"They use a curious set of assumptions of inflows into the Salton Sea," he said, adding the study also shows the Salton Sea degrading much more quickly than anybody else says. "Once you start with that, a lot of their projections are distorted."
Pacific Institute's 18-page comments are in response to the draft EIR.
Hearings on IID's and San Diego's petition for state approval of the transfer are under way in Sacramento and expected to last through the end of the month.
The Pacific Institute recommends the transfer proceed on an interim basis along the lines of the plan proposed by the Imperial County Farm Bureau, a water conservation plan that includes temporary fallowing, but avoids debt, allocation to the gate, long-term contracts and incentives to farm less. The plan was made public in March.
"Such temporary fallowing would limit impacts to the Salton Sea while addressing farmers' need for financial predictability," the Pacific Institute says. "This interim fallowing period would provide time for the development and implementation of long-term habitat preservation and dust-abatement plans for the Salton Sea, and a plan to reduce the concentration of selenium in drainage waters."
The 18 pages of comments goes on to say the interim basis of the transfer would end Dec. 31, 2007, by which time if the long-term habitat preservation and dust-abatement plans are not in place and funded, the transfer would be terminated.
The Pacific Institute's comments also touch on the DEIR's process and scope, hydrology and water quality, habitat conservation plan, biological resources, land use, air quality, socioeconomics and social justice.
Regarding the latter two issues, Pacific Institutes recommends there be a detailed, referenced description of the range of socioeconomic and environmental impacts, including health impacts resulting from increased selenium levels and increased fugitive dust emissions that would be borne by the disproportionately poor and minority populations within the IID water service area and All-American Canal subregion.
The deadline to submit comments on the DEIR was last week.
Elston Grubaugh, IID planning and resources department manager, said there have been about 115 written comments submitted.
"Most of them are fairly extensive," he said, adding the next step is to respond to the comments, either through an errata sheet if they are minor or, if significant changes to the DEIR are required, through a modified and reissued draft document.
Grubaugh said the intention is to present a final EIR to the IID board for its possible certification May 30 for California Environmental Quality Act purposes, and to IID and the Department of the Interior for National Environmental Policy Act purposes, some time after that.
>>Staff Writer Rudy Yniguez can be reached at 337-3440.