Noxious and Invasive Species

Several non-native noxious or invasive species are known to occur in the project 

area. These species include three grasses—red brome, cheatgrass, and split grass—and 

two dicots—Tournefort’s mustard and filaree. These species frequently colonize 

disturbed soils associated with agricultural fields and roadsides. The occurrence of 

tamarisk (also called salt cedar) was also reported in the eastern mining pit in the 1990s, 

but it is not visible on recent aerial photography of the area. Tamarisk typically colonizes 

wet areas associated with invaded riparian areas, including springs, rivers, and canals, 

outcompeting native vegetation for available resources (Eagle Crest, 2009b). 

Wildlife

Common wildlife species in the proposed project area are either migratory, and/or 

adapted to desert environments. In the habitats intersecting the proposed project, wildlife 

include ungulates, small and midsized mammals, birds, reptiles, and invertebrates. 

Common species include black-tailed hare, desert kit fox, coyote, bobcat, antelope 

ground squirrel, Merriam’s kangaroo rat, desert woodrat, California leaf-nosed bat, pallid 

bat, western pipistrelle, California myotis, black-throated sparrow, California horned lark, 

ash-throated flycatcher, mourning dove, cactus wren, lesser nighthawk, red-tailed hawk, 

and turkey vulture. Common species specifically associated with drainages include 

desert mule deer, verdin, black-tailed gnatcatcher, and phainopepla. Common reptiles 

include side-blotched lizard, desert iguana, zebra tailed lizard, western whiptail, desert 

horned lizard, gopher snake, and coachwhip. Amphibians are comparatively uncommon 

in the area due to lack of permanent water and unreliable ephemeral water. However, a 

few species of amphibians (red-spotted toad and Pacific treefrog) may breed in ephemeral 

water sources as they become available during summer or winter rains. Common 

invertebrates in the project area include spiders, beetles, true bugs, wasps, and ants.

Operation of the Eagle Mountain mine created specialized habitats associated with 

the mine pits, surrounding mine shafts, and the Eagle Mountain town site. These habitats 

attract additional wildlife species that do not typically occur in undisturbed desert areas, 

or occur at much lower densities outside areas with human activity. Species occupying 

these areas include common raven, house sparrow, house finch, and European starling. 

Several bat species, including California leaf-nosed bat, Townsend’s big-eared bat, and 
84

pallid bat, may now use the mine structures, and are generally intolerant of human 

activity.

Human Subsidized Predators

Increased human settlement in the arid southwestern United States is credited with 

an increased density of some predator species in this ecosystem, including ravens 

(Boarman et al., 2006; Knight et al., 1993) and coyote. Human settlement brings food 

and water subsidies to the desert environment and also adds new features to the 

landscape, like electricity and telephone line poles. These additions make the desert 

more habitable for wildlife species tolerant of human presence. While the increased 

density of these populations is dependent on human subsidies, their presence also creates 

increased predation rates on native wildlife including snakes, lizards, and the threatened

desert tortoise.

Over the last 50 years, human activities have substantially modified the desert 

environment in the vicinity of the proposed project. These modifications, in addition to 

the Eagle Mountain mine, include construction of the Eagle Mountain town site, the 

CRA, and the Metropolitan Water District’s pumping plant, and, to a lesser extent, 

development of campgrounds and other facilities within the JTNP. Landscape features 

associated with these developments include permanent supplies of standing water, 

electric and other utility lines, and potential food subsidies. These conditions are likely to 

subsidize resident populations of ravens and coyote. Both species are known to occur in 

the project area with some regularity; however, Eagle Crest has not conducted surveys for 

these species, and little is known about the current size of these populations other than 

that they are somewhat common.

Sensitive Species

Several species known to occur on or in the vicinity of the proposed project are 

accorded special status because of their recognized rarity or potential vulnerability to 

extinction. Frequently, they have an inherently limited geographic range and/or limited 

habitat. Some are state-listed as threatened or endangered and receive specific protection 

as defined in one or both of the federal ESA or California ESA. Candidate species for 

listing, species designated as “Species of Concern” or “Sensitive” by state or federal 

agencies, and plant species from Lists 1A, 1B, and 2 of the California Native Plant 

Society (CNPS), are protected under CEQA. These species are referred to collectively as 

special-status species. 

While plant species from CNPS Lists 3 and 4 are watchlist species and generally 

not included for special-status consideration, several species from these two lists have 

been included by the NECO Plan as species for which surveys must be completed where 

a project intersects the species ranges, as mapped in the NECO Plan. Therefore, these 

plants are also included in the list of special-status species for the proposed project. 

Similarly, any wildlife species listed by the NECO Plan as special-status, even if not 

otherwise considered special-status, is included. Finally, two species (burro deer and 
85

bighorn sheep) in the project area receive protection and management as game species, 

and burros are afforded protection by the Wild, Free-Roaming Horse and Burro Act. 

Special-status, game, and protected species that may occur or have been 

documented to occur in the project vicinity and have potential to be affected by project 

activities are listed in table 10. This list includes only those species with the potential to 

be found in the area of project components, not all special-status species that are 

regionally known. The list is based on (1) records of the California Natural Diversity 

Data Base for special-status species that are known to occur in the project survey area; 

(2) CNPS records for special-status plants; (3) results from recent, relevant surveys and 

reviews; (4) the NECO Plan; and (5) known habitats in the area (i.e., experience of the 

consulting biologist).

Because of the special habitat value within the project area, high population 

density in the project area, or potential for the project to have concentrated effects on a 

population, several of the species presented in table 10 are discussed in more detail 

below. 

These species include Nelson’s bighorn sheep, burrowing owls, bats, and Couch’s 

spadefoot toad. Two federally listed species are included in the list of special-status 

species with the potential to be in the project area: Coachella Valley milkvetch and 

desert tortoise; see section 3.3.4, Threatened and Endangered Species, for full discussion 

of these species.

Nelson’s Bighorn Sheep

Nelson’s bighorn sheep (also called desert bighorn sheep) are widely distributed from the 

White Mountains in Mono County to the Chocolate Mountains in Imperial County. They 

live most of the year close to the desert floor in canyons and rocky areas with ewe and 

ram populations generally occupying different areas and congregating during mating 

season. In summer, they move to better forage sites and cooler conditions in the 

mountains. Migration routes can occur across valleys between mountain ranges. The 

BLM management plan for this species identifies eight metapopulations, two of which 

are included in the NECO Planning Area: the Southern Mojave and Sonoran 

metapopulations. These metapopulations are further divided into demes, or populations. 

The project is located in the Southern Mojave Metapopulation, adjacent to the Eagle 

Mountain population and near the Coxcomb population. The central project area is 

located in BLM’s Joshua Tree National Park Desert Bighorn Sheep Wildlife Habitat 

Management Area.
86

Table 10. Potential for special-status species (Source: Eagle Crest, 2009a).

Species Federal

Status 

Statea CNPSb Habitat

Likelihood of 

Occurrence on the 

Project Site

Plants 

Abrams’s spurge 

(Chamaesyce 

abramsiana) 

-- -- 2 Sandy sites in Mojavean 

and Sonoran Desert scrubs 

in eastern California; 0–

3,000 feet 

Possible along the 

water pipeline; fall 

flowering 

Arizona spurge 

(Chamaesyce arizonica) 

-- -- 2 Sandy flats in Sonoran 

Desert scrubs, below 

~1,000 feet 

Possible along the 

water pipeline; not 

observed 

Ayenia 

(Ayenia compacta) 

-- -- 2 Sand and gravelly washes 

and canyons in desert 

scrubs, 450–3,600 feet 

Possible around the 

central project area; 

not observed on 2008 

or 2009 surveys

California ditaxis 

(Ditaxis serrata var. 

californica) 

-- -- 3 Sonoran Creosote Bush 

Scrub from 100 to 3,000 

feet 

Observed on both 

linear ROWs 

Coachella Valley 

milkvetch (Astragalus 

lentiginosus var. 

coachellae) 

E BLM 

Sensitive

-- 1B Loose to soft sandy soils, 

often in disturbed sites; 100 

to 2,200 feet 

Highly unlikely—little 

to no habitat on project 

lands and local 

reported populations 

appear to have been 

misidentified; not 

observed 
87

Species Federal

Status 

State

a CNPSb Habitat

Likelihood of 

Occurrence on the 

Project Site

Coue’s cassia (Senna covesii) -- --2 Dry washes and slopes in 

Sonoran Desert scrubs, 

1,000 to 3,500 feet 

Possible, especially on 

the bajadas (compound 

alluvial fans at the 

base of mountains)

and on/near the central 

project area; species 

not observed in 2008, 

2009 or on related 

surveys 

Crucifixion thorn 

(Castela emoryi) 

-- --2 Mojavean and Sonoran 

Desert scrubs; typically 

associated with drainages 

Observed on the water 

pipeline 

Desert sand-parsley 

(Ammoselinum 

giganteum) 

-- --2 Sonoran Desert scrub; 

known from only one site, 

near Hayfield Dry Lake, at 

1200 feet; last seen in 1922 

Highly unlikely; not 

observed 

Desert unicorn plant (Proboscidea 

altheaefolia) 

-- --4 Sandy areas in Sonoran 

Desert scrubs throughout 

southeastern California, 

below 3,300 feet

Observed near the well 

sites; possible 

throughout the valley 

Dwarf germander (Teucrium cubense 

depressum) 

-- --2 Sandy soils, washes, playa 

edges, and fields in 

Sonoran Desert scrubs, 

below 1,300 feet

Possible on the water 

pipeline, in the valley; 

not observed 
88

Species Federal

Status 

Statea CNPSb Habitat

Likelihood of 

Occurrence on the 

Project Site

Flat-seeded spurge 

(Chamaesyce 

platysperma) 

BLM 

Sensitive

-- 1B Sandy flats and dunes in 

Sonoran Desert scrubs; 

below 350 feet; may be 

extirpated in California 

Possible on the water 

pipeline, in the valley; 

not observed 

Foxtail cactus 

(Coryphantha 

alversonii) 

-- -- 4 Primarily rocky substrates 

between 250 and 4,000 

feet; Creosote Bush Scrub 

Observed on both 

linear ROWs 

Glandular ditaxis 

(Ditaxis claryana) 

-- -- 2 Sandy flats in Mojavean 

and Sonoran Creosote Bush 

scrubs in Imperial, San 

Bernardino, and Riverside 

counties; below 1,500 feet 

Possible; not observed 

Harwood’s eriastrum 

(Eriastrum harwoodii) 

-- -- 1B Range restricted to loosesandy areas of eastern 

Riverside and San 

Bernardino counties 

Unlikely due to lack of 

habitat; not observed 

Harwood’s milkvetch 

(Astragalus insularis 

var. harwoodii) 

-- -- 2 Dunes, windblown sands, 

and soft sands below 1200 

feet., east and south of 

Desert Center 

Unlikely, no apparent 

habitat; not observed 

Jackass clover 

(Wislizenia refracta var. 

refracta) 

-- -- 2 Sandy washes, roadsides, 

flats; 1,900 to 2,700 feet 

Unlikely due to lack of 

habitat; not observed 
89

Species Federal

Status 

Statea CNPSb Habitat

Likelihood of 

Occurrence on the 

Project Site

Las animas colubrina 

(Colubrina californica)

-- -- 2 Sonoran Creosote Bush 

Scrub <3,300 feet

Possible on/near the 

central project area; 

not observed in 2008, 

2009 or on related 

surveys

Mesquite neststraw 

(Stylocline sonorensis)

-- -- 1A Open sandy drainages; 

known from one site near 

Hayfield Spring; not seen 

since 1930 and presumed 

extinct in California

Highly unlikely; not 

observed

Orocopia sage 

(Saliva greatae)

BLM 

Sensitive

-- 1B Mojavean and Sonoran 

Desert scrubs; 

gravelly/rocky bajadas, 

mostly near washes; below 

3,000 feet; only known 

west of the Project 

Unlikely but possible 

near/on the central 

project area; reported 

south of the central 

project area in earlier 

surveys but not 

observed in 2008 and 

2009 on the linear 

ROWs

Sand evening primrose

(Camissonia arenaria) 

-- -- 2 Sandy washes, rocky 

slopes, Sonoran desert 

scrubs; below 1,500 (3,500) 

feet

Possible; not observed
90

Species Federal

Status 

Statea CNPSb Habitat

Likelihood of 

Occurrence on the 

Project Site

Slender woolly-heads 

(Nemacaulis denudate 

var. gracilis)

-- -- 2 Dunes in coastal and 

Sonoran Desert scrubs, 

primarily in the Coachella 

Valley; below 1,500 feet 

No habitat; not 

observed

Spearleaf 

(Matelea parvifolia)

-- -- 2 Rocky ledges and slopes, 

1,000 to 6,000 feet, in 

Mojave and Sonoran Desert 

scrubs

Possible habitat 

near/on the central 

project area

Spiny abrojo 

(Condalia globosa var. 

pubescens) 

-- -- 4 Sonoran Creosote Bush 

Scrub; 500 to 3,300 feet

Possible on/near the 

central project area; 

not observed in 2008 

or 2009 surveys

Wiggins’ cholla

(Opuntia wigginsii) 

-- -- 3 Eastern Riverside County, 

under about 3,000 feet

Observed in 2009 

surveys

Invertebrates 

Cheeseweed owlfly 

(Oliarces clara) 

-- -- -- Creosote bush scrub in 

rocky areas 

Possible, especially 

near the central project 

area 

Amphibians 

Couch’s spadefoot 

(Scaphiopus couchii) 

BLM 

Sensitive

SSC -- Various arid communities 

in extreme southeastern 

California and east, south 

Possible on entire 

project area; no 

artificial 

impoundments 
91

Species Federal

Status 

Statea CNPSb Habitat

Likelihood of 

Occurrence on the 

Project Site

Reptiles 

Chuckwalla

(Sauromalus ater) 

-- -- -- Rock outcrops in Mojave 

and Sonoran Desert scrubs 

Observed; also likely 

on/near the central 

project area 

Desert rosy boa 

(Charina trivirgata 

gracia) 

BLM 

Sensitive

-- -- Rocky uplands and 

canyons; often near stream 

courses 

Possible, especially 

near the central project 

area 

Mojave fringe-toed 

lizard 

(Uma scoparia) 

BLM 

Sensitive

SSC -- Restricted to aeolian sandy 

habitats in the Mojave and 

northern Sonoran deserts 

Does not occur on 

project area due to 

lack of habitat 

Desert tortoise 

(Gopherus agassizii) 

T T -- Most desert habitats below 

about 5,000 feet in 

elevation 

Observed on both 

linear ROWs in 2008 

and 2009; likely on 

central project area 

Birds 

American peregrine 

falcon 

(Falco peregrinus 

anatum) 

Delisted

BCC

E Fully 

Protected

-- Dry, open country, 

including arid woodlands; 

nests in cliffs 

Possible forager 

onsite, may nest in 

adjacent mountains; 

not observed 

Bendire’s thrasher 

(Toxostoma bendirei) 

BCC BLM 

Sensitive

SSC ABC:WLBCC Arid to semi-arid brushy 

habitats, usually with 

yuccas, cholla, and trees 

Possible; not observed 
92

Species Federal

Status 

Statea CNPSb Habitat

Likelihood of 

Occurrence on the 

Project Site

Burrowing owl 

(Athene cunicularia)

BCC 

BLM 

Sensitive

SSC -- Open, arid habitats Observed on linear 

ROWs; possible on 

central project area

Crissal thrasher 

(Toxostoma crissale)

BCC SSC -- Dense mesquite and 

willows along desert 

streams and washes 

Unlikely, but possible 

on central project area 

only; no habitat on 

linear ROWs and not 

observed 

Ferruginous hawk 

(Buteo regalis) 

BCC BLM 

Sensitive

WL -- Arid, open country Possible winter 

resident only 

Gila woodpecker 

(Melanerpes 

uropygialis) 

BCC E -- Desert woodland habitats Possible; not observed 

Golden eagle 

(Aquila chrysaetos) 

BCC BLM 

Sensitive

WL Fully 

Protected

-- Open country; nests in 

large trees in open areas or 

cliffs 

Possible forager on 

site, may nest in 

adjacent mountains; 

observed in 2008. 

Loggerhead shrike 

(Lanius ludovicianus) 

BCC SSC -- Arid habitats with perches Common; observed 

Mountain plover

(Charadrius montanus) 

BCC BLM 

Sensitive

SSC ABC:WLBCC Dry upland habitats, plains, 

bare fields 

Unlikely, but possible 

winter visitor to 

agricultural fields in 

the project area 
93

Species Federal

Status 

Statea CNPSb Habitat

Likelihood of 

Occurrence on the 

Project Site

Northern Harrier

(Circus cyaneus) 

-- SSC -- Open habitats; nests in 

shrubby pen land and 

marshes 

Possible; not observed 

Prairie Falcon 

(Falco mexicanus) 

BCC WL -- Dry, open country, 

including arid woodlands; 

nests in cliffs 

Likely forager on site, 

may nest in adjacent 

mountains; not 

observed 

Short-eared owl 

(Asio flammeus) 

-- SSC ABC:WLBCC Open habitats: marshes, 

fields; nests on ground and 

roosts on ground and low 

poles 

Possible winter visitor 

Sonoran yellow warbler 

(Dendroica petechia 

sonorana)

BCC SSC -- Riparian habitats, 

woodlands, orchards

Possible—no habitat 

on linear ROWs and 

habitat on the central 

project area is 

unknown; observed at 

the Eagle Mountain

town site reservoir on 

previous survey; not 

observed during 2008 

and 2009 surveys
94

Species Federal

Status 

Statea CNPSb Habitat

Likelihood of 

Occurrence on the 

Project Site

Vermilion flycatcher 

(Pyrocephalus rubinus)

-- SSC -- Wooded and shrubby sites 

near water, especially with 

willows, mesquite and 

cottonwoods

Highly unlikely except 

as transient—no 

habitat on linear 

ROWs and unlikely to 

be habitat on the 

central project area; 

not observed

Yellow-breasted chat

(Icteria virens)

-- SSC -- Dense streamside thickets, 

willows; brushy hillsides 

and canyons

Highly unlikely except 

as transient—no 

habitat on linear 

ROWs and unlikely to 

be habitat on the 

central project area; 

transients observed in 

area on two previous 

surveys, but not 

observed during 2008 

and 2009 surveys

Mammals

American badger 

(Taxidea taxus)

-- SSC -- Many habitats Observed in 2008 and 

2009

Big free-tailed bat

(Nyctinomops macrotis)

-- SSC WBWG:MH Cliffs and rugged rocky 

habitats in arid, country, 

also riparian woodlands

Possible forager on 

site, especially near 

mountains
95

Species Federal

Status 

Statea CNPSb Habitat

Likelihood of 

Occurrence on the 

Project Site

Burro deer

(Odocoileus hemionus 

eremicus)

-- Game 

species

-- Arboreal and densely 

vegetated drainages

Observed

California leaf-nosed bat 

(Macrotus californicus) 

BLM 

Sensitive

SSC WBWG:H Lowland desert associate, 

found in caves, mines, 

tunnels and old buildings 

Known from Eagle 

Mountain mine so 

possible near or on the 

central project area 

Colorado valley woodrat 

(Neotoma albigula 

venusta) 

-- -- -- Under mesquite in creosote 

bush scrub; southeastern 

California 

Possible 

Nelson’s bighorn sheep 

(Ovis canadensis 

nelsoni) 

BLM 

Sensitive

Game 

species (not 

hunted in 

project area)

-- In mountains and adjacent 

valleys in desert Scrub 

Likely near the central 

project area; detected 

on previous surveys 

Pallid bat 

(Antrozous pallidus) 

BLM 

Sensitive

SSC WBWG:H Several desert habitats Possible, primarily 

near the central project 

area; detected on 

previous surveys 

Pocketed free-tailed bat 

(Nyctinomops 

femorosaccus) 

-- SSC WBWG:M Variety of arid areas in 

pinyon-juniper woodland, 

desert scrubs, palm oases, 

drainages; always near 

rocky areas 

Possible near the 

central project area 
9

6

Species Federal

Status 

Statea CNPSb Habitat

Likelihood of 

Occurrence on the 

Project Site

Spotted Bat 

(Euderma maculatum) 

BLM 

Sensitive

SSC WBWG:H Arid scrub and grasslands, 

to coniferous forests, roosts 

in cliffs, forages along 

streams and in woodlands, 

fields 

Possible near the 

central project area 

Townsend’s big-eared 

bat 

(Corynorhinus 

townsendii) 

BLM 

Sensitive

SSC WBWG:H Broad habitat associations. 

Roosts in caves and 

manmade structures; feeds 

in trees 

Possible, primarily 

near the central project 

area and transmission 

line; detected on 

previous surveys 

Western mastiff bat 

(Eumops perotis 

californicus)

BLM 

Sensitive

SSC WBWG:H Cliffs, trees, tunnels, 

buildings in desert scrub 

Highly likely near/on 

the central project 

area; detected on 

previous surveys a Source: California DFG, 2010, 2009

Applicable Status codes are as follows:

E – Endangered

T – Threatened

Federal C – Candidate species for listing

Federal SC – Species of Special Concern (species whose conservation status may be of concern to FWS, but have no

official status [formerly C2 species])

Federal BCC –FWS Bird of Conservation Concern

State SSC – California DFG Species of Special Concern (species that appear to be vulnerable to extinction)

State Protected – Species that cannot be taken without a permit from California DFG
97

State Fully Protected – Species that cannot be taken without authorization from the Fish and Game Commission

State WL – Watchlist species: species that are not SSC, state-listed, or fully protected (Note: State WL species have not 

been included in this table if they have no other protection designation.)

BLM Sensitive – Species under review, rare, with limited geographic range or habitat associations, or declining. BLM 

policy is to provide the same level of protection as FWS candidate species

b CNPS: List 1A – Plants presumed extinct in California

List 1B – Plants rare and endangered in California and elsewhere

List 2 – Plants rare and endangered in California but more common elsewhere

List 3 – Plants about which CNPS needs more information

List 4 – Plants of limited distribution

(Note: CNPS lists 1 and 2 require CEQA consideration.)

ABC:WLBCC – American Bird Conservancy United States Watchlist of Birds of Conservation Concern

WBWG – Western Bat Working Group (http://wbwg.org):

H – High Priority – These species should be considered the highest priority for funding, planning, and conservation 

actions.

M – Medium Priority – These species warrant closer evaluation, more research, and conservation actions of both the 

species and the threats

L- Low Priority – Most of the existing data support stable populations of the species and that the potential for major 

changes in status is unlikely
98

A telemetry study conducted for the Eagle Mountain landfill project (Divine and 

Douglas, 1996) concluded that two non-interactive ewe populations inhabit the Eagle 

Mountains—one in the northern region of the mountains near the Eagle Mountain mine, 

and the other in the south near Lost Palms Oasis. The ram population generally occupies 

habitat between the two ewe populations. In the fall, the rams segregate themselves and 

migrate to the two ewe populations to breed. The study identified two primary water 

sources for the northern ewe population. Buzzard Spring (located south of the central 

project area) is ephemeral but more reliable than other springs and functions as the 

primary water source, and Eagle Tank (located north of the central project area) is 

ephemeral and dry during the summer months. Migration paths between these water 

sources likely traverse areas adjacent to the central project area.

Surveys conducted in 1995 for the Eagle Mountain landfill observed bighorn scat 

in the central project area. Eagle Crest was not given access the site to conduct current 

surveys, so more information about the Nelson’s bighorn sheep is not available.

Burrowing Owl

The burrowing owl is a BLM sensitive species that occurs in open arid areas. The 

owls generally occur in colonies and build nests in burrows, which are an essential 

component of burrowing owl habitat: both natural and artificial burrows provide 

protection, shelter, and nests for the owls. The burrows are typically constructed by other 

burrowing animals including kit fox, badger, and ground squirrel, but the owls also use 

human-made structures, such as cement culverts; cement, asphalt, or wood debris piles; 

or openings beneath cement or asphalt pavement (California Burrowing Owl Consortium,

1993). 

Eagle Crest conducted phase I habitat surveys (2008) and phase II 

presence/absence surveys (2009). During the phase II survey, biologists located two owl 

burrows—one active and one inactive. One burrow is located on the proposed water 

pipeline ROW, the other is on the proposed transmission line ROW near the southern 

terminus.

Raptors

Several special-status raptor species, including golden eagle and prairie falcon, 

have the potential to occur in the central project area. Golden eagles nest in large trees in 

open cliff areas. Prairie falcon nest on vertical cliff faces. Foraging habitat for both 

species includes open areas where small and mid-sized animals are present. Nesting 

season for golden eagles in the southern part of their range (including the project area) 

can begin as early as late January and last through August (California Wildlife Habitats 

Relationship System, 2010a). Nesting season for the prairie falcon lasts from midFebruary through mid-September with peak season from April to early August 

(California Wildlife Habitats Relationship System, 2010b). 
99

As part of its July 7, 2010, filing (Eagle Crest, 2010a), Eagle Crest provided 

results from golden eagle surveys that took place in March and April 2010. The surveys 

covered mountainous areas within 10 miles of the proposed project. The surveyors 

located a total of 34 golden eagle nest sites distributed among nine active and five 

inactive eagle territories in the project region. Four of the territories identified overlap 

the Eagle Mountain Project area. Surveyors recorded one incubating golden eagle female 

within the nine active territories. Other raptor species encountered during the surveys 

include the American kestrel, barn owl, Cooper’s hawk, great horned owl, long-eared 

owl, northern harrier, osprey, peregrine falcon, prairie falcon, red-tailed hawk and 

Swainson’s hawk. 

Bats

Several BLM sensitive bat species are known to occur in the project area. These 

species include big free-tailed bat, California leaf-nosed bat, pallid bat, pocketed freetailed bat, spotted bat, Townsend’s big-eared bat, and Western mastiff bat. These species 

all prefer roosting areas associated with caves, cliffs, or rocky outcrop habitat, which is 

present in the central project area. Foraging habitat for these species exists in desert 

scrub and desert riparian areas within the project area.

Couch’s Spadefoot Toad

Couch’s spadefoot toads spend their lives in proximity to ephemeral pools in the 

southern California desert. During dry periods the adults live buried under the surface. It 

is possible for the toads to survive these dry conditions for multiple years without 

emerging from their burrows. Following spring and summer rains, the toads emerge to 

feed and breed in the inundated pools. In portions of the project area where access was 

permitted, Eagle Crest conducted surveys for all ephemeral impoundments with the 

potential to support this species. No surveys were conducted in the central project area.

3.3.3.2 Environmental Effects

In its draft EIR for the Eagle Mountain Project, the State Water Board identified 

its recommended substation location and transmission line as the environmentally 

superior interconnection alternative for the project. As depicted on figure 2, the State 

Water Board’s recommended substation would be located immediately south of Interstate 

10 and about 6 miles east of the applicant’s proposed substation. The State Water 

Board’s recommended transmission line would diverge for the applicant’s proposed line 

after crossing the CRA. The State Water Board’s recommended transmission line would 

then parallel the existing 160-kV SCE transmission line for about 10.5 miles going 

southeast to a point just north of the proposed substation, then it would travel south about

2 miles to the substation. In the discussion below, staff compares the effects of this 

recommendation with the applicant’s proposed alternative.

Staff’s discussion of environmental effects presented below is based on 

information provided in the final license application (Eagle Crest, 2009a), additional 
100

information filed by Eagle Crest (Eagle Crest, 2009b, 2009c), Eagle Crest’s response to 

comments on the final license application (Eagle Crest, 2009e) Eagle Crest’s 

supplemental information filed on July 7, 2010 (Eagle Crest, 2010a). Staff’s discussion 

of effects specific to construction and operation of the transmission line is based on the 

results of Eagle Crest’s 2008, 2009, and 2010 surveys and information provided in the 

State Water Board’s draft EIR (State Water Board, 2010).

Effects of Construction on Vegetation

Construction of the project would permanently disturb lands within the footprint 

of project facilities including the Eagle Mountain switchyard, desalination area, 

administration buildings, access roads, transmission line support structures, and 

reservoirs. Additional temporary disturbance would occur at lay down and staging areas, 

and at transmission line pull sites. These activities have the potential to remove or 

disturb existing vegetation and alter soil characteristics through compaction, subsidence, 

erosion, and changes in drainage patterns. 

In response to the Commission’s request for additional information, Eagle Crest 

filed its WEAP on October 27, 2009. The WEAP includes the training of staff biological 

monitors that would be onsite during construction. The monitors would have the 

authority to halt construction activities if they determine sensitive resources are at risk. 

These monitors would be responsible for clearing and designating safe work areas, 

flagging sensitive areas, and monitoring exclusion fencing. Construction crews would be 

instructed to only work in areas approved by the biological monitors. Desert animals 

frequently take refuge in shaded areas associated with parked vehicles. As such, the 

biological monitors would also be responsible for inspecting and clearing these areas 

prior to vehicle movement.

During construction in native habitats, Eagle Crest proposes to restrict surface 

disturbance to the smallest area necessary to complete the construction (Measure BIO-5). 

Eagle Crest would design new spur roads and improvements to existing roads in a way 

that would preserve existing desert wash topography and flow patterns.

In addition to the measures described above, Eagle Crest also proposes several 

measures specifically designed to reduce effects of project construction on local 

vegetation, including the revegetation of all temporarily disturbed areas. In response to 

the Commission’s request for additional information, Eagle Crest filed its Revegetation 

Plan on October 27, 2009 (Measure BIO-8). The plan includes developing a quantitative 

description of the existing vegetation community, so revegetation success can be 

measured. To increase potential for successful revegetation in the desert environment, 

Eagle Crest would retain topsoil removed during site clearing and return the soil to the 

site prior to planting. Eagle Crest’s plan also includes micro-site preparation and 

grading. This preparation would include vertical mulching and other techniques to 

increase germination potential and plant growth. Eagle Crest’s planned restoration 

techniques include (1) seeding and/or planting seedlings of colonizing species and 
101

(2) developing a soil micro-community by inoculating mycorrhizal fungi and planting 

species that develop a mycorrhizal net. Following planting, Eagle Crest would 

implement weed control and initial irrigation. Eagle Crest’s Revegetation Plan also 

includes a schedule for the expected regrowth of native species and remedial measures to 

be implemented if needed.

As compared to the proposed route, the State Water Board’s recommended route

would increase the length of the transmission line by 2.9 miles. The State Water Board’s

route would cross 181 acres of Sonoran Creosote Bush Scrub; 97 acres of Desert Dry 

Wash Woodland; and 121 acres of developed land.

Our Analysis

Construction of the project would have unavoidable effects on local vegetation. 

Based on habitat mapping and current project design, construction of the proposed 

project would permanently remove or temporarily affect 67.7 acres of Sonoran creosote 

bush scrub and 15.4 acres of desert dry wash woodland. While some of these effects are 

temporary, such as disturbance within lay down and storage areas and pull sites, the 

desert environment in which they occur is very slow to regenerate. Clearing of native 

vegetation in lay down areas, transmission line pulling sites, transmission line support 

tower footprints, waste spoil and salt disposal sites, brine ponds, and water pipeline 

would be a necessary component of constructing project facilities. 

The State Water Board’s recommendation would require less new ROW 

development and cross a fewer acres of Dry Dessert Woodland. This alternative would 

cross 20 more acres of creosote bush scrub; however, unlike the proposed alternative, 

these lands would generally be outside the Desert Wildlife Management Area (DWMA)

and desert tortoise critical habitat. Additionally, this alternative would use a greater 

percentage of disturbed lands. Therefore, the State Water Board’s recommendation

would have less effect on vegetation resources.

Implementation of Eagle Crest’s proposed WEAP would ensure the potential for 

inadvertent effects on sensitive species is reduced. Keeping state and federal resource 

management agencies appraised of construction activities and implementation of 

mitigation measures would provide the agencies oversight of these activities and ensure 

effects are minimized and mitigation is effective. Careful planning and design of 

construction areas and access roads to reduce the extent of disturbance in native habitats 

and maintain existing drainage patterns is also a necessary component of limiting project 

effects in these areas. 

Eagle Crest’s proposed measures would limit effects of construction on vegetation 

through revegetation plantings and control of invasive species. Yet, compared to nondesert areas, the duration of these effects would be much longer, with regeneration to 

existing conditions likely requiring several decades. However, these effects would be 

highly localized within the project footprint and would have minimal effect on areas 

immediately adjacent to the disturbance areas. The overall area of disturbance would
102

also be small compared to the large extent of similar vegetation structure in the 

surrounding area and the project is not expected to cause any population level effects on 

vegetation species. This is true for all four transmission line routes analyzed.

Effects of Operation on Vegetation

Operation of the project would include the addition of water to the project 

reservoirs, proposed generating operations, and maintenance of project facilities. These 

activities could affect vegetation by providing water subsidies or disturbing new lands as 

required for maintenance.

To reduce potential effects of project operations on vegetation, Eagle Crest’s 

WEAP requires that all maintenance activities potentially requiring ground disturbance 

occur in the presence of biological monitors. Additionally, in 2006 Eagle Crest entered 

into a Memorandum of Understanding (MOU) with FWS, BLM, and U.S. Department of 

Agriculture, Forest Service (Forest Service) that provides guidelines for vegetation 

maintenance along transmission line ROWs on federal lands. This MOU also includes 

standards for revegetation practices in these areas.

Our Analysis

Following construction, staff expects operation of the transmission line and water 

pipelines would have little, if any, effect on vegetation. If any leaks are present in the 

pipeline, desert annuals are likely to colonize the localized areas. 

Specific soil conditions at the elevation of the normal high water line around both 

reservoirs are unknown since Eagle Crest was not given access to conduct surveys in 

these areas. However, past mining activities have removed any topsoil, and staff expects

current materials in these areas to have high mineral content and very low nutrient 

availability. Such areas typically require many decades to develop “crypotobiotic 

crusts,” which consist of microbes that convert elemental nitrogen into forms accessible 

to plants. Under these conditions, staff expects vegetation establishment to occur very 

slowly.

Operation of the project reservoirs would add water to areas currently void of 

vegetation. It is possible that vegetation would colonize these wetted areas, although any 

community development would be limited to the area near the normal high water line at 

each reservoir. Steep topography along the sides of the proposed reservoirs would limit 

the area of water availability to a narrow band around each reservoir. Other areas of the 

reservoir would be available for seed colonization during drawdown periods; however, 

these areas would then be inundated, normally on daily basis, as each reservoir is refilled 

during project operations. Proposed operations would involve daily water level 

fluctuations in both reservoirs of about 100 feet. Such frequent wetting and drying would 

greatly reduce the potential for any vegetation establishment below the high water lines.

Desert riparian tree species, including cottonwood and willows, are adapted to 

these sorts of environments. These species typically colonize bare mineral sand bars 
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deposited during the decline of spring flood pulses in desert streams (Stromberg, 1993). 

It is possible the wetted areas adjacent to the reservoir high water line would mimic these 

conditions. Seeds from these species are wind dispersed and have limited viability; they 

do not persist in the soil from one year to the next. To establish, the seeds need to land 

on wetted mineral soil, germinate, and develop sufficient root structure to maintain access 

to groundwater after water levels recede. If the water recedes too quickly, the seedlings 

will die (Stromberg, 1993). It is difficult to speculate how these species would respond 

to the daily wetting and drying along the sides of the proposed reservoirs. Over the 

course of the license, some limited establishment of these species should be expected. 

Effects of Construction on Noxious and Invasive Species

Construction of the project would remove existing vegetation and disturb soils, 

creating conditions suitable for the establishment of noxious or invasive plants. Once the 

species establish, they compete with native species for resources, which are limited in the 

desert environment. Proliferation of these invasive species has the potential to alter the 

existing landscape structure and wildlife habitat.

To prevent the establishment of noxious and invasive species, Eagle Crest 

proposes to implement its Invasive Species Monitoring and Control Plan (Measure BIO9). In response to the Commission’s request for additional information, Eagle Crest filed 

its plan on October 27, 2009. The plan includes pre-construction surveys to determine 

baseline conditions, followed with construction and post-construction surveys (to 

continue for 2 years post-construction) to identify any new populations of invasive 

species. If these surveys identify increases in weed species presence and/or frequency, 

Eagle Crest would implement control measures. Eagle Crest’s proposed control 

measures include manual and mechanical removal and application of EPA-certified 

herbicides.

Our Analysis

Construction activities would create areas suitable for establishment of invasive 

weeds by removing existing vegetation and disturbing soil. These effects would be 

increased along the State Water Board’s recommended route for the transmission line 

because of the greater levels of soil disturbance associated with the additional length of 

the line. Eagle Crest’s proposed plan to monitor and control invasive species is 

scientifically sound and would decrease the potential for weed proliferation in areas 

disturbed during construction. The proposed plan would be equally applicable to both

transmission line routes analyzed. The Invasive Species Monitoring and Control Plan 

identifies baseline conditions and biological triggers, indicating the need for 

implementation of control measures. However, the plan does not include criteria for 

determining success or adaptive management. If Eagle Crest amended the proposed 

Invasive Species Monitoring and Control Plan to include criteria for success and an 

adaptive management plan to be implemented if initial efforts do not prove successful, 

effects of noxious and invasive weeds could be further reduced.
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Effects of Operation on Noxious and Invasive Species

Operation of the project would include the addition of water to the project 

reservoirs, as well as operation and maintenance of project facilities. These activities 

could affect noxious and invasive weeds by providing water subsidies or disturbing new 

lands during maintenance. These conditions could create colonization potential for 

invasive species.

Eagle Crest’s Invasive Species Monitoring and Control Plan calls for surveying 

for invasive species up to 2 years following project construction. No surveys are

proposed for the remainder of the license.

Our Analysis

Eagle Crest’s Invasive Species Monitoring and Control Plan appropriately 

concentrates transects in areas where soil disturbance is expected during construction; 

however, there is no mention of surveys near potential water subsidies associated with the 

project. These water subsidies could occur at well sites or in areas within and adjacent to 

the project reservoirs.

The addition of water to desert soils, even in small amounts associated with leaks 

or seepage at well sites, would create microsites with greater vegetation growth than the 

surrounding areas. These microsites would provide ideal conditions for colonization by 

invasive species. Addition of water to the project reservoirs would also provide wetted 

soil conditions favorable for some plants. As discussed above, staff expects low levels of 

available nitrogen, resulting from mining activities, to inhibit vegetation colonization 

around the project reservoirs. These conditions would also inhibit colonization of most 

invasive species known to occur in the project area. However, tamarisk has germination 

requirements similar to cottonwood and willow (Stromberg, 1993) and could colonize the 

perimeter of project reservoirs. Implementation of Eagle Crest’s Invasive Species 

Monitoring and Control Plan would not address these issues.

In particular, the plan does not address the potential for weeds to colonize the 

reservoir areas where water availability would increase. Water subsidies related to 

project operations would occur at any seepage areas associated with the proposed 

reservoirs and well sites. If Eagle Crest modified its proposed Invasive Species 

Monitoring and Control Plan to include the identification and monitoring of these areas, 

the potential for increased weed proliferation would be reduced.

Additionally, the project reservoirs would continue to be a potential water source 

for invasive plants for the duration of the license. If soil conditions surrounding the high 

water line become suitable for vegetation establishment, noxious and invasive weeds are 

likely to be a component of the new vegetation growth. For reasons discussed above, 

staff expects vegetation would be slow to establish in these areas. As such annual 

surveys for invasive and noxious weeds are not necessary. However, If Eagle Crest 

amended the proposed plan to include annual surveys around the project reservoirs, 
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commencing once vegetation establishment is observed, the potential for weed 

proliferation would be further reduced. 

Effects of Construction on Wildlife

Construction effects on the vegetation community and habitat have the potential to 

affect wildlife through changing habitat characteristics. Construction of the proposed 

project would also require heavy vehicle traffic during the 4-year construction period, 

extended human presence, increased noise levels, and increased levels of artificial 

lighting. These factors have the potential to disturb and disorient wildlife, thereby 

increasing the susceptibility to predators, reducing foraging success, or disrupting 

breeding behavior. The potential for direct mortality associated with vehicular collisions 

would also increase.

Many of Eagle Crest’s proposed measures associated with construction 

management discussed in the vegetation section would also apply to wildlife. In addition 

to those measures, Eagle Crest proposes several measures specific to the protection of 

local wildlife. To protect migratory birds, Eagle Crest would complete surveys in all 

potential nesting sites for active bird nests (Measure BIO-11). Eagle Crest would 

conduct these surveys in vegetated habitat during all construction activities that are 

scheduled to occur between about February 15 and July 30 (breeding season for 

migratory birds in the project area). In areas without wildlife exclusion fencing or those 

areas that have not been cleared of tortoises, Eagle Crest would limit construction 

activities to take place during daylight hours (Measure BIO-20). Additionally, Eagle 

Crest would close, temporarily fence, or cover pipeline trenches at the end of each day 

(Measure BIO-21). Biological monitors would inspect open trenches to ensure animal 

safety. Eagle Crest would construct ramps leading out of the trenches to encourage 

animals to escape on their own.

Our Analysis

During construction, increased human presence and noise associated with vehicles 

and heavy machinery would have unavoidable effects on local wildlife. Construction 

activities would also create hazardous areas for wildlife, including open pits and trenches,

and shade areas associated with vehicles and material stockpile locations. Additionally, 

clearing of vegetation and grading to prepare vegetated areas for project facilities have 

the potential to disturb nesting birds and disturb or destroy animal burrows. The State 

Water Board’s recommendation would locate the transmission line outside the DWMA. 

Because this route would not bisect the DWMA, it would have a lesser effect on wildlife 

as compared with the applicant’s proposed transmission line route. Additionally, due to 

portions of the line traversing abandoned agricultural land, the quality of wildlife habitat 

along the State Water Board’s recommended route would be lower than that along the 

proposed transmission line route. Therefore, the State Water Board’s recommendation is 

expected to have the least effect on wildlife in the project area.
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Eagle Crest’s proposed measures, including the WEAP (discussed above), pre 

construction surveys for breeding birds, and exclusionary measures to prevent animals 

from occupying hazardous areas would substantially reduce the construction effects. 

While it is not possible to completely eliminate all direct and indirect effects, the 

proposed measures would reduce disturbance to acceptable levels. Sufficient habitat 

exists in the areas immediately surrounding the project construction area such that the 

majority of wildlife species are expected to temporarily disperse to less disruptive 

locations. Construction effects would also be temporary and would not create longlasting detrimental effects or affect wildlife species at a population level and would be 

equally applicable to either the proposed or State Water Board’s recommended 

transmission line route.

Effects of Project Reservoir Operation on Wildlife

Operation of the project reservoirs would add about 254 acres of surface water to 

the project area. Given the arid nature of the surrounding area, it is likely the presence of 

this water would attract local wildlife. The steep terrain surrounding the reservoirs could 

pose a hazard for animals trying to reach the water edge, potentially resulting in serious 

injury or drowning. In addition, the water could attract predators, including ravens, gulls, 

coyotes, or feral dogs, increasing the density of predatory species in the project area and 

potentially increasing predation rates on local wildlife species.

To prevent wildlife access to the upper and lower reservoirs in these areas, Eagle 

Crest would construct an 8- to 10-foot-tall exclusionary fence designed to be impassable 

to large mammals (including Nelson’s bighorn sheep, badger, fox, coyote, and deer) and 

desert tortoise (Measure BIO-18). In the northeast corner of the lower reservoir, a section 

of the fence would be structured so that it would be inundated during high water, thereby 

providing wildlife access to high water but not allowing animals to enter the pit. 

Topography in this location is less steep, providing easy access to drinking water for 

Nelson’s bighorn sheep. Eagle Crest proposes to maintain the fence for the life of the 

project. Eagle Crest would inspect all fences on a monthly basis and during/following all 

major rainfall events. Eagle Crest also proposes to temporarily repair any damage to the 

fencing immediately, followed by permanent repair within one week.

To prevent effects of increased predation on wildlife, Eagle Crest developed a 

Raven Monitoring and Control Plan (Measure DT-5). To some extent this plan is 

specifically designed to reduce potential predatory effects on desert tortoise by ravens. 

Although predators could prey on other local wildlife in addition to sensitive species, 

staff discusses this plan in more detail in section 3.3.4, Threatened and Endangered 

Species. 

During the NEPA scoping process, several entities commented that Eagle Crest’s 

proposed levels of groundwater pumping could affect regional aquifers or springs, 

depleting water resources available to wildlife. In response to these comments, Eagle 
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Crest notes that the existing geologic and hydrologic conditions in the project area 

preclude interaction between groundwater pumping and surface water availability.

In its letter in response to the Commission’s ready for environmental analysis 

(REA) notice, dated March 11, 2010, the National Parks Conservation Association 

comments that pumping groundwater to fill the project reservoirs could cause ground 

subsistence. Such subsidence could create depressions that could fill with water, 

drowning burrowing wildlife. In response to the National Parks Conservation 

Association’s comment, Eagle Crest notes that based on the existing geologic conditions 

in the project area and its proposed levels of groundwater pumping, no subsidence is 

expected to occur and no wildlife would be affected by subsidence-related changes in the 

environment.

Our Analysis

The presence of the upper and lower reservoirs would provide tempting sources of 

water for local wildlife. Past mining activities created steep, rugged topography in areas 

adjacent to the proposed reservoirs. Most wildlife that use this habitat in the Eagle 

Mountains are adapted to traversing similar steep and rugged areas; however, attempts to 

access the waterline would prove hazardous and likely cause injury or mortality to some 

individuals. Eagle Crest’s proposed construction of exclusionary fencing is a prudent 

measure to prevent these effects. The proposed fence design is suitable to prevent access 

to most species in the project area. Regular inspections and maintenance would ensure 

the fence is in effective operating condition and also reduce potential for animals to be 

trapped in small openings. 

With respect to implementation of Eagle Crest’s proposed Raven Monitoring and 

Control Plan, the primary effects are discussed in section 3.3.4, Threatened and 

Endangered Species. Using desert tortoise as an indicator species, Eagle Mountain 

would implement predator control measures as necessary. These measures would also 

benefit local wildlife species. 

As discussed further in section 3.3.2, Water Resources, Eagle Crest’s proposed 

rate of groundwater withdrawal is not expected to cause subsidence or affect surface 

water availability. As such, staff finds that such groundwater withdrawal is unlikely to 

affect wildlife in the project area.

Effects of Project Brine Pond Operation on Wildlife

As further discussed in section 3.3.2, Water Resources, the project facilities would 

include ponds and a reverse osmosis system used to remove salts and metals from 

reservoir water and maintain total dissolved solids concentrations within the reservoirs at 

the level of the source water. These ponds would have the potential to attract wildlife 

seeking water, and the high mineral content in the brine could pose health risks to 

wildlife. To prevent wildlife interaction with the ponds, Eagle Crest proposes to erect 

exclusionary fencing around this area. The fence design and maintenance would be 
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similar to that described above for the reservoir fencing. However, because the fences 

would not limit access to birds, Eagle Crest proposes additional measures (Measure BIO12) to discourage access and use habitat modification techniques and hazing to make the 

ponds less attractive to birds. Eagle Crest would monitor the success of these measures 

and based on monitoring results, implement adaptive management as necessary to ensure 

that bird use of the ponds is minimized, including, if feasible, enhanced hazing or pond 

covering that does not impede the evaporation function.

Our Analysis

Birds are likely to view the ponds as a safe source of drinking water. However, 

high total dissolved solids concentrations in these proposed ponds could be harmful or 

fatal to birds and other wildlife. Discouraging and/or preventing access to these areas is a 

necessary component of reducing project effects on avian species. Eagle Crest’s 

proposed measure to make this area less attractive to birds, monitor bird use, and if 

needed, implement exclusionary covering to prevent access would reduce these effects. 

However, Eagle Crest’s description of this measure does not provide enough detail to for 

us to fully analyze the effects. For example, the existing description does not indicate 

what hazing methods would be used, or thresholds at which more extensive exclusionary 

devices would be implemented. If Eagle Crest developed and implemented more detailed 

plan to reduce bird use of the desalination pond, including proposed hazing and habitat 

modification techniques, methods for measuring success, and thresholds for 

implementing exclusionary pond covering, potential effects would be further reduced.

Sensitive Species

In general, the potential effects of the project on most sensitive species presented 

in table 10 are similar to the effects discussed above for general wildlife species. 

However, due to special habitat value within the project area, high population density in 

the project area, or potential for the project to have concentrated effects on a population,

effects on some sensitive species are discussed in more detail below.

Effects of Construction on Special-Status Plants

Construction of the transmission line and water pipeline has the potential to affect 

sensitive plants species known to occupy the proposed ROW for these facilities. These 

species include California ditaxis, crucifixion thorn, desert unicorn plant, foxtail cactus, 

and Wiggins’ cholla. Potential effects include direct mortality of the plants during 

vegetation clearing activities and reduced survivorship or reproductive success caused by 

changes in soil characteristics, microtopography, or water supply. Construction of the 

State Water Board’s recommended transmission line route would increase potential for 

these effects due to the greater length of the route. Eagle Crest proposes several 

measures to minimize the potential for these effects.

Eagle Crest would use pre-construction surveys to identify special-status plant 

populations and species protected by the CDNPA (Measure BIO-6). Following surveys, 
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Eagle Crest would establish avoidance areas in construction zones for special plant 

resources. Where avoidance is not feasible, Eagle Crest would salvage and transplant 

any species that can be reasonably transplanted in an approved area. Eagle Crest also 

proposes to comply with the CDNPA and consult with the Riverside County Agricultural 

Commissioner for direction regarding disposal of protected plants (Measure BIO-7).

Our Analysis

As currently proposed, construction of the project transmission line and water 

pipeline would occur in areas populated with sensitive plant species. Failure to 

appropriately plan locations for equipment stockpiles, lay down sites, pull sites, and 

support tower footprints would create increased potential for direct effects on these 

species, likely killing numerous individuals and small populations. However, 

considerable flexibility exists in the specific locations of these project features. Eagle 

Crest’s proposal to conduct pre-construction surveys and designate avoidance areas 

would reduce potential effects on sensitive plants. Nonetheless, it is likely some 

disturbance would be unavoidable. This is especially true within the water pipeline 

ROW, where it is less feasible to make small adjustments to the disturbance area. In 

locations where disturbance is unavoidable, Eagle Crest’s proposal to allow salvage 

activities, transplant any reasonably movable species, and coordinate with the County 

Agricultural Commissioner for direction regarding disposal would further reduce project 

effects. These measures would be equally effective along both transmission routes 

analyzed.

Effects of Operation on Special-Status Plants

Maintenance activities that occur during project operations, including repair of 

transmission line support structures or the water pipeline, could require vegetation that 

would affect sensitive plants.

To reduce potential effects of project operations on special-status plants, Eagle 

Crest’s WEAP requires that all maintenance activities potentially requiring ground 

disturbance occur in the presence of biological monitors. Additionally, in 2006 Eagle 

Crest entered into an MOU with FWS, BLM, and the Forest Service that provides 

guidelines for vegetation maintenance along transmission line ROWs on federal lands. 

This MOU also includes standards for protecting special-status plants.

Our Analysis

Maintenance of the project transmission line and water pipeline would 

occasionally require ground disturbance. Staff expects that the area of disturbance 

required for these activities over the life of the project would be small in relationship to 

the area disturbed during construction. Additionally, Eagle Crest would, to the greatest 

extent practical, site project features away from areas with high sensitive plant presence. 

Maintenance of these features is, therefore, unlikely to affect special-status plants. Eagle 

Crest’s biological monitors would ensure that these activities do not affect special-status 
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plants. No further measures are needed to protect these species from effects of project 

operation.

Effects of Construction on Nelson’s Bighorn Sheep

Under the proposed schedule, major construction activities in the central project 

area are expected to last 3 to 4 years. During this time extensive use of heavy machinery 

including earth movers, dump trucks, cement trucks, and tunnel boring equipment would 

increase noise levels and increase human presence in this area compared to current 

conditions. These activities could disturb bighorn populations that spend much of the 

year in the mountainous areas surrounding the central project area. Construction of 

project roads and desert tortoise exclusionary fencing, as well as increases in artificial 

lighting, also have the potential to disrupt migratory paths for Nelson’s bighorn sheep 

moving between available water sources and to breeding and lambing grounds. The 

potential for vehicular collisions is also a concern. Following construction, project 

operations would provide an additional water source accessible to Nelson’s bighorn 

sheep in the northeast corner of the lower reservoir. Other areas around the reservoir 

perimeters would be fenced to exclude Nelson’s bighorn sheep to prevent attempts to 

access water by traversing hazardous terrain.

Eagle Crest notes that while the construction period would increase human 

presence and noise levels over current conditions, the central project area has been 

heavily mined over the past several decades. Eagle Crest does not expect disturbance 

levels related to project construction to be substantially greater than the noise and human 

presence associated with the past mining activities. Rather, Eagle Crest expects bighorn 

movements to continue as they had in the past. To reduce the effects of project 

construction on Nelson’s bighorn sheep, Eagle Crest’s desert tortoise exclusion fencing 

along project roads would be limited to 3 feet in height so as not prevent Nelson’s 

bighorn sheep movement. These fences would be removed following construction.

Our Analysis

Construction activities in the central project area would result in increased noise 

and human presence that could affect Nelson’s bighorn sheep populations in the area. 

Without more detailed information about the migratory pathways the bighorn sheep 

currently use to move from Eagle Tank to Buzzard Spring or to breeding and lambing 

areas, it is unclear how this disturbance would affect the current populations. However, 

staff finds it reasonable to assume that the proposed levels of disturbance would be 

similar to the historical mining operations. Given the topography in the mine area, it is 

probable that migration paths traverse the perimeter of the mine and have not changed in 

recent years when the mine has been mostly inactive. Under this scenario, project 

construction activities would not create a migratory barrier, and staff expects effects of 

project construction on Nelson’s bighorn sheep populations would be minor and 

temporary.
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Effects of Project Operations on Nelson’s Bighorn Sheep

Operation of the project would include maintenance activities and fluctuating 

levels of standing water in the reservoirs. These conditions have the potential to attract 

Nelson’s bighorn sheep into the central project area to access drinking water, increasing 

the risk of drowning or collisions with vehicles. Project lighting could also disturb this 

species, potentially affecting migration patterns.

During operations, Eagle Crest would reduce vehicle traffic to about one round 

trip per day. Wildlife exclusion fences would surround both reservoirs to prohibit 

Nelson’s bighorn sheep from accessing water in unsafe locations, but fence setbacks 

would permit access in the northeast corner of the lower reservoir. Project facilities 

would be lighted as a safety and security precaution, and the lights would include shields 

to focus light on the project interior and prevent light pollution to surrounding areas 

(Measure BIO-22).

Our Analysis

Following construction, vehicle trips in the central project area are expected to 

occur at the rate of only one vehicle per day and would pose a very limited risk of 

collisions. While facility lighting and equipment noise may create limited disturbance, 

they are not expected to affect Nelson’s bighorn sheep populations. The project would 

provide a new source of drinking water, which is a component of the management plan 

for this species. The addition of the new water source is likely to disrupt the migration of 

the northern ewe population to Buzzard Spring. This migration occurs outside of the 

breeding and lambing period and does not result in increased interaction with other ewe 

populations. The addition of the new water source is not expected to affect the greater 

Eagle Mountain bighorn sheep population. As such, operation of the project would 

provide some benefit to the bighorn population, counteracting any temporary negative 

effects associated with construction.

Effects of Construction on Burrowing Animals

Several sensitive species known to occur in the project area use burrows to escape 

the desert heat, hide from predators, and raise young. These species include badger, kit 

fox, and burrowing owl. Proposed construction activities have the potential to collapse 

these burrows or block their entrances, trapping animals inside. To prevent these effects, 

Eagle Crest proposes to continue consultation with California DFG to determine 

appropriate survey needs for the burrowing owl. Upon California DFG’s request, Eagle

Crest would conduct a Phase III survey for burrowing owl to further assess bird use of the 

project area and potential effects (Measure BIO-13). The Phase III survey would include 

a nesting season survey, followed by a winter survey if no burrows or owls are observed 

during the nesting season. Subsequently, Eagle Crest would conduct a pre-construction 

survey within 30 days of the start of project construction to assess species presence and 

the need for further mitigation. Because of the low observations of burrowing owls 
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during the Phase I surveys, Eagle Crest notes that California DFG may not require the 

Phase III survey and only pre-construction surveys would be needed.

If the Phase III or pre-construction surveys indicate burrowing owls are present, 

Eagle Crest would limit the construction period to September 1 through February 1 to 

avoid disruption of breeding activities (Measure BIO-14). Eagle Crest would avoid 

active nests by designating a minimum of a 250-foot buffer until fledging has occurred 

(February 1 through August 31). Following fledging, owls could be passively relocated 

away from construction activities.

To protect other sensitive burrowing animals, Eagle Crest would conduct preconstruction surveys for all burrows that might host a badger or kit fox (Measure BIO16). Eagle Crest would avoid active burrows and all fox natal dens where possible. 

Biological monitors would mark the perimeters of all avoidance areas with wooden 

stakes, at least 3 feet high, and no more than 10 feet apart. Where avoidance is 

infeasible, biological monitors would determine occupancy of burrows and encourage 

occupants to leave their burrows. Biological monitors would fully excavate all burrows 

from which badgers or foxes have been removed and collapse these burrows to ensure 

that animals cannot return prior to or during construction.

Our Analysis

If left unsurveyed or accounted for, project construction activities would likely 

cause injury or mortality to burrowing species through burrow collapse or entrapment. 

Given the low number of burrowing owls observed during project surveys, preconstruction surveys would provide adequate information necessary to develop 

mitigation measures for this species. Eagle Crest’s proposal to conduct pre-construction 

surveys for active burrows and either avoid such areas, or when necessary destroy 

unoccupied burrows, would reduce potential for injury or mortality. In general,

destruction of an unoccupied burrow does not pose an undue risk to the burrow’s 

occupant, which typically relocates to other vacant burrows in the vicinity. Destruction 

of unoccupied burrows is the best method of preventing injury in construction zones. 

However, when occupants are under additional stresses associated with nesting, birthing, 

or caring for young, burrow removal is not the appropriate option. Eagle Crest’s proposal 

to avoid active burrowing owl nests and natal kit fox dens would prevent additional 

effects on these species. These measures would be equally effective along both

transmission routes analyzed.

Effects of Operation on Burrowing Animals

Maintenance activities that occur during project operations, including repair of 

transmission line support structures or the water pipeline, could require ground 

disturbance activities in areas with animal burrows.

To reduce potential effects of project maintenance on burrowing animals, Eagle 

Crest’s WEAP requires that all maintenance activities potentially requiring ground 
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disturbance occur in the presence of biological monitors. These monitors would follow 

the same protocols discussed above for clearing burrows and ensuring special-status 

burrowing species are not affected.

Our Analysis

Maintenance of the project transmission line and water pipeline would 

occasionally require ground disturbance. Staff expects that the area of disturbance 

required for these activities over the life of the project would be small in relationship to 

the area disturbed during construction. Eagle Crest’s biological monitors would ensure 

these activities do not affect burrowing animals. 

Effects of Project Construction on Raptors

Several sensitive raptor species, including prairie falcon and golden eagle, could 

suffer effects of project construction if there are active nests near activities proposed in 

the central project area. Loud staccato noises and vehicle noise could disrupt nesting 

activities or cause nest abandonment. 

In the final license application, Eagle Crest proposed to conduct pre-construction 

surveys in the central project area to determine whether any active golden eagle or prairie 

falcon nests are present (Measure BIO-15). If surveys identified active nests, Eagle Crest 

proposed to provide protective 0.25-mile-radius buffers around the nests and stated that 

no construction activities would occur within these buffer areas during the nesting 

seasons.

In its comment letter filed on March 12, 2010, FWS recommends Eagle Crest 

consult with FWS to determine the need for golden eagle surveys.

In its reply to FWS, Eagle Crest notes that in response to new regulations and 

guidelines finalized subsequent to the filing of the final license application, Eagle Crest is 

engaging in consultation with FWS with regard to golden eagle surveys. Eagle Crest is 

conducting surveys for the 2010 nesting season and plans to submit to FERC the results 

of the surveys, with any appropriate mitigation measures, as soon as the information is 

available.

In its July 7, 2010, filing, Eagle Crest provided a report documenting raptor 

surveys in the project area. A summary of the results of this study is presented in section 

3.3.3.1, Terrestrial Resources, Affected Environment.

Our Analysis

If carried out near active raptor nests, project construction activities in the central 

project area would disturb nesting pairs and potentially cause nest abandonment. The 

Eagle Crests raptor survey report presents maps showing the locations of golden eagle 

nests in the project vicinity. However, proposed project features are not included on 

these maps, and there is no discussion as to whether these nests are within 0.25 mile of 

proposed construction activities. Therefore, the report does not provide sufficient detail 
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to determine the need for protection buffers or time of year restrictions on construction 

activities. Eagle Crest’s proposed measures include pre-construction surveys and 

development of protective buffer areas as needed. The results of the summer 2010 raptor 

surveys indicate that further analysis and implementation of this measure are warranted. 

These measures would be equally appropriate along both transmission routes analyzed. 

Effects of Project Operation on Raptors

The project transmission line has potential to affect raptors due to in-flight 

collisions with conductors or electrocution. Additional perching or nesting sites 

associated with the transmission line could have beneficial effects on some raptor 

species, but could also cause increased predation on local wildlife.

In its comment letter filed on March 12, 2010, FWS recommends that Eagle Crest 

ensure compliance with Avian Power Line Interaction Committee (APLIC) 

recommendations and develop an avian protection plan that meets FWS guidelines. FWS

also recommends co-locating the new line with existing lines in the project area. FWS 

states that this would reduce the creation of new perching and nesting sites for desert 

tortoise predators.

Eagle Crest filed a response to the FWS recommendations on April 23, 2010. In 

this response, Eagle Crest states that it would design and construct raptor-friendly 

transmission lines in strict accordance with the industry standard guidelines set forth in 

Suggested Practices for Raptor Protection on Power Lines: The State of the Art in 2006 

(APLIC, 2006) (Measure BIO-24). In addition, prior to the start of ground-disturbing 

activities, Eagle Crest would develop and file for Commission approval a transmission 

line design plan that would consider adequate separation of energized conductors, ground 

wires and other metal hardware, adequate insulation, and any other measures necessary to 

protect raptors from electrocution hazards.

Our Analysis

Avian injuries and fatalities associated with electrocution or collision with power 

lines have been reported since the late 1800s, and as power lines have proliferated across 

the country, bird losses have increased dramatically. A recent report estimated that 

fatalities in the United States range from 3.5 million to 1.05 billion birds every year 

(Hunting, 2002). Most electrocutions are associated with lines carrying 69 kV or less

because the spacing of hardware is often not sufficient to prevent birds from spanning 

between conductors or between a conductor and a ground (APLIC, 2006). The project 

would include a 13.5-mile double-circuit 500-kV line and a 4,000-foot-long 18-kV line

from the powerhouse to the collector substation.

Improper construction of project electric transmission facilities could pose 

increased risks to raptor injury and mortality. APLIC provides industry standards for 

electric transmission system design measures aimed at reducing effects on birds. These 

standards include spacing conductors such that they are beyond the wing span of large 
115

birds to prevent electrocution, as well as measures to increase line visibility to reduce 

potential for collisions. Eagle Crest proposes to construct the transmission line in 

compliance with these standards and to prepare a plan, for Commission approval, to 

protect raptors from electrocution hazards. However, Eagle Crest’s proposed measure 

does not address potential for avian collisions or procedures for monitoring and reporting 

avian injury or mortality resulting from interactions with the project transmission line. 

Addressing these components, in addition to implementing measures related to potential 

electrocution, would be necessary to meet the APLIC/FWS guidelines for an avian 

protection plan.

If Eagle Crest prepares an avian protection plan, in consultation with FWS, that 

includes design measures for reducing potential for electrocution and collision injuries, 

provides methods for surveying and reporting project related raptor mortality, 

incorporates a worker education plan pertaining to avian–power line interactions, and 

procedures for managing nesting on powerline structures, effects of project operation on 

raptors would be minimized. Such a plan would assist Eagle Crest in meeting the 

requirements of the Bald and Golden Eagle Protection Act and Migratory Bird Treaty 

Act.

Constructing new transmission support towers would increase perching and 

nesting structures for birds, including desert tortoise predators. However, constructing 

these new towers in areas where similar towers already exist would limit the spatial 

distribution of these resources. While the new towers would still present potential 

nesting and perching structures, the proximity of these structures to the existing structures 

could limit their suitability. Both ravens and other raptors nest in defended territories and 

are not likely to nest near pre-existing nests. Therefore, constructing the new line 

adjacent to existing lines would limit the creation of new nest sites. The State Water 

Board’s recommended transmission route would be co-located with existing structures 

and removed from mountainous nesting habitat. This recommended route would address 

FWS concerns regarding the addition of new nesting habitat and is expected to have the 

lowest effect on raptors.

Effects of Construction on Bats

Based on existing information, it is probable that some sensitive bat species use 

the rocks, crevices, or caves in the central project area as roosting habitat. If roosting 

locations are occupied during the filling of project reservoirs, these areas could be 

inundated, causing disturbance, injury, or mortality to sensitive species. To reduce the 

potential for project effects on sensitive bats, Eagle Crest proposes to conduct preconstruction bat surveys, using a qualified bat biologist, to determine the existence, 

location, and condition of bat roosts on the project site. The survey would also identify 

foraging habitat in the project area. Based on the results of these surveys, Eagle Crest 

would prepare a mitigation plan to avoid roosting and foraging effects on resident bats, 

minimize that disturbance, or as an unavoidable measure, evict bats (Measure BIO-17).
116

Our Analysis

Based on the limited data available for the central project area, staff finds that 

occurrences of bat roosts in the Eagle Mountain mine site are likely. Inundating these 

areas without providing mitigation could affect bats, including sensitive bat species. 

Eagle Crest’s proposal to conduct pre-construction surveys, and depending on the survey 

results, to develop and implement a bat protection and mitigation plan, would reduce 

these effects. If Eagle Crest prepares this plan in coordination with state and federal 

agencies, develops proposed environmental measures, methods for determining success, 

and adaptive management strategies, it would ensure the bat protection and mitigation 

plan is most effective.

Effects of Operation on Bats

Operation of the project would include lighting the central project area and 

fluctuating water levels in the reservoirs. The addition of lights and water would likely 

result in increases in insects in the area of the project reservoirs. These insects could 

provide a food source for bats. Fluctuation of the reservoir water levels associated with 

generation activities could result in suitable roosting areas being available at one time of 

day but then flooded later in the day. Bats using these roosts could be trapped by rising 

water levels.

To reduce to potential for project effects on sensitive bats, Eagle Crest proposes to 

prepare a mitigation plan to avoid roosting and foraging effects on resident bats, 

minimize that disturbance, or as an unavoidable measure, evict bats (Measure BIO-17). 

Preparation of this plan would occur following surveys to determine bat presence in the 

central project area.

Our Analysis

Inundation of roosting areas could affect bats, including sensitive bat species if 

these areas are left open and accessible during low water periods and then inundated 

during roosting periods. Adding lights to the central project area would attract insects to 

the areas. Bats are also likely to come to these areas to feed, resulting in an increased 

likelihood that the available roosting habitat in the central project area would be 

occupied. Eagle Crest’s proposal to conduct pre-construction surveys and, based on the 

survey results, develop and implement a bat protection and mitigation plan would reduce 

these effects. If Eagle Crest were to prepare this plan in coordination with state and 

federal agencies and develop proposed mitigation measures, methods for determining 

success, and adaptive management strategies, it could ensure the bat protection and 

mitigation plan would be most effective. 

Effects of Construction on Couch’s Spadefoot Toad

The project could affect Couch’s spadefoot toad if grading, construction of project 

roads, or construction of other project facilities alter topography or water availability to 
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existing ephemeral pools that contain this species. Since small populations of these toads 

occur in isolated depressions that generally gather small amounts of water, small changes 

in topography and water availability has the potential to eliminate an entire population in 

an affected depression.

To reduce potential for project effects on this species, Eagle Crest, in compliance 

with the NECO Plan, proposes to avoid effects on all ephemeral pools in the project area. 

Once access is permitted, Eagle Crest would conduct surveys for ephemeral pools in the 

central project area. If present, the pool would be avoided, if possible. If avoidance is 

not possible, then Eagle Crest would construct a new pool as close as is feasible to 

replicate and replace each lost pool. All larvae would be moved to the new pool 

(Measure BIO-10).

Our Analysis

Eagle Crest’s surveys indicate that there are no ephemeral pools along the 

proposed transmission line or water pipeline ROWs. However, these surveys have not 

been conducted along the additional alternatives. Eagle Crest’s proposed measure to 

survey the central project area for ephemeral pools and avoid these areas or relocated 

toads to other suitable habitat would eliminate potential effects in this area. If the final 

transmission line is constructed in areas not previously surveyed for ephemeral pools, 

there is potential for effects on Couch’s spadefoot toad. If Eagle Crest conducted preconstruction surveys in all areas of proposed construction activity not previously 

surveyed in 2009, and implemented the same protection measures proposed for the 

central project area, then potential effects of the transmission line would be eliminated.

Effects of Operation on Couch’s Spadefoot Toad

Maintenance activities that occur during project operations, including repair of 

transmission line support structures or the water pipeline, could require ground 

disturbance activities that have the potential to alter local patterns of surface runoff. 

There is potential for these activities to disturb Couch’s spadefoot toad habitat.

To reduce potential effects of project maintenance on burrowing animals, Eagle 

Crest’s WEAP requires that all maintenance activities potentially requiring ground 

disturbance occur in the presence of biological monitors. These monitors would follow 

the same protocols discussed above for identifying and protecting sensitive habitat, 

including ephemeral pools.

Our Analysis

Maintenance of the project transmission line and water pipeline would 

occasionally require ground disturbance. Staff expects that the area of disturbance 

required for these activities over the life of the project would be small in relationship to 

the area disturbed during construction. Eagle Crest’s biological monitors would ensure 

these activities do not affect potential habitat for Couch’s spadefoot toad. 
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3.3.3.3 Cumulative Effects

During project scoping several terrestrial resources were identified for which the 

Eagle Mountain Project, in conjunction with other reasonably foreseeable projects, could 

have cumulative effects. These resources include desert bighorn sheep and raven 

populations. To analyze potential cumulative effects on these resources, staff evaluated 

the combined effects of the proposed project, the proposed Eagle Mountain landfill, and 

solar projects proposed in the Chuckwalla Valley.

Nelson’s Bighorn Sheep

Both the proposed project and the Eagle Mountain landfill (if constructed; see 

Land Use in section 3.3.5) would occupy lands in the central project area. As discussed 

above, desert bighorn sheep are known to occur in this area and to migrate between 

natural sources of drinking water located to the north and south of this area. Construction 

and operation of these projects could disturb bighorn sheep by increasing noise and 

human presence in the area. Combined, these projects are expected to occupy 6,875 

acres, 47 percent of which would be associated with the pumped storage project. 

Construction of the two projects is not expected to occur simultaneously, so there would 

not be cumulative effects of construction at one time. However, construction of both 

projects could result in prolonged increases in noise-related stress that could affect 

bighorn sheep in the project area over the total construction period. 

Construction activities are expected to involve about 75 trucks per month for the 

project and 1,500 trucks per month for the landfill (see Land Use in section 3.3.5). Eagle 

Crest does not propose to develop any new access roads or conduct any road 

improvements within the central project area. For the landfill, Eagle Crest would 

construct 6 miles of new, paved access roads, and widen an additional 6 miles of existing 

road. During operation, Eagle Crest expects to require 2 truck trips per day, while the 

landfill operations, Eagle Crest would require between 50 to 100 trucks per day 

depending on the age of the project. Eagle Crest’s estimate of 75 trucks per month seems 

low for the amount of materials needed for the proposed project. However, even if this 

number is increased by a factor of 10, the contribution of the proposed project to total 

stress associated with construction noise would be small compared to that associated with 

construction of the landfill.

Proposed solar projects would be located on the valley floor and are not expected 

to affect desert bighorn sheep. Based on these predicted use levels, staff finds that 

construction and operation of both the proposed project and the Eagle Mountain landfill 

could affect desert bighorn sheep in the central project area. However, the Eagle 

Mountain Project would constitute a small percentage of these effects and Eagle Crest’s 

proposed measures to reduce effects on desert bighorn sheep would mitigate for its share 

of any cumulative effects.
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Ravens

Both the proposed project and the Eagle Mountain landfill (if constructed; see 

Land Use in section 3.3.5) would occupy lands in the central project area, and each 

project is expected to provide increased food availability to ravens. The proposed project 

would increase available drinking water associated with project reservoirs (254 acres) 

and nesting and perching habitat associated with the transmission line (13.5 miles). As 

discussed above, all of these resources are already present in the landscape surrounding 

the project, including power lines and CRA water. If proposed solar facilities are 

constructed in the Coachella Valley, additional transmission lines would be constructed, 

providing additional nesting and perching habitat. The Eagle Mountain landfill would 

increase available food sources associated with the importation of waste to about 2,164 

acres of land in the project area. No similar food sources currently exist in the project 

vicinity. If both projects are constructed, the combined effects of increased food sources

would likely create conditions suitable for expansion of the raven populations. However, 

the contribution of the pump storage facility would be small related to the contribution of 

the landfill because water subsidies and transmission lines are already present in the 

project vicinity and are not expected to be limiting resources for raven populations. 

Additionally, Eagle Crest’s proposed measures to study effects of the project on ravens 

and implement control measures as needed would ensure the collective effects on ravens 

with the landfill project are not substantially greater than the effects of the proposed 

landfill and solar facilities alone.

Both the proposed project and the Desert Sunlight Solar Farm (BLM, 2010a) 

would require construction of new transmission lines to interconnect with the electric 

grid. As proposed, Eagle Crest would construct a new substation near Desert Center and 

create a new 500-kV transmission corridor along Eagle Mountain Road. The Desert 

Sunlight Solar Farm would construct the Red Bluff substation about 6 miles east of 

Desert Center along the Interstate 10 corridor and construct a new 230-kV transmission 

line that would parallel the existing SCE 160-kV line. The State Water Board’s

recommendation for the proposed Eagle Mountain Project would use the same substation 

and transmission corridor for both the Eagle Mountain and Desert Sunlight Solar Farm 

projects, consistent with the California Public Utilities Commission environmentally 

preferred alternative for the Desert Sunlight Solar Farm (BLM, 2010a). This 

recommendation would reduce disturbance to terrestrial resources by eliminating the 

need for a second substation and would reduce effects on ravens by minimizing the 

addition of new transmission structures that would create favorable nesting habitat.

3.3.4 Threatened and Endangered Species 

3.3.4.1 Affected Environment

Two special-status species with the potential to occur in the proposed project area 

are federally listed as threatened or endangered: Coachella Valley milkvetch (Astragalus 

lentiginosus var. coachellae) is endangered and desert tortoise (Gopherus agassizii) is 
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threatened. In addition, the milkvetch is listed as sensitive by BLM and List 1B by CNPS 

and the desert tortoise is listed as threatened and protected by California DFG.

Coachella Valley Milkvetch 

This subspecies occurs primarily from the Coachella Valley east to Desert Center. 

Off-highway vehicle (OHV) recreational use is one of the greatest threats to this species, 

and many populations may no longer exist. 

The species is distinguished from other silky-haired milkvetch species by its 

strongly inflated, two-celled, papery, speckled seed pods. It is an herbaceous perennial 

whose aboveground portions die back during drought periods. While it is restricted to 

loose-sandy, including aeolian (wind-blown), soils, the substrate over the soil may be 

slightly gravelly. Microhabitat sites are often associated with disturbance, consistent 

with many legumes, and individuals are commonly found in road berms. FWS has 

designated several critical habitat units for this species along the Interstate 10 corridor 

between Indio and Palm Springs, California. No critical habitat is present in the project 

area.

Eagle Crest conducted surveys for this species in concert with surveys for desert 

tortoise in spring 2008 and 2009.33

Desert Tortoise

 Surveyors did not encounter any Coachella Valley 

milkvetch in the project area.

The desert tortoise inhabits the Southwest in areas north of Baja California, with a 

current range extending from southwestern Utah, west to the Sierra Nevada Range in 

California, and south through Nevada and Arizona into Sonora, Mexico.

The desert tortoise occupies arid habitats below 4,000 feet. In the Colorado and 

Sonoran deserts of southern California and Arizona, desert tortoises occupy somewhat 

lusher desert habitats, with increased bunch grasses, cacti, and trees. Because of the 

burrowing nature of tortoises, soil type is an important habitat component. In California, 

tortoises typically inhabit soft sandy loams and loamy sands, although they are also found 

on rocky slopes and in rimrock that provide natural cover sites in crevices. Hills with 

rounded, exfoliating granite boulders often host higher densities than the surrounding 

flats, especially in Arizona. Valleys, alluvial fans, rolling hills, and gentle mountain 

 

33 In both 2008 and 2009, surveyors were not given access to Kaiser properties for 

surveying. The exclusion area included the proposed project water pipeline ROW west 

of the Metropolitan Water District CRA and the transmission line ROW north of UTM 

3745200N (North American Datum 83). As a result, Eagle Crest was unable to conduct 

on-site surveys of the mine pits that would form the reservoirs and other central project 

areas.
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slopes are inhabited. The only areas tortoises typically avoid are intermittent lakes and 

steep, talus-covered slopes.

In 1989, information on high mortality rates and the presence of an upper 

respiratory tract disease in populations of the desert tortoise resulted in a temporary 

emergency listing as endangered (FWS, 2010). The Mojave population—which inhabits 

California (including the project area), Nevada, Utah, and parts of Arizona north of the 

Colorado River—was listed in the final rule on April 2, 1990, as threatened. The 1994 

Recovery Plan identified six evolutionarily significant units of the desert tortoise in the 

Mojave Region, based on differences in tortoise behavior, morphology and genetics, 

vegetation, and climate. Within those recovery units, suggested DWMAs act as reserves 

in which recovery actions are implemented. The NECO Plan furthers this recovery goal 

by prescribing conservation and management measures for DWMAs. The Chuckwalla 

DWMA intersects 17.7 acres of the project (table 11).

Table 11. Acreage of desert tortoise habitat in the Eagle Mountain Pumped Storage 

Project area (Source: Eagle Crest, 2009a).

Project Element DWMA

FWS Critical 

Habitat

BLM 

Category 3 

Habitat

Total in 

Desert 

Tortoise 

Habitat

Central project area 0 0 0 0

Transmission tower 

footprint plus 

construction area

(3,600 square feet per 

tower)

2.1

(27 towers)

2.4

(29 towers)

1.6–2.7

(19–33 towers)

4.0–5.1

(48–62 towers)

Access road

(20-foot ROW)

15.6 16.6 14.7 31.3

Pulling/tensioning 

sites

Currently unknown (intended to fall within the transmission line 

ROW and substation site)

Equipment laydown 

sites

0 0 0 0

Proposed 

interconnection 

collector substation

0 0 25 25

Water pipeline 

(30-foot ROW)

0 0 22.9 22.9

Total project acreage 17.7 19 64.2–65.3 83.2–84.3
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FWS designated critical habitat for desert tortoise in the Mojave Region in 1994 

(50 CFR Part 17). The proposed project would cross portions of the Chuckwalla Unit, 

which encompasses 1,020,600 acres in Riverside and Imperial counties, California. This 

area provides nesting, sheltering, foraging, and dispersal habitat and contributes to 

species gene flow.

During March and early April of 2008 and 2009, Eagle Crest conducted surveys 

for the desert tortoise along the project’s linear elements and at potential well sites. In 

2008, the proposed project routes were preliminary, so surveys were conducted both on 

areas where the project could ultimately occur and areas that were later eliminated from 

consideration in 2009. Because of the uncertain nature of the proposed routes in 2008, 

the extensive survey protocol required by FWS for desert tortoises was not used. Rather, 

Eagle Crest used the following procedures to collect evidence of desert tortoises:

• Transmission Line ROW—Inside Wildlife Habitat Management Areas 

(WHMAs), surveyors walked four, 50-foot-wide, adjacent transects within the 

200-foot transmission line ROW; outside WHMAs, surveyors walked two, 

100-foot-wide, adjacent, meandering transects in the ROW.

• Water Pipeline ROW—Where the proposed ROW was precise, surveyors 

walked a 30-foot-wide transect; where the ROW was imprecise, surveyors 

walked two, 100-foot-wide, adjacent, meandering transects.

• Other ROWs—For ROWs through abandoned jojoba fields that had access 

roads, only the roadsides were surveyed.

• Potential Well Sites—Surveyors examined all known commercial wells in the 

project area that had the potential to supply water to the project.

In 2009, pedestrian transects were completed consistent with the FWS desert 

tortoise survey methodology. Per those protocols, 100 percent of the ROWs were 

surveyed using parallel, 30-foot-wide, pedestrian belt transects. The ROW for the 

proposed transmission line is 200 feet wide. Eagle Crest surveyed a 60-foot ROW 

associated with the proposed water pipeline to account for minor route shifts in the final 

30-foot-wide ROW. In addition, Eagle Crest surveyed a 30-foot-wide zone-of-influence 

(ZOI) (i.e., both sides of the ROWs at 100, 300, 500, 1,200, and 2,400 feet from the outer 

edges of the ROWs). The exception to this occurred where the ROWs went through 

jojoba fields, which are not tortoise habitat, although it is recognized that a tortoise could 

enter these areas from adjacent native habitat, even if unlikely.

In both 2008 and 2009, all tortoise signs (e.g., individuals, dens, burrows, scat, 

tracks, pellets, skeletal remains) that surveyors encountered were measured, mapped and 

described relative to condition, size, and (where applicable) gender. Current and recent 

weather conditions were recorded to identify the potential for tortoise activity and the 

topography, drainage patterns, soils, substrates, plant cover, anthropogenic disturbances, 

and aspect-dominant, common, and occasional plant species were described and mapped. 

Surveyors used Global Positioning System (GPS) units to map sign and habitat features.
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During 2008, surveyors encountered three tortoise burrows and one carcass in the 

project area that was surveyed. In 2009, following the FWS protocol, Eagle Crest’s 

surveyors encountered 34 burrows, 8 carcasses, 16 scat piles, and 2 live tortoises. The 

majority of tortoise signs (56 out of 60 observations) were encountered on transects 

associated with the proposed transmission line.

3.3.4.2 Environmental Effects

Coachella Valley Milk Vetch

Effects of the project on Coachella Valley milk vetch would occur only through 

direct disturbance to individuals present in the project area. Eagle Crest’s surveys 

indicate this species does not occur in the project area, so no effects are anticipated and 

no measures would be needed to protect this species. Staff finds the project would not 

affect Coachella Valley milk vetch.

Effects of Construction on Desert Tortoise

Construction of the project would involve the use of heavy machinery, road 

grading, vegetation removal, and heavy vehicle traffic in the project area. These 

activities have the potential to destroy desert tortoise burrows, increasing stress to 

individuals or potentially causing mortality if burrows are occupied at the time of 

collapse. Tortoises often seek shelter under vegetation or other structures that provide 

shade from the desert sun. Mechanized clearing of these structures could harm individual 

tortoises. Desert tortoises also seek shelter under parked vehicles and travel along road 

grades. Increased vehicle use in the area could create increased risk of collisions with 

tortoise, resulting in injury or mortality. In addition to measures already discussed, 

including the WEAP, Revegetation Plan, and Invasive Species Monitoring and Control 

Plan, which could help reduce effects on desert tortoise, Eagle Crest proposes the 

following measures to reduce the effects of construction on this species: pre-construction 

and clearance surveys; monitoring during construction; exclusion fencing; and the Desert 

Tortoise Removal and Translocation Plan.

The applicant’s proposed transmission line would occupy about 82 acres of desert 

tortoise habitat. The proposed line includes 23 line support structures in the BLM 

DWMA, 24 structures in the Chuckwalla Unit of critical habitat, and 25 structures in 

other suitable habitat for desert tortoise. All of the structures within the BLM DWMA 

and critical habitat would be along a new transmission corridor and removed from 

existing transmission lines. For part of its length within the BLM DWMA and critical 

habitat (about 3.5 miles), the applicant’s proposed transmission line would run parallel to 

the existing Eagle Mountain Road and therefore occupy areas that are already disturbed. 

The remainder of the ROW would require clearing undisturbed areas that support desert 

tortoise habitat. The proposed substation would be outside the DWMA and the critical 

habitat area.
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The State Water Board’s recommendation would occupy a total of about 78 acres 

of desert tortoise habitat, including 74.3 acres within the Chuckwalla Unit of critical 

habitat (74 acres for the substation and 0.3 acre for transmission line structures). One 

line support structure would be located within the BLM DWMA, 3 structures within 

critical habitat, and 47 structures in other suitable habitat for desert tortoise. The majority 

of these structures would be adjacent to an existing transmission line. 

In FWS’ March 12, 2010, letter, it recommends Eagle Crest relocate the 

transmission line out of desert tortoise critical habitat. FWS recommends Eagle Crest colocate the new line with existing transmission lines near the project site to reduce the 

addition of new perching areas for predatory birds within the critical habitat area. 

To reduce effects on desert tortoise, Eagle Crest would remove all tortoises from 

harm’s way during the construction period (Measure DT-1) following conditions and 

guidelines in the Desert Tortoise Removal and Translocation Plan (discussed below). For 

linear facilities, Eagle Crest’s biological monitors would first survey for all desert 

tortoises that might be within construction zones or are likely to enter construction zones, 

immediately prior to the start of construction. The biological monitors would identify 

active burrows, and insert a 3-inch stick into the floor of the runway to monitor tortoise 

use (as tortoises enter or exit the burrow, the stick would be displaced and point in the 

direction of movement). Biological monitors would map the locations of all tortoises so 

that those locations could be monitored for tortoise use during construction.

In the central project area, Eagle Crest would first conduct surveys to determine 

the presence of desert tortoise. If there is any suggestion of tortoise presence, either due 

to the presence of tortoise habitat and/or tortoise sign, Eagle Crest would erect exclusion 

fencing and complete a clearance survey to remove tortoises from within the fenced area

(Measure DT-3). Biological monitors would complete a minimum of two clearance 

passes inside this area with each survey occurring during periods with heightened tortoise 

activity, from mid-March to mid-April and during October. 

Eagle Crest does not propose to conduct any activities within unfenced areas on 

the linear facilities without biological monitors present (Measure DT-2). This includes 

both construction monitoring and maintenance activities that require surface disturbance. 

Qualified biological monitors meeting FWS and California DFG certification 

requirements would remove all tortoises following FWS and California DFG guidelines. 

Eagle Crest would avoid active burrows and special-resource burrows where possible. 

Where avoidance of any burrow is infeasible, biological monitors would determine 

occupancy through the use of fiber optics, probes, or mirrors. Monitors would then 

excavate the burrow with hand tools in the method prescribed by Desert Tortoise Council 

(1999), Guidelines for Handling Desert Tortoises during Construction Projects. Any 

tortoises found would be removed from the construction area. Along the water pipeline, 

Eagle Crest would close, cover, or fence trenches at the end of each day. Biological 

monitors would survey open trenches at first light, midday, and at the end of each day to 

ensure tortoise safety.
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If necessary, Eagle Crest would install temporary fencing in the active work area 

to separate a tortoise from active construction to maximize protection. If a tortoise is 

injured or killed, Eagle Crest would cease all activities and contact the project biologist. 

Injured tortoises would be taken to a qualified veterinarian if the tortoise is expected to 

survive. FWS would determine if the tortoise can be returned to the wild, if it recovers. 

Following site clearance, Eagle Crest’s project biologist would prepare a report 

documenting the clearance surveys, construction monitoring, the capture and release 

locations of all tortoises found, individual tortoise data, and other relevant data. Eagle 

Crest would submit this report California DFG and FWS.

Eagle Crest proposes to enclose the substation with a permanent tortoise exclusion 

fence to keep adjacent tortoises from entering the site. The fencing type would be 1- by 

2-inch vertical mesh galvanized fence material, extending at least 2 feet above the ground 

and buried at least 1 foot. Where burial is impossible, the mesh would be bent at a right 

angle toward the outside of the fence and covered with dirt, rocks, or gravel to prevent 

the tortoise from digging under the fence. Eagle Crest would construct tortoise-proof 

gates at site entry points. All fence construction would take place in the presence of 

biological monitors to ensure that no tortoises are harmed. Following installation, 

biological monitors would inspect the fencing monthly and during all major rainfall 

events and conduct any necessary repairs immediately.

Any areas in the central project area that are determined through surveys to require 

fencing would be fenced as outlined above. Where a fence is discontinuous (between 

tailings piles for example), the fence ends would extend well up the slope of the piles to 

ensure that tortoises cannot go around the end. Alternative methods may be explored to 

ensure that the fences are functional at excluding tortoises.

For both the central project area and the linear facilities, any necessary relocation 

of individual tortoises would require movement only to suitable habitat in the immediate 

vicinity (Measure DT-4). In response to the Commission’s request for additional 

information, Eagle Crest filed its Tortoise Removal and Translocation Plan on October 

27, 2009. This plan includes specific measures Eagle Crest would implement when 

relocating tortoises. These measures include:

• Descriptions of acceptable habitat where tortoises can be placed;

• Data to be collected from each capture/relocation event;

• Procedures for protecting tortoises encountered along roadways;

• Procedures for protecting tortoises encountered during periods with extreme 

high temperature (>43 degrees Celsius or 109°F);

• Approved methods for carrying tortoises; and

• Procedures for post-release monitoring.
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Finally, Eagle Crest proposes to offset effects on tortoise habitat with the purchase 

of a minimum of 160 acres of suitable tortoise habitat for conservation purposes 

(Measure DT-6). Eagle Crest would purchase this land in the habitat range for the same 

population of desert tortoises that occupy the project area. Eagle Crest would use the 

following criteria to identify suitable parcels for purchase:

• Lands that are part of larger block of lands that are currently protected or able 

to be protected;

• Lands that are not subject to intensive habitat degradation (e.g., recreational 

use, grazing use, agriculture);

• Lands that have inherently moderate-to-good habitat that would naturally and 

ultimately regenerate when current disturbances are removed;

• Lands that are bordered by native habitat suitable for tortoises; and

• Lands that represent a buffer for a block of good habitat.

Our Analysis

As currently proposed, construction of the project would occur within both FWSdesignated critical habitat and BLM DWMA. Additional habitat outside of these 

designated areas is also known to support this species. Therefore, construction of the 

project would be likely to affect desert tortoise through the removal and/or disturbance to 

occupied and protected habitat. 

The State Water Board’s recommended transmission line would be located 

adjacent to, but outside of the DWMA, and would cross only a small section of critical 

habitat immediately north of the substation. Construction of the alternative substation 

would disturb 74 acres of critical habitat. However, these effects would be concentrated 

in a location with generally low habitat quality and few recorded occurrences of desert 

tortoise. Additionally, the transmission line would comply with the FWS’

recommendation to co-locate the line with existing transmission lines. Therefore, the 

State Water Board’s recommendation would have lesser effects on desert tortoise.

Eagle Crest proposes measures that would provide multiple layers of protection 

from project effects including pre-construction surveys and clearance surveys to identify 

tortoises in unsafe locations, development of procedures for the safe relocation of these 

individuals, and development of measures to prevent tortoises for entering unsafe 

locations after they are cleared. These measures are consistent with FWS’ recommended

measures for handling desert tortoise (FWS, 2009). Additionally, Eagle Crest would 

allow only employees who meet FWS standards to handle tortoises. Eagle Crest’s 

proposed measures would substantially reduce the risk of project construction effects on 

desert tortoise. Staff finds construction of the project may affect but is not likely to 

adversely affect desert tortoise.
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The NECO Plan states that all lands within a DWMA would be designated as 

Category I Desert Tortoise Habitat, with required compensation of 5 acres for every acre 

disturbed. All lands outside a DWMA are considered Category III habitat, with a 

1:1 compensation ratio. Eagle Crest’s proposed purchase of 160 acres of compensation 

lands is based on the proposed project disturbing 19 acres of Category I habitat and 

65 acres of Category III habitat. However, construction of the State Water Board’s

recommendation, as staff recommends, would result in different levels of disturbance to 

Category I and Category III habitat. The specific acreages of disturbance would depend 

on whether the extent to which applicant constructs the interconnection substation or 

whether the substation is first constructed as a component of the Desert Sunlight Solar 

Farm (BLM, 2010a). If Eagle Crest were to recalculate the disturbance to Category I and 

Category III habitat after completing the interconnection design and recalculate 

appropriate acreages of compensation lands, the area of compensation would be more 

appropriately tied to project effects.

Effects of Operation on Desert Tortoise

Operation of the project would increase surface water availability to predatory 

species including ravens, gulls, and coyote. Additionally, the presence of the 

transmission line could provide additional perching and nesting area for predatory birds. 

By providing increases in these resources, the project could result in increases in the 

population size of these species in the vicinity of the project. Because these species are 

known to prey upon desert tortoise, such population increases could pose an increased 

risk of predation to this species and result in population reductions. Project maintenance 

activities would also pose a risk to the desert tortoise. These risks would depend on the 

specific activity required for project maintenance, but vehicle collisions would probably 

most likely. Finally, the project would permanently occupy or disturb 84 acres of desert 

tortoise habitat, reducing habitat availability for this species.

Interior, in its March 12, 2010, letter, recommends that Eagle Crest relocate the 

transmission line out of desert tortoise critical habitat. Interior recommends Eagle Crest 

co-locate the new line with existing transmission lines near the project site to reduce the 

addition of new perching areas for predatory birds within the critical habitat area. FWS 

also comments that where the new transmission line could not be co-located with existing 

lines, the new line would result in increased perching and nesting structure for desert 

tortoise predators. FWS recommends Eagle Crest avoid creating such an environment 

where predation rates on desert tortoise could increase.

The proposed transmission would result in the creation of a new utility corridor 

removed from pre-existing transmission lines. Under these conditions, the transmission 

line structures would likely provide suitable perching and nesting habitat for ravens, 

potentially increasing predation risk to desert tortoise. Conversely, the State Water 

Board’s recommended transmission line would parallel an existing 160-kV line supported 

with wooden H-frame structures.
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To reduce the potential for project operations to result in increased predation on 

desert tortoise, Eagle Crest developed a Raven Monitoring and Control Plan. In response 

to the Commission’s request for additional information, Eagle Crest filed a completed 

draft of this plan on October 27, 2009. Specific components of the plan include the 

following:

• Identifying specific project components with potential to attract ravens;

• Conducting surveys during project construction (years 1 to 3) to determine 

baseline conditions of raven populations on project lands and within 1 

kilometer of the project boundary;

• Conducting post-construction monitoring to detect changes in raven population 

size, nesting behavior, or evidence of tortoise predation (once every 5 years for 

the duration of the license);

• Development of a trash and food waste management program;

• Hazing measures at project reservoirs and desalination ponds;

• Procedures for removing raven nests, if determined necessary through 

consultation with FWS;

• Procedures for reporting study results to management agencies; and 

• Thresholds for success or need for additional control measures.

Finally, during project maintenance activities where ground disturbance would 

occur, Eagle Crest would ensure qualified biological monitors are present. These 

monitors would use methods and procedures described above to protect desert tortoise.

The Park Service filed comments on the final license application on March 11, 

2010. In its letter, the Park Service comments that Eagle Crest’s management of desert 

tortoise predators should not be limited to ravens, but also include coyote, wild dogs, 

gulls, and other potential predators.

In response to this comment, Eagle Crest notes that the project reservoirs would 

not be the only water source in the area and that existing sources, including the CRA, 

Metropolitan Water District’s pumping station reservoir, wastewater treatment ponds, 

and agricultural irrigation systems also subsidize predator species. Eagle Crest contends 

that since water is constantly available from these sources, water supply is not a limiting 

factor on predator species population size in the project vicinity. Eagle Crest also notes 

that if monitoring indicates increases in gull, coyote, or other desert tortoise predator 

species, the Raven Monitoring and Control Plan is designed to be expanded to address 

these predator species as an adaptive management measure.
129

Our Analysis

Operation of the project would increase available water sources for desert tortoise 

predators. The completed transmission line would provide additional perching and 

nesting locations for ravens and other predatory birds. However, since neither of these 

resources appear to be limiting factors (both are readily available in the project vicinity),

the extent to which these additional resources would support increases in predator 

populations in not clearly evident. On the other hand, without successful implementation 

of mitigation for these effects, there is potential for adverse effects on the desert tortoise.

Eagle Crest’s proposed measures include surveys to determine base line conditions 

for raven populations in the project area; and, a plan for follow up surveys to quantify the 

effects of project facilities on raven population size. Although Eagle Crest notes that 

these surveys would also detect increases in gull, coyote, or wild dog populations, the 

mechanism for such detections is not clear; the Raven Monitoring and Control Plan does 

not include any surveys for these species. If Eagle Crest amends the current Raven 

Monitoring and Control Plan to include baseline and post-construction survey methods 

for coyote, wild dogs, and gulls and develops mitigation measures to be implemented if 

increases in population levels are detected, in turn developing a desert tortoise predator 

control plan, as the Park Service recommends, effects on desert tortoise would be 

reduced.

Eagle Crest’s description of the raven survey schedule includes 3 survey years 

during construction followed with surveys once every 5 years for the duration of the 

license. However, it is unclear whether the post construction surveys would commence 

during the year of project completion, or 4 to 5 years following project completion. If 

project operation supports an increase in tortoise predator species, there is potential for 

adverse effects if a 4- to 5-year time lapse occurs between the baseline surveys and the 

first post-construction survey. If Eagle Crest includes in the desert tortoise predator 

control plan, a survey schedule that includes initiation of post-construction surveys 

during the second year after project completion, followed by surveys once every 5 years, 

any initial increases in tortoise predator populations would be detected, and 

implementation measures could be implemented to reduce effects on desert tortoise.

Any reasonable efforts Eagle Crest can make to locate the line outside of desert 

tortoise critical habitat and co-locate with other transmission lines would be beneficial. 

Co-locating lines near existing lines would still add potential perching and nesting 

habitat, but the quality of this habitat would be lower than the habitat that would be 

created by adding new structures to areas where transmission lines are not already 

present. Minimizing the number of new structures constructed in desert tortoise critical 

habitat areas would reduce the creation of new perching and nesting habitat in these 

areas. Implementation of the revised desert tortoise predator control plan and Eagle 

Crest’s other proposed measures, including habitat compensation and monitoring during 

maintenance activities, would reduce potential effects of project operation on desert 

tortoise. 
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Eagle Crest’s proposed WEAP, Desert Tortoise Removal and Translocation Plan, 

Raven Monitoring and Control Plan, and proposed compensation for disturbance to desert 

tortoise habitat would reduce potential effects of construction and operation of the project 

on desert tortoise. Staff’s recommended modifications to these measures, including the 

desert tortoise predator control plan and co-locating the transmission line with existing 

SCE line, as the State Water Board recommends, would further reduce potential effects 

on this species. However, surveys have shown the project area to support a population of 

desert tortoise, with multiple live tortoises, tortoise scat, and tortoise remains observed 

along proposed project features. As such, it is likely encounters between desert tortoise 

and construction and/or maintenance crews would occur. These encounters would likely 

result in the need to handle tortoises for removal to other areas and disturbance to or 

destruction of tortoise habitat. Such interactions, even when conducted following FWS 

guidelines and with the best of intentions, would increase stress and potentially result in 

desert tortoise mortality. Additionally, permanent effects would occur within the 

Chuckwalla Unit of designated critical habitat. Therefore, staff finds the proposed 

project, with staff-recommended modifications, may adversely affect desert tortoise and 

critical habitat for this species.

3.3.4.3 Cumulative Effects

The proposed project would not affect Coachella Valley milkvetch and would not 

contribute to any cumulative effects on this species in combination with other foreseeable 

actions in the vicinity.

Construction and operation of the pumped storage project, the Eagle Mountain 

landfill (see Land Use in section 3.3.5), and multiple solar projects proposed in the 

Coachella Valley all have the potential to affect desert tortoise. These effects include 

both direct disturbance and removal of suitable habitat. As discussed above, the Eagle 

Mountain Project would have a relatively small contribution to cumulative effects on 

terrestrial resources in the central project area, when combined with the Eagle Mountain 

landfill. Similarly, the project’s contributions to cumulative effects on desert tortoise in 

this area are also negligible and Eagle Crest’s proposed measures would mitigate for 

these effects.

On the Coachella Valley floor, there are currently 11 proposed solar 

developments, totaling about 123,600 (± 35,000) acres, under review. There is little 

certainty as to how many of these projects will be constructed. Similarly, it is not 

possible to ascertain the acreage of suitable desert tortoise habitat these projects would 

occupy. However, compared to the scale of these potential projects the effects of the 

Eagle Mountain Project on desert tortoise habitat in the Coachella Valley (about 85 acres) 

is negligible. Eagle Crest’s proposed monitoring and mitigation measures would ensure 

the project does not contribute to adverse cumulative effects on the desert tortoise. Colocating project facilities with the Desert Sunlight Solar Farm, as the State Water board 

recommends, would also reduce cumulative effects on desert tortoise.
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3.3.5 Recreation, Land Use, and Aesthetics

3.3.5.1 Affected Environment

Regional Recreation Resources

Recreational resources in the region are primarily provided and managed by the 

Park Service and BLM and include some resources on lands owned by the state of

California. Activities within the region include hiking, camping, backpacking, hunting, 

scenic/wildlife viewing, rock hounding, rock climbing, mountain biking, horseback 

riding, and OHV use.

Joshua Tree National Park and Wilderness Area

The JTNP is the most visited public land for recreational resources in the project

vicinity. The JTNP encompasses nearly 792,000 acres of land, of which 585,000 acres 

have been designated wilderness under the Wilderness Protection Act of 1964 (Park 

Service, 2010). This 585,000-acre wilderness area surrounds the central project area on 

three sides (figure 8). At its closest point, the park boundary is located about 2 miles 

from the proposed project site within the inactive Eagle Mountain mine. The Park 

Service manages the JTNP, and there are trails that provide for motorized and nonmotorized forms of access. No existing or proposed project features are located inside 

the park or wilderness area. 

Access to the JTNP is from Interstate 10 to the south and from State Route 62 to 

the north. The JTNP offers a variety of dispersed recreational activities and camping. 

Due to its unique geology and rock formations, this area is internationally known as a 

prime rock climbing destination. Massive boulders and rock outcrops provide some of 

the best rock climbing in the United States. Skilled and novice technical rock climbers 

from around the world are attracted to the challenging climbing routes (BLM and 

California DFG, 2002). The JTNP continues to be a popular destination for both local 

and non-local residents and has increased visitation steadily over the past several years,

such that it is now considered a year-round destination. The wilderness area provides an 

opportunity for solitude in nature and for primitive recreation such as hiking, 

backpacking, and horseback riding. Opportunities abound for viewing, studying, and 

photographing a diversity of flora and fauna. 

Developed recreational facilities, including trails, camping, picnic, and day-use 

facilities, are more prevalent in the northwestern portion of the JTNP. In keeping with 

the management prescriptions of the wilderness area designation, recreational facilities in 

this segment of the park include a few backcountry roads and trails. Cottonwood Visitors 

Center greets visitors at the southern access road to the JTNP, while the northern portion 

is accessible from the Oasis Visitor Center near Twentynine Palms, and the West 

Entrance Station south of the town of Joshua Tree. All but one of the nine campgrounds 

within the JTNP are located in the western half of the park. 
132

Figure 8. Recreation resources in the vicinity of the proposed project (Source: Eagle Crest, 2009a, as modified by 

staff).
133

Backcountry hiking and camping are popular in the park. Trails and facilities are 

more limited in the eastern half nearest the proposed project area; however, this area of 

the JTNP is home to more than 30 abandoned mines, an attraction to some visitors. One 

backcountry unpaved road, Black Eagle Mine Road, traverses canyon areas within the 

park and exits toward the proposed project area. The Big Wash Hiking Corridor is a Park 

Service trail within JTNP that follows the Big Wash arroyo from Victory Pass just south 

of the Metropolitan Water District’s pumping plant, west into JTNP and gradually 

turning northwest, terminating at Black Eagle Mine Road about 2 miles west of the 

eastern park boundary. 

The JTNP Backcountry and Wilderness Plan (Park Service, 2001) identifies an 

overnight restriction area (day-use only) within the wilderness area, bordering the park 

boundary, and about 2 miles due south of the proposed reservoirs site. There are no 

roads, trails, or trail corridors identified in the plan that indicate there is access to this day 

use only area at the present time or planned for the future.

Bureau of Land Management

The majority of recreational opportunities on BLM lands includes hiking and 

OHV use. BLM maintains an inventory of trails and areas open or closed to OHV 

activity. BLM also maintains several primitive campsites within the region.

Existing Recreation Resources in the Proposed Project Vicinity

Recreational resources in the project area are primarily dispersed opportunities on 

public lands; however, there are a small number of developed amenities. Public lands in 

the vicinity of the Interstate 10 corridor and Chuckwalla Valley include Ford Dry Lake 

and Palen Dry Lake, which are OHV use areas managed by BLM. Additionally, BLM 

manages the Chuckwalla Valley Dune Thicket and Alligator Rock, both Areas of Critical 

Environmental Concern (ACEC) located near Interstate 10. These areas are designated 

for the protection of wildlife and other resources. The Desert Lily Sanctuary is a 2,040-

acre preserve adjacent to State Route 177 about 8 miles southeast of the proposed 

reservoir site. In addition to the JTNP and wilderness area, other designated wilderness 

areas in the vicinity include the BLM-managed Chuckwalla Mountains wilderness area 

south of Interstate 10 outside Desert Center; the Palen/McCoy wilderness area east of 

State Route 177; and the Orocopia Mountains wilderness area southwest of Desert 

Center. There are no developed facilities at any of these locations other than gravel 

parking and signage at the Desert Lily Sanctuary. BLM allows overnight (overflow) 

camping on a gravel lot north of Interstate 10 just outside the south entrance to JTNP. 

Developed recreational facilities in the area include a museum, golf course, and 

campground. The General Patton Museum is located just off Interstate 10 at Chiraco 

Summit. This facility also borders a large historic area known as Camp Young, which 

was established as a desert warfare practice area during World War II. The small 

community of Lake Tamarisk, located about 5 miles southeast of the proposed project 

area, has a 9-hole golf course (see figure 9). BLM operates the only developed 
134

Figure 9. Land ownership in the vicinity of the proposed project (Source: Eagle Crest, 2009a, as modified by staff).
135

campground outside JTNP in the vicinity of the proposed project, Corn Springs in the 

Chuckwalla Mountains Wilderness, about 7 miles south of Desert Center. A private 

business has proposed to develop the Desert Center Airport off State Route 177 east of 

Lake Tamarisk into a large-scale motocross facility with multiple tracks, grandstands, 

clubhouses, and other associated facilities. According to the developer’s web site, they 

are currently looking for investors. 

Visitation

The majority of recreation activity in the region occurs within the JTNP. The park 

received almost 1.4 million visitors in 2008, with 3,895 recorded backcountry stays (Park 

Service, 2008). Most of the park’s developed facilities lie to the west of the main, paved 

park road, with the exception of Cottonwood Springs Visitor Center and its associated 

facilities. Recreation facilities on the east side of the park are minimal and, as such, 

recreation use on the east side of the park is relatively sparse, as is information about the 

number of users in this portion of the park. The JTNP Management Plan notes that only 

about 0.5 percent of visitors to the park spend the night in the back country (Park Service,

2001). The backcountry wilderness registration board closest to the proposed project is 

located at Porcupine Wash on Pinto Basin Road just west of the intersection of Black 

Eagle Mine Road and Old Dale Road. Miscellaneous backcountry use in the southeastern 

portion of the park over the past 5 years has ranged from between 3,900 to 5,900 usernights annually (Eagle Crest, 2009c). About 500 of these user-nights are estimated to be 

attributed to the eastern region of the Park (Eagle Crest, 2009c).

Day use of the east side JTNP lands prior to its inclusion into the park/wilderness 

system in 1994 relied on 4-wheel drive access to many locations (Park Service, 2001). 

Four-wheel drive/OHV use is prohibited within wilderness areas. Black Eagle Mine 

Road, an unmaintained dirt road, traverses a non-wilderness corridor in this eastern 

section of the park, and continues beyond the park boundary to the Eagle Mountain mine 

and proposed project site. The park allows only road-licensed 4-wheel drive vehicles to 

access this road, and it is used by both locals and tourists; however, the Park Service does 

not maintain vehicle counters along the road. Based on its experience, Park Service staff 

estimated that the road may see about 1,000 day-use visits in a season (Eagle Crest,

2009c). The Black Eagle Mine Road is barricaded with a large boulder in the middle of 

the road about 3 miles east of the JTNP boundary. The road block is positioned at the 

apex of the saddle of the Eagle Mountains running north-south, precluding vehicular 

access between the park and the Eagle Mountain mine site. About 5 to 10 abandoned 

mines are located short distances off of Black Eagle Mine Road along the route within 

the JTNP boundary. 

Outside of JTNP, OHV use is the primary dispersed recreational activity in 

the area. OHV use has long been a major part of the recreation in the area, and,

nationally, OHV use has increased five-fold in the last 3 years (BLM, 2010b). As noted 

previously, BLM maintains an inventory of trails that indicates areas open or closed to 

OHV activity. There are no BLM OHV areas designated as “open” within Riverside 
136

County, where riding off designated routes is permitted. All BLM lands throughout the 

region are designated “limited use” for OHV purposes, meaning that all vehicles must 

remain on designated routes of travel. There are no estimates of the amount of 

recreational use these lands receive.

Similarly, BLM does not keep records of visitor use at the few camping areas in 

the vicinity (e.g., Corn Springs campground, JTNP dispersed camping overflow area, 

general dispersed camping). BLM has noted as part of the review of the NECO Plan that 

this area receives little recreational use (Eagle Crest, 2009a). 

Land Use

Land Use in the Project Area

Much of the land surrounding the Eagle Mountain mine is public land managed 

primarily by the Park Service and BLM. Communities in the vicinity of the proposed 

project include the town of Eagle Mountain, Lake Tamarisk, and Desert Center. Kaiser 

developed the town of Eagle Mountain, which is located adjacent to the Eagle Mountain 

mine, to house mine workers. The town site consists of about 250 single-family 

dwellings, a store, café, two churches, a school, and a post office among other features. 

After the mine closed in 1986, the town became largely vacant; however, a few Kaiser 

employees maintain residence there. California Department of Corrections contracted 

with private prison operators to house low-risk inmates in renovated facilities that 

occupied the old town shopping center between 1986 until its closing in 2003. The 

correctional facility included housing units in four pods. When operated as a state 

facility, the rated capacity was 436 minimum security beds. Riverside County board 

members studied the site as a potential county correctional facility; however, the 2007 

feasibility study (DMJM Design/AECOM, 2007) recommended the County should not 

pursue this as an option.

Lake Tamarisk and Desert Center are located about 9 and 10 miles southeast of the 

Eagle Mountain mine, respectively. Both towns are small communities with fewer than 

100 single-family dwellings combined. Both communities as well as Eagle Mountain are 

accessed by Kaiser Road, which connects to Interstate 10 at Desert Center.

Land Use Within and Adjacent to the Proposed Project Boundary

Reservoir and Construction Laydown Areas—The site consists of mountainous, 

rocky terrain that has been extensively disturbed as a result of past mining activity. 

Inactive open pits, tailings piles, and remnant tailings ponds exist on site. Remnants of 

the structures associated with the previous mining, including railhead, haul roads, and ore 

processing/refining facilities, still exist, although most of the ore processing and refining 

facilities have been removed.

The central project area occupies only a portion of the acreage encompassing the Eagle 

Mountain mine area. Kaiser has proposed to develop much of the area between the two 
137

open mine pits proposed as the upper and lower reservoirs for this project as a landfill. 

As part of the landfill proposal, BLM would exchange about 3,500 acres of public land 

within the area for offsite private lands to support the landfill project in the mine area. 

Figure 10 provides the phasing and layout of the proposed landfill project. If the land 

exchange were not to be consummated, the project boundary for the proposed project 

would include nearly 1,059 acres of federal land managed by BLM. If the land exchange 

is executed, 676 acres of the proposed project features would be on federal lands. The 

California State Lands Commission holds a 100 percent mineral interest on 467 acres 

surrounding the proposed lower reservoir site. 

Water Pipeline Corridor—Water for the proposed project would originate from 

three wells in the Chuckwalla Valley about 11 miles from the proposed reservoirs. Water 

from the wells would be conveyed to the lower reservoir via pipeline extending alongside 

existing roads and a Metropolitan Water District transmission line corridor within a 

proposed 60-foot-wide pipeline ROW. 

Land uses adjacent to the corridor consist primarily of undeveloped desert land. 

The southern third of the proposed route would cross several private parcels with inactive 

agricultural fields. The remainder of the route would consist of undeveloped federal land 

managed by BLM. As the proposed route approaches the Eagle Mountain area, it would 

cross the CRA before reaching the lower reservoir (figure 9).

Transmission Line Corridor—The proposed route for the project’s double-circuit 

500-kV transmission line would be located almost entirely on public lands managed by 

BLM. Exceptions include private lands within the project boundary owned by Kaiser and 

a small crossing of land owned by the Metropolitan Water District as the route crosses 

the existing district’s aqueduct and transmission lines. Eagle Mountain proposes a 200-

foot-wide corridor for construction, operation, and maintenance of the proposed 

transmission line. The proposed route would extend about 13.5 miles from the proposed 

project switchyard south-southeast to a proposed interconnection collector substation that 

would interconnect with the proposed Devers-Palo Verde No. 2 transmission line located 

near Desert Center.

The transmission line would exit the project switchyard and extend south to a 

point on the west side of the Eagle Mountain rail line. At this point, the route turns 

southeast to a location adjacent to existing SCE 161-kV wood pole transmission lines. 

Here, the line would turn to parallel the existing transmission lines and access road, 

crossing the Metropolitan Water District’s metal tower electric transmission structures 

and passing to the east of the Metropolitan Water District’s pumping plant. Most of this 

route segment from the mine to the Metropolitan Water District’s pumping plant would 

be located on public land managed by BLM, except for a small parcel of land around the 

CRA and Aqueduct Road owned by Metropolitan Water District. This area of the 

proposed transmission line is undeveloped except for a number of unpaved access roads, 

the paved Aqueduct Road, and existing transmission lines.
138

Figure 10. Proposed phasing of the land fill project (Source: Eagle Crest, 2009a, as 

modified by staff).

East of the Metropolitan Water District’s pumping plant, the transmission line 

route would cross over a pass in the small hills near the Eagle Mountain railroad. At this 

point, the route would turn southwest for a short distance before turning south to parallel 

the existing Eagle Mountain Road. The route would continue to parallel Eagle Mountain 

Road for about 3 miles, then turn southeast and continue for another 2.5 miles to the 

proposed substation. Land use in the location of the proposed substation is undeveloped 

desert; rural open space as designated in the County’s General Plan. South of the 

proposed substation, low density residential development exists as a part of 

Desert Center. 

Plans

BLM is the primary land manager in the region. The entire proposed project area 

is located within the 25-million acre California Desert Conservation Area (CDCA), of 

which about 12 million acres are public lands. The California Desert Conservation Area 

Plan (BLM, 1980) is the BLM’s land use plan for the CDCA. The general goal of the 
139

CDCA Plan is to provide for the use and protection of the desert’s natural, cultural, and 

aesthetic resources. This plan specifies that activities on BLM-managed public lands 

must conform with the approved land use. 

Public lands under BLM management within the CDCA have been designated 

geographically into four Multiple Use Classes. The majority of the proposed project site 

itself is not designated because it is largely or entirely private land and therefore not 

directly under BLM stewardship. The plan does provide Multiple Use Class designations 

for portions of the proposed project site and directly adjacent public land. Public lands 

are assigned a Multiple Use Class according to the following allowable level of multiple 

uses. 

• Class “C” (controlled use) designation is the most restrictive, and is assigned to 

wilderness areas; 

• Class “L” (limited use) lands are managed to provide lower intensity, carefully 

controlled multiple uses while ensuring that sensitive resource values are not 

significantly diminished; 

• Class “M” (moderate use) lands are managed to provide for a wider variety of 

uses such as mining, livestock grazing, recreation, utilities, and energy 

development, while conserving desert resources and mitigating damages that 

permitted uses may cause; and 

• Class “I” (intensive use) provides for concentrated uses of lands and resources 

to meet human needs (BLM, 2002). 

The proposed reservoirs and surrounding area are included within one of six 

concurrent CDCA Plan amendments—the NECO Plan, a plan developed for a geographic 

subset of the larger CDCA. Public lands west of the Kaiser lands but east of the JTNP 

boundary are managed as Multiple Use Class-L, and public lands east of the Eagle 

Mountain mine are managed according to Multiple Use Class-M guidelines. 

The CDCA Plan identifies designated utility corridors targeted for transmission 

lines, pipelines, and related structures such as substations and compression stations and 

indicates that applications for utility rights-of-way will be encouraged by BLM 

management to use designated corridors (BLM, 1980). The plan states that sites 

associated with power generation or transmission not identified in the CDCA Plan will be 

considered through the plan amendment process (BLM, 1980). 

Routes within defined corridors and on BLM-managed lands require authorization 

of a ROW grant from BLM. Figure 9 identifies the current BLM Multiple Use Classes 

relative to the project and the CDCA Plan utility corridors.

Riverside County—The project study area lies within Riverside County’s Desert 

Center Land Use Planning Area. The vast majority of the planning area is classified as 

Rural Open Space and zoned as Natural Assets. Within the Desert Center Land Use 

Planning Area, Riverside County has established two specific policy areas. Policy areas 
140

are specific geographic districts that contain unique characteristics that merit detailed 

attention and focused policies. The Eagle Mountain policy area encompasses the 

proposed project site and the Eagle Mountain town site. Outside this specific policy area 

boundary, “Rural Open Space” dominates the county land use designation, with the 

exception of an area of “Rural Open Space-Mineral Resources” to the north/northwest of 

the proposed reservoirs area. Riverside County zoning and land use plans identify the 

Eagle Mountain mine site as a landfill site.

34

The Desert Center policy area encompasses currently undeveloped land located 

adjacent to and north of the small, unincorporated community of Desert Center. The 

terminus of the proposed transmission line and substation would be included within this 

policy area.

 

Joshua Tree National Park—The JTNP was established first as a national 

monument in 1936 and later changed to a National Park in 1994. As noted previously, 

the Eagle Mountain wilderness area is within the park boundary. The closest part of the 

JTNP is located within 2 miles of the proposed project area and is designated by the Park 

Service as backcountry transition or wilderness subzones. Lands within the backcountry 

transition subzone are managed to maintain the natural resources and processes that are 

unaltered by human activity except for approved developments essential for use and 

appreciation such as park roads, picnic areas, and backcountry parking areas. This 

designation applies to the Black Eagle Mine Road corridor. The remainder of the area 

outside the road corridor is designated as a wilderness subzone, and no development is 

allowed. The wilderness area designation allows only non-motorized, non-mechanized 

activities to occur within its boundaries, with minimal trail creation and maintenance.

Aesthetics

The proposed project is located about 10 miles north of Desert Center, California, 

less than 60 miles from the Colorado River. This area of California is generally referred 

to as the western Sonoran Desert, or more commonly called the “Colorado Desert,” and 

includes the area between the Colorado River Basin and the Coast Ranges south of the 

 

34 Specific Plan 305 was approved on September 8, 1997 (Riverside County, 

1997). Specific plans are for land use for the development of large property holdings, 

which are otherwise eligible for development under the Riverside County General Plan. 

Specific Plan Zone shall be applied only to property for which a specific plan of land use 

has been adopted; provided, however, that the Specific Plan Zone may be adopted 

concurrently with a specific plan. The zone shall be applied only upon a finding that the 

specific plan of land use contains definitive development standards and requirements 

relating to land use, density, lot size and shape, siting of buildings, setbacks, circulation, 

drainage, landscaping, architecture, water, sewer, public facilities, grading, maintenance, 

open space, parking, and other elements deemed necessary for the proper development of 

the property.
141

Little San Bernardino Mountains and the Mojave Desert. The overall character of the 

area is a combination of arid and semi-arid landscapes alternating between basins and 

mountain ranges. Local elevations range from about 400 to 2,500 feet, while regionally 

the San Bernardino Mountains 100 miles west of the area rise up to about 11,500 feet and 

the Salton Sea, about 50 miles southwest of the area, is 227 feet below sea level. 

The proposed project components would be located in an area that is visually 

characterized by broad, flat desert valleys bordered by highly eroded mountain ranges. 

The arid environment and low lying, sparse vegetation provide long views across the 

desert landscape from key view points. One of the visually striking features of this area 

is how abruptly the mountains rise above the valley. The proposed project would be 

located within an inactive iron-ore mine site within the Eagle Mountains with the 

transmission and water pipelines running across the Chuckwalla Valley. The valley is a 

mostly flat desert bordered by the Eagle Mountains to the west, the Coxcomb Mountains 

to the north east, and the Chuckwalla Mountains to the south. The small communities of 

Lake Tamarisk and Desert Center are located within this valley near Interstate 10 about 9

and 10 miles, respectively, south of the inactive mine.

BLM Visual Resource Management System

The BLM’s Visual Resource Management (VRM) system is a management tool to 

assist BLM in carrying out its mandate to ensure that the scenic values of the public lands 

are considered before allowing uses that may have negative visual effects. The VRM 

system involves inventorying scenic values and establishing management objectives for 

those values through the resource management planning process, and then evaluating 

proposed activities to determine whether they conform with management objectives. 

The visual resource inventory process provides BLM managers with a means for 

determining visual values. The inventory consists of a scenic quality evaluation, 

sensitivity level analysis, and a delineation of distance zones. Based on these three 

factors, BLM-administered lands are placed into one of four visual resource inventory 

classes. These inventory classes represent the relative value of the visual resources. 

Classes I and II represent the most valued resources, Class III represents a moderate 

value, and Class IV represents resources of least value. 

VRM classes are categories assigned to public lands and serve two purposes: 

(1) an inventory tool that portrays the relative value of the visual resources, and (2) a 

management tool that portrays the visual management objectives. The VRM system 

evaluates the quality of existing scenery by accounting for the distance from which 

scenery is viewed and peoples’ sensitivity to changes in the landscape. According to the 

VRM system, resource management classes comprise the following objectives: 

• Class I—The objective of this class is to preserve the existing character of the 

landscape. This class provides for natural ecological changes; however, it does 

not preclude very limited management activity. The level of change to the 
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characteristic landscape should be very low and must not attract attention. 

Areas of Critical Environmental Concern are classified as VRM Class I.

• Class II—The objective of this class is to retain the existing character of the 

landscape. The level of change to the characteristic landscape should be low. 

Management activities may be seen but should not attract the attention of the 

casual observer. Any changes must repeat the basic elements of form, line, 

color, and texture found in the predominant natural features of the 

characteristic landscape.

• Class III—The objective of this class is to partially retain the existing character 

of the landscape. The level of change to the characteristic landscape should be 

moderate. Management activities may attract attention but should not 

dominate the view of the casual observer. Changes should repeat the basic 

elements found in the predominant natural features of the characteristic 

landscape.

• Class IV—The objective of this class is to provide for management activities 

that require major modifications of the existing character of the landscape. 

The level of change to the characteristic landscape can be high. These 

management activities may dominate the view and be the major focus of 

viewer attention. However, every attempt should be made to minimize the 

effect of these activities through careful location, minimal disturbance, and 

repeating the basic elements.

BLM has not established visual resource management classes for lands within the 

Chuckwalla Valley or Eagle Mountain areas. Because the BLM VRM system is a wellestablished management tool, Eagle Crest conducted a draft VRM analysis and developed 

surrogate VRM Classes to help evaluate the potential effects of the project on visual 

resources areas part of its license application. Staff presents the applicant-devised 

surrogate VRM inventory classes below and shows them in figure 12: 

BLM Indicator Reservoirs Water Pipeline

Scenic Quality Class Rating

Transmission Alignment

IV III and IV II,III and IV

Existing Site-specific Aesthetics

Reservoir Area—The mountainous landscape of the proposed reservoirs site is 

dominated by the disturbances associated with major hard rock mining operations. 

Extensive pits created when the ore was removed are bounded by benched side walls and 

large tailing piles. Mined areas within the project area represent highly disturbed, 

human-modified landscapes consisting of large open pits, tailing piles and ponds, and the 

remains of ore processing facilities and mining equipment. The massive amounts of 
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tailing piles surrounding the mine exhibit regular terraces with some eroded qualities. 

The Eagle Mountain mine extends into the mountain slopes and presents a distinctly 

different visual character from the surrounding undisturbed portions of the mountains. 

The area around the mine is of considerable magnitude, and the contrast generated from 

the exposed tailing piles and storage of the excavated materials is visible from most areas 

within the Chuckwalla Valley north of Interstate 10. These piles contrast in shape, 

texture, and color with the surrounding unmodified landscape. Adjacent to the mine, the 

town of Eagle Mountain is largely composed of deserted homes and vacant buildings. 

Views beyond the inactive mine site include the Eagle Mountain backdrop, which 

precludes views into JTNP from lower elevation points. Views across the Chuckwalla 

Valley from the mine site are relatively unobstructed, providing long sight lines to the 

Coxcomb Mountains in the distance. Human-made disturbances that visibly stand out 

from the natural landscape include: roads, a railroad, transmission lines for the CRA, and 

wood distribution poles supplying electricity to the Eagle Mountain town site. High 

voltage transmission lines also parallel Interstate 10; however, about 11 miles away, the 

definition and contrast the lines provide against the natural surroundings is muted.

Transmission Line and Pipeline—Access to the Eagle Mountain mine site and the 

proposed transmission line and water pipeline corridors are through the Chuckwalla 

Valley. The valley is representative of desert basin features and consists of relatively flat 

to gently sloping topography that visually separates and accents the adjacent mountain 

ranges. The Chuckwalla Valley, like others in the region, is dominated by colors of the 

physical landscape: exposed rocks, sand, gravel, and sparse vegetation. After winters 

with above-normal precipitation, desert wildflowers provide a colorful ground cover. 

Overall, the visual characteristics are created by the combinations of alluvial washes, 

wind-blown landforms, and vegetation. 

The natural features of the Chuckwalla Valley are modified by residential and 

commercial developments, including the Eagle Mountain town site, Lake Tamarisk, and 

Desert Center. Linear landscape elements within this landscape unit include roads, 

transmission lines, railroads, OHV tracks, the CRA, numerous stormwater draining dikes 

for the interstate, and the Metropolitan Water District’s pumping station and related 

facilities. Primary transportation corridors within the unit include Interstate 10 and State 

Route 177. Kaiser Road is the main paved road from Desert Center to the proposed 

project site, Eagle Mountain Road is an alternative route, and other maintained and 

unmaintained dirt roads cross the valley. 

The expansive scale and flat topography of the valley offers panoramic views of 

the surrounding mountain ranges from many locations. The relatively flat and uniform 

landscape character is typical of the regional landscape setting.
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Key Viewpoints Associated with the Project

Many of the features associated with constructing the proposed project would be 

visible from public roads or lands that adjoin the proposed project site. Changes to the 

landscape would be most visible to people who use Kaiser Road, Eagle Mountain Road, 

Interstate 10, and State Route 177. Other important areas with views of the proposed 

project features include the small residential communities of Lake Tamarisk and Desert 

Center. Backcountry hikers in JTNP could also potentially see proposed project features 

from ridge tops at the park boundary.

Kaiser Road—Kaiser Road is the main travel route connecting Desert Center with 

the Eagle Mountain mine site. The road is about 9 miles long running north for twothirds of the route before turning northwest and directly toward the mine for the final 

one-third of the route (figure 8). Kaiser Road is also the main travel route from Interstate 

10 at Desert Center to Lake Tamarisk. The road runs primarily through the middle of the 

valley and views along the road are the low lying areas in all directions in the foreground 

with the various mountain ranges as the backdrop, depending on the direction. From 

Kaiser Road in Desert Center (about 10 miles away from the proposed reservoirs), the 

existing mining operations are visible on the Eagle Mountains as contrasting colors and 

lines from the exposed and stockpiled mine tailings. Similarly, from Lake Tamarisk 

(about 9 miles away from the proposed reservoirs), the view is similar in that the contrast 

of the mine tailings is visible in the distance in the middle of Eagle Mountain while the 

sparse desert vegetation covers the foreground and valley.

Views from Kaiser Road closer to Eagle Mountain mine show that the modified 

landscape surrounding the mine (e.g., flat tops or terraced tailing piles) is the most visible 

modification in the area. The human-modified landscape also includes visible grading 

for the CRA, the old mine railroad, and the transmission towers to the Metropolitan 

Water District’s pumping plant nearby. 

Eagle Mountain Road—Eagle Mountain Road is a paved, two-lane asphalt road 

that parallels Kaiser Road about 3 miles west of Desert Center. The road provides an 

alternative, and more direct, route to the Eagle Mountain mine via Interstate 10. Views 

from the road looking north toward the mine site from near Interstate 10 are similar to 

views from Kaiser Road in that the foreground is dominated by low-lying desert 

vegetation, framed by the Eagle Mountains on the western flank and the taller Coxcomb 

mountains in the far distance about 20 miles away.

Interstate 10 near Desert Center—Interstate 10 is a federal interstate highway that 

runs adjacent to Desert Center and receives heavy commercial and non-commercial travel 

use. Riverside County designated this portion of Interstate 10 as an Eligible County 

Scenic Highway. Similar to views from Kaiser and Eagle Mountain roads, the most 

visible human-made feature on the mountains is the contrast created by the Eagle 

Mountain mine tailing piles. The distance to the mine reduces the effect because the 

surrounding mountains are striking compared to the relatively flat valley floor. Because 
145

this desert setting with interspersed mountains and valleys covers hundreds of miles, 

drivers on Interstate 10 may be visually saturated with the regional landscape and would 

likely not notice the inactive mine while traveling at high speeds along the highway. 

Features in the foreground include the small commercial and residential buildings that 

comprise Desert Center, the small road network, and various transmission and 

distribution towers. Desert vegetation has been cleared in more areas surrounding the 

developed areas, showing a greater amount of the ground surface than in other locations 

further from town.

State Route 177 East and West of Lake Tamarisk—SCE maintains a transmission 

ROW that cuts across perpendicular to State Route 177 about 3 miles northwest of Lake 

Tamarisk. The ROW includes a maintained dirt road between a single wood pole 

distribution line and a taller double wood pole transmission line that runs directly toward 

the Eagle Mountain mine and proposed reservoirs site. Similar to the other viewpoints 

within the basin, the foreground is low lying vegetation with unobstructed views to the 

mountains that rise from the valley floor in the distance. Historical agricultural fields are 

adjacent to the highway, with the existing power lines in the foreground. The majority of 

these fields are not currently under cultivation; however, the remnants of the row 

cropping technique are still evident. The wood pole electric transmission system 

dominates the views in this area and is clearly visible, with little in the way of either 

natural or human-made structures to block their view, aside from the fact that the 

transmission system features are of similar color to the surrounding environment. 

Joshua Tree National Park—The JTNP surrounds the proposed reservoirs site on 

three sides, with the park boundary about 2 miles away at the closest point. The 

historical iron ore mining operations extended away from the pits for some considerable 

distance in order to stockpile the mine tailings, and evidence of the greater mine footprint 

(extent of operations) is visible in aerial photography and comes within 1,000 feet of the 

park boundary at its closest point on the north side of the mine. Generally, this eastern 

park edge has very few visitor amenities. The Black Eagle Mine Road, within a nonwilderness corridor, provides vehicular access to the Eagle Mountains and connects the 

JTNP with the Chuckwalla Valley via the Eagle Mountain mine. Complete access is 

currently precluded by placement of a large boulder in the middle of the road about 2 

miles outside the JTNP boundary. The mine area and the proposed reservoirs would be 

clearly visible from the ridge tops within the JTNP because the views would be 

unobstructed and the proposed facilities would be in the foreground. This area of JTNP 

has some historical mines, which may draw hikers exploring the rugged terrain; however, 

the number of visitors to the entire southeastern portion of the park is low, and few 

people venture to the ridge tops near the proposed project site.
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3.3.5.2 Environmental Effects

Recreation

Effects of Construction on Recreation Resources 

Within the Chuckwalla Valley, construction activity would occur within the Eagle 

Mountain mine area (proposed reservoirs, intake/outlet structures, and other 

infrastructure necessary to operate the project); along Eagle Mountain Road (proposed 

transmission line); near Desert Center (proposed interconnect substation); and across the 

valley (water pipeline) from near the Desert Center airport to the Eagle Mountain mine

area. 

The proposed reservoirs and appurtenant facilities would be constructed within the 

existing Eagle Mountain mine, which uses private lands, precluding public access to the 

area. There are no existing developed recreation facilities. Public access restrictions are 

proposed to continue during the construction period and during operations. The proposed 

landfill project, discussed in more detail in Land Use, could potentially share other 

adjacent mine pits, which would also preclude public access to these areas. 

According to maps developed by the applicant, about 2 miles of the water pipeline 

would cross BLM lands, and public access to these lands during construction activities 

would be precluded. The proposed route is adjacent to an existing transmission line 

ROW with wood pole towers under which is a maintained dirt access road. For about the 

last 3 miles, the pipeline would parallel Kaiser Road to the reservoir site.

Eagle Crest proposes to use the existing road network for access and construction 

laydown areas. Eagle Crest proposes to coordinate construction schedules with BLM and 

provide posted notices of construction activity and any temporary road/access closure. 

According to the proposed construction schedule, these activities would take place over a 

period of about 4 years (Measure REC-1). Eagle Crest proposes to use Eagle Mountain 

Road as the primary route for construction related traffic to and from the proposed 

reservoir site, as well as for construction of the proposed transmission line.

Our Analysis 

Construction of the proposed transmission line would use Eagle Mountain Road as 

the main artery for all related traffic (e.g., transporting materials, workers). Although the 

transmission line would use the Eagle Mountain Road as access to minimize unnecessary 

effects on the desert ecosystem from additional spur roads, construction traffic volumes 

and moving machinery on site to install transmission towers could result in road closures 

or substantial travel delays. The road does supply access to a number of dirt roads that 

provide access to the existing Metropolitan Water District transmission lines just outside 

the JTNP boundary. Hikers wishing to use the Big Wash Hiking Corridor, which 

connects Black Eagle Mountain Road in JTNP with Eagle Mountain Road near Victory 

Pass, would be inconvenienced by the presence and activities associated with installing 
147

the transmission line outside the park. However, Eagle Mountain Road is not a through 

road and the number of recreation users expected to be affected by construction activities 

would be low. Under the applicant’s proposal, posted notices would inform visitors 

wanting to use this road as access into JTNP or other dispersed areas in the vicinity about 

construction schedules and potential closures.

The volume of motorists affected by potential road closures due to water pipeline 

construction along Kaiser Road would be minimal and limited to vehicles traveling to the 

mine site where the road terminates. In addition to restricted access to the existing road 

under the existing transmission line, OHV and other dispersed recreation users, both 

north and south of the proposed pipeline, would see and hear the construction activity 

associated with trenching and installing the underground pipeline. 

No developed recreation facilities are located in the vicinity of the proposed 

interconnect substation; therefore, construction would not affect existing developed 

recreational facilities. The site’s proximity to Desert Center suggests dispersed recreation 

would not exist on these lands because better options exist elsewhere in the area. 

Aesthetic effects of construction such as hearing noise associated with construction and 

seeing construction equipment and vehicles are discussed later in this section under

Aesthetics. Any aesthetic effects associated with the construction vehicles would not 

continue beyond the project’s 4-year construction phase.

Effects of Operation on Recreation Resources

Eagle Mountain states that the reservoirs would be fenced, and access to the 

reservoirs and other nearby project features would be controlled through security gates 

and enforced with on-site personnel. The two proposed reservoirs and appurtenant 

facilities would occupy the Eagle Mountain mine site, which does not have any public 

recreation facilities and does not allow public access. 

Our Analysis

Because recreation was precluded prior to the proposed project, operations 

associated with the reservoirs, powerhouse, switchyard, brine pools, etc. would not affect 

existing developed or dispersed recreation activities within this area.

Comments received during scoping indicated concern that the proposed project 

may affect recreational use of nearby Chuckwalla Valley Dune Thicket ACEC (closest 

project feature is more than 20 miles away). No proposed project features would cross or 

displace lands within any ACEC within the region. This also includes the Desert Lily 

Preserve ACEC and Alligator Rock ACEC, which are closer to the project (closest 

project feature is less than 2 miles away). 

No developed recreation facilities are located in the vicinity of the proposed 

interconnect substation; therefore, operation of the substation would not affect existing 

developed recreational facilities. 
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Effects of Construction on Recreation in Joshua Tree National Park 

Construction activities would require blasting, heavy machinery, and security 

lighting, and would produce associated noises and air emissions during construction. The 

proposed reservoirs and portions of the transmission lines would be within about 2 miles 

of the JTNP boundary (see figure 8). 

Eagle Crest proposes to implement night sky monitoring in collaboration with the 

Park Service during construction and a trial operational period (to measure changes from 

baseline conditions and adjust project lighting if needed). Eagle Crest proposes that final 

lighting designs would incorporate directional lighting, light hoods, and operational 

devices that allow to be turned on as needed for safety. Eagle Crest also identifies low 

pressure sodium or LED lighting as potential light source types (Measure AES-1).

Our Analysis

Although the proposed project would be located outside the park, construction 

activities would be noticeable from points within the park. The degree to which this 

would degrade the values of solitude and lack of human influence must be weighed 

within the overall context of the setting. Human influences, including an extensive open 

pit mine, already exist adjacent to the JTNP and are visible from the same locations 

within the park from which proposed project features would be visible. The proposed 

reservoir area would use the mining area on the eastern slope of the mountains, and, if 

viewers were to reach ridge-top vistas at the extreme eastern boundary of the park, they 

would also see the larger, pre-existing impacts from historic mining operations and other 

human modifications to the landscape throughout the Chuckwalla Valley. This would be 

true for all points on the eastern slope of the Eagle Mountains within the park and these

areas that are not easily accessible or normally popular with JTNP visitors. 

Given the challenges and limited locations of possibly viewing or hearing 

construction activities, points off Black Eagle Mine Road, within JTNP, would provide 

visitors a vantage point to see into the proposed reservoirs. Staff estimate that the annual 

number of park users potentially affected by daytime construction would be in the low 

hundreds35

Construction of the proposed transmission line would occur within less than 1 mile 

at its closest point to JTNP, and slightly farther under the State Water Board’s

recommended transmission line. Construction may cause delays or conflict with visitors 

wanting to access the Big Wash Hiking Corridor on the eastern slope of the mountains 

near Victory Pass. These construction effects would last 4 years according to the Eagle 

Crest’s proposed construction schedule.

. Construction effects would begin in the first year and continue throughout 

the remaining period of construction, estimated by Eagle Crest to be 4 years.

 

35 Based on an estimated 1,000 visitors to the entire region in a year and only a 

fraction of those who would climb to the peaks for a view.
149

Construction security lighting or possible nighttime lighted construction activity 

would introduce additional artificial light sources to the Chuckwalla Valley; these effects 

could be minimized through design specifications. Backcountry campers seeking the 

remote nature of the eastern portion of the JTNP may experience a decrease in nighttime 

dark sky conditions, and the dark sky monitoring should quantify and guide design and 

product selection to help offset these conditions. 

Effects of Operation on Recreation in the Joshua Tree National Park 

Although the proposed project would be located outside the park, project features 

and night lighting would be noticeable from vantage points within the park. As noted 

previously, Eagle Crest proposes to implement night sky monitoring with the Park 

Service to help guide lighting product selection and design alternatives to minimize the 

amount of light pollution originating from the proposed project (Measure AES-1).

Our Analysis

Implementation of design techniques to minimize light pollution from security 

lighting surrounding the reservoirs and switchyard would concentrate light where it 

would be needed, reducing the amount of light contributed to the general surroundings 

and potentially visible from sensitive resources or locations. Techniques such as 

directional lighting, light hoods, and motion sensors are common in landscape design to 

balance the amount of light for a specific task and the light emanating away from an area. 

Light pollution is a byproduct of the amount of light, typically measured in lumens or 

candles, rather than the type of source (e.g., low pressure sodium or LED). Energy 

efficient lights can be used as proposed by Eagle Crest; however, thoughtful design and 

product selection should provide sufficient task lighting with reduced pollution. Lighting 

techniques would be further refined during the project’s late design and early operations 

phases based on information developed through dark sky monitoring to be conducted by 

Eagle Creek and the Park Service. This monitoring would help identify and refine 

lighting techniques to reduce the amount of potential lighting the proposed project would 

contribute to the erosion of dark night skies in the area and help to identify methods to 

mitigate these effects. Development of a monitoring plan prepared in consultation with 

the Park Service that includes specific study methodology, results, recommendations, 

conclusions and a plan for how lighting design or equipment changes would be 

implemented after the findings are posted would ensure that night sky conditions are 

protected. Although seeing project features and night lighting would contribute to the 

degradation of the values of solitude and night sky conditions, few people would be 

annually exposed to those conditions.
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Land Use 

Effects of Construction and Operation of Project Facilities

The Eagle Mountain mine site is a historical industrial use area and operation of a 

pumped storage project would be consistent with the historical, industrial type use of the 

area; however, the details of securing rights to develop on the property are complex and 

could be tied to the outcome of the pending land exchange appeal discussed in more 

detail later in this section. The proposed types of land use, intensive utility or solid waste 

landfill, are similar to the historical land use activities associated with mining. As 

proposed, the pumped storage project would operate side-by-side with the proposed

landfill project (if constructed) within the existing open mine pits. 

BLM’s CDCA Plan identifies uses that are considered suitable for each land use 

zone. Utility features and structures, such as switch yards, transmission lines and towers 

and outbuildings, alter the setting and may conflict with the intended condition of some 

of the land use zones. Construction of two reservoirs within existing open mine pits 

could conflict with existing BLM land use plans for the areas. Further, new transmission 

lines can add visual elements to the landscape away from the existing open pit mines that 

contrast with traditional land uses.

The proposed storage area and desalinization ponds would be located adjacent to 

the Eagle Mountain town site in an area south of the now-closed state penitentiary. 

Depending on the exact location of the ponds, construction of the ponds may require 

demolition of some portion of the structures associated with the now-closed state 

penitentiary. The town site is largely vacant; however, according to the license 

application, a small number of residences remain occupied. The proposed project 

features, including the transmission line, would be sited just a few hundred feet outside 

the west and south sides of the Eagle Mountain town site. Eagle Crest proposes to use 

existing access roads surrounding the proposed reservoir sites, also indicating that

construction access to/from the proposed interconnect substation site would be from the 

Eagle Mountain Road exit off Interstate 10 and following the Frontage Road east to the 

site (Measure LU-1). Two weeks prior to beginning construction, the applicant proposes 

to post notices locally stating the hours of operation for construction near the Desert 

Center community and along State Route 177 (Measure LU-2).

Eagle Crest’s proposed 13.5-mile-long transmission line would parallel the 

existing Eagle Mountain Road for about 4.5 miles before crossing the Chuckwalla Valley 

in a southeasterly direction to connect to the proposed interconnection collector 

substation on the western edge of Desert Center. The proposed water pipeline that would 

supply the reservoirs with water would be buried near an existing transmission line or 

road rights-of-way from near the Desert Center Airport to the Eagle Mountain mine.

Interior, in response to the REA notice, recommends the proposed transmission 

lines be co-located with existing transmission lines near the project site.
151

As described in section 1.3.2.2, California Environment Quality Act

Environmental Impact Report, and section 3.3.3.2, Terrestrial Resources, Environmental 

Effects, the State Water Board’s recommended substation location, along with the 

proposed substation near Desert Center, is shown in figures 2 and 11. Figure 11 shows

land use in the applicant’s proposed and the State Water Board’s recommended

substations locations and the associated transmission routes.

The proposed water pipeline would cross undeveloped public (BLM) and some 

previously farmed privately owned lands. Proposed pipelines would be tunneled 

underneath State Route 177 and the Metropolitan Water District aqueduct. 

Our Analysis

As with other construction effects, noise and dust would likely affect the few 

residents of the town site; however, these activities are not uncommon to the historic and 

much larger operations that occurred during construction of the penitentiary and normal 

operations of the mine. The heavy construction activity required to build the two 

reservoirs and associated facilities would be consistent with prior activities of the mine 

site (blasting, truck traffic, and heavy machinery use). Construction effects are estimated 

to be finished within 4 years. 

Development of the proposed lower reservoir would present a potential conflict 

with certain mineral reserve interests, because the area would be inundated upon 

implementation of the proposed project. There are no plans to recover these reserves at 

this time due to the current economics associated with the remaining reserves. These 

mineral reserves are under the control of the California State Lands Commission. The 

use of the eastern mining pit as a reservoir would restrict the recovery of these mineral 

reserves during the life of the project. 

The proposed transmission route would cross BLM lands that are managed as 

Multiple Use Class designations “Limited” and “Moderate” as part of the NECO Plan, 

including crossing about 6 miles of NECO’s DWMA. After crossing the Metropolitan 

Water District CRA southeast of the reservoirs, 4.5 miles of the proposed route would be 

sited within a designated BLM utility corridor identified in the NECO Plan. The 

remaining 9 miles of the proposed route would be located outside the corridor. 

Consequently, BLM would need amendment to the CDCA Plan prior to issuing a ROW

grant to construct within the corridor.

Interior’s recommended transmission line route would result in siting the line 

almost entirely within the BLM utility corridor, a 2-mile-wide route along the existing 

Metropolitan Water District and Devers-Palo Verde lines in the valley. This 

recommended route would lengthen the transmission line by about 4 miles and also 

would require crossing some public lands near Interstate 10. Construction of this 

recommended alignment could require the development of temporary access roads; 

however, most of the route could be developed via the existing Hayfield Road,
152

Figure 11. Land use near the applicant’s proposed and State Water Board’s recommended substations locations and 

associated transmission routes (Source: Eagle Crest, 2010a).
153

which parallels the Metropolitan Water District’s transmission line between its pumping 

plant and the Interstate 10 frontage road into Desert Center. A BLM ROW access permit 

still would be required; however, this would likely alleviate the need to request an 

amendment to the NECO Plan while also consolidating utility lines together along the 

eastern slope of the Eagle Mountains. Effects of Interior’s recommended transmission 

line and the other routes on wildlife are discussed in section 3.3.3, Terrestrial Resources, 

Wildlife.

Under the State Water Board’s recommendation, about 86 percent of the 12.5-

mile-long transmission line would be located on either side of an existing 160-kV wood 

H-frame transmission line owned by SCE. This recommended route would pass near 

several residences near the existing SCE line north of the Kaiser Road crossing. East of 

the Kaiser Road crossing, the remainder of the route would be, at a minimum, more than 

0.5 mile from existing residences. The State Water Board’s recommended transmission 

line would cross 4.9 miles of private land (compared with 0.4 mile for the proposed 

route) and would avoid, for the most part, the region’s DWMA (0.1 mile compared with

5.9 miles for the proposed route). Three road crossings would be required, including 

Kaiser Road, State Route 177, and Interstate 10. The State Water Board’s recommended

transmission line route would require additional coordination and permitting with the 

California Department of Transportation for the crossing of Interstate 10. Under this 

recommendation, the line would pass within about 0.75 mile of the Desert Center Airport,

a privately owned airport. Several abandoned agricultural fields would be crossed by this

recommended route where it would parallel the existing H-frame ROW between Kaiser 

Road and several miles south of State Route 177. Overall, this recommended route 

would be about 3 miles longer than the applicant’s proposed route.

The applicant’s proposed interconnection collector substation would convert about 

25 acres of currently vacant public land managed by BLM to project facilities, and the 

State Water Board’s recommended substation would convert about 75 acres of land also 

managed by BLM. A planned transmission line (Devers-Palo Verde No. 2) is expected to 

be constructed by SCE paralleling the south side of Interstate 10 and to which the State 

Water Board’s recommended substation would be directly connected. Construction of 

the applicant’s proposed project transmission line and substation would have short-term 

effects (noise, dust, and traffic) on the nearby residences of Desert Center, but the State 

Water Board’s recommended substation would be located in a remote area without any 

nearby residences. Construction activities would be consistent with the Multiple Use 

Class Moderate land designation and would last less than 4 years. 

Operation of the applicant’s proposed substation or other substation would change

the current vacant nature of the site with utility uses, permanently altering the land use. 

The applicant’s proposed substation and the State Water Board’s recommended

substation would also preclude the public from dispersed recreation uses on the public 

lands, although the sites are likely less desirable than other locations within the 

Chuckwalla Valley, as described elsewhere in this section under Recreation Resources.
154

Use of the Eagle Mountain Mine Road exit off Interstate 10 and Frontage Road 

into Desert Center as proposed by the applicant would minimize construction-related 

traffic in the residential community of Desert Center. The Desert Center exit off of 

Interstate 10 serves Desert Center, Lake Tamarisk, and motorists traveling State Route

177. Use of the proposed route (Eagle Mountain Mine Road) would minimize the 

amount of road damages, dust, traffic congestion and delays and other nuisances 

associated with construction traffic near the residential center. Publically posting the 

proposed construction schedule and potential closures or delays would be a courtesy to 

local residents and motorists passing through the area. Construction of the State Water 

Board’s recommended transmission line and substation would result in more construction 

traffic in the Desert Center area as compared with the applicant’s proposed transmission 

line and substation. Review of recent aerial photography indicates that the farmlands in 

which the proposed water pipeline would be sited have not recently been used for 

agriculture purposes. The proposed open-cut, sidecast construction method would have

temporary short-term effects on any active cropland. Construction activities would not 

last more than 4 years, after which farming activities could resume, assuming appropriate 

settling of the restored surface has occurred. Coordination with the California 

Department of Transportation and the Metropolitan Water District to identify reinforcing 

requirements and other safety measures prior to proceeding would be required. 

Effects of Construction on Proposed Eagle Mountain Landfill and Recycling 

Center

Issues surrounding the compatibility of the two proposed projects sharing the same 

general area and adjacent footprints are complex. The proposed pumped storage project 

was designed to be constructed and operated simultaneously with the approved landfill 

project, but the landfill project was not designed, planned, or permitted to operate 

simultaneously with another project. Both project concepts have moved through various 

stages of regulatory permitting over the last 20 years, and the anticipated start date for the 

landfill project is further complicated by Kaiser’s most recent appeal of the 9th District 

Court of Appeals upholding of an earlier decision that the proposed land swap between 

Kaiser and BLM is illegal. 

Eagle Crest suggested that the pumped storage project would be constructed first,

which may cause problems for construction of the landfill as currently designed. 

Additionally, the pumped storage project proposes to use mine tailings in securing the 

mine pits and dams during reservoir construction; materials also proposed for use for 

landfill operations.

The proposed project would be constructed at the now non-operational Eagle 

Mountain mine, and certain facilities would be located on lands that also have been 

designated for the municipal landfill operation. The Riverside County Board of 

Supervisors approved the landfill project in 1992. The proposed 4,659-acre landfill 

would be constructed in phases over a period of many decades. Construction and 

operation of each phase of the landfill would progress from west to east as shown in 
155

figure 10. Initiation of the landfill is contingent on the landfill operator owning all the 

fee lands included in the proposal. To achieve this prerequisite, the landfill business 

venture and BLM had agreed on a land exchange; however, that decision was brought to 

court, where the exchange was overturned. This decision was upheld by the 9th U.S. 

Circuit Court of Appeals on November 10, 2009 (National Parks v. Kaiser Eagle 

Mountain, No. 05-56908 D.C. No. CV-99-00454-RT Opinion). BLM has decided not to 

appeal this decision; however, Kaiser has decided to pursue an appeal, continuing the 

legal procedures to construct the landfill. According to Eagle Crest, the proposed 

pumped storage project is designed to be operationally compatible with the proposed 

landfill should the land exchange be consummated and both projects move forward.

Due to circumstances outside this proceeding, it is unclear if the proposed landfill 

project would be permitted. Although this issue is unresolved, staff discusses the 

potential effects of the landfill if constructed.

Our Analysis

Eagle Crest’s application was developed assuming construction of the project

would precede construction of the landfill and there would be no overlapping 

construction activities. Construction of the pumped storage project first would allow the 

energy infrastructure to be developed without construction congestion from two major 

projects. Because the approval process for both projects is out of the developer’s hands 

at this time, calculating the timing of construction schedules is not possible. If the past is 

any indication of the potential timing, the landfill project is still a couple of years away 

from a court decision, and additional time might be needed to secure any expired permits 

prior to starting construction. Similarly, regulatory approval and securing financing 

could delay the pumped storage project and theoretically the two could start construction 

simultaneously. Construction of both projects simultaneously would pose challenges and 

necessitate strong communication between parties to ensure the projects are designed and 

constructed to operate in such proximity.

Although the two projects are proposed for the same general area, the proposed 

pumped storage project facilities would be constructed and operated either underground 

or away from the proposed initial landfill footprint, while the proposed landfill would 

operate on the land surface. Although the proposed powerhouse would be underground, 

the land surface above this feature would, during Phase 3 of the landfill project, receive 

waste material for permanent storage and burial in the landfill. The proximity of these 

two projects may be suitable from a land use perspective because they would both be 

contained within the greater footprint of the historic mine operations; however, the 

technical details are beyond the scope of this analysis at this time. Other proposed 

pumped storage project facilities such as the substation, staging, storage and 

administration area and the reverse osmosis system and desalination ponds would be 

constructed south of the proposed landfill.
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Effects of Operation on Proposed Eagle Mountain Landfill and Recycling Center

During the first four phases36

Proposed Phase 5 of the landfill is projected to begin in about year 84 of 

operations, and it could include overlapping uses in the vicinity of the eastern mining pit, 

the lower reservoir for the pumped storage project. 

of the proposed landfill project, no overlap would 

occur between the landfill disposal areas and lands required for the proposed pumped 

storage project except for use of the primary access road into the site. The pumped 

storage project reservoirs would use the central and eastern mining pits, areas that are not 

proposed to be used during Phases 1 through 4 of the landfill. The project powerhouse 

and water conveyance tunnels would be constructed underground. Landfill compatibility 

plans submitted by Eagle Crest show that both proposed project features would be 

constructed to operate simultaneously with both projects within feet of each other in 

some places. For example, Phase I of the landfill would abut the proposed south saddle 

dam of the upper, (central mining pit) reservoir. 

Our Analysis

The landfill was approved by Riverside County for a 50-year operation. However, 

Phase 5 is not a part of the County-approved landfill project. Solid waste management 

has changed dramatically since the landfill project was originally proposed (e.g., 

implementation and increasing participation rates of recycling programs and other 

existing and new landfill sites currently available) and the need to permit Phase 5 could 

be pushed back beyond the original 50-year estimate. 

Eagle Crest states that its proposed project is designed to minimize the areas of 

overlap to avoid potential conflict among the two proposed projects. Such design 

provisions include the location of staging areas, realignment of the proposed transmission 

line, and use of fine tailings for components of the dam structure. Comparison of the 

extent of visible historical earth work and modifications throughout the Eagle Mountain 

mine property show that there is sufficient room to design and construct these two 

different projects in the same general location separated by both vertical and horizontal 

spacing, depending on the specific location and based on Eagle Crest’s proposal; 

however, the landfill project has not developed a design for the technical details of such a 

working relationship. 

 

36 The proposed landfill project would be constructed over 4 phases that would 

proceed over 50 years, depending on volume of waste delivered. The phases would 

proceed using the existing open mine pits from the west (near the proposed upper 

reservoir) to the east (toward the central mine pit).
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Effects of Construction and Operation of Project Desalinization Ponds on Land 

Use

Eagle Crest proposes to initially fill the reservoirs and maintain the water level in 

the project reservoirs from groundwater wells in the Chuckwalla Valley. Groundwater 

quality in combination with evaporative losses would increase the salinity, posing a risk 

of accelerated wear on the project structures and possible groundwater leakage. To

maintain salinity and total dissolved solids levels within the reservoirs equal to that of the 

groundwater, the applicant proposes to construct and use a reverse-osmosis system to 

treat water supply in the reservoir system. Water for treatment would be drawn from the 

upper reservoir while treated water would be returned to the lower reservoir and the 

concentrated brine from the reverse-osmosis process would be directed to about 56 acres 

of evaporation and solidifying ponds.

Our Analysis

Eagle Crest estimates that about 2,500 tons of salt would be removed from the 

reservoirs each year and that these solids produced from the evaporation and solidifying 

ponds would need to be removed once every 10 years. Eagle Crest does not provide 

information on the fate of these solids. Staff determined that the weight of salt is about 

75 pounds/cubic foot or about 1 ton per yard, and each highway-approved haul truck is 

capable of carrying about 20 yards. Staff estimates that the removal of 1 year of salt 

(2,500 tons) would require about 125 truck trips. If removal were scheduled in 10-year 

intervals as proposed, the disposal would require about 1,250 truck trips, or substantially 

fewer train trips if the privately owned Eagle Mountain Railroad is used to move the salt. 

Until potential uses and destinations are developed, Eagle Crest would have 

sufficient space within the proposed brine ponds to store this material for decades; 

however, it is not clear if this would significantly alter the utility of the remaining space 

within the ponds if they were used as storage for long periods. Eagle Crest would be 

responsible for the appropriate disposal of these solids, which could include transport to 

the proposed neighboring landfill or yet-to-be-determined, market-based opportunities 

(e.g., use in molten fluids for proposed concentrated solar projects throughout the region). 

The potential effects of brine water seeping into groundwater and surface waters are 

discussed in sections 3.3.2, Water Resources.

Aesthetics

Effects of Construction on Viewsheds

Construction and operation of the proposed project would use the existing iron ore 

mine, a substantially disturbed area within the Eagle Mountains, and would also 

introduce new visual elements in the viewsheds of BLM land throughout the Chuckwalla 

Valley, adjacent JTNP, and the small communities of Lake Tamarisk and Desert Center. 

These views would include the reservoirs, dams, power lines, water pipeline ROW, 

fences, brine ponds, graded and revegetated landscapes, and buildings.
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Construction of the proposed reservoirs and associated facilities (e.g., powerhouse, 

reverse-osmosis facility, brine ponds, substation, switch yard, storage area, and surge 

tank) would occupy lands previously disturbed by historical Eagle Mountain mining 

operations. 

No new roads would be developed to access the mine site because access to the 

site would use the existing Kaiser Road; however, additional access roads to proposed 

project facilities would be required. These new roads would provide access to the upper 

reservoir dams, inflow and outflow structures, the upper surge chamber and the access 

tunnel portal, and the storage/administration area. The road to the access tunnel portal 

and the storage/administration would be paved with asphaltic concrete; the other roads 

would be gravel surfaced. 

Construction of the proposed 13.5-mile transmission line would occur within a 

200-foot ROW, resulting in effects on a total of 327 acres required for the lines. The 

transmission lines would connect to a new interconnection collector substation that would 

be built on 25 acres near Desert Center. The buried water pipeline would run in an 

almost straight line from the well fields northwest to the proposed lower reservoir, a 

distance of about 16 miles. During construction, Eagle Crest proposes to reduce the 

sidecast material to minimize the contrast that the excavated material would pose to the

surrounding landscape and revegetate the fill material with native vegetation after 

construction.

As described in section 1.3.2.2, California Environment Quality Act

Environmental Impact Report, and section 3.3.3.2, Terrestrial Resources, Environmental 

Effects, the State Water Board has recommended a transmission line route and substation 

location. Figure 12 provides the applicant-prepared VRM classes in the proposed and 

recommended substation locations and the associated transmission routes.

Eagle Crest proposes a number of design elements and construction methods that 

are aimed at reducing the potential effects of construction activities of the proposed 

project on the aesthetic resources, including the following:

• Incorporate directional lighting, light hoods, low pressure sodium bulbs or 

LED lighting, and operational devices in final design to allow surface nightlighting in the central site to be turned on as needed for safety and fund night 

sky monitoring to be conducted in collaboration with the Park Service during 

the post-licensing design period, construction and a trial operational period 

(AES-1).

• Combine and organize staging areas and areas needed for equipment operation 

and material storage and assembly with construction lands to the extent 

feasible to minimize total footprint needed (AES-2).
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Figure 12. Visual resources in the substation and transmission line areas (Source: Eagle Crest, 2010a, as modified by 

staff).
160

• For construction of the water pipeline, reduce, to the extent possible, side cast 

soils to reduce color contrast with the surrounding landscape. Backfill the 

pipeline disturbed zone and revegetate with native vegetation immediately 

following completion of pipeline construction (AES-3).

• Employ visual mitigation in the design of the transmission line to minimize 

visual effects (AES-4).

• Use existing access roads and construction laydown areas to the extent feasible 

and revegetate with native vegetation immediately following construction 

(AES-5).

Interior, in response to the REA notice, recommends the proposed transmission 

lines be co-located with existing transmission lines near the project site.

Our Analysis

Construction of the proposed project would require using on- and off-road 

construction vehicles, machinery, and equipment to move earth; transport and place fill; 

grade the proposed project footprint; drill, blast, and excavate tunnel sites; store and 

move raw materials; and develop other infrastructure (e.g., new roadways and 

underground utilities). As proposed by Eagle Crest, making efficient use of construction 

staging areas; using existing roads, ROWs, and construction lay-down areas to the fullest 

extent possible; and revegetating areas that are disturbed and unnecessary for operations 

would help limit the introduction of visual elements to the viewshed (AES-2, AES-3 and 

AES-5).

The most common views of the construction activity and the resulting changes in 

landscape would be from public roads. To most viewers, construction within the existing 

footprint of the mine would be similar to past mining operations with active heavy 

machinery and earth moving equipment associated with developing the new hydro 

structures at the site.

Because of its location on the mountain side and unobstructed setting, a portion of 

construction activities at the mine site would be visible from parts of the Chuckwalla 

Valley and potentially from as far away as Interstate 10. Activities would be most visible 

to people traveling along the local roads in the Chuckwalla Valley; however, the overall 

anticipated number of viewers is expected to be small given that both Kaiser and Eagle 

Mountain roads are not through routes and the overall sparsely populated nature of the 

area results in low traffic volume on State Route 177. Motorists travelling on Interstate

10 in the vicinity of Desert Center represent the largest number of viewers potentially 

affected by construction, and view durations would likely be short because of the high 

travel speeds (posted 70 mph speed limit) through this area and because the long viewing 

distances would obscure any details of the activity. The State Water Board’s

recommended transmission line would cross Interstate 10 and result in the motorists 

being able to see construction activity from Interstate 10. Construction, especially of the 
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State Water Board’s recommended transmission line route, could compromise the 

County’s designation of this portion of Interstate 10 as an Eligible County Scenic 

Highway.

Construction activities would conflict with the existing aesthetics experienced by 

hikers venturing to the mountains surrounding the mine site from within JTNP since 

operations at the mine have essentially ceased; however, construction would be confined 

to an area previously disturbed during past mining activities. These effects would last for 

the duration of the construction activities (about 4 years). Proposed construction within 

the inactive mine area would be consistent with the applicant-prepared “Class IV” VRM 

scenery rating. 

Transmission line construction activities would introduce heavy machinery into 

the area to construct the tower pads, erect the poles, and string the lines. Additionally, 

construction of the interconnection collector substation would require grading the site and 

building a series of transformers and associated electrical equipment that would be stored 

in a chain-link fence area. Although Eagle Crest proposes to use existing roads and 

access routes, additional access spurs may be required in areas where the alignment is 

proposed to be located away from existing road network. Constructing the additional 

road spurs would cause visible scars within the desert landscape. These new spurs would 

introduce new linear elements into the landscape.

Construction of the proposed transmission alignment across BLM land would 

introduce new cultural modification into the landscape, but not enough of a modification 

to justify lower VRM class ratings. Construction of the 54 to 68 towers, or more for the 

longer State Water Board-recommended transmission route, would introduce new 

structures, adding human development into the viewshed. The vegetation, which is 

generally low, brush type shrubs, would provide only marginal screening for these tall 

and linear features. 

Views of the proposed transmission alignment within the Chuckwalla Valley, 

except for locations near the proposed transmission alignment, would generally be in the 

middle ground and foreground views to most viewers (residential centers or major roads). 

Segments of the proposed transmission alignment would be close to both the Eagle 

Mountain Road and Interstate 10, but the proposed transmission line would cross only 

Eagle Mountain Road. Consequently, there are numerous points where the transmission 

towers and corridors would be visible in the foreground, middle ground, and background. 

Aligning the transmission line to cross Eagle Mountain Road at an approximate 90 

degree angle would slightly reduce its visual effect on road users (AES-4). 

Excavation of the pipeline within the Chuckwalla Valley would be visible from 

motorists on most travel routes in the valley including State Route 177, Kaiser Road, and 

Eagle Mountain Road. Excavation of the pipeline that crosses State Route 177 and the 

section that parallels Kaiser Road would be clearly visible; however, the expected 

number of motorists on Kaiser Road in this vicinity would be minimal. Construction 

would introduce a visible scar across the desert valley and revegetation without assistance 
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(e.g., watering) may take years for the site to fully recover, during which OHV use would 

pose a risk to the recovery process.

Effects of Operation on Viewsheds

Eagle Crest proposes to construct two saddle dams surrounding the existing 

central mine pit that is proposed as the upper reservoir. At its maximum normal water 

level, the upper reservoir would have a surface area of 191 acres at an elevation of 2,485 

feet. This proposed reservoir requires two dams, one 1,100 feet long with a height of 60 

feet and the other 1,300 feet long with a height of 120 feet. 

The proposed lower reservoir would occupy what is now referred to as the eastern 

mine pit of the Eagle Mountain mine. Other than preparation of the earthen materials 

within the pit, no new dam would be constructed at this location. At its normal full water 

level, the reservoir would have a surface area of 163 acres at an elevation of 1,092 feet.

The proposed reservoir areas would include storage buildings, a substation, 

reverse-osmosis facilities, brine ponds, lighting, and security fencing around the entire 

area. The entire proposed project area near the reservoirs would be fenced and public 

access would be precluded. Eagle Crest indicates that facilities would have security 

lighting. Eagle Crest proposes that lighting would be designed to minimize light 

pollution through the use of directional lighting, lower intensity lights (e.g., low pressure 

sodium bulbs or LEDs), and operational devices to allow surface night-lighting 

surrounding the proposed project facilities to be turned on as-needed (e.g., motion 

detection). The lighting design and product selections contribution to light to the night 

sky would be monitored for a trial operational period. 

The presence of between 54 and 68 steel lattice towers, or more for the State 

Water Board’s recommended transmission line, ranging in height from 175 to 235 feet 

with new electrical transmission wires, would introduce new, vertical human 

infrastructure into the Chuckwalla Valley. Towers would be spaced about 1,000 feet 

apart (depending on the local topography). North of the Metropolitan Water District’s 

pumping plant, the proposed route would cross and parallel existing wood pole 

transmission lines and the Kaiser railroad, adding another human-made element into the 

landscape. South of the Metropolitan Water District’s pumping plant, the proposed 

transmission line route would parallel the existing Eagle Mountain Road for about 4 

miles before turning southeast to the interconnection collector substation site. The 

transmission line would introduce a new feature into the landscape and create a new 

vertical visual contrast that parallels the existing road. This line segment would be within 

the middle ground viewing distance to the greatest number of viewers (all of the lower 

Chuckwalla Valley, including Lake Tamarisk, Desert Center, and Interstate 10). Eagle 

Crest proposes to site the tower structures so that they would not be positioned on the 

highest topographical points along the route to minimize their effect on the desert 

landscape. 
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As described in section 1.3.2.2, California Environment Quality Act

Environmental Impact Report, and section 3.3.3.2, Terrestrial Resources, Environmental 

Effects, the State Water Board’s recommended substation would be located east of Desert 

Center. Figure 12 provides visual resources in the proposed and recommended substation 

locations and the associated transmission routes.

The proposed interconnection collector substation is proposed to have security 

fencing and lighting to prohibit trespass. This substation would be located less than a

quarter mile west of Desert Center and would be clearly visible to residents and motorists 

on Interstate 10. The State Water Board’s recommended substation would be located on 

the south side of Interstate 10 and slightly closer to Interstate 10 than the proposed 

substation near Desert Center.

Our Analysis

Under Eagle Crest’s proposal, the reservoirs, dams, spillway, fencing, substation, 

reverse osmosis plant, brine ponds, and storage area would introduce new and different 

uses into the historical Kaiser iron ore mine. Proposed project features near the 

reservoirs would be visible from areas within the Chuckwalla Valley; however, the 

details would be difficult to ascertain because the features would be in the viewers’ 

middle ground and within the already disturbed Eagle Mountain mine site. These 

structures would supplement additional lines and structures into the already heavily 

manipulated landscape within the mine footprint. The presence of water within the two 

proposed reservoirs would introduce a new visual feature absent from previous 

operations and completely different from the surrounding desert landscape. 

Because of the site’s setting in the Eagle Mountains, views of the water would be 

possible only from higher vantage points, which in the local area is limited to the peaks 

mostly within the JTNP. Recreation estimates mentioned in section 3.3.5, Recreation, 

Land Use, and Aesthetics, indicate that the mountains in the southeastern portion of the 

park receives very low use levels (tens of people per day). Locations within the JTNP 

that provide views of the proposed project features would also include views of the 

Chuckwalla Valley, which includes in the foreground the existing disturbed setting

surrounding the mine from historic mining operations as well as existing transmission 

lines, the Eagle Mountain town site, and Metropolitan Water District’s pumping plant.

From within Chuckwalla Valley, the reservoirs would be most visible in the 

foreground and middle ground distance, with diminished visibility proportional to the 

observer’s distance. Views of the proposed facilities, most notably the flat top of the 

upper reservoir dam, could be visible from Kaiser Road and State Route 177; however, 

the flat lines would be consistent with the existing terraced look of the tailings piles, and 

given the distances, topographical obstructions would mask the new facilities to most 

viewers. Given the distance to Interstate 10 still further southeast, it is unlikely that the 

majority of the public would be able to discern the features associated with the reservoirs 

as separate or unique from the existing features related to the historical mining 
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operations. Operation of the proposed reservoirs would not justify any change to the 

BLM VRM Class C designation.

Implementation of night sky monitoring, as requested by the Park Service, would 

help gather the data necessary to understand the potential changes to the night sky due to 

proposed project security lighting. Development of a specific night sky monitoring study 

and plan in consultation with the Park Service, as described above, would ensure that 

findings from the monitoring result in design or product selection that minimizes light 

pollution from project sources. Incorporation of low-light emitting policies and design 

elements would prevent further degradation of the dark night sky in close to the JTNP, 

thereby preserving wilderness qualities in areas out of direct sightlines of the proposed 

facilities.

Visibility of transmission lines within the Chuckwalla Valley would be greatest to 

motorists on Eagle Mountain Road near the town site and Kaiser Road (both of which 

have low traffic volumes) because this section would be in the middle ground. This 

transmission line section would also be visible to hikers on or near the ridge tops in the 

JTNP designated wilderness area and lower elevations within the park within the 

wilderness buffer zone. From these vantage points the proposed transmission alignment 

would be in the foreground and middle ground viewing distances. Because there are 

existing wood pole transmission lines, rail lines, an abandoned air strip, the existing CRA 

switchyard and forebay associated with the pumping station, and a small cluster of 

residential buildings in the view, the proposed transmission line would be incremental to 

the existing visual conditions within this portion of the alignment. Towers built with dull 

finish and carrying conductors with qualities that reduce glare and visual contrast as 

proposed by Eagle Crest, would be consistent with construction trends designed to 

minimize visual contrast from new transmission lines.

At its closest point, the proposed transmission line route that parallels the existing 

Eagle Mountain Road, would be less than a mile from the JTNP boundary; however, 

visual contrast observed from locations within the JTNP currently includes the existing 

powerline to the CRA pumping station, numerous dirt roads in the area, and the railroad 

in the foreground. As previously discussed, the southeast area of JTNP receives a very 

little amount of visitor use. This segment of the line would parallel Eagle Mine Road, 

minimizing the amount of disturbances required in developing access spur roads to 

construct and maintain the towers. This section of the proposed line would not justify a 

lower VRM class rating (existing Class III). 

Visual contrasts of the proposed access and spur roads and towers would become 

greater as the route leaves the Eagle Mountain Road and crosses to the proposed 

interconnection collector substation site 2.5 miles away. This segment would be clearly 

visible in middle- and foreground viewsheds from key viewpoints, notably Interstate 10, 

Lake Tamarisk and Desert Center. Visual contrast would be high due to increased 

visibility of a new utility structure and details introduced into the natural landscape. 

Although views from Interstate 10 are of short duration, they sweep across the proposed 
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route due to the bend in the interstate alignment, providing panoramic views of the 

Chuckwalla Valley. Visual effects of the proposed line would be greatest for this 

segment because it would run across most of the western portion of the lower valley and 

be located in the foreground of the greatest number of potential viewers, motorists on 

Interstate 10. Co-locating the lines within the existing utility ROW as recommended by 

Interior would combine new linear features with existing features (CRA transmission line 

and railroad) at the eastern toe of the Eagle Mountains. Continuing the route south along 

Eagle Mountain Road across Interstate 10 to a new western substation would introduce a 

new overhead element visible to all highway traffic. 

Positioning the substation to the south of Interstate 10 reduces the visual contrast 

of the feature by minimizing its presence in the overall panoramic view; however, the 

substation’s location would intrude on views of Alligator Rock from east-bound travelers 

on Interstate 10. This effect would be limited to views within a few miles of the site 

because the intervening topography blocks direct sightlines of the substation area until it 

is within the foreground view. 

Operation of the new substation may result in a new source of light and glare from 

night lighting. Use of non-reflective materials, designs that minimize light glare (such as 

shielding and directional light hoods) may reduced these effects. Most of the 

transmission line would be within middle ground and background view zones. The visual 

change here would be high and would not meet VRM Class II or III objectives. The State

Water Board’s recommended substation would be located to the south of Interstate 10 on 

lands classified by the applicant as VRM Class III. This location is remote and more than 

5 miles from the population center of Desert Center. The location is also on the 

periphery of segments along Interstate 10 that provide maximum panoramic views of the 

Chuckwalla Valley. The substation’s size and discordant mass of equipment at varying 

heights would create a strong contrast to the surrounding natural features that would 

dominate views from Interstate 10 due to its location within foreground distance zones. 

The substation structures would intrude into views of Alligator Rock. Such views, 

however, would be brief; the substation becomes most visually apparent about 2 miles 

out, which at 70 mph would be visible for 2 minutes or less. Planting of desert vegetation 

at strategic locations and treatment of features (e.g., color, nonspecular material) would 

reduce visual contrast but not sufficiently within foreground view zones to avoid 

appearing in the skyline or to meet VRM Class III designations. 

The State Water Board’s recommended transmission route would connect with the 

applicant’s proposed transmission line route north of the Metropolitan Water District

pumping station, then parallel SCE’s existing 160-kV wood H-frame transmission line. 

The State Water Board’s recommended route would continue to parallel the existing line 

southeast for about 10 miles before turning south and leaving the existing H-frame line to

cross Interstate 10 to the State Water Board’s recommended substation. 

More than 60 percent of the route would cross through BLM managed lands with

VRM Class III designations while the remainder is Class IV. Some of these lands are 
166

currently proposed to be used for large-scale solar projects. The State Water Board’s

recommended transmission line would be located adjacent to an existing transmission 

line ROW for 10 of its 12.5 miles). The vertical forms of the lattice towers would be 

visible, but difficult to discern in middle-and background view distances as a result of the 

scale, existing towers and variable texture of the valley landscape. The route would 

affect foreground views of travelers on State Route 177 but these would be in addition to

the existing SCE 160-kV line along the road sides. 

With the exception of the Interstate 10 crossing, the State Water Board’s

recommended transmission line would create an incremental increase of the visual effect

caused by the existing transmission line and would not dominate the view of the casual 

observer. The level of change created by this alternative would be moderate and would

continue to meet the spirit of VRM Class III and IV objectives. 

About 2 miles from Interstate10, the State Water Board’s recommended

transmission line would turn south and leave the existing transmission line ROW. The 

vertical form and lines of the lattice towers would become more visible as the route 

approaches the foreground view zone of Interstate 10. The route’s perpendicular

alignment and crossing of Interstate10 would minimize the extent and time the line would 

be visible from Interstate10 travelers, but the overall change in the foreground view zone 

caused by the towers and the proposed east substation would be high.

Revegetation of the disturbed areas from installing the underground water pipeline 

and unneeded construction laydown areas and transmission line access roads is proposed, 

using native plants that may take decades to mature given the rate at which desert 

ecosystems respond. After the initial filling of the reservoirs, only a single groundwater 

well is proposed to be retained to provide replacement water to the reservoirs. Although 

Eagle Crest has not disclosed plans for the exact location or how the well site would be 

secured (e.g., fencing, building, etc.), the site would likely occupy a small footprint.

3.3.5.3 Cumulative Effects

Participants in scoping identified concerns about the proposed project’s 

cumulative effects on recreation and land uses within the Chuckwalla Valley. The 

proposed project is one of numerous proposed projects for the Chuckwalla Valley that 

would contribute to past, ongoing, and future effects on future land uses, wilderness 

values, and dark night sky conditions. Future, planned developments within the 

Chuckwalla Valley, including additional transmission line projects, the potential landfill,

and numerous solar projects are likely to contribute effects on these resources. 

Recent legislation (California Senate Bill 107, Renewable Energy Portfolio 

Standard and Executive Order S-14-08) requires that 33 percent of all electricity 

generated in California originate from renewable sources. This in combination with the 

federal American Recovery and Reinvestment Act (stimulus funding) has resulted in a 

number of renewable energy proposals to be constructed in the California deserts. In the 

Desert Center area, five large-scale solar projects have been proposed, totaling more than
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30,500 acres, with many more solar energy projects proposed for the greater Mojave 

Desert. These projects would contribute to the conversion of the rural desert landscape to 

one potentially filled with utility-grade solar projects and appurtenant facilities including 

transmission lines. Construction and operation would result in increased traffic and 

possibly a long-term demand for more services in the Lake Tamarisk and Desert Center 

areas, further contributing pressure for more land use conversions. Additional congestion 

and human development in the area would put additional pressure on the dispersed 

recreation opportunities throughout the area. 

Development of the proposed project would contribute to conversion of the 

landscape to one filled with more human-made energy infrastructure; however, the 

proposed project could also have positive effects on the growing renewable energy 

industry due to its energy storage capabilities. For example, energy generated from other 

renewable sources (e.g., wind) at night could be stored and substituted for non-renewable 

sources when other renewable sources may not be as reliable. Eagle Crest would not be 

able to choose where its electricity would originate to move the water to the upper 

reservoir; however, there is a growing concern related to the need for large-scale energy 

storage systems to better balance the electrical grid.

Development and operation of the proposed project in addition to other potential 

projects, including the landfill and solar projects, may have an effect on the wilderness 

experiences of visitors to the remote eastern margins of JTNP. As described in the 

discussion of Aesthetics earlier in this section, these projects would be most noticeable to 

park visitors near the eastern boundaries. Development of the proposed landfill would 

increase rail and truck traffic in the Eagle Mountain mine area as solid waste is prepared 

and stored. Hauling of salt produced as part of this project would contribute additional 

truck traffic to local roads. 

Utility-scale solar projects are another human development that has the potential 

to be more visible to JTNP users in the reasonably foreseeable future. Thousands of solar 

panels or reflection mirrors are proposed to be constructed in the Chuckwalla Valley,

which could reflect the sunlight and catch the attention of JTNP users. 

Construction of the transmission line would add to the cumulative effects on land 

use because the construction of 13.5 miles of line and dozens of towers would contribute 

additional energy infrastructure into the Chuckwalla Valley. Siting the line outside the 

existing BLM utility corridor as proposed would contribute to incremental erosion of the 

large open spaces the utility corridors are designed to preserve.
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3.3.6 Cultural Resources

3.3.6.1 Affected Environment

Section 106 of the National Historic Preservation Act

Section 106 of the NHPA as amended requires the Commission to take into 

account the effects of licensing a hydropower project on any historic properties and allow 

the Advisory Council on Historic Preservation a reasonable opportunity to comment if 

any adverse effects on historic properties within the hydropower project’s APE are 

identified. If Native American properties have been identified, section 106 also requires 

that the Commission consult with interested Native American tribes that might attach 

religious or cultural significance to such properties.

Historic properties are defined as any district, site, building, structure, or object 

that is included in or eligible for inclusion in the National Register. In this document, 

staff also uses the term “cultural resources” to include properties that have not been 

evaluated for eligibility for listing in the National Register. In most cases, cultural 

resources less than 50 years old are not considered eligible for the National Register. 

Cultural resources need enough internal contextual integrity to be considered historic 

properties. For example, dilapidated structures or heavily disturbed archaeological sites 

may not have enough contextual integrity to be considered eligible. TCPs are a type of 

historic property that are eligible for the National Register because of their association 

with cultural practices or beliefs of a living community that: (1) are rooted in that 

community’s history; or (2) are important in maintaining the continuing cultural identity 

of the community (Parker and King, 1998).

Area of Potential Effects

Pursuant to section 106, the Commission must take into account whether any 

historic property could be affected by the issuance of a license within a project’s APE. 

The APE is determined in consultation with the California SHPO and is defined as the 

geographic area or areas within which an undertaking may directly or indirectly cause 

alterations in the character or use of historic properties, if any such properties exist. In 

this case, the APE for the Eagle Mountain Project includes lands within the proposed 

project boundary, plus lands outside the proposed project boundary where project 

operations may affect the character or use of historic properties and/or TCPs. In its AIR 

response filed December 22, 2009, Eagle Crest states that the APE is identical to the 

proposed project boundary and includes:

• the spillway from the upper reservoir, which would flow into Eagle Creek;

• Eagle Creek from the spillway to the lower reservoir;

• the spillway from the lower reservoir; and 

• the access road to the West Saddle dam and to the elevator shaft. 
169

The California SHPO stated that it did not object to how the APE was defined 

(letter from M.W. Donaldson, California SHPO, Office of Historic Preservation, 

Sacramento, CA, to Russ Kaldenberg, Principal, ASM Affiliates, Carlsbad, CA, 

December 22, 2009).

In appendix A of its supplemental information filed July 7, 2010 (Eagle Crest, 

2010a), Eagle Crest’s consultant ASM Affiliates (ASM) describes the State Water 

Board’s recommended transmission line and substation location as included in the project 

APE (Schaefer, 2010).

Cultural History Overview

Prehistoric Background

The prehistory of Southern California is divided into three temporal periods: 

Paleo-Indian, Archaic, and Late Prehistoric. The Paleo-Indian period dating from 

10,000–6,000 B.C. is typified by non-ceramic stone tool assemblages, rock features, and 

cleared circles in the Colorado Desert, which have been assigned to the San Dieguito 

pattern (10,000–6,000 B.C.). The San Dieguito pattern represented a hunter-gatherer 

adaptation by which small, mobile bands exploited small and large game and collected 

seasonally available wild plants. 

The Archaic period (6,000 B.C.–A.D. 500) in southern California is typified by 

the Pinto and Amargosa patterns (6,000 B.C.–A.D. 500), which are considered regional 

specializations within the widespread hunting-gathering adaptations that characterized the 

Archaic period. Information suggests that the California deserts were less hospitable 

during the Archaic period, and that the mobile hunter-gatherers were forced to 

concentrate around limited locations or move to more habitable regions. The small 

quantity of artifacts at some sites suggests strategically stored food and seed processing 

equipment that was used by small mobile groups. 

The Late Prehistoric period (A.D. 500–1900) is typified by the Patayan pattern and 

innovations such as the introduction of pottery making by the paddle-and-anvil technique, 

bow-and-arrow technology, and the introduction of floodplain agriculture. Agriculture 

and ceramics were probably introduced either from northwestern Mexico or from the 

Hohokam culture on the Gila River in present day Arizona.

Between A.D. 1000 and 1700, desert peoples of this region appear to have 

extended their focus somewhat away from the Colorado River floodplains to a more 

mobile, diversified resource procurement pattern, with increased travel between the river 

and Lake Cahuilla to the southwest). Long-range travel to special resource collecting 

zones and ceremonial locales, trading expeditions, and possibly warfare are reflected by 

the numerous trail systems seen throughout the Colorado Desert. Pot drops, trailside 

shrines, and other evidence of transitory activities are often associated with these trails, 

including within the Chuckwalla Valley and at springs and other water sources in the 

surrounding mountains and washes. The final recession of Lake Cahuilla by about A.D. 
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1700 resulted in a return to reliance on the Colorado River floodplain and increasing 

population growth in the Coachella Valley and San Jacinto and Santa Rosa mountains.

Ethnohistoric Background

Ethnographically (Post A.D. 1540), the project vicinity was occupied by the 

Colorado River People, the Desert Cahuilla, and the Chemehuevi. 

The Colorado River People, known as the Halchidhoma, were a Yuman-speaking 

group who lived along the Palo Verde Valley of the lower Colorado River Valley, in the 

vicinity of modern Parker and Blythe. Although somewhat distant from the project area, 

they are likely to have traveled between their homeland and the Coachella Valley via the 

Chuckwalla Valley. Foods were procured by seasonal rounds of hunting, fishing, and 

gathering supplemented by small-scale agricultural practices. The primary source of 

dietary animal protein came from fish caught in the Colorado River. Residential bases 

were centered on the Colorado River but conformed to a seasonal pattern. Spring and 

summer houses were located near agricultural fields, but on the mesas, where they would 

be safe from floods, open-air ramadas were constructed on the floodplains adjacent to the 

fields. During the winter season, Colorado River People relocated to residential bases on 

Colorado River terraces and the lower mountain slopes 

Likewise, while the principal residential locations of the Desert Cahuilla were in 

the Coachella Valley and the Santa Rosa and San Jacinto mountains, they were also 

known to have traveled and maintained cultural contact with Colorado River peoples. 

The Chuckwalla Valley would have been one of their principal travel corridors for this 

purpose. A dozen or more independent landholding Cahuilla clans lived within the 

region. In addition to each lineage’s residential area and other locations within a clan 

territory, ownership rights to various food-collecting, hunting, and other areas were 

claimed by the various lineages. While villages were occupied year-round, a large 

number of their inhabitants would leave at specific times to exploit seasonally ripening 

foods in different environmental zones. Temporary camps would be established in these 

food-collecting areas, and surpluses would be transported back to the main village. Many 

animal resources were also hunted. Cahuilla clans were arranged so that each community 

was placed in an area near water and food resources. Throughout the area there were 

sacred places used primarily for rituals, inter-clan meetings, caching sacred materials, and 

shamans’ activities. European diseases probably began to affect the Cahuilla in the 

early1800s and became particularly severe in the 1860s. In 1876 and 1877, the United 

States government set aside small reservations for all groups classified as “Mission 

Indians.” These reservations were established in a checkerboard pattern encompassing 

48 sections, spread across the eastern edge of the Santa Rosa and San Jacinto mountains 

and the Coachella Valley. With various additions and withdrawals over time, these lands 

have remained the permanent land base of the Cahuilla to the present. 

The Chemehuevi occupied desert areas west of the Mohave and north of the 

Cahuilla probably in the period between A.D. 1200 and 1500. The Chemehuevi lived in 
171

smaller and more mobile groups than the Cahuilla or the Yuman-speakers, in order to 

adapt to the sparser and more widely distributed and scarcer resources of their desert. 

The Chemehuevi were great travelers and regularly visited many of their neighbors and 

may have brought them into the general project area more often than other groups. They 

subsisted primarily on small game and a wide variety of seasonally available wild plants. 

The Chemehuevi have distinguished themselves from their Yuman neighbors by their 

very different mythology, worldview, religious practices, kinship system, and political 

organization. Between 1865 and 1871 some indigenous groups began moving south to 

inhabit the newly created Colorado River Reservation. Additional land was added to the 

Colorado River Reservation in 1874 to encourage the Chemehuevi to move there from 

areas near Blythe, Needles, Beaver Lake, and Chemehuevi Valley; however, not until the 

early 1900s did the Chemehuevi agree to move.

Historic Background

Extensive mineral exploration in the project vicinity began in the early 1860s. In 

1881–1882, Jack Moore staked a claim and with his father and two other partners 

founded the Eagle Mountain Mining District for the exploitation of iron, gold, and silver. 

They failed to maintain the necessary assessment work to validate the claim and the area 

was abandoned for mineral development until 1895. That year L.S. Barnes began to 

consolidate the claims within the area. He completed his consolidation by 1912 and sold 

the package to Henry E. Harriman, CEO of the Southern Pacific Railroad. 

World War II saw an enormous demand for steel, but shortly prior to the war in 

1936, the Joshua Tree National Monument was formed, and the boundary included the 

Eagle Mountain claims, thus protecting the ore bodies from mining. Henry J. Kaiser then

took interest in the Eagle Mountain claims. He purchased the Eagle Mountain claims 

from the Harriman heirs and succeeded in having the Joshua Tree Monument boundaries 

shifted to exclude the Eagle Mountain properties. He then began work in 1944 to survey

a new railroad route between Eagle Mountain and the Southern Pacific Railroad. 

Construction on the railroad began in 1947 and was completed on June 23, 1948, as the 

Kaiser Industrial Railroad (Eagle Mountain Industrial Railroad). Ore shipment from the 

mine began immediately, and by 1971 the Eagle Mountain iron mine was producing 90 

percent of California’s total iron output. 

More than 4,000 people were employed in the operation, making the Eagle 

Mountain mine Riverside County’s largest employer. The company town of Eagle 

Mountain included schools, fire and police departments, civic facilities, 416 rental 

houses, 185 trailers, 383 dormitory rooms, and 32 apartments. As a result of establishing 

the Eagle Mountain mine and employing thousands, Kaiser provided his workers with a 

comprehensive medical plan, which later became known as Kaiser Permanente. 

Competition from abroad and other economic factors caused the mine to close in 1983 

after 35 years in operation. Much of the housing stock was either removed, left vacant, 

or vandalized. By 1994, a school, a new low-security prison, and some rental properties 

remained at Eagle Mountain, but it is largely a ghost town today. 
172

The town of Desert Center was founded in 1925 by Stephen Ragsdale and his wife 

after buying a homestead that was developed about 10 years earlier. The town remains as 

a waypoint on Interstate 10, which runs near the southern edge of the project area and is a 

major transportation artery connecting the Los Angeles area with Arizona. The route 

may have been used prehistorically because it represented a relatively low (but dry) 

corridor for travel between the lower Colorado River in Palo Verde Valley and the 

Coachella Valley. During the early twentieth century, as the region’s highway system 

was gradually developed, the route was known under a succession of different 

designations, including Legislative Route 64 and U.S. Route 60. Interstate 10 was 

completed in 1968.

The CRA runs through the study area. The aqueduct was constructed between 

1931 and 1941 by Metropolitan Water District as one of the major Colorado River water 

delivery public works projects, which also included the construction of Hoover dam and 

other canals supplying water to southern California. These projects are recognized as 

pivotal components that allowed the enormous growth of the Los Angeles area during 

World War II and in the following decades. In 1955 and 1994, the American Society of 

Civil Engineers (ASCE) recognized the CRA as one of the “Seven Engineering Wonders 

of American Engineering” (ASCE, 2010).

The deserts of southern California and western Arizona became the focus of 

important military training exercises during World War II. The project area is located 

near what was once the Desert Training Center, a 10- to 130-square-mile area that was 

opened on April 30, 1942, as the largest military training installation ever created. This 

facility had General George S. Patton, Jr., as its first commanding officer and served the 

vital purpose of training troops for desert warfare conditions and tactics in preparation for 

the North African Campaign. After the Allied victory in North Africa in 1943, an 

emphasis on desert warfare was no longer necessary. The name of the Desert Training 

Center was changed to the California-Arizona Maneuver Area (CAMA) on October 20, 

1943, and its purpose was expanded to serve as a simulated theater of operations 

emphasizing large-scale logistics and not exclusively desert warfare training and tactics. 

The facility provided training for combat troops, service units, and staff under conditions 

similar to a combat theater of operations until its closure in May 1944. Divisional camps 

that may have deployed troops into the project area include Camp Desert Center, Camp 

Iron Mountain, Camp Granite, and Camp Coxcomb, all of which are located north of 

Desert Center. A network of railroads and roads connected all the divisional camps and 

depots. Many smaller camps, bivouacs, firing ranges and other facilities were 

constructed throughout the Desert Training Center/CAMA.

The divisional camp nearest the project area was Camp Desert Center; it was

located between Camp Young and Desert Center and extended immediately east of Eagle 

Mountain Road and north of the old highway that preceded Interstate 10. Very little 

documentary information is currently known for Camp Desert Center, and its specific 

history and range of functions are not clearly understood. BLM did not include Camp 

Desert Center in its interpretive plan for the major camps of the Desert Training 
173

Center/CAMA, although the interpretive plan includes preservation and interpretive goals 

for the other major sites. The 34,000-acre area included a barracks area with tent 

housing, an observer’s camp, an ordinance camp, an evacuation hospital, a quartermaster 

truck site, and an extensive maneuver area.

Previous Cultural Resources Investigations

Eagle Crest conducted a search of cultural resource records housed at the Eastern 

Information Center of the California Historic Resources Information System at the 

University of California, Riverside, and at the BLM Palm Springs Field Office. This 

search was supplemented by a review of reports available at ASM Affiliates. This record 

search was augmented by additional information provided by ECORP Consulting, Inc.

(ECORP), a firm that had conducted a recent survey in the project area but had not yet 

provided a report to the California Historic Resources Information System. The 

background research identified 56 previous reports within a 1-mile radius of the project 

APE, of which 27 included portions of the project area proper (Schaefer, 2010, 2009). 

As cited by Schaefer (2010, 2009), previous studies that were found to have 

addressed significant portions of the project’s APE include Cowan and Wallof (1977; RI00220), Wallof and Cowan (1977; RI-00222), Carrico et al. (1982; RI-00221), Bull et al. 

(1991; RI-03321), Love (1994; RI-03949), Schaefer (2003), and the ECORP study (no 

reference provided).

During these previous studies, a total of 123 cultural resource sites were recorded 

within a 1-mile radius of the project area. Of these, only six sites are located at least 

partially within the project APE: an underground portion of the CRA (site P-33-06726), 

which is crossed by the proposed transmission line route and the proposed and alternative 

water line corridors; the Eagle Mountain mine and town site (site P-33-006913), two 

resources associated with the Desert Training Center 36th Evacuation Hospital (P-33-

015971, P-33-017642), and two prehistoric sites (P-33-015091, P-33-015093). The Eagle 

Mountain town site record includes the railyard and in at least two locations, the project 

alignment intersects the Eagle Mountain Industrial Railroad, which is considered part of 

the Eagle Mountain mine and town site complex. 

Identified Resources

Prehistoric and Historic Archaeological Resources

In March 2009, Eagle Crest conducted an intensive archaeological survey of the 

accessible portion of the project APE, encompassing 620 acres. A final report titled A 

Class III Field Inventory for the Proposed Eagle Mountain Pumped Storage Project, 

Riverside California (Schaefer and Iversen, 2009) was prepared that presented the results 

of the fieldwork. The survey area included the 200-foot-wide proposed transmission line 

route, as well as other routes, the 60-foot-wide proposed and alternative water line routes, 

two proposed collection substation locations, and four potential water supply well 

locations. Access to lands within the APE owned by Kaiser was not granted; these lands,
174

including the Eagle Mountain mine and town site and associated railroad, were not 

surveyed. 

In section 6 of its July 2010 supplemental information filing, Eagle Crest presents 

the preliminary results of ASM Affiliates’ recent archaeological survey of the applicant’s 

proposed and the State Water Board’s recommended transmission routes or substation 

locations (Eagle Crest, 2010a). A summary of the survey results were provided in a letter 

report titled Results of Class I Record Search and Class III Field Inventory of Eagle 

Mountain Pumped Storage Project Alternative Transmission Line Corridors and 

Substations (Schaefer, 2010). In this letter report, ASM Affiliates states that the report 

only provides the preliminary results of the survey and that an addendum to the original 

project survey report prepared by Schaefer and Iversen (2009) would be forthcoming. 

The preliminary letter report states that for the State Water Board’s recommended 

transmission line route and substation, cultural resources data were based on the recent 

survey information provided by ECORP (no reference provided).

Based on the records search, the information provided by ECORP, as cited by 

ASM Affiliates (2010), and the subsequent archaeological survey, a total of forty-seven 

archaeological sites were identified within the surveyed portion of the APE. Including 

the Eagle Mountain mine and town site, eight resources are known to be present within 

the APE as previously approved by the California SHPO. An additional 39 sites were 

identified during recent surveys of the applicant’s proposed and the State Water Board’s 

recommended transmission routes and substation locations. 

Table 12 provides a summary of all archaeological sites identified within the 

project APE to date.

Although it has not been formally evaluated, Eagle Crest assumes that the CRA

(P-33-006726) is eligible for listing on the National Register. In the area of the proposed 

crossings, the aqueduct occurs as a deeply buried, massive, underground pipeline where 

the transmission line and waterlines would cross the aqueduct route. It is virtually 

invisible on the surface except for a road and earthen berm. The California SHPO agreed 

that assuming eligibility of this structure was acceptable (letter from M.F. Donaldson, 

California SHPO, Office of Historic Preservation Sacramento, CA, to R. Kaldenberg, 

ASM Affiliates, Carlsbad, CA, December 22, 2009). 

Both the Eagle Mountain mine and the town site are recorded as P-33-006913. 

This property also includes features associated with the Eagle Mountain Railroad. In a 

previous consultation, BLM and the California SHPO concurred that this property was 

not eligible for the National Register (letter from C. Widell, California SHPO, 

Sacramento, CA, to H.R. Bisson, District Manager, BLM, California Desert District, 

Riverside, CA, December 12, 1996). However, at the time of the original 1996 

determination and SHPO consultation, the property did not meet the 50-year age 

requirement for listing on the National Register. Because it now meets that requirement,
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Table 12. Archaeological and historic resources within the Eagle Mountain Project 

APE (Source: Schaefer, 2010, 2009, as modified by staff).

Primary 

Number/

Temporary 

Designation Description Date

National Register 

Eligibility

P-33-001811 Prehistoric lithic 

scatter

Unknown Recommended not eligible

P-33-0626 Colorado River 

Aqueduct

1931–present Unevaluated; assumed 

eligible

P-33-006913 Eagle Mountain 

mine and town site

(including railroad)

1947–1983 Previously determined not 

eligible (1996); pending 

re-evaluation

P-33-013987 Historic telegraph/

telephone line

Unknown Recommended not eligible

P-33-015091 Prehistoric lithic 

scatter/rock ring

Unknown Recommended not eligible

P-33-015093 Prehistoric lithic 

scatter

Unknown Recommended not eligible

P-33-015971 Desert Training 

Center (rock 

alignment possibly 

associated with 36th 

Evacuation Hospital)

Circa 1943 Recommended potentially 

eligible

P-33-017642 Desert Training 

Center (possibly 

associated with 36th 

Evacuation Hospital)

Circa 1943 Recommended potentially 

eligible

P-33017643 Trash Dump 1940s–1950s Not eligible

P-33017644 Trash Dump 1940s–1950s Not eligible

P-33017645 Trash Dump 1940s–1950s Not eligible

P-33017646 Trash Dump 1940s–1950s Not eligible

P-33017647 Trash Dump 1940s–1950s Not eligible

P-33017648 Isolate highway 

marker

1914–1934 Not eligible

DS-115 Historic Refuse Unknown Recommended not eligible
176

Primary 

Number/

Temporary 

Designation Description Date

National Register 

Eligibility

DS-120 Historic Refuse 

(Desert Center 

Dump)

Unknown Recommended Not 

Eligible

DS-123 Historic Refuse Unknown Recommended not eligible

DS-124 Historic Mining Unknown Recommended not eligible

DS-125 Historic Refuse Unknown Recommended not eligible

DS-132 Historic Refuse Unknown Recommended not eligible

DS-137 Historic Mining Unknown Recommended not eligible

DS-178 Historic Refuse Unknown Recommended not eligible

DS-179 Historic Refuse Unknown Recommended not eligible

DS-195 Historic Refuse Unknown Recommended not eligible

DS-203 Historic Road Unknown Recommended not eligible

DS-227 Historic/Modern 

Fire Ring

Unknown Recommended not eligible

DS-228 Prehistoric Lithic 

Scatter

Unknown Recommended not eligible

DS-231 Prehistoric Lithic 

Scatter

Unknown Recommended not eligible

DS-232 Historic Refuse Unknown Recommended not eligible

DS-239 Historic Refuse Unknown Recommended not eligible

DS-240 Prehistoric 

Habitation

Unknown Recommended potentially 

eligible

DS-245 Prehistoric Lithic 

Scatter

Unknown Recommended not eligible

DS-313 Historic Refuse Unknown Recommended not eligible

DS-314 Historic Refuse Unknown Recommended not eligible

DS-315 Prehistoric Lithic 

Scatter

Unknown Recommended not eligible

DS-316 Historic Refuse Unknown Recommended not eligible

DS-326 Historic Rock Unknown Recommended not eligible
177

Primary 

Number/

Temporary 

Designation Description Date

National Register 

Eligibility

Features

DS-327 Historic Post Unknown Recommended not eligible

DS-330 Historic Rock 

Feature

Unknown Recommended not eligible

DS-485 Historic Mining Unknown Recommended not eligible

DS-486 Historic Mining Unknown Recommended not eligible

DS-487 Historic Mining Unknown Recommended not eligible

DS-494 Historic Refuse Unknown Recommended not eligible

DS-495 Historic Refuse Unknown Recommended not eligible

DS-703 Historic Refuse Unknown Recommended not eligible

DS-705 Historic Mining Unknown Recommended not eligible

EM-1 Historic Refuse Unknown Recommended not eligible

the California SHPO subsequently requested re-evaluation of the resource (letter from 

M.F. Donaldson, California SHPO, Office of Historic Preservation Sacramento, CA, to 

R. Kaldenberg and J. Schafer, ASM Affiliates, Carlsbad, CA, October 26, 2009). 

Five historic can and trash scatters were also recorded within the APE (P-33-

17643 through P-17647). These appear to represent the disposal of household refuse 

along a dirt road during the late 1940s or 1950s, most likely from the community of 

Desert Center via Ragsdale Road. Because of their spatial dislocation from specific 

Desert Center households or enterprises proper, these sites are not associated with known 

persons or specific activities or periods with historic significance. Additionally, a 

concrete highway marker (P-33-17648) was recorded as an “isolate” but could also be 

interpreted as an “object.” Such monuments were used between 1914 and 1934. The 

California SHPO concurred that the five dump sites and the single isolate are not eligible 

for listing on the National Register (letter from M.F. Donaldson, California SHPO, Office 

of Historic Preservation, Sacramento, CA, to R. Kaldenberg and J. Schafer, ASM 

Affiliates, Carlsbad, CA, October 26, 2009). 

The Agua Caliente Band of Cahuilla Indians expressed concern with regard to 

prehistoric trails that may pass through the area (letter from S. Milanovic, Tribal Historic 

Preservation Office [THPO] Intern, Department of Historic Preservation, Agua Caliente 

Band of Cahuilla Indians, Palm Springs, CA, to G. Gillin, Project Manager, GEI 

Consultants, Rancho Cordova, CA, August 26, 2008). Such trails may be archaeological 
178

in nature and may also be considered TCPs. Eagle Crest responded that it was aware of 

previously recorded trail segments and associated sites that would have served as 

alternate travel routes to the Cocomaricopa Trail connecting the Colorado River to the 

Coachella Valley (letter from R. Kaldenberg, Principal, ASM Affiliates, Carlsbad, CA, to 

Sean Milanovich, THPO Intern, Agua Caliente Band of Cahuilla Indians, Palm Springs, 

CA, September 10, 2009). However, Eagle Crest stated that no evidence of prehistoric or 

ethnohistoric trails was found within the project APE and that existing records indicated 

that the trail system was located elsewhere.

None of the 39 resources located in the applicant’s proposed and the State Water 

Board’s recommended transmission routes or substation locations have been formally 

evaluated for listing on the National Register. However, the ASM Affiliates letter report 

recommends that site DS-240, consisting of a prehistoric habitation site, containing lithic 

artifacts, ceramics, and fire-affected rock, could contain information relevant to 

prehistoric use of the Chuckwalla Valley (Schaefer, 2010). Two additional sites (P-33-

017642 and P-33-015971) are potentially associated with the 36th Evaluation Hospital at 

the Desert Training Center. The inventory report states that both of these sites are also 

potentially eligible for the National Register (Schaefer, 2010). In its supplemental 

information filing, Eagle Crest (2010a) states that additional cultural materials extend 

north of these sites for several miles and that the potential exists for a National Register 

district or a multiple property submission exists. The remaining 36 sites have been 

recommended as ineligible. 

Traditional Cultural Properties and Sacred Sites

Contact with Native Americans that have traditional ties to the Eagle Mountain 

Project vicinity began in September 2007. On April 16, 2008, Eagle Crest’s consultant 

requested a records search of the California Native American Heritage Commission’s 

(NAHC’s) Sacred Lands File. A response was received on April 30, 2009, stating that no 

sacred lands were known within the proposed project area. 

Since September 2007, Eagle Crest and/or the Commission have requested input 

on the proposed project from the following Native American tribes:

• Agua Caliente Band of Cahuilla Indians,

• Barona Band of Mission Indians,

• Cabazon Band of Mission Indians,

• Cahuilla Band of Mission Indians,

• Chemehuevi Indian Reservation,

• Colorado River Indian Reservation,

• Fort Mojave Indian Tribe,

• Morongo Band of Mission Indians,
179

• Torres-Martinez Desert Cahuilla Indians, and

• Twenty-Nine Palms Band of Mission Indians.

The Agua Caliente Band of Cahuilla Indians requested a meeting to discuss the 

proposed project. The Morongo Band of Mission Indians also expressed an interest in 

the proposed project area. However, to date, no potential TCPs have been identified 

within the project APE.

3.3.6.2 Environmental Effects

Effects of Project Operations on Cultural Resources 

Cultural resources can be disturbed by any action (natural, animal, or human) that 

disturbs soils or ground surfaces on which they occur. Archaeological and historic-era 

sites are particularly susceptible to damage as a result of construction activity. 

Eagle Crest has identified 47 cultural resource properties that are located within 

the project APE, including the APE encompassing the applicant’s proposed and the State 

Water Board’s recommended transmission routes and substations (see table 12). The 

California SHPO determined that six of these resources are not eligible for the National 

Register (letter from M.F. Donaldson, California SHPO, Office of Historic Preservation 

Sacramento, CA, to R. Kaldenberg and J. Schafer, ASM Affiliates, Carlsbad, CA, 

October 26, 2009). 

The CRA has not been evaluated for the National Register, but will be treated as 

eligible. In its application, Eagle Crest states that because the CRA is buried where it 

would be crossed by proposed project transmission and water pipelines, construction 

activities are unlikely to affect the qualities of the property that could make it eligible for 

the National Register. 

In its application, Eagle Crest cites the SHPO’s 1996 letter concurring that the 

Eagle Mountain town site and mine are not eligible for the National Register. Further, 

the last sentence in section 1, Overview and Executive Summary, of the HPMP also 

implies that this resource is not a historic property. However, in section 2.4 of the 

HPMP, Eagle Crest correctly acknowledges that the site and its associated railroad may 

now meet National Register eligibility criteria and that project construction and 

subsequent operation and maintenance activities have the potential to affect this resource. 

Because the project also could potentially affect previously unidentified cultural 

resources and human remains, the Aqua Caliente Band of Cahuilla Indians (letter from S. 

Milanovic, THPO Intern, Department of Historic Preservation, Agua Caliente Band of 

Cahuilla Indians, Palm Springs, CA, to G. Gillin, Project Manager, GEI Consultants, 

Rancho Cordova, CA, August 26, 2008) and the Cabazon Band of Mission Indians (Eagle 

Crest, 2009c) both recommend the presence of cultural resources monitors during 

construction activities. 
180

Eagle Crest (2010a) states that site DS-240 is discrete in size and can be avoided 

during through project design to mitigate potential effects, but that construction of the 

transmission alternative through sites P-33-017642 and P-33-015971 has the potential to 

cause direct and indirect effects on the physical remains of the 36th Evacuation Hospital 

site and other associated remains form the World War II era Desert Training 

Center/CAMA.

Our Analysis

Construction and operation activities of the proposed Eagle Mountain Project 

would have the potential to affect known cultural resource properties, including the CRA, 

which remains unevaluated but is considered to be eligible for the National Register; the 

Eagle Mountain mine and town site (P-33-006913) and its associated railroad; and the 39 

unevaluated sites identified in the applicant’s proposed and the State Water Board’s 

recommended transmission routes and substation locations. Project construction and 

operation activities also could potentially affect potential TCPs, unanticipated 

discoveries, and human remains that may be identified in the future. 

In its June 2009 final license application and subsequent December 2009 HPMP, 

Eagle Crest proposes measures to address sites potentially subject to adverse project 

effects. Staff analyzes and discusses these proposed measures in Management of Historic 

Properties below.

Management of Historic Properties

In its June 2009 final license application, Eagle Crest proposed several measures 

to address potential project effects to cultural resources. These are:

• CLT-1—Evaluate cultural sites for their National Register eligibility;

• CLT-2—Monitor sensitive areas during construction; and 

• CLT-3—In the event that historic properties or human remains are identified 

during construction of the project, develop an HPMP in consultation with 

BLM, the California SHPO, and Native American tribes. 

These measures would apply only to lands within the APE outside of the Kaiser 

property. In December 2009, Eagle Crest filed an HPMP (referred to herein as CLT-4) 

that contains measures for the entire Eagle Mountain APE, including measures for 

potential project effects on cultural resources located on Kaiser lands. The HPMP 

contains and replaces Measures CLT-1 through CLT-3 referred to in the final license 

application. 

The HPMP was developed in consultation with the California SHPO, BLM, Agua 

Caliente Band of Cahuilla Indians, Cabazon Band of Mission Indians, Chemehuevi 

Indian Reservation, Colorado River Reservation, Fort Mojave Indian Tribe, Morongo 

Band of Mission Indians, Torres-Martinez Desert Cahuilla Indians, and the Twenty-Nine 

Palms Band of Mission Indians (Eagle Crest, 2009e). The HPMP would be used by 
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Eagle Crest staff to ensure that the management goals for the preservation or appropriate 

treatment of historic resources are achieved. The HPMP was prepared in consideration of 

a document prepared in consultation with the Commission titled, Guidelines for the 

Development of Historic Properties Management Plans for FERC Hydroelectric Projects

(ACHP, 2002). It its HPMP, Eagle Crest Energy proposes to undertake a variety of 

general measures for implementing the HPMP and managing cultural resources, 

including:

• Appointment of a historic properties management coordinator, who would be 

responsible for overseeing implementation of the HPMP.

• Preparation of an implementation report every 2 years during project 

construction and every 6 years during operation and maintenance. These 

reports would be provided to agencies and tribes and describe all activities 

associated with the HPMP that were undertaken during that reporting period.

• Preparation of a plan to review the effectiveness of the HPMP every 6 years in 

consultation with the California SHPO, BLM, Riverside County, interested 

tribes, the Commission, and other consulting parties.

• Pre-action review of planned actions involving ground disturbance conducted 

by the historic properties management coordinator in consultation with the 

California SHPO, interested tribes, and appropriate land management agencies, 

as specified in the HPMP.

• Implementation of protocols for future cultural resources field investigations 

(i.e., field survey, archaeological testing, data recovery or other alternative 

mitigation measures), which include consultation with the California SHPO, 

agencies, and interested tribes.

• Implementation of a plan and procedures to address the inadvertent discovery 

of previously unknown cultural resources or human remains. This plan would 

provide for the development of an as-needed monitoring program for sensitive 

areas.

• Development of a cultural resources element for a project WEAP that would 

ensure that Eagle Crest employees are familiar with cultural resource laws and 

regulations, instructions on HPMP protocols and requirements, and other 

information regarding historic properties. 

• Development of interpretive signage that would be placed outside the main 

gate of the proposed facility and would provide the public with information 

about the prehistory and history of the project area, the Native Americans who 

inhabited the area, and background information on the functioning of the Eagle 

Mountain Project. 

The HPMP also includes measures specific to potential historic properties 

identified within the APE that was approved by the SHPO in 2009. Eagle Crest proposes 
182

to design project transmission lines and water pipes to avoid direct or indirect effects on 

buried portions of the CRA. Inspections would be undertaken every 2 years to determine 

whether conditions are stable or if any disturbances or deterioration has occurred. 

Further, Eagle Crest proposes to prepare a work plan to document the Eagle Mountain 

mine and town site and associated railroad, including the potential for a historic district, 

upon gaining legal access to the lands. Upon completion of documentation of the site and 

any other cultural resources within the Kaiser property in the APE, Eagle Crest would 

consult with the California SHPO, BLM, and the Commission to evaluate National 

Register eligibility. If any resources are determined to be eligible, the HPMP calls for 

avoidance or mitigation measures to be developed, and consultation with the California 

SHPO with regard to potential project effects. Finally, in the event that interested tribes 

identify potential TCPs within the project APE, Eagle Crest’s proposed HPMP includes a 

plan to document and evaluate such properties and to resolve project adverse effects on 

TCPs that are eligible for the National Register. 

In its draft EIR, the State Water Board (2010) commented that the construction 

would have potentially significant effects on the CRA (P-33-06726), resources located in 

the central project area (e.g., the Eagle Mountain mine and town site and associated 

railroad, P-33-006913), and unknown or buried cultural resources. However, the State 

Water Board concluded that these effects would be reduced to less than significant, if the 

measures proposed within the HPMP are implemented. 

Our Analysis

Eagle Crest’s proposal to appoint a historic properties management coordinator 

would ensure that the requirements of the HPMP are followed. Additionally, regular 

reporting to agencies and affected tribes on the status of overall cultural resources 

management would provide a forum for parties to discuss the HPMP and provide 

recommendations about management of cultural resources. However, annual reporting 

during construction (rather than reporting every 2 years) and annual reporting during 

subsequent operation and maintenance (rather than reporting every 6 years) is standard 

for hydroelectric projects. Annual reporting would ensure that consulting parties are 

regularly informed of project activities and any cultural resources issues that may arise 

over the license term. The frequency of reporting could be decreased in the future if the 

Commission and other consulting parties agree that annual reporting is no longer 

warranted.

Eagle Crest proposes to review the HPMP every 6 years. Affording appropriate 

federal land-management agencies the opportunity to comment, along with the California 

SHPO and tribes, on proposed revisions to the HPMP would ensure that those with an 

interest in the management of cultural resources would be able to contribute their views. 

Such a review process is typically undertaken every 5 years under FERC hydroelectric 

project licenses. However, Eagle Crest’s plan to review the HPMP every 6 years 

concurrent with the Licensed Hydropower Recreation Report (FERC Form 80) would 
183

likely provide comparable protection to cultural resources. If consulting parties wish to 

request an earlier review based on the results of the annual HPMP implementation report, 

Eagle Crest could include a clause in the HPMP to allow for an earlier review. 

As specified in the HPMP, Eagle Crest’s implementation of review procedures 

prior to ground-disturbing activities and protocols for future cultural resources field 

investigations would ensure that cultural resources are considered during project planning 

and that appropriate studies are undertaken. Further, the HPMP, Appendix A, contains 

protocols to be followed if previously unknown cultural resources or human remains are 

identified during project activities. Implementation of these measures would ensure that 

new discoveries are treated appropriately. However, the HPMP does not discuss the 

curation of archaeological materials that may be recovered during pre-construction 

fieldwork or fieldwork that may be undertaken in the future. Including in the HPMP a 

plan to address curation of the materials, which would be in accordance with federal and 

state requirements, would ensure that such materials are properly conserved and 

accessible, under properly controlled conditions, to those with appropriate research or 

cultural interests.

The HPMP also discusses the need for archaeological monitoring during 

construction activities and states that if archaeological monitoring is required, it would be 

conducted by a qualified cultural resources specialist and by a designated Native 

American monitor. However, the HPMP does not describe the circumstances under 

which a monitor would be needed and who would make that decision. It also does not 

specify a process for determining which of the interested tribes would provide the Native 

American monitor. Inclusion of specific parameters within the HPMP for monitoring, 

both during construction and during subsequent project operation and maintenance 

activities requiring ground disturbance, and a process for consultation with interested 

tribes to appoint a Native American monitor, would ensure that monitoring is undertaken 

appropriately.

Eagle Crest’s proposal to include a cultural resources element to its WEAP 

program would ensure that staff is regularly informed about issues, procedures, and 

protocols regarding cultural resource management in the project area. Additionally, 

Eagle Crest’s proposal to install interpretive signage regarding cultural resources would 

enable the public to become aware of the cultural importance of the project area. The 

inclusion on the signs of information pertaining to site protection and applicable laws 

would provide an effective vehicle for educating the public about vandalism, its effects, 

and its potential legal consequences. Consultation with interested Native American tribes 

during the development of the training sessions and providing them with an opportunity 

to provide input on the interpretive signs would contribute toward staff and public 

understanding of Native American perspectives on cultural resources. 

Implementation of the measures for the identification, management, and treatment 

of resources associated with the CRA and the Eagle Mountain town site, mine, and 

associated railroad that are contained within Eagle Crest’s proposed HPMP would ensure 
184

that the potential effects of the project upon these resources are properly addressed in 

accordance with section 106. However, revision of the HPMP’s Overview and Executive 

Summary to correctly identify the Eagle Mountain mine and town site and railroad as a 

potential historic property help clarify that issue.

Additionally, the HPMP does not discuss the additional APE that includes the 

State Water Board’s recommended transmission route and substation location. Revision 

of the HPMP to include (1) a detailed discussion of the expanded APE alternatives, 

including revised APE maps; (2) a description of the sites documented by Schaefer 

(2010) and located within the expanded APE; and (3) inclusion of a detailed plan and 

schedule for National Register evaluations, assessment of effects, and identification of 

measures to resolve adverse effects of project construction, operation, and maintenance 

on any of sites identified within the specific Commission staff’s recommended 

transmission line corridor and substation location, including the documentation of 

appropriate consultation with the participating tribes, BLM, and California SHPO would 

ensure that these properties are appropriately considered in accordance with section 106. 

Section 4.2 of the December HPMP currently contains procedures to evaluate the effects 

of project activities to cultural resources both within and outside of the APE as previously 

approved by the California SHPO; these procedures would ultimately apply to the 

specific Commission staff’s recommended transmission line corridor and substation 

location. However, because revisions to the HPMP are recommended to address other 

issues, it would be reasonable to address the expanded APE and the new alternatives in 

the revised HPMP at this time as well. 

Finally, staff finds that it is appropriate for Eagle Crest to include the handling of 

newly discovered paleontological resources on federal land either in the final HPMP, or 

as an appendix to it, due to the recent paleontological law enacted by Congress in March 

of 2009 that requires all federal land managers to manage and protect paleontological 

resources discovered on their lands.37

 

37 See Omnibus Public Land Management Act (OPLMA) of 2009, Public Law 

111-011. P.L. 111-011, Title VI, Subtitle D on Paleontological Resources Preservation 

(OPLMA-PRP) (123 Stat. 1172; 16 U.S.C. 470aaa). This statute requires the Secretaries 

of the Interior and Agriculture to manage and protect paleontological resources on federal 

land using scientific principles and expertise. The OPLMA-PRP includes specific 

provisions addressing management of these resources by BLM, the Park Service, the 

Reclamation, FWS, and the Forest Service.

 Although staff recognizes that section 106 has no 

provisions for protecting paleontological resources, such resources should be protected in 

any case, and it is appropriate to use an HPMP to reference the protection of such 

resources because they are similar in nature to archeological resources. 
185

3.3.7 Socioeconomics

3.3.7.1 Affected Environment

Riverside County is located in southern California and stretches from the Colorado 

River and Arizona border in the east to Orange County and within 14 miles of the Pacific 

Ocean to the west. The county encompasses about 7,200 square miles. The 

socioeconomic study area is defined as the unincorporated areas of eastern Riverside 

County (Eagle Mountain, Lake Tamarisk, and Desert Center) and cities within about 60 

miles of the project (Blythe, Coachella, Indio, Palm Desert, Cathedral City, and Palm 

Springs). This description of the socioeconomic environment relies upon statistics at the 

county level, with local details provided where data are available. 

Population

The population of Riverside County grew 35 percent from the 2000 census of 

1,545,387 to an estimated 2,088,322 in 2008 (California Department of Finance, 2008, as 

cited by Eagle Crest, 2009a). The county’s population ranks fourth of California’s 58 

counties and is more than the population of 15 states in the United States. The City of 

Riverside, which is the county seat and is located about 100 miles west of the project site, 

had an estimated 2008 population of 296,842, equaling 14 percent of the county’s 

residents. 

Population trends for the study area towns are shown in table 13. Most have 

grown more rapidly than the county as a whole, although some of that growth was in the 

population of inmates in the Chuckwalla Valley State Prison and Ironwood State Prison. 

The inmates are counted in the City of Blythe’s population for state tax purposes. 

Table 13. Population (Source: Riverside County Economic Development Agency, 

2004, as cited by Eagle Crest, 2009a).

Area 1980 1990 2000 2007

Blythe 6,805 8,428 20,465 22,625

Cathedral City a 30,085 42,647 52,115

Coachella 9,129 16,896 22,724 38,486

Indio 21,611 36,793 49,116 77,146

Palm Desert 11,081 23,252 41,155 49,752

Palm Springs 32,359 40,181 42,805 46,858

Riverside County 663,166 1,170,413 1,545,387 2,031,625

a Incorporated in 1981.
186

Eagle Mountain is located in an 802-square mile Census block group that had a 

population of 738 people in 1990 and 977 people in 2000, giving it a population density 

of 1.2 people per square mile. The project site is located about in the center of the 

Census block group.

The Eagle Mountain town site population peaked at 3,700 residents (CH2M HILL, 

1996, as cited by Eagle Crest, 2009a), and was listed as having 2,453 people in 1970 and 

1,890 people in 1980 (U.S. Bureau of the Census, 2008, as cited by Eagle Crest, 2009a). 

The closing of the mine in 1983 also led to the closing of the private town of Eagle 

Mountain, and also slowed or stopped growth in nearby communities such as Desert 

Center and Lake Tamarisk. 

Riverside County is expected to double its population between 2000 and 2020, 

reaching an estimated population of 2.9 million people in 2020 (Riverside County, 2003, 

as cited by Eagle Crest, 2009a). The county grew in total population by 31.5 percent 

between 2000 and 2007, while the state of California grew by only 7.6 percent during the 

same time period. 

The county has an average of 214.4 people per square mile in 2006 but much 

higher in the urbanized west and much lower (1.2 people per square mile) in the project 

region and similar low densities in surrounding open spaces of the central and east 

portions of the county.

Employment and Income 

The Riverside County Economic Development Agency (2009, as cited by Eagle 

Crest, 2009a) states that the unemployment rate within Riverside County from 1990 to 

2006 has been above the state and national averages. The agency’s data show a civilian 

labor force of 910,400 residents with 845,700 employed and an unemployment rate of 

7.1 percent in February 2008. The County experienced an unemployment rate of 

between 5.1 percent and 6.7 percent from 1998 to 2007. Riverside County employment 

by sector for 2006 is depicted in table 14.

The United States Census states that the median household income in 2006 was 

$53,508 for Riverside County, which was below the state median of $56,645. The 

California Department of Finance shows that in 2005 the per capita income for Riverside 

County was $27,167, which was 73.6 percent of the California average. The United 

States Census shows that 12.2 percent of people were below the poverty level in 2006, 

down from 14.2 percent in 2000 and up from 10.8 percent in 1990 (U.S. Bureau of the 

Census, 2008, as cited by Eagle Crest, 2009a). 

The Riverside County Economic Development Agency (2006, as cited by Eagle 

Crest, 2009a) shows the taxable sales within the County were $29,816,237 in 2006, up 

from the 2001 total of $18,231,555. The tax rate for Riverside County including state, 

local, and district tax is 7.75 percent.
187

Table 14. Riverside County employment by sector, 2006 (Source: U.S. Bureau of the 

Census, 2008, as cited by Eagle Crest, 2009a).

Industry Individuals Percentage

Agriculture, forestry, fishing and hunting, and 

mining 

13,824 1.6%

Construction 112,297 12.7%

Manufacturing 90,885 10.3%

Wholesale trade 32,279 3.7%

Retail trade 119,795 13.6%

Transportation and warehousing, and utilities 40,334 4.6%

Information 16,973 1.9%

Finance, insurance, real estate, and rental and 

leasing

58,680 6.7%

Professional, scientific, management, 

administrative 

80,500 9.1%

Educational, health and social services 147,594 16.7%

Arts, entertainment, recreation and food services 90,159 10.2%

Public Administration 35,430 4.0%

Other Services 42,553 4.8%

Total 881,303

Infrastructure and Accommodations 

Housing

The California Department of Finance’s (2008, as cited by Eagle Crest, 2009a) 

data indicate that there were about 773,331 housing units in the county in 2008, 

compared to 584,674 units in 2000. The figures for 2008 include 559,169 units of single 

family housing and 127,740 multiple family units. The median home price for the 

County stood at $234,105 in January 2009. Housing accommodations for towns in the 

project region are depicted in table 15. 
188

Table 15. Housing accommodations and characteristics (Source: Riverside County 

Economic Development Agency, 2008, as cited by Eagle Crest, 2009a).

Median Home 

Price 

Median 

Rental 

Price Total Units Vacancy Rate

Owner 

Occupied

2000 2008 2000 2000 2008 2000 2008 2000

Blythe $90,800 $187,000 $501 4,851 5,444 16.2% 16.1% 57%

Cathedral 

City 

$125,500 $226,500 $695 17,813 21,561 21.7% 21.1% 65%

Coachella $83,700 $215,500 $470 4,807 8,814 4.4% 4.4% 61%

Indio $99,000 $272,500 $579 16,899 26,464 18.0% 18.0% 56%

Palm 

Desert 

$189,100 $382,500 $744 28,071 34,120 31.5% 31.0% 67%

Palm 

Springs 

$157,000 $295,000 $631 30,979 33,479 33.3% 33.4% 61%

Riverside 

County 

$146,500 $275,000 $660 584,674 773,331 13.4% 13.0% 69%

In 2008, the vacancy rate for all housing units (single family, multiple family, and 

mobile homes) within the County was 13 percent. Within the project region, Palm 

Springs accounted for the highest vacancy rate at 33.4 percent or 11,192 units in 2008. 

The City of Coachella experienced the lowest rate at 4.4 percent or 386 units. The 

combined total number of vacant housing units for the six towns within the project region 

is 28,021, with 100,533 vacant units county-wide (California Department of Finance, 

2008, as cited by Eagle Crest, 2009a). The U.S. Census 2005-2007 Community Survey 

shows 193,931 renter-occupied housing units with 12,818 vacant rental units and a rental 

vacancy rate of 6.2 percent.

Within the cities in the project region, there are about 257 hotels/motels 

accounting for 11,599 rooms. Palm Springs contains the highest number with 187 hotels 

and motels and 6,400 rooms (Riverside County Economic Development Agency, 2004, 

as cited by Eagle Crest, 2009a). 

Community, Municipal, and Social Services 

Community and social services available in the County include educational 

facilities, churches, libraries, hospitals, and nursing homes. 

All major municipalities within the project region provide basic municipal 

services. Within unincorporated areas, services are provided by Riverside County. 
189

Within the project region and specifically the Eagle Mountain area, water and sewer 

systems are adequate to meet the communities’ existing needs. In addition to the basic 

services provided in the Eagle Mountain area, the County also provides enhanced 

services through County Service Areas (CSA). CSA 51, which includes the Eagle 

Mountain area, provides water, sewer, and trash disposal services. The Eagle Mountain 

town site has water and sewer services provided by Kaiser’s wastewater collection and 

treatment system and two Kaiser-owned wells. 

Enrollment of students in the Riverside County K-12 schools for 2006/2007 is 

413,059. In addition, there are 23 school districts within the County. These districts 

contain 265 elementary schools, 74 middle schools and 65 high schools, 11 charter 

schools and 50 continuing education/adult education schools. The school districts 

employed 21,663 certified staff members with 11.8 average years of teaching experience 

and 17,105 classified staff.

Riverside County and local municipalities within the project region maintain law 

enforcement departments. Riverside County currently employs 1,879 patrol officers and 

a total of 3,865 funded positions. The nearest County Sheriff station to the project site is 

the Colorado River Station located in Blythe (Riverside County Sheriff's Department, 

2008, as cited by Eagle Crest, 2009a), more than 40 miles from the proposed project site. 

The major municipalities within the project region maintain fire departments. 

Riverside County operates 93 stations with 952 career and 1,100 volunteer personnel for 

unincorporated and sixteen contract cities. Riverside County station #49 at Lake 

Tamarisk is the closest station with #45 Blythe Air Base and #43 Blythe being the next 

nearest stations. All three stations are staffed full time, 24 hours a day, 7 days per week 

with a minimum 3-person crew, including paramedics.

Municipalities within the project region provide emergency medical services in 

addition to fire protection. The nearest hospitals to the project site are located at Indio 

and Blythe, each more than 40 miles away. Riverside County has about 18 licensed 

hospitals with 3,134 beds. Within the project region, there are four licensed hospitals 

with 816 beds. Within the County there are 24 community clinics, 35 surgical clinics, 

and 3 rehabilitation clinics. 

3.3.7.2 Environmental Effects 

Effects of Construction on Socioeconomics

Construction of the proposed project is expected to occur over a period of 4 years 

and to generate about 4,674 person-months of employment during that time. Peak 

monthly employment of 209 workers would occur in Year 2. 

Eagle Crest estimates the total construction workforce payroll cost for the project 

to be $58 million. Additionally, project construction is estimated to require $39 million

in design engineering, $49 million in construction administration and engineering, and $3 

million in legal and administrative costs. The distribution of this payroll would fluctuate 
190

over time and would parallel the fluctuations in employment. Labor expenditures would 

be highest in Year 2. 

Eagle Crest does not propose any mitigation measures related to socioeconomic 

parameters such as employment, income, or local government services.

Our Analysis

Project construction would have a beneficial effect on local employment and 

income. Eagle Crest expects that most of the general labor required during construction 

would be available from the labor pool within the County and project region, indicating 

that as much as 50 percent of the skilled trades and management and support personnel 

could also be provided by regional labor. There would be some need for non-local 

workers to meet the project manpower requirements. Current estimates of the peak 

construction work force and the expected percentage of non-local workers suggest that 

during the peak period about 105 workers would require short-term (2 years or less) 

housing accommodations. 

Eagle Crest is not proposing to use the Eagle Mountain town site for employee 

housing, but expects that workers needing short-term housing would find lodging in the 

available houses, rental units, or hotel/motel rooms that are locally abundant. This 

includes 28,021 vacant housing units and 12,818 vacant rental units within the County, as 

well as about 11,600 hotel/motel rooms within the communities of Blythe, Cathedral 

City, Palm Desert, Palm Springs, and Indio.

Primary and secondary schools within the project region have room for additional 

students if any school age children accompany the construction workers who temporarily 

relocate to the area. 

Medical facilities also appear to be adequate, with one bed per about 645 people 

within the County. In addition, Riverside County operates a full-time fire station in Lake 

Tamarisk. Eagle Crest would be required to follow the Development Impact Fee 

Program as adopted by Riverside County to assess fees for the fire district. Because no 

new housing construction is anticipated, it is expected that existing public services 

(water, sewer, waste) would meet the requirements of the project-related workforce. 

Because of the anticipated small effect on municipal services and infrastructure, 

the effect on local municipal costs during construction is expected to be insignificant; 

further, as described below, it would be offset by anticipated tax revenues. 

The project would contribute to the revenues of County and local governments 

primarily through the payment of property taxes and sales and use taxes. With respect to 

property taxes, the assessed valuation of the project and the associated property tax 

payments would rise on an annual basis, in proportion to the work completed. Based 

upon on the construction cost estimate and tax schedule, Eagle Crest estimates that 

property taxes would rise to about $8,390,000 (2008 Dollars) per year by the time 

construction is complete. Sales tax, at a rate of 7.75 percent, is imposed on the sale of 
191

tangible personal property and specified services. With an estimated construction cost of 

$1,171 million (2009 Dollars), the project could generate substantial sales tax revenue 

through the purchase of material and equipment within the county, although the amount 

of those purchases has not been estimated.

Project construction would also have indirect effects on employment, income, and 

government revenues associated with the construction workforce and the purchase of 

materials and supplies. For construction activity of this type, gross output multipliers 

often range from 1.0 to 1.5. This means for every dollar spent in the county on materials 

and supplies, the indirect effect would account for an additional $1.00 to $1.50 in 

spending. 

Employment multipliers also generally range from 1.0 to 1.5 for construction 

projects. This means for every construction job created, another 1.0 to 1.5 job(s) would 

be created in the retail, service, and non-basic employment sectors. 

Effects of Operations on Socioeconomics

An estimated 30 persons would manage, operate, and maintain the project, 

working in two 15-person shifts. The total staff requirement per shift includes three 

management personnel, seven engineers, two power plant operators, one maintenance 

technician and two administrative staff. Energy Crest estimates the annual labor cost 

(operations staff plus home office administration) at $2.3 million (2009 dollars). 

Eagle Crest does not propose any mitigation measures related to socioeconomic 

parameters such as employment, income, and local government services. 

Our Analysis

The socioeconomic effect of the project during the operation phase would be much 

less than during the construction phase, although the project estimates an annual 

operating budget of $28.3 million (2009 dollars). 

The annual O&M budget for project supplies and parts would be $2.5 million. 

Purchase of supplies and parts within the region would add annual local economic 

benefits. 

The project would not have any substantial ongoing effects on local/County 

government costs. The relatively small labor force is unlikely to create any effects on 

housing, schools, and other public services within the project area. 

Eagle Crest estimates that the project would generate about $7.67 million per year 

in property tax revenue at the completion of construction. Sales tax revenue would 

decrease during the project’s operational phase compared to the construction phase, but 

Eagle Crest estimates that about $187,500 in annual sales tax revenue could be generated 

from the purchasing of plant supplies and parts. Eagle Crest may also be required to pay 

taxes on the tangible personal property on the facility (equipment, inventories, etc.). 
192

The ongoing expenditures for materials, services, and payroll would also generate 

indirect benefits within the region. The typical multiplier for utilities operations is 1.5 for 

employment. Therefore, the operations workforce of 30 personnel may generate up to an 

additional 15 indirect or secondary jobs. 

There would be no displacement of residences or business establishments due to 

construction and operation of the project. 

3.3.8 Air Quality and Noise

3.3.8.1 Affected Environment

Air Quality

The California Air Resources Board (CARB), part of the California EPA and one 

of the entities, along with local air districts, responsible for achieving and maintaining 

healthful air in California, reports that air pollution is one of the state’s most serious 

problems (CARB, 2010). The reasons for the state’s air quality problems include: (1) a 

large population (about 37 million and growing), which translates into a high number of 

vehicle miles traveled and associated vehicle emissions; (2) a geography with the most 

heavily populated areas of the state being valleys or basins surrounded by mountains; and 

(3) a climate of hot, stagnant summer air that traps air pollutants in heavily populated 

valleys and basins. Sources of air emissions in California include stationary sources 

(e.g., commercial facility operations), area-wide sources (e.g., fugitive dust, residential 

fireplaces), mobile sources (e.g., on-road vehicles and trucks, aircraft, boats, trains), and 

natural sources (e.g., biogenic and geogenic hydrocarbons, natural windblown dust, 

wildfires).

State and National Air Quality Standards

To maintain acceptable ambient air quality and protect public health, both 

California and the federal government have adopted ambient air quality standards 

(AAQSs) for criteria or indicator air pollutants. An AAQS establishes the concentration 

above which the pollutant is known to cause adverse health effects on sensitive groups 

within the population, such as children and the elderly. The goal is for localized project 

effects not to cause or contribute to an exceedance of the standards. AAQSs are 

classified as either “primary” or “secondary” standards. Primary standards define levels 

of air quality, including an adequate margin of safety, necessary to protect the public 

health. National secondary AAQSs define levels of air quality necessary to protect the 

public welfare from any known or anticipated adverse effects of a pollutant. The criteria 

pollutants for which standards have been established are carbon monoxide, lead, ozone, 

nitrogen dioxide, particulate matter (PM10 and PM2.5), and sulfur dioxide. Brief

descriptions for the four criteria pollutants of most relevance to the proposed project are 

provided below.
193

Carbon Monoxide

Carbon monoxide is a colorless, odorless gas that is directly emitted as a 

byproduct of combustion. The principal sources of carbon monoxide emissions are 

motor vehicles, and the highest concentrations of this gas occur under cold, stagnant 

weather conditions. Carbon monoxide is harmful because it is absorbed through the 

lungs into the blood stream and reduces the ability of the blood to transport oxygen. As a 

result, the blood supply to the heart, lungs, and other tissues is reduced, with potentially 

critical consequences for the sick and elderly. 

Particulate Matter (PM10 and PM2.5)

Particulate matter is a mixture of different substances, including metals, carbon, 

nitrates, sulfates, organic compounds, and complex mixtures such as diesel exhaust and 

soil. Particulate matter has been classified as either PM10 or PM2.5 material. PM10

particulates, which have an aerodynamic diameter of 10 microns or smaller, are referred 

to as “respirable” material because they are small enough to penetrate into inner regions 

of the lungs where they can be harmful to human health. PM2.5 particulate matter, which 

is even finer (aerodynamic diameter of 2.5 microns or smaller), can deposit deeper in the 

lungs when inhaled. Exposure to particulate matter aggravates respiratory illnesses and is 

especially harmful to people with pre-existing heart and lung diseases. Particulate matter 

(both PM10 and PM2.5) can either be directly emitted (e.g., dust or soot) or formed in the 

atmosphere from precursor gaseous emissions, including nitrogen oxides, sulfur oxides 

and ammonia. Based on EPA estimates, the largest contributor to PM10 levels nationwide 

is fugitive dust, which accounts for 89 percent of the total particulate matter. EPA also 

estimates that about 14 percent of fugitive dust is attributable to construction activities 

and 9 percent to re-suspension on paved roads. 

Ozone

Ozone is a colorless, odorless gas that constitutes the main component of urban 

smog. Ozone is not directly emitted as a pollutant, but is formed when precursor 

hydrocarbon and nitrogen oxides emissions react photochemically in the presence of 

sunlight. Stagnant air or low wind speeds and warm temperatures provide optimum 

conditions for ozone formation. Ozone irritates the lungs and damages the respiratory 

system. 

Sulfur Dioxide 

Sulfur dioxide (SO2) is a combustion product of sulfur or sulfur–containing fuels,

such as coal and diesel. SO2, which is also a precursor to the formation of atmospheric 

sulfate and particulate matter, contributes to potential atmospheric sulfuric acid formation 

that could precipitate downwind as acid rain. 
194

For most of the criteria air pollutants, California State standards are more stringent 

than federal standards because of inferences from different health effects studies and 

incorporation of a higher margin of safety to protect sensitive individuals. California and 

federal (i.e., EPA) AAQSs for criteria pollutants are presented in table 16.

Table 16. Selected California and federal ambient air quality standards (Source: 

CARB, 2010; EPA, 2010).

Pollutant

Averaging 

Time

California 

Standards

Federal Standards

Primary Secondary

Ozone (O3) 1 hour 0.09 ppm 

(180 μg/m3

)

0.12 ppm 

(235 μg/m3)

Same as 

primary 

standard 8 hour 0.07 ppm 0.08 ppm 

(157 μg/m3)

Respirable 

particulates 

(PM10)

24 hour 50 μg/m3 150 μg/m3 Same as 

primary 

standard Annual mean 20 μg/m3 50 μg/m3

Fine 

particulates 

(PM2.5)

24 hour No standard 65 μg/m3 Same as 

primary 

standard Annual mean 12 μg/m3 15 μg/m3

Carbon 

monoxide 

(CO)

8 hour 9 ppm (10 mg/m3) 9 ppm (10 mg/m3) None

1 hour 20 μg/m3

(23 mg/m3)

35 μg/m3

(40 mg/m3)

1 hour 0.18 ppm 

(472 μg/m3)

0.100 ppm

Sulfur dioxide 

(SO2)

Annual mean -- 0.03 ppm 

(80 μg/m3)

--

24 hour 0.04 ppm 

(105 μg/m3

)

0.14 ppm 

(365 μg/m3)

--

3 hour -- -- 0.5ppm 

(1,300 μg/m3

)

1 hour 0.25 ppm 

(655 μg/m3)

-- --
195

Under the federal Clean Air Act, each state must identify non-attainment areas that

do not meet the National Ambient Air Quality Standards (NAAQS). For any nonattainment designation, a State Implementation Plan (SIP) is developed to define actions 

to be taken to achieve attainment of the applicable NAAQS. In summary: 

• An attainment area is any area that meets the NAAQS,

• A non-attainment area is any area that does not meet the NAAQS, and 

• A maintenance area is any area previously designated non-attainment that is in 

transition back to attainment.

As shown in table 17, the area surrounding the proposed project site is currently 

designated as attainment for all criteria pollutants subject to NAAQS, but is designated 

by CARB as nonattainment for ozone and PM10 under the California AAQSs. 

Table 17. Project area designations in 2010 under NAAQS and California AAQS

(Source: Eagle Crest, 2009a).

Designation by: CO PM10 PM2.5 O3 NO2 SO2 Pb

NAAQSa A A A A A A A

California AAQSb U N U N A A A

Notes: A – attainment

CO – carbon monoxide

N – non-attainment

NO2 – nitrogen dioxide

O3 –ozone

Pb – lead 

PM2.5 – fine particulate matter

PM10 – respirable particulate matter

SO2 – sulfur dioxide

U – unclassified (treated as attainment)

a EPA (2010)

b CARB (2010)

General Conformity is the federal process used to ensure that the air quality effects 

of federal actions not related to motor vehicle transportation plans are also considered in 

the air quality planning of nonattainment and maintenance areas. Because the area 

surrounding the proposed project site is currently designated as attainment/unclassified 

for all NAAQS, although it is nonattainment for the California AAQS for ozone and 

PM10, General Conformity is not applicable and a General Conformity Determination is 

not required for the Eagle Mountain Project. 

Prevention of Significant Deterioration (PSD) regulations were first promulgated 

by the EPA (40 CFR part 52) to prevent air quality degradation in those areas where 
196

criteria air pollutant concentrations are below (within) the ambient standards (i.e.,

attainment areas). Exceedance of a PSD trigger level requires a demonstration by 

pollutant dispersion modeling that the emissions will not interfere with the attainment or 

maintenance of any NAAQS at the point of maximum effect and would not cause an 

exceedance of a PSD increment. 

South Coast Air Quality Management District

To better manage common air quality problems, California is divided into 15 air 

basins, each of which is associated with an Air Quality Management District (AQMD). 

The project site is located within the Mojave Desert Air Basin, which is within the 

jurisdiction of the SCAQMD The SCAQMD acts as the primary reviewing agency for 

environmental documents addressing potential air quality impacts, and it develops 

regulations that must be consistent with, or more stringent than, federal and state air 

quality policies. The SCAQMD is responsible for developing attainment plans for the 

region for inclusion in California’s SIP, as well as establishing and enforcing air pollution 

control rules and regulations. The attainment plans must demonstrate compliance with 

federal and state AAQSs, and must first be approved by CARB before inclusion into the 

SIP. The SCAQMD regulates, permits, and inspects stationary sources of air pollution, 

while the state is responsible for emission standards and controlling actual tailpipe 

emissions from motor vehicles. For the Eagle Mountain Project, the relevant rules and 

regulations are as follows: 

• Rule 402—requires implementation of dust suppression techniques to prevent 

fugitive dust from creating a nuisance off site, and

• Rule 403—requires use of best available technologies to reduce the amount of 

particulate matter (dust) entrained in ambient air as a result of anthropogenic 

(human-made, e.g. construction) activities. 

Because the project site is in California, the potential effects on air quality are

determined based on CEQA guidelines, SCAQMD thresholds for criteria pollutants, and 

other relevant considerations. These guidelines identify certain thresholds that may be 

pertinent in determining whether an effect is significant. Using these thresholds, the 

project would be examined to determine whether it would: 

• Result in a cumulative increase in ambient concentrations or emissions of any 

criteria pollutant that is designated as in non-attainment for the project area 

under an applicable federal or state AAQS and emission thresholds,

• Create new sensitive receptors to be affected by substantial increases of 

pollutant concentrations, and

• Create objectionable odors affecting a substantial number of people.

With respect to criteria pollutants, the SCAQMD provides quantitative guidance 

regarding thresholds for both construction and operational activities. These thresholds, 

listed in pounds per day, are presented in table 18 for construction and operations. 
197

Table 18. South Coast Air Quality Management District thresholds (pounds per day)

(Source: SCAQMD, 2009).

Source VOC NOx CO PM10 PM2.5 SOx

Construction 75 100 550 150 55 150

Operation 55 55 550 150 55 150

Notes:CO – carbon monoxide

NOx – nitrous oxides

PM2.5 – particulate matter greater than 2.5 microns in diameter

PM10 – particulate matter greater than 10 microns in diameter

SOx – sulfur oxide

VOC – volatile organic compounds

Noise

Noise, which is defined as unwanted sound, is emitted from many sources 

including airplanes, factories, railroads, power generation plants, and highway vehicles. 

The magnitude of noise is described by its sound pressure. Because the range of sound 

pressure varies greatly, a logarithmic scale is used to relate sound pressures to some 

common reference level, the decibel. Sound pressures described in decibels are called 

sound pressure levels. 

To describe noise environments and to assess effects of noise on sensitive areas, a 

frequency weighting measure called A-weighting, which simulates human perception, is 

commonly used. It has been found that this measure of sound levels best reflects the 

human ear’s reduced sensitivity to low frequencies and correlates well with human 

perceptions of the annoying aspects of noise. The A-weighted decibel scale (dBA) is 

cited in most noise criteria. Decibels are logarithmic units that compare the wide range 

of sound intensities to those that the human ear is most sensitive to. Table 19 identifies 

dBA levels of typical noise environments. 

Several time-averaged scales represent noise environments and consequences of 

human activities. The most commonly used noise descriptors are as follows: 

• Leq—the equivalent A–weighted sound level over a given period; 

• Ldn—average day–night 24–hour average sound level; and 

• Lmax—the maximum sound level measured over the measurement period.
198

Table 19. A-weighted decibel scale sound levels of typical noise environments

(Source: FICON, 1992, as modified by staff).

A-Weighted Overall Level Noise Environment

120 Uncomfortably Loud

(32 times as loud as 70 dBA)

Military jet takeoff at 50 feet

100 Very loud

(8 times as loud as 70 dBA)

Jet flyover at 1,000 feet

80 Loud

(2 times as loud as 70 dBA)

Propeller plane flyover at 

1,000 feet; diesel truck 40 mph at 

50 feet

70 Moderately loud Freeway at 50 feet from pavement 

edge; vacuum cleaner (indoor)

60 Relatively quiet

(1/2 as loud as 70 dBA)

Air condition unit at 10 feet; 

dishwasher at 10 feet (indoor)

50 Quiet

(1/4 as loud as 70 dBA)

Large transformers; small private 

office (indoor)

40 Very quiet

(1/8 as loud as 70 dBA)

Bird calls; lowest limit of urban 

ambient sound

10 Extremely quiet

(1/64 as loud as 70 dBA)

Just audible

0 Threshold of hearing

Note: dBA – A-weighted decibel scale

mph – miles per hour

Regulatory Setting 

Most local jurisdictions have noise exposure standards designed to ensure that 

noise does not excessively affect the quality of life of citizens. Noise is regulated in the 

proposed project area through general plan policies and noise ordinances. The Riverside 

County General Plan (Riverside County, 2003, as cited in Eagle Crest, 2009a) identifies 

policies and standards intended to direct planning associated with the effects of new 

developments, while the county’s noise ordinances establish standards and procedures for 

addressing specific noise sources. 

For the state of California, noise intensity is also discussed in terms of Community 

Noise Equivalent Level, which describes a weighted average noise level that increases 

the relative significance of evening and nighttime noise. The Community Noise 

Equivalent Level descriptor is used to evaluate community noise levels, which includes a 

5 and 10 dBA penalty added to evening (7:00 p.m. to 10:00 p.m.) and nighttime 
199

(10:00 p.m. to 7:00 a.m.) sound levels, respectively, in consideration of people’s 

increased sensitivity to noise during those periods. 

Riverside County General Plan—Riverside County identifies land use 

compatibility noise levels to ensure acceptable noise environments for each land use 

within unincorporated Riverside County. As part of the general plan, the noise element 

also identifies noise compatibility, noise mitigation strategy, stationary noise, and 

temporary construction policies that may be applicable to the proposed project. 

Riverside County Noise Ordinance—Riverside County Ordinance 847, Regulating 

Noise, identifies general noise level standards that are not to be exceeded within the 

county (Riverside County, 2009, as cited in Eagle Crest, 2009a). For example, the 

maximum noise level standards that would be applicable to sensitive receptor locations in 

the project vicinity (i.e., rural residences) are 55 dBA from 7:00 a.m. to 10:00 p.m. and 

45 dBA from 10:00 p.m. to 7:00 a.m. The ordinance also regulates noise from the

operation of power tools or equipment and motor vehicles. 

Ambient Noise Levels 

The general project area is remote, with relatively low noise levels that are 

estimated to average between 35 and 45 dBA. The main noise source in the area is 

vehicle noise on nearby roads, including Interstate 10, Eagle Mountain Road, and Kaiser 

Road. Vehicle noises can range up to 80 dBA, depending on the distance of the receptor 

from the source. 

Ambient Leq noise measurement data were last collected in the project area for the 

review of the proposed Eagle Mountain landfill project (Riverside County, 1996, as cited 

in Eagle Crest, 2009a). Although these data are more than 13 years old, the ambient 

conditions in the study area are largely the same, with the exception that at the time of the 

measurements, a state-run correctional facility used some of the buildings at the Eagle 

Mountain town site. That correctional facility has since relocated from the site.

Ambient Leq noise levels at the Eagle Mountain town site were measured to be 

between 38 and 63 dBA, depending on the distance of the measurement locations from 

Kaiser Road. Now that the correctional facility is not located at the site, existing average 

ambient noise levels likely would be closer to the lower level of the measured range. 

Ambient Leq noise levels in the vicinity of the communities of Lake Tamarisk and Desert 

Center were measured to be moderately higher than those in the immediate project area, 

ranging between 54 and 60 dBA and 66 and 70 dBA, respectively. The ambient Leq 

noise level near Interstate 10 at Kaiser Road was measured to be 73 dBA. 

Sensitive Receptors 

For noise analyses, sensitive receptors are generally defined as land uses that are 

sensitive to noise, such as residential areas, schools, convalescent and acute care 

hospitals, some parks and recreational areas, and churches and other religious facilities. 
200

The closest sensitive receptors to the proposed project site are residences about 4 

miles to the south-southeast and southeast of the site, along Eagle Mountain Road/Phone 

Line Road and Kaiser Road, respectively. However, these sensitive receptors are within 

about 200 feet of the proposed location of the electric transmission line route along Eagle 

Mountain Road and the water supply line route that would be along Kaiser Road. 

In addition, the general project vicinity is located about 2 miles from the closest 

JTNP boundary. 

3.3.8.2 Environmental Effects

Air Quality

For the purposes of air quality analyses, sensitive areas are generally defined as 

land uses where the public has continuous access and with population concentrations that 

would be particularly susceptible to disturbance from dust and air pollutant 

concentrations associated with project construction and/or operation. These sites 

generally include schools, day-care centers, libraries, hospitals, residential-care centers, 

parks, and churches. Some locations are considered more sensitive to air pollutants than 

others, including places with concerns of pre–existing health issues, proximity to 

emissions sources, or duration of exposure to air pollutants. 

In addition to the mostly abandoned Eagle Mountain town site, the two small 

communities of Lake Tamarisk and Desert Center are located about 9 and 10 miles 

southeast of the proposed reservoirs, respectively. The proposed site is also about 2 miles 

from the southeastern boundary of JTNP at its nearest point and about 30 miles from the 

more developed sections of JTNP. National Parks and wilderness areas are designated as 

Class I areas, and afforded protection through the federal PSD program. Visibility and 

air concentrations due to fugitive dust emissions during construction are the main issue 

for air quality. 

Effects of Construction on Air Quality

Air emissions associated with construction activities would be temporary and 

variable, depending on project location, duration, and level of activity. These emissions 

would be predominantly associated with the exhaust generated by operating construction 

equipment, but could also be attributed to fugitive dust (PM2.5 and PM10) produced by

materials staging, demolition, and earthworks activities, as well as concrete processing 

operations. 

In its license application, Eagle Crest proposes measures derived from South Coast 

AQMD Rule 403 to limit dust sources from grading, trenching, wind erosion, and truck 

filling/dumping at the site (see section 2.2.4, Proposed Environmental Measures, for a 

description of proposed Measures AQ-1 through AQ-12). In addition, Eagle Crest 

proposes measures to reduce effects from engine exhaust, including developing and 

implementing a transportation management plan, using 2002 and newer equipment and 
201

emission control devices for older equipment to reduce exhaust from diesel equipment, 

and using electrical drops from an existing electrical service in lieu of installing 

temporary electrical generators. Eagle Crest also proposes to work collaboratively on a 

cost-share basis with the Park Service to complete a 2-year air monitoring study. 

Our Analysis

Two categories of construction equipment would generally be used at the site:

• On-road trucks and vehicles for the transport and delivery of supplies, 

materials, and equipment to and from the site, as well as the employee 

vehicles; and 

• Non-road equipment operated exclusively on site for construction activities

such as paving, utility installation, site clearing and fill operations, earth 

moving, earth loading and unloading, structure installation, and tunnel boring.

Eagle Crest developed activity levels and vehicle assignments for non-road and 

on-road construction vehicles based on requirements and projected construction 

schedules. Non-road exhaust emissions factors were calculated using the current version 

of the CARB OFFROAD2007 model, while on-road emissions factors were computed 

using county-specific data processed by the CARB EMFAC2007 model. Based on the 

construction equipment assignments, usage schedules and engine exhaust factors 

determined from the models described above, Eagle Crest estimated air emissions.

Eagle Crest also estimated fugitive dust PM emissions from soil disturbance, wind

erosion of stockpiles, traffic on unpaved surfaces, blasting, and demolition using the 

SCAQMD’s CEQA Air Quality Handbook, EPA’s Compilation of Air Pollution 

Emissions Factors (i.e., AP-42), and other accepted guidance. Eagle Crest applied a 75 

percent control efficiency pertaining to fugitive dust and relevant emissions based on 

implementation of the proposed mitigation techniques. 

Table 20 provides the annual construction-related emissions associated with the 

proposed project identified by project year and pollutant type. Based on the current 

construction schedule, annual construction-related emissions would be highest in 2013 or 

2014, depending upon the pollutant. Table 20 also shows that the proposed project would 

represent a very small percentage (less than 0.06 percent) of the forecasted annual 

emissions within the Mojave Desert Air Basin. 
202

Table 20. Estimated annual construction emissions (tons) (Source: Eagle Crest, 

2010a).

Year CO VOC NOx PM10 PM2.5 SO2 CO2 N2O CH4

2012 59.0 7.46 54 2.83 2.54 0.08 7,998 0.05 0.68

2013 57.8 7.86 57 2.95 2.64 0.09 9,021 0.05 0.71

2014 60.2 7.67 51 2.79 2.49 0.09 9,297 0.07 0.72

2015 15.8 1.66 10 0.61 0.54 0.025 1,931 0.03 0.15

Maximum 60.2 7.86 57 2.95 2.64 0.09 9,297 0.07 0.72

Percent of 

Mojave 

Desert Air 

Basin 

regional 

emissions

0.05% 0.02% 0.06% 0.004% 0.02% 0.003% NA NA NA

Notes:CH4 – methane

CO – carbon monoxide 

CO2 – carbon dioxide

NA – not available

N2O – nitrous oxide

NOx – nitrous oxides

PM2.5 – particulate matter greater than 2.5 microns in diameter

PM10 – particulate matter greater than 10 microns in diameter

SO2 – sulfur dioxide

VOC – volatile organic compound

Table 21 provides the estimated daily construction-related emissions associated 

with the proposed project before applying any of the mitigation measures proposed by 

Eagle Crest. These estimated emissions are less than the SCAQMD CEQA thresholds for 

all pollutants except NOx, where the estimated emissions exceed the threshold in 3 out of 

4 years. Eagle Crest proposes Measures AQ-1 through AQ-12, development and 

implementation of a transportation management plan, use of 2002 and newer equipment, 

use of emission controls on older equipment, and use of electrical drops in place of 

temporary generators to reduce construction-related emissions. Levels of NOX might still 

exceed CEQA standards, but the monitoring during construction proposed by Eagle Crest 

would determine whether standards are exceeded and whether additional measures are 

needed.
203

Table 21. Daily construction emissions (pounds) (Source: Eagle Crest, 2010a).

Year CO VOC NOx PM10 PM2.5 SO2

2012 454 57 417 21.7 19.6 0.62

2013 444 60 436 22.7 20.3 0.71

2014 464 59 392 21.4 19.1 0.73

2015 121 13 74 4.7 4.2 0.16

Maximum 464 60 436 22.7 20.3 0.73

CEQA threshold 550 75 100 150 55 150

Exceed CEQA No No Yes No No No

Notes: CO – carbon monoxide

NOx – nitrous oxides

PM10 – particulate matter greater than 10 microns in diameter

PM2.5 – particulate matter greater than 2.5 microns in diameter

SO2 – sulfur dioxide

VOC – volatile organic compound

Air emissions related to the off-highway trucking movement of nearly 3 million 

cubic yards of on-site materials were included in the above emission calculations. Eagle 

Crest anticipates that there is an extensive stock of mine tailings available on site that 

Eagle Crest plans to use for facility construction. In the unlikely event that these 

materials are not usable and equivalent materials must be brought from off-site sources, 

the annual construction emissions would increase by about 1, 10, 17, and 1 tons of 

reactive organic gases, CO, NOX, and PM10, respectively, during the worst case year, and 

the daily construction emissions would increase by about 7, 75, 138, and 8 pounds per 

day, respectively. This would increase the daily construction emissions, but not to a level 

that would exceed the CEQA threshold (except for NOX). Thus, the use of off-site fill 

material instead of on-site fill material would not change the overall effects related to the 

proposed project and air quality. 

Eagle Crest also proposes to work collaboratively on a cost-share basis with the 

Park Service to complete a 2-year air monitoring study. As requested by the Park 

Service, the monitoring results would be used to adjust the construction workload if any 

exceedances are observed.

Effects of Operations on Air Quality 

Project operation would have minimal direct effects on air quality. The indirect 

effects could be beneficial if power from the pumped storage project replaces or 

supplements fossil-fueled peaking generation facilities. 
204

Our Analysis

During operations, air pollutant emissions associated with project maintenance 

activities would be minimal, and according to Eagle Crest, would not exceed SCAQMD 

thresholds for operation. Table 22 provides the estimated operation-related annual 

emissions associated with maintenance of the proposed project.

Table 22. Annual operational emissions (tons) (Source: Eagle Crest, 2009a).

CO VOC NOx PM10 PM2.5 SO2 CO2 N2O CH4

0.57 0.01 0.05 0.01 0.01 0.00 102 0.00 0.01

Notes: CO – carbon monoxide

VOC – volatile organic compounds

NOx – nitrous oxides

PM10 – particulate matter greater than 10 microns in diameter

PM2.5 – particulate matter greater than 2.5 microns in diameter

SO2 – sulfur dioxide

CO2 – carbon dioxide

N2O – nitrous oxide

CH4 – methane

The maximum energy requirement to refill the proposed upper reservoir would be 

about 1,600 MW, generally consumed during off-peak periods. Eagle Crest states that 

this energy would normally be provided by wind (typically with excess generation during 

nighttime conditions) and solar facilities during off-peak hours (generally on weekend 

days) and by general base-load electrical generation during the nighttime hours. In this 

manner, the project would act like a storage system for the energy generated during the 

off-peak hours. During peak energy demand periods, about 1,300 MW of generation 

would occur. In this manner, the project would eliminate the need for up to 1,300 MW of

natural gas (fossil-fueled) peaking facilities during peak periods, and decrease emissions 

associated with the fossil-fueled facilities. 

Eagle Crest estimated annual emissions for the modeled offset facility by 

assuming natural gas-fired generation using a simple cycle turbine. A simple cycle 

turbine plant was assumed because it is considered to be state-of-the-art and is the most 

likely source of generation if the proposed project were not built. Annual emissions were 

calculated assuming that up to 4,732,000 megawatt-hours (MWh) would be offset 

annually by the proposed project. 

These emissions were calculated using emissions factors from two sources: 

(1) state average emission factors presented in EPA’s Emissions & Generation Resource 

Integrated Database for emissions of NOx and SO2, and (2) worst-case emission factors 

by source type presented in EPA’s AP-42 for other pollutants. Table 23 provides the 
205

estimated amount of offset emissions, including about 1,443,260 tons of CO2 from 

the project. 

Table 23. Annual offset electrical generation air emissions (tons) (Source: Eagle 

Crest, 2009a).

CO VOC NOx PM10 PM2.5 SO2 CO2 N2O CH4

345 48.2 1,796 276 276 1,323 1,443,260 8.75 15.9

Notes: CH4 – methane

CO – carbon monoxide 

CO2 – carbon dioxide

N2O – nitrous oxide

NOx – nitrous oxides

PM10 – particulate matter greater than 10 microns in diameter

PM2.5 – particulate matter greater than 2.5 microns in diameter

SO2 – sulfur dioxide

VOC – volatile organic compound

Noise

Staff’s analysis of potential noise effects that could result from the short-term 

construction and long-term operation of the proposed project is discussed below. The 

noise analysis considers Riverside County noise regulations and ordinances and Federal 

Transit Administration guidelines.

Effects of Project Construction on Noise Levels

Construction of the project would have a temporary effect on ambient noise levels. 

Although a few intermittent activities such as rock drilling or pavement breaking would 

be louder, engine noise would be the dominant source of noise from most construction 

equipment. 

Eagle Crest proposes to comply with the County of Riverside’s General Plan and its 

applicable noise ordinance codes during construction (Measure NOI-1). Eagle Crest also 

plans to equip all construction equipment with properly operating and maintained noise 

mufflers and intake silencers, consistent with manufacturers’ standards (Measure NOI-2). 

Our Analysis

Aerial photographs of the region show that there are no sensitive land uses, such 

as residences, schools/churches, or parks located in the general project vicinity, which 

includes the proposed Eagle Mountain upper and lower reservoir sites, the proposed 

pressure and tailrace tunnel locations, and the proposed powerhouse, switchyard, and 

reverse osmosis treatment sites. These project sites are about 4 miles from the nearest 

sensitive receptors (i.e., rural residences along Kaiser Road and Eagle Mountain Road) 
206

and about 2 miles from the closest boundary of JTNP. As noted earlier in this section, 

sensitive receptors would be within about 200 feet of the proposed locations of the 

electric transmission line along Eagle Mountain Road and the water supply line along 

Kaiser Road. 

Project construction in the vicinity of the upper and lower reservoir sites would 

increase noise levels that could be audible in the JTNP. During construction, including 

construction of the electric transmission line and water supply line, the highest noise 

generating activities are expected to be earth moving, i.e., excavation, grading, and 

filling. For the noise analysis, the majority of construction equipment was assumed to be 

mobile off-road equipment, including dozers, backhoes, graders, and dump trucks, which 

generate maximum noise levels of up to 88 dBA at 50 feet (FTA, 2006, as cited in Eagle 

Crest, 2009a). The loudest piece of construction equipment is anticipated to be a 

stationary rock drill, which would generate maximum noise levels of 98 dBA at 50 feet. 

Based on the assumed noise levels at 50 feet from the construction equipment, a 

standard acoustical equation was used to estimate the attenuation of noise based on the 

distance from the construction site to the nearest JTNP boundary and the nearest sensitive 

receptors. The equation uses a noise attenuation rate of about 7.5 dBA per doubling of 

distance to account for the absorption of noise waves due to ground surfaces such as soft 

dirt and bushes (Caltrans, 1998, as cited in Eagle Crest, 2009a). Table 24 shows 

estimated construction noise levels that would affect people at the nearest sensitive land 

uses to the proposed reservoir sites and the proposed pipeline/transmission line routes. 

These estimated noise levels represent the worst-case scenario because the estimates do 

not account for noise attenuation due to the presence of natural sound barriers. Noise 

levels associated with construction activities at the reservoir sites would be expected to 

be at least 5 to 10 dBA less at the nearest sensitive receptors because most of the work 

would be completed at the bottom of the proposed reservoir sites where the line of sight 

between the construction activities and the receptors would be blocked. 

Table 24. Minimum distances and Lmax noise levels (in dBA) at sensitive land uses

(Source: Eagle Crest, 2009a). 

Project Component

Closest Distance to the 

Sensitive Land Use

Lmax at 50 feet 

(rock drill/dump 

truck)

Lmax at Closest 

Residence 

(rock drill/dump 

truck

Reservoir sites 4 miles (residences) 98/88 32/22

Reservoir sites 2 miles (JTNP) 98/88 43/33

Pipeline/transmission 

line

200 feet (residences) 98/88 83/73

Notes:JNTP — Joshua Tree National Park and wilderness area

Lmax — the maximum sound level measured over the measurement period
207

As indicated in table 24, maximum estimated construction noise from the vicinity 

of the reservoir sites at the nearest residences would be 32 dBA during rock drilling and 

22 dBA for dump trucks and other construction activities. These noise levels would 

likely not be audible at the nearby residences. The same construction activities would 

generate noise levels at the boundary of JTNP that would be up to 43 dBA during rock 

drilling and 33 dBA during other construction activities. However, rock drilling, if 

necessary, would generate loud noises only during early stages of the construction and 

the noise would be substantially attenuated when excavation for the project tunnels and 

other facilities proceeds deep into the ground. Thus, rock drilling activities could be 

audible at the boundary of JTNP, but the effect would be temporary and not substantial. 

Construction of the proposed tunnels and powerhouse facilities would occur 

underground. Therefore, noise effects associated with construction of these facilities 

would be limited. Maximum construction noise at the nearest sensitive receptors to the 

transmission line and water pipeline would be adverse; however, it is anticipated that 

construction of the facilities would proceed in a linear fashion, and construction noise 

effects at any one location along the pipeline or transmission line route would last for no 

more than several weeks. 

Construction of the project would also create increased traffic on local roads. 

Increased traffic would be generated from the movement of workers, materials, and 

equipment to the site. The primary routes used to access the project site would be 

Interstate 10 and Kaiser Road, and workers coming to the site would use these routes. 

Given the existing low volumes of traffic levels along Kaiser Road, construction traffic 

would result in an increase in noise levels at residences along the road, an adverse 

temporary effect. Based on aerial photographs, about 20 residences would be affected by 

the increased traffic noise along Kaiser Road. 

Compliance with the applicable County of Riverside noise ordinance codes during 

construction would minimize the effects of noise levels during construction. Eagle 

Crest’s other proposed measures would lower the noise level during construction by 

equipping all construction equipment with properly operating and maintained noise 

mufflers and intake silencers, consistent with manufacturers’ standards. 

Effects of Project Operations on Noise Levels

Normal operation of the proposed project would result in a minimal increase in 

road traffic but would not substantially increase ambient noise levels along Kaiser Road. 

The proposed underground powerhouse would not affect above-ground noise levels. 

Noise could be generated from the transmission lines in some situations. Eagle Crest has 

not proposed any measures to limit noise levels during project operation. 

Our Analysis 

During project operation, the increase in traffic along the access roads north of 

Interstate 10 would be minimal due to the low number of employees expected to be 
208

employed at the site. One exception would be related to salt removal operations from the 

evaporation and solidification ponds. Removal of the expected salt volume from on-site 

locations to an unspecified and likely off-site location would require about 280 truck trips 

per year if the removal were done on an annual basis. Because Eagle Crest proposes to 

implement the salt removal process at 10-year intervals, resulting in almost 3,000 truck 

trips in a short period, the truck noise related to this operation would be noticeable. 

Under wet weather conditions, high-tension transmission lines may generate 

audible noises known as corona discharge. The degree or intensity of the corona 

discharge and the resulting audible noise (normally a low-level hissing or crackling 

noise) are affected by humidity, air density, wind, and water in the form of rain, drizzle, 

and fog. Humidity levels increase the conductivity of the air and therefore increase the 

intensity of the discharge. Also, irregularities on the conductor surface, such as nicks or 

sharp points and airborne contaminants, can increase the corona activity. The higher 

voltages at which modern transmission lines operate have increased the noise problem, 

and the power industry designs, constructs, and maintains transmission lines so that 

during dry conditions they would operate below the corona-inception voltage. This 

means that the proposed line would generate a minimal amount of corona-related noise 

during the vast majority of the time in the very dry desert location of the proposed 

transmission line. However, during rare foul weather conditions, corona discharges could 

be produced by water droplets and fog. 

Eagle Crest estimates that the corona noise at the edge of the proposed 500-kV 

transmission line ROW (i.e., 100 feet from the centerline of the transmission line) would 

range from 45 to 50 dBA. At 200 feet from the transmission line, this would equate to a 

noise level range of about 37 to 43 dBA. This low-level noise would be noticeable only 

close to the line during the very rare wet weather conditions. 

3.3.8.3 Cumulative Effects

The air quality cumulative effects analysis considers whether the project, in 

combination with other reasonably foreseeable local and regional developments, would 

create a significant cumulative effect. The other potential developments include several 

solar projects and the proposed Eagle Mountain landfill. 

In general, the cumulative air quality analysis can consider applicable planning 

documents that guide development at, or in the vicinity of, the project and within the 

region; under CEQA this is considered a plan-based approach. The cumulative 

contribution of the proposed project to criteria pollutants is considered in the ongoing 

planning by the SCAQMD to meet the state and federal regulatory AAQSs into the 

future. This planning is based on inventories of emissions anticipated from development 

in accordance with each of the county general plans within the air basin. 

Given the progress and locations of other projects, Eagle Crest concluded that

construction of the solar projects would be removed from cumulative actions due to their 

locations and distances from the proposed project; while construction of the Eagle 
209

Mountain landfill project would also be removed due to its time schedule (construction 

would probably not occur simultaneously with construction of the proposed project). 

Because construction of the proposed project would result in a temporarily 

significant construction-related effect for NOX in construction years 2013 and 2014, the 

proposed project would also be considered to have a significant cumulative air quality 

impact for NOX, as a precursor to ozone formation, in those years. However, because of 

the temporary nature of construction activities and implementation of Eagle Crest’s 

proposed measures, the severity and frequency of these effects would be limited. 

Furthermore, Eagle Crest’s proposal to work collaboratively on a cost-share basis with 

the Park Service to complete a 2-year air monitoring study would provide data to adjust 

the construction workload if any exceedances are observed.

Based on the location and timing of the project, the CO, PM10, and PM2.5 effects

are not likely to be cumulatively significant.

3.4 NO-ACTION ALTERNATIVE

Under the no-action alternative, the Eagle Mountain Project would not be 

constructed. There would be no changes to the physical, biological, or cultural resources 

of the area and electrical generation from the project would not occur. The power that 

would have been developed from a renewable resource would have to be replaced from 

other sources that would probably include nonrenewable fuels. 
210

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211

4.0 DEVELOPMENTAL ANALYSIS

In this section, staff looks at the Eagle Mountain Project’s use of environmental 

resources for hydropower purposes to see what effect various environmental measures 

would have on the project’s costs and power generation. Under the Commission’s 

approach to evaluating the economics of hydropower projects, as articulated in Mead 

Corp.,

38

For each of the licensing alternatives, staff’s analysis includes an estimate of: (1) 

the cost of individual measures considered in the EIS for the protection, mitigation and 

enhancement of environmental resources affected by the project; (2) the cost of 

alternative power; (3) the total project cost (i.e., for construction, operation, maintenance, 

and environmental measures); and (4) the difference between the cost of alternative 

power and total project cost. If the difference between the cost of alternative power and 

total project cost is positive, the project produces power for less than the cost of 

alternative power. If the difference between the cost of alternative power and total 

project cost is negative, the project produces power for more than the cost of alternative 

power. This estimate helps to support an informed decision concerning what is in the 

public interest with respect to a proposed license. However, project economics is only 

one of many public interest factors the Commission considers in determining whether, 

and under what conditions, to issue a license.

the Commission compares the current project cost to an estimate of the cost of 

obtaining the same amount of energy and capacity using the likely alternative source of 

power for the region (cost of alternative power). In keeping with Commission policy as 

described in Mead Corp., staff’s economic analysis is based on current electric power 

cost conditions and does not consider future escalation of fuel prices in valuing the 

hydropower project’s power benefits.

4.1 POWER AND DEVELOPMENTAL BENEFITS OF THE PROJECT

Table 25 summarizes the assumptions and economic information staff uses in its 

analysis. This information was provided by Eagle Crest in its license application. Staff

finds that the values provided by Eagle Crest are reasonable for the purposes of its

analysis. Cost items common to all alternatives include: taxes and insurance costs; net 

investment (the total investment in power plant facilities remaining to be depreciated); 

estimated future capital investment required to maintain and extend the life of plant 

equipment and facilities; relicensing costs; normal operation and maintenance cost; and 

Commission fees.

 

38 See Mead Corporation, Publishing Paper Division, 72 FERC ¶ 61,027 (July 13, 

1995). In most cases, electricity from hydropower would displace some form of fossilfueled generation, in which fuel cost is the largest component of the cost of electricity 

production.
212

Pumped storage facilities are net energy consumers. The amount of energy 

produced as water passes from the upper reservoir to the lower reservoir through the 

turbines is less than the amount of energy required to operate the plant and pump water 

back up to the upper reservoir. However, the benefits of pumped storage facilities are 

realized when the value of generation is greater than the cost of pumping. Typically, 

there are sources of power such as nuclear, solar and wind projects that can provide 

power at low rates during night-time or low-demand hours, compared to rates available 

during day-time, high-demand hours. Therefore, the pumped storage facility can provide 

power during the day when energy demands are high and can use power from other 

facilities during the night when energy demand is low. If power used to pump water to 

the upper reservoir can be purchased from renewable sources, including some of the 

substantial renewable projects that are proposed near the project, the need to use fossilfueled facilities to provide that power would be avoided. There are substantial wind 

generation facilities near the proposed project site that could provide power to pump 

water to the upper reservoir during night-time hours. Solar facilities, which are planned 

near the site, could help provide power to pump water to the upper reservoir during lower 

power demand periods during day-time hours on weekends. The power produced during 

the day may also displace non-renewable, fossil-fired generation. Displacing the 

operation of fossil-fired generation may avoid some power plant emissions and create an 

environmental benefit. 

Pumped storage facilities can be switched from pumping to generating and back 

again very quickly, as needed, for system support and demand response. These facilities 

also provide black start capabilities for larger baseload generation units, as well as 

spinning and non-spinning reserve, which are all important capabilities for the electrical 

grid and market. These ancillary services to the electric grid can provide additional 

revenue. The proposed energy storage volume would permit operation of the project at 

full capacity for up to 9 to 10 hours each weekday, with up to 12 to 14 hours of pumping 

each weekday night and additional pumping during the weekend to fully recharge the 

upper reservoir. 
213

Table 25. Parameters for the economic analysis of the Eagle Mountain Project. 

Parameter Value Source

Period of analysis (years) 30 Staff

Taxes and insurance (%) 2.1 Eagle Crest, 2009a, Exhibit D

Federal income tax rate (%) 35 Staff

Net investment, $ 0 Staff

Operation and maintenance, $/year 

(includes property taxes, makeup 

water pumping costs, land leases, 

water treatment costs, property 

insurance, FERC fees, and 

administrative fees)

$29,473,000 in 

years 1-3 and 

$28,310,000 

each year 

thereafter

Eagle Crest, 2009a, Exhibit D

Energy value ($/MWh) $40 Estimated by staff based on 

Eagle Crest, 2009b

Capacity value ($/kW-year) $154 Staff based on Energy 

Information Administration’s 

Annual Energy Outlook 

Ancillary services value ($/kW-year) $95 Estimated by staff based on 

Eagle Crest, 2009b

Pumping ratio (MWh pumping/MWh 

generating)

1.25 Eagle Crest, 2009a, Exhibit D

Pumping energy value ($/MWh) $20 Estimated by staff based on 

Eagle Crest, 2009b

Interest rate (%) 6 Eagle Crest, 2009a, Exhibit D

Discount rate (%) 6 Eagle Crest, 2009a, Exhibit D

Notes: kW kilowatt

MW – megawatt

MWh – megawatt-hour
214

4.2 COMPARISON OF ALTERNATIVES

Table 26 compares the installed capacity, annual generation, cost of alternative 

power, estimated total project cost, and difference between the cost of alternative power 

and total project cost for each of the alternatives considered in this draft EIS: no action, 

Eagle Crest’s proposal, the staff alternative, and staff alternative with mandatory 

conditions.

Table 26. Summary of the annual cost of alternative power and annual project cost for 

the alternatives for the Eagle Mountain Pumped Storage Project (Source: 

staff).

Eagle Crest’s Proposal Staff Alternative

Installed capacity (MW) 1,300 1,300

Annual generation (MWh) 4,308,000 4,308,000

Dependable capacity (MW) 1,276 1,276

Annual cost of alternative power $493,872,000 $493,872,000

($/MWh) 114.64 114.64

Annual project cost $359,817,540 $360,708,580

($/MWh) 83.52 83.73

Difference between the cost of 

alternative power and project cost

$134,054,460 $133,163,420

($/MWh) 31.12 30.91

Notes: MW – megawatt

MWh – megawatt-hour

4.2.1 No-action Alternative

Under the no-action alternative, the project would not be constructed as proposed 

and would not produce any electricity. 

4.2.2 Eagle Crest’s Proposal

Eagle Crest proposes to develop the Eagle Mountain Project using two existing 

inactive mine pits as upper and lower reservoirs. The project would require substantial 

civil modifications and additions to the site for use as a generating facility. Eagle Crest

proposes various environmental measures to protect existing environmental resources in 

the vicinity of project features.

Under Eagle Crest’s proposed alternative, the project would generate an average 

of 4,308,000 MWh annually. The annual cost of alternative power under Eagle Crest’s 

proposed alternative would be $493,872,000, or $114.64/MWh. The average annual 
215

project cost would be $359,817,540, or $83.52/MWh. Overall, the project would produce 

power at a cost that is $134,054,460, or $31.12/MWh, less than the cost of alternative 

power.

4.2.3 Staff Alternative

The staff alternative includes all of Eagle Crest’s proposed environmental 

measures. The staff alternative would have the same capacity and energy attributes as 

Eagle Crest’s proposed project. Table 27 shows the staff-recommended additions, 

deletions, and modifications to Eagle Crest’s proposed environmental protection and 

enhancement measures and the estimated cost of each. Under the staff alternative, the 

average annual cost of alternative power would be $493,872,000, or $114.64/MWh. The 

annual project cost would be $360,708,580, or $83.73/MWh. Overall, the project would 

produce power at a cost that is $133,163,420, or $30.91/MWh, less than the cost of 

alternative power.

4.3 COST OF ENVIRONMENTAL MEASURES

Table 27 gives the cost of each of the environmental enhancement measures 

considered in staff’s analysis. Staff converts all costs to equal annual (levelized) values 

over a 30-year period of analysis to give a uniform basis for comparing the benefits of a 

measure to its cost.
216

Table 27. Cost of environmental mitigation and enhancement measures considered in assessing the environmental 

effects of the proposed operation of the Eagle Mountain Pumped Storage Project (Source: staff).

Enhancement/Measure Entity

Capital Cost 

(2010$)

Annual 

Cost 

(2010$)

Levelized 

Annual Cost 

(2010$)

Geologic and Soils Resources

1. Implement the Erosion and Sediment Control 

Plan filed July 7, 2010, that describes the erosion 

and sediment control practices to minimize soil 

erosion in construction areas and prevent sediment 

transport into stormwater discharges away from 

the construction site (Measure GEO-1).

Eagle Crest, staff $1,650,000 $0 $108,820

Water Resources

1. Develop a groundwater level monitoring

network (including existing and new monitoring 

wells) to confirm that project pumping would be 

maintained at levels in the range of the historical

pumping (Measure WS-1).

Eagle Crest, staff $698,000 $0 $46,030

2. During the initial fill pumping period, monitor 

wells on neighboring properties whose water 

production may be impaired by project 

groundwater pumping; if project pumping would 

adversely affect these wells, replace or lower the 

pumps, deepen the existing well, construct a new 

well, and/or compensate the owner for increased 

pumping costs (Measure WS-3)

Eagle Crest $75,000 $1,000 $5,600
217

Enhancement/Measure Entity

Capital Cost 

(2010$)

Annual 

Cost 

(2010$)

Levelized 

Annual Cost 

(2010$)

3. Monitor wells on neighboring properties whose 

water production may be impaired by project 

groundwater pumping during the initial fill 

pumping period. If it is determined that project 

pumping is lowering water levels in those wells by 

5 feet or more, replace or lower the pumps, deepen 

the existing wells, construct a new well, and/or 

compensate the well owner for increased pumping 

costs to maintain water supply to those 

neighboring properties (Measure MM GW-2)

State Water Board $75,000a $100,000a $69,950

4. Monitor groundwater on a quarterly basis for 

the first 4 years of project pumping; possibly 

extend monitoring from quarterly to bi-annually or 

annually, depending on findings and prepare 

annual reports for submittal to the Commission 

and the State Water Board, confirming actual 

drawdown conditions (Measure WS-4).

Eagle Crest, staff $0 $19,100 $12,420

5. Perform aquifer tests during final engineering 

design to confirm the seepage recovery well rates 

and aquifer characteristics (Measure SR-1).

Eagle Crest, staff $2,428,000 $155,000 $260,880
218

Enhancement/Measure Entity

Capital Cost 

(2010$)

Annual 

Cost 

(2010$)

Levelized 

Annual Cost 

(2010$)

6. Alternatively, manage seepage from the 

reservoirs, which if left unimpeded could raise the 

groundwater levels by up to 3 feet 

(implementation of this alternative would require 

confirmation of groundwater rises and water 

quality of the resulting seepage) (Measure SR1A).

(only presented by 

Eagle Crest as an 

alternative measure 

to Measure SR-1 if 

SR-1 is 

unacceptable)

$0 $0 $0

7. Control seepage from the upper reservoir by 

using a separate set of seepage recovery wells, 

employ a testing program for these seepage 

recovery wells and make final drawdown 

observations in nearby observation wells to 

support final engineering design (Measure SR-2).

Eagle Crest, staff $3,279,000 $297,000 $409,300

8. Develop a groundwater level monitoring 

network (including existing and new monitoring 

wells) to confirm that seepage recovery well 

pumping would be effective at managing 

groundwater levels beneath the CRA and in the 

Eagle Creek Canyon portions of the proposed 

landfill, and record groundwater levels, water 

quality, and production at the project seepage 

recovery wells (Measure SR-3). 

Eagle Crest, staff $0b $0 $0
219

Enhancement/Measure Entity

Capital Cost 

(2010$)

Annual 

Cost 

(2010$)

Levelized 

Annual Cost 

(2010$)

9. Maintain seepage from the upper reservoir 

below the bottom of elevation of the landfill liner 

and maintain seepage from the lower reservoir to 

prevent a significant rise in water levels beneath 

the CRA (Measure SR-4)

Eagle Crest, staff $0c $0c $0

10. Monitor groundwater on a quarterly basis for 

the first 4 years of project pumping; possibly 

extend monitoring from quarterly to bi-annually or 

annually, depending on findings (Measure SR-5).

Eagle Crest, staff $0 $28,600 $18,590

11. Install a reverse osmosis desalination facility 

and brine disposal lagoon to remove salts and 

metals from reservoir water and maintain total 

dissolved solids concentrations at the level of the 

source water, as part of project design (Measure 

GQ-1).

Eagle Crest, staff $45,400,000 $715,000 $3,458,930

12. Implement a monitoring program to measure 

groundwater quality to assess and maintain 

groundwater effects less than significant by 

sampling reservoirs, seepage recovery wells, and 

wells upgradient and downgradient of the 

reservoirs and brine disposal lagoon on a quarterly 

basis for the first 4 years (Measure GQ-2).

Eagle Crest, staff $753,000 $50,800 $82,680

13. Replace wells located within the reservoir 

with wells located outside of reservoirs (Measure 

LF-1).

Eagle Crest, Staff $981,000 $0 $64,700
220

Enhancement/Measure Entity

Capital Cost 

(2010$)

Annual 

Cost 

(2010$)

Levelized 

Annual Cost 

(2010$)

14. Implement measures to release excess water 

from the reservoirs during large rainfall events, 

such as the 100-year event and up to and including 

the probable maximum flood.

Eagle Crest, Staff $10,000,000d $0 $659,510

15. Construct two extensometers—one in the 

upper Chuckwalla Valley near OW-3 and the 

other in the Orocopia Valley near OPW15—to 

measure potential inelastic subsidence that could 

affect the operation of the CRA (Measure WS-2).

Eagle Crest, staff $368,000 $0 $24,270

16. Develop and implement a reservoir-level 

monitoring plan to ensure that the water levels are 

managed properly within operational restraints 

and to help determine possible water level effects 

on terrestrial resources.

Staff $20,000 $5,000 $4,570

17. Develop and implement a brine pond-level 

monitoring plan to ensure that the brine levels of 

the ponds are managed properly and to help 

determine if a leak has developed in the linings of 

the ponds.

Staff $10,000 $12,000 $8,460

18. Develop and implement a more 

comprehensive monitoring well placement and 

monitoring program around the proposed brine 

and solidification ponds to allow for the earlier 

detection of a possible leak in the lining of the 

ponds.

Staff $75,000 $6,000 $8.850
221

Enhancement/Measure Entity

Capital Cost 

(2010$)

Annual 

Cost 

(2010$)

Levelized 

Annual Cost 

(2010$)

19. Develop a groundwater hydrologic budget 

report which combines the data from groundwater 

monitoring, pumpage, seepage recovery, 

precipitation and evaporation and groundwater 

flow direction.

Staff $2,000 $2,000 $1,430

20. Perform channel modifications and other 

measures to contain flows associated with the 

probable maximum flood to the Eagle Creek 

channel and to direct these flows into the proposed 

lower reservoir.

Staff $4,000,000 $0 $263,800

Fisheries Resources

1. Obtain a Streambed Alteration Agreement, 

which would identify the condition and location of 

all state jurisdictional waters, effects, and 

mitigation measures, including the acreage 

assessment of washes that may be affected, 

construction requirements associated with 

working on or near the washes, and compensation 

for lost or damaged acreage (Measure BIO-23).

Eagle Crest, staff $60,000 $0 $3,960

Terrestrial Resources

1. Concurrent with final design engineering, 

develop a comprehensive site-specific mitigation 

and monitoring program in consultation with the 

Biological Technical Advisory Team (Measure 

BIO-1).

Eagle Crest, staff $15,000 $25,000 $17,240
222

Enhancement/Measure Entity

Capital Cost 

(2010$)

Annual 

Cost 

(2010$)

Levelized 

Annual Cost 

(2010$)

2. Designate a project biologist who would be 

responsible for implementing and overseeing the 

biological compliance program (Measure BIO-2).

Eagle Crest, staff $0 $25,000 $16,250

3. Implement the WEAP to ensure that project 

construction and operation would be conducted 

within a framework of safeguarding 

environmentally sensitive resources and restrict 

construction and maintenance activities to 

minimize project effects (Measures BIO-3 and 

BIO-19).

Eagle Crest, staff $100,000 $0 $6,600

4. Regularly submit reports to the relevant 

resource agencies, documenting project activities, 

mitigation implemented, and mitigation 

effectiveness, and providing recommendations, as 

needed (Measure BIO-4).

Eagle Crest, staff $80,000 $8,000 $10,480

5. During construction in native habitats, restrict 

disturbance to the smallest area necessary to 

complete the construction; design new spur roads 

and improvements to existing roads in a way that 

would preserve existing desert wash topography 

and flow patterns (Measure BIO-5). 

Eagle Crest, staff $0c $0c $0
223

Enhancement/Measure Entity

Capital Cost 

(2010$)

Annual 

Cost 

(2010$)

Levelized 

Annual Cost 

(2010$)

6. Conduct pre-construction surveys to identify 

special-status plant populations and species 

protected by the CDNPA, and establish avoidance 

areas in construction zones for special plant 

resources. Where avoidance is not feasible, 

salvage and transplant any species that can be 

reasonably transplanted in an approved area 

(Measure BIO-6).

Eagle Crest, staff $15,000 $0 $990

7. In compliance with CDNPA, consult with the 

County Agricultural Commissioner for direction 

regarding disposal of protected plants (Measure 

BIO-7).

Eagle Crest, staff $5,000 $0 $330

8. Implement the Revegetation Plan, dated 

October 27, 2009, for areas that are temporarily 

disturbed during construction (Measure BIO-8).

Eagle Crest, staff $45,000 $5,000 $6,220

9. Implement the Invasive Species Monitoring 

and Control Plan, dated October 27, 2009, to 

minimize the spread of invasive non-native 

vegetation (Measure BIO-9).

Eagle Crest, staff $15,000 $5,000 $4,240
224

Enhancement/Measure Entity

Capital Cost 

(2010$)

Annual 

Cost 

(2010$)

Levelized 

Annual Cost 

(2010$)

10. Implement requirements of the Northern and 

Eastern Colorado Desert Coordinated 

Management (NECO) Plan to avoid disturbance of 

impoundments and restrict surface flow to 

impoundments. If avoidance is not possible, 

construct a new impoundment as close as feasible 

to replicate and replace each lost impoundment 

(Measure BIO-10).

Eagle Crest, staff $3,000 $0 $200

11. For construction activities scheduled to occur 

between about February 15 and July 30 in 

vegetated habitat, survey all potential nesting sites 

for active bird nests (Measure BIO-11).

Eagle Crest, staff $5,000 $0 $330

12. Develop and implement a plan to manage

evaporation ponds to minimize their attractiveness 

and access to migratory birds and establish a 

monitoring program to identify bird usage of the 

evaporation ponds, effectiveness of bird 

deterrents, and water quality. Based on 

monitoring results, implement adaptive 

management (Measure BIO-12).

Eagle Crest, staff $200,000 $40,000 $39,190
225

Enhancement/Measure Entity

Capital Cost 

(2010$)

Annual 

Cost 

(2010$)

Levelized 

Annual Cost 

(2010$)

13. If requested, complete a Phase III survey, 

including a nesting season survey, followed by a 

winter survey if no burrows or owls are observed 

during the nesting season survey, and a preconstruction survey, to further assess burrowing 

owl use of the project area and potential effects. 

(With California DFG approval, the preconstruction survey may obviate the need for the 

Phase III survey) (Measure BIO-13).

Eagle Crest, staff $7,000 $0 $460

14. Limit the construction to September 1 through 

February 1, if burrowing owls are present, to 

avoid disruption of breeding activities; avoid 

disruption of burrowing owl nesting activities; use 

a minimum of a 250-foot buffer to avoid active 

nests until fledgling has occurred (Measure BIO14).

Eagle Crest, staff $10,000 $0 $660

15. Determine through pre-construction surveys if 

0.25-mile construction buffers would be required 

during prairie falcon or golden eagle nesting 

seasons (Measure BIO-15).

Eagle Crest, staff $2,000 $0 $130
226

Enhancement/Measure Entity

Capital Cost 

(2010$)

Annual 

Cost 

(2010$)

Levelized 

Annual Cost 

(2010$)

16. Conduct pre-construction surveys for all 

burrows that might host badger or kit fox, avoid 

active burrows, where possible, and mark the 

perimeters of all avoidance areas with 3-foot-high, 

and no more than 10-foot-apart, wooden stakes. 

Where avoidance is infeasible, encourage 

occupants to leave their burrows (Measure BIO16). 

Eagle Crest, staff $15,000 $0 $990

17. Conduct pre-construction surveys to 

determine the existence, location, and condition of 

bat roosts and identify foraging habitat. Based on 

results of surveys, develop a mitigation plan to 

avoid roosting and foraging effects on resident 

bats, minimize disturbance, or as an inescapable 

measure, evict bats (Measure BIO-17). 

Eagle Crest, staff $15,000 $5,000 $4,240

18. Construct security fencing around portions of 

the central project area to exclude larger terrestrial 

wildlife, including bighorn sheep, deer, coyotes, 

foxes and badger, from entering project areas that 

pose hazards (Measure BIO-18).

Eagle Crest, staff $0c $0c $0

19. In areas without wildlife exclusion fencing or 

those areas that have not been cleared of tortoises, 

conduct construction activities only during 

daylight hours (Measure BIO-20).

Eagle Crest, staff $0c $0c $0
227

Enhancement/Measure Entity

Capital Cost 

(2010$)

Annual 

Cost 

(2010$)

Levelized 

Annual Cost 

(2010$)

20. Close, temporarily fence, or cover pipeline 

trenches every day. Conduct inspections (by an 

approved biological monitor) of any open trenches 

at first light, midday, and at the end of each day to 

ensure animal safety (Measure BIO-21).

Eagle Crest, staff $0c $0c $0

21. Design, install, and maintain facility lighting 

to prevent casting of light into adjacent native 

habitat (Measure BIO-22).

Eagle Crest, staff $0c $0c $0

22. Modify the proposed Invasive Species 

Monitoring and Control Plan to include criteria for 

success and an adaptive management plan to be 

implemented if initial efforts do not prove 

successful. Include the reservoirs and water 

seepage areas with other areas to be monitored for 

invasive plants. Monitor water seepage and 

reservoirs on an annual basis following vegetation 

establishment.

Staff $2,000 $1,000 $780
228

Enhancement/Measure Entity

Capital Cost 

(2010$)

Annual 

Cost 

(2010$)

Levelized 

Annual Cost 

(2010$)

23. Develop and implement a transmission line 

design plan that includes an avian protection plan, 

prepared in consultation with FWS, and design 

measures for reducing potential for electrocution 

and collision injuries; provides methods for 

surveying and reporting project-related raptor 

mortality; incorporates a worker education plan 

pertaining to avian–power line interactions; and 

includes procedures for managing nesting on 

power line structures.

Staff $20,000 $5,000 $4,570

Threatened and Endangered Species

1. Remove tortoises from harm’s way during the 

construction period (Measure DT-1).

Eagle Crest, staff $100,000 $0 $6,600

2. Ensure that no construction or maintenance 

that requires surface disturbance in unfenced areas 

on the linear facilities would occur without 

biological monitors (Measure DT-2).

Eagle Crest, staff $200,000 $0 $13,190

3. Enclose the substation and other hazardous 

areas with permanent tortoise exclusion fence to 

keep adjacent tortoises from entering the site 

(Measure DT-3).

Eagle Crest, staff $200,000 $5,000 $16,440

4. Implement the Desert Tortoise Removal and 

Translocation Plan dated October 27, 2009

(Measures DT-4 and DT-7).

Eagle Crest, staff $40,000 $0 $2,640
229

Enhancement/Measure Entity

Capital Cost 

(2010$)

Annual 

Cost 

(2010$)

Levelized 

Annual Cost 

(2010$)

5. Implement the Raven Monitoring and Control 

Plan dated October 27, 2009 (Measure DT-5).

Eagle Crest, staff $0 $8,000 $5,200

6. Purchase about 160 acres of land to 

compensate for the Category I and Category III 

Desert Tortoise habitat that would be disturbed 

(Measure DT-6).

Eagle Crest, staff $780,000 $0 $51,440

7. Conduct pre-construction surveys for the 

spadefoot toad in all areas of proposed 

construction activity not previously surveyed in 

2009, and implement the same protection 

measures proposed for the central area.

Staff $10,000 $0 $660

8. Amend the current Raven Monitoring and 

Control Plan to include baseline and postconstruction survey methods for coyote, wild 

dogs, and gulls, and develop mitigation measures 

to be implemented if increases in population 

levels are detected, and develop tortoise predator 

control plan, as the Park Service recommends. 

Include a survey schedule that includes initiation 

of post-construction surveys during the second 

year after project completion, followed by surveys 

once every 5 years.

Staff $25,000 $1,000 $2,300
230

Enhancement/Measure Entity

Capital Cost 

(2010$)

Annual 

Cost 

(2010$)

Levelized 

Annual Cost 

(2010$)

Recreation Resources

1. Coordinate construction activities with BLM 

and provide posted notices of construction activity 

and any temporary road/access closure (Measure 

REC-1).

Eagle Crest, staff $0c $0c $0

Land Use

1. Provide construction access to and from the 

substation site from the Eagle Mountain Road exit 

and follow the Frontage Road east to the site 

(Measure LU-1).

Eagle Crest, staff $0c $0c $0

2. Two weeks prior to beginning construction, 

locally post notices stating hours of operation for 

construction near the Desert Center community 

and along State Route 177 (Measure LU-2).

Eagle Crest, staff $20,800 $0 $1,370

Aesthetic Resources

1. Incorporate directional lighting, light hoods, 

low pressure sodium bulbs or LED lighting, and 

operational devices in final design to allow 

surface night-lighting in the central site to be 

turned on as needed for safety (Measure AES-1).

Eagle Crest, staff $180,000 $6,000 $15,770
231

Enhancement/Measure Entity

Capital Cost 

(2010$)

Annual 

Cost 

(2010$)

Levelized 

Annual Cost 

(2010$)

2. Combine and organize staging areas and areas 

needed for equipment operation and material 

storage and assembly within construction lands to 

the extent feasible to minimize total footprint 

needed (Measure AES-2).

Eagle Crest, staff $0c $0c $0

3. For construction of the water pipeline, reduce, 

to the extent possible, side cast soils to reduce 

color contrast with the surrounding landscape. 

Backfill the pipeline disturbed zone and revegetate 

with native vegetation immediately following 

completion of pipeline construction (Measure 

AES-3).

Eagle Crest, staff $0c $0c $0

4. Employ visual mitigation in the design of the 

transmission line to minimize visual effects 

(Measure AES-4).

Eagle Crest, staff $0c $0c $0

5. Use existing access roads and construction 

laydown areas to the extent feasible and revegetate 

with native vegetation immediately following 

construction (Measure AES-5).

Eagle Crest, staff $0c $0c $0

6. Design and construct the transmission line 

along the State Water Board’s recommended 

transmission line route.

Staff $9,072,000e $0 $598,310
232

Enhancement/Measure Entity

Capital Cost 

(2010$)

Annual 

Cost 

(2010$)

Levelized 

Annual Cost 

(2010$)

7. Consult with the Park Service to develop and 

implement a formal night sky monitoring study 

plan that includes descriptions of monitoring 

methods and number and types of sampling 

events. The plan should also include a process for 

incorporating study findings into design and 

lighting product selection that would minimize 

light pollution from project sources. The 

anticipated night sky study would incorporate 

measures proposed by Eagle Crest in Measure 

AES-1.

Staff $95,000 $0 $6,270

Cultural Resources

1. Implement the project’s December 2009 

HPMP, including Measures CLT-1, -2, -3.

Eagle Crest $282,500 $6,500 $22,860

2. Revise the December 2009 HPMP in 

consultation with the BLM, California SHPO and 

participating tribes to address the following: 

(1) clarification in the HPMP’s Overview and 

Executive Summary that the Eagle Mountain 

mine, town site, and associated railroad are 

potential historic properties; (2) requirements for 

annual reporting during construction and an 

annual HPMP implementation report; (3) a plan to 

address curation of recovered archaeological 

materials; (4) clarification of when cultural 

resources monitoring and which monitoring 

Staff $30,000 $6,500 $6,200
233

Enhancement/Measure Entity

Capital Cost 

(2010$)

Annual 

Cost 

(2010$)

Levelized 

Annual Cost 

(2010$)

protocols would be required; (5) a requirement for 

consultation with Native American tribes 

regarding employee training and public 

interpretation programs; and (6) a detailed 

discussion of the expanded APE alternatives, 

including revised APE maps; (7) a description of 

the sites documented by Schaefer (2010) and 

located within the expanded APE; (8) a plan and 

schedule for National Register evaluations, 

assessment of effects, and identification of 

measures to resolve adverse effects of project 

construction, operations and maintenance on any 

of sites identified within the specific Commission 

staff’s recommended transmission line corridor 

and substation location; and (9) measures for 

handling newly discovered paleontological 

resources and the reporting of such discoveries to 

BLM. The anticipated PA would implement the 

HPMP.

Air Quality and Noise

1. Periodically water or apply suitable surfactant 

for short-term stabilization of disturbed surface 

areas and storage piles (Measure AQ-1).

Eagle Crest, staff $461,250 $0 $30,420

2. Prevent project-related trackout onto paved 

surfaces by using a variety of construction 

management strategies (Measure AQ-2).

Eagle Crest, staff $25,000 $0 $1,650
234

Enhancement/Measure Entity

Capital Cost 

(2010$)

Annual 

Cost 

(2010$)

Levelized 

Annual Cost 

(2010$)

3. Stabilize graded site surfaces upon completion 

of grading when subsequent development is 

delayed or expected to be delayed by more than 30 

days, except when precipitation dampens the 

disturbed surface (Measure AQ-3).

Eagle Crest, staff $92,500 $0 $6,100

4. Limit areas of active surface disturbance (such 

as grading) to no more than 15 acres per day 

(Measure AQ-4).

Eagle Crest, staff $30,750 $0 $2,030

5. Reduce non-essential earth-moving activities 

during windy conditions, and cease clearing, 

grading, earth-moving, or excavation activities if 

winds exceed 25 mph averaged over a 1-hour 

duration (Measure AQ-5).

Eagle Crest, staff $30,500 $0 $2,010

6. Develop and implement a transportation 

management plan for employees (Measure AQ-6).

Eagle Crest, staff $20,000 $0 $1,320

7. Strictly abide by the applicable state law 

requirements for diesel truck idling (AQ-7).

Eagle Crest $10,000 $0 $660

8. Use electrical drops in place of temporary 

electrical generators, and substitute low- and zeroemitting construction equipment and/or alternative 

fueled or catalyst equipped diesel construction 

equipment wherever economically feasible 

(Measure AQ0-8).

Eagle Crest, staff $10,000 $0 $660
235

Enhancement/Measure Entity

Capital Cost 

(2010$)

Annual 

Cost 

(2010$)

Levelized 

Annual Cost 

(2010$)

9. Obtain proper South Coast Air Quality 

Management District permits for electrical 

generators (Measure AQ-9).

Eagle Crest $10,000 $0 $660

10. Properly tune and maintain heavy-duty diesel 

trucks in accordance with manufacturer’s 

specifications to ensure minimum emissions under 

normal operations (Measure AQ-10).

Eagle Crest, staff $20,000 $0 $1,320

11. Use 2002 model or newer construction 

equipment, where feasible (Measure AQ-11).

Eagle Crest, staff $80,000 $0 $5,280

12. Retrofit older off-road construction 

equipment with appropriate emission control 

devices prior to onsite use, wherever feasible 

(Measure AQ-12).

Eagle Crest, staff $50,000 $0 $3,300

13. Establish an air quality study design for two 

years of air quality monitoring (Measure AQ-13).

Eagle Crest, staff $40,000 $0 $2,640

14. Comply with the County of Riverside General 

Plan applicable noise ordinance codes during 

construction (Measure NOI-1).

Eagle Crest $30,000 $0 $1,980

15. Equip construction machinery with properly 

operating and maintained noise mufflers and 

intake silencers (Measure NOI-2).

Eagle Crest, staff $20,000 $0 $1,320

a Based on very limited, available information, staff estimated that the cost to compensate a single well owner for increased 

pumping costs per well over a 30-year period could be as high as $60,000. About 50 wells could experience a drawdown in excess 

of 5 feet due to proposed groundwater withdrawals associated with the project.
236

b In the revised table 4-1, submitted with Eagle Crest’s December 22, 2009, additional information response filing, Eagle 

Crest (2009c) states that the costs for this measure are included in the costs presented for Measure WS-1 above; 

therefore, staff has shown no cost here.

c Eagle Crest did not provide specific costs to implement this measure; therefore, staff assumes that the cost is included in 

the base construction cost of the project.

d This measure would also include the cost to install the lower reservoir spillway and discharge channel proposed to add 

after the license application was filed. Eagle Crest did not provide an estimate for the cost to install the spillway and 

channel, so staff has conservatively estimated the cost of this measure at $10,000,000.

e Staff estimated that the implementation of this measure would increase the length of the transmission line by about 3.0

miles. The cost shown represents only the incremental cost to extend the line based on Eagle Crest’s estimated cost for 

the proposed 13.5-mile-long route of $40,824,000 ($3,024,000 per mile). The cost of Eagle Crest’s proposed 13.5-milelong route is included in the base construction cost of the project
237

5.0 CONCLUSIONS AND RECOMMENDATIONS

5.1 COMPARISON OF ALTERNATIVES

In this section, staff compares the development and non-developmental effects of 

Eagle Crest’s proposal, Eagle Crest’s proposal as modified by staff, and the no-action 

alternative. 

Staff estimates the annual generation of the project under the three alternatives

identified above. Staff analysis shows that the annual generation would be 4,308 GWh

for the proposed action; 4,308 GWh for the staff alternative; and 0 GWh for the no-action 

alternative.

Staff summarizes the environmental effects of the different alternatives below.

39

Table 28. Comparison of the proposed action and the staff alternative for the Eagle 

Mountain Pumped Storage Project (Source: staff).

Staff presents the effects of the proposed and staff alternative transmission line and 

substation in table 28 and also discusses it in section 5.2.

Resource Proposed Action Staff Alternative

Project 

Facilities

Construct the proposed substation 

location near Desert Center, as 

shown in figure 2.

Recommend construction of the 

substation about 6 miles east of 

Desert Center and south of Interstate 

10, as shown in figure 2.

Construct the proposed 

transmission line, as shown in 

figure 2.

Recommend construction of the 

transmission line along the State 

Water Board’s recommended

transmission line route, as shown in 

figure 2.

Geology and 

Soils

Implement the Erosion and 

Sediment Control Plan filed July 

7, 2010.

Same as proposed.

Water 

Resources

To evaluate effects of project 

operations on groundwater levels 

and ensure that levels are 

maintained at historical values, 

develop a groundwater level 

monitoring network and monitor 

Same as proposed, but include in the 

recommended comprehensive 

groundwater monitoring program.

 

39 Under the no-action alternative, the project would not be built.
238

Resource Proposed Action Staff Alternative

during project operations 

(including reservoir filling) 

initially quarterly and possibly 

extending to bi-annual or annual 

monitoring depending on findings 

and prepare annual reports.

To limit the effects of project 

groundwater pumping during the 

initial fill pumping period, monitor 

existing wells on neighboring 

properties whose water production 

may be impaired if project 

pumping would adversely affect 

these wells, replace or lower the 

pumps, deepen the existing well, 

construct a new well, and/or 

compensate owner for increased 

pumping costs.

Include the monitoring aspect in the 

recommended comprehensive 

groundwater monitoring program. 

Regarding the replacement, or 

alteration of new wells, and 

compensation for increased 

pumping cost, staff notes that the 

FPA, section 10(c), 16 U.S.C. 803, 

makes clear that a licensee of a 

hydropower project “shall be liable 

for all damages occasioned to the 

property of others by the 

construction, maintenance, or 

operation of the project works....”

To effectively control seepage 

from the upper and lower

reservoirs, install an array of 

seepage recovery wells outside the 

down-gradient end of each of 

these two reservoirs. A testing 

program would be initially 

employed during final engineering 

(prior to project operations) to 

confirm the assumed 

hydrogeologic conditions 

(e.g., aquifer characteristics and 

bedrock fracture 

interconnectedness) and seepage 

recovery well pumping rates.

Same as proposed, but include in the 

recommended comprehensive 

groundwater monitoring program.

To ensure that seepage recovery 

via pumping wells would be 

effective at managing groundwater 

levels beneath the Metropolitan 

Same as proposed, but include in the 

recommended comprehensive 

groundwater monitoring program.
239

Resource Proposed Action Staff Alternative

Water District’s Colorado River 

Aqueduct (CRA) and in the Eagle 

Creek Canyon portion of the 

proposed landfill, develop a 

groundwater level monitoring 

network (including existing and 

new monitoring wells) and record 

groundwater levels, water quality, 

and production at the project 

seepage recovery wells

To limit the effects of seepage 

from the reservoirs, maintain 

seepage from the upper reservoir 

below the bottom of the elevation 

of the landfill liner and maintain 

seepage from the lower reservoir 

to prevent a significant rise in 

water levels beneath the CRA.

Same as proposed, but include in the 

recommended comprehensive 

groundwater monitoring program.

Monitor groundwater levels by 

using the network of proposed 

groundwater monitoring wells on 

a quarterly basis for the first 

4 years of project pumping;

possibly extend monitoring from 

quarterly to bi-annually or 

annually, depending on findings. 

This measure would focus on 

assessing seepage conditions in 

the project vicinity, rather than 

drawdown conditions as a result of 

project pumping in the Desert 

Center area.

Same as proposed, but include in the 

recommended comprehensive 

groundwater monitoring program.

To remove salts and metals from 

the reservoir water and maintain 

total dissolved solids 

concentration at the level of the 

source water, install a reverse 

osmosis desalination facility and 

brine disposal lagoons.

Same as proposed.
240

Resource Proposed Action Staff Alternative

Assess effects on groundwater

quality by sampling reservoirs, 

seepage recovery wells, and wells 

upgradient and downgradient of 

the reservoirs and brine disposal 

lagoons, and implement a 

monitoring program for 

groundwater quality on a quarterly 

basis for the first 4 years.

Implement a reservoir and brine 

pond-level monitoring plan and a 

more comprehensive monitoring 

program of monitoring wells for the 

proposed brine and solidification 

ponds.

Replace four existing wells

located within the proposed 

reservoir area with wells located 

outside of reservoirs.

Same as proposed.

Release excess water from the 

reservoirs to Eagle Creek during 

large rainfall events, such as the 

100-year event and up to and 

including the probable maximum 

flood (PMF).

Same as proposed, but also 

recommend modifications and other 

measures to Eagle Creek, if 

necessary, to contain the flow within

Eagle Creek and direct the flow to 

the proposed lower reservoir.

To ensure that potential 

subsidence would not affect the 

CRA, construct two 

extensometers.

Same as proposed, but also specify

operation of these two devices.

Terrestrial 

Resources

Consult with a Biological 

Technical Advisory Team 

(including Eagle Crest, BLM, 

FWS, and California DFG) to 

develop a comprehensive site 

specific mitigation and monitoring 

plan.

Same as proposed, and file for 

Commission approval.
241

Resource Proposed Action Staff Alternative

Implement the Worker 

Environmental Awareness 

Program, filed October 27, 2009, 

to provide oversight of 

construction activities by trained 

biologists and train construction 

crews to recognize biologically 

sensitive resources.

Same as proposed.

Prepare status reports for resource 

agencies during construction 

period.

File quarterly reports with BLM, 

FWS, California DFG, and the 

Commission.

Limit construction activities in 

native habitats, preserve existing 

desert wash topography and flow 

patterns.

File pre-construction plans that 

delineate limits of disturbance and 

limits of existing washes or 

impoundments.

Conduct pre-construction surveys 

for state special-status plants, and 

establish avoidance areas where 

possible. When avoidance is not 

possible, implement transplant or 

salvage measures.

Include results of surveys, 

designated avoidance areas, and 

transplant locations in preconstruction plans filed with BLM, 

FWS, California DFG, and the 

Commission.

Implement the Revegetation Plan 

filed October 27, 2009.

Same as proposed.

Implement the Invasive Species 

Monitoring and Control Plan filed 

October 27, 2009.

Revise plan to incorporate success 

criteria and adaptive management 

that would be implemented if 

success criteria are not be achieved. 

Extend the plan’s scope to include 

project reservoirs and water seepage 

areas. These areas should be 

monitored on an annual basis 

following vegetation establishment.

Implement measures to avoid 

disturbance or restrict flow to 

impoundments that could support 

Couch’s spadefoot toad.

Conduct pre-construction surveys 

for such impoundments in any areas 

of construction activity not already 

surveyed.
242

Resource Proposed Action Staff Alternative

Prior to any construction activities 

occurring in vegetated areas 

between February 15 and July 30, 

conduct surveys for active 

migratory bird nests and provide a 

15-foot no-activity buffer around 

active nests.

Same as proposed.

Develop and implement a 

evaporation pond management 

plan to limit effects on birds.

Revise plan to include proposed 

hazing and habitat techniques, 

success criteria, and thresholds for 

implementing exclusionary pond 

covering.

Conduct Phase III or preconstruction surveys for 

burrowing owls. 

Conduct pre-construction surveys,

but no Phase III surveys. 

Incorporate results of preconstruction surveys into 

development of site specific 

comprehensive mitigation plan.

If needed (based on survey 

results), limit construction from 

September 1 through February 1 in 

areas with burrowing owls and 

provide protection buffer for 

active nests.

Same as proposed.

Based on pre-construction 

surveys, determine need for and 

implement 0.25-mile construction 

buffers around active golden eagle 

or prairie falcon nests.

Same as proposed.

Conduct pre-construction surveys 

for all burrows that could host 

badger or kit fox and implement 

measures to avoid causing injury 

to animals.

Same as proposed.

Conduct pre-construction surveys 

for bat roosts and foraging areas. 

Include agency consultation, 

proposed mitigation measures, 
243

Resource Proposed Action Staff Alternative

Develop and implement avoidance 

and mitigation measures based on 

survey results.

success criteria, and proposed 

adaptive management measures in 

the plan and submit the plan for 

Commission approval.

Construct security fencing around 

project reservoirs, collection 

substation, and evaporation ponds 

to exclude large mammals like 

badger, fox, deer, coyote, and 

bighorn sheep. Design fence to 

provide access to drinking water in 

the lower reservoir.

Same as proposed.

In construction areas without 

wildlife exclusion fencing or those 

areas that have not been cleared of 

tortoises, conduct construction 

activities only during daylight 

hours.

Same as proposed.

Implement measures to ensure 

animals are not trapped in pipeline 

trenches during construction.

Same as proposed.

Design lighting to prevent casting 

light into adjacent native habitat.

Same as proposed.

Develop and implement a 

transmission line design plan to 

reduce potential for avian 

electrocutions and design lines in 

accordance with industry 

guidelines.

Include measures in plan to reduce 

risk of avian collisions, protocols for 

monitoring and reporting 

avian/powerline interactions, and 

worker education measures.

Threatened 

and 

Endangered 

Species

Implement Desert Tortoise 

Removal and Translocation Plan 

filed October 27, 2009.

Same as proposed.

Purchase and manage for 

conservation about 160 acres of 

desert tortoise habitat to 

Upon completion of final project 

design and construction plans, 

recalculate acres of project-related 
244

Resource Proposed Action Staff Alternative

compensate for effects on desert 

tortoise.

disturbance to Category I and 

Category III desert tortoise habitat 

and determine appropriate 

compensation acreage based on 

NECO Plan compensation ratios.

Implement Raven Monitoring and 

Control Plan filed October 27, 

2009.

Modify plan to include baseline 

surveys and post-construction 

monitoring methods for coyotes, 

wild dogs, and gulls. Include 

mitigation measures to be 

implemented if increases in 

population levels are detected 

following construction. Include a 

monitoring schedule that would 

begin the second year after project 

completion, followed by surveys 

once every 5 years.

Recreation 

Resources

Coordinate construction schedules 

with BLM and provide posted 

notices of construction activity 

and any temporary road/access 

closure.

Same as proposed.

Land Use Provide construction access to and 

from the substation site from the 

Eagle Mountain Road exit and 

follow the Frontage Road east to 

the site.

Same as proposed for access to the 

site, but incorporate truck trip plans 

and traffic controls related to the 

removal of salts from the proposed 

desalination facilities.

Two weeks prior to beginning 

construction, locally post notices 

stating hours of operation for 

construction near the Desert 

Center community and along State 

Route 177.

Same as proposed.

Aesthetics Incorporate lighting measures in 

the central project area to 

minimize the effect on 

surrounding areas outside of the 

Same as proposed.
245

Resource Proposed Action Staff Alternative

project; also conduct night sky 

monitoring after consultation with 

the Park Service.

Combine and organize staging 

areas and areas needed for 

equipment operation and material 

storage and assembly within

construction lands to the extent 

feasible to minimize total footprint 

needed.

Same as proposed.

For construction of the water 

pipeline, reduce color contrast 

with the surrounding landscape

and revegetate with native 

vegetation.

Same as proposed.

Employ visual mitigation in the 

design of the transmission line to 

minimize visual effects.

Same as proposed.

Use existing access roads and 

construction laydown areas to the 

extent feasible and revegetate with 

native vegetation.

Same as proposed.

Cultural 

Resources

Implement the project’s revised 

HPMP.

Modify plan to include:

1. Clarification in the Executive 

Summary that the Eagle Mountain 

mine, town site, and railroad are 

potential historic properties.

2. Annual HPMP implementation 

reporting during and after 

construction.

3. Curation of recovered 

archaeological materials.

4. Specific criteria that would 

determine the need for cultural 

resources monitoring and a plan to 

identify appropriate Native 
246

Resource Proposed Action Staff Alternative

American involvement.

5. A plan to include interested 

Native American tribes in the 

development of staff training and 

public interpretation programs.

6. A detailed discussion of the 

expanded APE transmission 

alternative, including revised APE 

maps.

7. A description of the sites 

document by Schaefer (2010) and 

located within the expanded APE

8. Inclusion of a detailed plan and 

schedule for National Register 

evaluations, assessment of effects, 

and identification of measures to 

resolve adverse effects of project 

construction, operations and 

maintenance to sites identified 

within the specific Commission staff 

alternative transmission line 

corridor and substation location.

9. Measures for handling newly 

discovered paleontological 

resources and reporting discoveries 

to BLM.

Air Quality Prevent project-related trackout 

onto paved surfaces by using a 

variety of construction 

management strategies.

Same as proposed, and include in 

the Erosion and Sediment Control 

Plan.

Provide measures and standards to

stabilize graded site surfaces upon 

completion of grading.

Same as proposed, and include in 

the Erosion and Sediment Control 

Plan.

Limit areas of active surface 

disturbance (such as grading) to no 

more than 15 acres per day.

Same as proposed.
247

Resource Proposed Action Staff Alternative

Reduce non-essential earthmoving activities during windy 

conditions.

Same as proposed.

Develop and implement a 

transportation management plan 

for employees.

Same as proposed.

Use electrical drops in place of 

temporary electrical generators, 

and substitute low- and zero 

emitting construction equipment 

and/or alternative fueled or 

catalyst-equipped diesel 

construction equipment wherever 

economically feasible.

Same as proposed.

Properly tune and maintain heavyduty diesel trucks in accordance 

with manufacturers’ specifications 

to ensure minimum emissions 

under normal operations.

Same as proposed.

Use 2002 model or newer 

construction equipment.

Same as proposed.

Retrofit older off-road 

construction equipment with 

appropriate emission control 

devices prior to onsite use.

Same as proposed.

Implement a 2-year air monitoring 

study after consultation with the 

Park Service.

Same as proposed.

Noise Equip construction machinery 

with properly operating and 

maintained noise mufflers and 

intake silencers.

Same as proposed.
248

5.2 COMPREHENSIVE DEVELOPMENT AND RECOMMENDED 

ALTERNATIVE 

Sections 4(e) and 10(a)(1) of the FPA require the Commission to give equal 

consideration to the power development purposes and to the purposes of energy 

conservation; the protection, mitigation of damage to, and enhancement of fish and 

wildlife; the protection of recreational opportunities; and the preservation of other aspects 

of environmental quality. Any license issued shall be such as in the Commission’s 

judgment will be best adapted to a comprehensive plan for improving or developing a 

waterway or waterways for all beneficial public uses. This section contains the basis for, 

and a summary of, staff’s recommendations for licensing the Eagle Mountain Project. 

Staff weighs the costs and benefits of its recommended alternative against other proposed 

measures.

Based on staff’s independent review of agency and public comments filed on this 

project and review of the environmental and economic effects of the proposed project and 

its alternatives, staff selected the staff alternative, as the preferred option. Staff

recommends this option because: (1) issuance of an original hydropower license by the 

Commission would allow Eagle Crest to operate the project as an economically beneficial 

and dependable source of electrical energy during high demand hours; (2) the 1,300 MW 

of electric energy generated from a renewable resource may offset the use of fossilfueled, electric generating plants during high demand hours, thereby reducing 

atmospheric pollution; (3) the majority of the power used to pump water to the upper 

reservoir during low demand hours is expected to come from renewable sources or 

available base-load sources; (4) the public benefits of this alternative would exceed those 

of the no-action alternative; and (5) the recommended measures would help protect 

water, wildlife, recreation, land use, aesthetics, cultural, air quality and noise resources 

during construction and operations. 

In the following section, staff makes recommendations as to which environmental 

measures proposed by Eagle Crest or recommended by agencies and other entities should 

be included in any license issued for the project. In addition to Eagle Crest’s proposed 

environmental and mitigation measures, staff recommends additional staff-recommended 

environmental measures to be included in any license issued for the project. Staff also 

discusses which measures it does not recommend including in the license.

Measures Proposed by Eagle Crest 

Based on staff’s environmental analysis of Eagle Crest’s proposal discussed in 

section 3.0 and the costs discussed in section 4.0, staff recommends including the 

following environmental measures proposed by Eagle Crest in any license issued for the 

project. Staff’s recommended modifications to Eagle Crest’s proposed measure are 

shown in italics.
249

Geology and Soils

• Implement the Erosion and Sediment Control Plan filed July 7, 2010, that 

describes the erosion and sediment control practices to minimize soil erosion in 

construction areas and prevent sediment transport into stormwater discharges 

away from the construction site (Measure GEO-1).

Water Quality/Water Quantity

Measures for Drawdown Monitoring and Control

• Develop a groundwater level monitoring network (including existing and new 

monitoring wells [see figure 7]) to confirm that project pumping throughout 

the project operations would be maintained at levels that are in the range of 

historical pumping in the Chuckwalla Aquifer (Measure WS-1). Possibly 

extend monitoring from quarterly to bi-annually or annually, depending on 

findings and prepare annual reports for submittal to the Commission and State 

Water Board, confirming actual drawdown conditions (Measure WS-4). 

• During the initial fill pumping period, monitor existing water supply wells on 

neighboring properties whose water production may be impaired by project 

groundwater pumping; if project pumping would adversely affect these wells, 

replace or lower the pumps, deepen the existing well, construct a new well, 

and/or compensate owner for increased pumping costs (Measure WS-3). 

Measures for Seepage Monitoring and Control

• To confirm aquifer characteristics and adequate pumping rates in the reservoir 

seepage recovery wells, perform aquifer tests during final engineering design 

(prior to project operations) (Measure SR-1).

• To effectively control seepage from the upper reservoir, use a separate set of 

seepage recovery wells, employ a testing program for these seepage recovery 

wells, and make drawdown observations in nearby observation wells to support 

final engineering design (Measure SR-2).

• Confirm that seepage recovery well pumping would be effective at managing 

groundwater levels beneath the Metropolitan Water District’s CRA and in the 

Eagle Creek Canyon portion of the proposed landfill, and record groundwater 

levels, water quality, and production at the project seepage recovery wells 

(Measure SR-3). 

• Maintain seepage from the upper reservoir at a groundwater level below the 

bottom of the elevation of the landfill liner and maintain seepage from the 

lower reservoir to prevent a significant rise in water levels beneath the CRA 

(Measure SR-4).
250

• Using the network of groundwater monitoring wells proposed under Measure 

WS-1, monitor groundwater levels on a quarterly basis for the first 4 years of 

project pumping; possibly extend monitoring from quarterly to bi-annually or 

annually, depending on findings (Measure SR-5). Unlike WS-4, this measure 

would focus on assessing seepage conditions in the project vicinity, rather than 

drawdown conditions as a result of project pumping in the Desert Center area.

• As an adaptive management measure pending the initial findings of measures 

SR-1 through SR-5, manage seepage from the reservoirs, which if left 

unimpeded could raise groundwater levels by up to 3 feet (implementation of 

this alternative would require confirmation of groundwater level rises and 

water quality of the resulting seepage) (Alternative Measure SR-1A).

Measures for Water Quality Monitoring and Control

• Install and operate a reverse osmosis desalination facility and brine disposal 

ponds to remove salts and metals form reservoir water and maintain total 

dissolved solids concentrations at the level of the source water (Measure GQ1). Monitor groundwater quality to assess and limit groundwater effects by 

sampling reservoirs, seepage recovery wells, and wells upgradient and 

downgradient of the reservoirs and brine disposal lagoons on a quarterly basis 

for the first 4 years (Measure GQ-2). Modify this measure to include 

implementation of a comprehensive water quality monitoring plan for the 

reservoirs, seepage wells, monitoring wells, and brine ponds, and include steps 

to be taken in the event of water quality degradation.

• Monitor groundwater quality to assess and maintain groundwater effects at 

levels less than significant by sampling reservoirs, seepage recovery wells, and 

wells upgradient and downgradient of the reservoirs and brine disposal lagoon 

on a quarterly basis for the first 4 years (Measure GQ-2). Modify this measure 

to include implementation of a comprehensive water quality monitoring plan 

for the reservoirs, seepage wells, monitoring wells, and brine ponds, and 

include steps to be taken in the event of water quality degradation.

Other Water Resources Measures

• Replace four existing wells located within the proposed reservoirs with wells 

located outside of reservoirs (Measure LF-1).

• Release excess water from the reservoirs during large rainfall events, such as 

the 100-year event and up to and including the PMF.

• Construct and operate two extensometers—one in the upper Chuckwalla 

Valley near Observation Well 3 (OW-3) and the other in the Orocopia Valley 

near OW-15—to measure potential subsidence that could affect the operation 

of the CRA (Measure WS-2). 
251

Terrestrial Resources

• Concurrent with final design engineering, develop a comprehensive sitespecific mitigation and monitoring program in consultation with the Biological 

Technical Advisory Team, made up of representatives from Eagle Crest, BLM, 

FWS, California DFG (Measure BIO-1) to protect state sensitive, BLM 

sensitive, and federally listed plant and wildlife species. 

• Implement the WEAP filed October 27, 2009, to ensure that project 

construction and operation would be conducted within a framework of 

safeguarding environmentally sensitive resources (Measure BIO-3).

• Submit quarterly reports to BLM, FWS, California DFG, and the Commission, 

documenting project activities, mitigation implemented, and mitigation 

effectiveness, and providing recommendations, as needed (Measure BIO-4).

• Prior to construction in native habitats prepare, in consultation with BLM, 

FWS, and California DFG, and file for Commission approval, a plan that 

details construction plans and limits of disturbance such that surface 

disturbance is restricted to the smallest area necessary to complete the 

construction; and new spur roads and improvements to existing roads are 

designed in a way that would preserve existing desert wash topography and 

flow patterns, and avoid disturbing or restricting flow to impoundments that 

could support Couch’s spadefoot toad (Measures BIO-5 and BIO-10).

• Use pre-construction surveys to identify state special-status plant populations 

and species, and establish avoidance areas in construction zones for special 

plant resources. Where avoidance is not feasible, salvage and transplant any 

species that can be reasonably transplanted in an approved area (Measure BIO6). Include location of sensitive plant resources, construction avoidance 

areas, and transplant locations on construction plans filed with the 

Commission.

• Implement the Revegetation Plan filed October 27, 2009, for areas that are 

temporarily disturbed during construction (Measure BIO-8).

• Implement the Invasive Species Monitoring and Control Plan filed October 27, 

2009, to minimize the spread of invasive non-native vegetation (Measure BIO9). Modify the proposed Invasive Species Monitoring and Control Plan, and 

file for Commission approval, to include criteria for success and an adaptive 

management plan to be implemented if initial efforts do not prove successful. 

Include the reservoirs and water seepage areas along with other areas to be 

monitored for invasive plants. Monitor water seepage and reservoirs on an 

annual basis following vegetation establishment. 

• For construction activities scheduled to occur between about February 15 and 

July 30 in vegetated habitat, survey all potential nesting sites for active bird 
252

nests. Active nests would be flagged and provided a 15-foot buffer from 

construction activities (Measure BIO-11).

• Develop and implement a plan to manage evaporation ponds to minimize their 

attractiveness and access to migratory birds and establish a monitoring 

program to identify bird usage of the evaporation ponds, effectiveness of bird 

deterrents, and water quality. Based on monitoring results, implement adaptive 

management to include more intensive hazing measures or exclusionary pond 

covers (Measure BIO-12). Include in the plan proposed hazing and habitat 

modification techniques, methods for measuring success, and thresholds for 

implementing exclusionary pond covering and file for Commission approval.

• Conduct a pre-construction survey to further assess burrowing owl use of the 

project area and potential effects. Incorporate survey results and mitigation 

measures into the comprehensive mitigation and monitoring program

(Measure BIO-13). If burrowing owls are present, limit the construction to 

September 1 through February 1, to avoid disruption of breeding activities; 

avoid disruption of burrowing owl nesting activities; use a minimum of a 250-

foot buffer to avoid active nests until fledging has occurred (Measure BIO-14).

• Determine through pre-construction surveys if 0.25-mile construction buffers 

would be required during prairie falcon or golden eagle nesting seasons 

(Measure BIO-15).

• Conduct pre-construction surveys for all burrows that might host badger or kit 

fox, avoiding active burrows, where possible, and mark the perimeters of all 

avoidance areas with 3-foot-high and no more than 10-foot-apart, wooden 

stakes. Where avoidance is infeasible, encourage occupants to leave their 

burrows (Measure BIO-16). 

• Conduct pre-construction surveys to determine the existence, location, and 

condition of bat roosts and identify foraging habitat. Based on results of 

surveys, develop a mitigation plan to avoid roosting and foraging effects on 

resident bats, minimize disturbance, or, as an inescapable measure, evict bats 

(Measure BIO-17). Prepare the bat mitigation plan after consultation with 

FWS and California DFG and file for Commission approval, to include 

proposed environmental measures, methods for determining success, and 

adaptive management strategies to ensure successful mitigation for loss of bat 

habitat is achieved.

• Construct security fencing around project reservoirs, collection substation, and 

evaporation ponds to exclude larger terrestrial wildlife, including bighorn 

sheep, deer, coyotes, foxes, and badger, from entering project areas that pose 

hazards (Measure BIO-18).
253

• In areas without wildlife exclusion fencing or those areas that have not been 

cleared of tortoises, conduct construction activities only during daylight hours 

(Measure BIO-20). 

• Close, temporarily fence, or cover pipeline trenches each day. Conduct 

inspections of any open trenches at first light, midday, and at the end of each 

day to ensure animal safety (Measure BIO-21).

• Design, install, and maintain facility lighting to prevent casting of light into 

adjacent native habitat (Measure BIO-22).

• Develop and implement, after consultation with FWS and file for Commission 

approval, a transmission line design plan that considers adequate separation of 

energized conductors, ground wires, and other metal hardware, adequate 

insulation, and any other measures necessary to protect raptors from 

electrocution hazards and design and construct raptor-friendly transmission 

lines in strict accordance with the industry standard guidelines set forth in 

Suggested Practices for Raptor Protection on Power Lines: The State of the Art 

in 2006, by Avian Power Line Interaction Committee, Edison Electric Institute, 

and Raptor Research Foundation. After consultation with FWS, design 

measures for reducing potential for avian collision injuries, provide methods 

for surveying and reporting project-related avian mortality, incorporate a 

worker education plan pertaining to avian–power line interactions, and 

include procedures for managing nesting on power line structures.

Threatened and Endangered Species

• Implement Desert Tortoise Removal and Translocation Plan to protect desert 

tortoise from potential effects related to construction activities.

• Following completion of final project design and interconnection plans, 

calculate projected-related effects on Category I and Category III Desert 

Tortoise Habitat. Prepare and file for Commission approval a desert tortoise 

habitat compensation plan that identifies acres of disturbance and acreage and 

location of proposed compensation lands.

• Implement the Raven Monitoring and Control Plan filed October 27, 2009 

(Measure DT-5). Amend the current Raven Monitoring and Control Plan to 

include baseline and post-construction monitoring methods for coyotes, wild 

dogs, and gulls and develop mitigation measures to be implemented if 

increases in population levels are detected, and develop a desert tortoise 

predator control plan, as the Park Service recommends. Include a survey

schedule that includes initiation of post-construction surveys during the second 

year after project completion, followed by surveys once every 5 years.
254

Recreation Resources

• Coordinate construction schedules with BLM and provide posted notices of 

construction activity and any temporary road/access closure (Measure REC-1).

Land Use

• Provide construction access to and from the substation site from the Eagle 

Mountain Road exit and follow the Frontage Road east to the site (Measure

LU-1).

• Two weeks prior to beginning construction, locally post notices stating hours 

of operation for construction near the Desert Center community and along 

State Route 177 (Measure LU-2).

Aesthetic Resources

• Incorporate directional lighting, light hoods, low pressure sodium bulbs or 

LED lighting, and operational devices in final design to allow surface nightlighting in the central site to be turned on as needed for safety. Also, develop, 

after consultation with the Park Service, a night sky monitoring plan during the 

post-licensing design period (to represent baseline conditions) and during 

construction and a trial operational period (Measure AES-1). File the plan for 

Commission approval.

• Combine and organize staging areas and areas needed for equipment operation 

and material storage and assembly within construction lands to the extent 

feasible to minimize total footprint needed (Measure AES-2).

• For construction of the water pipeline, reduce, to the extent possible, side cast 

soils to reduce color contrast with the surrounding landscape. Backfill the 

pipeline disturbed zone and revegetate with native vegetation immediately 

following completion of pipeline construction (Measure AES-3).

• Employ visual mitigation in the design of the transmission line to minimize 

visual effects such as specifying materials with a dull finish and background 

appropriate colors (Measure AES-4).

• Use existing access roads and construction laydown areas to the extent feasible 

and revegetate with native vegetation within 3 months following completion of 

construction of the respective component (Measure AES-5).

Cultural Resources

• Implement the project’s December 2009 HPMP. 
255

Air Quality

• Periodically water or apply suitable surfactant for short-term stabilization of 

disturbed surface areas and rock and soil storage piles (Measure AQ-1).

• Prevent project-related trackout onto paved surfaces by using a variety of 

construction management strategies (Measure AQ-2).

• Stabilize graded site surfaces upon completion of grading when subsequent 

development is delayed or expected to be delayed by more than 30 days, 

except when precipitation dampens the disturbed surface (Measure AQ-3).

• Limit areas of active surface disturbance (such as grading) to no more than 15 

acres per day (Measure AQ-4).

• Reduce non-essential earth-moving activities during windy conditions, and 

cease clearing, grading, earth-moving, or excavation activities if winds exceed 

25 mph averaged over a 1-hour duration (Measure AQ-5).

• Develop and implement a transportation management plan including ride 

sharing, shuttle transit and other measures for employees to reduce vehicle 

trips (Measure AQ-6).

• Use electrical drops in place of temporary electrical generators, and substitute 

low- and zero emitting construction equipment and/or alternative fueled or 

catalyst equipped diesel construction equipment wherever economically 

feasible or if necessary to meet CARB or other applicable air quality standards

(Measure AQ-8).

• Properly tune and maintain heavy-duty diesel trucks in accordance with 

manufacturers’ specifications to ensure minimum emissions under normal 

operations (Measure AQ-10).

• Use 2002 model or newer construction equipment, where feasible or if 

necessary to meet CARB or other applicable air quality standards (Measure 

AQ-11).

• Retrofit older off-road construction equipment with appropriate emission 

control devices prior to onsite use, where feasible or if necessary to meet 

CARB or other applicable air quality standards (Measure AQ-12).

• In consultation with the Park Service develop and implement a 2-year air 

monitoring study to determine possible effects of the project on air quality.

Noise

• Equip construction machinery with properly operating and maintained noise 

mufflers and intake silencers (Measure NOI-2).
256

Additional Measures Recommended by Staff

In addition to Eagle Crest’s proposed measures listed above, staff also

recommends including the following staff-recommended measures in any license issued 

for the Eagle Mountain Project: 

Project Facilities

• File for Commission approval a plan that identifies the route and tower 

placements associated with constructing the project transmission line along the 

staff-recommended transmission line route (State Water Board 

recommendation) as shown in figure 2.

• File for Commission approval a plan to connect the project to the electrical 

grid by terminating the transmission line at the staff-recommended substation 

location, about 6 miles east of the proposed substation location and south of 

Interstate 10 (State Water Board recommendation) as shown in figure 2.

Water Resources

• During project construction, perform channel modifications and other 

measures, such as rip rap protection, to contain flows associated with the PMF

to the Eagle Creek channel and direct these flows into the proposed lower 

reservoir and file a report with the Commission when measures are completed. 

• Develop and implement a reservoir-level monitoring plan to ensure that the 

water levels are managed properly within operational restraints to ensure 

protection of terrestrial resources and file for Commission approval. 

• Develop and implement a brine pond-level monitoring plan to ensure that the 

ponds are managed properly and help limit leakage through the lining of the 

ponds and file for Commission approval.

• Implement a comprehensive monitoring well placement plan including 

partially horizontal monitoring wells and monitoring program around the 

proposed brine and solidification ponds to allow for the earlier detection of 

leaks in the lining of the ponds and file for Commission approval. 

• The applicant proposes groundwater monitoring under five different 

measures—WS-1, WS-3, WS-4, SR-3, and SR-5—that each have specific 

purposes. Implement these separate measures together as a comprehensive 

groundwater monitoring program to ensure that information collected as part of 

each measure are reported simultaneously for the purpose of better evaluating 

the project effects on the groundwater levels in the Chuckwalla Aquifer. Use

the comprehensive groundwater monitoring program results to develop a 

groundwater hydrologic budget and annually submit the associated reports for 

review by the State Water Board and filed with the Commission. 
257

• In addition to the applicant’s proposed actions under Measure WS-3, modify 

this measure to continue monitoring beyond the initial fill period (estimated 4-

7 years, as estimated by Eagle Crest); the length of additional monitoring 

should be determined through consultation with the State Water Board and 

filed for Commission approval. 

Terrestrial Resources and Threatened and Endangered Species

• Conduct pre-construction surveys for the spadefoot toad in all areas of 

proposed construction activity not previously surveyed in 2009 or 2010, and 

implement the same protection measures proposed for the proposed project 

reservoir areas.

Recreation, Land Use, and Aesthetics

• Incorporate truck trip plans and traffic controls related to the removal of salts 

from the proposed desalination facilities.

Cultural Resources

• Consult with BLM, participating tribes, and California SHPO to revise the 

December 2009 HPMP to include: (1) clarification in the HPMP’s Overview 

and Executive Summary that the Eagle Mountain mine, town site, and 

associated railroad are potential historic properties; (2) requirements for annual 

reporting during construction and an annual HPMP implementation report,

(3) a plan to address curation of recovered archaeological materials, 

(4) clarification of when cultural resources monitoring and which monitoring 

protocols would be implemented; (5) a requirement for consultation with 

Native American tribes regarding employee training and public interpretation 

programs; (6) a detailed discussion of the expanded APE alternatives, 

including revised APE maps; (7) a description of the sites documented by 

Schaefer (2010) and located within the expanded APE; (8) inclusion of a 

detailed plan and schedule for National Register evaluations, assessment of 

effects, and identification of measures to resolve adverse effects of project 

construction, operations and maintenance on any of sites identified within the 

specific Commission staff’s recommended transmission line corridor and 

substation location, including the documentation of appropriate consultation 

with the participating tribes, BLM, and California SHPO; and (9) measures for 

handling newly discovered paleontological resources and the reporting of such 

discoveries to BLM. The anticipated PA would incorporate the revised HPMP. 
258

Following is a discussion of the key issues and basis for the additional staffrecommended measures. 

Transmission Line Route

Eagle Crest’s proposed 13.5-mile transmission line route (see figure 2) would

generally follow existing access roads and Eagle Mountain Road from the central project 

area to an intersection with the Metropolitan Water District’s CRA. Along this segment, 

the line would parallel existing transmission lines. After crossing the CRA, the proposed 

line would continue to follow Eagle Mountain Road to a point about 2 miles north of 

Interstate 10. There are no existing utility structures such as towers or power lines along 

this segment. At this location, the line would turn to the southeast toward Desert Center 

sub-station. This 2.5-mile section of the line would require new ROW and would not 

follow existing landscape features. Of the total 13.5 miles, about 4.5 miles would be

within BLM’s designated utility corridor. 

The staff alternative transmission line would diverge from the applicant’s 

proposed route along Eagle Mountain Road and follow the existing SCE transmission 

line ROW and proposed water pipeline southeast to a point directly north of the proposed 

eastern substation southeast of the Desert Center airstrip, where it would turn south to 

connect to the substation. Unlike the applicant’s proposed route, the staff alternative 

transmission line route would result in the construction of new structures closer to 

existing transmission line structures, thus reducing incremental effects on biological, 

visual, and land use resources.

As summarized in table 29, staff analysis shows that the staff alternative for the 

transmission line route would have lower environmental effects than the applicant’s 

proposed route. The majority of the applicant’s proposed measures to reduce 

construction effects associated with the transmission line are applicable to both routes. 

However, because the staff alternative: (1) would be located outside of the desert tortoise 

critical habitat area, (2) would not bisect and would be outside the DWMA, and 

(3) would parallel an existing transmission line, it is staff’s recommended alternative

transmission line route.

Table 29. Summary of key differences in the potential effects of Eagle Crest’s 

proposal and the staff alternative for the route of the proposed transmission 

line (Source: staff). 

Resource

Applicant’s Proposed 

Transmission Line

Staff-Recommended Transmission 

Route (State Water Board’s 

Recommended Route)

Vegetation A Revegetation Plan for 

disturbed areas would be 

implemented.

Due to a longer route (additional 2.9

miles), revegetation measures would 

need to cover about a 20% larger area.
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Resource

Applicant’s Proposed 

Transmission Line

Staff-Recommended Transmission 

Route (State Water Board’s 

Recommended Route)

Desert Tortoise Desert tortoise protection 

measures would be conducted, 

including surveys, relocation, 

and exclusion fencing for 

areas under construction. 

About 2.4 miles would be 

within designated critical 

habitat.

Same protection measures would be 

conducted, but co-locating the line 

within an existing transmission 

corridor would result in less 

disturbance to sensitive tortoise 

habitat and lower predation risks 

associated with perching and nesting 

habitat. Not within designated critical 

habitat.

Raptors Line would be constructed 

according to APLIC 

guidelines and an avian 

protection plan would be 

prepared.

Same protection measures, but new 

structure locations would be less 

attractive to raptors due to proximity 

to existing structures.

Couch’s 

Spadefoot Toad

Proposed corridor was 

surveyed and no suitable 

habitat was identified.

Additional surveys would be needed 

for areas not previously surveyed.

Recreation The transmission line would 

be about 2 miles from the 

JTNP boundary.

The transmission line would be 

farther from the National Park 

boundary.

Aesthetics Line would follow Eagle 

Mountain Road then cut 

across the Chuckwalla Valley 

directly to Desert Center. 

Line would not cross 

Interstate 10.

Line would be co-located with 

existing lines. Line would cross 

Interstate 10.

Land Use Line would be located outside 

the BLM CDCA Utility 

corridor and would cross 0.4 

mile of private land.

Line would cross 4.9 miles of private 

land.

Cultural 

Resources

Line would avoid most 

potential project effects.

Line would avoid most potential 

project effects.
260

Water Resources

The project effects on groundwater and water resources are key issues with the 

proposed project. Major proposed project facilities and measures, which would limit the 

environmental effects on the surrounding environment from groundwater withdrawal, 

seepage of groundwater from the reservoirs, degradation of the water quality in the 

reservoirs due to evaporation, and potential water releases from the reservoirs, include the 

following: 

• Groundwater monitoring, aquifer testing, and seepage control measures, 

• Construction of the reverse osmosis facility, and 

• Development of a water release system for the reservoirs. 

Aquifer tests and groundwater level monitoring would help ensure that the effects 

of the proposed water withdrawal for project facilities do not exceed the historical 

drawdown levels of about 130 feet near Desert Center. This amount of drawdown 

occurred in the 1980s during a period of much more intensive irrigation for agricultural 

fields near Desert Center which are now mostly abandoned. Nearer to the proposed 

reservoirs, the aquifer tests and seepage control measures will help insure that the 

seepage amounts do not raise groundwater levels and affect nearby infrastructure and 

users such as the CRA. The reverse osmosis system, which also includes evaporation 

ponds and other facilities, would address water quality degradation such as increased salt 

content caused by from high evaporation rates by removing salts and other particles. The 

water release procedures to emergency overflow structures on the reservoirs would 

ensure that following a rare high inflow event, excess water would be released in a 

manner that ensures that the nearby infrastructure and the CRA facility, located 

downgradient of the lower reservoir, would not be affected. 

Construction and operation of the proposed Eagle Mountain Project without 

adequate surface and especially groundwater quality and quantity protection measures 

could adversely affect the dry desert environment where water is a limited and valuable 

resource. On-site investigations, once access is possible, should help determine if acid 

production is likely to result by filling the existing mining pits with water for the 

proposed pumped storage project, which could affect water quality degradation in the 

reservoirs. The likelihood of acid production when the mineral deposits of the existing 

mining pits are exposed to water is very dependent on the characteristics of the ore 

deposits and reliable information is currently not available due to the lack of site access. 

While staff finds Eagle Crest’s proposed measures to be largely adequate, staff 

recommends additional monitoring and associated measures to limit extent of effects of 

the proposed project. Under the staff alternative, reservoir level monitoring would be 

implemented not only for operational compliance and safety issues, which would largely 

be covered under Part 12 of the Commission’s regulations for safety of water power 

projects and project works, but also to provide information on the extent of availability of 
261

and access to water in the lower reservoir for terrestrial resources as proposed to enhance 

the desert bighorn sheep native to the area. Similarly, staff recommends modifying the 

Eagle Creek channel to ensure that it is capable of conveying water from large storm 

events without affecting existing or proposed infrastructure. However, it is possible that 

once future access to the site is allowed and more detailed investigations and hydraulic 

calculations are possible, this measure may not be needed depending on the filing of the 

investigative report with the Commission.

As noted above, Eagle Crest proposes to install a reverse osmosis system to 

maintain the water quality of the reservoirs in the high evaporation desert environment to 

be similar to the quality of the groundwater used to fill and operate the project. Eagle 

Crest proposes to direct brine from the reverse osmosis system to evaporation and drying 

ponds where it would be removed, likely in 10-year intervals. While maintenance and 

monitoring of these ponds, including the installation of monitoring wells to help identify 

leaks, was proposed by Eagle Crest, additional monitoring should occur to allow for 

corrective action to occur sooner than under Eagle Crest’s proposal. Eagle Crest should 

file a brine pond-level monitoring plan to ensure that the ponds are not overfilled and that 

the water level fluctuations are representative of the evaporation rate. If water levels in a 

brine pond decrease faster than expected, it could be an indication of that the pond liner 

has failed and a leak has developed. In the area of the proposed brine ponds, the 

groundwater level is several hundreds of feet below the surface and Eagle Crest proposed 

monitoring wells would be placed in the groundwater to monitor for possible leakage of 

the brine ponds. Staff’s analysis indicated that brine leakage could take months or years 

to reach the groundwater table before it could be detected in the monitoring wells. 

Therefore, staff recommends that in addition to the planned conventional monitoring 

wells, Eagle Crest should investigate whether partially horizontal monitoring wells 

extending beneath the evaporation ponds could detect a change in water vapor (an 

indication of a likely leak in the brine ponds) much more rapidly than normal 

groundwater monitoring. Due to a depth to groundwater of several hundred feet below 

the surface, it could take many years for leakage from the brine ponds to be detectable in 

conventional groundwater monitoring wells.

Staff estimates that implementation of the water resources measures proposed by 

Eagle Crest would have an annualized cost of $5,042,910. The majority of this cost is 

due to the cost and operation of the reverse osmosis system which is a key component to 

maintain water quality in the proposed closed system in a very high evaporation 

environment. Staff estimates that the additional measures described above would 

increase the annualized cost of measures by $287,110. Considering the extent of limited 

water resources in the area, and the possible project effects on water resources, staff

considers the benefits and protection of water resources to be worth the costs.

Terrestrial Resources and Threatened and Endangered Species

Construction, operation, and maintenance of the proposed Eagle Mountain Project 

without adequate protection measures could adversely affect terrestrial resources. Eagle 
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Crest, as part of its license application, filed numerous monitoring and mitigation 

measures to protect the existing terrestrial resources. These proposals include measures 

to protect desert tortoises, including a Raven Monitoring and Control Plan and the 

purchase of 160 acres of land to compensate for desert tortoise habitat that would be 

disturbed during construction of the proposed project. Staff finds Eagle Crest’s proposed 

measures largely suitable for the proposed project; however, staff recommends several 

additions. 

The proposed pumped storage project would introduce water to the dry desert 

environment, potentially increasing suitable habitat for invasive plants. The applicant’s 

Invasive Species Monitoring and Control Plan includes monitoring and treatment of areas 

disturbed during project construction to reduce potential encroachment of invasive 

species. However, the operation of the project will increase soil moisture surrounding the 

project reservoirs and any water seepage areas, which could create suitable conditions for 

invasive weed establishment. To avoid potential increases of invasive weeds in these 

areas, we recommend modifying the proposed Invasive Species Monitoring and Control 

Plan to include the reservoir shorelines and areas near the proposed water supply wells. 

However, because soil conditions in the existing mine pits may not be conducive to 

vegetation establishment, staff only recommends initiating monitoring for invasive weeds 

in these areas once vegetation becomes established. 

Construction of the project transmission lines would create potential electrocution 

and collision hazards for raptors and other avian species in the Chuckwalla Valley. Eagle 

Crest’s proposed transmission line design plan would address potential effects of 

electrocution, but the proposed plan does not include measures to reduce potential for 

avian collisions with power lines, provide monitoring and reporting protocol to track 

avian–powerline interactions, or include a worker education program. Therefore, Eagle 

Crest should modify, in consultation with FWS, its proposed transmission line design 

plan to include an avian protection plan. This plan should (1) meet the APLIC/FWS 

guidelines for an avian protection plan; (2) present designs to reduce the potential for 

avian electrocution and collisions; (3) provide methods for surveying and reporting 

project-related raptor mortality and managing nesting on the proposed transmission lines; 

and (4) include a workers education program. 

Eagle Crest conducted surveys for the spadefoot toad in many areas near the 

project in 2009. However, as a result of site access limitation and modifications to the 

proposed project’s footprint, including staff-recommended transmission line route, not all 

areas were surveyed for the spadefoot toad. As a result, staff recommends preconstruction surveys for spadefoot toad in areas not previously surveyed and where 

project construction, operation and maintenance activities would occur. Staff also 

recommends the same protection measures for the spadefoot toad as proposed for the 

central project area.

Ravens are a known predator of the threatened desert tortoise. However, the 

proposed Raven Monitoring and Control Plan does not address other desert tortoise 
263

predators that may increase in numbers as a result of the construction and operation of the 

project. Therefore, staff recommends that Eagle Crest develop a desert tortoise predator 

control plan in addition to the proposed Raven Monitoring and Control Plan. This plan 

should: (1) include baseline and post-construction survey methods for other tortoise 

predators, including coyotes, wild dogs, and gulls; (2) include mitigation measures to be 

implemented if the number of predators increases; and (3) include a schedule that 

initiates post-construction surveys during the second year after project completion, 

followed by surveys once every 5 years. 

Eagle Crest proposes to purchase and conserve about 160 acres of desert tortoise 

habitat to compensate for project-related disturbance in Category I habitat (within the 

DWMA) and Category III (suitable habitat outside the DWMA) desert tortoise habitat. 

Development of this measure was based on the design of the proposed project and the 

NECO Plan guidelines for 1:1 Compensation in Category III habitat and 5:1 

compensation within DWMA. Specific compensation related to the staff alternative 

would depend on final project design and is expected to range between 6 acres (based on 

effects of the transmission line) and 375 acres (if Eagle Crest constructs the 

interconnection substation). To ensure the purchase of compensation lands is 

appropriately based on project effects, staff recommends Eagle Crest prepare a desert 

tortoise compensation plan following completion of final project design. The plan should 

identify acreage of project disturbance within Category I and Category III desert tortoise 

habitat and identify the proposed acreage and location of compensation lands. The plan 

should be prepared in consultation with FWS and BLM and filed with the Commission 

for approval.

Staff estimates that implementation of the terrestrial and threatened and 

endangered resources measures proposed by Eagle Crest would have an annualized cost 

of $204,060. Staff estimates that the additional measures that are described above would 

increase the annualized cost of measures by $8,310. Considering the possible project 

effects on these resources, staff considers the benefits and protection of terrestrial and 

threatened and endangered resources to be worth the costs.

Recreation, Land Use, and Aesthetics

Construction, operation, and maintenance of the proposed Eagle Mountain Project 

could adversely affect recreation, land use, and aesthetics in the project area. Likely 

effects include increased nighttime sky lighting, limits to some access routes, and

inundation of some of the remaining but currently non-economical ore reserves. Most of 

the effects, other than those from the proposed transmission lines and substation, would 

be similar to or lesser than effects that occurred during historic operation of the Eagle 

Mine. Construction and operation of the proposed project would be designed to occur 

within historical mining pits also proposed for landfill development. Eagle Crest’s 

proposal would be designed to co-exist with the proposed landfill if the two 

developments are constructed. In addition to designing the project to limit effects on the 

proposed landfill, Eagle Crest proposes measures to limit the effects of construction on 
264

recreation, land use and aesthetics by coordinating planned road closures and other 

schedules with the public. Other measures proposed by Eagle Crest including measures 

associated with lighting of the proposed central project area and construction measures 

throughout the proposed project, would also limit the effects of lighting on the 

surrounding environment and avoid some of the visual degradation during the 

construction of the transmission line and other proposed linear features of the project. 

Staff estimates that implementation of the recreation, land use, and aesthetics 

resources measures proposed by Eagle Crest would have an annualized cost of $17,140. 

Staff estimates that the additional measures that are described above would increase the 

annualized cost of measures by $804,010. This cost difference is largely the result of the 

incremental cost increase of staff’s recommended transmission route and substation, as 

compared with the applicant’s proposed route. Staff’s recommended route would protect

a wide range of resources, including terrestrial and threatened and endangered species, 

aesthetics, and cultural resources. Considering the possible project effects on these 

resources, staff considers the protection of these resources to be worth the costs.

Cultural Resources

Construction, operation, and maintenance of the proposed Eagle Mountain Project 

without adequate protection measures could adversely affect properties that are eligible 

for listing on the National Register. Eagle Crest filed an HPMP in September 2009 for 

the purpose of protecting and interpreting historic properties. The HPMP was revised in 

December 2009.

Staff finds that the HPMP adequately identifies the APE, describes the cultural 

resources inventories that were conducted within the APE, identifies potential 

disturbances to historic properties, and provides for the appropriate treatment of the CRA, 

Eagle Mountain mine and town site, and TCPs that may be identified in the future. The 

HPMP also provides procedures for handling unanticipated discoveries and the proper 

treatment of human remains and sacred objects, if they are encountered. However, staff’s

review of the HPMP reveals that the plan does not correctly identify the Eagle Mountain 

mine, town site, and associated railroad as a potential historic property that meets the age 

criteria for inclusion on the National Register and may be eligible for listing. 

Additionally, the HPMP does not provide for frequent enough reporting during 

construction and subsequent HPMP implementation reporting, and curation of 

archaeological materials that could be recovered during test or data recovery excavations 

that may become necessary. Further, although the HPMP does provide for cultural 

resources monitoring, it does not clearly specify the circumstances under which 

monitoring would be required or a means by which an appropriate Native American 

monitor would be determined. Further, it does not call for consultation with Native 

American tribes regarding employee training and public interpretation programs. Finally, 

because the 2009 HPMP was prepared prior to Eagle Crest’s July 2010 Supplemental 

Information filing, it does not discuss the additional APE that includes the State Water 
265

Board’s recommended transmission line corridor and substation location or the potential 

effects on historic properties. 

For these reasons, staff recommends that the HPMP be approved with the 

following additional modifications:

• Annual HPMP implementation reporting during and after construction;

• Curation of recovered archaeological materials;

• Specific criteria that would determine the need for cultural resources 

monitoring and a plan to identify appropriate Native American involvement;

• A plan to include interested Native American tribes in the development of staff 

training and public interpretation programs; 

• A detailed discussion of the expanded APE alternatives, including revised APE 

maps; 

• A description of the sites documented by Schaefer (2010) and located within 

the expanded APE; 

• Inclusion of a detailed plan and schedule for National Register evaluations, 

assessment of effects, and identification of measures to resolve adverse effects 

of project construction, operations and maintenance on any of the 39 sites 

identified within the specific Commission staff recommended transmission line 

corridor and substation location, including the appropriate consultation process 

with the participating tribes, BLM, and California SHPO; and

• Measures for handing newly discovered paleontological remains, and reporting 

such discoveries to BLM.

Implementation of the HPMP with staff’s additional measures would ensure that 

adverse effects on historic properties as a result of project operation and maintenance or 

other project-related activities would be addressed over the term of a license. Staff 

anticipates that any license issued for the project would include a condition to implement 

a PA executed among the Commission, the California SHPO, and the Advisory Council

on Historic Preservation, if the Council chooses to participate. Eagle Crest, BLM, and 

others would be invited to sign the PA as concurring parties. The PA would include a 

measure to implement the HPMP with staff’s additional measures.

Staff estimates that implementation of the protective measures proposed in Eagle 

Crest’s HPMP would have an annualized cost of $22,860. Staff estimates that the 

additional measures that are list above would increase the annualized cost of measures 

included in the HPMP by $6,200. Considering the extent of cultural heritage that is 

present in the project area, staff considers the benefits to cultural resources to be worth

the costs.
266

Socioeconomics

Under Eagle Crest’s proposal, project construction would provide about 100 jobs 

during the peak construction period and would provide revenues to county and local 

government through property, sales, and use taxes. Project operation would provide 

about 30 jobs, as well as substantial property tax payments. During both construction and 

operation, staff anticipates tax payments would more than compensate for any increase in 

the need for government services. No residences or businesses would be displaced due to 

construction and operation of the project. 

Air Quality and Noise

The vehicles and machinery used for the project construction would result in 

substantial amounts of emissions. However, most emissions are expected to remain 

below the state air quality levels except for Nitrogen Oxide. Eagle Crest proposes to 

consult with the Park Service to develop and implement a 2-year air monitoring study. 

Monitoring results would be used to adjust the construction workload if any air quality 

exceedances are observed during the later portions of the construction. During operation 

of the project, the annual offset of emissions by the proposed project is estimated at about

1,443,260 tons of CO2 as compared to a conventional fossil fueled peaking generation 

facility of the same size. 

Compliance with the applicable County noise ordinance codes during construction 

would minimize the effects of noise levels during construction. Eagle Crest’s proposed 

measures would lower the noise level during construction by equipping all construction 

equipment with properly operating and maintained noise mufflers and intake silencers, 

consistent with manufacturers’ standards. 

5.3 UNAVOIDABLE ADVERSE EFFECTS

Unavoidable adverse effects are those that cannot be reversed except in the 

extreme long term. Unavoidable adverse effects within the project area are the following: 

• About 1,700 acre-feet per year of the groundwater used to fill and maintain the 

reservoirs would evaporate. 

• Visual impacts of the project structures, especially the transmission line and 

substation, would be irreversible but would be limited by mitigation measures 

and the recommended route and location.

• Construction of the project would eliminate between 35 and 46 acres of 

currently undisturbed desert habitat.
267

5.4 CONSISTENCY WITH COMPREHENSIVE PLANS

Section 10(a)(2)(A) of the FPA, 16 U.S.C.§803(a)(2)(A), requires the Commission

to consider the extent to which a project is consistent with the federal or state 

comprehensive plans for improving, developing, or conserving a waterway or waterways

affected by the project. Staff reviewed 13 comprehensive plans that are applicable to the 

Eagle Mountain Project, located in California. No inconsistencies were found.

California

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California Department of Water Resources. 1994. California water plan update. Bulletin 

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California State Water Resources Control Board. 1995. Water quality control plan report. 

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U.S. Fish and Wildlife Service. Canadian Wildlife Service. 1986. North American 

waterfowl management plan. Department of the Interior. Environment Canada. 

May 1986.
268

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269

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California. ASM Affiliates, Carlsbad, CA. (not seen, as cited by Schaefer, 2010, 

2009)

Youd, T.L. and D.M. Perkins. 1978. Mapping liquefaction induced ground failure 

potential. Journal of the Geotechnical Engineering Division 104(4):433–446 pp. 

American Society of Civil Engineers.
279

7.0 LIST OF PREPARERS

Federal Energy Regulatory Commission

Ken Hogan—FERC Project Coordinator; Fisheries Resources, Socioeconomics, Air 

Quality, Developmental Analysis (Fishery Biologist; B.T., Fisheries Management 

and Aquaculture)

Mary Greene—Recreation, Land Use, and Aesthetics (Environmental Biologist; B.S., 

Biology) 

Joe Hassell—Need for Power, Geomorphology, Hydrology, Water Quantity and Quality, 

Groundwater, Engineering and Developmental Analysis (Environmental Engineer; 

B.S. and M.S., Agricultural Engineering)

Shana Murray—Recreation, Land Use, and Aesthetics (Outdoor Recreation Planner;

M.S., Recreation, Park, and Tourism Management)

Carolyn Templeton—Geology and Soil Resources/Geomorphology, Terrestrial 

Resources and Threatened and Endangered Species, (Environmental Biologist; 

B.S., Biology; M.S., GeoEnvironmental Science)

Frank Winchell—Cultural Resources (Archeologist; B.A., M.A., Ph.D., Anthropology)

Louis Berger Group

John Hart—Task Manager; Hydrology, and Noise (Hydrologist; B.A., Physics)

Ellen Hall—Senior Technical Review; Socioeconomic Resources (Environmental 

Planner/Resource Economist; Ph.D., Resource Economics; M.Ag., Agricultural 

Economics; B.A., History/Economics)

James Hamski—Water Resources (Hydrologist; B.S., Environmental Science)

Kenneth Hodge—Need for Power, Engineering, and Developmental Analysis (Senior 

Engineer; B.S., Civil Engineering)

Coreen Johnson—Editorial Review (Technical Editor; B.A., English/Education) 

Alison Macdougall—Cultural Resources (Senior Environmental Manager; B.A., 

Anthropology)

George Perng—Air Quality (M.S., Environmental Engineering; B.S., Civil and 

Environmental Engineering)

Tyler Rychener—Fisheries, Terrestrial, Threatened and Endangered Species 

(Environmental Scientist/GIS; M.S., Plant Biology; B.S., Biology)

Denise Short—Noise (Technical Editor; M.S., Agriculture, Food, and the Environment; 

B.A., English)
280

Jot Splenda—Senior Review of Water Quality; Recreation, Land Use, and Aesthetics

(Environmental Planner; M.E.S.M, Water Resource Management; B.S., Ecology 

and Evolution)

Subcontractor Staff

Stillwater Sciences

Glen Leverich—Geology and Soils/Geomorphology (Geologist/Geomorphologist; M.S., 

Geology; B.S., Environmental Studies)
281

8.0 LIST OF RECIPIENTS

Eagle Crest Energy Company

3000 Ocean Park BLVD, Suite #1020

Santa Monica, CA 90405

Terry L. Cook

Kaiser Ventures, LLC

3633 Inland Empire Blvd, Suite 480

Ontario, CA 91764

California Department of Water Resources 

Division of Safety of Dams

P.O. Box 942836

Sacramento, CA 94236

Kristine Wilson

Attorney at Law

Perkins Coie LLP

10885 NE 4th Ave., Suite 700

Bellevue, WA 98004

California Office of Planning & Research 

CA Planning & Research Office

P.O. Box 3044

Sacramento, CA 95812 

Peter VonHaam

Sr. Dep. Gen. Counsel

Metropolitan Water District of Southern 

California

P.O. Box 54153

Los Angeles, CA 90054-0153

Donna Charpied

Executive Director

Citizens for the Chuckwalla Valley

P.O. Box 397

Desert Center, CA 92239-0397

Matthew D Hacker

P.O. Box 54153

Los Angeles, CA 90054-0153

Robert Perdue

Executive Officer

Colorado River Regional Water Quality 

Control Board

73-720 Fred Waring Drive, Suite 100

Palm Desert, CA 92260

Matthew Bullock

Office of Chief Counsel

State Water Resources Control Board 

P.O. Box 2000

Sacramento, CA 95812

Daniel Hyde

Lewis, Brisbois Bisgaard & Smith, LLP

221 N Figueroa St, Suite 1200

Los Angeles, CA 90012-2639

Paul Murphey

Division of Water Rights

State Water Resources Control Board 

P.O. Box 2000

Sacramento, CA 95812
282

Stephen Maguin

Chief Engineer & Gen. Manager

County Sanitation District No. 2 of Los 

Angeles County

P.O. Box 4998

Whittier, CA 90607

Jennifer Watts

Environmental Scientist

California State Water Resources Control 

Board

1001 I Street

Sacramento, CA 95814

Kimberly A Huangfu

County Sanitation Districts of Los Angeles 

County, CA

P.O. Box 4998

Whittier, CA 90607

Dramy Saechao

Hearings and Special Programs

State Water Resources Control Board 

1001 I Street

Sacramento, CA 95814

Donald Clarke, Partner

GKRSE Law

1500 K Street NW, Suite 330

Washington, DC 20005

Nathan Jacobsen

Staff Counsel

State Water Resources Control Board

1001 I Street, 22nd Floor

Sacramento, CA 95814

Markham Quehrn

Attorney

Perkins Coie LLP

10885 N.E. Fourth St., Suite 700

Bellevue, WA 98004-5579

Randy C. Baysinger

Assistant General Manager

Turlock Irrigation District

P.O. Box 949

Turlock, CA 95381-0949

Alexis Strauss

Director, Water Division

U.S. Environmental Protection Agency

75 Hawthorne Street

San Francisco, CA 94105

John R. Kalish, Field Manager

U.S. Department of the Interior

Bureau of Land Management

1201 Bird Center Drive

Palm Springs, CA 92262-8001

FERC Contact

California Fish & Game Commission

Attn: Environmental Services Division

1416 9th Street

Sacramento, CA 95814-5511

Cherilyn E. Widell

State Historic Preservation Officer

California Office of Historic Preservation

1416 9th Street

Sacramento, CA 95814

CA Planning & Research Office

P.O. Box 3044

Sacramento, CA 95812

Michael Tsosie

Colorado River Indian Reservation

26600 Mojave Road

Parker, AZ 85344
283

Water Users Association

P.O. Box 31

El Nido, CA 95317

Governor of California

RE: FERC Projects

Office of the Governor of California

State Capitol Building

Sacramento, CA 95814

County Clerk

County of Siskiyou

510 N Main Street

Yreka, CA 96097-2525

Senior Environmental Scientist

Water Resources Control Board

1001 I St

Sacramento, CA 95814

Commander, U.S. Army Corps of Engineers

San Francisco District Office

1455 Market St, #1760

San Francisco, CA 94103

Metropolitan Water District 

P.O. Box 54153

Los Angeles, CA 90054

Spindale Top Bayou Farm Inc. 

P.O. Box 642

Brenham, TX 77834

North Star Capital Development

6382 Klamath Drive

Westminster, CA 92683

Warren and Joanne Dean

92 Rio Vista

Solvang, CA 93463

Om Garg

39 Hidden Tr

Irvine, CA 92603

Benjamin and Laura Hugo

and Hector and Maria Centalana

12928 Ocaso Ave

La Mirada, CA 90638

Richard Vlowers 

31722 Railroad Canyon Rd

Canyon Lake, CA 92587

Hope Halkum and Eleanor Mortenson

3539 S. Carolina Street

San Pedro, CA 90731

Fernando and Juanita Gonzalez

82290 Ocotillo Avenue

Indio, CA 92201

Riverside Jejoba Income Corporation

103 N. Lake Drive

Ormond Beach, FL 32174

Eagle Crest Mg. Company

74199 El Paseo, No. 204

Palm Desert, CA 92260

John and Joseph Draskobisch

2201 Whyte Park Ave

Walnut Creek, CA 94595

Catherine and Philip Hu

5215 E. Chapman Ave, No. 45

Orange, CA 92869
284

Patricia Sanderson Port

U.S. Department of the Interior

Office of Environmental Policy and 

Compliance

1111 Jackson Street, Suite 520

Oakland, CA 94607

Douglas S. McPherson

U.S. Department of the Interior, Bureau of 

Reclamation

27708 Jefferson Ave, Suite 202

Temeccula, CA 92590-2628

Brendan Hughes

61093 Prescott Trail

Joshua Tree, CA 92252

Curt Sauer, Superintendent

Joshua Tree National Park

74485 National Park Drive

Twentynine Palms, CA 92277-3597

Mike Cipra

California Desert Program Manager

National Parks Conservation Association

61325 29 Palms Highway, Suite B

Joshua Tree, CA 92252