The National Parks Conservation Association has joined the fight against the Los Angeles Department of Water and Power’s proposed Southern Owens Valley Solar Ranch, which would be built in close proximity to the Manzanar National Historic Site. We look forward to working with NPCA on this effort. The following is their letter to LADWP in opposition to the project.
November 18, 2013
Ms. Nadia Parker/Mr. Chuck Holloway
Environmental Planning and Assessment
Los Angeles Department of Water and Power
111 North Hope Street, Room 1044
Los Angeles, CA 90012
RE: National Parks Conservation Association’s comments on the South Owens Valley Solar Ranch Draft Environmental Impact Report and formal request that the project be alternately sited to avoid impacts to Manzanar National Historic Site.
This letter is intended to provide comments and guidance related to known and underrepresented impacts to Manzanar National Historic Site (NHS) proposed by the South Owens Valley Solar Ranch (SOVSR). National Parks Conservation Association’s (NPCA) comments are public and intended to ensure that this process carefully considers, minimizes and/or eliminates impacts to nationally significant natural and cultural resources. These comments have been submitted in compliance with the extended review period ending November 26, 2013. NPCA appreciates that our requests for extension of the comment period and a scoping meeting in Los Angeles have been honored. We remain hopeful that LADWP will take us up on our offer to connect decision makers with a tour of Manzanar with important stakeholders and for a stakeholder meeting on this matter with National Park Service, the National Historic Trust for Preservation, the Manzanar Committee, and key affected delegates from the Japanese American and Asian American communities.
NPCA is dedicated to the protection and enhancement of National Park Service units for current and future generations. NPCA advocates on behalf of 837,000 members and activists, including over 111,000 in California. NPCA works to safeguard the protections won for resources and recreational opportunities within and affecting the California Desert1 NPCA manages three field offices in the Mojave Desert, including the Mojave Field Office in Barstow, CA.
Our 401 National Park Service units are collectively referred to as “America’s Best Idea.” These units range from 11 million acres of Alaskan wilderness at Wrangell St. Elias to Civil War Battlefields, from the Everglades to the Lincoln Memorial. These units represent a collective American experience that tells the story of our pre-history, our natural history, our struggles for freedom, and in some cases tell the difficult stories about dark times in our collective past. Manzanar NHS tells one of those difficult and important stories. According to the NPS web site “Manzanar National Historic Site was established to preserve the stories of the incarceration of nearly 120,000 Japanese Americans during World War II and to serve as a reminder to this and future generations of the fragility of American civil liberties”2 The imprisonment of these citizens devastated families, communities, and businesses. It is noteworthy that the United States Army leased the Manzanar property from Los Angeles. The Manzanar site is located a mere 3.5 miles from the SOVSR proposed site.
The viewshed in the Owens Valley is spectacular and world-renowned. To the east lie the Inyo and distant White Mountains and to the west are the Eastern Sierras, including some of the highest peaks in the lower 48 states. That setting is important in understanding the experience of those citizens imprisoned at the Manzanar camp. As people from all over the country and world come to learn about the events that took place at Manzanar during WWII, they too experience the conflict presented by the imprisonment of citizens amid one of the most beautiful natural settings in the world—to have to witness such beauty while being forcibly held. The viewshed from the Manzanar camp is a critical part of the cultural experience and landscape. It is crucial that the landscape remain intact for the National Park Service to tell the solemn story of what happened at Manzanar. In other words, changing the character of the view removes the opportunity for visitors, including those who were incarcerated and their families, to share the view that the Japanese Americans experienced and reduces our overall ability to connect to that experience. The private lands off Manzanar Reward Road include other cultural resources including dumps and air strips critical to researching and understanding the cultural history of what life was like for incarcerated Japanese American citizens.
Insufficient Analysis Of Impacts To Cultural Resources
NPCA believes that the Draft EIR has avoided meaningful analysis of the impacts to Manzanar. The site is mentioned within Aesthetics (DEIR 4.2) including cursory analysis of Known Observation Point 2 from the Manzanar NHS parking lot. According to this analysis “It is the closest potentially long-duration viewpoint of the Project site that would be used by a large number of people. It is furthermore potentially sensitive because of the historic nature of the Manzanar property”3 The DEIR continues to find that despite being high contrast and visible from the site that the viewshed would not be substantially impacted. Here is an excerpt of that discussion:
From KOP 2, the Project facilities would be apparent based on the contrast created by the darker solar panel field set against the lighter tones of the surrounding vegetation and soil(see Figure 4.2-7, KOP 2: Manzanar National Historic Site, Proposed Condition). However, because the Project site is in the far middle ground distance and because the Project would be viewed at a shallow angle from KOP 2, the solar panels would present a very low profile that would not obstruct any features of, or distract from the broader scenic vista to the east, which is dominated by the Inyo Mountains.4
The DEIR fails to address within Aesthetics or Cultural Resource that Manzanar’s viewshed is a cultural resource and that any changes to that viewshed would be a significant negative impact to the NHS’s ability to carry out its mission as set forth in its enabling legislation. This DEIR should have created a stand-alone section which discusses its impacts to National Park Resources in addition to addressing the cultural relevance of Manzanar and providing thoughtful analysis to all foreseeable impacts proposed by this action. NPCA requests that this analysis be conducted and added as a supplement to this DEIR. We also request that this analysis be done in partnership with the National Park Service which has expressed concerns about this project location and its proposed impacts to the NHS.
Insufficient Analysis Of Alternatives
NPCA requests that more attention be given to building out alternatives for this project. It is presumptive for the DEIR to find that identifying lands outside the Owens Valley will likely introduce species conflicts with desert tortoise and Mojave ground squirrel. LADWP owns hundreds of thousands of acres of private lands in the Owens Valley and West Mojave Desert. Most of these lands likely have sufficient solar insolation, proximity to transmission, are disturbed, and support the purpose of the project. This project site is the only one that proposes significant impacts to Manzanar, a nationally significant cultural resource. NPCA requests that LADWP conduct an inventory of their available private lands and present that analysis to the public. It is impossible for the public to provide meaningful input about the DEIR without sufficient information about what other lands are available for this project that would not present the same impacts. The lack of analysis of the harm to Manzanar’s cultural resources is a flaw within the DEIR that minimizes one of the key impacts of this project.
Widespread Public Opposition
This proposal has drawn significant controversy and opposition due to its unintentional cultural insensitivity. Stakeholder groups such as the Manzanar Committee have opposed this site, NPCA opposes this site, and hundreds of LADWP ratepayers in the Owens Valley and Los Angeles have expressed their opposition and disappointment about this project site, especially considering the significant private land holdings available to the department. NPCA strongly urges LADWP to reconsider this project site which proposes significant negative impacts to Manzanar NHS. Opposition is galvanizing and growing against this proposal and the opportunity for LADWP to avoid unnecessary conflict and controversy can be accomplished by relocating this site away from Manzanar’s viewshed.
We are happy to discuss our comments further in person or by phone. We continue to urge LADWP decision makers to join a tour of Manzanar to more fully appreciate the values present and the impacts proposed. We also continue to urge LADWP decision makers to hold a stakeholder meeting with NPCA, the Manzanar Committee, the NPS, and key stakeholders interested in this issue.
Thank you for the opportunity to provide input.
California Desert Senior Program Manager
National Parks Conservation Association
1Through FLPMA, the California Desert Protection Act of 1994, the Public lands omnibus bill of 2009, the National Parks Organic Act of 1916, and the Endangered Species Act.
3SOVSR DEIR Vol. 1. Pg. 4-19
4SOVSR DEIR Vol. 1 Pg. 4-21
Community members are urged to sign an online petition opposing the LADWP proposal. To view/sign the petition on Change.org, click on: Halt LADWP’s Plan To Build A 1,200-Acre Solar Energy Generating Station Adjacent to Manzanar National Historic Site.
Community members are also strongly urged to send letters to LADWP in opposition to the Southern Owens Valley Solar Ranch. Letters should be addressed to:
Environmental Planning and Assessment
Los Angeles Department of Water and Power
111 North Hope Street, Room 1044
Los Angeles, California 90012-2607
Comments may also be sent via e-mail, and should be addressed to Ms. Parker at email@example.com, or to Charles Holloway, at firstname.lastname@example.org.
To download a form letter that can be used, click on the image at right.
All letters and e-mails must be received by LADWP no later than 5:00 PM PST on December 20, 2013.
Those who would like to review the Draft Environmental Impact Report for the project can read it on the web at: http://www.ladwp.com/envnotices.
For more information, please call the Manzanar Committee at (323) 662-5102, or send e-mail to email@example.com.
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