To: Greg Thomsen – BLM (lucernesolar@blm.gov)
Re: Comments
– DEIS - Chevron Energy Solutions –
From: Chuck Bell, Pres. (chuckb@sisp.net)
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
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
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
Unless we missed it – there was no mention of a right-turn
lane onto
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
The Big Bear hospital is cited as close and
available in case of injury, emergency, etc.
It might be, but the responding
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
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
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
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.
.