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National Parks Conservation Association-CBD Et Al Cadiz DEIR Comment Letter 3-13-12 FINAL

National Parks Conservation Association-CBD Et Al Cadiz DEIR Comment Letter 3-13-12 FINAL

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Published by highcountrynews
Comments on the Cadiz Draft Environmental Impact Report from National Parks Conservation Association and other conservation groups.
Comments on the Cadiz Draft Environmental Impact Report from National Parks Conservation Association and other conservation groups.

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Published by: highcountrynews on Mar 23, 2012
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Comments on Cadiz Water Project 2011 DEIR Page 1
VIA email and FedEx
March 13, 2012Tom BarnesESA626 Wilshire Boulevard, Ste. 1100Los Angeles, CA 90017FAX: 213-599-4301Email:cadizproject@esassoc.com 
RE: Comments on the Cadiz Valley Water Conservation, Recovery, and Storage ProjectDraft Environmental Impact Report State Clearinghouse #2011031002Submitted on behalf of:Center for Biological Diversity:National Parks Conservation AssociationCalifornia Wilderness CoalitionSan Bernardino Valley Audubon SocietySierra Club Desert CommitteeMojave Desert Land TrustSierra ClubMorongo Basin Conservation AssociationDefenders of WildlifeDesert Tortoise CouncilSierra Club Desert Committee, San Gorgonio Chapter, and National OrganizationSouthern California Watershed AllianceDesal Response GroupDesert Survivors
Comments on Cadiz Water Project 2011 DEIR Page 2Dear Mr. Barnes:On behalf of the Center for Biological Diversity (“CBD”), the National ParksConservation Association (“NPCA”), the California Wilderness Coalition (CWC), SanBernardino Valley Audubon Society, Sierra Club Desert Committee, the Mojave Desert LandTrust, the Morongo Basin Conservation Association, Defenders of Wildlife, the Desert TortoiseCouncil, the San Gorgonio Chapter of the Sierra Club,
Southern California Watershed Alliance,Desal Response Group and Desert Survivors, we appreciate and welcome the opportunity tocomment on the Cadiz Valley Water Conservation, Recovery, and Storage Project (“Cadiz WaterProject,” “Proposed Project” or “Project”) Draft Environmental Impact Report (“DEIR”).For the reasons set forth below, commenters request that a new DEIR be prepared for theProposed Project under the lead agency of San Bernardino County. Also, the right-of-way(“ROW”) for the Proposed Project requires Bureau of Land Management (“BLM”) approval, andthe Proposed Project, therefore, requires full review under the National Environmental PolicyAct (“NEPA”), 42 U.S.C. section 4321
et seq.
We urge the appropriate state agencies tocoordinate with the appropriate federal agencies to prepare a joint EIR/DEIS for the ProposedProject that complies with both state and federal law.NPCA is a non-profit organization whose mission is to protect and enhance America’snational parks for present and future generations. NPCA has 450,000 members nationwide andover 45,000 California members, and works with elected officials, the media, and communitiesto foster stewardship of our national treasures. NPCA has three offices in the Mojave Desert:Joshua Tree, Barstow, and Las Vegas.The Center for Biological Diversity (“CBD”) is a national, nonprofit conservationorganization with more than 320,000 members and online activists dedicated to protectingendangered species and wild places. Due to the proposed project’s significant impacts to desertsand to the development of suburban sprawl, CBD has followed the proposed project closely in itsvarious iterations through the years, and has utilized its staff biologist to review the relevantimpacts on plants and wildlife.The California Wilderness Coalition (“CWC”) protects the natural landscapes that makeCalifornia unique, providing clean air and water, a home to wildlife, and a place for recreationand spiritual renewal. With 3,000 members, CWC is the only organization dedicated toprotecting and restoring California's wild places and native biodiversity on a statewide level.Since 1976, we have empowered local communities and conservationists to be the voice for wildCalifornia.The San Bernardino Valley Audubon Society (SBVAS) is a chapter of the NationalAudubon Society, which has about half a million members nationwide. The chapter itself hasapproximately 1800 members who reside in the inland empire. Audubon members regularlyvisit the Mojave desert for birdwatching, photography, and the appreciation of nature.The Sierra Club is a national nonprofit organization of approximately 1.3 millionmembers and supporters dedicated to exploring, enjoying, and protecting the wild places of the
Comments on Cadiz Water Project 2011 DEIR Page 3earth; to practicing and promoting the responsible use of the earth’s ecosystems and resources; toeducating and enlisting humanity to protect and restore the quality of the natural and humanenvironment; and to using all lawful means to carry out these objectives. Sierra Club’s DesertCommittee includes members that focus on conservation of deserts of the southwest, includingCalifornia. The San Gorgonio chapter focuses on conservation issues throughout SanBernardino County, California.Mojave Desert Land Trust conserves land with important biological, cultural and scenicvalues. Our work helps to secure the biodiversity, beauty, and integrity of healthy desertecosystems for future generations to enjoy. We have 1,300 land trust members, and as a majorlandowner in the California desert, we have acquired more than 37,000 acres of important deserthabitat through acquisition, restoration, land stewardship and strategic partnerships with stateand federal agencies.The Morongo Basin Conservation Association (MBCA) advocates for a healthy desertenvironment that nurtures our rural character, cultural wealth, and economic well-being. Wehave over 400 members and supporters
Defenders of Wildlife (“Defenders”)
is a national environmental organization with 1.1million members and supporters in the U.S., including 109,000 in California. Defenders isdedicated to protecting all wild animals and plants in their natural communities. To this end,Defenders employs science, public education and participation, media, legislative advocacy,litigation and proactive on-the-ground solutions in order to prevent the extinction of species,associated loss of biological diversity, and habitat alteration and destruction.
The Desert Tortoise Council is a private, non-profit organization comprised of hundreds of professionals and laypersons who share a common concern for wild desert tortoises and acommitment to advancing the public’s understanding of this species. Established in 1976 topromote conservation of tortoises in the deserts of the southwestern United States and Mexico,the Council regularly provides information to individuals, organizations and regulatory agencieson matters potentially affecting the desert tortoise within its historical range.The Southern California Watershed Alliance works on steelhead restoration, damremoval, and jobs through water conservation programs with community based-organizationsthroughout the Southern CA Bight, from Point Conception to southern point south of Ensenada,Baja CA, Mexico.The Desal Response Group works on the environmental response to ocean waterdesalination proposals in CA and northern Baja California by promoting the alternative portfolioof water reclamation, onsite water reuse, serious water demand programs, stormwater and urbanrunoff capture and treatment, rainwater catchment, and greywater.Desert Survivors is a non-profit organization with the mission of experiencing, sharingand protecting desert wilderness. Recognizing that the places they love to explore will notremain wild unless they give others the opportunity to experience them, Desert Survivors iscommitted to actively monitoring and preserving desert wilderness. In addition to its advocacy

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