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Lucerne Valley Economic Development Association (LVEDA)
To: Carrie Hyke, Principal Planner
SB County Advanced Planning
385 N. Arrowhead Ave.
San Bernardino, CA 92415-0182
And
Granite Wind Project Manager
Bureau of Land Management
Barstow Field Office
2601 Barstow Road
Barstow, CA 92311
From: Richard Selby, LVEDA Board & Chuck Bell, LVEDA President
P.O. Box 941 P.O. Box 193
Lucerne Valley, CA 92356 Lucerne Valley, CA 92356
Date: 6/21/10
RE: NOP – GRANITE MT. WIND ENERGY PROJECT
We appreciate the project presentations at LVEDA and within the community with
County/BLM participation. LVEDA endorses economic development that is truly
“economic” – AND consistent with the rural character of our community and
protection of our surrounding natural resources.
NOTE: We have requested both County and BLM to lead a planning/zoning effort to
determine the most appropriate and feasible locations for Calif. Desert
solar/wind projects – in conjunction with the County General Plan and BLM’s
Calif. Desert and West Mojave Plans. It is critical that we take a global
approach instead of reacting to each application on a project by project basis –
including this one.
Although LVEDA didn’t originally take a position on this project, it has become
evidently clear that the community has. This position is mostly from an
aesthetic viewpoint and it doesn’t favor the establishment of this project.
LVEDA asked that the following issues be addressed in the EIS/EIR and we will
make an attempt to discuss our concerns in relation to how these issues were
addressed as well as point out further issues.
Following are specific issues/impacts that were asked to be addressed:
1. ACCESS:
A. Quantify construction traffic (ADT and types) traveling through Lucerne
Valley to Spinel Rd. – how mitigate impacts along our commercial corridor?
B. Effects (noise, dust, traffic, etc.) on residents along Spinel Rd./Hwy 247.
C. Impacts on public land/desert resources from improved access and
inherent/increased OHV use in valley leading to site. How mitigate?
D. Full environmental/energy use assessment of Lucerne Valley vs. Apple Valley
access options.
2. GENERAL:
A. Analysis of project’s net energy benefit relative to roof-top solar options
in the coastal basin (the area of demand).
B. Description and analysis of the total range of construction/operation impacts
on habitats/populations of big horn sheep, quail/chukar (including lost hunting
areas), various types of recreation, etc.
C. Visual and other effects on Lucerne Valley “Cove” residents.
DISCUSSION ON LEVEDA’S ISSUES:
In general, the EIR/EIS document has addressed at least some of these issues to
some extent but to what extent these issues were examined is our question. Most
all answers to our questions are contained in Chapter Three of the EIS/EIR so
references of tables, etc. will be from this chapter unless stated otherwise.
1. ACCESS;
A. We questioned the traffic quantities (ADT) traveling through Lucerne Valley.
The EIS/EIR only references the two main highways (18 & 247) and mostly highway
247. This seems short-sighted and not addressing the complete routes of concern.
The construction traffic will attribute 750 daily trips through Lucerne Valley
and all of this prior to 7 a.m. till 6 p.m. (Table 3.13-D). Traffic mitigation
wasn’t mentioned since the report states that the roadway system will support
this additional traffic.
B. Effects of noise, dust, traffic. etc, on residents on Barstow and Spinel
Roads. First, noise. County noise limits for daytime are 55 dBA for maximum of
30 minutes and 45 dBA for same period at night. Higher levels are accepted with
shorter time durations. The report shows current noise study done for Spinel
Road approximately ¾ mile west of highway 247 to be 26.8 to 56.9 dBA daytime and
23.3 to 41.7 dBA nighttime with similar noise levels on an unnamed road
approximately 1 mile north of Spinel Road. Tables 3.5-F, G, H show that
construction noise will be anywhere from 75 dBA to 85 dBA, a significant
increase over the county standard but the report exempts construction noise.
Table 3.5-K shows noise levels for the wind turbines at from 4 m/s up to 12 m/s.
At 8 m/s one turbine puts out 31 dBA level for a southwest wind (prevailing) at
the Spinel Road location. So would 28 of these be 28 times 31 dBA at the Spinel
location? It seems reasonable that it would not be so but it also seems
reasonable that the residents of Spinel Road will have to put up with some high
level of turbine noise and the same for the residents 1 mile north of Spinel
Road. Haynes Road was another test location which showed current levels
exceeding the county standard so additional turbine noise may just be unbearable
as well at Haynes Road (1/4 mile west of hwy 247).
Next, dust, Section 3.2.6 states that the construction of the project will
exceed MDAQMD thresholds for PM10 even after mitigation (Table 3.2-D). The
report only states that construction BMP’s will be implemented. How will this be
regulated in such a remote location?
Then, traffic, so as mentioned in the previous section A, 750 trips per day will
be added to the local traffic. Does this mean 750 trips up and down Spinel Road?
This could irritate the Spinel Road residents tremendously. Would this traffic
warrant a left turn pocket, at least temporary, on Highway 247 to Spinel Road?
C. Impacts from improved access. Improving and establishing roadways through the
Granite Mountains and up to 28 turbine sites will give the OHV crowd a new found
off-road track. Up to 229 acres of land will be disturbed and 12.7 miles of new
roads will be created. Once you build a road in the desert or the mountains, it
has a habit of staying there, forever. Where does this report address the
effects of 12.7 miles of new roads being used for off-highway purposes? The dust
from this activity didn’t seem to appear in this report. The report did address
the endangered species but only marginally. For the days that the biologists
were on site counting such species. This report seems to disregard the long-term
effects of these turbines operating and destroying species, like the raptors,
which are only accounted for by a brief visit. These populations change from
year to year, decade to decade. The loss, from the turbines in operation, of any
raptors and other species seems intolerable due to the fragile environment of
the Granite Mountains and Lucerne Valley.
D. The Lucerne Valley vs. Apple Valley access options now seem moot since the
report now favors access from Lucerne Valley only. So, Lucerne Valley will get
to put up with all the problems associated with this project and its failed
mitigations.
2. GENERAL;
A. Analysis of the project’s net energy benefit relative to roof-top solar
options being used in the coastal basin was not addressed. The project estimates
that it will produce 185,000 MWh per year or enough to power over 77,000
residential customers. LVEDA does not see how this will directly benefit Lucerne
Valley. (See 3, G) Also, production figures such as these are usually inflated
vs. actual production.
B. The analysis on how the project will impact the species is addressed in
section 3.4 but again seems short-sighted. Section 3.18.3 Biological Resources
states that 90 acres will be lost to native vegetation and up to 170 acres of
disturbed habitat would result in an adverse impact, however, mitigation
measures and BMP’s will make these impacts negligible. Of course, this means
negligible as far as government agencies limits will allow. A look at Table
3.4-A on the biological survey dates shows that less than 70 days were used for
avian surveys over a seven year period and far less for mammals, reptiles,
invertebrates and vegetation. The report states that all impacts are tolerable
and within limits. It doesn’t appear that enough research went into the
biological studies for a project of this scale and scope. The report shows that
the project is not within a designated recreation area (see Figure 3.10-1).
However, the construction of this project will create a new one with 12.7 miles
of new roads for the off-highway vehicle users. The report states that this
project would not significantly impact designated recreational uses, but did
they include the new area that the project will create?
C. Visual effects to the residents of Lucerne Valley. Here’s the biggest point
of contention yet. Do the residents of Lucerne Valley (& Fairview Valley) want
to look at these turbines for the next 40 years? A large majority of local
residents in attendance of LVEDA meetings (>95%) are opposed to the aesthetic
impacts. Now, the question remains, how much weight does the aesthetic issue
carry? At least one LVEDA member looks forward to seeing the wind turbines on
the mountain ridges. The report does a fine job of showing the before and after
photos of the mountain ridgelines. If these are correct in scale, the appearance
of these 28 towers is a significant alteration of the mountain skyline. These
towers will ruin a scenic view of the Granite Mountains that has been enjoyed
for hundreds of years.
3. OTHER AND ADDITIONAL ISSUES;
A. Economic characteristics should be considered here. The report gives two
sentences to the description of the Lucerne Valley community. It only mentions
the three mines and the water reclamation project from Big Bear. This hardly
describes Lucerne Valley. There’s no mention of the bedroom-like community of
desert living rural lifestyle that we all enjoy nor the mention of any current
farming, animal raising, the vast equestrian community nor the religious
community which includes not only places of worship but religious retreats as
well. This is what describes Lucerne Valley and LVEDA gets the impression that
the people are not in favor of this project. The report states that it will
contribute $680,000 to $1,060,000 annually to the communities of Lucerne and
Apple Valleys in payroll, maintenance, fuel, supplies, contractors, equipment
rentals, insurance and land rents, a very high percentage of which would not be
purchased in Lucerne Valley. It’s also expected that up to $500,000 annually in
taxes will come to the county. How much of this will really come to Lucerne
Valley? Only private portions of land are subject to property taxes unless the
county can assess taxes on the improvements and equipment on federal land. The
county may be too inclined to approve such projects as this, giving away the
best interests of the local areas in exchange for tax income.
B. Property values are not well examined in this report since the report states
that the effects on property values for lands around wind energy projects is not
known since not many studies have been done regarding this. Wonder why? The
potential for a downgrade of property values after the construction of this
project are very real and expected. This was the number 2 issue brought up by
the citizens of Lucerne Valley. These types of projects belong in industrial
zones, not on our mountain tops. Attached is an article from the INDUSTRIAL WIND
ACTION GROUP addressing the issue of a recent study regarding the DOE’s position
on the lack of property value losses in areas around wind farms?
C. Lighting as required by the FAA. These turbine towers will be required to
have warning lights for aviators, or at least 13 of the 28 will. The report
states that FAA lighting is expected to result in potentially adverse nighttime
visual impacts. So, not only will the turbines be a daylight visual blight, but
now a nighttime one as well. We believe that a study on the strobe effects from
the turbines in daylight on the community of Apple Valley during morning hours
and in Lucerne Valley during afternoon hours as well as strobe effects from the
FAA warning lights at night. There are definite problems from the strobe effects
(or shadow flicker) on the residents that live in the North Palm Springs area
near the wind turbines located there. Recently the military has put a hold on
the wind projects in and around Barstow so as to study these types of effects on
their aircraft. So, there must be something to be considered here.
D. Mitigations and BMP’s seem to be the only answer that the report has to solve
all the negative impacts from this project. Unfortunately, history has shown
that mitigations don’t always work and Best Management Practices aren’t always
followed. Remote areas like the Granite Mountains will make it difficult to do
so. Not all facility operators are negligent and we hope that this project will
take an example of those facility operators in the vicinity that are diligent in
there BMP’s and mitigations as well as regulatory oversight diligence. It will
be difficult to know the real impact of bird and other species losses from the
wind turbines due to the removal by the local predators.
E. Why is the Lucerne Valley access preferred? It appears that the west access
from Apple Valley would be closer from the freeway off of Boulder Road and
through Fairview Valley. There’s more land disturbance on that side of the
Granite Mountains than on the Lucerne Valley side.
F. 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 (i.e. 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. Projects like Lucerne Valley’s proposed new
downtown sewer project would be an example of rewarding the community.
G. The question comes to mind in regards to the stated kilowatt production. The
stated yearly production is 185,000 megawatt-hours. The stated turbine would
produce 2.3 megawatts. Using the stated 28 turbines at 2.3 megawatts each would
equal 64.4 megawatts. It would take around 2873 hours per turbine per year which
would be almost 8 hours per day 365 days per year of maximum producing wind to
meet the stated yearly production. This is totally overstated. This project
would be lucky to achieve 1/3 of that production. Is this project worthwhile at
around 60,000 megawatts per year? Usually, the output is between 14% and 20% of
the rated output so saying even 1/3 is very generous. We believe that the stated
output is based on rated capacity at optimum wind which we do not believe is
reasonable. How about a “Cost Benefit Analysis” of power produced vs. from all
other sources?
H. When it comes to the need for construction water, we think that using our
precious groundwater would be detrimental to the community especially if it
comes from the Lucerne Valley Basin (north of the Helendale fault), since this
basin has been dropping for the last 50 years. Construction water should come
from the non-potable water of the Morongo pipeline. What impact will this have
on the pipeline?
I. Another issue would be the future project’s decommissioning. The need for
bonding should be established to handle the decommissioning and reclamation of
this project. The question has come up with how to address the recycling of the
turbines parts at the end of their lifecycle. These machines are made from toxic
materials and materials like fiberglass in the propellers. Disposal of the
massive concrete foundations full of rebar is concerning as well as how does the
project proponent propose to reclaim the environment.
J. These turbine hubs are 262 feet in the air. No local fire protection
authority has equipment and apparatus sufficient to extinguish a turbine fire.
At least one turbine per year catches on fire in the North Palm Springs wind
farm and the local fire fighters can do nothing but let it burn and just keep
the surrounding environment from burning. Response time to the Granite Mountains
is going to be much longer than in North Palm Springs. This seems to subject the
environment to possible fire destruction. When these turbines burn, they give
off toxic fumes and burnt debris, like fiberglass from the propellers. The
prevailing winds blow from the west and southwest which will blow the fire
debris onto the neighborhood around Spinel Road. There may only be a few
residents there but even the loss of one is too much.
K. What about the cumulative impacts on Lucerne Valley when you add in the
Chevron Solar project on Santa Fe Fire Road in east Lucerne Valley, the First
Solar solar projects on Rabbit Springs Road and Desert View Road in southwest
Lucerne Valley, the Next Era solar project on Haynes Road in north Lucerne
Valley and also the possible 29 Palms Marine Base expansion into east Lucerne
Valley near Cougar Buttes. It appears that Lucerne Valley has been picked to
put-up with the alternate energy projects that mostly benefit the power grid for
the greater good (or mostly the down-the-hill demand).
L. The report talks some about jobs but also mentions that the skilled work
force needed to construct and operate this project will be filled by contractors
and persons from out of the area with some minimal labor possibly coming from
Lucerne Valley. There doesn’t seem to be much incentive for jobs enough for the
local community to support this project.
M. Can this project arrange for sales tax to be generated in San Bernardino
County with Measure I (road) revenue to come back to Lucerne Valley?
N. What transmission line impacts to the proposed Edison Jasper Substation would
happen?
O. Would “Leasehold Interest” revenue to the county under Senator Feinstein’s
proposed Desert Protection Act be deducted from BLM’s PILT payments to the
county?
4. CONCLUSION;
As you can see, LVEDA has major concerns regarding this projects viability and
its location. LVEDA is an open forum for the community to address issues like
this one. So far, there has been only one LVEDA member stand up for this project
with all others being not in favor in any form. This project would permanently
alter a pristine local desert-mountain environment for what we believe are over
stated production estimates. LVEDA in its majority is not convinced that this
project is a good fit for this community.
LVEDA is requesting a meeting with the applicant, county planning staff and the
BLM prior to finalization of the EIS and a decision on the permit.
ATTACHMENT
From: "Wind Alert! (IWA)" <info@windaction.org>
Sent: Monday, February 15, 2010 12:24 PM
To: <atomictoadranch@netzero.net>
Subject: RELEASE: Expert: Flawed Methodologies Used In U.S. Doe Study On
Property Values And Wind Power Projects
> FOR IMMEDIATE RELEASE
> http://www.windaction.org/releases/25672
>
>
> EXPERT: FLAWED METHODOLOGIES USED IN U.S. DOE STUDY ON PROPERTY VALUES AND
> WIND POWER PROJECTS
>
> Serious questions raised concerning the credibility of the results
>
> NEW HAMPSHIRE (February 15, 2010) -- Real estate appraisal experts are
> challenging the scientific credibility and accuracy of a recent US
> Department of Energy ('DOE') report on the effect of wind power projects
> on property values. A new paper [1] asserts that well known flaws in the
> methodology used in the study raise serious questions concerning the
> credibility of the results, and the DOE report's authors failed to follow
> well-developed and tested standards for performing regression analyses on
> property sales.
>
> The Department of Energy's Lawrence Berkeley National Laboratory report [2]
> titled "The Impact of Wind Power Projects on Residential Property Values
> in the United States: A Multi- Site Hedonic Analysis" released December
> 2009 generated media headlines [3] claiming "Wind farms have no effect on
> property value." The report asserts that an analysis of residential home
> sales across the United States found no evidence that home prices
> surrounding wind facilities were "consistently, measurably, and
> significantly affected by either the view of wind facilities or the
> distance of the home to those facilities". While the authors acknowledge
> that individual homes in proximity to the towers may be negatively
> affected, such impact was declared "either too small and/or too infrequent
> to result in any widespread, statistically observable impact".
>
> The authors relied on a methodology known as Multi-Site Hedonic Analysis.
>
> The DOE study caught the attention of Mr. Albert Wilson [4], a value of
> environmental impacts on business and real estate with more than 25 years
> experience who has specifically studied hedonic analyses of real estate
> for more than a decade, and has taught and written extensively on these
> impacts and methods.
>
> "I have no opinion concerning the effect of wind power projects on
> residential property values," Wilson told Windaction.org. "However, I was
> compelled to respond professionally when it became apparent that the
> latest report by the Department of Energy was predicated on flawed
> methods - flaws that are well known in the literature but apparently
> ignored or missed by the report's authors."
>
> In his paper, "Wind Farms, Residential Property Values, And Rubber
> Rulers"[1] Wilson writes that the underlying methods used in the
> development of the DOE study raise serious questions concerning the
> credibility of the results. In particular, the authors failed to follow
> any of the well-developed and tested standards for performing regression
> analyses on property sales.
>
> "There are literally thousands of possible real estate regression models.
> Absent published and recognized standards on the validation of data, model
> development and testing, and calibration of the model against the real
> world market, a regression may be nothing more than a rubber ruler that
> can be stretched to provide a desired result," he wrote.
>
> And since any hedonic analysis depends entirely on the accuracy and
> reliability of the regression used, if the underlying regression does not
> conform to recognized standards, Wilson argues there can be no independent
> assurance of that accuracy or reliability.
>
> Offering specifics on the study's flaws, Wilson is highly critical of
> DOE's nationwide approach whereby thousands of real estate transactions
> were examined in communities surrounding wind power facilities spread
> across the United States. The authors consolidated all of these markets
> and treated them as the same with little consideration of basic
> differences. For example, sales prices in areas of declining population
> and therefore decreasing demand-a majority of the areas examined-are not
> directly comparable to sales prices in areas of increasing population and
> therefore increasing demand. Even within the ten communities identified in
> the DOE report, such aggregation of markets is questionable. In Washington
> State, which was used as the base for comparison to all other areas in the
> study, the authors aggregated the urban market of Kennewick with the rural
> market of Milton-Freewater -- two very different areas some 42 miles
> apart!
>
> Wilson was clear when he wrote, "The failure to recognize and account for
> the need for homogeneity of markets is a common failing of hedonics."
>
> The DOE study completely ignores this point by creating an average sales
> price representing houses from nine states and at least 20 different
> markets -- a gross oversimplification that Wilson asserts cannot provide
> for the specificity required to answer a micro-question such as an
> influence on sales price from a highly localized condition i.e. distance
> to or view of a wind energy project.
>
> This problem becomes even more significant when, as Wilson points out,
> less than 10% of the sales transactions used in the Report had any view of
> turbines and only 2.1% had a view rated greater than minor. In fact, the
> study is dominated by transactions where no influence is reasonably
> likely. While the author's of the DOE study claim their analysis is
> "data-rich", in fact, their claim is an overstatement of the situation
> because of this issue.
>
> The DOE study was three years in the making and cost taxpayers at least
> $500,000. It is difficult to see how the public was served by an exercise
> that failed to follow even the most basic requirements for regression
> analysis which is the foundation on which hedonic methods are based.
>
> About Windaction.org: Industrial Wind Action Group seeks to promote
> knowledge and raise awareness of the risks and damaging environmental
> impacts of industrial wind energy development. Information and analysis on
> the subject is available through its website http://www.windaction.org/.
> To subscribe to the Windaction.org weekly newsletter, visit
> http://www.windaction.org/subscribe
>
> CONTACT:
> Lisa Linowes
> 603-838-6588
> llinowes@windaction.org
>
> ###
>
> [1]
> http://www.arwilson.com/pdf/newpdfs/WindFarmsResidentialPropertyValuesandRubberRulers.pdf
>
> [2] http://eetd.lbl.gov/ea/EMS/reports/lbnl-2829e.pdf
>
> [3] http://www.windaction.org/news/24397
>
> [4] http://www.arwilson.com/
>
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