Comments to County Over Renewable Energy Development

SAN BERNARDINO COUNTY PARTNERSHIP FOR RENEWABLE ENERGY AND CONSERVATION (SPARC) – ROUND 2 COMMENTS 9/4/14

Chuck Bell (chuckb@sisp.net) 760 964 3118
Pres. – Lucerne Valley Economic Development Association (LVEDA)
P. O. Box 193
Lucerne Valley, CA 92356

Lorrie Steely (2saveourskyline@gmail.com)
Founder – Mojave Community Conservation Collaborative (MC3)
P. O. Box 2397
Apple Valley, CA 92307

We know you are all busy and likely tired of hearing from us – but you all get paid to stay on top of these issues and are elected or staffed to represent us. Our desert and its rural character are in the crosshairs up here, and we are trying our best to protect the integrity of our communities. We just had scoping sessions with BLM and CPUC on a major SCE transmission line proposed to run through our communities, our avian corridors, endangered species habitats and more. Close to 600 people turned out for four meetings and we only had two weeks notification. We were just in the midst of SPARC meetings. We have DRECP popping up again in a few weeks (a draft at 8-10,000 pages). All these critical meetings and forums are occurring all at once and the outcomes could forever adversely affect our communities. SPARC meeting attendance has been ‘SPARCE’ due to poor noticing and timing of meetings – except for the Hesperia meeting where word of mouth got the people out. But even the sparsely attended Barstow meeting allowed for good and productive discourse – mainly because it drifted away from the typical ‘fill out the form’ venue. More of the County’s CEC grant $ should be spent on public outreach – notification – more community participation during the process – even if just with specified community/group reps. – and not just at specified intervals.

Those of us ‘up here’ are getting (seemingly) conflicting and confusing messages from ‘down there’ (ie: Will SPARC be the County’s lead document and policy – or will it be the DRECP, etc.?).

The ‘community engagement’ portion of SPARC’s Round 1 document seems to have captured the essence of our concerns about industrial-scale RE projects – a bit promising - which in turn should be influencing County actions.

But then we received a (hard to read) map that the County presented at a public CEC workshop on 8/5 – showing a range of areas suitable for RE projects – not much different that the ‘Development Focus Areas’ in the initial DRECP draft that included and surrounded our communities – which got everyone riled up in the first place – certainly not reflecting what you have been hearing over the years nor what your own SPARC findings are. If this map is no longer relevant or a “mistake” – it was nevertheless presented to the CEC at the workshop. To adequately represent stakeholders, the County must get it rescinded with an explanation so the CEC doesn’t consider it the ‘County’s Position’. Stakeholders have been engaged in these processes for over 7 years and this map not only conflicts with county residents positions, but also with community opposition to projects like LADWP’s Green Path North, Black Lave Butte Wind and the proposed North Peak Wind project -- which the County and other elected officials opposed as well. This map, mistake or not, suggests that the County is going down the misguided path of an industry and utility driven model that ignores local and regional planning, tax impacts, recreation and current conservation investments and cumulative effects.

And then this from a staff e-mail:

“Mr. Newcombe’s presentation included a map that the Public Works Department prepared as part of their participation in DRECP, which is a separate planning effort from SPARC. Land Use Services is collaborating with Public Works to ensure that the County’s renewable energy and conservation plan (SPARC) is compatible with the DRECP habitat conservation plan”.

What does all this mean? DRECP is more ‘energy’ than ‘conservation’. How can SPARC and its resulting Renewable Element to the General Plan be an independent County-based document and guidelines if it will be subservient to whatever it is that the State’s DRECP comes up with – especially in light of its first draft’s disastrous ‘Development Focus Areas’. Is this statement an affirmation that the County will automatically buy into and adopt the DRECP – which it doesn’t have to. It’s time for our elected reps. and planning staff to meet with involved community/group reps – determine where these things can and should go – where not – get some zoning for industrial-scale PV solar (not wind) – cut to the chase and reduce this bureaucracy. Lucerne Valley has 5 to 6 square miles of really good potential PV solar ground – supported by the community – as we have been telling you for years. Good old fashioned zoning was a wonderful invention. If there is one county left that doesn’t have to keep surrendering to the dysfunctional state of Calif. – able to directly work with affected communities to solve this issue – it should be this County. We need aggressive County leadership accountable to and representing residents so that outside consultants that know little about the desert don’t dilute the integrity of the product.

SPARC POLICY AND IMPORTANT ELEMENTS:

Adopt policy: Utilize rooftops - commercial parking lots for PV solar (Distributed Generation) - where necessary infrastructure exists - (which alone should suffice to meet “renewable goals”) - before considering the use of the Plan’s “zoned” lands.

Strong opposition to utility-scale wind projects – too heavily subsidized – view shed obtrusive – inefficient generation of power during peak demand periods relative to other sources - harm to raptors/eagles/etc. – a multitude of access roads that encourage OHV trespass, trash dumping, ambient particulate matter - long transmission lines/new corridors over and around hills – intermittent power from wind that is difficult for the grid to accept without shutting down other generation sources.

Advocate County’s implementation of AB 811. Seek partners and funds/grants to implement.

With Distributed Generation our highest priority and utilized first – the Renewable Energy Element to the General Plan needs to include ‘industrial-scale’ zoning for those few communities that have the ground and resources to accommodate such projects – with the emphasis on options for ‘community solar’ projects directly benefitting community/county residents.

A SPARC distinction/definition/designation of a ‘small’ vs. ‘large’ scale renewable energy project should NOT be based on the amount of megawatts produced - which depends on system types, site characteristics, etc. It should be based on acreage. We propose that any site over 20 acres be considered ‘large scale’.
The RE Element must factor in the continued improvements of solar technologies and the eventual “Net Zero” energy requirement to be placed on residential and commercial/industrial development – (Distributed Generation) – significantly negating the need for industrial-scale projects. With all the incentives provided to developers inducing said projects – we could end up with industrial-scale generation that is not needed and will become a blight on the landscape.

The RE Element also must include a ‘Transmission Plan’ that doesn’t require new alignments/corridors – only short connections to the existing grid.

California residents already pay some of the highest electricity rates in the nation. Use some of the County’s CEC grant(s) to determine the ultimate potential cost of electricity and rates resulting from the County’s potential max. generation on its planned RE acreage.

SPARC’s analysis needs to include the net air quality and CO2 benefits/detriments/tradeoffs of development within all of its RE planned acreage - compared to more conventional generators – factoring in the loss of carbon sequestering desert vegetation and soils (significant per recent studies) – the global effects of importing panels, etc. from China produced by coal-burning electrical generation (exporting of our pollution abroad) – all the other energy/pollution inputs into the manufacture of panels and associated infrastructure – and construction/decommissioning related emissions.

Economic Concerns of Utility Scale Renewables:

• Loss of property values in vicinity of these projects – especially for residential and tourism businesses
• Minimal jobs (temporary and permanent) for local residents vs. more permanent jobs from roof top and distributed solar
• Tax benefits/detriments for the community and County
• We are in an adjudicated groundwater basin administered by a Watermaster. Major issue is the pumping of limited, allotted water for construction/operation - and how it could affect farming and local water purveyors (mutual water companies) as to their ability to procure dwindling water rights to meet their own overproduction that meets the needs of the valley’s residents. (Utility scale solar has proven to require significant water consumption for construction and dust control, ie: 50-60 AF to date for 2 Lucerne Valley PV projects still under construction).
• Government subsidies for solar/wind – our tax dollars adversely affecting our community.
• Loss of agricultural lands for production, zoning concerns for future agricultural uses
• Conflicts with existing/future, more economically viable development – loss of areas used for regular events – and on BLM land – conflicts with other multi-uses including recreation, mining, conservation, etc.
* Wildlife habitat loss (which requires compensation by forced acquisition of off-site lands – and their removal from potential beneficial economic uses).
* Negative impact on tourism and recreation

Development Concerns of Utility Scale Renewables:

• The siting of such developments in areas of residential uses
• The obscuring of view sheds
• Additional infrastructure on and off site (transmission lines, substations, etc)
• Use of land that has a better future potential (zoning)
• Construction related disruptions (e.g. planned power outages, etc.)
• Ground/habitat disturbance and future dust creation – potential for desertification – health risks (ie: valley Fever)
•Significant water consumption in over-drafted, adjudicated basins for construction and operation

Specific Siting Criteria and Conditions of Approval:
(all are important and not necessarily listed in order of priority)

NOTE: Lucerne Valley’s 4 square mile “Industrial-Scale PV Suitable Area” is delineated on the map we have submitted numerous times – our only location that meets the following criteria.

• Avoid locations where current economically beneficial (job-producing) land uses or periodic events would be adversely affected.
• No solar thermal due to size and water requirements. (See Ivanpah)
• No industrial scale wind turbines. (See Tehachapi)
• Provide proof of a Power Purchase Agreement (PPA) utilizing existing transmission lines and capacity to feed into the local distribution grid.
• No Photo Voltaic (PV) fixed systems over 8’ in height - no tracking systems over 8’ in height when stowed. (See Newberry Springs)
• Confine PV to within 2 miles of existing transmission corridors. Required lines of new projects must connect to existing lines. Existing or new substations must be within established corridors. Improved parcels must not be adversely affected.
• Notify residents/landowners of all applications within a community – (desert view sheds and noise levels extend for miles). County post all RE applications in local newspapers identified by the community (ie: Lucerne Valley Leader).
• Require larger than required setbacks from property lines when near (within 1000 feet) of residential areas on the following scale; add an additional 20 feet to the minimum setback as per the County Development Code for every 10 additional acres over 20 acres (ie; add 20’ for 30 acres, etc.) up to a maximum of 100 feet of additional setback. Note: This only applies in a situation where residential use is sparse and PV is agreeable to said residents.
• Plan all construction traffic around the main community corridors.
• Min. 1000’ setback from a “scenic” state highway.
• Enforce a ground disturbance plan to control soil erosion/sand blow/weeds in and around the solar structures – no adverse effects on surrounding properties. Mowing is significantly preferable to grading/de-brushing – and beneficial to developers to avoid future wind erosion and complaints triggering code enforcement. Install parallel sand fencing on sites with (wind) erodible soils.
• Select flat sites that do not require mass grading – require soil disturbance only in increments.
• No soil disturbance during typical windy (desert) months – generally January to June.
• Renewable energy installations should be located on flat terrain and not in dry washes so as not to interfere with floodwater runoff and to reduce grading requirements.
• Zone and approve projects only on those lands with minimal native vegetation and habitat. (Utilize fallowed ag. land/disturbed parcels with minimal biological/drainage/etc. impacts).
• Industrial-scale PV should be naturally screened by native vegetation that will survive without supplemental water after the first/second year – or developed in an area currently containing buffering plants/trees – ie: natives, tamarisk, etc.
• Full mitigation for construction/operation impacts.
• Adequate monitoring for compliance so County Code Enforcement doesn’t end up ‘inheriting’ project impacts.
• All required infrastructure to be funded by developer.
• Water for construction from non-potable sources.
• Local hiring for construction and operation to the maximum extent possible.
• Require the purchase of construction materials in S. B. County to at least get sales tax (and Measure I road revenue) to partially compensate from road damage from said activity.
* Project applicants provide an “economic impact report” to include property value impacts, number of temporary jobs for local residents, permanent jobs for local residents, tax and other new revenues that will directly benefit communities - disclosing every expected economic impact – positive and negative – to be performed by a third party, reputable entity with experience in energy project-related economic analysis.
• Require a study of each proposed project to determine its incremental effect on the cost of electricity – local and regional rates – etc.
• Assess each individual project for its net air quality/CO2 emissions.
• Require applicant to post a bond sufficient to demolish the project at the end of its productive life and to reclaim the landscape and terrain to a specified condition. (Require detailed photos and survey info re: a site’s condition prior to development). If a solar or wind installation ceases to produce an agreed upon minimum output over an agreed upon time, it shall be decommissioned, demolished, and not be allowed to remain indefinitely as an eyesore that produces just a token output, delaying its demise.

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