LUCERNE VALLEY ECONOMIC DEVELOPMENT ASSOCIATION (LVEDA)

To: Doug Feremenga, Project Planner - Planning Division

From: Chuck Bell, Pres.
P. O. Box 193
Lucerne Valley, CA 92356 760 964 3118 chuckb@sisp.net

Date: 12/18/09

RE: RABBIT SPRINGS SOLAR, LLC - EDISON MISSION ENERGY - 450 011 08

LVEDA is not taking a final position on the project until the EIR is submitted.

As expressed in our various comments on “renewable” energy projects – we advocate solar panel installations on roof tops and parking lots rather than spreading utility-scale developments throughout remote desert locations. The amount of land required for solar power generation relative to the energy produced is a marginal use of desert resources. Sunshine is only one of the desert’s many attributes. We prefer nuclear generation on the coast where the demand for power is greatest. Cost/kwh would be a fraction of solar or wind sources.

Lucerne Valley is besieged with numerous solar/wind project proposals and applications: (This project - Granite Mt. Wind - Fry Mt. Wind – Chevron Solar – undisclosed PV sites near Camprock Rd. – Recurrent Energy’s 2 PVsites “somewhere near” Hwy 18 – a massive PV array in and around Lucerne Dry Lake? – who knows what else?.). Plus SCE’s proposed “Jasper Substation” to accommodate Granite Mt. Wind’s power connection “and other projects – don’t know where” (per SCE). Plus the proposed 29 Palms Marine Base expansion into Johnson and Lucerne Valleys. Plus LADWP’s Green Path North transmission line (which ISN’T dead). These piece-meal projects are flowing in – one after the other – prior to finalization of the so-called “regional” BLM Programmatic process/RETI/etc., etc. plans – literally the “cart before the horse” – committing sites and associated future transmission links from who knows where - before we “all” figure out the best places for them. Whether the County requires an “Energy Overlay” for these “renewables” or not – the fact remains that build-out of even just a few of these plants will significantly trump the integrity of our Community Plan that we and the County worked so hard to produce – not to mention the inevitable land-use conflicts on the ground.

THE COUNTY NEEDS TO HELP US FILTER THROUGH ALL THIS – DEALING WITH THE “WHOLE” SO WE DON’T GET BURIED IN THE “PARTS” – DO SOME REAL “ENERGY PLANNING” FOR LV AND SURROUNDING COMMUNITIES - AND SOON BEFORE ANY OF THESE PROJECTS GET TOO FAR IN THE PROCESS. ALSO NEED TO ASSESS COMMUNITY ECONOMIC IMPLICATIONS – PARTICULARLY WHAT HAPPENS IF AND WHEN PROJECTS ARE ABANDONED DUE TO NEW TECHNOLOGIES OR CESSATION OF SUBSIDIES.

Notwithstanding our concerns re: utility-scale projects, this project basically complies with our general policy of utilizing private, previously disturbed parcels with existing roads, infrastructure, etc. – offering land-owners the opportunity to market properties that are not likely suitable for other types of development – as an alternative to consuming what’s left of undisturbed public lands – subsidized by taxpayers and public land users.

However, this particular parcel – located within the central portion of the valley - especially with its water rights - could be an excellent location for large parcel/rural residential development – significantly more consistent with our Community Plan goals and land-use designations than industrial/energy uses - an alternative that needs to be assessed in the EIR.

We hope that notices were sent to the owners of the Rancho Lucerne property – a (pending) PUD on the east side of Barstow Rd. - adjacent to the project site. Their perspectives would be critical for the solar project’s land-use evaluation.

We concur with and appreciate the project’s avoidance of the site’s less disturbed western and riparian portions near the Helendale Fault.

Require vegetative or other screening for Holmes Rd. residences if so requested.

Dust/sand-blow control would be critical and must be closely monitored.

Construction vehicle access to the site directly via Rabbit Springs Rd. eastbound from Hwy 18 will constitute a nuisance/impact on numerous residences. Construction access eastbound through the Lucerne Valley Hwy 18 commercial corridor will adversely affect traffic flow – and result in left-turn movements from Barstow Rd. (Hwy 247) – possibly requiring a Caltrans’ left-turn pocket – especially if access to the site is from Rabbit Springs Rd. Material hauled in from eastern sources would reduce traffic impacts.

Salvageable remnants of the Gobar homestead should be made available to the community for transfer to another location.

Our local labor force must be utilized to the maximum extent possible for construction and operation. The community would not appreciate the import of workers and construction equipment – ignoring our varied and professional resources that can perform numerous tasks.