National Public Lands

941 E Ridgecrest Boulevard

Ridgecrest, California 93555


June 27, 2013


Mathew Hall, Kern County Planning and Community

2700 M Street, Suite, 100

Bakersfield, CA 93301


Reg Oro Verde Solar Project by Sun Edison, LLC (pp12205)


Dear Mr. Hall and Ms Andrea Brewer-Anderson


Since 1999 National Public Lands News, a non-profit organization dedicated to informing citizens about their public lands, has provided comments to BLM and Kern/Inyo and San Bernardino Counties regarding NEPA and CEQA documents.


I have personally provided comments to Kern County planning since 1980 and our organization would like to be added to your list of interested stakeholders.


We were just notified by the BLM at one of our citizens Round Table Meetings that comments were due on this subject.  We realize that we are late in the input of our scoping comments to Kern County, but hope that you will address our items in the EIS/EIR to follow, as they will be submitted under the time limit for Edwards Air Force.


  1. Under the Proposed Action (2) the lease will be on federal lands.  Our question is are they fee lands or does it involve surface and subsurface lands.  After looking through the document I was unclear.  This needs to be legally clear.


  1. Under the Proposed Action (2), it goes on to say that it will be from 150 to 450 MW.  The area involved between the acreage involved leaves one deficient in implication and scope of the project.  By saying it will be 150, and then saying it will be 450 MW (area) it is segmenting NEPA by piece milling.


  1. Under #5 Scope of the EIS/EIR Analysis it states that Cultural Resources will be analyzed.  However this area is within the CDCA and one more value needs to be looked at, i.e. Native American Values. 


  1. Under Alternative B is states that it will be “decommissioning” a solar facility that already includes 1500 acres.  While looking through the document, again it is not specific on the difference in acreage.  So will the facility be the possible 4000 acres plus the 1500 acres.  Again, after looking through the document, we were very unclear.


  1. After looking at Alternatives A and B, it is quite logical to deduce that the footprint will be over 6000 acres which is not represented at the initial analysis of the proposed actions.


  1. We have some concerns that the unincorporated areas are being overlooked in conjunction to cumulative impacts.


  1. A Joshua Tree Mitigation measure needs to be tied in the analysis and more concern should be looked at in regards to grading of more desert lands.  This year the air quality has been detrimental to the towns of Mojave, Rosamond and California City due to the denudement of the desert landscape.


  1. We would like to see more mitigation measures for the tortoise, Mojave Ground  Squirrel, raptors, vegetation and water.


Again, we are sorry we are late with our comments, however better notification to the public is called for under the California Desert Plan.


Thank you in advance for allowing our comments to at least be heard, although we understand the comment period ended on the 24th for Kern County. 


In cooperation,




Sophia Anne Merk, Director

National Public Lands


cc BLM-Ridgecrest Office