Appendix C – Fremont Valley Preservation Project


Cancellation of 3, 315 acres that are under Williamson Act contract

p. 4.2-17 (p. 1224) Notice of non-renewal.  However, project site would be allowed to return to agricultural use at the end of operating life of facility.  Conversion of project area back to agricultural uses


p.4.2-20 (p. 1227) The impact is considered significant and unavoidable.  Cumulative loss of Williamson Act and agricultural lands resulting from proposal project, when combined with other proposed projects in the County would also be considered significant and unavoidable.


While we deplore the loss of agricultural land in a state that is the nation’s top agricultural producer, we do understand that no agricultural production has occurred on the site in over eight years.  We approve of the conversion of the project area back to agricultural use at the end of the operating life of the facility and the removal of all project facilities.


Appendix D – Fremont Valley Preservation Project


p.5 (p. 1241)) “Fremont  Valley has been identified as an area in which groundwater withdrawal has caused the development of earth fissures.  Large tension cracks associated with localized differential subsidence resulting from groundwater withdrawal have been observed in the Fremont Valley area (Holzer 2005).”


pp.8 and 9 (pp.1244,1245) “Sons property may have a potential to be impacted by debris or mud flow associated with flash floods from Jawbone Canyon west of the property.  Brothers property may be impacted by debris or mud flow associated with flash floods from Red Rock Canyon southwest of the property.  Cantil Property appears to be located in the path of an un-named alluvial fan wash.”


p. 1262 Figure 13; p. 1263 Figure 14 Flood flow maps and diagrams


Description of pipeline construction to allow for effects of potential damage for ground movement in fault zone areas.

p.1331 “Shut-off valves on either side of the Fault Rupture Hazard Zone should be included to minimize water jetting and erosion should the pipelines rupture due to fault movement.”


Impacts from flash floods as shown on flood flow maps and diagrams in Appendix J Flood Analysis represent a potentially significant impact.  Appendix C to Appendix J – FEMA Flood Zone Exhibits pp. 6648, 6649, 6650 6651.  Appendix D to Appendix J – Model Results pp 6656, 6657, 6660, 6661, 6664, 6665, 6668, 6669.



Appendix E – Fremont Valley Preservation Project


p. 1425  Letter Addendum about project decommissioning.  Project completed in 2017- decommissioned in 2042.


p. 11 (p. 1694)  CARB air monitoring stations – Barstow, Trona, Lancaster, Mojave.


p. 25 (p, 1708) PM10 fugitive dust emissions – main source will be from vehicular traffic – less than significant level.  What about wind blown dust and sand; windstorm events?


p. 36 (p. 1719) “ Proposed Project together with all other planned solar projects within Kern County portion of the Mojave Desert Air Basin and planned non-solar Projects located within a six mile radius could result in potentially significant cumulative impacts during construction.  Additionally the subject Project’s contribution to cumulative impacts would be cumulatively considerable because the construction emissions alone would exceed EKAPCD and Kern County significance standards.”


p. 28 (p. 1711 Project will pose an extremely minute impact on regional ozone and :M10 formation.  With mitigation measures – regional contribution to these cumulative impacts will be almost negligible – Project is not cumulatively significant with regard to regional impacts.  What about site specific impacts?  Address wind events and highly erodible soils. 


p. 33 (p.1716)  No cumulative emissions thresholds have been established by EKAPCD.


p. 36 (p. 1719)  impacts are combined with all other solar projects in Kern County


p. 45 (p. 1728) Suggested PM10 Mitigation Measures  “Streets adjacent to Project site should be kept clean and accumulated silt removed – assure compliance during grading and construction phases –What about implementing this measure at other times – after windstorms?


Air Quality section of Draft EIR


p. 4.3-4 (p. 435) EKAPCD is classified as non-attainment for the state 24 hour PM10 standard


P. 4.3-9 (p. 440) Discussion of health impacts of PM10


p. 4.3-19 (pp. 450-452)  Discussion of Valley Fever


p. 4.3-22 (p. 453)  Kern County portion of Mojave Desert Air Basin MDAB is designated as non-attainment for the state ozone and PM10 standards.


p.4.3-52 (p. 483)  Valley Fever – long term residents have typically already developed immunity to Valley Fever.


p.4.3-55 (p. 486)  when construction of proposed solar project ceases, significant cumulative air quality impacts would also cease.  What about long term wind raised dust and dust storms creating PM10 impacts? P. 4.4-2 (p. 490) dry winds in excess of 25 MPH in late winter and early spring


p. 4.4-23 (p. 511)  Site 1 Homes – barbed wire and sheep fencing surrounds the site, with much of the fencing deeply buried by wind-drifted  sand.


p. 4.4-25 (p. 513)  wind erosion is significant issue on Site 2 Sons blowing sandy soil into drifts as deep as roofs of abandoned houses.


P, 4.4-28 (p. 516)  Site 4 Randsburg/Saltdale – largely windswept sandy barrens.  Sands have blown high enough to create drifts and bury many of the fences.

Biological resources section of Draft EIR


p. 4.4-66 (p. 554) Project operator shall purchase suitable habitat as compensatory mitigation for impacts to Desert Tortoise and Mojave Ground Squirrel


p. 4.4-76 (p. 564)  Proposed water storage basins on project sites may proide an attractant to both migratory and resident birds into close proximity with interior collection and supply power lines


p. 4.4-78 (p. 566) Would result in significant and unavoidable contribution to cumulative loss of habitat for special status species that may utilize habitat at the project area


p. 4.4-79 (p. 567) cumulative impacts would be significant and unavoidable for loss of habitat.




Notes prepared for Eastern Kern County Resource Conservation District   October 17-23, 2013

by  President Donna C. Thomas