941 E Ridgecrest Blvd

Ridgecrest, California 93555



November 5, 2013


Ridgecrest City Council

100 W California Ave
Ridgecrest, CA 93555

Re: Fremont Valley Preservation Water Bank and Solar Project


Dear Council,


National Public Lands News has written several letters regarding this project to address our concerns about various aspects of the DEIR and data in the Appendices for this project.


It is apparent that this DEIR is extremely incomplete in spite of its many pages. Basic problems such as water, subsidence, air quality, and biota data have been given superficial examination. These issues need to be addressed and careful, complete studies done before this project moves forward. Therefore, we are requesting that Ridgecrest take a closer look at this project.


The issue of blowing dust needs to be addressed immediately. The only mention of dust emissions for the project deals with vehicular traffic during the construction phase of the solar project. However the fallow agriculture lands have contributed greatly to the dust storm events existing already in the project area. What about the long-term wind raised fugitive dust and dust storms and the resulting PM 10 impacts? How will they be addressed? Kern County Air Pollution Control District Rule 402 Fugitive Dust, is a rule designed to limit the emission of fugitive dust from multiple sources using required methods and practices such as road treatments to limit silt loading, specific construction scheduling, erosion controls, wind and water emissions, and removal of bulk storage piles. Rule 402 applies to owners or operators of unpaved and paved roads used for industrial activity, construction and demolition activity, industrial fugitive dust, activities on BLM land, and disturbed surface areas on public land. All of these items need to be addressed.


We would like to suggest that the proponents of this action use the Kern County Guidelines for Preparing an Air Quality Assessment for Use in Environmental Impact Reports, dated 12/01/06 (the website is Guidelines.pdf), and subsequent air pollution controls.


We would also like to suggest that before the Projects start, a portable PM-10 Monitoring Station be installed at each site for 6 months before any work starts, during construction, and for the duration of the projects. Please refer to Guidelines of California Air Requirements under section 189 (d) as necessary for the area.


This DEIR does not address the issue of airborne contaminants from the proposed water banking/percolation ponds (fifteen hundred acres in total). There will be times when the recharge ponds will sit empty with dirt on the sides and bottom that will be subject to blowing away. Do your mitigation measures include covering the ponds to control the dust when they are empty, and cover over the ponds when they are filled with water to prevent harm to native and migratory wildlife, and prevent the spread of West Nile virus?


There is no mention in the DEIR of the military air corridor, R-2508, that has been created between Edwards AFB, China Lake NAWS, and Fort Irwin. Blowing dust and scattered light pollution from solar fields will negatively impact the mission of all three of these military installations. Typical activities within the R-2508 complex include: aircraft research and development in all stages of flight; operational weapons; test and evaluation flights; student pilot training; air combat maneuvering (ACM) and proficiency flights; civilian test aircraft in direct support of DOD and/or defense testing. Test operations must remain flexible and air space requirements are not entirely predictable. Activity within the R-2508 complex is not limited to scheduled aircraft. General aviation aircraft fly unrestricted with visual flight rules (VFR) within the R-2508 complex. The future of the Inyokern iDEA iHub project would also be negatively impacted. These issues need to be addressed in the DEIR.


The cursory treatment of Valley Fever in this area is against health and safety concerns. The DEIR states that masks will be provided to workers in this area and then goes on to say those residents in the area are immune to this spore. California City Residents have documented proof of the Valley Fever. Of the population in California, 60% has been exposed to this virus. Outbreaks in areas where large land areas have been scraped have been quite devastating to workers and the general and indigenous population. A medical screening of the local population should be initiated prior subjecting them to further risk.


We would like to point out to the Council and people of Ridgecrest that this is a DEIR with huge consequences. It will directly affect the tourism in this area.


Ridgecrest needs to look at the dust storms that are possible and how it will affect the R-2508 Air Space, the financial impacts on the Naval Weapons Center, City and Airport.


Please ask for an extension from Kern County to explain these items.


In cooperation,


Sophia Anne Merk, Director


cc: Kern County Air Planning

Kern County Air Quality Board