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Border 2012

I. Introduction

A draft environmental assessment (EA) and draft finding of no significant impact (FNSI) were prepared for the Parallel Conveyance System Project in Tijuana, Mexico, by the U.S. Environmental Protection Agency (EPA), Region 9. Interested agencies and the public were invited to submit comments on the draft EA and FNSI during the 30-day public comment period that ended October 27, 1997. (As required by law, the EPA did not take administrative action on this project during the comment period.) Ten comment letters were received on the project. The final EA consists of the previously published draft EA along with this document, which includes copies of the comment letters received and the EPA's responses to the comments in those letters.

II. Comment Letters Received

The EPA received ten comment letters on the draft EA, from the following nine agencies and organizations:

III. The EPA's Response to Comments Comments have been marked and numbered on the letters.

The EPA's responses, presented below, are keyed to the numbers assigned to the comments. In revised statements deletions are shown in brackets (like [this]) and additions are shown in underline (like this).

SD-1: The comment expresses the City of San Diego's support for the project.

TJVCWD-1: The comment expresses the support of the Tia Juana Valley County Water District for the project and the district's agreement with the EPA decision to issue a FNSI for the project.

TJVCWD-2: The name of the water district appeared incorrectly as "Tijuana Valley County Water District" throughout the draft EA. The correct spelling of the water district is noted as "Tia Juana Valley County Water District."

OHP-1: The Parallel Conveyance System Project is not associated with the International Wastewater Treatment Plant. The proposed project is an independent undertaking of the State Public Services Commission of Tijuana, Mexico (or CESPT, in its Spanish acronym).

IBWC-1 and IBWC-2: The CESPT EA and CESPT's application to the Border Environmental Cooperation Commission (BECC) for this project state that the existing conveyance facilities, especially the pumping plant, often operate at maximum capacity. Despite the diversion of flows mentioned in the comment letter, it is possible during a typical daily cycle for the existing systems to operate at maximum capacity. Also, the emergency connection is not continuously available; for example, in September 1997, the connection was temporarily closed. However, the EPA lacks specific data on the daily operating levels of Tijuana's conveyance facilities. For this reason, the following sentences in the draft EA are revised as follows:

"The existing system currently [operates at maximum capacity] lacks redundancy, and must, therefore, be operated continuously." (Page 1, second paragraph.)

"During a typical daily cycle, t[T]he present production of wastewater (37 million gallons per day, MGD) [exceeds both the existing conveyance system's capacity] requires the conveyance system to operate continuously, and at times, at maximum capacity (nominal capacity of 35 MGD) [and the San Antonio de los Buenos treatment plant's capacity (nominal capacity 17 MGD). Operating continuously at maximum capacity] Continuous operation of the system, due to its lack of redundancy, has necessitated a postponement of maintenance activities...." (Page 3, first paragraph.)

IBWC-3: The year column was mistakenly omitted from Table 1.1 in the draft EA. The first row of values in the table corresponds to the year 1995; the second row, to the year 1996; the third row, to the year 1997; the fourth row, to the year 1998; the fifth row, to the year 1999; the sixth row, to the year 2000; the seventh row, to the year 2001; the eighth row, to the year 2002; the ninth row, to the year 2003; the tenth row, to the year 2004; and the last row, to the year 2005.

Also, the first sentence on page 5 is revised as follows: "Based on the flow estimates provided by CESPT (Table 1.1), untreated flow at Punta Bandera will be 3 MGD in 1999, 6 7 MGD in 2000, and 11 MGD in 2001."

IBWC-4: The sentence is revised as follows: "Together IWTP and SBOO will treat and discharge 50 25 MGD of Tijuana's wastewater."

IBWC-5: The sentence is revised as follows: "The anticipated wastewater flow in Tijuana's wastewater conveyance system in 1999 is 45 MGD."

IBWC-6: The sentence is revised as follows: "Chapter 4's discussion of these resources addresses the following key issues:...."

IBWC-7: The sentence is revised as follows: "The impacts of these collectors [was] were analyzed in the FEIS for the IWTP (IBWC 1994)."

IBWC-8: The EPA believes, and CESPT's application for the project to the BECC implies, that the proposed project will not be implemented in the near future without financial assistance from the U.S. The sentence is revised as follows: "...the current situation would continue, as the parallel conveyance line and the improvements at San Antonio de los Buenos [cannot] would not occur in the near future without BEIF support."

IBWC-9: The sentence is revised as follows: "The primary use of the parallel conveyance line and pumping [pump] plant is as a backup for the existing conveyance system."

IBWC-10: See our response to IBWC-8, above. The sentence is revised as follows: "...neither the construction of the conveyance system nor the improvements to the San Antonio de los Buenos wastewater treatment plant would occur in the near future."

IBWC-11: The sentence is revised as follows: "...the SAB plant would treat 25 MGD since the completion of the expansion is anticipated in September 1998...."

IBWC-12: The sentence is revised as follows: "However, the possible interim use of the parallel conveyance system and the rehabilitated SAB plant would substitute 7 MGD of advanced primary chlorinated effluent from IWTP and 8 MGD of treated effluent from the rehabilitated SAB plant for the 15 MGD of raw sewage discharged under the no action alternative and delay of the SBOO beyond May 1999."

IBWC-13: The sentence is revised as follows: "Existing conditions reflect the environmental effects [Bandera] to the Pacific Ocean of current discharges at Punta Bandera."

IBWC-14: The sentence and the one before it are combined and changed to read as follows: "If SBOO is delayed, between 11 MGD and 15 MGD of raw sewage could be discharged at Punta Bandera in 1998 and 1999. [Under the no action alternative, the discharge at Punta Bandera will be 18 MGD of raw sewage and] along with 17 MGD of effluent from the unimproved SAB plant."

IBWC-15: The sentence is revised as follows: "...the SAB plant's effluent would comply with CNA [Mexico]'s standards for coastal water discharges (shown in Table 4.3)."

IBWC-16: The sentence is revised as follows: "...the need to [measure] monitor the influent and effluent at SAB for a wide range of parameters...."

IBWC-17: Whenever standards differed under the three sets of Mexican standards for coastal waters in NOM-001-ECOL-1996, the lowest permissible standards were chosen for Table 4.3. This was done so the analysis of the project's potential environmental impacts would be as sensitive as possible.

Several column headings in Table 4.3 are incorrect. The headings for the Mexico coastal waters standards are revised as follows: "Daily Average" is changed to "Monthly Average" and "Instantaneous Maximum" is changed to "Daily Average." The headings for the IWTP effluent standards are revised as follows: "Daily Average" is changed to "Monthly Average" and "Instantaneous Maximum" is changed to "Daily Maximum." Also, it should have been specified in the table that the units for settleable solids are milliliters per liter (ml/l).

IBWC-18: The sentence is revised as follows: "IWTP would discharge its effluent to the parallel system only to avoid discharge to the Tijuana River only if SBOO is substantially delayed."

IBWC-19: The sentence is revised as follows: "The possible interim use of the parallel system and rehabilitated SAB plant would replace the raw sewage flows of 15 MGD in 1999 with 7 MGD of IWTP advanced primary effluent and 8 MGD of expanded SAB treated effluent..."

IBWC-20: The analysis done on the basis of standards shown in Table 4.3 does not need to be revised according to our response to IBWC-17. The sentence is only revised as follows: "...therefore, the IWTP effluent would not satisfy [CNA's ocean discharge] Mexico's coastal waters standards for Biochemical Oxygen Demand (BOD) and Total Suspended Solids (TSS) as shown in Table 4.3."

IBWC-21: The sentence is revised as follows: "[If] Whether or not the 7 MGD of IWTP's effluent was [not] chlorinated before being discharged at Punta Bandera, the potential of the total discharge at Punta Bandera for exceeding coliform standards in the U.S. would decrease relative to the no action alternative; however, the potential would increase relative to the primary use discharge scenario for the same year because the [flow] total discharge at Punta Bandera would be higher under the interim use alternative."

IBWC-22: Comparing the potential for the exceedance of coliform standards under the two options is warranted because under the possible interim use option the flow discharged at Punta Bandera in 1999 would be 7 MGD higher than under the primary use option.

IBWC-1(ad): The comment states that, in general, the IBWC finds the draft EA to be satisfactory.

IBWC-2(ad): The comment has been withdrawn at the request of the IBWC.

CARE-1: The comment expresses the support of Citizens Against Recreational Eviction for the project.

FWS-1: In its comment letter FWS pointed out that the project could impact gnatcatchers in the U.S. by disturbing coastal sage scrub habitat across the border in Mexico that may be suitable for their use. A survey of the project right-of-way by the IBWC determined that the project would disturb approximately 4.8 acres of coastal sage scrub habitat, ranging from marginal to good quality. The acreage is located in Mexico, immediately across the border from Goat Canyon and Smuggler Gulch, and is made up of four unconnected strips ranging in length from 400' to 2000' and in width from 10' to 60'. It should also be noted that these areas are located along a busy four-lane road and have previously been disturbed during earlier construction projects.

The EPA will make funds available to the FWS's San Diego National Wildlife Refuge for the purchase of 5 acres of coastal sage scrub habitat in San Diego County that are occupied, or suitable for occupation, by the California gnatcatcher to become part of the Refuge's Otay Sweetwater Unit. The San Diego Refuge will result in the protection of coastal sage scrub with long-term conservation value and management.

GEG-1: CESPT, not the EPA, is the sponsor of the proposed project. Relocation or modification of the pumping station at Parque México de Playas de Tijuana is outside the scope of the Parallel Conveyance System Project that has been proposed by CESPT. The comment does not address the proposed project or the FNSI issued by the EPA.

CILA-1: The comment expresses (in the original Spanish and its English translation) CILA's agreement with the EPA's decision to issue a FNSI for the project instead of preparing an environmental impact statement.

PHS-1: The EPA agrees with the comment that the project alone will not "safeguard the public health, environment, public's recreation, water quality and economy of the San Diego area," as stated in the EA. This worthwhile goal will require a combination of means in addition to the project being proposed. This is implied in other sections of the EA, as the comment letter acknowledges.

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