LUCERNE VALLEY ECONOMIC DEVELOPMENT ASSOCIATION (LVEDA)

To: Greg Thomsen – BLM (LucerneSolar@BLM.gov)

Ralph Hollenbacher – Chevron (Rhollenbacher@chevron.com)

Re: Scoping - Chevron Energy Solutions – Lucerne Valley Solar Project.

From: Chuck Bell, Sec.

P. O. Box 193

Lucerne Valley, CA 92356 760 964 3118

Date: 8/3/09

LVEDA’s Mission Statement:

Provide a forum for discussion and action on important community issues – promote infrastructure improvements – work with County and developers to promote development that is both “economic” and compatible with our rural lifestyle, environment and resource availability.

Appreciate the scoping session - hopefully productive for BLM and Chevron. Although this PV project is a relatively small “utility scale” proposal – and adjacent to a transmission line that can apparently accommodate the voltage - we will not take a position until the environmental process is complete.

GENERAL COMMENTS:

In order not to get the “cart before the horse” - this project should be assessed via BLM’s Programmatic process which will identify the limited areas available and suitable for solar plants - quantifying the amount of acreage/sq. miles and alignments dedicated to all the land-uses that we already provide s. Calif. - to fully understand why we need a "Solar Energy Siting Element" to our current BLM and County Plans

Lucerne Valley could well be surrounded by the following projects: LADWP’s GPN transmission line – Granite Mt. Wind – Fry Mt. Wind – the proposed Cannon Solar PV – SCE’s solar PV – Chevron’s project - etc. etc.

Granted, we have wind and sun which should be shared with our countrymen.  But we also have the Mojave Desert which is a treasure unto itself - which cannot be consumed for the benefit of the urban coastal basin.  Lucerne Valley provides that megalopolis with limestone, cement, aggregate (with its incessant truck traffic and no sales tax revenue for us since these raw materials are “wholesale” – providing sales tax only for other jurisdictions when converted to final products), recreation (particularly the resource-consumptive and largest OHV open areas in the nation), power line/pipeline corridors, tremendous amounts of acreage designated for expanding military bases, public open space, immense areas set-aside for habitat protection, etc. etc. 

As alternatives to large-scale renewable facilities on public land, this project’s analysis should include a quantitative assessment of the megawatts of solar power that could potentially be generated within the urban areas of demand (ie: roof top and parking lot systems) prior to any further commitment of public land resources to subsidize urban areas.

Use of BLM land should not displace private sector opportunities – with the cheaper use of gov. land competing w/solar plant options on private land (ie: tremendous amounts of fallowed agricultural and disturbed parcels in s. Cal. counties that cannot otherwise be developed due to water and other restrictions) - allowing landowners to make the best use of their properties – in turn providing local jurisdictions with more property tax revenue.

We also have to deal with the dilemma; "where and how do we mitigate the impacts of all these proposed projects?"

Utilities, PUC and the renewable industry need to devise means to reward communities that will bear the burden of all these solar/wind plants – and in turn provide incentives for acceptance (ie reduced elec. rates, etc). Minimal local employment, minor amounts of property taxes and the occasional donation to some community organization do not provide adequate compensation. Even a program ensuring the County receives any sales tax revenue does not substantially benefit the affected community.

SPECIFIC COMMENTS

The EIS needs to assess and mitigate the following:

If even two of these proposed projects start construction at the same time – related traffic through town will become a major impact that must be mitigated.

De-brushing/grading will create a long-term dust source, adversely affecting the facility and down-wind receptors. Minimal grading, vegetation mowing and placement of decomposed granite or small gravel will help to stabilize the site and reduce weed infestations – as well as enhancing native re-vegetation if and when facilities are removed.

Santa Fe Fire Rd. should be paved or at least graveled – benefit to local residents and eliminating a dust source.

A right-turn lane on Hwy 247 would provide safer egress in this area of high-speed traffic – especially for the construction phase.

Project’s effect on surrounding private land values.

Include the total project’s phases in the analysis – not just Phase 1.

The cost/benefit of power produced vs. from all other sources.

The existing transmission line’s available capacity – ultimate requirement for upgrading.

Net transmission loss through said line.

Impact on Mojave Water Agency’s Morongo Pipeline.

Effect on a possible future “historic/scenic” designation for Hwy 247 (Old Woman Springs Rd.)

Bonding requirements for site reclamation/restoration.

Cumulative impacts (environmental, socio-economic, traffic, visual, etc.) from this and all other proposed projects proposed for the Lucerne Valley/Johnson Valley region – (ie: LADWP’s GPN transmission line, Granite Mt. Wind, Fry Mt. Wind, Edison Solar, Cannon Solar, 29 Palms Marine Base expansion, etc.).