Truckhaven (aka Ocotillo Wells SVRA) BLM Comments
Below is the letter I sent to the BLM (and Parks' OHV commission and Governor) regarding proposed Geothermal Leasing at Ocotillo Wells SVRA ( Truckhaven to the BLM).
April 4, 2007
Bureau of Land Management
California Desert District Office
Attn: John Dalton
22835 Calle San Juan de Los Lagos
Moreno Valley CA 92553
RE: Truckhaven Draft Environmental Impact Statement Comments
Dear Sir,
I believe there is much misunderstanding about the proposed Truckhaven Geothermal project - much of it stems from misinformation in the DEIS.
A few of the glaring issues are the blatant misnaming of the project area as Truckhaven - when it is really Ocotillo Wells SVRA. The DEIS certainly refers to Ocotillo Wells SVRA throughout the document but the title I believe is misleading. Truckhaven is commonly known as the area north of S22 and West of SR86, if the public were properly made aware of the true location of this project I believe the outcry would be significantly greater. This error should not be understated, a few hundred acres of desert in the middle of Imperial County is a local issue… but 500 acres of OWSVRA is a Southern California Issue. Because this area is used by citizens in a much broader area the public throughout Southern California should be made aware of this potential loss of recreation land and be offered the ability to comment on its impact.
Under Section 4.11 Visual Resources, your DEIS fails to address the effect of Light Pollution at night. The Ocotillo Wells and the surrounding desert area enjoys extremely crisp and clear nights throughout the year, which offer excellent vantage for stargazing. Every power plant I have ever seen has hundreds of bright lights all night long – potentially destroying one of the benefits of the solitude of the desert.
Under the RFD, section 2.2 the DEIS states that up to 36.5% of the total acres (14,731 acres) could be disturbed but the number is quickly downplayed to 340 acres for wells and 186 acres for power plants – I’m concerned that is a gross underestimate. For example of great concern are the Well field pipelines discussed in GeothermEx,Inc.’s plans in Appendix B on page 3-2, where they state that 24” diameter pipelines are run a few feet off the ground. So the footprint of the wells and pipeline may come in within your RFD, but a pipeline a “few feet” off the ground spoils access and views, one doesn’t go to the desert to be in the middle of and industrial park. Nor is my experience enhanced when I have to drive around pipelines.
Section 2.2 states that there is not accurate information on the Geothermal resources available, just proprietary data from 1981 – what if you are wrong and they are sitting on a Geothermal gold mine? Now we loose 36% OR MORE of our SVRA! The BLM just says “OOPS that was the RFD at the time, hey there generating clean electricity now go away.” How then do we get compensated for our lost recreation opportunities? I believe any leasing should impound a portion of the mineral rights royalties for OHV land acquisition in California.
The most important error is the DEIS's estimate of annual visitors to Ocotillo Wells SVRA of 15,000 (section 3.15.2, and on page 3-63 under recreation) (and then in page 3-53 you state 1 million visitors) anyone who has been there on ANY weekend between October and May would know by even the most cursory count that the number is at least 10 and more like 100 times greater than 15000 annual visitors. The factual numbers are gathered daily by the Parks Staff at the Ocotillo Wells Ranger Station, and have been provided to me upon asking by the Sector Superintendent Nedra Martinez. (Printed Spreadsheet attached as exhibit A) For the Calendar year 2006 there were 1,899,446 visitors. Even more important is the annual growth of visitors, During the period 2000-2006 visitors have increased 284,164 per year putting projected visitors well over 2 Million for 2007 and over 3 Million by the end of this decade.
The DEIS correctly notes that Off-Road areas are scarce resources in the State of California, that they are getting more and more scarce and that the citizens of this state have suffered a 48 percent decrease in acres available to OHV recreation in the California Desert! We are loosing property from our Government (See Boxer and Feinstein's huge land grabs) from Environmental Extremists who seek to close what lands are left - what the government, through Boxer, Feinstein, Et al., won't take for them they will sue to keep us out of. Now from businesses who are seeking to develop our lands, our recreation lands are once again under attack.
400 or 500 acres may not seem like much to you but when you have nearly 2 Million visitors per year in just 75,000 acres as does Ocotillo Wells SVRA that's nearly 27 visitors per year per acre. Compare that with the Anza Borrego State Park's 600,000 acres of land and 600,000 annual visitors and you will agree that even one acre of land in Ocotillo Wells is extremely valuable to the OHV recreation community.
We as OHV enthusiasts MUST fight to hold onto every acre of land we currently have access to - especially those within a SVRA.
Section 2.1.4 of the DEIS states that Acquiring State lands in a 1:1 compensation scheme is not feasible as it would be cost prohibitive – EXACTLY my point – this IS valuable land – we can’t obtain and open any more areas so we must stand our ground and fight for what little we have. Millions of visitors use this land for recreational enjoyment and there is no alternative place for us to go.
Please go find a place to drill on the other side of the 86 or south of the 78 that won't affect the limited OHV recreational opportunities within our California State Parks Managed SVRA. Page 1-7 notes that in accordance with 43 CFR 2301.11 the BLM is prohibited from issuing leases on .. b. NPS Lands…,why are State Parks lands so much less valuable? The SVRA is managed by State Parks and should enjoy the same protections even if you are not required to do so by law. Finally, the DEIS in section 1.1 notes that there are 118,720 acres of land classified as KGRA (Known Geothermal Resource Areas) in the El Centro Field Office’s management area, is that land fully tapped out?
Please take note of my preference for Alternative 1 – No Action.
Sincerely,
Charles Seeger
Cc: California State Parks OHV Commission, Gov. Arnold Schwarzenegger
Exhibit A - Ocotillo Wells Visitor Numbers as provided by the Ocotillo Wells Sector Superintendent
April 4, 2007
Bureau of Land Management
California Desert District Office
Attn: John Dalton
22835 Calle San Juan de Los Lagos
Moreno Valley CA 92553
RE: Truckhaven Draft Environmental Impact Statement Comments
Dear Sir,
I believe there is much misunderstanding about the proposed Truckhaven Geothermal project - much of it stems from misinformation in the DEIS.
A few of the glaring issues are the blatant misnaming of the project area as Truckhaven - when it is really Ocotillo Wells SVRA. The DEIS certainly refers to Ocotillo Wells SVRA throughout the document but the title I believe is misleading. Truckhaven is commonly known as the area north of S22 and West of SR86, if the public were properly made aware of the true location of this project I believe the outcry would be significantly greater. This error should not be understated, a few hundred acres of desert in the middle of Imperial County is a local issue… but 500 acres of OWSVRA is a Southern California Issue. Because this area is used by citizens in a much broader area the public throughout Southern California should be made aware of this potential loss of recreation land and be offered the ability to comment on its impact.
Under Section 4.11 Visual Resources, your DEIS fails to address the effect of Light Pollution at night. The Ocotillo Wells and the surrounding desert area enjoys extremely crisp and clear nights throughout the year, which offer excellent vantage for stargazing. Every power plant I have ever seen has hundreds of bright lights all night long – potentially destroying one of the benefits of the solitude of the desert.
Under the RFD, section 2.2 the DEIS states that up to 36.5% of the total acres (14,731 acres) could be disturbed but the number is quickly downplayed to 340 acres for wells and 186 acres for power plants – I’m concerned that is a gross underestimate. For example of great concern are the Well field pipelines discussed in GeothermEx,Inc.’s plans in Appendix B on page 3-2, where they state that 24” diameter pipelines are run a few feet off the ground. So the footprint of the wells and pipeline may come in within your RFD, but a pipeline a “few feet” off the ground spoils access and views, one doesn’t go to the desert to be in the middle of and industrial park. Nor is my experience enhanced when I have to drive around pipelines.
Section 2.2 states that there is not accurate information on the Geothermal resources available, just proprietary data from 1981 – what if you are wrong and they are sitting on a Geothermal gold mine? Now we loose 36% OR MORE of our SVRA! The BLM just says “OOPS that was the RFD at the time, hey there generating clean electricity now go away.” How then do we get compensated for our lost recreation opportunities? I believe any leasing should impound a portion of the mineral rights royalties for OHV land acquisition in California.
The most important error is the DEIS's estimate of annual visitors to Ocotillo Wells SVRA of 15,000 (section 3.15.2, and on page 3-63 under recreation) (and then in page 3-53 you state 1 million visitors) anyone who has been there on ANY weekend between October and May would know by even the most cursory count that the number is at least 10 and more like 100 times greater than 15000 annual visitors. The factual numbers are gathered daily by the Parks Staff at the Ocotillo Wells Ranger Station, and have been provided to me upon asking by the Sector Superintendent Nedra Martinez. (Printed Spreadsheet attached as exhibit A) For the Calendar year 2006 there were 1,899,446 visitors. Even more important is the annual growth of visitors, During the period 2000-2006 visitors have increased 284,164 per year putting projected visitors well over 2 Million for 2007 and over 3 Million by the end of this decade.
The DEIS correctly notes that Off-Road areas are scarce resources in the State of California, that they are getting more and more scarce and that the citizens of this state have suffered a 48 percent decrease in acres available to OHV recreation in the California Desert! We are loosing property from our Government (See Boxer and Feinstein's huge land grabs) from Environmental Extremists who seek to close what lands are left - what the government, through Boxer, Feinstein, Et al., won't take for them they will sue to keep us out of. Now from businesses who are seeking to develop our lands, our recreation lands are once again under attack.
400 or 500 acres may not seem like much to you but when you have nearly 2 Million visitors per year in just 75,000 acres as does Ocotillo Wells SVRA that's nearly 27 visitors per year per acre. Compare that with the Anza Borrego State Park's 600,000 acres of land and 600,000 annual visitors and you will agree that even one acre of land in Ocotillo Wells is extremely valuable to the OHV recreation community.
We as OHV enthusiasts MUST fight to hold onto every acre of land we currently have access to - especially those within a SVRA.
Section 2.1.4 of the DEIS states that Acquiring State lands in a 1:1 compensation scheme is not feasible as it would be cost prohibitive – EXACTLY my point – this IS valuable land – we can’t obtain and open any more areas so we must stand our ground and fight for what little we have. Millions of visitors use this land for recreational enjoyment and there is no alternative place for us to go.
Please go find a place to drill on the other side of the 86 or south of the 78 that won't affect the limited OHV recreational opportunities within our California State Parks Managed SVRA. Page 1-7 notes that in accordance with 43 CFR 2301.11 the BLM is prohibited from issuing leases on .. b. NPS Lands…,why are State Parks lands so much less valuable? The SVRA is managed by State Parks and should enjoy the same protections even if you are not required to do so by law. Finally, the DEIS in section 1.1 notes that there are 118,720 acres of land classified as KGRA (Known Geothermal Resource Areas) in the El Centro Field Office’s management area, is that land fully tapped out?
Please take note of my preference for Alternative 1 – No Action.
Sincerely,
Charles Seeger
Cc: California State Parks OHV Commission, Gov. Arnold Schwarzenegger
Exhibit A - Ocotillo Wells Visitor Numbers as provided by the Ocotillo Wells Sector Superintendent
posted by powerchuck at 8:30 PM
1 Comments:
Well said Charlie. Thanks for the time and effort you put into this. I hope it works!
Steve
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