Aspen Supports Banning To Upgrade Water System
Continuing our long-term project life cycle services to water and infrastructure agencies, Aspen is supporting the Banning Heights Mutual Water Company (BHMWC) and the City of Banning to obtain US Forest Service approval to upgrade and operate a historic Southern California Edison (SCE) water conveyance system. The system is critical to the two users because it delivers all BHMWC’s water supply and much of the City’s supply.
Aspen’s services include biological resources surveys and hydrology studies in the tributary streams where the conveyance system originates. In addition, Aspen has provided extensive support to our two clients during coordination with SCE, the San Bernardino National Forest (SBNF), and the Federal Energy Regulatory Commission (FERC), to complete an ownership transfer and necessary permitting for the system. The permitting tasks are especially complex because of multiple federal regulators and permittees, as well as historic right-of-way (ROW) grants and water rights.
This water conveyance system originated in 1913 or earlier, when it went into service to provide needed water supply. Beginning in 1923, hydroelectric power generation was added as a second use. There are several historic ROW grants applicable to parts of the water conveyance and hydroelectric facilities. As an electric power generator, the system has operated under license issued to SCE by FERC. The system is no longer generating electricity, and SCE plans to surrender its FERC license, make repairs and upgrades, then transfer ownership to the City, BHMWC, and the San Gorgonio Pass Water Agency (SGPWA).
Parts of the system are located on National Forest lands. Therefore, the FERC license surrender and ownership transfer hinge on the City obtaining an SBNF Special Use Permit (SUP) for those components. To issue the SUP, the SBNF must review discretionary aspects of the upgrades and long-term O&M according to the National Environmental Policy Act (NEPA). This NEPA analysis will overlap in part, but not completely, with a NEPA Environmental Assessment already prepared by FERC, reviewing SCE’s license surrender application. In light of the project’s long history and two-fold use for water conveyance and hydroelectric generation, clarifying the nature and extent of regulatory responsibilities and NEPA requirements has been challenging for all parties.
Aspen has been coordinating among three water agencies: the SBNF, SCE, and FERC to identify the best path to obtaining the required SUP. In addition to the SBNF NEPA review, Aspen is working with the City to complete CEQA review, and coordinating with SCE to complete Army Corps of Engineers, California Department of Fish and Wildlife, and Regional Water Quality Control Board permitting. Aspen’s team is working with the BHMWC and the City to ensure “right-size” NEPA and CEQA analysis by making the best use of the existing FERC and SCE documents. In addition, Aspen is working with its clients to ensure full consideration of the established water rights and right-of-way grants during environmental review.