Anza Borrego Foundation calls for halt to fast-tracking of all major energy projects;
Cleveland National Forest Foundation says EIR violates CEQA, fails to examine less harmful alternatives such as rooftop solar
By Miriam Raftery
February 15, 2014 (San Diego’s East County)—The Anza Borrego Foundation (ABF) and a law firm representing the Cleveland National Forest Foundation (CNFF) have submitted comments warning of dire consequences from Soitec Solar’s proposed massive solar projects in the Boulevard community. Both urge the County to put the brakes on the proposed projects, which they warn would cause irreparable harm to wildlife and ecosystems not only in rural Boulevard, but in Anza Borrego State Park and Cleveland National Forest.
The ABF and Anza Borrego State Park own lands adjacent to Soitec’s proposed projects, which would include nearly 9,000 solar modules on meadows and wetlands. In its comment letter sent to the County on February 13, ABF executive director Paige Rogowski urged the County to choose the “no project” alternative for Soitec’s proposal.
The ABF comment letter warns that the project would negatively impact groundwater from the headwaters of the Carrizo Creek watershed including creeks feeding into Carrizo Gorge and Carrizo Canyon. This would negatively impact wildlife including endangered bighorn sheep, eagles, peregrine falcons, Quino checkerspot butterflies and plant life, also “impeding free movement of wildlife by reducing habitat connectivity and ruining wildlife corridors.”
Soitec has contended that the region has adequate water for its project, which could use 50 million gallons of water. Local planners in Jacumba and Boulevard have cast serious doubts on that contention, noting that major operations such as rock-crushing and cement-making on site were omitted from the draft EIR's water use estimate.
The ABF letter similarly notes that Soitec’s project estimates for water use relied on the same consulting firm (Dudek) that grossly under-estimated water use for SDG&E’s ECO-substation. That project used 90 million gallons of water—triple Dudek’s estimate. (photo, left)
“Soitec estimates in the DEIR [Draft Environmental Impact Report] can be expected to be underestimated by at least the same factor, given the `fast track’ broad-brushed analysis given to the proposal and the same company and crew doing the estimates,” the ABF concluded.
Going even further, however, the ABF letter reveals, “ABF opposes the concept of `Fast Tracking’ energy projects on private or public lands. `Fast tracking is a euphemism for avoiding laws put in place to address environmental impacts, the very essence of why the United States enacted N EPA (National Enviornmental Policy Act) and the California Legislature created CEQA (California Environmental Quality Act). “
As evidence of the irreversible damage caused by fast-tracking, Rogowski said the state park has already been negatively impacted by Pattern Energy's Ocotillo Express Wind Facility on 12,500 acres of federal Bureau of Land Management public lands adjacent to the Anza Borrego Desert State Park.
“Ocotillo Wind (photo, right) has had a profound negative impact upon the park’s natural and cultural resources, has created a barrier to wildlife, has encroached upon a documented desert bighorn sheep lambing area, and has forever blighted the scenic qualities of the entire southern sector of the state park,” Rogowski wrote.
Shute, Mihaly & Weinberger LLP, a law firm representing the Cleveland National Forest Foundation, has also sent a letter to Robert Hingtgen at the County’s Planning and Development Services office. The CNFF, which promotes sustainable land use planning, concludes that the Soitec draft EIR fails to comply with CEQA because it does not analyze alternatives such as producing the same amount of power using rooftop solar. The CNFF’s law firm asks the County to delay further consideration of the project until a legally adequate EIR is prepared that fully complies with CEQA.
“CNFF fully supports renewable energy,” the comment letter states. But the comment notes that project EIR “obfuscates the scope of the project, ignores the growth inducing impacts, and fails to supports its conclusion that the project will have a positive impact on curbing climate change. Let’s be frank: unless the County commits to replace a commensurate amount of `dirty’ energy, this project will simply enable sprawl development. “
Further, the CNFF law firm notes, “The project proposes massive solar farms on relatively pristine backcountry habitat. It would result in significant environmental impacts related to biological and cultural resources, land use, air quality, and aesthetics.” It would also use massive amounts of water, threatening groundwater supplies, the letter states.
It concludes, “The County must not approve such a project when feasible alternatives-- such as rooftop solar—exist…To achieve an adequate range of alternatives to the proposed project, the County must evaluate a `distributed generation’ alternative,” such as rooftop solar. CNFF concludes that distributed generation “can accomplish the same goals as utility-scale solar projets—i.e., the development of large quantities of renewable energy—but with substantially reduced environmental impacts as it does not require developing undeveloped land.”
The EIR also fails to state who will purchase the power from the project, and at what cost to ratepayers, the CNFF attorneys’ letter points out.
Residents have launched an online petition asking Supervisors to save their wildlife, water supplies, wild and scenic places. and put solar in urban environments instead. You can read the petition and sign it here.