Dear Supervisor Tillemans:

I spoke at the March 18 workshop, and appreciated the opportunity to address the Supervisors, members of the Planning Department, and the public with my concerns about the REGPA.  As I expressed then, my concern about the REGPA is related to my deep attachment to this county, especially to Death Valley National Park and to the Owens Valley.  I am writing to elaborate on my opposition to the proposed Renewable Energy General Plan Amendment (REGPA).

While I support renewable energy planning, I do not believe that the proposed REGPA is the right vehicle for this.  A major shortcoming is its failure to abide by many of its own stated criteria for exclusion in determining renewable energy development areas (REDAs) listed on page five and six.  I am particularly concerned by the REGPAs failure to exclude cultural and historic resources and scenic resources.  These were some of the most popular criteria for exclusion at the public outreach meetings late in 2013, and are also major reasons for public opposition to the proposed Los Angeles Department of Water and Power Southern Owens Valley Solar Ranch within the Owens Valley REDA.

I also wonder why the REGPA is not more aligned to the stated purpose of the Desert Renewable Energy Conservation Plan (DRECP) in which Inyo County is participating, which is to: “help provide effective protection and conservation of desert ecosystems while allowing for the appropriate development of renewable energy projects.”  Other participants in the public outreach meetings late in 2013 appear to share a concern for ecosystems, as page six shows that participants added seeps and springs and wildlife corridors including avian and insect migration corridors to the list of criteria for exclusion they believe should be applied.  It is unclear how or whether the criteria of protection and conservation of desert ecosystems are applied in the mapping of the REDAs in the REGPA.

The failure to exclude cultural, historic, and scenic resources and to protect and conserve desert ecosystems seems obvious when examining the REDAs included in the preferred alternative.

The REDA detailed on page 12 contains much of the southern Owens Valley located east of Highway 395.  Designation of this area as a REDA is entirely inappropriate.  Multiple scenic, historic, and cultural resources are included in this REDA, including: the view from the Sierra Nevada Mountains and their wilderness and trails; the view from the Inyo Mountains and their wilderness and trails; Paiute and other historic and archeological sites; and the historic viewshed of the Manzanar National Historic Site, a place of pilgrimage and learning and a unit of the National Park Service drawing approximately 85,000 visitors annually.  The Lower Owens River Project (LORP) within this REDA and related draft Lower Owens River Recreation Use Plan seem incompatible with energy development.  I have helped with bat monitoring outside abandoned mines in the foothills adjacent to or in this REDA, and want to see research into the impact designation could have on bats and other wildlife that rely on the REDA for food, water, or shelter.

The REDA detailed on page 13 contains the Owens Lakebed.  I am ambivalent about this designation.  The lake is an intensely disturbed area, an important element in favor of consideration for energy development.  It is, however, also habitat for migratory birds, including some rare ones like snowy plovers, burrowing owls, and eagles.  In a potential benefit to local humans, this holds economic possibilities for ecotourism.  Any consideration of designating the Owens Lakebed as a REDA should be accompanied by documentation about its resources and serious study of how and whether development could couple with protection of the wildlife that relies on the place.

The REDA detailed on page 14 contains Centennial Flat and Darwin.  I share the National Park Service’s concerns about impacts on views from Death Valley National Park if this area is designated as a REDA.  Wildlife does not recognize planning boundaries and construction projects introduce exotic plants, so I worry also that designation as a REDA would negatively impact wildlife reliant on Death Valley National Park and the surrounding public lands for food, water, or shelter and would introduce exotic plants and threaten native ones.

The REDA detailed on page 17 contains the southern part of the Panamint Valley.  I share the National Park Service’s concerns about the impacts on views from Death Valley National Park, and have concerns about the impact on area plants and wildlife.  The very place names in this REDA: Nadeau Road, Indian Ranch Road, and Wingate Road, suggest ties to resources significant to mining, commerce, transportation, and land use history in Inyo County and beyond.

The REDA detailed on page 19 surrounds Death Valley Junction.  I share the National Park Service’s concern for this area of how the designation as a REDA will impact the endangered Devils Hole pupfish.  Additionally, Death Valley Junction is replete with cultural and industrial historic resources.  Thankfully, the Amargosa Opera House appears to be left out of the REDA.  The historic complex it was part of before Marta Beckett’s colorful involvement with the site, however, extends east of Highway 127 and into the REDA.  Noted western author Zane Grey visited and wrote about this complex, associated with area mining and industry, early in the 20th century.

Throughout, I am concerned by the absence of citations and analysis of the biological, historical, cultural, scenic, and archeological resources within the REDAs.  I know from personal experience with the REDAs cited above that there are conflicts with cultural and historic resources, scenic views, and habitat.  I have not, however, engaged in anything approaching the level of biological or historical survey and contextual study that I would expect of anyone making land-use planning recommendations about the areas.  The absence of sources and analysis in the REGPA makes me wonder what kind of study the authors conducted to justify their selection of the REDAs.  My casual existing knowledge and the public comments that I reviewed make me suspicious about potential conflicts within the other REDAs, as well as the depth of conflicts in the REDAs that I site in this letter.

I would appreciate clearer mapping of the REDAs that includes property lines for parcels managed by the Los Angeles Department of Water and Power, National Park Service, Bureau of Land Management, and Forest Service, as well as any Areas of Critical Environmental Concern, Desert Wildlife Management Areas, Wilderness, and Sensitive Species Areas.  Overlays on USGS quad maps would also be helpful.  Planning documents should always be specific about included and excluded geography.

The DRECP maps included in the REGPA are difficult to read online, but it appears that the disturbed land alternative shown on page 31 of the REGPA includes minimal Inyo County land meeting the criteria for inclusion of disturbed lands and low resource conflict.  This suggests that the amount of Inyo County land included in the REGPA as REDAs is inappropriate.

I reviewed the more than100 pages of public comments on the REGPA posted on the Inyo County Planning Department website.  Nearly all writers oppose the REGPA as currently proposed.  The first letter posted is from the Center for Biological Diversity and the Range of Light Group, Toiyabe Chapter, Sierra Club, the parties that threatened legal suit against Inyo County in 2011 for the earlier, similar REGPA.  The six page letter includes the phrase: “we strongly urge the county to start with a more realistic set of REDAs.”  As another participant pointed out in last week’s workshop, lawsuits cost money.  It seems counterproductive and expensive to adopt the current REGPA in the face of such intense opposition from both private citizens and organized groups.

Following last week’s workshop, I heard the Board of Supervisors express interest in pursuing research and consideration of distributed generation solar development in Inyo County, possibly even as a County controlled revenue source.  I welcome that conversation, and hope it continues.  I attended the Owens Valley Committee fundraiser at the Mountain Light Gallery last night, and was encouraged by the possibilities raised by the featured speaker, Bill Powers, who is part of the coalition Solar Done Right.  Powers sited Marin and Sonoma as California case studies for responsible solar efforts.  I look forward to perusing Solar Done Right’s website, the efforts in Marin and Sonoma, and the initiatives Powers mentioned in his talk, particularly Community Choice Aggregation (CCA), passed by the California Assembly in 2002 and used in Marin, and the One Block off the Grid initiative.  I hope you will also take a look at these sources.

Thank you for your attention to my concerns with the REGPA and the multitude of other concerns expressed in writing and in public meetings.  I hope that on April 1 you will vote against adopting the REGPA as it stands, and will instead direct the Planning Department to research and  include less destructive models for renewal energy development and to analyze and deeply scale back the preferred alternative in order to protect lands possessed of ecological, historical, cultural, and scenic value from inclusion in REDAs.

Sincerely,

Kristen Luetkemeier

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