FACTS YOU WONT SEE IN THE LOCAL PAPERS
THE HUALAPAI VALLEY SOLAR PROJECT
(referring document descriptions at end of summary and files attached)
LONG TERM NEGATIVE IMPACT OF THE HUALAPAI VALLEY BASIN: The Hualapai Valley Basin is in depletion, also known as overdraft. Well pumpage is almost 3 times the estimated groundwater recharge rate. Based on data reviewed this aquifer may have been in continuous depletion for decades. As such, Mohave Counties General Plan Policy 3.5 appropriately applies here. Section 3.5, vilifies Smart Growth Practices and only allows for the approval of power plants using “DRY-cooling” technology.
ANALYSIS OF ADEQUATE WATER SUPPLY: An Analysis of Adequate Water Supply was issued by the Arizona Department of Water Resources ADWR November 9th, 2007 in regards to the Red Lake Residential Development. This same report is now being depicted by HVS as an Analysis of Adequate Water Supply for the proposed Hualapai Valley Solar Power Plant HVS. This analogy is inappropriate on many levels.
· Individual Water Reports were required for each subdivision plat and/or phase of the Red Lake Residential Development. Simply put this was to allow for proof of water availability as the subdivision grew. If for instance the first phase of the development was shown to have negatively impacted the water supply then the second phase of the development would be denied a Water Report or the project would be scaled back to adjust for the lack of adequate water supply. In comparison HVS, a WET-cooled solar power plant will aggressively and immediately extract/pump millions of gallons of groundwater per day from day one of operation and will continue this practice for 30+ years. .
·
The residential project was
also required to create its own effluent for outdoor recreation areas and
golf courses. The projected effluent creation was calculated into the
Analysis of Adequate Water Supply. It takes about 1000 homes to maintain
grey water for a golf course. In comparison HVS proposes to build a 35+ mile
long pipeline from the City of Kingman’s Hilltop Wastewater Treatment Plant
HWTP and pump about 1 million gallons a day effluent to the project a small
percentage of total water used. Remember that there is no neutral policing
of the fresh water being pumped by HVS from the Hualapai Valley Basin.
Another issue is that the pipeline just might be a pipe dream as it is not
required by the Certificate of Environmental Compatibility CEC that has been
issued. HVS is only required to begin “negotiations” for wastewater with
the City of Kingman within 2 years of project approval. Let’s pretend that
a miracle happens and the pipeline is actually built and HVS actually
purchases effluent from the City of Kingman. The recharge rate to the
aquifer will be drastically reduced with most of the wastewater evaporating
instead of recharging. The effluent from the HTWP which had been promised
to be utilized on Cerbat Golf Course which utilizes UNKNOWN (estimates are
MASSIVE) quantities of fresh water and has been a sticking point with
activist and concerned decision makers in the area for many years. We were
advised and assured by past and present officials that the HWTP would
correct a long time negative impact/insult to our water supply. The City of
Kingman has now re-written its wastewater guidelines to fit with the
supposed sale of wastewater to HVS instead of delivering it to the golf
course(s). It’s a simple and obvious trade off. They don’t send the
effluent to the golf course so the fresh water is still impacted by HVS
water use.
· The original Analysis of Adequate Water Supply for the Red Lake Residential Development can also be used in evidence for a Water Report unless new hydrological data indicates otherwise. There is new hydrological data available that continues to show depletion in the Hualapai Basin as well as the Cone of Depression seriously impacting the area. Local experts say that the water flow has actually reversed from flowing North (into Lake Mead) to flowing South towards the City of Kingman due to the Cone of Depression. The determination may also be invalidated if the development plan or other conditions change materially prior to the filing for a Water Report. I cannot think of a more drastic material change then from a residential development to an industrial project in which solar electric generation takes place on the land. Legal availability of water has not been proven for this project and no Water Reports have been applied for.
SMART GROWTH: Long range policies established by the state of Arizona and the County of Mohave in Smart Growth Practices are not being addressed. Local guidelines and policy are being re-written to avoid legal responsibility for inappropriate decisions made. Mohave County attempts to push total responsibility for water decisions onto the state of Arizona. They believe that this will protect them from law suits that will start piling up as the wells continue to run dry. Every state-federal-local government agency has policy to plan for drought and natural resource preservation.
OUTSIDE AN AMA: No real protection for this community or mine and my neighbors water supply at all. HVS’s statement that IF the basin was actually in depletion that ADWR would have forced an AMA is not accurate. This is not the way that the AMA process works. They know this but they utilize whatever tactics necessary to acquire the water. UNCERTAINTY OVER WATER WILL BE THE REAL CAUSE OF SLOWING MOHAVE COUNTIES ECONOMIC GROWTH NOT REQUIRING THIS GROUP TO UTILIZE DRY-COOLING TO PRODUCE ENERGY!
CALIFORNIA HAS FINALLY LEARNED FROM THEIR MISTAKES THAT’S WHY HVS IS HERE: To squeeze through the cracks of lack of water regulations and protections in Mohave County. These local officials are no match for the Harvard and MIT grads who own and run HVS.
THERE ARE COMPARABLE PROJECTS WHICH ARE GOING DRY COOLED OR HAVE ASSESSED THE ECONOMIC IMPACT OF THE SAME. HVS is inaccurate in their statement that viable information is not available.
STIMULUS FUNDING: This is a new process and the designations and definitions on what is labeled green, renewable, sustainable etc. has not been appropriately accessed nor defined at the federal level wherein most of the monies will be delivered The risks are on the backs of the American tax payer. This handful of HVS executives will become instant millionaires with the 30% cash back they will receive in 2011. All they have to do is to fast track this project through and start construction by the end of 2010. All the while depleting a communities water supply with not a shred of decency or shame. They don’t care. This is all about greed, selfishness and power.
HILLTOP WASTEWATER TREATMENT PLANT: Has a capacity of 5.1 million gallons per day BUT only takes in enough wastewater to put out 1 million gallons of water per day. Salem’s growth expectations are exaggerated considering the hard economic times and the trend to conserve water (not flush it down the sewer frivalous etc.) has not been considered. Accurate numbers need to be utilized and the comment that ALL of Kingman would be on sewer is so outrageous and unbelievable that I am shocked that he ever made the claim.
UNITED STATES DEPARTMENT OF ENERGY: DRY- cooling is recommended by the United states Department of Energy per the United States Congress. The D.O.E. report states that there is only a SLIGHT drop in production to utilize the DRY-cooling process. Comparable projects to HVS show that “the competitition ” of HVS are utilizing DRY-cooled technology and as such HVS’s assertion that they must produce energy via WET-cooled technology in order to be “comepetivie” is an inaccurate and misleading statement. What they want is a distinct advantage over every other project coming into this community and they want control and ownership of the water. This negates equal opportunities for other truly green, low footprint industry to come into our area. Other projects such as Needle Mountain Solar display respect this community and understand what protecting a finite resource such as our water supply means to the enrichment of EVERYONE’S lives and property values and not to a hand full of individuals. HVS’s continued argument that they cannot be competitive going DRY-cooled is simply inaccurate and shows that there are other reasons for HVS’s insistence of a WET-cooled plant. Ask T Boone Pickens about the value of water!
RED LAKE/ VERNAL POOL: Red lake is called Red Lake for a reason. There is water in the lake every single year for 2 to 3 months. I have lived here since 2000 and ride my horse regularly in the area. This area should be designated as a vernal pool. It is an extremely fragile desert eco system and is home to diverse and vital wildlife, plant life etc.. the destruction of areas such as this are irreversible and vital to humanity as well as having an important spiritual impact.
FLOOD CONTROL: Each year this area is increasingly flooded with torrential currents covering the roadways, lands and dwellings. The more the area is denuded the worst it gets. Winds are dangerously high and I cannot imagine 4000 more acres of denuded land concerning flooding as well as dust issues.
ARIZONA CORPORATION COMMISSION: The Arizona Corporation Commission (ACC) bylaws require them to follow the community’s “master /general plan”. It is time (both legally and morally) that the A.C.C. follow a communities plan to protect its natural resources and to concretely follow it own rules. Mohave County is currently re-writing its General Plan. It is my understanding that they have purposely left out any references to water.
PROP 207: “Diminution in Value, just compensation. Prop 207 was passed relating to the Private Property rights Protection Act. HVS is being proposed in an area that is zoned rural residential. Heavy industrial zoning will negatively affect property value, lifestyle, health and safety issues. All the negative impacts that go along with water destructive industry into our VERY RURAL area. Although Mohave County representatives have expressed publicly their concerns over threats of law suits by developers who demand don’t get their way no matter how drastic the zoning change from the primal dedication of the land or land uses Prop 207 does NOT apply to HVS. Mohave County officials have repeatedly and publically stated that they are afraid they will be sued by developers if they do not protect their private property rights and approve drastic changes in their zoning and land use designations. It seems that the common man doesn’t have a private property rights here.. Numerous citizens will testify concerning the negative impact of the heavy industrial zoning in their neighborhoods and their concern of their property values plummeting. Proposition 207 will apply and this community will be filing for compensation.
BEST AVAILABLE CURRENT TECHNOLOGY: HVS has refused to use the best available current technology BACT, in water conservation and preservation. The technology they are using is inefficient and antiquated and depends on the depletion of a community’s water supply to produce energy. Where is in the intrinsic value of the water. This project is not a part of the solution to reducing and. or eliminating fossil fuels. With its utilization of our water supply they are part of the problem.
CORRUPTION OF THE PUBLIC PROCESS: From the beginning the public process concerning Hualapai Valley Solar (HVS) AKA Mohave Sun Power lacked any true interaction and or participation of the community. Although outspoken from the beginning citizens concerns of the structure, content and intent of the Citizens Participation Plan were ignored. Complaints were made immediately to the Mohave County Board of Supervisors, HVS representatives, Development Services and the County Managers office. The county gave full control to HVS and gave no acknowledgment to the requests of the citizenship. The general Plan has been changed to specifically posture HVS to go WET-cooled and Energy Zones were specifically designed to accommodate any conflicts or possible denials of any kind for anything that HVS wanted to do. This is the reasoning for HVS not applying for their rezone as of yet. It has been an unbelievable experience concerning what I consider corruption for a lack of better terms
The CEC is WITHOUT full and encouraged participation of the citizenship and or interveners.
The “cone of depression” is already in play. The massive and immediate pumping by HVS will have an expedient effect on the wells surrounding the HVS wells. The draw down on surrounding wells (mine included) will destroy life (and property values) for those who own the lands and live upon them. The devastation of the fragile desert environment is unavoidable and life as we know it here in this very rural area will end.
Negative impact on wildlife and habitat is extensive and has NOT been thoroughly addressed.
REFERENCES
1. Montgomery and Associates Water Resources for HVS Project Proposed Mohave County General Plan
2. Memorandum of Understanding (City of Kingman)
3. The Secret to low-water-use, high-efficiency concentrating solar
4. City of Kingman Water Adequacy Study (Final Report, May 1993)
5. USGS in cooperation with ADWR Ground-water Occurrence and Movement, 2006, and Water-level Changes in the Detrital, Hualapai, and Sacramento Valley Basins, Mohave County Arizona
6. Beacon Solar Energy Project Dry Cooling Evaluation (WorleyParsons 2008, Report # FPLS-O-LI-450-0001, http://www.energy.ca.gov/sitingcases/beacon/documents/applicant/2008-02-01_dry_cooling_evaluation_tn-49597.pdf
7. Letter to WAPA from Hualapai Tribe concerning BACT, Dry-cooled
8. Lake Mead
9. HWTP FACT SHEET
10. BRIGHTSOURCE Very comparable project to HVS DRY-cooled
11. Hydrology of the Upper Colorado River Planning Area - Groundwater (West Basins) RECHARGE RATE
12. Concentrating Solar Power Commercial Application Study: Reducing Water Consumption of Concentrating Solar Power Electricity generation Report to Congress U.S. Department of Energy, http://www.nrel.gov/csp/pdfs/csp_water_study.pdf
13. POLICY 3.5, PG 38 OF MOHAVE COUNTY GENERAL PLAN
14. Needle Mountain Power, DRY-cooled, Stirling Dish
15. Stirling Energy Systems, http://www.swrec.org/2009/documents/powerpoints/
solar101csp_stirling_christensen_swrec2009.pdf
16. Solar Millennium to go DRY-cooled