San Bernardino County appears to be going to great lengths to dismiss legitimate concerns over the planned construction of the 3,500 acre Daggett Solar Power Project. The project, which would surround the Barstow-Daggett Airport on three sides - west, north, and east - has been a source of concern for residents, environmentalists, and the U.S. Army's Fort Irwin National Training Center, which uses the airport for its rotary (helicopter) and fixed-wing aviation operations.
In the Environmental Impact Report, air quality issues, and concerns over airborne particulate matter such as PM 10 and PM 2.5 were dismissed by noting the project site area is already out of attainment for Ozone, PM 10, and PM 2.5.
"Since air quality attainment status is measured on a cumulative basin level, data from additional monitoring stations or additional baseline ambient air quality data would not substantially alter attainment status nor would it change the MDAQMD’s (Mojave Desert Air Quality Management District) established significance levels or the relationship of the project’s expected fugitive dust emissions (which are calculated on a project specific basis) to those significance levels."
There are several problems with this response.
First, yes, attainment status is measured on a cumulative basin level. But that is measured by a monitoring station 11.7 miles west of the project in question, in an area that is fairly developed (thus less likely to have airborne particulates), and the station is upwind of the project site, so it is misleading to imply that measurements from that station represents conditions at the project site in any manner.
In addition, if the monitoring station reveals non-attainment nearly 12 miles upwind of the project in an area less likely to experience air quality issues, then it is highly likely that air quality could be significantly worse at and downwind of the project site than the levels measured upwind. The County provides no evidence that this would not be the case, instead engaging in a rhetorical shell game claiming that the project's expected "fugitive dust emissions" would add little to the basin-wide numbers that lead to non-attainment of federal and state air quality numbers.
This does not mean that air quality would not be seriously degraded for residents downwind of the project - including the aircraft maintenance facility at the Barstow-Daggett Airport. Airborne particulate matter is an issue of both cost and safety concerns for aircraft maintenance, and could create operational issues for aviation operations at Fort Irwin as well. The County's response? "Pilots typically avoid departing or landing during dusty conditions."
The Barstow Airport Aviation Safety Committee commented on the EIR that it had "vastly understated impacts to aircraft safety and to safe airport operation." The Committee noted concerns about glare during landings and departures, as well as dust effects.
"Obscuring of a pilot's view will at best, cause the aircraft to have to abort the takeoff or the landing and, at worst, cause the pilot to lose 'situational awareness,' in other words, to be unable to judge the position of the aircraft with relation to the ground and to the aircraft height above the ground," the Committee noted. "Losing view of the ground is likely to cause an aircraft to collide violently with the ground, with catastrophic results. In addition, dust ingestion into aircraft engines is also a very serious concern... Dust ingestion can also be severe enough to cause actual engine failure. Again, this can lead to catastrophic results (i.e. aircraft crashes)."
The County's response? "The project would not impact a pilot's ability to fly and land a plane... Dust from the project would not impact an airplane's engine to any greater degree than exists under current conditions."
Desert residents who live downwind of existing utility scale solar power projects in San Bernardino County have repeatedly testified that they have suffered a serious degradation of quality of life from blowing sand and dust from project sites; a lack of response from the County when these issues are reported; health problems as a result of airborne particulate matter from the project sites; a build-up of sand on their properties; and, a significant drop in property values and the ability to sell their homes in order to relocate to locations where they would not suffer from these impacts. Land Use Services staff appears to be deaf to these citizen complaints and concerns. When the concern over economic impacts to residents was raised, the County's response was, "An EIR is not required to evaluate long- and short-term economic effects of the project on the economic welfare of the County's residents under CEQA."
When issues are raised pertaining to the potential of fires and explosions from the large cargo container-sized lithium-ion battery storage units that are planned for the site, the County seems to believe that the volunteer fire departments of Daggett and Newberry Springs are sufficient, as long as they are properly trained. While the project will be assessed a $157 per acre per year fee for public safety services, the County will manage the receipt of these fees "as appropriate to ensure public safety service impacts are mitigated and that safety services are adequate and available to the project. This is anticipated to involve both the Daggett and Newberry Springs Volunteer Fire Departments for the portion of the project constructed in each specific district." This does not guarantee that these volunteer fire departments will receive all of the approximately $550,000 per year in funding, nor does it indicate the cost of specialized equipment and supplies that these volunteer fire departments may require to be capable of fighting lithium-ion battery explosions and fires, nor does it indicate that there will be adequate personnel available to engage in any such operation.
The County also dismisses concerns over a "heat island" effect raised by Fort Irwin staff. Our discussions with aviation staff from Fort Irwin indicated a serious level of concern over the construction of the Daggett Solar Power Project. The response to their concerns over the potential for 3,500 acres of black photovoltaic panels in the desert surrounding their aviation operations base at the Barstow-Daggett Airport is to dismiss the heat island effect as a "misconception."
Oddly, the Report from Nature.com, "The Photovoltaic Heat Island Effect: Larger solar power plants increase local temperatures" is not cited in the County's rebuttal to concerns over the potential heat island effect. This study "found temperatures over a PV plant were regularly 3–4 °C warmer than wildlands at night, which is in direct contrast to other studies based on models that suggested that PV systems should decrease ambient temperatures.
"Some models have suggested that PV systems can actually cause a cooling effect on the local environment, depending on the efficiency and placement of the PV panels. But these studies are limited in their applicability when evaluating large-scale PV installations because they consider changes in albedo and energy exchange within an urban environment (rather than a natural ecosystem) or in European locations that are not representative of semiarid energy dynamics where large-scale PV installations are concentrated."
In other words, the County purposefully is misrepresenting the potential heat island effect that could significantly impact airport operations, especially during the hotter times of the year. Army personnel we spoke with from Fort Irwin's aviation operations indicated an increase of this level could lead to shutting down aviation operations during summer months, and the study found the heat island effect to be most pronounced during the warmest months.
The heat island effect has been raised before with respect to utility scale PV solar projects, especially after the tornado that destroyed 200,000 solar modules at the Desert Sunlight site in 2015. Destruction of PV panels on site, such as at the Desert Sunlight site, further raises the potential for hazardous waste such as cadmium could be left in the desert soil. PV panels for a site less than twice the size of the proposed Daggett project was estimated to contain 100,000 pounds of cadmium.
The Daggett Solar Power EIR has gone to great lengths to dismiss or trivialize the concerns of San Bernardino County residents and taxpayers, as well as that of the U.S. Army and those entrusted with airport operations at the Barstow-Daggett Airport. The Planning Commission rubber-stamped the County's recommendation of this project - a project that would not have been allowed to proceed had Land Use Services not hijacked the Renewable Energy Conservation Element 4.10 language for 1.5 years, language that would have prevented this project from being considered at this location. The Board of Supervisors review of this project will be the last opportunity for residents and concerned citizens to have their voices heard on the issues surrounding this project.