Mayor Eric Garcetti, City of Los Angeles
Dear Mayor Garcetti,
I am a resident of the town of Independence in the Owens Valley. Along with many other residents of Owens Valley, I am deeply concerned about the proposal by the Los Angeles Department of Water and Power (LADWP) to construct a 1200-acre industrial solar installation known as the Southern Owens Valley Solar Ranch (SOVSR) in an area rich in cultural resources and in the viewshed of the Manzanar Historical Site. Our concerns include 1) a precedent-setting change in LADWP land management focus in Owens Valley from watershed management to industrial development, 2) the approval process for this development, 3) the destruction of prehistoric and historic archaeological sites, and 4) degradation of the visitor experience and integrity of the Manzanar National Historic Site.
One hundred years ago, the Los Angeles Aqueduct was completed and water was delivered to the city. LADWP had acquired land and water rights, mostly in the southern part of Owens Valley, prior to construction of the Aqueduct. During the 1920s and 30s, LADWP acquired land and water rights in the northern part of the valley and now it owns about 90% of the taxable land in Owens Valley. Since 1913, LADWP has managed its land as a watershed which has been a mixed blessing. An agricultural-based economy gave way to one based on tourism and recreation. Unfortunately, the new economy has not provided the economic opportunities to prevent young families, particularly in the south County, from moving away.
On the other hand, there are small towns separated by open land that is spectacular and pristine. This is what Los Angeles and the Bay Area lost when they urbanized. Solar installations, once they are constructed, do not provide significant employment so the long-term benefit to the local economy is, at best, questionable. This development, along with those sure to follow if it is approved, will compromise the attractiveness of Owens Valley for tourists and recreationists and will damage our fragile economy.
The decision-making process for SOVSR is flawed. LADWP claims it is exempt from Inyo County ordinances and zoning as provided by the California Government Code and is the lead agency under CEQA. Thus, the developer is the lead agency which is an obvious conflict of interest. On October 1, 2010, LADWP released a Notification of Preparation for an EIR for two potential solar sites in southern Inyo County, one near Owens Lake called the Southern Site and the Northern Site at Owenyo, and held the required scoping meeting in Lone Pine on October 28, 2010. In August 2013 LADWP released a Draft Environmental Impact Report (DEIR) that proposed a new site on the east side of Owens Valley directly across from the Manzanar National Historic Site, surprising everyone.
LADWP should have issued a new NOP when it was decided to propose a new site. If LADWP had done so, it would have learned at the scoping meeting required by CEQA that the new site is far more sensitive than the Southern Site. Now we hear from LADWP Director of Systems Planning and Development Randy Howard that he is “personally surprised at the level of their comments” after hearing of the criticisms of the new site from the Los Angeles based Manzanar Committee. It is not surprising that the flawed process produced a flawed DEIR. Instead of an objective analysis of the environmental impacts of the development, it is a shoddy, contrived document intended to justify a decision already made by LADWP management.
On page 2-6 of the DEIR it is stated that field surveys have determined this site has a lower density of cultural resources than the alternative sites. A letter to LADWP regarding the DEIR from the State Historical Preservation Officer Carol Roland-Nawi, stated, “Overall the DEIR for the Southern Owens Valley Solar Ranch fails to properly address the identification and treatment of historical resources.” She concluded, “I strongly urge LADWP to appoint a third party to review the Cultural Resources section in the Southern Owens Valley Solar Ranch DEIR and supporting technical documentation.” Hopefully the third party would be an independent one. Comments on the deficiencies of the DEIR by qualified experts, too voluminous to discuss here, have been sent to LADWP and clearly show significant prehistoric and historic archaeological resources will be destroyed if the project is allowed to proceed.
The aesthetics analysis asserts that the view of the site is intermittently obscured by vegetation. This is simply not true. There is an unobstructed view of the site from almost everywhere in southern Owens Valley and the surrounding mountains. LADWP says the view of the site from Manzanar and Highway 395 will not be significantly impacted by this development. Former Manzanar internees and their families, as well as those of us who live here and look across the valley at that site every day will tell you that this, also, is simply not true.
This proposal by LADWP is a display of cultural insensitivity to the Japanese-American community that is astonishing for a city as diverse as Los Angeles. Thirty-one people, many of them former internees or descendents of internees spoke in opposition to this project at a public meeting on a Saturday morning in November at the LADWP headquarters in Los Angeles. No one spoke in favor of it. They told what visiting Manzanar meant to them and how vital the desert views are to their experiencing what is was like for family members who were incarcerated. They pleaded eloquently and emotionally with the LADWP officials to leave the viewshed as it is. I hope the message will be heard.
I urge you to do whatever you can to encourage LADWP to withdraw this proposal.
David L. Wagner