Letter to the Editor: Plea to LA’s Mayor

IFMayor 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.

Respectfully,

David L. Wagner

Independence, CA

, , ,

50 Comments
Newest
Oldest Most Voted
Inline Feedbacks
View all comments
Daris
Daris
8 years ago

I just saw a notice in the Inyo Register of an environmental impact notice for Munro Valley Solar south of Olancha near Walker Creek Road. More solor means more transmission lines. When will it end?

Ted
Ted
8 years ago

Nice to see some intelligent conversation going on…its refreshing.

Wayne Deja
Wayne Deja
8 years ago

Here is a funny one…..A while back,I was talking with a long-time LADWP employee,and during the conversation,he said DWP employees are actually official,trained Government workers,and “authorities”…..is that true ?…..am I missing something,or is that true ?….maybe it is,based on something I witnessed during a structure fire here in my town… Read more »

Benett Kessler
Benett Kessler
8 years ago
Reply to  Wayne Deja

DWP workers, per se, have no law enforcement authority. Although I have been told that there may be a few such workers somewhere. DWP has been very helpful in times of disastrous fires. Not sure of the situations you are referencing, but overall DWP has no authority to tell you… Read more »

Wayne Deja
Wayne Deja
8 years ago
Reply to  Benett Kessler

Benett….thank you….now I know……The fire I was mentioning,it was actually kind of disturbing how many “agencies” and “authorities” were thinking they were in charge….with a fire that,for a while,was getting out of hand and jumping from one house…then two,and almost a third….Kind of figured the Fire Department,ICSO,and maybe CHP were… Read more »

Benett Kessler
Benett Kessler
8 years ago
Reply to  Wayne Deja

I remember that fire. It was frightening. Certainly too many managers is not what is needed in such cases.
BK

Desert Tortoise
Desert Tortoise
8 years ago
Reply to  Wayne Deja

LADWP is a department of LA City government. It is not a business. They are municipal employees of the City of LA, but they have no law enforcement powers. You can tell anyone in DWP to pound sand and there is absolutely nothing they can do to you. As an… Read more »

Russ Monroe
Russ Monroe
8 years ago

Apologies Ken, I failed to address all of your questions. Posting a link to most of the information that I post here is not possible, as most of what I write about is my first hand observation. I go to DW&P public meetings and listen. If you need a link,… Read more »

Ken Warner
Ken Warner
8 years ago
Reply to  Russ Monroe

No problem. It’s a complicated topic that can look different from different angles. I don’t know enough about power generation and transmission to discuss it with any substance. I only know that we will need more and more electricity to match the needs of our growing population.

Russ Monroe
Russ Monroe
8 years ago
Reply to  Ken Warner

Yup Ken and the you ” know that we will need more and more electricity to match the needs of our growing population.” is where we disagree. I do not think that is the case, and my home is proof that it does not have to be the case.

Ken Warner
Ken Warner
8 years ago
Reply to  Russ Monroe

If you’ve figured out a way to live off the grid, my compliments. But what you did for yourself can’t be done by everybody. Many people don’t own their own homes or have the capital for what is needed. Many sites here in Mammoth Lakes don’t get Sun for very… Read more »

Russ Monroe
Russ Monroe
8 years ago

For an instant? While the sun is shinning, for a hour or two on either side of noon, is the only time a fixed solar panel will put out full, or rated, power. The sun does not shine on Manzanar for more than 12 hours a day, at most, and… Read more »

Steve
Steve
8 years ago
Reply to  Russ Monroe

What relevance are those numbers if no transmission lines are available to take the power out of this valley? Russ have you been out to the site, There are two transmission lines that run right past the site. One is a 500kv AC line and the other is a 200kv… Read more »

Russ Monroe
Russ Monroe
8 years ago
Reply to  Steve

Yes Steve, the lines are there. The issue is: are they full? In the EIR, DW&P claims to have just enough empty space to absorb the new source, but a few years ago they said that there wasn’t enough capacity left for even a small solar project. Which DW&P to… Read more »

Eastside Dweller
Eastside Dweller
8 years ago
Reply to  Russ Monroe

Russ, Hydro and gas combustion turbines are quick ramp and are often used to balance solar and wind power fluctuations. Nuclear and fossil fuel steam plants are slower, most efficient at full load, and best used for continuous baseline load.

Russ Monroe
Russ Monroe
8 years ago

Eastside, I agree that some hydro can, as well as the gas turbines, that we do not have here. Many improvements need to be made to integrate several intermittent sources locally. I am very much in favor of many forms of alternative energy, but the uncontrolled expansion of private grid… Read more »

Eastside Dweller
Eastside Dweller
8 years ago

Russ, agree local solar hookup policy is more than flawed, especially when compared to programs for LA ratepayers. Ratepayer Advocate and others actually criticized feed in credit as too generous. Isn’t the Barren Ridge upgrade project tied to opening up Owens Valley capacity by upgrading grid south of here? I… Read more »

Russ Monroe
Russ Monroe
8 years ago

Eastside; DW&P says that one of the reasons for the Manzanar location of the project is that they can tie into the Inyo-Rinaldi 230kv line which runs through the site. At the last meeting in Lone Pine they said that 200 mega-watts would fill that line to capacity. Of course,… Read more »

Eastside Dweller
Eastside Dweller
8 years ago

Russ, Interesting, if they don’t need on peak power, why do they need a solar plant at all? Probably just to meet “green” mandates whether they make environmental or business sense or not, as I have complained about here before. I’d be more than angry if I invested in solar… Read more »

Steve
Steve
8 years ago
Reply to  Russ Monroe

Hay Russ check this out. Looks like the work of making the old lines capable of handling the new power is already being done. This is America after all and as Americans we always solve problems. The Western Electricity Coordinating Council (WECC) and eight of its member transmission owners are… Read more »

Russ Monroe
Russ Monroe
8 years ago
Reply to  Steve

Yes, Steve, I am well aware of the possibilities. Improving controls is fine. Still does not address the issue here, of; offset power. I’m sure that the grid will improve. I’m also certain that it will have many sources to balance. In my opinion; paving the desert with silicon panels… Read more »

Philip Anaya
Philip Anaya
8 years ago
Reply to  Russ Monroe

The Inyo -Rinaldi Transmission Line that DWP would use for the SOVSR would be the 500 Kv AC Line. I’ve been told that there is a current available capacity on that Line of 240 mega-watts. (There is a lot of information In the 2011 and 2012 DWP Resource Plan. It’s… Read more »

Russ Monroe
Russ Monroe
8 years ago
Reply to  Philip Anaya

Philip your quote; “The Inyo -Rinaldi Transmission Line that DWP would use for the SOVSR would be the 500 Kv AC Line.” contradicts both what was said by DW&P at the last meeting in Lone Pine and the EIR from DW&P. That’s where my is my information came from. SOVSRP… Read more »

Philip Anaya
Philip Anaya
8 years ago
Reply to  Philip Anaya

You are correct Russ . Section 3.4 of the DEIR, page 3-25 “The facility would utilize LADWP’s existing 230 kV Inyo-Rinaldi transmission line to convey energy to load centers.” This is exactly why we need some expert consultants educating and informing everyone , not to say that there is no… Read more »

Russ Monroe
Russ Monroe
8 years ago
Reply to  Philip Anaya

Your welcome Philip.
Quoting Wikipedia is not something I would recommend.

Eastside Dweller
Eastside Dweller
8 years ago
Reply to  Philip Anaya

PA, You have confused some of the information about Barren Ridge. I also posted some links above. https://www.ladwp.com/ladwp/faces/wcnav_externalId/au-p-p-brrtp-FinalEISEIR?_adf.ctrl-state=13mrbalep5_4&_afrLoop=223615798656290 Castaic pumped hydro balances baseline steam generation and intermittent solar and wind. Stores excess energy and uses it at peak demand or when a cloud stops PV or wind dies. Mostly used… Read more »

Eastside Dweller
Eastside Dweller
8 years ago
Reply to  Philip Anaya

PA, my links seem to be failing. Use ladwp.com to about us to power to projects to Barren Ridge Renewables Transmission Project to EIR.

Philip Anaya
Philip Anaya
8 years ago
Reply to  Philip Anaya

Eastside D. Your link is working correctly. I had seen this link previously. The broad description on Wikipedia of the Castaic Power Plant Pyramid dynamic I thought would be adequete to describe the infrastructure of that portion of the grid that supplies Los Angeles. Thanks for suppling the link to… Read more »

Russ Monroe
Russ Monroe
8 years ago

Two hundred thousand homes? During a sunny day? According to: Wiki? No F minus for you here Ken; you can’t even turn that paper in for a grade. Your math is off by two thirds, if you use Wiki criteria, which no one should. My home has never been connected… Read more »

Ken Warner
Ken Warner
8 years ago
Reply to  Russ Monroe

So tell us all what are the correct figures? The Solar Ranch is a 200 MW plant. Wiki.answers says: One megawatt is equal to one million watts, so for one instant, one megawatt can power 1000 homes. 200 times 1000 is two hundred thousand. What are your calculations? And what… Read more »

Eastside Dweller
Eastside Dweller
8 years ago
Reply to  Ken Warner

Ken, you forgot hours of generation. 200 Megawatts divided by 200,000 homes equals 1000 watts or 1 Kilowatt per home. 1KW times 10 hrs of sun equals 10 KWH per home. 30 days times 10 KWH equals 300 KWH per month. Average California residential monthly bill is 573 KWH, about… Read more »

Russ Monroe
Russ Monroe
8 years ago

Point taken Eastside. Ignorance times stupidity makes for all kinds of disaster and we have no shortage of either one do we?

Ken Warner
Ken Warner
8 years ago
Reply to  Ken Warner

Now I understand what your point is. You two are talking about killowatt hours which is a different way to look at the capacity of a power source than the instantaneous killowatts. That’s a different — but valid — argument but not my argument. As for your concerns about the… Read more »

quack
quack
8 years ago

Highway 395 existed at the same time Manzanar did, though it was called something else. Manzanar extended all the way to the proposed site of the solar farm; internees worked over there at the dump and the sewage plant. Besides Manzanar, there are extensive archaeological resources on the proposed site… Read more »

Ken Warner
Ken Warner
8 years ago

Manzanar is not going to be touched in any way by the Solar Ranch which is 4 miles away an will be practically invisible. A million cars, trucks, RV’s and motorcycles drive by Manzanar on 395 yards away. Nobody seems to care about that. 37 people spoke out against the… Read more »

sugar magnolia
sugar magnolia
8 years ago

I’d like to hear more about their claim of being exempt from Inyo County ordinances. What is that claim based on? In Inyo County, LADWP is not a municipality, they are simply another landowner with no municipal jurisdiction. And as a utility company, they are not exempt from Inyo County… Read more »

Desert Tortoise
Desert Tortoise
8 years ago
Reply to  sugar magnolia

LADWP is not an investor owned utility company. The are a municipal department of a charter city. As a result they do not answer to the PUC and being a charter city, much of the government code that applies to general law cities does not apply to charter cities. Since… Read more »

Ben Holgate
Ben Holgate
8 years ago

Desert Tortoise does mental gymnastics everyone!

Deseert Tortoise
Deseert Tortoise
8 years ago

There are no mental gymnastics. When a city buys land in another county, called “going extraterrestrial” in the parlance of government agencies, the city is exempt from the regulation by the county in which it bought land. That is the California Government Code. You might want to familiarize yourself with… Read more »

Benett Kessler
Benett Kessler
8 years ago

DT, You may be certain, but lawyers in Inyo County are not. The County Counsel used careful language in the matter of LA abiding by local codes – saying something to the effect that this issue was up for question. Remember, courts do set precedence when issues are challenged. Depends… Read more »

Desert Tortoise
Desert Tortoise
8 years ago
Reply to  Benett Kessler

We had a discussion of that just last night at a city council meeting with those Kern County officials. The way the CGC is written, cities with facilites outside their city limits are basically exempt from regulation by counties on those properties. The county can try to fight an EIR,… Read more »

Benett Kessler
Benett Kessler
8 years ago

And what courts have to say about it.
BK

Ben Holgate
Ben Holgate
8 years ago

Your position is ridiculous on its face. As if a municipality has the right to engage in any enterprise within any other municipality without any regard to zoning or other processes. I don’t think you even believe it but we won’t know that because you won’t put your name to… Read more »

Mary Roper
Mary Roper
8 years ago

Agreed. But, the City of Los Angeles does operate under its own General Plan. In fact there is a whole section concerning the Owens Valley, and on page 56 of the 85 page “Conservation Element of the City of Los Angeles General Plan”, there is this statement: “The city is… Read more »

sugarmagnolia
sugarmagnolia
8 years ago
Reply to  Mary Roper

one cannot give themselves jurisdiction. They can say whatever they want in their general plan, it doesn’t make it fact.

sugarmagnolia
sugarmagnolia
8 years ago

DT – so you are saying that the town of mammoth lakes could purchase property in Inyo County, possibly even in the city of Bishop and completely ignore set backs, zoning, general plan…and build whatever and however they wanted to? That just makes no sense. Cities and Counties would be… Read more »

Desert Tortoise
Desert Tortoise
8 years ago
Reply to  sugarmagnolia

no. Mammoth Lakes is a General Law city subject to the California Government Code. Los Angeles is a Charter City, and is defined by the State Constitution Article 11. Read this pamphlet: http://www.municode.com/webcontent/statelawpamphlets/CA.pdf Because LA is a charter city, LAs laws supersede all laws that conflict with it’s own unless… Read more »

sugarmagnolia
sugarmagnolia
8 years ago
Reply to  sugarmagnolia

Thanks for code citation DT….as Benett says, we’ll see what the courts rule, as that seems very subject to interpretation. I would read that as applying to LA lands within the county that the city resides in…ie.where the City has jurisdiction, its law may supercede the Counties or even the… Read more »

Mongo The Idiot
Mongo The Idiot
8 years ago

LADWP:

The Utility of Modern Conflict.

Philip Anaya
Philip Anaya
8 years ago

Mr.Wagner,
Thank you for sharing your excellent letter . This is exactly what Mayor Garcetti and the people of Los Angeles need to hear, an accurate and precisely written presentation of the past and present history of DWP in the Owens Valley . You sir are a great communicator