LUCERNE VALLEY ECONOMIC DEVELOPMENT ASSOCIATION (LVEDA)

 

To:       Greg Thomsen – BLM   (lucernesolar@blm.gov)

 

Re:      Comments – DEIS - Chevron Energy Solutions – Lucerne Valley Solar 

 

From:  Chuck Bell, Pres.   (chuckb@sisp.net)

            P. O. Box 193

            Lucerne Valley, CA  92356              760 964 3118

 

Date:   5/27/10

 

(Please also incorporate by reference our previous scoping comments)

 

 

GENERAL

 

LVEDA provides an “open forum” dealing with major projects and issues affecting/benefiting Lucerne Valley – therefore is not taking a direct “pro or con” position on this project.  However we are in general opposition to utility-scale solar projects – especially on public land – preferring the use of pre-disturbed/fallowed private land – but as a first priority – solar panels on rooftops/parking lots/etc. throughout s. Calif. (which the DEIS failed to analyze as a viable alternative to the further commitment of public land resources to subsidize urban areas).

 

We question the intent of a large corporation or its affiliates going through all the time, expense, permitting, paperwork, mitigation, etc. for a (relatively minor) 45 MW project.  If it’s a “feel good – we’re doing something ‘green’ endeavor” – we prefer that the applicant partner with SCE and spread out its “good will” on rooftops and parking lots – a bigger public relations benefit.

 

For whatever reason – to the best of our knowledge - Chevron Energy Solutions reps. have not   participated in community meetings – unlike the reps. of every other local solar/wind project currently in the permitting process.  Its absence has been noticed.    

 

Before the final decision is made, this project should be assessed via BLM’s Programmatic process which will identify the limited areas available and suitable for solar plants – along with an understanding of all the land-uses that Lucerne Valley already provide s. Calif. - to fully understand current conflicts and why we need an "Energy Element" in our current BLM and County Plans.

 

The DEIS is well written and understandable, however it devotes a lot of pages to extraneous litigation-avoidance stuff – leaving some real, critical issues unresolved.

 

 

SPECIFIC COMMENTS/POSITIONS

 

(Due to time constraints – apologize, but DEIS pages are generally not cited):

 

Alt 4 – Modified Site Layout – a viable option - would allow a buffer and on-site location and maintenance of transplanted yuccas/joshua trees – more reliable than “availability off-site to the public” – which would likely result in 50% mortality at best.

 

The “private land” alternative was basically ignored with inadequate rationale.  First Solar and Next-Era found large, fallowed parcels in Lucerne Valley – with a lot more existing all the way to Palmdale.  

 

Rated generating capacity vs. actual production is a major issue with desert solar projects.  The net benefit is likely marginal.  Energy/CO2 emissions/etc. required for making panels, structures, construction, etc. – plus the consumption of 516 acres of public land (@11 ½ acres/MW) – plus the additional loss of “multiple use” on the mitigation/compensation land ----compared to other energy sources – need to be assessed from a more global perspective.

 

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.  The proposed “mowing” is certainly worth pursuing.  However, the perennially-shaded ground will become devoid of vegetation and root structure – and the partially shaded area will likely generate more weeds than natives – thus a hindrance to operations and the need for regular weed abatement.  (Note:  Mojave rattlesnakes will love the shade on the project’s periphery).  The “Weed Control Plan” seems to have realistic and effective measures.  (The Mojave Desert Resource Conservation District and its affiliated Mohave Weed Management Area group can offer advice if requested).

 

Construction water might be obtainable from the Mojave Water Agency’s “Morongo Pipeline” – generally following Foothill Rd. immediately north of the project site – the use of untreated state water vs. good quality groundwater.  Contact:  MWA (760 946 7000) for info.and location of connections.

 

The long-term effectiveness of tortoise relocations to adjacent areas didn’t seem adequately addressed.

 

3.11-3:  The statement:  “Hunting is not an allowable use on the Proposed Action site” is very likely incorrect.  It certainly won’t be when construction starts – but currently – the only regulation we know of is “shotgun only”.

 

To fully assess the consequence of the project’s effect on biological resources – the DEIS needs a description of the most likely location for the 1:1 ratio mitigation/compensation – the location and ultimate loss of “multiple uses” on said parcel that might be purchased – or to what resource any “in-lieu” fee might be directed.  Off-site mitigation/compensation requirements ARE a direct result of this project and need to be fully explained.

 

Assuming the applicant fully intends to develop both phases, approval of Phase 1 alone is premature w/o knowing the transmission requirements of both phases together (upgrading existing line or a new one).  Needs discussion!   

 

New transmission lines or upgrades should include “raven proof” devices to the extent feasible – ravens being the biggest threat to juvenile tortoises.

 

The “heat sink” and albedo “change” effects need to be assessed, especially for the larger projects and those close to residential uses.

 

Project decommissioning and recycling of facilities were described – however specific measures for reclamation were sketchy.  Bonding or some other means to assure ultimate clean-up and reclamation in case of project abandonment need to be included in the permit.

 

The “level of service” (LOS) assessments for regional highways/roads don’t adequately quantify the actual “on the road” impacts – especially on Hwy 18 through Lucerne Valley’s commercial area and 4 way stop.  CHP escorting will likely be necessary.  The proposed “off-peak” construction travel may not fully suffice in and by itself.

 

Unless we missed it – there was no mention of a right-turn lane onto Santa Fe Fire Rd.  Quote from our scoping letter:  “A right-turn lane on Hwy 247 would provide safer egress in this area of high-speed traffic – especially for the construction phase”.

 

The analysis re: the project’s future effect on BLM’s CDCA Plan’s “Contingent Corridor S” is probably correct – but this “corridor” needs to be removed from the Plan in order to preclude another “Green Path North” attempt.

 

4.6-5: Question:  The project description seems to indicate that the panels would be “fixed” in place – thus w/o tracking ability.  If so – is this statement correct?:  “During precipitation events, solar panels would be placed in the flat horizontal position”.

 

Table 1-1:  The statement:  “The site chosen is within a ‘development corridor’ …..” is NOT consistent with the LV Community Plan’s locations for “industrial” development and thus misleading.  The entire table includes very weak rationale.

 

The Big Bear hospital is cited as close and available in case of injury, emergency, etc.  It might be, but the responding County Fire paramedics – and likely the back-up ambulance service from Victor Valley – normally transport patients to Apple Valley or Victorville hospitals – not Big Bear.  

 

Figure 3.18-1:  The Cumulative Projects Map shows a “Cumulative Effects Study Area” (CESA) boundary within a 6 mile “buffer” radius from the project site.  However it shows other proposed project locations outside said “buffer”.  A complete and adequate cumulative impact analysis needs to show and assess all the proposed projects within the larger Lucerne Valley area that is affected.  Some of the renewable projects listed may no longer be considered.  The ones not shown – all with applications currently being processed by the County and/or BLM – are 2 “First Solar” PV’s west on Hwy 18 and another adjacent to Barstow Rd. – Granite Wind west of Barstow Rd. (with DEIR/EIS issued) – Next-Era’s PV in n. Lucerne Valley – plus the proposed 29 Palms Marine Base expansion into a major portion of Lucerne/Johnson Valleys northeast of the Chevron site.  All these projects will have significant cumulative effects on our community.   

 

Following are responses to various “Social and Economic” statements and issues:

 

3.15-6:  The statement re: LVEDA is correct and appreciated.

 

4.15-3:   The statement:  With the project, “the social well-being of LVEDA (and its reps.) would be enhanced because compatible sustainable infrastructure development would be implemented within the Lucerne Valley” is a bit esoteric and certainly not fully consistent with our mission.  Some of the residents close to the project site remain opposed and thus seem to be “adversely affected” by the project. 

 

Need more emphasis on “local hiring”.  Talent and equipment are locally available for a substantial portion of the construction and maintenance work required.  It certainly won’t look good to import a lot of outside workers – union or not – when a local workforce is available.  Would be just another imposition on our community.  Cement/concrete/aggregate are locally available and we certainly expect that they be utilized if the project is built.   

 

The project’s effect on surrounding private land values is summarily dismissed.  At the very least, it could hinder area sales.  Empirical data is insufficient to determine “no substantial effect”.

 

These projects aren’t necessarily “beneficial” to local communities.  We need ways to make them more “friendly and welcomed”.  Chevron could be the lead in devising a method to “arrange” the purchase of materials in San Bernardino County – with sales tax benefiting the county – and ideally – the ½ cent Measure I (road tax) portion dedicated to Lucerne Valley roads that get  hammered by all the truck traffic associated with these projects.

 

We invite the applicant to a LVEDA meeting to better explain the project’s tax revenue benefit – specifically the annual taxes from its “leasehold interest”.  Property taxes are not generated from public lands.  How do these projects’ tax incentives affect property tax revenue normally based on the assessed values of the facilities?  Would the annual “leasehold interest” revenue be deducted from what the county receives from BLM as “payment in lieu of taxes” (PILT)?

 

WE REQUEST A MEETING WITH THE APPLICANT AND BLM PRIOR TO FINALIZATION OF THE EIS AND A DECISION ON THE PERMIT.

 

 

 

 

 

 

 

 

 

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