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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: 1/7/10
RE: BOULEVARD , LLC - NEXTERA – 60 MW PV - 453 091 72
Doug:
Some of this is repetition of our generic comments on all these applications –
too many projects and too little time to adequately focus on each one.
LVEDA is not taking a final position on the project until the EIR (if required)
is submitted. Whether we eventually support or oppose this project – an EIR
might be avoided if mitigation suffices.
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.
Lucerne Valley is besieged with numerous solar/wind project proposals and
applications: (This project – Rabbit Springs Solar – Strawberry Peak Solar -
Granite Mt. Wind - Fry Mt. Wind – Chevron Solar – proposed 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. A CUMULATIVE IMPACT ANALYSIS IS CRITICAL TO ASSESS IMPLICATIONS TO
OUR LAND-USE CONFIGURATIONS..
Notwithstanding our concerns re: utility-scale projects, this project basically
complies with our general policy of utilizing previously disturbed private
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.
Dust/sand-blow control would be critical and must be closely monitored –
especially with a 30 month construction period.
Bonding to assure site reclamation if and when project is abandoned. Need to
assess community economic implications – particularly what happens if and when
projects are abandoned due to new technologies or cessation of subsidies
Construction vehicle access to the site (assuming eastbound from Hwy 18 – north
on Hwy 247 – Barstow Rd.) will adversely affect traffic flow through the Lucerne
Valley commercial corridor. If 2 or 3 of these solar plants start construction
at the same time – cumulative traffic impacts will be more than “significant”.
Paving improvements on Haynes and Meridian Roads should be required – offering
some compensating benefit to local residents.
If PVs constitute a “heat sink” – quantify increase in localized temperatures.
Consider natural or fence-type screening for surrounding residences if so
requested.
Groundwater in that area can be of marginal quality – OK for construction –
likely not for panel washing unless filtered. Impact on local wells must be
assessed.
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.
LOCAL RESIDENTS DIRECTLY AFFECTED BY THE PROJECT HAVE SUBMITTED SPECIFIC AND
PERTINENT COMMENTS/CONCERNS THAT MUST BE ADDRESSED.
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