Tubb Canyon Desert Conservancy

The Behemoth at our Doorstep

June 2024

The specter of a towering 500 kV transmission line cutting in half the Anza-Borrego Desert State Park has haunted our region for the last two decades. Construction of such a line would be a disturbing, years-long proposition. The region’s unsurpassed wilderness scenery and long uninterrupted views are the foundation of Borrego’s destination economy. Such a 500 kV transmission line’s negative economic impact on visitation to the town and Park has been calculated in the tens of millions of dollars. And residents of Borrego would receive no benefit from the completed line, but simply pay the economic and environmental price of its presence.

The Sunrise Powerlink was a close call, but the threat was averted when that line was sited south of the Park. Today there is a new threat. The powers that be are planning a new 500 kV line that would transect the Park, and it is on the verge of becoming a reality.

The forces behind today’s threat dwarf the mere corporate greed that fueled the drive to build the Sunrise Powerlink. Today’s threat is driven by California’s urgent response to climate change, a dramatic shift in the regulatory environment, and politicians who are singing from the song book given to them by the investor-owned utility industry.

There are important actions that Borregans and those who love the Park can take, but first a description of the circumstances.

California’s Historic Response to Climate Change

In 2019 the California legislature passed, and the governor signed, Senate Bill 100 requiring all electricity consumed in California in 2045 to be generated from renewable sources. This legislative mandate created an urgency among the regulatory agencies that are responsible for ensuring California has a reliable electricity grid now and in the future.

A Shifting Regulatory Environment

During the early 2000’s when local residents struggled to keep the Sunrise Powerlink out of the Park, the three agencies responsible for ensuring that California has a reliable electric grid—the California Independent System Operator (ISO), the California Public Utility Commission (CPUC), and the California Energy Commission (CEC)—functioned largely independently. The CEC produced 10-year demand forecasts. The ISO used those forecasts to plan for the growth and development of the grid, and the CPUC exercised its authority to give or withhold regulatory approval to proposed projects. Today is a different world.

In December 2022 the relationships among these three agencies shifted significantly when they signed a Memorandum of Understanding (MOU) designed to “streamline” the siting and permitting of new grid infrastructure by removing much of the check and balance dynamic that previously existed. Section 9 of the MOU states, “The ISO transmission planning process will consider and incorporate the scenarios and portfolios developed by the CPUC with input from the CEC, and the subsequent CPUC siting/permitting process will then give substantial weight to project applications that are consistent with the ISO's final transmission plan.” (See full text of the MOU here: bit.ly/4bK9GXH.)

Implications for Borrego Springs and the Anza-Borrego Desert State Park

In May 2023 the Board of Governors of the ISO approved its 2022-2023 Transmission Plan. This plan was created in coordination with the CPUC. The plan deals with transmission lines throughout the state, but of paramount importance to Borrego and the Park is the section affirming the need for a 500 kV line to run from southern Imperial County to northern San Diego County. This line is referred to as the Imperial Valley-North of SONGS 500 kV Line and is estimated to cost ratepayers $2.3 billion dollars. SONGS is the San Onofre Nuclear Generating Station located in northern San Diego County. (See full text of the plan here: bit.ly/4bu1lrp.)

This new world of “coordination of activity” among regulatory agencies means that the ISO’s 2022-2023 Transmission Plan authorizing a 500 kV line from southern Imperial County to northern San Diego County was developed in conjunction with the CPUC and that the CPUC with its siting/permitting authority will give “substantial weight” to the project application when it eventually comes before the CPUC for final approval.

The simple translation of the MOU is, “The CPUC is now involved from the beginning in the ISO’s planning process for transmission lines, so when it comes time for the CPUC to approve those lines planned by the ISO, the CPUC will approve them. Quickly! And why not? The CPUC has been involved in the planning from the beginning.”

The upshot for Borrego and the State Park is that the Imperial Valley-North to SONGS Line is the largest, most expensive plan in the ISO’s 2022-2023 Transmission plan, and is very likely (“substantial weight”) to receive CPUC approval.

Full Speed Ahead

In the year since issuing its 2022-2023 Transmission Plan, the ISO has wasted no time in seeking a company to build the Imperial Valley-North of SONGS Line. On May 9, 2024, the ISO published a report detailing the selection process for the “Project Sponsor” that would build, own, manage, and operate the Imperial Valley-North of SONGS 500 kV Line. In an interesting twist, SDG&E was not selected as the Project Sponsor. The firm selected is Horizon West Transmission, LLC. (See full text of the report here: bit.ly/3V86lwi).

The Route through the Park

In its application submitted to the ISO, Horizon West described the route it will take in constructing the Imperial Valley-North of SONGS Line. “… its proposed route is approximately 135 miles along and it would acquire land rights from the BLM, DoD, California State Parks, and private landowners. Horizon West indicated that its proposed route would minimize impacts to the Anza Borrego Desert State Park by following a combination of existing transmission lines, existing roads, and other permanent impacts within the park for the majority of the crossing.”

Currently, the only existing transmission line in the State Park is the 69kV line on wooden poles that is sufficiently innocuous to be barely visible as it traverses a path from the Narrows Substation to the Warner Substation. (See Map 1) A 500 kV line with its 180 - 200-foot-tall metal towers in the same easement as the existing 69 kV line would be visible from miles away. The footprint on the ground of such massive towers is the size of a house.

AB 3238 - Circumventing CEQA

For years Californians have been afforded the due process protections of the California Environmental Quality Act (CEQA). As imperfect as it is, CEQA has been a hurdle that many environmentally destructive projects could not clear. CEQA has been the bane of unbridled development.

CEQA would be a challenging hurdle for the Imperial Valley-North of SONGS Line. However, a bill, AB 3238, now winding its way through the California Legislature would exempt the Imperial Valley- North of SONGS Line from CEQA. Section 2 of AB 3238 sponsored by Assemblyman Eduardo Garcia (D-Coachella) “would, until January 1, 2035, exempt from CEQA projects for the expansion of an existing public right-of-way across state-owned land to accommodate the construction, expansion, modification, or update of electrical infrastructure, as defined.” This section of the bill means that expanding the right-of-way of the existing 69 kV line through the State Park would be exempt from CEQA.

Remember the CPUC’s new role in planning and approving transmission lines described above? AB 3238 would make full use of the CPUC’s enhanced role to approve projects. Section 3 states, “This bill would vest the (California Public Utilities) commission with the exclusive power (emphasis added) to approve and site necessary electrical infrastructure projects, as defined. The bill would, except as provided, specify that the approval and siting by the (California Public Utilities) commission of a necessary electrical infrastructure project is in lieu of any approval, concurrence permit, certificate, or similar document required by any state, local, or regional agency, or federal agency to the extent permitted by the federal law, for the use of the site and related facilities.” This section of the bill means the CPUC would have carte blanche to site a transmission line wherever it sees fit without regard to input from other public agencies such as the Department of Parks and Recreation or the Department of Fish and Wildlife.

What you can do.

What happens next is depends on what happens to AB 3238. If the bill is allowed to become law, CEQA protections would be gone and there would be little standing in the way of the CPUC, with its “exclusive power,” approving the route through the State Park for a 500 kV transmission line.

For those interested in participating in this political process, there are a number of things that can be done, beginning with contacting the elected officials listed below. The message to these individuals is not that we are opposed to renewable energy or California’s aggressive goals. But rather we are looking for ways to meet California’s renewable energy goals without destroying California’s public lands. One alternative is to maximize rooftop and parking lot solar in the urban areas along California’s coast. Studies have demonstrated such an approach would more than meet current and projected demand for electric power.

 

1. Alert your friends and neighbors to this imminent threat to Borrego Springs and the Park.
2. Call, and encourage others to contact, Assemblyman Eduardo Garcia’s office at (916) 319-2036 and voice opposition to his special interest bill (AB 3238) that would sacrifice the State Park.
3. Call, and encourage others to contact, the Governor’s office at (916) 445-2841to voice your opposition to this proposed power grab (AB 3238) by the CPUC that dramatically diminishes all other voices and concerns.
4. Call, and encourage others to contact, Senator Brian Jones office at (916) 651-4040 and ask him to oppose AB 3238 when it comes up for a vote in the Senate.
5. Call, and encourage others to contact, Assemblywoman Marie Waldron at (916) 319-2075 and ask her to oppose AB 3238 when it comes up for a vote in the Assembly.
6. If your primary residence is in California but outside the districts of Assemblymembers Garcia and Waldron, and you are outside the Senate District of Senator Brian Jones, then please call your own State Assemblymember and State Senator, and encourage others to contact them as well, and ask your representatives to oppose AB 3238 when it comes up for a vote in the Assembly and Senate.

 

 

 

Technical Memorandum

Read the Technical Memorandum (pdf) reviewing technical assumptions and assertions regarding groundwater dependent ecosystems underlying aspects of the Borrego Subbasin Groundwater Management Plan.

 

Borrego in the crosshairs … again

Spring 2023

Borrego’s perennial celebration of springtime wildflowers is shadowed by a darker perennial—San Diego’s incessant musings of turning Borrego Springs into an industrial wasteland. In 2010 Borregans fought off the Sunrise Powerlink. In 2015 it was the Desert Renewable Energy Conservation Plan. In 2021 it was the County Water Authority’s Regional Conveyance System. This time it is the County’s Regional Decarbonization Framework (RDF). (For the full Report, please visit https://bit.ly/3DL7xwy)

The Good News: San Diego County now has a Board of Supervisors that strives to make decisions based on facts and scientific evidence, that understands climate change is an existential threat caused by human activity, and that is taking actions within its power to address the causes of climate change.

The Bad News: Some of the same consultants who wrote SDG&E’s decarbonization plan were hired by the County to write its decarbonization plan, referred to as the Regional Decarbonization Framework (RDF). Instead of assembling a breadth of independent expert opinion, the County is using the same small group of consultants that advised SDG&E. So, SDG&E, which represents itself, and the County, which represents the citizens of San Diego County, are getting advice from the same source despite the conflict of interest.

No wonder there is a striking similarity between SDG&E’s and the County’s visions for electricity generation in the future. Both plans—SDG&E’s and the County’s—see remote, industrial-scale power generation and the transmission lines to take electricity from the east county to the coast as essential to decarbonizing electricity production in San Diego County. Rooftop and parking lot solar in coastal communities, which would not require new, long-distance transmission lines, are dismissed in the RDF, and by SDG&E, as insufficient to address the challenge.

The Worse News: The RDF’s Scenario 1, the purported “low-cost option,” envisions covering the unincorporated part of San Diego County known as Borrego Springs with industrial-scale solar farms and transporting that electricity to the coast via new 500 kV transmission lines. Figure 1, from page 27 of the RDF, shows Borrego Springs covered in lime green squares indicating just how inexpensive electricity generated in Borrego Springs would be compared to other parts of the county. However, as explained below, the data used to create the conclusions illustrated by Figure 1 is incomplete, thus resulting in inaccurate conclusions, i.e., bad inputs create bad outputs.

Figure 2, from page 42 of the RDF, shows the build out of industrial-scale solar farms in Borrego over the next 20 years. Although somewhat difficult to see, that expanding cluster of squares in the upper right-hand corner of the maps in Figure 2 is Borrego Springs, which would be carpeted by solar farms instead of springtime wildflowers.

The Worst News: The San Diego County Board of Supervisors is scheduled to vote to approve, or not, the RDF on March 15, 2023.

The authors of the RDF claim they are not “picking winners or losers.” And it is true the RDF considers scenarios for decarbonizing San Diego’s electricity generation that are not as devastating for Borrego Springs and the Park as Scenario 1; but it doesn’t take much creativity to imagine the discussions of government officials charged with choosing which decarbonization option to implement … beginning with, “Why wouldn’t we implement the least expensive option?”

At a meeting on February 6th with Supervisor Desmond’s Land Use staff person, Hunter McDonald, this author representing the Tubb Canyon Desert Conservancy pointed out the current draft of the RDF is making cost comparisons of various pathways to achieve decarbonization without including all the relevant costs. Specifically, the calculations behind Scenario 1 only take into account the costs of land acquisition and solar farm construction. It does not include the multi-billion dollar cost of building new 500kV transmission lines. The RDF does not take into account the hundreds of millions of dollars of costs that would occur as a consequence of industrializing Borrego Springs and the Park—lost tourism revenue, decreased property values, decreased property taxes, lost hotel taxes, increased health costs due to degraded air quality, etc.—if Scenario 1, the purported low-cost option were selected and implemented. These costs that the RDF simply ignores can be calculated and must be included in any future draft of the RDF if this document is to be relied upon to make fact-based cost comparisons of the various possible pathways to decarbonization of San Diego’s power generation.

At the same February 6th meeting, Bill Powers of the Protect Our Communities Foundation pointed out the current draft of the RDF that promotes remote, industrial-scale generation over distributed, in-basin (rooftop) generation in coastal communities does so by using patently incorrect numbers in its calculations. Left out of the RDF’s calculations for electricity generation in the back county is the $3.9B that would be required to build the 500 kV transmission lines. Left out of the RDF’s calculations of potential rooftop solar in coastal communities is the true square footage of potential rooftop and parking lot solar installations that could be built in coastal communities. A further example of the RDF’s authors putting their collective thumbs on the “cost-comparison scale” is that the RDF uses outdated rooftop solar construction costs that are almost twice actual current costs.

The County’s current timeframe calls for the Board of Supervisors to approve the RDF at its meeting on March 15, 2023. The Tubb Canyon Conservancy and the Protect our Communities Foundation have requested Supervisor Desmond move to delay the approval of the RDF until such time as the calculation errors are corrected and all economic costs relevant to Borrego Springs are included in the RDF.

Supervisor Desmond needs to hear from every Borregan on this issue. If we want to protect our Park and community, we need to insist the Board of Supervisors delay approval of the RDF until such time as the true costs of decarbonization are reflected in its analysis of all the possible paths forward. When the accurate and full costs of each option are acknowledged and included in the calculations, they will show that building rooftop and parking lot solar in coastal communities is the environmentally sound, low-cost option for decarbonizing San Diego’s grid.

Please take the time NOW to call Supervisor Desmond’s office at (619) 458-2600 and speak to Hunter McDonald. Ask him to delay approval of the RDF until it reflects the true costs of each option for decarbonization discussed in the RDF. Or you may email Mr. McDonald at Hunter.McDonald@sdcounty.ca.gov. By email, by phone, or in person, NOW is the time to make your voice heard.

 

 

J. David Garmon, MD
President, Tubb Canyon Desert Conservancy

 

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