The Mojave Watch position on the Daggett Solar Power Project
The San Bernardino County Board of Supervisors is holding a hearing that could deny the appeal made by the Newberry Community Services District (CSD), and could issue a final approval for the project, this Tuesday, December 10. It is the position of Mojave Watch that this is a reckless approach toward the likely negative impacts of this project upon the people and natural resources of the project area, entirely dismissive of the concerns of the residents likely to be impacted. It would be irresponsible for the Board of Supervisors to approve this project at this time without additional studies and hearings.
Our written comments submitted as part of the public record, are the following:
Dear Board of Supervisors,
You will be asked by Terri Rahhal, Director of Land Use Services to deny the appeal of the Newberry CSD and to approve the Daggett Solar Power Facility at your Board of Supervisors meeting on December 10. I strongly urge you to obtain more information and to listen carefully to your constituents prior to accepting Rahhal's out-of-hand dismissal of all concerns about this project. I have attended the lone public scoping meeting for the project held last year, and have followed the project and the related RECE 4.10 language adoption process in detail. There are numerous concerns and questions that arise from my experience.
As background, the Daggett Solar Power Facility almost certainly would not have been allowed to even apply, had the RECE 4.10 language been in place at the time of application. I have heard Rahhal state publicly that after the public comment period had closed for input on the RECE 4.10 language, and after she had been directed to bring that language before the Planning Commission for its review, she held private meetings with solar power project developers to get their input on, essentially, how to craft an industry-friendly version of the RECE 4.10 language and subvert the will of the residents of San Bernardino County.
You are all familiar with the fact that the RECE 4.10 language was sent by the Board of Supervisors to the Planning Commission in August, 2017. Yet, thanks greatly to Rahhal, who was busy trying to craft an alternative to the language she recognized publicly as being the will of the people living in the area in question, it took approximately 1.5 years for the language to make it to the Planning Commission and back to the Board of Supervisors. Thanks to strong and eloquent public support, both the Planning Commission and Board of Supervisors endorsed and approved the original language Rahhal had been working to subvert.
But Rahhal's delaying tactics allowed the Daggett Solar Power Facility project and others to be grandfathered in, prior to the final approval of RECE 4.10. The fact Rahhal knew that language was precisely what your constituents wanted, and worked so hard to subvert the will of San Bernardino County citizens and taxpayers, met privately with developers, and allowed applications to proceed while the RECE 4.10 language was kept in limbo, raises serious ethical questions about the procedures Rahhal and Land Use Services implemented during this time. It is clear Rahhal has operated to this point with a position of utter dismissal of all citizen concerns about these projects, and a reading of staff responses to the FEIR, and the tone of contempt and dismissal found in those responses, indicates that ideology continues in Land Use Services.
I have found, with the limited time and resources available for Mojave Watch, that there have been what appear to be purposeful omissions in some of these responses to concerns presented, the most egregious being the omission of any mention of a 2016 study on heat island effects of solar power facilities (PV) based in the desert. The response addendum includes studies of solar power facilities not located in the desert, while omitting the sole recent study that did include solar power facilities located in the desert. As a result, the addendum concludes no heat island effect results from these facilities, while the study that included desert facilities, does conclude there is a heat island effect.
This is significant in that the 5.5 square mile project encircles the Barstow-Daggett Airport on three sides. Immediately following the public scoping meeting for the project in 2018, I met personally with aviation operations personnel from Fort Irwin. They were exceedingly concerned about numerous aspects of this project impairing, or even halting aviation operations for the U.S. Army's training base there. They noted that an increase of even two to three degrees in ambient air temperature at the airport could effectively halt Army aviation operations there during the warmer parts of the year.
In addition, they were concerned about airborne particulates (the area is already out of compliance with PM10 and PM2.5 standards and the LUS response is since it is out of complaince, it doesn't matter if it gets more out of compliance as a result of the project's construction). Their concern about particulates was on several levels, from visibility and related safety issues, to the impacts of blowing sand and dust on aircraft engines, with resultant safety issues, increased maintenance issues, and the potential need to increase their budget to address these issues. They strongly noted that the Department of Defense has no funding allocated to relocate Fort Irwin's aviation operations, and that if this project did negatively impact, reduce, or halt operations, that was it. There were no options for alternatives.
Military aviation combat readiness training is an extremely important aspect to overall military training at Fort Irwin. I strongly recommend holding further meetings with the aviation personnel from Fort Irwin to ensure their concerns have been adequately addressed, prior to any approval of this project. This also ensures that civil aviation needs will be adequately addressed as well, as their concerns, including the height of surrounding power transmission towers that will be included in this project, will be addressed, and the safe operations of the Barstow-Daggett Airport will not be degraded. It is imperative that the Board of Supervisors take on this meeting as Land Use Services has been dismissive of all concerns about airport operations. In my opinion, not only the quality of operations at the airport, but possibly lives, may be at stake, and it is too serious of a matter for dismissal.
It would seem the Barstow Airport Aviation Safety Committee agrees, as they commented on the EIR that it had "vastly understated impacts to aircraft safety and to safe airport operation." An approval of this project without ensuring that all safety and operational concerns are addressed, leaves the Board of Supervisors in the unenviable position of being responsible for any aviation accidents that transpire as a result of these unaddressed concerns. I'm certain all of you are strongly and seriously concerned about preserving safe operations at this airport, for military and civilian aviators.
Concerns voiced by residents downwind of the project over airborne particulates have also been entirely dismissed, with the rationale that since the region is out of compliance, and the nearest air quality measuring station is located nearly 12 miles upwind of the project in Barstow, then it ultimately doesn't matter if the project adds to the levels of PM10 and PM2.5, which are demonstrated to be health hazards. While it is clear that under Rahhal's direction, Land Use Services is entirely unconcerned with public health matters, quality of life issues for residents, impacts to property values, and social/economic justice issues (as these rural residents are often from lower income groups, elderly, or disabled and cannot simply relocate should they suffer negative impacts from the project), these residents are your constituents. It is imperative that their concerns be heard and addressed prior to project approval. Many cannot simply drive to San Bernardino to ensure their voices are heard over Rahhal's coordinated and taxpayer-funded support for the project.
It could be useful for the Board of Supervisors to consider working through the CSDs of the impacted areas to compile useful input that would otherwise be lost. I have personally heard, time and again, at community meetings, about those residents negatively impacted by smaller solar power projects greenlighted in the county. A universal theme appears to have arisen during those comments, which is that if enforcement of any project agreement is supposed to be conducted by Land Use Services, it often does not happen. The belief by many residents is that if a project is approved, there will be no remedy presented by county staff for any issues that arise, whether it's large quantities of sand blown over residential properties, drops in property values, resultant health complications, or the outright inability to sell one's property to relocate.
Water concerns have also been dismissed out-of-hand by county staff. Please keep in mind that it's not some NGO environmental group that is expressing serious reservations about water use for this project having significant impacts on wildlands. It's the Mojave Basin Area Watermaster and the California Department of Fish and Wildlife that have raised the likely possibility that this project could seriously impact the Camp Cady Wildlife Area and the Afton Canyon Area of Critical Environmental Concern. Not only is this of significant environmental concern, not just for these areas, but for the ecological integrity of all connected and related wildlands, but Afton Canyon is one of the Barstow area's major draws for outdoor recreation. As the former president of the state-designated tourism partner for the Desert Region, I'm well aware of the serious positive economic impacts of outdoor recreation in the Mojave Desert. Areas such as Afton Canyon and Camp Cady need to be protected. This project should not be allowed to proceed until the Watermaster, Fish and Wildlife, and other agencies have their concerns about water use addressed. As Land Use Services continues to be more interested in dismissal rather than resolving concerns, this project should not be approved until the Board of Supervisors hears from these agencies that their concerns have been addressed adequately.
In addition, this project is expected to destroy dozens of ancient creosote rings (approximately 70) from 2,600 to 4,200 years old. Not only should these ancient desert residents be protected (and are supposed to be, according to the county), but they also play a significant role in carbon sequestration. What is the point of creating renewable energy projects that damage carbon sequestration? While the positive impacts of a renewable energy project will last 20 to 30 years, the negative impacts on carbon sequestration caused by the loss of ancient creosote rings will last for centuries. This destruction would directly violate the 2007 General Plan Desert Conservation Goal, as well as the CEQA process. The Board of Supervisors should not endorse the violation of the county's own General Plan, nor CEQA.
One additional practical concern for residents, is that of large scale lithium-ion battery storage units on the project site. While county staff argues that it is safe, it is important to note that the units that exploded and injured eight firefighters at an Arizona power storage facility were also deemed safe. With only volunteer fire departments in Daggett and Newberry Springs, it is crucial that the Board of Supervisors fully understands the risks of the power storage infrastructure of the project. This is an area of high winds, and with approximately 4,600 residents immediately downwind, a fire could expand quickly, or a spread of toxic smoke and gases could be dispersed. Again, county staff is quick to claim that an accident could never happen, or if it did, it would be quickly, easily, and safely contained. But to be clear, downwind residents and local firefighters will be the guinea pigs for this experiment.
As director of Mojave Watch, as well as a desert journalist, resident, and longtime citizen of San Bernardino County, I strongly urge the Board of Supervisors to reject approval of the Daggett Solar Power Facility project until these concerns, and others that citizens may bring to your attention, be adequately addressed. There is simply too much at stake to rely upon the dismissive support for the project from Terri Rahhal and her staff at Land Use Services without additional input and appropriate resolution of these issues. It is my belief that the concerns of taxpaying county citizens, aviators, hydrology experts, wildlife biologists, and others, are every bit as valid as that of a developer and the county staff that went to great lengths to support this project over the concerns of citizens, aviators, hydrology experts, wildlife biologists, and others. Please vote to deny this project until those concerns are appropriately addressed.
Director, Mojave Watch
The San Bernardino County Board of Supervisors is set to review, and possibly approve, the Daggett Solar Power Project at their upcoming meeting on Tuesday, December 10. Desert residents and those concerned about desert issues should use this opportunity to have their voices heard about the potential impacts of this project. Please feel free to use our concerns and/or your own, in an email to the Board of Supervisors prior to the hearing for the Daggett Solar Power Project.
District 1: Supervisor Lovingood (cut and paste for online contact form)
District 2: Supervisor Rutherford: firstname.lastname@example.org
Clerk of the Board: COB@sbcounty.gov