Inyo County Planning Commission:

The Independence Civic Club appreciates the opportunity to participate in the development of the REGPA as a stakeholder.  Renewable energy development has the potential to radically transform the Inyo County landscape with economic and social, as well as environmental, consequences.  Because of the implications of widespread renewable energy development, it is critical that the public have adequate time and opportunity to meaningfully read and analyze the documentation.  Insufficient time was provided for this prior to the deadline for submission of comments on February 19 in preparation for the Planning Commission meeting on February 26, 2014.

In general we find that the documents reviewed do not reflect the values we expressed and heard others express at the various public venues conducted by Planning Department.  It is our belief that Inyo County’s public is overwhelming opposed to siting large-scale renewable energy facilities in much of the County, damaging as it would be to the tourism-based economy that we rely upon, and destructive of the ecosystems and beauty of the County.  On the contrary, Inyo’s citizens seem to support distributed solar and small feed-in tariff plants sited on disturbed lands.  Yet the REDAs outlined in the backup material for the Planning Commission meeting of February 26, 2014 include areas of spectacular natural beauty such as Deep Springs, Centennial Flat and the Southern Owens Valley.  The REDAs should be reevaluated and reduced to realistic sizes on lands that have already been disturbed, and with a focus on small facilities.

It also appears that the evaluation of scenic values is arbitrary in these documents.  For some unimaginable reason, the area on the west side of Highway 395 in the Owens Valley has been declared scenic, while the east side of the Highway is considered of low value, though the Deepest Valley is a continuum of beauty, and a spectacular world-class landscape.  Further, much attention has been paid to the “Scenic Highway” designation, as though a highway doesn’t become scenic until a political designation makes it so.   If all of Highway 395 has not been declared scenic, then that is an oversight of the body that makes that designation, and should be corrected.

It is proposed that the County seek compensation if renewable energy facilities are NOT developed for various reasons.  However, if large-scale renewable energy facilities ARE developed there will likely be fiscal impacts to the County in the provision of various services, such as law enforcement, public works, etc., resulting in a net increase in cost to the County for encouraging such development.  Further, the installation of industrial scale solar or wind facilities will negatively impact businesses that rely on the tourist economy.  Tourists don’t visit Inyo County to see industrial sites.  They come for the world-class vistas, spectacular Inyo and Sierra Nevada mountains, undamaged open spaces and National Parks.  The network of tourist-based small businesses in Southern Inyo County may need to seek financial wholeness from those responsible for permitting this kind of renewable energy development.  Although this is partially addressed at the bottom of page 39, there is no implication that a business owner may be able to recapture lost future revenues.  Also, housing values may decline in areas with industrial solar and wind sites.  Provision should be made for the County/developers to compensate homeowners for a reduction in property values due to the encouragement of this kind of renewable energy blight.

It doesn’t appear that attention was paid to the impact of climate change on species migration, particularly with desert tortoise and Mojave ground squirrel.  It is likely that species will move northward as the climate warms, increasing the range of various species into the Owens Valley.  The Owens Valley REDA overlies the area that will likely be future habitat for those species.

The documents don’t seem to address the impact that large solar facilities appear to have on birds and insects, both the apparent confusion these animals have about photovoltaic panels and water, leading to death, and the death of birds in the heat produced by other types of solar facilities.  The Owens Valley REDA is in a portion of the Pacific Flyway and adjacent to the Lower Owens River Project, and conflicts with animal life are likely.

All of the Owens Valley lies either within the Owens Valley Land Management Plan area or the Lower Owens River Project area, prescribed and defined by the Memorandum of Understanding that, together with the 1991 EIR and Water Agreement, provide a legal framework for oversight of LADWP lands under the purview of various parties.  The Owens Valley REDA is in conflict with these legal agreements.

Inyo County encompasses some of the most spectacular scenery in the world – from Shoshone and Death Valley in the southeast to the massive wall of the Sierra Nevada in Southern Owens Valley.  It has been the inspiration and subject of artists such as Ansel Adams, Maynard Dixon, Galen Rowell, Ferdinand Grofe and Mary Austin, who have ennobled the vistas of Inyo through their creations.  It is our treasure to enjoy now, but our duty to ensure that future generations of creators can continue to see the magnificence of nature and feel the wonder and humility of Inyo, to produce new works of inspiration.  And yes, scenic wonders and beauty are the economic drivers of Inyo County.  Preserving those rare attributes make economic sense.



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