To the Planning Commission, members of the Board of Supervisors, and the public of Inyo County:

I have reviewed all 385 pages of the Renewable Energy General Plan Amendment (hereto called the REGPA) and its attached appendices, and have been considering its implications for some time now. The REGPA presents some very concerning questions – ones that deserve direct and pointed scrutiny by all of us here in the Owens Valley. I realize it is difficult to consider many of the issues at hand, as they necessarily involve our own long-term projections about the future well-being of our unique and beautiful home, and that finding a responsible and effective path forward means making some hard decisions. It is also important to remember, for each of us, that past actions or mistakes are not condemnations of our ability to adequately assess the issues of the present, and that malleability and empathy are vital assets in our decision making processes concerning the future. I truly believe that each of us in the room hold the Owens Valley and Inyo County dear to our hearts, that we can work together, and in our own ways we all want the best for our home, this empyrean length of the American West. It is with these thoughts in mind that I would like to voice my own concerns regarding the REGPA and its possible outcomes.

It is vitally important that we act as a community on each of these issues. As residents, we take the front lines in defending our valley and assuring its continued well-being. I am thankful that the County has opened their doors to this public comment session, and such action tells me that our input, as citizens, is important. However, there are significant logical discrepancies within the literature associated with the issues at hand; this literature ultimately will be the central body of evidence when the time comes for our elected officials to make decisions, so it is absolutely necessary for these discrepancies to be highlighted and discussed prior to those decisions.

The background report of the REGPA states, on page 6, that the General Plan “is where a community develops its visions, goals, and policies for land use and development.” It goes on to state that the County “hopes to provide the proper structure and guidance for potential development and keep it consistent with (the) overall vision of the County that was adopted through a thorough public process and expressed in the General Plan,” and that “[o]verall, the county and its citizens are in support of renewable energy development.” These are important statements that need specific consideration.

Firstly, the idea that the visions, goals, and policies of the General Plan were developed as “a community” is a stretch by any measure. It is true that the County held meetings for both the public and for stakeholders, however a closer look at the reality of the attendance figures quickly  undermines the claim that adequate community input is a core characteristic of the REGPA. I know many of the people that attended, and I know they are passionate, educated on the issues, and highly involved, but a closer look at the numbers is in order. Even if we sum the attendance of all public meetings pertaining to the REGPA, the total of 145 people (page 42) results in a survey response rate of just 0.8%. Concerning person-to-person survey metrics, a response rate of 80% is considered acceptable. Now, if we are to determine community involvement – as the REPGA does – simply by opening poorly-advertised meetings to public attendance in a county of 18,000 far-flung people, then this is the only statistically relevant math that can be derived from such actions. Obviously, a response rate of 0.8% is so low that it is only mentionable because of its inadequacy, and nothing more, and the margin of error falls exceedingly far outside that of acceptable measurements. Perhaps an argument could be made that the response rate was actually near 100%, in that nearly everyone in attendance at these meetings provided a response to the questions posed. As tempting as this argument is, its soundness fails on the grounds that it doesn’t take into consideration the appropriate measurements of statistical accuracy. The proposals in the REGPA concern lands across all of Inyo County – and thusly all of its citizens – which, given the attendance of 145 concerned citizens, results in a responding population base of only 0.8%. Again, this becomes statistically insignificant based of the realities of the numbers available. These basic measures highlight both the need for significantly better ways to involve the public on important County issues, and that the conclusions made by the REGPA concerning community support and its affect on the document are simply wrong. It should give elected officials pause to know that the documentation they’ve been given states one reality concerning the voices of their constituents, and in actuality proves to show the exact opposite.

Second, the plan states that “the county and its citizens are in support of renewable energy development.” Let us take a moment to consider the evidence, and the meaning, of this important statement.

Even if we disregard the statistical insignificance of the responses included in the REGPA documentation and take them at face value, the numbers do not at all support the claim that we, as a county, are “in support of renewable energy development” as it is being proposed. As the data is presented, mistakes could be easily made regarding the public’s support of renewable energy development on Owens Valley Land. Tables were included that divide responses into neat and easy “yes,” “no,” and “maybe, [but] I need more information” categories. It is vitally important to fully understand the verbiage of how these questions were posed: The responses provided in the REGPA have nothing to do with public support for energy development; they are simply the result of asking community members if the materials presented at the public meetings were “an appropriate evaluation tool” for the topics at hand. This circuitous language is best understood by applying the same assessment methods to different criteria: As a music teacher, my students make a recording of their first read-though of a new piece of music. Obviously, this performance would be very rough and not refined. Later, after two months of rehearsal, the same group records their final performance of the piece. This recording would be, in comparison, much more polished, detailed and good. Now, if I played both recordings for you, and then asked whether or not the two provided an adequate evaluation tool as to which was the superior performance, obviously your answer would be “yes – I can evaluate the difference based on these two recordings.” Note, however, that at no point did I ask you which was the better performance, or which was the performance you preferred. Therein lies the danger in how the materials are presented in the REGPA concerning community support – it is not documented support for the issues at hand, but the acknowledgment that the materials presented to the public were adequate evaluation tools, and nothing more.

Thankfully, true measures of support are actually presented in the REGPA, albeit much further into the document. On page 32 of appendix C, the most important data concerning community favor is presented in a table, and the consensus among those who participated is that the vast majority of Inyo County is not suitable for large-scale renewable energy development. Based on documented commentary by local agencies such as the Manzanar Committee, the Owens Valley Committee, numerous editorial letters, stories in local and national news, and the inclusion of letters from other concerned citizens in the REGPA itself, this consensus is supported by a significant majority of the population of Owens Valley and Inyo County at large.

Therefore, even if we disregard the statistical insignificance of the numbers at hand and the absence of their relation to the proclaimed “support of renewable energy development,” the data presented still proceeds to show that the support of such development simply doesn’t exist. The information presented by the REGPA proves that the statistical realities of public support have no relation to the issues at hand, and only provide a cursory relationship to the evaluative properties of the characteristics provided; the documented public involvement speaks to an undeniable opposition towards large-scale energy development in Inyo County. If the community is to develop “visions, goals, and policies” through a “thorough public process,” then based on numerical realities presented in the REGPA it is painfully evident that no such process was adhered to in the organization of the document.

The only possible conclusions, therefore, are as follows: One – that the math is fundamentally insufficient to be used as a basis for policy proposals and decisions, and two – that the public input (a core element of how these proposals were constructed) proves to be the exact opposite of what the REGPA claims it is. Please understand what the unacceptable nature of this document’s logic implies: that approval would mean the Board is perfectly fine with unsound and reckless policy-making, and that the Planning Department creates large-scale general plans that are full of gaping structural holes and disregard for the very rules that were used to create them. I don’t imagine either entity is looking to publicly make a habit of acting in such disreputable terms. If the Board of Supervisors is willing to adopt policies that blatantly disregard the community’s input – the very people for which you’ve been elected to be the political voice – I, and many others, would be deeply concerned for the well-being of our County. I would ask the Board of Supervisors to be highly skeptical of documentation that espouses semantic tactics such as the ones at work here, and I would ask the Planning Department to hold themselves to a higher standard of discourse in their future proceedings.

But enough with numbers. We all know the real issue at hand is how we treat our County, the place we call home. It should raise a number of red flags when we turn over the processes of large-scale development to entities that are far removed from our own geographical location. Page 34 of the REGPA documentation lists the proposed and potential projects, and nearly all include the involvement of national and international energy corporations that have nothing to do with the daily workings of our County. It is true that such entities must follow a standard course of action pertaining to permits and legal oversight (a procedural highlight, to be sure, of the REGPA documentation), but past experience has proved that massive corporate bodies have plenty of ways to circumvent such regulations. Projects include those by Northland Power, LADWP, Brightsouce, and other undisclosed entities. I firmly believe that we, as citizens, know what’s best for our valley, and turning over development to foreign corporations is a recipe for disaster. History proves to be on the same side, if we consider our County’s past concerning water rights and the export of natural resources. Given our place in determining our possible course of action, we have an incredible opportunity to act in support of the long-term well-being of our home, something that the officials of the past would most certainly have given anything to be part of, in retrospect.

Item 22.7, on pages 39-42 of the REGPA, explicitly states that Inyo County is “a land of scenic beauty” and that it’s “hard to find a place in the County without a view of a dramatic landscape feature.” I whole-heartedly agree, and it is telling that such wording would be included in the governmental proceedings of a county and their concerns pertaining to the development of such a unique and delicate western locale. But as much as we love these characteristics of our home, there are dangers in adopting policies based on such abstract language. I believe that the eastern side of the valley and the Inyo Range rival the Sierra in their beauty and and visual impact. Someone not so inclined to more arid landscapes may disagree. But, as you can see, making broad and sweeping policy decisions based on what we deem to be “scenic resources” can be problematic and must be approached cautiously. If we are to act politically based on what we see as important physical landscapes and their intrinsic, emotional, or even spiritual magnitude, then the only way to do so is by the involvement of knowledgable experts and the public at large – those that are most closely tied to said landscape. We cannot expect outside entities, like the energy corporations proposing projects in our county, to make accurate decisions about the environment they will potentially forever alter, and we should be extremely hesitant to give them such power. These are the decisions of true locals – those who know and love the land. “Scenic beauty” has been written into the REGPA; those that know it best are those whose voices are most vital to the argument. At this point, if the language is removed, it will be unequivocally seen as a blatant disregard of our County’s most important characteristic: its astounding natural environment. South County contains landscapes that draw visitors from across the globe; we now have a chance to uphold the sanctity of that beauty, or open it to the development and desecration of outside entities. It is my hope that everyone involved in the policy-making of my home takes this into consideration.

On page 2 of appendix B of the REGPA documentation, it states outright that “the term ‘environment’ includes the ecological environment of the county as well as the social, aesthetic and economic environment of the county.” It continues: “Impacts upon the quality of life within the county are considered environmental impacts. Therefore, the definition of environment is not limited by and may be broader than environmental considerations under the California Environmental Quality Act or the National Environmental Policy Act.” To reiterate: the verbiage of the document at hand is stronger than that of CEQA, pertaining to environmental well-being. Our quality of life is inexorably tied to our natural landscape and environment, including our status as a travel destination throughout the world because of that landscape. Large-scale development would forever alter this indispensable characteristic of our home.

This leads us to an incredibly important question: If we don’t allow large-scale developments, what do we do instead? There are state- and federal-level initiatives that require our direct involvement in renewable energy. Thankfully, the answer to this question is built into the REGPA itself. All we need to do is commit to the specifics already in place.

As I have shown, the citizens are significantly opposed to large-scale, industrial energy development in Inyo County. The logic tells us that the the REGPA’s claims concerning community support for it are not sound, and that the proposals of the REGPA fail to meet the standards set by the document itself. Characteristics such as these make for policies bound to fail. The document does, however, show us that ideas such as rooftop solar and small-scale, individual plans are supported. As the REGPA states, rules regarding small-scale developments are “already adequately addressed by existing County regulations (page 47).” As a community, we need to commit to these ideas. It isn’t far-fetched by any measure that we could be a lamppost for the development of more efficient and cutting-edge small-scale energy implementation that also leaves such delicate and beautiful landscapes untouched. This course of action may be more difficult than simply handing over the reigns to large corporations. But: since when have significant hurdles hindered our love for the well-being of our home? We have always been the underdog – the other, unrepresented side of the coin when it comes to the “greatest good for the greatest number.” And it is our strength and concern for our valley that keeps it protected and pristine.

On the home page of the Planning Department’s website, it states that they are “charged with the orderly growth and development of the County while maintaining its quality of life and natural environment.” Now is the time to live up to that statement, remembering that “[i]mpacts upon the quality of life within the county are considered environmental impacts.” Our quality of life is inexorably tied to our landscape and its continued well-being. To the members of the Planning Department: I ask you why, in all honesty, you want our valley and county to be forever changed by industrial development. To the Board of Supervisors: I ask you to make yourselves part of a history that future generations will look back upon and see your commitment to the protection of one of the world’s most unique and precious landscapes, and its people. I have given multiple reasons why the proposals of the REGPA should be dismissed simply on the basis of unsound logic; the most important decisions, however, lie outside of those measures. The most important decisions are the ones we make of our home and our community, for generations to come, within immeasurable circumstances. The community has spoken; I have the utmost faith that those charged with the policy decisions of our County will uphold the voice of the people and, most importantly, the unspoken voice of our land itself.


Thank you for your time, and regards -

Bryan Curt Kostors

Independence, CA




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