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Smallwood, K. S. 1999. Abating pocket gophers (Thomomys spp.) to regenerate forests in clearcuts.
Environmental Conservation 26:59-65.
Smallwood, K. S. 1998. Patterns of black bear abundance. Transactions of the Western Section of the Wildlife Society 34:32-38.
Smallwood, K. S. 1998. On the evidence needed for listing northern goshawks (Accipter gentilis) under the Endangered Species Act: a reply to Kennedy. J. Raptor Research 32:323-329.
Smallwood, K. S., B. Wilcox, R. Leidy, and K. Yarris. 1998. Indicators assessment for Habitat Conservation Plan of Yolo County, California, USA. Environmental Management 22: 947-958.
Smallwood, K. S., M. L. Morrison, and J. Beyea. 1998. Animal burrowing attributes affecting hazardous waste management. Environmental Management 22: 831-847.
Smallwood, K. S, and C. M. Schonewald. 1998. Study design and interpretation for mammalian carnivore density estimates. Oecologia 113:474-491.
Zhang, M., S. Geng, and K. S. Smallwood. 1998. Nitrate contamination in groundwater of Tulare County, California. Ambio 27(3):170-174.
Smallwood, K. S. and M. L. Morrison. 1997. Animal burrowing in the waste management zone of Hanford Nuclear Reservation. Proceedings of the Western Section of the Wildlife Society Meeting 33:88-97.
Morrison, M. L., K. S. Smallwood, and J. Beyea. 1997. Monitoring the dispersal of contaminants by wildlife at nuclear weapons production and waste storage facilities. The Environmentalist 17:289- 295.
Smallwood, K. S. 1997. Interpreting puma (Puma concolor) density estimates for theory and management. Environmental Conservation 24(3):283-289.
Smallwood, K. S. 1996. Managing vertebrates in cover crops: a first study. American Journal of Alternative Agriculture 11:155-160.
Smallwood, K. S. and S. Geng. 1997. Multi-scale influences of gophers on alfalfa yield and quality.
Field Crops Research 49:159-168.
Smallwood, K. S. and C. Schonewald. 1996. Scaling population density and spatial pattern for terrestrial, mammalian carnivores. Oecologia 105:329-335.
Smallwood, K. S., G. Jones, and C. Schonewald. 1996. Spatial scaling of allometry for terrestrial, mammalian carnivores. Oecologia 107:588-594.
Van Vuren, D. and K. S. Smallwood. 1996. Ecological management of vertebrate pests in agricultural systems. Biological Agriculture and Horticulture 13:41-64.
Smallwood, K. S., B. J. Nakamoto, and S. Geng. 1996. Association analysis of raptors on an
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agricultural landscape. Pages 177-190 in D.M. Bird, D.E. Varland, and J.J. Negro, eds., Raptors in human landscapes. Academic Press, London.
Erichsen, A. L., K. S. Smallwood, A. M. Commandatore, D. M. Fry, and B. Wilson. 1996. Whitetailed Kite movement and nesting patterns in an agricultural landscape. Pages 166-176 in D. M.
Bird, D. E. Varland, and J. J. Negro, eds., Raptors in human landscapes. Academic Press, London.
Smallwood, K. S. 1995. Scaling Swainson's hawk population density for assessing habitat-use across an agricultural landscape. J. Raptor Research 29:172-178.
Smallwood, K. S. and W. A. Erickson. 1995. Estimating gopher populations and their abatement in forest plantations. Forest Science 41:284-296.
Smallwood, K. S. and E. L. Fitzhugh. 1995. A track count for estimating mountain lion Felis concolor californica population trend. Biological Conservation 71:251-259 Smallwood, K. S. 1994. Site invasibility by exotic birds and mammals. Biological Conservation 69:251-259.
Smallwood, K. S. 1994. Trends in California mountain lion populations. Southwestern Naturalist 39:67-72.
Smallwood, K. S. 1993. Understanding ecological pattern and process by association and order.
Acta Oecologica 14(3):443-462.
Smallwood, K. S. and E. L. Fitzhugh. 1993. A rigorous technique for identifying individual mountain lions Felis concolor by their tracks. Biological Conservation 65:51-59.
Smallwood, K. S. 1993. Mountain lion vocalizations and hunting behavior. The Southwestern Naturalist 38:65-67.
Smallwood, K. S. and T. P. Salmon. 1992. A rating system for potential exotic vertebrate pests.
Biological Conservation 62:149-159.
Smallwood, K. S. 1990. Turbulence and the ecology of invading species. Ph.D. Thesis, University of California, Davis.
Peer-reviewed Reports
Smallwood, K. S., and L. Neher. 2017. Comparing bird and bat use data for siting new wind power generation. Report CEC-500-2017-019, California Energy Commission Public Interest Energy Research program, Sacramento, California. http://www.energy.ca.gov/2017publications/CEC-500- 2017-019/CEC-500-2017-019.pdf and http://www.energy.ca.gov/2017publications/CEC-500-2017- 019/CEC-500-2017-019-APA-F.pdf
Smallwood, K. S. 2016. Bird and bat impacts and behaviors at old wind turbines at Forebay, Altamont Pass Wind Resource Area. Report CEC-500-2016-066, California Energy Commission Public Interest Energy Research program, Sacramento, California.
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http://www.energy.ca.gov/publications/displayOneReport.php? pubNum=CEC-500-2016-066 Sinclair, K. and E. DeGeorge. 2016. Framework for Testing the Effectiveness of Bat and Eagle Impact-Reduction Strategies at Wind Energy Projects. S. Smallwood, M. Schirmacher, and M.
Morrison, eds., Technical Report NREL/TP-5000-65624, National Renewable Energy Laboratory, Golden, Colorado.
Brown, K., K. S. Smallwood, J. Szewczak, and B. Karas. 2016. Final 2012-2015 Report Avian and Bat Monitoring Project Vasco Winds, LLC. Prepared for NextEra Energy Resources, Livermore, California.
Brown, K., K. S. Smallwood, J. Szewczak, and B. Karas. 2014. Final 2013-2014 Annual Report Avian and Bat Monitoring Project Vasco Winds, LLC. Prepared for NextEra Energy Resources, Livermore, California.
Brown, K., K. S. Smallwood, and B. Karas. 2013. Final 2012-2013 Annual Report Avian and Bat Monitoring Project Vasco Winds, LLC. Prepared for NextEra Energy Resources, Livermore, California. http://www.altamontsrc.org/alt_doc/p274_ventus_vasco_winds_2012_13_avian_ bat_monitoring_report_year_1.pdf
Smallwood, K. S., L. Neher, D. Bell, J. DiDonato, B. Karas, S. Snyder, and S. Lopez. 2009. Range Management Practices to Reduce Wind Turbine Impacts on Burrowing Owls and Other Raptors in the Altamont Pass Wind Resource Area, California. Final Report to the California Energy Commission, Public Interest Energy Research – Environmental Area, Contract No. CEC-500-2008- 080. Sacramento, California. 183 pp. https://tethys.pnnl.gov/publications/range-managementpractices-reduce-wind-turbine-impacts-burrowing-owls-other-raptors Smallwood, K. S., and L. Neher. 2009. Map-Based Repowering of the Altamont Pass Wind Resource Area Based on Burrowing Owl Burrows, Raptor Flights, and Collisions with Wind Turbines. Final Report to the California Energy Commission, Public Interest Energy Research – Environmental Area, Contract No. CEC-500-2009-065. Sacramento, California. http:// www.energy.ca.gov/publications/displayOneReport.php?pubNum=CEC-500-2009-065 Smallwood, K. S., K. Hunting, L. Neher, L. Spiegel and M. Yee. 2007. A framework to screen wind power sites for potential impacts to birds in California. Final Report to the California Energy Commission, Public Interest Energy Research – Environmental Area, Contract No. Submitted but not published. Sacramento, California.
Smallwood, K. S. and C. Thelander. 2005. Bird mortality in the Altamont Pass Wind Resource Area, March 1998 – September 2001 Final Report. National Renewable Energy Laboratory, NREL/SR-500-36973. Golden, Colorado. https://www.nrel.gov/docs/fy05osti/36973.pdf Smallwood, K. S. and C. Thelander. 2004. Developing methods to reduce bird mortality in the Altamont Pass Wind Resource Area. Final Report to the California Energy Commission, Public Interest Energy Research – Environmental Area, Contract No. 500-01-019. Sacramento, California. 531 pp. https://tethys.pnnl.gov/publications/developing-methods-reduce-bird-mortality-altamontpass-wind-resource-area
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Thelander, C.G. S. Smallwood, and L. Rugge. 2003. Bird risk behaviors and fatalities at the Altamont Pass Wind Resource Area. Period of Performance: March 1998—December 2000.
National Renewable Energy Laboratory, NREL/SR-500-33829. U.S. Department of Commerce, National Technical Information Service, Springfield, Virginia. 86 pp.
Thelander, C.G., S. Smallwood, and L. Rugge. 2001. Bird risk behaviors and fatalities at the Altamont Wind Resource Area – a progress report. Proceedings of the American Wind Energy Association, Washington D.C. 16 pp.
Non-Peer Reviewed Publications
Smallwood, K. S. 2026. Burrowing Owls (Athene cunicularia) in the Altamont Pass Wind Resource Area. Report to East Bay Regional Park District. 218 pp.
Smallwood, K. S., L. Neher, and D. A. Bell. 2023. Golden eagle roost sites based on telemetry data.
Report to Salka Energy, San Diego, California. 29 pp.
Smallwood, K. S. 2009. Methods manual for assessing wind farm impacts to birds. Bird Conservation Series 26, Wild Bird Society of Japan, Tokyo. T. Ura, ed., in English with Japanese translation by T. Kurosawa. 90 pp.
Smallwood, K. S. 2009. Mitigation in U.S. Wind Farms. Pages 68-76 in H. Hötker (Ed.), Birds of Prey and Wind Farms: Analysis of problems and possible solutions. Documentation of an International Workshop in Berlin, 21st and 22nd October 2008. Michael-Otto-Instiut im NABU, Goosstroot 1, 24861 Bergenhusen, Germany. http://bergenhusen.nabu.de/forschung/greifvoegel/ Smallwood, K. S. 2007. Notes and recommendations on wildlife impacts caused by Japan’s wind power development. Pages 242-245 in Yukihiro Kominami, Tatsuya Ura, Koshitawa, and Tsuchiya, Editors, Wildlife and Wind Turbine Report 5. Wild Bird Society of Japan, Tokyo.
Thelander, C.G. and S. Smallwood. 2007. The Altamont Pass Wind Resource Area's Effects on Birds: A Case History. Pages 25-46 in Manuela de Lucas, Guyonne F.E. Janss, Miguel Ferrer Editors, Birds and Wind Farms: risk assessment and mitigation. Madrid: Quercus.
Smallwood, K. S. and C. Thelander. 2006. Response to third review of Smallwood and Thelander (2004). In Terry Surles and Edward Vine, Eds., Avian/Wind Statistical Peer Review Project. Report to California Energy Commission. Contract No. 500-02-004. https://tethys.pnnl.gov/sites/default/files/publications/Surles-2006.pdf Neher, L. and S. Smallwood. 2005. Forecasting and minimizing avian mortality in siting wind turbines. Energy Currents. Fall Issue. ESRI, Inc., Redlands, California.
Jennifer Davidson and Shawn Smallwood. 2004. Laying plans for a hydrogen highway. Comstock’s Business, August 2004:18-20, 22, 24-26.
Jennifer Davidson and Shawn Smallwood. 2004. Refined conundrum: California consumers demand more oil while opposing refinery development. Comstock’s Business, November 2004:26- 27, 29-30.
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Smallwood, K.S. 2002. Review of “The Atlas of Endangered Species.” By Richard Mackay.
Environmental Conservation 30:210-211.
Smallwood, K.S. 2002. Review of “The Endangered Species Act. History, Conservation, and Public Policy.” By Brian Czech and Paul B. Krausman. Environmental Conservation 29: 269-270.
Smallwood, K.S. 1997. Spatial scaling of pocket gopher (Geomyidae) burrow volume. Abstract in Proceedings of 44th Annual Meeting, Southwestern Association of Naturalists. Department of Biological Sciences, University of Arkansas, Fayetteville.
Smallwood, K.S. 1997. Estimating prairie dog and pocket gopher burrow volume. Abstract in Proceedings of 44th Annual Meeting, Southwestern Association of Naturalists. Department of Biological Sciences, University of Arkansas, Fayetteville.
Smallwood, K.S. 1997. Animal burrowing parameters influencing toxic waste management.
Abstract in Proceedings of Meeting, Western Section of the Wildlife Society.
Smallwood, K.S, and Bruce Wilcox. 1996. Study and interpretive design effects on mountain lion density estimates. Abstract, page 93 in D.W. Padley, ed., Proceedings 5th Mountain Lion Workshop, Southern California Chapter, The Wildlife Society. 135 pp.
Smallwood, K.S, and Bruce Wilcox. 1996. Ten years of mountain lion track survey. Page 94 in D.W. Padley, ed. Abstract, page 94 in D.W. Padley, ed., Proceedings 5th Mountain Lion Workshop, Southern California Chapter, The Wildlife Society. 135 pp.
Smallwood, K.S, and M. Grigione. 1997. Photographic recording of mountain lion tracks. Pages 75- 75 in D.W. Padley, ed., Proceedings 5th Mountain Lion Workshop, Southern California Chapter, The Wildlife Society. 135 pp.
Smallwood, K.S., B. Wilcox, and J. Karr. 1995. An approach to scaling fragmentation effects. Brief 8, Ecosystem Indicators Working Group, 17 March, 1995. Institute for Sustainable Development, Thoreau Center for Sustainability – The Presidio, PO Box 29075, San Francisco, CA 94129-0075.
Wilcox, B., and K.S. Smallwood. 1995. Ecosystem indicators model overview. Brief 2, Ecosystem Indicators Working Group, 17 March, 1995. Institute for Sustainable Development, Thoreau Center for Sustainability – The Presidio, PO Box 29075, San Francisco, CA 94129-0075.
EIP Associates. 1996. Yolo County Habitat Conservation Plan. Yolo County Planning and Development Department, Woodland, California.
Geng, S., K.S. Smallwood, and M. Zhang. 1995. Sustainable agriculture and agricultural sustainability. Proc. 7th International Congress SABRAO, 2nd Industrial Symp. WSAA. Taipei, Taiwan.
Smallwood, K.S. and S. Geng. 1994. Landscape strategies for biological control and IPM. Pages 454-464 in W. Dehai, ed., Proc. International Conference on Integrated Resource Management for Sustainable Agriculture. Beijing Agricultural University, Beijing, China.
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Smallwood, K.S. and S. Geng. 1993. Alfalfa as wildlife habitat. California Alfalfa Symposium 23:105-8.
Smallwood, K.S. and S. Geng. 1993. Management of pocket gophers in Sacramento Valley alfalfa.
California Alfalfa Symposium 23:86-89.
Smallwood, K.S. and E.L. Fitzhugh. 1992. The use of track counts for mountain lion population census. Pages 59-67 in C. Braun, ed. Mountain lion-Human Interaction Symposium and Workshop.
Colorado Division of Wildlife, Fort Collins.
Smallwood, K.S. and E.L. Fitzhugh. 1989. Differentiating mountain lion and dog tracks. Pages 58- 63 in Smith, R.H., ed. Proc. Third Mountain Lion Workshop. Arizona Game and Fish Department, Phoenix.
Fitzhugh, E.L. and K.S. Smallwood. 1989. Techniques for monitoring mountain lion population levels. Pages 69-71 in Smith, R.H., ed. Proc. Third Mountain Lion Workshop. Arizona Game and Fish Department, Phoenix.
Reports to or by Alameda County Scientific Review Committee (Note: all documents linked to SRC website have since been removed by Alameda County)
Smallwood, K. S. 2014. Data Needed in Support of Repowering in the Altamont Pass WRA. SRC document P284, County of Alameda, Hayward, California.
Smallwood, K. S. 2013. Long-Term Trends in Fatality Rates of Birds and Bats in the Altamont Pass Wind Resource Area, California. SRC document R68, County of Alameda, Hayward, California.
Smallwood, K. S. 2013. Inter-annual Fatality rates of Target Raptor Species from 1999 through 2012 in the Altamont Pass Wind Resources Area. SRC document P268, County of Alameda, Hayward, California.
Smallwood, K. S. 2012. General Protocol for Performing Detection Trials in the FloDesign Study of the Safety of a Closed-bladed Wind Turbine. SRC document P246, County of Alameda, Hayward, California.
Smallwood, K. S., l. Neher, and J. Mount. 2012. Burrowing owl distribution and abundance study through two breeding seasons and intervening non-breeding period in the Altamont Pass Wind Resource Area, California. SRC document P245, County of Alameda, Hayward, California.
Smallwood, K. S 2012. Draft study design for testing collision risk of Flodesign wind turbine in former AES Seawest wind projects in the Altamont Pass Wind Resource Area (APWRA). SRC document P238, County of Alameda, Hayward, California.
Smallwood, L. Neher, and J. Mount. 2012. Winter 2012 update on burrowing owl distribution and abundance study in the Altamont Pass Wind Resource Area, California. SRC document P232, County of Alameda, Hayward, California.
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Smallwood, S. 2012. Status of avian utilization data collected in the Altamont Pass Wind Resource Area, 2005-2011. SRC document P231, County of Alameda, Hayward, California.
Smallwood, K. S., L. Neher, and J. Mount. 2011. Monitoring Burrow Use of Wintering Burrowing Owls. SRC document P229, County of Alameda, Hayward, California.
Smallwood, K. S., L. Neher, and J. Mount. 2011. Nesting Burrowing Owl Distribution and Abundance in the Altamont Pass Wind Resource Area, California. SRC document P228, County of Alameda, Hayward, California.
Smallwood, K. S. 2011. Draft Study Design for Testing Collision Risk of Flodesign Wind Turbine in Patterson Pass Wind Farm in the Altamont Pass Wind Resource Area (APWRA). http://www.altamontsrc.org/alt_doc/p100_src_document_list_with_reference_numbers.pdf Smallwood, K. S. 2011. Sampling Burrowing Owls Across the Altamont Pass Wind Resource Area.
SRC document P205, County of Alameda, Hayward, California.
Smallwood, K. S. 2011. Proposal to Sample Burrowing Owls Across the Altamont Pass Wind Resource Area. SRC document P155, County of Alameda, Hayward, California. SRC document P198, County of Alameda, Hayward, California.
Smallwood, K. S. 2010. Comments on APWRA Monitoring Program Update. SRC document P191, County of Alameda, Hayward, California.
Smallwood, K. S. 2010. Inter-turbine Comparisons of Fatality Rates in the Altamont Pass Wind Resource Area. SRC document P189, County of Alameda, Hayward, California.
Smallwood, K. S. 2010. Review of the December 2010 Draft of M-21: Altamont Pass Wind Resource Area Bird Collision Study. SRC document P190, County of Alameda, Hayward, California.
Alameda County SRC (Shawn Smallwood, Jim Estep, Sue Orloff, Joanna Burger, and Julie Yee).
Comments on the Notice of Preparation for a Programmatic Environmental Impact Report on Revised CUPs for Wind Turbines in the Alameda County portion of the Altamont Pass. SRC document P183, County of Alameda, Hayward, California.
Smallwood, K. S. 2010. Review of Monitoring Implementation Plan. SRC document P180, County of Alameda, Hayward, California.
Burger, J., J. Estep, S. Orloff, S. Smallwood, and J. Yee. 2010. SRC Comments on CalWEA Research Plan. SRC document P174, County of Alameda, Hayward, California.
Alameda County SRC (Smallwood, K. S., S. Orloff, J. Estep, J. Burger, and J. Yee). SRC Comments on Monitoring Team’s Draft Study Plan for Future Monitoring. SRC document P168, County of Alameda, Hayward, California.
Smallwood, K. S. 2010. Second Review of American Kestrel-Burrowing owl (KB) Scavenger Removal Adjustments Reported in Alameda County Avian Monitoring Team’s M21 for the
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Altamont Pass Wind Resource Area. SRC document P171, County of Alameda, Hayward, California.
Smallwood, K. S. 2010. Assessment of Three Proposed Adaptive Management Plans for Reducing Raptor Fatalities in the Altamont Pass Wind Resource Area. SRC document P161, County of Alameda, Hayward, California.
Smallwood, K. S. and J. Estep. 2010. Report of additional wind turbine hazard ratings in the Altamont Pass Wind Resource Area by Two Members of the Alameda County Scientific Review Committee. SRC document P153, County of Alameda, Hayward, California.
Smallwood, K. S. 2010. Alternatives to Improve the Efficiency of the Monitoring Program. SRC document P158, County of Alameda, Hayward, California.
Smallwood, S. 2010. Summary of Alameda County SRC Recommendations and Concerns and Subsequent Actions. SRC document P147, County of Alameda, Hayward, California.
Smallwood, S. 2010. Progress of Avian Wildlife Protection Program & Schedule. SRC document P148, County of Alameda, Hayward, California. SRC document P148, County of Alameda, Hayward, California.
Smallwood, S. 2010. Old-generation wind turbines rated for raptor collision hazard by Alameda County Scientific Review Committee in 2010, an Update on those Rated in 2007, and an Update on Tier Rankings. SRC document P155, County of Alameda, Hayward, California.
Smallwood, K. S. 2010. Review of American Kestrel-Burrowing owl (KB) Scavenger Removal Adjustments Reported in Alameda County Avian Monitoring Team’s M21 for the Altamont Pass Wind Resource Area. SRC document P154, County of Alameda, Hayward, California.
Smallwood, K. S. 2010. Fatality Rates in the Altamont Pass Wind Resource Area 1998-2009.
Alameda County SRC document P-145.
Smallwood, K. S. 2010. Comments on Revised M-21: Report on Fatality Monitoring in the Altamont Pass Wind Resource Area. SRC document P144, County of Alameda, Hayward, California.
Smallwood, K. S. 2009. SRC document P129, County of Alameda, Hayward, California.
Smallwood, K. S. 2009. Smallwood’s review of M32. SRC document P111, County of Alameda, Hayward, California.
Smallwood, K. S. 2009. 3
rd Year Review of 16 Conditional Use Permits for Windworks, Inc. and Altamont Infrastructure Company, LLC. Comment letter to East County Board of Zoning Adjustments. 10 pp + 2 attachments.
Smallwood, K. S. 2008. Weighing Remaining Workload of Alameda County SRC against Proposed Budget Cap. Alameda County SRC document not assigned. 3 pp.
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Alameda County SRC (Smallwood, K. S., S. Orloff, J. Estep, J. Burger, and J. Yee). 2008. SRC comments on August 2008 Fatality Monitoring Report, M21. SRC document P107, County of Alameda, Hayward, California.
Smallwood, K. S. 2008. Burrowing owl carcass distribution around wind turbines. SRC document P106, County of Alameda, Hayward, California.
Smallwood, K. S. 2008. Assessment of relocation/removal of Altamont Pass wind turbines rated as hazardous by the Alameda County SRC. SRC document P103, County of Alameda, Hayward, California.
Smallwood, K. S. and L. Neher. 2008. Summary of wind turbine-free ridgelines within and around the APWRA. SRC document P102, County of Alameda, Hayward, California.
Smallwood, K. S. and B. Karas. 2008. Comparison of mortality estimates in the Altamont Pass Wind Resource Area when restricted to recent fatalities. SRC document P101, County of Alameda, Hayward, California.
Smallwood, K. S. 2008. On the misapplication of mortality adjustment terms to fatalities missed during one search and found later. SRC document P97, County of Alameda, Hayward, California.
Smallwood, K. S. 2008. Relative abundance of raptors outside the APWRA. SRC document P88, County of Alameda, Hayward, California.
Smallwood, K. S. 2008. Comparison of mortality estimates in the Altamont Pass Wind Resource Area. SRC document P76, County of Alameda, Hayward, California.
Alameda County SRC (Smallwood, K. S., S. Orloff, J. Estep, J. Burger, and J. Yee). 2010.
Guidelines for siting wind turbines recommended for relocation to minimize potential collisionrelated mortality of four focal raptor species in the Altamont Pass Wind Resource Area. SRC document P70, County of Alameda, Hayward, California.
Alameda County SRC (J. Burger, Smallwood, K. S., S. Orloff, J. Estep, and J. Yee). 2007. First DRAFT of Hazardous Rating Scale First DRAFT of Hazardous Rating Scale. SRC document P69, County of Alameda, Hayward, California.
Alameda County SRC (Smallwood, K. S., S. Orloff, J. Estep, J. Burger, and J. Yee). December 11, 2007. SRC selection of dangerous wind turbines. Alameda County SRC document P-67. 8 pp.
Smallwood, S. October 6, 2007. Smallwood’s answers to Audubon’s queries about the SRC’s recommended four-month winter shutdown of wind turbines in the Altamont Pass. Alameda County SRC document P-23.
Smallwood, K. S. October 1, 2007. Dissenting opinion on recommendation to approve of the AWI Blade Painting Study. Alameda County SRC document P-60.
Smallwood, K. S. July 26, 2007. Effects of monitoring duration and inter-annual variability on precision of wind-turbine caused mortality estimates in the Altamont Pass Wind Resource Area,
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California. SRC Document P44.
Smallwood, K. S. July 26, 2007. Memo: Opinion of some SRC members that the period over which post-management mortality will be estimated remains undefined. SRC Document P43.
Smallwood, K. S. July 19, 2007. Smallwood’s response to P24G. SRC Document P41, 4 pp.
Smallwood, K. S. April 23, 2007. New Information Regarding Alameda County SRC Decision of 11 April 2007 to Grant FPLE Credits for Removing and Relocating Wind Turbines in 2004. SRC Document P26.
Alameda County SRC (Smallwood, K. S., S. Orloff, J. Estep, and J. Burger [J. Yee abstained]).
April 17, 2007. SRC Statement in Support of the Monitoring Program Scope and Budget.
Smallwood, K. S. April 15, 2007. Verification of Tier 1 & 2 Wind Turbine Shutdowns and Relocations. SRC Document P22.
Smallwood, S. April 15, 2007. Progress of Avian Wildlife Protection Program & Schedule.
Alameda County SRC (Smallwood, K. S., S. Orloff, J. Estep, J. Burger, and J. Yee). April 3, 2007.
Alameda County Scientific Review Committee replies to the parties’ responses to its queries and to comments from the California Office of the Attorney General. SRC Document S20.
Smallwood, S. March 19, 2007. Estimated Effects of Full Winter Shutdown and Removal of Tier I & II Turbines. SRC Document S19.
Smallwood, S. March 8, 2007. Smallwood’s Replies to the Parties’ Responses to Queries from the SRC and Comments from the California Office of the Attorney General. SRC Document S16.
Smallwood, S. March 8, 2007. Estimated Effects of Proposed Measures to be Applied to 2,500 Wind Turbines in the APWRA Fatality Monitoring Plan. SRC Document S15.
Alameda County SRC (Smallwood, K. S., S. Orloff, J. Estep, J. Burger, and J. Yee). February 7, 2007. Analysis of Monitoring Program in Context of 1/1//2007 Settlement Agreement.
Smallwood, S. January 8, 2007. Smallwood’s Concerns over the Agreement to Settle the CEQA Challenges. SRC Document S5.
Alameda County SRC (Smallwood, K. S., S. Orloff, J. Estep, J. Burger, and J. Yee). December 19, 2006. Altamont Scientific Review Committee (SRC) Recommendations to the County on the Avian Monitoring Team Consultants’ Budget and Organization.
Reports to Clients
Assessment of wildlife collision risk with fourth wind turbine layout of Sand Hill and Rooney Ranch Wind Farms. Report to Viracocha Wind, Bethesda Maryland, and Salka, San Diego, California. 2 pp.
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Smallwood, K. S. 2025. Review of Identifying Critical Drivers of Western Snowy Plover Reproductive Success to Guide Management Toward Recovery Goals (Neuman et al. 2024). Report to Center for Biological Diversity.
Smallwood, K. S. 2024. Assessment of grading impacts on eagles at Viracocha Wind. Report to Viracocha Wind, Bethesda Maryland, and Salka, San Diego, California. 1 p.
Smallwood, K. S. 2023. Assessment of wildlife collision risk with third wind turbine layout of Sand Hill & Rooney Ranch Wind Farm. Report to Viracocha Wind, Bethesda Maryland, and Salka, San Diego, California.
Smallwood, K. S. and D. A. Bell. 2022. Ground squirrel abundance and repeat raptor surveys at Vasco Caves Regional Preserve, 2006‒2019. Report to the East Contra Costa County Habitat Conservancy Science and Research Grant Program. 80 pp.
Smallwood, K. S. 2022c. Assessment of wildlife collision risk with second wind turbine layout of Sand Hill and Rooney Ranch Wind Farm. Report to Viracocha Wind LLC and Salka LLC.
Smallwood, K. S. 2022b. Assessment of wildlife collision risk with second wind turbine layout of Viracocha Wind Farm. Report to Viracocha Wind LLC and Salka LLC.
Smallwood, K. S. 2022. Survey for Burrow Systems of San Joaquin Kangaroo Rat (Dipotomys nitratoides) at Natural Resource Management Area 5, Naval Air Station, Lemoore. Report to U.S.
Navy.
Smallwood, K. S. 2022a. Assessment of wildlife collision risk with initial wind turbine layout of Viracocha Wind Farm. Report to Viracocha Wind LLC and Salka LLC.
Smallwood, K. S. 2020. Baseline Map of California Ground Squirrel Burrow Systems on Marsh Creek Preserve. Report to East Bay Regional Park District, Oakland, California.
Smallwood, K. S. 2020. Comparison of bird and bat fatality rates among utility-scale solar projects in California. Report to undisclosed client.
Smallwood, K. S., D. Bell, and S. Standish. 2018. Skilled dog detections of bat and small bird carcasses in wind turbine fatality monitoring. Report to East Bay Regional Park District, Oakland, California.
Smallwood, K. S. 2018. Addendum to Comparison of Wind Turbine Collision Hazard Model Performance: One-year Post-construction Assessment of Golden Eagle Fatalities at Golden Hills.
Report to Audubon Society, NextEra Energy, and the California Attorney General.
Smallwood, K. S., and L. Neher. 2018. Siting wind turbines to minimize raptor collisions at Sand Hill Repowering Project, Altamont Pass Wind Resource Area. Report to S-Power, Salt Lake City, Utah.
Smallwood, K. S., and L. Neher. 2018. Siting wind turbines to minimize raptor collisions at Rooney Ranch Repowering Project, Altamont Pass Wind Resource Area. Report to S-Power, Salt Lake City,
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Utah.
Smallwood, K. S. 2017. Summary of a burrowing owl conservation workshop. Report to Santa Clara Valley Habitat Agency, Morgan Hill, California.
Smallwood, K. S., and L. Neher. 2018. Comparison of wind turbine collision hazard model performance prepared for repowering projects in the Altamont Pass Wind Resources Area. Report to NextEra Energy Resources, Inc., Office of the California Attorney General, Audubon Society, East Bay Regional Park District.
Smallwood, K. S., and L. Neher. 2016. Siting wind turbines to minimize raptor collisions at Summit Winds Repowering Project, Altamont Pass Wind Resource Area. Report to Salka, Inc., Washington, D.C.
Smallwood, K. S., L. Neher, and D. A. Bell. 2017. Mitigating golden eagle impacts from repowering Altamont Pass Wind Resource Area and expanding Los Vaqueros Reservoir. Report to East Contra Costa County Habitat Conservation Plan Conservancy and Contra Costa Water District.
Smallwood, K. S. 2016. Review of avian-solar science plan. Report to Center for Biological Diversity. 28 pp
Smallwood, K. S. 2016. Report of Altamont Pass research as Vasco Winds mitigation. Report to NextEra Energy Resources, Inc., Office of the California Attorney General, Audubon Society, East Bay Regional Park District.
Smallwood, K. S., and L. Neher. 2016. Siting Wind Turbines to Minimize Raptor collisions at Sand Hill Repowering Project, Altamont Pass Wind Resource Area. Report to Ogin, Inc., Waltham, Massachusetts.
Smallwood, K. S., and L. Neher. 2015a. Siting wind turbines to minimize raptor collisions at Golden Hills Repowering Project, Altamont Pass Wind Resource Area. Report to NextEra Energy Resources, Livermore, California.
Smallwood, K. S., and L. Neher. 2015b. Siting wind turbines to minimize raptor collisions at Golden Hills North Repowering Project, Altamont Pass Wind Resource Area. Report to NextEra Energy Resources, Livermore, California.
Smallwood, K. S., and L. Neher. 2015c. Siting wind turbines to minimize raptor collisions at the Patterson Pass Repowering Project, Altamont Pass Wind Resource Area. Report to EDF Renewable Energy, Oakland, California.
Smallwood, K. S., and L. Neher. 2014. Early assessment of wind turbine layout in Summit Wind Project. Report to Altamont Winds LLC, Tracy, California.
Smallwood, K. S. 2015. Review of avian use survey report for the Longboat Solar Project. Report to EDF Renewable Energy, Oakland, California.
Smallwood, K. S. 2014. Information needed for solar project impacts assessment and mitigation
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planning. Report to Panorama Environmental, Inc., San Francisco, California.
Smallwood, K. S. 2014. Monitoring fossorial mammals in Vasco Caves Regional Preserve, California: Report of Progress for the period 2006-2014. Report to East Bay Regional Park District, Oakland, California.
Smallwood, K. S. 2013. First-year estimates of bird and bat fatality rates at old wind turbines, Forebay areas of Altamont Pass Wind Resource Area. Report to FloDesign in support of EIR.
Smallwood, K. S. and W. Pearson. 2013. Neotropical bird monitoring of burrowing owls (Athene cunicularia), Naval Air Station Lemoore, California. Tierra Data, Inc. report to Naval Air Station Lemoore.
Smallwood, K. S. 2013. Winter surveys for San Joaquin kangaroo rat (Dipodomys nitratoides) and burrowing owls (Athene cunicularia) within Air Operations at Naval Air Station, Lemoore. Report to Tierra Data, Inc. and Naval Air Station Lemoore.
Smallwood, K. S. and M. L. Morrison. 2013. San Joaquin kangaroo rat (Dipodomys n. nitratoides) conservation research in Resource Management Area 5, Lemoore Naval Air Station: 2013 Final Report (Inclusive of work during 2000-2013). Naval Facilities Engineering Command, Southwest, Desert Integrated Products Team, San Diego, California.
Smallwood, K. S. and M. L. Morrison. 2013. San Joaquin kangaroo rat (Dipodomys n. nitratoides) conservation research in Resource Management Area 5, Lemoore Naval Air Station: 2012 Progress Report (Inclusive of work during 2000-2012). Naval Facilities Engineering Command, Southwest, Desert Integrated Products Team, San Diego, California.
Smallwood, K. S. 2012. Fatality rate estimates at the Vantage Wind Energy Project, year one.
Report to Ventus Environmental, Portland, Oregon.
Smallwood, K. S. and L. Neher. 2012. Siting wind turbines to minimize raptor collisions at North Sky River. Report to NextEra Energy Resources, LLC.
Smallwood, K. S. 2011. Monitoring Fossorial Mammals in Vasco Caves Regional Preserve, California: Report of Progress for the Period 2006-2011. Report to East Bay Regional Park District.
Smallwood, K. S. and M. L. Morrison. 2011. San Joaquin kangaroo rat (Dipodomys n. nitratoides) Conservation Research in Resource Management Area 5, Lemoore Naval Air Station: 2011 Progress Report (Inclusive of work during 2000-2011). Naval Facilities Engineering Command, Southwest, Desert Integrated Products Team, San Diego, California.
Smallwood, K. S. 2011. Draft study design for testing collision risk of FloDesign Wind Turbine in Patterson Pass, Santa Clara, and Former AES Seawest Wind Projects in the Altamont Pass Wind Resource Area (APWRA). Report to FloDesign, Inc.
Smallwood, K. S. 2011. Comments on Marbled Murrelet collision model for the Radar Ridge Wind Resource Area. Report to EcoStat, Inc., and ultimately to US Fish and Wildlife Service.
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Smallwood, K. S. 2011. Avian fatality rates at Buena Vista Wind Energy Project, 2008-2011.
Report to Pattern Energy.
Smallwood, K. S. and L. Neher. 2011. Siting repowered wind turbines to minimize raptor collisions at Tres Vaqueros, Contra Costa County, California. Report to Pattern Energy.
Smallwood, K. S. and M. L. Morrison. 2011. San Joaquin kangaroo rat (Dipodomys n. nitratoides) Conservation Research in Resource Management Area 5, Lemoore Naval Air Station: 2010 Progress Report (Inclusive of work during 2000-2010). Naval Facilities Engineering Command, Southwest, Desert Integrated Products Team, San Diego, California.
Smallwood, K. S. 2010. Wind Energy Development and avian issues in the Altamont Pass, California. Report to Black & Veatch.
Smallwood, K. S. and L. Neher. 2010. Siting repowered wind turbines to minimize raptor collisions at the Tres Vaqueros Wind Project, Contra Costa County, California. Report to the East Bay Regional Park District, Oakland, California.
Smallwood, K. S. and L. Neher. 2010. Siting repowered wind turbines to minimize raptor collisions at Vasco Winds. Report to NextEra Energy Resources, LLC, Livermore, California.
Smallwood, K. S. 2010. Baseline avian and bat fatality rates at the Tres Vaqueros Wind Project, Contra Costa County, California. Report to the East Bay Regional Park District, Oakland, California.
Smallwood, K. S. and M. L. Morrison. 2010. San Joaquin kangaroo rat (Dipodomys n. nitratoides) Conservation Research in Resource Management Area 5, Lemoore Naval Air Station: 2009 Progress Report (Inclusive of work during 2000-2009). Naval Facilities Engineering Command, Southwest, Desert Integrated Products Team, San Diego, California. 86 pp.
Smallwood, K. S. 2009. Mammal surveys at naval outlying landing field Imperial Beach, California, August 2009. Report to Tierra Data, Inc. 5 pp Smallwood, K. S. 2009. Mammals and other Wildlife Observed at Proposed Site of Amargosa Solar Power Project, Spring 2009. Report to Tierra Data, Inc. 13 pp Smallwood, K. S. 2009. Avian Fatality Rates at Buena Vista Wind Energy Project, 2008-2009.
Report to members of the Contra Costa County Technical Advisory Committee on the Buena Vista Wind Energy Project. 8 pp.
Smallwood, K. S. 2009. Repowering the Altamont Pass Wind Resource Area more than Doubles Energy Generation While Substantially Reducing Bird Fatalities. Report prepared on behalf of Californians for Renewable Energy. 2 pp.
Smallwood, K. S. and M. L. Morrison. 2009. Surveys to Detect Salt Marsh Harvest Mouse and California Black Rail at Installation Restoration Site 30, Military Ocean Terminal Concord, California: March-April 2009. Report to Insight Environmental, Engineering, and Construction, Inc., Sacramento, California. 6 pp.
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Smallwood, K. S. 2008. Avian and Bat Mortality at the Big Horn Wind Energy Project, Klickitat County, Washington. Unpublished report to Friends of Skamania County. 7 pp.
Smallwood, K. S. 2009. Monitoring Fossorial Mammals in Vasco Caves Regional Preserve, California: report of progress for the period 2006-2008. Unpublished report to East Bay Regional Park District. 5 pp.
Smallwood, K. S. and M. L. Morrison. 2008. San Joaquin kangaroo rat (Dipodomys n. nitratoides) Conservation Research in Resource Management Area 5, Lemoore Naval Air Station: 2008 Progress Report (Inclusive of work during 2000-2008). Naval Facilities Engineering Command, Southwest, Desert Integrated Products Team, San Diego, California. 84 pp.
Smallwood, K. S. and M. L. Morrison. 2008. Habitat Assessment for California Red-Legged Frog at Naval Weapons Station, Seal Beach, Detachment Concord, California. Naval Facilities Engineering Command, Southwest, Desert Integrated Products Team, San Diego, California. 48 pp.
Smallwood, K. S. and B. Nakamoto. 2008. Impact of 2005 and 2006 West Nile Virus on Yellowbilled Magpie and American Crow in the Sacramento Valley, California. 22 pp.
Smallwood, K. S. and M. L. Morrison. 2008. Former Naval Security Group Activity (NSGA), Skaggs Island, Waste and Contaminated Soil Removal Project (IR Site #2), San Pablo Bay, Sonoma County, California: Re-Vegetation Monitoring. Report to U.S. Navy, Letter Agreement – N68711- 04LT-A0045. Naval Facilities Engineering Command, Southwest, Desert Integrated Products Team, San Diego, California. 10 pp.
Smallwood, K. S. and M. L. Morrison. 2008. Burrowing owls at Dixon Naval Radio Transmitter Facility. Report to U.S. Navy. Naval Facilities Engineering Command, Southwest, Desert Integrated Products Team, San Diego, California. 28 pp.
Smallwood, K. S. and M. L. Morrison. 2008. San Joaquin kangaroo rat (Dipodomys n. nitratoides) Conservation Research in Resource Management Area 5, Lemoore Naval Air Station: 2007 Progress Report (Inclusive of work during 2001-2007). Naval Facilities Engineering Command, Southwest, Desert Integrated Products Team, San Diego, California. 69 pp.
Smallwood, K. S. and M. L. Morrison. 2007. A Monitoring Effort to Detect the Presence of the Federally Listed Species California Clapper Rail and Salt Marsh Harvest Mouse, and Wetland Habitat Assessment at the Naval Weapons Station, Seal Beach, Detachment Concord, California.
Installation Restoration (IR) Site 30, Final Report to U.S. Navy, Letter Agreement – N68711-05LTA0001. U.S. Navy Integrated Product Team (IPT), West, Naval Facilities Engineering Command, San Diego, California. 8 pp.
Smallwood, K. S. and M. L. Morrison. 2007. San Joaquin kangaroo rat (Dipodomys n. nitratoides) Conservation Research in Resource Management Area 5, Lemoore Naval Air Station: 2006 Progress Report (Inclusive of work during 2001-2006). U.S. Navy Integrated Product Team (IPT), West, Naval Facilities Engineering Command, Southwest, Daly City, California. 165 pp.
Smallwood, K. S. and C. Thelander. 2006. Response to third review of Smallwood and Thelander
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(2004). Report to California Institute for Energy and Environment, University of California, Oakland, CA. 139 pp.
Smallwood, K. S. 2006. Biological effects of repowering a portion of the Altamont Pass Wind Resource Area, California: The Diablo Winds Energy Project. Report to Altamont Working Group.
Available from Shawn Smallwood, [email protected] . 34 pp.
Smallwood, K. S. 2006. Impact of 2005 West Nile Virus on yellow-billed magpie and american crow in the Sacramento Valley, California. Report to Sacramento-Yolo Mosquito and Vector Control District, Elk Grove, CA. 38 pp.
Smallwood, K. S. and M. L. Morrison. 2006. San Joaquin kangaroo rat (Dipodomys n. nitratoides) Conservation Research in Resource Management Area 5, Lemoore Naval Air Station: 2005 Progress Report (Inclusive of work during 2001-2005). U.S. Navy Integrated Product Team (IPT), West, Naval Facilities Engineering Command, South West, Daly City, California. 160 pp.
Smallwood, K. S. and M. L. Morrison. 2006. A monitoring effort to detect the presence of the federally listed species California tiger salamander and California red-legged frog at the Naval Weapons Station, Seal Beach, Detachment Concord, California. Letter agreements N68711-04LTA0042 and N68711-04LT-A0044, U.S. Navy Integrated Product Team (IPT), West, Naval Facilities Engineering Command, South West, Daly City, California. 60 pp.
Smallwood, K. S. and M. L. Morrison. 2006. A monitoring effort to detect the presence of the federally listed species California Clapper Rail and Salt Marsh Harvest Mouse, and wetland habitat assessment at the Naval Weapons Station, Seal Beach, Detachment Concord, California. Sampling for rails, Spring 2006, Installation Restoration (IR) Site 1. Letter Agreement – N68711-05lt-A0001, U.S. Navy Integrated Product Team (IPT), West, Naval Facilities Engineering Command, South West, Daly City, California. 9 pp.
Morrison, M. L. and K. S. Smallwood. 2006. Final Report: Station-wide Wildlife Survey, Naval Air Station, Lemoore. Department of the Navy Integrated Product Team (IPT) West, Naval Facilities Engineering Command Southwest, 2001 Junipero Serra Blvd., Suite 600, Daly City, CA 94014- 1976. 20 pp.
Smallwood, K. S. and M. L. Morrison. 2006. Former Naval Security Group Activity (NSGA), Skaggs Island, Waste and Contaminated Soil Removal Project, San Pablo Bay, Sonoma County, California: Re-vegetation Monitoring. Department of the Navy Integrated Product Team (IPT) West, Naval Facilities Engineering Command Southwest, 2001 Junipero Serra Blvd., Suite 600, Daly City, CA 94014-1976. 8 pp.
Dorin, Melinda, Linda Spiegel and K. Shawn Smallwood. 2005. Response to public comments on the staff report entitled Assessment of Avian Mortality from Collisions and Electrocutions (CEC700-2005-015) (Avian White Paper) written in support of the 2005 Environmental Performance Report and the 2005 Integrated Energy Policy Report. California Energy Commission, Sacramento. 205 pp.
Smallwood, K. S. 2005. Estimating combined effects of selective turbine removal and winter-time shutdown of half the wind turbines. Unpublished CEC staff report, June 23. 1 p.
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Erickson, W. and S. Smallwood. 2005. Avian and Bat Monitoring Plan for the Buena Vista Wind Energy Project Contra Costa County, California. Unpubl. report to Contra Costa County, Antioch, California. 22 pp.
Lamphier-Gregory, West Inc., Shawn Smallwood, Jones & Stokes Associates, Illingworth & Rodkin Inc. and Environmental Vision. 2005. Environmental Impact Report for the Buena Vista Wind Energy Project, LP# 022005. County of Contra Costa Community Development Department, Martinez, California.
Morrison, M. L. and K. S. Smallwood. 2005. A monitoring effort to detect the presence of the federally listed species California clapper rail and salt marsh harvest mouse, and wetland habitat assessment at the Naval Weapons Station, Seal Beach, Detachment Concord, California. Targeted Sampling for Salt Marsh Harvest Mouse, Fall 2005 Installation Restoration (IR) Site 30. Letter Agreement – N68711-05lt-A0001, U.S. Department of the Navy, Naval Facilities Engineering Command Southwest, Daly City, California. 6 pp.
Morrison, M. L. and K. S. Smallwood. 2005. A monitoring effort to detect the presence of the federally listed species California clapper rail and salt marsh harvest mouse, and wetland habitat assessment at the Naval Weapons Station, Seal Beach, Detachment Concord, California. Letter Agreement – N68711-05lt-A0001, U.S. Department of the Navy, Naval Facilities Engineering Command Southwest, Daly City, California. 5 pp.
Morrison, M. L. and K. S. Smallwood. 2005. Skaggs Island waste and contaminated soil removal projects, San Pablo Bay, Sonoma County, California. Report to the U.S. Department of the Navy, Naval Facilities Engineering Command Southwest, Daly City, California. 6 pp.
Smallwood, K. S. and M. L. Morrison. 2004. 2004 Progress Report: San Joaquin kangaroo rat (Dipodomys nitratoides) Conservation Research in Resources Management Area 5, Lemoore Naval Air Station. Progress report to U.S. Department of the Navy, Lemoore, California. 134 pp.
Smallwood, K. S. and L. Spiegel. 2005a. Assessment to support an adaptive management plan for the APWRA. Unpublished CEC staff report, January 19. 19 pp.
Smallwood, K. S. and L. Spiegel. 2005b. Partial re-assessment of an adaptive management plan for the APWRA. Unpublished CEC staff report, March 25. 48 pp.
Smallwood, K. S. and L. Spiegel. 2005c. Combining biology-based and policy-based tiers of priority for determining wind turbine relocation/shutdown to reduce bird fatalities in the APWRA.
Unpublished CEC staff report, June 1. 9 pp.
Smallwood, K. S. 2004. Alternative plan to implement mitigation measures in APWRA.
Unpublished CEC staff report, January 19. 8 pp.
Smallwood, K. S., and L. Neher. 2005. Repowering the APWRA: Forecasting and minimizing avian mortality without significant loss of power generation. California Energy Commission, PIER Energy-Related Environmental Research. CEC-500-2005-005. 21 pp. [Reprinted (in Japanese) in Yukihiro Kominami, Tatsuya Ura, Koshitawa, and Tsuchiya, Editors, Wildlife and Wind Turbine
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Report 5. Wild Bird Society of Japan, Tokyo.]
Morrison, M. L., and K. S. Smallwood. 2004. Kangaroo rat survey at RMA4, NAS Lemoore.
Report to U.S. Navy. 4 pp.
Morrison, M. L., and K. S. Smallwood. 2004. A monitoring effort to detect the presence of the federally listed species California clapper rails and wetland habitat assessment at Pier 4 of the Naval Weapons Station, Seal Beach, Detachment Concord, California. Letter Agreement N68711-04LTA0002. 8 pp. + 2 pp. of photo plates.
Smallwood, K. S. and M. L. Morrison. 2003. 2003 Progress Report: San Joaquin kangaroo rat (Dipodomys nitratoides) Conservation Research at Resources Management Area 5, Lemoore Naval Air Station. Progress report to U.S. Department of the Navy, Lemoore, California. 56 pp. + 58 figures.
Smallwood, K. S. 2003. Comparison of Biological Impacts of the No Project and Partial Underground Alternatives presented in the Final Environmental Impact Report for the JeffersonMartin 230 kV Transmission Line. Report to California Public Utilities Commission. 20 pp.
Morrison, M. L., and K. S. Smallwood. 2003. Kangaroo rat survey at RMA4, NAS Lemoore.
Report to U.S. Navy. 6 pp. + 7 photos + 1 map.
Smallwood, K. S. 2003. Assessment of the Environmental Review Documents Prepared for the Tesla Power Project. Report to the California Energy Commission on behalf of Californians for Renewable Energy. 32 pp.
Smallwood, K. S., and M. L. Morrison. 2003. 2002 Progress Report: San Joaquin kangaroo rat (Dipodomys nitratoides) Conservation Research at Resources Management Area 5, Lemoore Naval Air Station. Progress report to U.S. Department of the Navy, Lemoore, California. 45 pp. + 36 figures.
Smallwood, K. S., Michael L. Morrison and Carl G. Thelander 2002. Study plan to test the effectiveness of aerial markers at reducing avian mortality due to collisions with transmission lines:
A report to Pacific Gas & Electric Company. 10 pp.
Smallwood, K. S. 2002. Assessment of the Environmental Review Documents Prepared for the East Altamont Energy Center. Report to the California Energy Commission on behalf of Californians for Renewable Energy. 26 pp.
Thelander, Carl G., K. Shawn Smallwood, and Christopher Costello. 2002 Rating Distribution Poles for Threat of Raptor Electrocution and Priority Retrofit: Developing a Predictive Model. Report to Southern California Edison Company. 30 pp.
Smallwood, K. S., M. Robison, and C. Thelander. 2002. Draft Natural Environment Study, Prunedale Highway 101 Project. California Department of Transportation, San Luis Obispo, California. 120 pp.
Smallwood, K.S. 2001. Assessment of ecological integrity and restoration potential of
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Beeman/Pelican Farm. Draft Report to Howard Beeman, Woodland, California. 14 pp.
Smallwood, K. S., and M. L. Morrison. 2002. Fresno kangaroo rat (Dipodomys nitratoides) Conservation Research at Resources Management Area 5, Lemoore Naval Air Station. Progress report to U.S. Department of the Navy, Lemoore, California. 29 pp. + 19 figures.
Smallwood, K.S. 2001. Rocky Flats visit, April 4th through 6th, 2001. Report to Berger & Montaque, P.C. 16 pp. with 61 color plates.
Smallwood, K.S. 2001. Affidavit of K. Shawn Smallwood, Ph.D. in the matter of the U.S. Fish and Wildlife Service’s rejection of Seatuck Environmental Association’s proposal to operate an education center on Seatuck National Wildlife Refuge. Submitted to Seatuck Environmental Association in two parts, totaling 7 pp.
Magney, D., and K.S. Smallwood. 2001. Maranatha High School CEQA critique. Comment letter submitted to Tamara & Efren Compeán, 16 pp.
Smallwood, K. S. and D. Magney. 2001. Comments on the Newhall Ranch November 2000 Administrative Draft EIR. Prepared for Ventura County Counsel regarding the Newhall Ranch Specific Plan EIR. 68 pp.
Magney, D. and K. S. Smallwood. 2000. Newhall Ranch Notice of Preparation Submittal. Prepared for Ventura County Counsel regarding our recommended scope of work for the Newhall Ranch Specific Plan EIR. 17 pp.
Smallwood, K. S. 2000. Comments on the Preliminary Staff Assessment of the Contra Costa Power Plant Unit 8 Project. Submitted to California Energy Commission on November 30 on behalf of Californians for Renewable Energy (CaRE). 4 pp.
Smallwood, K. S. 2000. Comments on the California Energy Commission’s Final Staff Assessment of the MEC. Submitted to California Energy Commission on October 29 on behalf of Californians for Renewable Energy (CaRE). 8 pp.
Smallwood, K. S. 2000. Comments on the Biological Resources Mitigation Implementation and Monitoring Plan (BRMIMP). Submitted to California Energy Commission on October 29 on behalf of Californians for Renewable Energy (CaRE). 9 pp.
Smallwood, K. S. 2000. Comments on the Preliminary Staff Assessment of the Metcalf Energy Center. Submitted to California Energy Commission on behalf of Californians for Renewable Energy (CaRE). 11 pp.
Smallwood, K. S. 2000. Preliminary report of reconnaissance surveys near the TRW plant south of Phoenix, Arizona, March 27-29. Report prepared for Hagens, Berman & Mitchell, Attorneys at Law, Phoenix, AZ. 6 pp.
Morrison, M. L., K. S. Smallwood, and M. Robison. 2001. Draft Natural Environment Study for Highway 46 compliance with CEQA/NEPA. Report to the California Department of Transportation. 75 pp.
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Morrison, M.L., and K.S. Smallwood. 1999. NTI plan evaluation and comments. Exhibit C in W.D.
Carrier, M.L. Morrison, K.S. Smallwood, and Vail Engineering. Recommendations for NBHCP land acquisition and enhancement strategies. Northern Territories, Inc., Sacramento.
Smallwood, K. S. 1999. Estimation of impacts due to dredging of a shipping channel through Humboldt Bay, California. Court Declaration prepared on behalf of EPIC.
Smallwood, K. S. 1998. 1998 California mountain lion track count. Report to the Defenders of Wildlife, Washington, D.C. 5 pages.
Smallwood, K.S. 1998. Draft report of a visit to a paint sludge dump site near Ridgewood, New Jersey, February 26th, 1998. Unpublished report to Consulting in the Public Interest.
Smallwood, K.S. 1997. Science missing in the “no surprises” policy. Commissioned by National Endangered Species Network and Spirit of the Sage Council, Pasadena, California.
Smallwood, K.S. and M.L. Morrison. 1997. Alternate mitigation strategy for incidental take of giant garter snake and Swainson’s hawk as part of the Natomas Basin Habitat Conservation Plan. Pages 6-9 and iii illustrations in W.D. Carrier, K.S. Smallwood and M.L. Morrison, Natomas Basin Habitat Conservation Plan: Narrow channel marsh alternative wetland mitigation. Northern Territories, Inc., Sacramento.
Smallwood, K.S. 1996. Assessment of the BIOPORT model's parameter values for pocket gopher burrowing characteristics. Report to Berger & Montague, P.C. and Roy S. Haber, P.C., Philadelphia. (peer reviewed).
Smallwood, K.S. 1997. Assessment of plutonium releases from Hanford buried waste sites. Report Number 9, Consulting in the Public Interest, 53 Clinton Street, Lambertville, New Jersey, 08530.
Smallwood, K.S. 1996. Soil Bioturbation and Wind Affect Fate of Hazardous Materials that were Released at the Rocky Flats Plant, Colorado. Report to Berger & Montague, P.C., Philadelphia.
Smallwood, K.S. 1996. Second assessment of the BIOPORT model's parameter values for pocket gopher burrowing characteristics and other relevant wildlife observations. Report to Berger & Montague, P.C. and Roy S. Haber, P.C., Philadelphia.
Smallwood, K.S., and R. Leidy. 1996. Wildlife and their management under the Martell SYP.
Report to Georgia Pacific, Corporation, Martel, CA. 30 pp.
EIP Associates. 1995. Yolo County Habitat Conservation Plan Biological Resources Report. Yolo County Planning and Development Department, Woodland, California.
Smallwood, K.S. and S. Geng. 1995. Analysis of the 1987 California Farm Cost Survey and recommendations for future survey. Program on Workable Energy Regulation, University-wide Energy Research Group, University of California.
Smallwood, K.S., S. Geng, and W. Idzerda. 1992. Final report to PG&E: Analysis of the 1987
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California Farm Cost Survey and recommendations for future survey. Pacific Gas & Electric Company, San Ramon, California. 24 pp.
Fitzhugh, E.L. and K.S. Smallwood. 1987. Methods Manual – A statewide mountain lion population index technique. California Department of Fish and Game, Sacramento.
Salmon, T.P. and K.S. Smallwood. 1989. Final Report – Evaluating exotic vertebrates as pests to California agriculture. California Department of Food and Agriculture, Sacramento.
Smallwood, K.S. and W. A. Erickson (written under supervision of W.E. Howard, R.E. Marsh, and R.J. Laacke). 1990. Environmental exposure and fate of multi-kill strychnine gopher baits. Final Report to USDA Forest Service –NAPIAP, Cooperative Agreement PSW-89-0010CA.
Fitzhugh, E.L., K.S. Smallwood, and R. Gross. 1985. Mountain lion track count, Marin County, 1985. Report on file at Wildlife Extension, University of California, Davis.
Written Expert Testimony on Environmental Documents (Year; pages) I was retained or commissioned to comment on environmental planning and review documents, including:
Pacific Palmdale DEIR, Palmdale (2026; 50);
Village Farms Project FEIR, Davis (2026; 17);
Village Farms Project DEIR, Davis (2025; 19);
7336 PS Solar Project DEIR, Twentynine Palms (2026; 52); Baker Street Warehouse Project DEIR, Lake Elsinore (2026; 55); Dexter Village IS/MND, Lake Elsinore (2026 ; 52);
83 Princess Street, California Design Review, City of Sausalito (2026; 39); Replies to responses to comments on Bridgehead Industrial Project DEIR, City of Oakley (2026; 49);
Delta Conveyance Project Incidental Take Permit, California Department of Water Resources (2025; 37);
Tri Pointe Homes Staff Report, City of Banning (2025; 38); Replies to responses to comments on Locust Gateway Development Project DEIR, City of Rialto (2025; 30);
Meredith International Centre Specific Plan Amendment – Planning Area 3 Project FEIR Addendum, City of Ontario (2025; 44);
Pepper 210 Commerce Center Project IS/MND, City of Rialto (2025; 35); Pacific Gateway Specific Plan Project DEIR, San Joaquin County (2025; 57); Lake Creek Logistics Center DEIR, City of Apple Valley (2025; 49); Replies to responses to comments on E&P Technology Way - Building A & B IS/MND, County of Napa (2025; 56);
Menifee 27 Residential Staff Report (2025; 46);
Shingle Springs Band of Miwok Indians 295.7-Acre Fee-to-Trust Project Environmental Assessment (2025; 17);
Catavina Residential Project IS/MND, Palm Desert (2025; 52);
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Menifee Business Park DEIR (2025; 43);
Replies to responses to comments on Ophir Road Warehouse Project DEIR, Oroville (2025; 19);
Thermal Ranch Specific Plan DEIR, County of Riverside (2025; 53); Camino Pablo Single-Family Residential Subdivision IS/MND, Morgan Hill (2025; 44); Adesa Foods Project IS/MND, City of Rialto (2025; 34); Entrada South and Valencia Commerce Center SEIR, County of Los Angeles (2025; 61); Malibu Vineyards Industrial Parkway Project DREIR, City of Bakersfield (2025; 37); Locust Gateway Development Project DEIR, City of Rialto (2025; 41); FSRE Industrial Concord Project DEIR, City of Concord (2025; 34); Bridgehead Industrial Project DEIR, City of Oakley (2025; 40); San Francisco Housing Element 2022 Update FEIR Addendum (2025; 22); Trails at Lyons Canyon DEIR, County of Los Angeles (2025; 55); Replies to responses to comments on Conejo Summit Project DEIR, Thousand Oaks (2025; 30);
Replies to responses to comments on Rome Hill Commercial IS/MND, City of Lake Elsinore (2025; 16);
Rome Hill Commercial IS/MND, City of Lake Elsinore (2025; 34); Replies to responses to comments on Town & Country Village Project DEIR, County of El Dorado (2025; 46);
Arroyo Vista Project DEIR. County of Riverside (2025; 46); Rubio Village Mixed-Use Project IS/MND, City of San Gabriel (2025; 64); Replies to responses to comments on Bickmore Warehouse IS/MND, Hesperia (2025; 4); Vesting Tentative Tract Map 7500 Staff Report, City of Bakersfield (2025; 10); Spirit Living at 55 Thomas Dr/70 Knoll Rd Design Plans, Tiburon (2025; 39); Cargo Solutions Truck Warehouse and Truck Stop Hesperia Project IS/MND (2025; 40); Fontana Master Case No. 23-0101, Conditional Use Permit No. 24-0022, and Design Review No. 23-0024 Class-32 CEQA Categorical Exemption, City of Fontana (2025; 32); Vesting Tentative Tract Map 7471 IS/MND, City of Bakersfield (2025; 46); Replies to responses to comments on Upper Westside Specific Plan DEIR, County of Sacramento (2025; 56);
Upper Westside Specific Plan DEIR, County of Sacramento (2025; 63); Flat Creek Solar Project Major Renewable Energy Facility Siting Permit pursuant to Article VIII of the New York State Public Service Law, Towns of Root and Canajoharie, Montgomery County, New York (2025; 37);
Replies to responses to comments on Dogwood Geothermal Energy Project DEIR, Imperial County (2025; 22);
Wineville Development Project DEIR, Jurupa Valley (2025; 43); Desert Business Park MSD Addendum, County of Riverside (2025; 29); Chino Gateway Terminal Project DEIR Addendum, Chino (2025; 39); Mesa Verde Specific Plan DSEIR, City of Calimesa (2025; 53); Harvest Landing Retail Center & Business Park DEIR, City of Perris (2025; 40); Hive Live Project DEIR, Costa Mesa (2025; 37);
Perris Airport Logistics Center DEIR, Perris (2025; 41); Vehicle-Caused Mortality of Western Snowy Plovers On Oceano Dunes State Vehicular
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Recreation Area (2025; 17);
Dakota Warehouse Project IS/MND, Apple Valley (2025; 36); Delta Conveyance Project FEIR, CDFW ITP, California Department of Water Resources (2025; 45);
Oceanside Transit Center EIR, Oceanside (2025; 41);
Auburn Development, Ecosave III (LDP 23-02) IS/MND, Adelanto (2025; 39); Replies to responses to comments on Dogwood Geothermal and Solar DEIR, Imperial County (2025; 22);
Pinyon Solar Project EA, BLM, Phoenix (2025; 63);
Armorlite Lofts Project DEIR/FEIR, San Marcos (2025; 47); Ophir Road Warehouse Project DEIR, Oroville (2025; 47); Intex Corporate Office and Fulfillment Center Project, Long Beach (2025; 35); Sywest Industrial Building FEIR, Goleta (2025; 42);
Vista Santa Domingo Warehouse Project rezone, Otay Mesa (2025; 28); Replies to responses to comments on Airport South Industrial Park and City Annexation DEIR, Sacramento (2025; 33);
Flat Creek Solar Project 94-c Permit for Major Renewable Energy Facility, Montgomery County, New York (2025; 29);
Bickmore Warehouse IS/MND, Hesperia (2025; 25);
Replies to responses to comments on Brew Enterprises Warehouse, Perris (2025; 41); Nexus Hotel IS.MND, Palm Springs (2025; 33);
Ranegras Plains Energy Center Project DEIS, Arizona (2025; 58); Riverside County General Plan Amendment for 350,000+ sf warehouse (2025; 31); Riverside County General Plan Amendment for 224,800 sf warehouse (2025; 29); Hageman Industrial Park DEIR, Bakersfield (2025; 42); Adelanto Warehouse CEQA Exemption (2025; 25);
Tire Recycling Facility IS/MND, Adelanto (2025; 29);
Replies to responses to comments on Sites Reservoir Application to California Water Board (2025; 41);
Bakersfield General Plan Amendment/Zone Change No. 24-0372, Bakersfield (2025; 29); The Pointe Apartments CEQA Exemption, Oxnard (2025; 37); Mill Point Solar I Article VIII Permit for Major Renewable Energy Facility, Montgomery County, New York (2025; 36);
Conejo Summit Project DEIR, Thousand Oaks (2025; 45); Replies to responses to comments on March Plaza IS/MND, Perris (2025; 5); March Plaza IS/MND, Perris (2024; 32);
Replies to responses to comments on Arcadia Town Center IS/MND, Arcadia (2025; 3); Arcadia Town Center IS/MND, Arcadia (2024; 33);
Westlanc Partners Hotel Project IS/MND, Lancaster (2025; 44); Temecula Resort and Spa Class 32 Exemption, Temecula (2025; 34); Briones Regional Park Staff Report, East Bay Regional Park District (2024; 63); Declaration regarding Havana Warehouse, Riverside County (2024; 6); 11623 Glenoaks Blvd (no CEQA review), City of Los Angeles (2024; 28); Five Point Community Offices SSEIR, Irvine (2024; 23); Replies to responses to comments on ENV-2022-6190-CE Categorical Exemption - Class 32,
Smallwood CV 34
City of Los Angeles (2024; 17);
ENV-2022-6190-CE Categorical Exemption - Class 32, City of Los Angeles (2024; 2); 380 North First Street DEIR, San Jose (2024; 21);
Site Plan Review 23-014 IS/MND, Lancaster (2024; 29); Big Ranch Road Annexation Exemption, City of Napa (2024; 43); E&P Technology Way - Building A & B IS/MND, County of Napa (2024; 30); Outlaw Battery Energy Storage Project IS/MND, Kings County (2024; 26); Replies to responses to comments on Hills Preserve Project DEIR, Anaheim (2024; 57), and update (2024; 4);
Replies to responses to comments on Tennessee Village Mixed-Use Project IS/MND, Redlands (2024; 26);
Glen Annie Site (#11) in the Housing Element Update, County of Santa Barbara (2024; 61); Quail Meadows Apartments CEQA Exemption, Encinitas (2024; 61); Dogwood Geothermal and Solar DEIR, Imperial County (2024; 60); Hills Preserve Project DEIR, Anaheim (2024; 57), and update (2024; 14); Temescal Commercial Project EA/IS, County of Riverside (2024; 36); 11011 Torreyana Road Project SMND, Torrey Pines (2024; 42); Rosemount Storage Project IS/MND, Cathedral City (2024; 9); Town & Country Village Project DEIR, El Dorado County (2024; 40); Maruchan Expansion Project EIR Addendum, Irvine (2024; 30); American River One Project CEQA Exemption, Sacramento (2024; 35); Spruce & Red Oak Apartments Project Notice of Exemption Supplement Information, Rancho Cucamonga (2024; 38);
SDG Commerce 220 Distribution Center DEIR, American Canyon (2024; 39); Simi Pak Industrial Project IS/MND, Simi Valley (2024; 33); Replies to responses to comments on 4
th & Hewitt Project DEIR, Los Angeles (2024; 5);
Replies to responses to comments on Hardt and Brier Business Park IS/MND, San Bernardino (2024;
Riverview Development Project IS/MND, Santa Clarita (2024; 37); Replies to responses to comments on 1360 N. Vine Street Project DEIR, Los Angeles (2024; 5);
1360 N. Vine Street Project DEIR, Los Angeles (2024; 29); Sites Reservoir Application to California Water Board (2024; 43); 022-221-100 Corona Drive, Pacifica (2024: 26);
Airport South Industrial Park and City Annexation DEIR, Sacramento (2024; 53); Early Times Cell Tower at 12415 Fig Road IS/MND, County of Sacramento (2024; 29); University Community Plan, San Diego (2024; 10);
2720 S Willow Industrial Project IS/MND, Rialto (2024; 31); Elisabeth Solar Energy Project EA, Yuma Arizona (2024; 75); Jove Solar Energy Project DEIS, Yuma Arizona (2024; 103); Tennessee Village Project IS/MND, Redlands (2024; 43); Declaration on Whistling Ridge Energy Project Site Certification Agreement, Washington Energy Facility Site Evaluation Council (2024; 30);
Replies to responses to comments on Dynamo Solar IS/MND, Napa (2024; 11); Dynamo Solar IS/MND, Napa (2024; 37);
Smallwood CV 35
Shirk & Riggin Industrial Park DEIR, Visalia (2024; 37); Replies to responses to comments on Cal 98 Holdings IS/MND, Imperial County (2024; 10); Cal 98 Holdings IS/MND, Imperial County (2024; 39);
2
nd Replies to responses to comments on Amazing 34 Distribution Center IS/MND, San Bernardino (2024; 28);
Western States Solar Plan DPEIS, Washington D.C. (2024; 66); Patterson Business Center IS/MND, Perris (2024; 30);
Replies to responses to comments on Sunset and Everett Project SCEA, Los Angeles (2024; 24);
Sunset and Everett Project SCEA, Los Angeles (2024; 33); 605-613 Bridgeway, Sausalito (2024; 28);
PBP Industrial Project IS/MND, Palmdale (2024; 35);
Replies to responses to comments on Lockwood III Apartments IS/MND, Oxnard (2024; 19); Lockwood III Apartments IS/MND, Oxnard (2024; 42);
1169 8th Ave. Mixed-use Development City Posting, San Diego (2024; 16); 2
nd Brew Enterprises Warehouse IS/MND, Perris (2024; 39); Replies to responses to comments on Hughes SMCC Industrial Project DEIR, San Marcos (2024; 5);
Hughes SMCC Industrial Project DEIR, San Marcos (2024; 44); Harvill and Water Warehouse IS/MND, County of Riverside (2024; 41); Brew Enterprises Warehouse IS/MND, Perris (2024; 34); Garden Street Hotel Staff Report, Santa Barbara (2024; 31); River Walk Specific Plan DEIR, Riverbank (2024; 72);
Woodlake Holdings Industrial Park DEIR (2024; 34);
2
nd Quail Meadows Apartments CEQA Exemption, Encinitas (2024; 60); Replies to responses to comments on One Hamilton Drive Affordable Housing DEIR, Mill Valley (2024; 29);
Glen Annie Housing Element Update, County of Santa Barbara (2024; 53); Replies to responses to comments on 4260 Arch North Drive Class 32 Categorical Exemption, Los Angeles (2023; 10);
4260 Arch North Drive Class 32 Categorical Exemption, Los Angeles (2023; 27); 2
nd Replies to responses to comments on Rubio Village IS/MND, San Gabriel (2023; 17); West Foothill Development IS/MND, Upland (2023; 9);
Costco Camarillo IS/MND (2024; 37);
Shiloh Business Park General Plan Consistency Checklist, Windsor (2023; 25); Assembly and Light Industrial Building IS/MND, Grand Terrace (2024; 33); SMP 38, SMP 39. SMP 40 DEIR, Livermore (2023; 41);
Summit Ridge Wind Farm second visit, The Dalles (2024; 43); Summit Ridge Wind Farm first visit, The Dalles (2023; 31); 3601 E. Mission Class 32 Categorical Exemption, Los Angeles (2023; 31); [Redacted] Conservation Easement, Tennessee (2023; 55); Hardt and Brier Business Park IS/MND, San Bernardino (2023; 32); Sacramento Street CEQA Exemption, San Francisco (2023; 22); One Hamilton Drive Affordable Housing DEIR, Mill Valley (2023; 48);
Smallwood CV 36
Elmore North Geothermal site visit, Salton Sea (2023; 32); Morton Bay Geothermal site visit, Salton Sea (2023; 53); Black Rock Geothermal site visit, Salton Sea (2023; 29); Covelop Warehouse IS/MND, Paso Robles (2023; 39);
Walnut Creek Flow Trail IS/MND (2023; 34);
Replies to responses to comments on Rubio Village IS/MND, San Gabriel (2023; 15); Ashley Warehouse Environmental Checklist, Lathrop (2023; 38); Replies on 6615 Pacific Coast Highway Site Plan Review, Long Beach (2023; 12) Science Research Park Expansion Project EIR Addendum, San Diego (2023; 40); Rubio Village IS/MND, San Gabriel (2023; 14);
Havana Investment Industrial Categorical Exemption, Jurupa Valley (2023; 22); New Cal Centre EIR Addendum, Kern County (2023; 39);
4
th & Hewitt Project DEIR, Los Angeles (2023; 19);
4260 N Arch Drive Categorical Exemption, Los Angeles (2023; 27); 6700 Pacific Coast Highway Site Plan Review, Long Beach (2023; 29); Replies to responses to comments on 6615 Pacific Coast Highway Site Plan Review, Long Beach (2023; 12);
6615 Pacific Coast Highway Site Plan Review, Long Beach (2023; 34); Moonlight Apartments biological assessment, Encinitas (2023; 46); Replies to responses to comments on Modera Melrose Mixed-use DEIR, Oceanside (2023; 11);
Modera Melrose Mixed-use DEIR, Oceanside (2023; 39);
550 Piercy Road Industrial IS/MND, San Jose (2023; 28); Living Spaces Development IS/MND, Fresno (2023; 28);
FIND Food Bank Staff Report, Indio (2023; 19);
Replies to responses to comments on Shadowbox Studios DEIR, Santa Clarita (2023; 35); Shadowbox Studios DEIR, Santa Clarita (2023; 50);
Tulare 40 Generation Facility IS/MND, Tulare County (2023; 20); Garden Street Hotel Staff Report, Santa Barbara (2023; 19); Replies to responses to comments on 975 Manhattan Apartments Discretionary Approval, Los Angeles (2023; 10);
975 Manhattan Apartments Discretionary Approval, Los Angeles (2023; 12); 6
7h visit Veterans Affairs Site Plan Review No. 20-0102 MND, Bakersfield (2023; 14); Coachella Airport Business Park IS/MND, Coachella (2023; 31); 3400 Tecate Warehouse Staff Report, Camarillo (2023; 26); Green Valley III Apartments DEIR, Fairfield (2023; 50); Pacific Specific Plan DEIR, San Marcos (2023; 55);
Amara Bay Mixed Use Staff Report, Chula Vista (2023; 46); Greenlaw Partners Warehouse IS, Fresno (2023; 23);
PODS Warehouse IS/MND, Desert Hot Springs (2023; 30); 6
th visit Veterans Affairs Site Plan Review No. 20-0102 MND, Bakersfield (2023; 9); Replies on Ormat Brawley Solar Project DEIR, Brawley (2023; 80); One Hamilton as part of City of Mill Valley’s 2023-2031 Housing Element Update DSEIR (2023; 31);
Smallwood CV 37
Second letter on Shinohara Project IS/MND, Chula Vista (2023; 22); 3890 Depot Road Project IS/MND, Hayward (2023; 33);
Wellprofit Wellness Mixed-use project CEQA Exemption, Temecula (2023; 31); Quail Meadows Apartments CEQA Exemption, Encinitas (2023; 55); RCCB Fresno Distribution Center Notice of Exemption, Fresno (2022; 14); Stoddard Wells Industrial Project IS/MND, City of Victorville (2022; 31); 16454 Adelanto Road Warehouse Distribution Facility Class 32 Categorical Exemption, Adelanto (2022; 17);
Replies on Pure Water Project – Las Virgenes-Triunfo Joint Powers Authority FPEIR, Agoura (2022; 26);
Desert Gateway MND Addendum, Desert Hot Springs (2022; 35); Blue Oaks Commerce Center MND Addendum, City of Roseville (2022; 12); Replies on Coachillin Amendment to Specific Plan, Desert Hot Springs (2022; 24); Island View Mixed-Use CEQA Compliance Memo, City of Rancho Cucamonga (2022; 17); Prairie Station Apartments IS/MND, City if Inglewood (2022; 32); Golden Land Warehouse CEQA Exemption, City of Rialto (2022; 12); South Juarez Street Design Review, Banning (2022; 17); Replies on Pentair Expansion Industrial Warehouse FMND, Moorpark (2022; 13); 2
nd Replies on Greentree FEIR, Vacaville (2022; 16);
Replies on Temporary Outdoor Vehicle Storage FEIR, Port of Hueneme (2022; 21); National City-Bayfront, San Diego DEIR (2022; 56);
Goshen Community Plan General Plan Amendment & Addendum (2022, 6); Primrose and Adelanto warehouse Categorical Exemption, Adelanto (2022, 14); TenTen Hollywood Categorical Exclusion (2022, 17);
Waste to Hydrogen project IS/MND, Lancaster (2022, 36); Las Virgenes-Triunfo Pure Water Project <Agoura Hills, (2022; 43); Shinohara Project IS/MND, Chula Vista (2022; 30);
Marlborough-Northgate Warehouse IS/MND, Riverside (2022; 33); Meyers Ave, Warehouse IS/MND, Escondido IS/MND (2022; 27); Northgate Industrial Park IS/MND, Sacramento (2022; 28); Ramona-Indian Warehouse IS/MND, Perris (2022; 44);
Norwalk Entertainment District EIR (2022; 29);
Breeze Luxury Apartments IS/MND, Oceanside (2022; 40); Paso Commons Golden Hills Commerce Center IS/MND, Paso Robles (2022; 35); YS Industrial Park Application, Visalia (2022; 20);
Pentair Expansion Industrial Warehouse IS/MND, Moorpark (2022; 28); Salvador Solar IS/MND, Riverside (2022; 27);
Fresno General Plan Amendment 555 IS/MND (2022; 21);
570 Crespi Drive IS/MND, Pacifica (2022; 40);
Renaissance Ranch Commerce Center DEIR, Temescal Valley (2022; 53); Replies on Glen Ivy Senior Living IS/MND, Temescal Valley (2022; 24); Glen Ivy Senior Living IS/MND, Temescal Valley (2022; 46); FedEx Distribution Warehouse IS, Lancaster (2022; 35); Urban Villages EIR Addendum, San Marcos (2022; 32);
Smallwood CV 38
NextEra San Ardos Solar IS/ND, San Ardo (2022; 20);
Summit Avenue Warehouse IS/MND, Fontana (2022; 28);
Gateway at the Oaks DEIR, Thousand Oaks (2022; 30);
Primrose and Adelanto Warehouse CEQA Exemption, Adelanto (2022; 11); Fore Apartments Staff Report, Oxnard (2022; 29);
975 Manhattan Rd. discretionary approval, Los Angeles (2022; 12); Coachillin DEIR, North Palm Springs (2022; 30);
2740 W. Nielsen Ave Warehouse IS/MND, Fresno (2022; 25); Golf Center Warehouse Staff Report, Indio (2022; 26); Desert Peak Energy IS/MND, Palm Springs (2022; 26);
Replies on Greentree FEIR, Vacaville (2022; 13);
Greentree DEIR, Vacaville (2022; 31);
Town Center DEIR, Laguna Niguel (2022; 16);
2
nd Replies on Freedom Circle Focus Area and Greystar General Plan Amendment Project FEIR, San Jose (2022; 3);
Corydon III CEQA Categorical Exemption, Lake Elsinore (2022; 11); Park Edge Apartments IS/MND, Santa Maria (2022; 30);
Replies on UCSF New Hospital FEIR at Parnassus Heights FEIR. San Francisco (2022; 13); Replies on North Central Valley BESS Project IS/MND, Stockton (2022; 21); 9248 Holly Road Cannabis CEQA Exemption, Adelanto (2022; 12); Replies on Amazing 34 Distribution Center IS/MND, San Bernardino (2022; 10); Amazing 34 Distribution Center IS/MND, San Bernardino (2022; 28); Replies on Freedom Circle Focus Area and Greystar General Plan Amendment Project FEIR, San Jose (2022; 5);
Replies on Alviso Hotel Project IS/MND, San Jose (2022; 49); Bussetto Foods IS/ND, Fresno (2022; 34);
Spruce Ave Commerce Center, Rialto (2022;);
5006 and 5010 Mission Boulevard Warehouse IS/MND, Montclair (2022; 18); Conejo Summit IS/MND, Thousand Oaks (2022; 28);
Sixth visit, Veterans Affairs Site Plan Review No. 20-0102 MND, Bakersfield (2022; 4); TC NO. CAL. Development Warehousing and Distribution Facility Project DEIR, Stockton (2022; 33);
Replies on Davidon Homes FEIR, Petaluma (2022; 49);
Rural preservation and net conservation benefit coalition reply to post hearing briefs, Garnet Solar (2022; 24);
Garnet Solar direct testimony, New York (2022; 17);
Fifth visit, Veterans Affairs Site Plan Review No. 20-0102 MND, Bakersfield (2022; 11); Shirk & Riggin Industrial Park Application, Visalia (2022; 22); Duarte Industrial Application, Visalia (2022; 17);
Amond World Cold Storage Warehouse IS/MND, Madera (2022; 23); Replies on Schulte Logistics Centre EIR, Tracy (2022; 28); Alta Cuvee Mixed Use Project Recirculated IS/MND, Ranch Cucamonga (2022; 8); Fourth visit, Veterans Affairs Site Plan Review No. 20-0102 MND, Bakersfield (2022; 9); Replies on 1242 20th Street Wellness Center Project FEIR, Santa Monica (2022; 5);
Smallwood CV 39
656 South San Vicente Medical Office Project EIR, Los Angeles (2022; 21); UCSF New Hospital at Parnassus Heights DEIR. San Francisco (2022; 40); DPR-21-021Warehouse IS, Modesto (2022; 19);
Ormat Brawley Solar Project DEIR, Brawley (2022; 37); Site visits to Heber 1 Geothermal Repower Project IS/MND (2022; 31); Heritage Industrial Center Design Review, Chula Vista (2022; 13); Temporary Outdoor Vehicle Storage DEIR, Port of Hueneme (2022; 31); CNU Medical Center and Innovation Park DEIR, Natomas (2022; 35); Beverly Boulevard Warehouse IS/MND, Pico Rivera (2021; 28); Hagemon Properties IS/MND Amendment, Bakersfield (2022; 23); Airport Distribution Center IS/MND, Redding (2021; 22); Orchard on Nevada Warehouse Staff Report, Redlands (2021; 24); Landings Logistics Center Exemption, Bakersfield (2021; 19); Replies on Hearn Veterans Village IS/MND, Santa Rosa (2021; 22); North Central Valley BESS Project IS/MND, Stockton (2021; 39); 2
nd Replies on Heber 1 Geothermal Repower Project IS/MND (2022; 21); Stagecoach Solar DEIR, Barstow (2021; 24);
Updated Sun Lakes Village North EIR Amendment 5, Banning, Riverside County (2021; 35); Freedom Circle Focus Area and Greystar General Plan Amendment Project EIR, San Jose (2021; 43);
Operon HKI Warehouse IS/MND, Perris (2021; 26);
Fairway Business Park Phase III IS/MND, Lake Elsinore (2021; 23); South Stockton Commerce Center IS/MND, Stockton (2021; 31); Starpoint Warehouse IS/MND, San Bernardino (2021; 24); Replies on Heber 1 Geothermal Repower Project IS/MND (2021; 15); Heber 1 Geothermal Repower Project IS/MND (2021; 11); Alviso Hotel Project IS/MND, San Jose (2021; 43);
Replies on Easton Research Park West IS/MND, Rancho Cordova (2021; 3); Easton Research Park West IS/MND, Rancho Cordova (2021; 31); US Cold Storage DEIR, Hesperia (2021; 30);
1242 20th Street Wellness Center Project FEIR, Santa Monica (2021; 23); Third visit, Veterans Affairs Site Plan Review No. 20-0102 MND, Bakersfield (2021; 10); Roseland Creek Community Park Project IS/MND, Santa Rosa (2021; 23); Vista Mar Declaration of Irreparable Harm, Pacifica (2021; 3); LogistiCenter at Fairfield IS/MND (2021; 25);
Alta Cuvee Mixed Use Project IS/MND, Ranch Cucamonga (2021; 29); Caligrows Architectural and Site Plan Review, Patterson (2021; 21); 1055 E. Sandhill Avenue Warehouse IS/MND, Carson (2021; 10); Chestnut & Tenth Street Commercial Project IS/MND, Gilroy (2021; 27); Libitzky Management Warehouse IS/MND, Modesto (2021; 20); 3rd Replies on Heber 2 Geothermal Repower Project IS/MND, El Centro (2021; 10); Medical Office Building DEIR, Santa Cruz (2021; 30);
Scannell Warehouse DEIR, Richmond (2021; 24);
Diamond Heights Application, San Francisco (2021; 24);
Smallwood CV 40
Costa Azul Mixed-Use EIR Addendum, San Diego (2021; 25); Woodland Research Park DEIR (2021; 45);
2
nd Replies on Diamond Street Industrial IS/MND, San Marcos (2021; 9); Replies on Diamond Street Industrial IS/MND, San Marcos (2021; 3); Diamond Street Industrial IS/MND, San Marcos (2021; 28); DHS 109 Industrial Park IS/MND, Desert Hot Springs (2021; 33); Jersey Industrial Complex Rancho Cucamonga (2022; 22); 1188 Champions Drive Parking Garage Staff Report, San Jose (2021; 5); San Pedro Mountain, Pacifica (2021; 22);
Pixior Warehouse IS/MND, Hesperia (2021; 29);
2
nd Replies on Heber 2 Geothermal Repower Project IS/MND, El Centro (2021; 9); Hearn Veterans Village IS/MND, Santa Rosa (2021; 23); Second visit, Veterans Affairs Site Plan Review No. 20-0102 MND, Bakersfield (2021; 11); Replies on Station East Residential/Mixed Use EIR, Union City (2021; 26); Schulte Logistics Centre EIR, Tracy (2021; 30);
4150 Point Eden Way Industrial Development EIR, Hayward (2021; 13); Airport Business Centre IS/MND, Manteca (2021; 27);
Dual-branded Hotel IS/MND, Santa Clara (2021; 26);
Legacy Highlands Specific Plan EIR, Beaumont (2021; 47); UC Berkeley LRDP and Housing Projects #1 and #2 EIR (2021; 27); Santa Maria Airport Business Park EIR, Santa Maria (2021; 27); Replies on Coachella Valley Arena EIR Addendum, Thousand Palms (2021; 20); Coachella Valley Arena EIR Addendum, Thousand Palms (2021; 35); Inland Harbor Warehouse NOD, Ontario (2021; 8);
Alvarado Specific Plan DEIR, La Mesa (2021; 35);
Harvill Avenue and Rider Street Terminal Project MND, Riverside (2021; 23); Gillespie Field EIR Addendum, El Cajon (2021; 28);
Heritage Wind Energy Project section 94-c siting process, New York (2021: 99); Commercial Street Hotels project Site Plans, Oakland (2021; 19); Heber 1 Geothermal Repower Project MND, El Centro (2021; 11); Citrus-Slover Warehouse Project MND, Fontana (2021; 20); Scott Ranch Project RDEIR (Davidon Homes), Petaluma (2021; 31); Replies on StratosFuel Renewable H2 Project MND, Victorville (2021; 5); StratosFuel Renewable H2 Project MND, Victorville (2021; 25); Replies on PARS Global Storage MND, Murietta (2021; 22); Baldwin-Zacharias Master Plans EIR, Patterson (2021; 38); 1000 Gibraltar Drive EIR, Milpitas (2021; 20);
Mango Avenue Industrial Warehouse Project, Fontana, MND (2021; 20); Veterans Affairs Site Plan Review No. 20-0102 MND, Bakersfield (2021; 25); Replies on UCSF Comprehensive Parnassus Heights Plan EIR (2021; 13); 14 Charles Hill Circle Design Review (2021; 11);
SDG Commerce 217 Warehouse IS, American Canyon (2021; 26); Mulqueeney Ranch Wind Repowering Project DSEIR (2021; 98); Clawiter Road Industrial Project IS/MND, Hayward (2021; 18);
Smallwood CV 41
Garnet Energy Center Stipulations, New York (2020);
Heritage Wind Energy Project, New York (2020: 71);
Ameresco Keller Canyon RNG Project IS/MND, Martinez (2020; 11); Cambria Hotel Project Staff Report, Dublin (2020; 19); Central Pointe Mixed-Use Staff Report, Santa Ana (2020; 20); Oak Valley Town Center EIR Addendum, Calimesa (2020; 23); Coachillin Specific Plan MND Amendment, Desert Hot Springs (2020; 26); Stockton Avenue Hotel and Condominiums Project Tiering to EIR, San Jose (2020; 19); Cityline Sub-block 3 South Staff Report, Sunyvale (2020; 22); Station East Residential/Mixed Use EIR, Union City (2020; 21); Multi-Sport Complex & Southeast Industrial Annexation Suppl. EIR, Elk Grove (2020; 24); Sun Lakes Village North EIR Amendment 5, Banning, Riverside County (2020; 27); 2
nd comments on 1296 Lawrence Station Road, Sunnyvale (2020; 4); 1296 Lawrence Station Road, Sunnyvale (2020; 16);
Mesa Wind Project EA, Desert Hot Springs (2020; 31);
11th Street Development Project IS/MND, City of Upland (2020; 17); Vista Mar Project IS/MND, Pacifica (2020; 17);
Emerson Creek Wind Project Application, Ohio (2020; 64); Replies on Wister Solar Energy Facility EIR, Imperial County (2020; 12); Wister Solar Energy Facility EIR, Imperial County (2020; 28); Crimson Solar EIS/EIR, Mojave Desert (2020, 35) not submitted; Sakioka Farms EIR tiering, Oxnard (2020; 14);
3440 Wilshire Project IS/MND, Los Angeles (2020; 19); Replies on 2400 Barranca Office Development Project EIR, Irvine (2020; 8); 2400 Barranca Office Development Project EIR, Irvine (2020; 25); Replies on Heber 2 Geothermal Repower Project IS/MND, El Centro (2020; 4); 2
nd comments on Heber 2 Geothermal Repower Project IS/MND, El Centro (2020; 8); Heber 2 Geothermal Repower Project IS/MND, El Centro (2020; 3); Lots 4-12 Oddstad Way Project IS/MND, Pacifica (2020; 16); Declaration on DDG Visalia Warehouse project (2020; 5); Terraces of Lafayette EIR Addendum (2020; 24);
AMG Industrial Annex IS/MND, Los Banos (2020; 15);
Replies to responses to comments on responses on Casmalia and Linden Warehouse, Rialto (2020; 15);
Clover Project MND, Petaluma (2020; 27);
Ruby Street Apartments Project Env. Checklist, Hayward (2020; 20); Replies to responses to comments on responses on 3721 Mt. Diablo Boulevard Staff Report (2020; 5);
3721 Mt. Diablo Boulevard Staff Report (2020; 9);
Steeno Warehouse IS/MND, Hesperia (2020; 19);
UCSF Comprehensive Parnassus Heights Plan EIR (2020; 24); North Pointe Business Center MND, Fresno (2020; 14);
Casmalia and Linden Warehouse IS, Fontana (2020; 15); Rubidoux Commerce Center Project IS/MND, Jurupa Valley (2020; 27);
Smallwood CV 42
Haun and Holland Mixed Use Center MND, Menifee (2020; 23); First Industrial Logistics Center II, Moreno Valley IS/MND (2020; 23); GLP Store Warehouse Project Staff Report (2020; 15);
Replies on Beale WAPA Interconnection Project EA & CEQA checklist (2020; 29); 2
nd comments on Beale WAPA Interconnection Project EA & CEQA checklist (2020; 34); Beale WAPA Interconnection Project EA & CEQA checklist (2020; 30); Levine-Fricke Softball Field Improvement Addendum, UC Berkeley (2020; 16); Greenlaw Partners Warehouse and Distribution Center Staff Report, Palmdale (2020; 14); Humboldt Wind Energy Project DEIR (2019; 25);
Sand Hill Supplemental EIR, Altamont Pass (2019; 17); 1700 Dell Avenue Office Project, Campbell (2019, 28); 1180 Main Street Office Project MND, Redwood City (2019; 19:
Summit Ridge Wind Farm Request for Amendment 4, Oregon (2019; 46); Shafter Warehouse Staff Report (2019; 4);
Park & Broadway Design Review, San Diego (2019; 19);
Pinnacle Pacific Heights Design Review, San Diego (2019; 19); Pinnacle Park & C Design Review, San Diego (2019; 19); Preserve at Torrey Highlands EIR, San Diego (2019; 24); Santana West Project EIR Addendum, San Jose (2019; 18); The Ranch at Eastvale EIR Addendum, Riverside County (2020; 19); Hageman Warehouse IS/MND, Bakersfield (2019; 13);
Oakley Logistics Center EIR, Antioch (2019; 22);
27 South First Street IS, San Jose (2019; 23);
2
nd replies on Times Mirror Square Project EIR, Los Angeles (2020; 11); Replies on Times Mirror Square Project EIR, Los Angeles (2020; 13); Times Mirror Square Project EIR, Los Angeles (2019; 18); East Monte Vista & Aviator General Plan Amend EIR Addendum, Vacaville (2019; 22); Hillcrest LRDP EIR, La Jolla (2019; 36);
555 Portola Road CUP, Portola Valley (2019; 11);
Johnson Drive Economic Development Zone SEIR, Pleasanton (2019; 27); 1750 Broadway Project CEQA Exemption, Oakland (2019; 19); Mor Furniture Project MND, Murietta Hot Springs (2019; 27); Harbor View Project EIR, Redwood City (2019; 26);
Visalia Logistics Center (2019; 13);
Cordelia Industrial Buildings MND (2019; 14);
Scheu Distribution Center IS/ND, Rancho Cucamonga (2019; 13); Mills Park Center Staff Report, San Bruno (2019; 22); Site visit to Desert Highway Farms IS/MND, Imperial County (2019; 9); Desert Highway Farms IS/MND, Imperial County (2019; 12); ExxonMobil Interim Trucking for Santa Ynez Unit Restart SEIR, Santa Barbara (2019; 9); Olympic Holdings Inland Center Warehouse Project MND, Rancho Cucamonga (2019; 14); Replies to responses to comments on responses on Lawrence Equipment Industrial Warehouse, Banning (2019; 19);
PARS Global Storage MND, Murietta (2019; 13);
Smallwood CV 43
Slover Warehouse EIR Addendum, Fontana (2019; 16);
Seefried Warehouse Project IS/MND, Lathrop (2019; 19) World Logistics Center Site Visit, Moreno Valley (2019; 19); Merced Landfill Gas-To-Energy Project IS/MND (2019; 12); West Village Expansion FEIR, UC Davis (2019; 11);
Site visit, Doheny Ocean Desalination EIR, Dana Point (2019; 11); Replies to responses to comments on responses on Avalon West Valley Expansion EIR, San Jose (2019; 10);
Avalon West Valley Expansion EIR, San Jose (2019; 22); Sunroad – Otay 50 EIR Addendum, San Diego (2019; 26); Del Rey Pointe Residential Project IS/MND, Los Angeles (2019; 34); 1 AMD Redevelopment EIR, Sunnyvale (2019; 22);
Lawrence Equipment Industrial Warehouse IS/MND, Banning (2019; 14); SDG Commerce 330 Warehouse IS, American Canyon (2019; 21); PAMA Business Center IS/MND, Moreno Valley (2019; 23); Cupertino Village Hotel IS (2019; 24);
Lake House IS/ND, Lodi (2019; 33);
Campo Wind Project DEIS, San Diego County (DEIS, (2019; 14); Stirling Warehouse MND site visit, Victorville (2019; 7); Green Valley II Mixed-Use Project EIR, Fairfield (2019; 36); We Be Jammin rezone MND, Fresno (2019; 14);
Gray Whale Cove Pedestrian Crossing IS/ND, Pacifica (2019; 7); Visalia Logistics Center & DDG 697V Staff Report (2019; 9); Mather South Community Masterplan Project EIR (2019; 35); Del Hombre Apartments EIR, Walnut Creek (2019; 23);
Otay Ranch Planning Area 12 EIR Addendum, Chula Vista (2019; 21); The Retreat at Sacramento IS/MND (2019; 26);
Site visit to Sunroad – Centrum 6 EIR Addendum, San Diego (2019; 9); Sunroad – Centrum 6 EIR Addendum, San Diego (2018; 22); North First and Brokaw Corporate Campus Buildings EIR Addendum, San Jose (2018; 30); South Lake Solar IS, Fresno County (2018; 18);
Galloo Island Wind Project Application, New York (not submitted) (2018; 44); Doheny Ocean Desalination EIR, Dana Point (2018; 15); Stirling Warehouse MND, Victorville (2018; 18);
LDK Warehouse MND, Vacaville (2018; 30);
Gateway Crossings FEIR, Santa Clara (2018; 23);
South Hayward Development IS/MND (2018; 9);
CBU Specific Plan Amendment, Riverside (2018; 27);
2
nd Replies to responses to comments on responses on Dove Hill Road Assisted Living Project MND (2018; 11);
Replies to responses to comments on responses on Dove Hill Road Assisted Living Project MND (2018; 7);
Dove Hill Road Assisted Living Project MND (2018; 12); Deer Ridge/Shadow Lakes Golf Course EIR, Brentwood (2018; 21);
Smallwood CV 44
Pyramid Asphalt BLM Finding of No Significance, Imperial County (2018; 22); Amáre Apartments IS/MND, Martinez (2018; 15);
Petaluma Hill Road Cannabis MND, Santa Rosa (2018; 21); 2
nd comments on Zeiss Innovation Center IS/MND, Dublin (2018: 12); Zeiss Innovation Center IS/MND, Dublin (2018: 32);
City of Hope Campus Plan EIR, Duarte (2018; 21);
Palo Verde Center IS/MND, Blythe (2018; 14);
Logisticenter at Vacaville MND (2018; 24);
IKEA Retail Center SEIR, Dublin (2018; 17);
Merge 56 EIR, San Diego (2018; 15);
Natomas Crossroads Quad B Office Project P18-014 EIR, Sacramento (2018; 12); 2900 Harbor Bay Parkway Staff Report, Alameda (2018; 30); At Dublin EIR, Dublin (2018; 25);
Fresno Industrial Rezone Amendment Application No. 3807 IS (2018; 10); Nova Business Park IS/MND, Napa (2018; 18);
Updated Collision Risk Model Priors for Estimating Eagle Fatalities, USFWS (2018; 57); 750 Marlborough Avenue Warehouse MND, Riverside (2018; 14); Replies to responses to comments on responses on San Bernardino Logistics Center IS (2018; 12);
San Bernardino Logistics Center IS (2018; 19);
CUP2017-16, Costco IS/MND, Clovis (2018; 11);
Desert Land Ventures Specific Plan EIR, Desert Hot Springs (2018; 18); Ventura Hilton IS/MND (2018; 30);
North of California Street Master Plan Project IS, Mountain View (2018: 11); Tamarind Warehouse MND, Fontana (2018; 16);
Lathrop Gateway Business Park EIR Addendum (2018; 23); Centerpointe Commerce Center IS, Moreno Valley (2019; 18); Amazon Warehouse Notice of Exemption, Bakersfield (2018; 13); CenterPoint Building 3 project Staff Report, Manteca (2018; 23); Cessna & Aviator Warehouse IS/MND, Vacaville (2018; 24); Napa Airport Corporate Center EIR, American Canyon (2018, 15); 800 Opal Warehouse Initial Study, Mentone, San Bernardino County (2018; 18); 2695 W. Winton Ave Industrial Project IS, Hayward (2018; 22); Trinity Cannabis Cultivation and Manufacturing Facility DEIR, Calexico (2018; 15); Shoe Palace Expansion IS/MND, Morgan Hill (2018; 21); Newark Warehouse at Morton Salt Plant Staff Report (2018; 15); Northlake Specific Plan FEIR “Peer Review”, Los Angeles County (2018; 9); Replies to responses to comments on responses on Northlake Specific Plan SEIR, Los Angeles County (2018; 13);
Northlake Specific Plan SEIR, Los Angeles County (2017; 27); Bogle Wind Turbine DEIR, east Yolo County (2017; 48); Ferrante Apartments IS/MND, Los Angeles (2017; 14);
The Villages of Lakeview EIR, Riverside (2017; 28);
Data Needed for Assessing Trail Management Impacts on Northern Spotted Owl, Marin
Smallwood CV 45
County (2017; 5);
Notes on Proposed Study Options for Trail Impacts on Northern Spotted Owl (2017; 4); Pyramid Asphalt IS, Imperial County (Declaration) (2017; 5); San Gorgonio Crossings EIR, Riverside County (2017; 22); Replies to responses to comments on responses on Jupiter Project IS and MND, Apple Valley (2017; 12);
Proposed World Logistics Center Mitigation Measures, Moreno Valley (2017, 2019; 12); MacArthur Transit Village Project Modified 2016 CEQA Analysis (2017; 12); PG&E Company Bay Area Operations and Maintenance HCP (2017; 45); Central SoMa Plan DEIR (2017; 14);
Suggested mitigation for trail impacts on northern spotted owl, Marin County (2016; 5); Colony Commerce Center Specific Plan DEIR, Ontario (2016; 16); Fairway Trails Improvements MND, Marin County (2016; 13); Review of Avian-Solar Science Plan (2016; 28);
Replies on Pyramid Asphalt IS, Imperial County (2016; 5); Pyramid Asphalt IS, Imperial County (2016; 4);
Agua Mansa Distribution Warehouse Project Initial Study (2016; 14); Santa Anita Warehouse MND, Rancho Cucamonga (2016; 12); CapRock Distribution Center III DEIR, Rialto (2016: 12); Orange Show Logistics Center IS/MND, San Bernardino (2016; 9); City of Palmdale Oasis Medical Village Project IS/MND (2016; 7); Comments on proposed rule for incidental eagle take, USFWS (2016, 49); Replies on Grapevine Specific and Community Plan FEIR, Kern County (2016; 25); Grapevine Specific and Community Plan DEIR, Kern County (2016; 15); Clinton County Zoning Ordinance for Wind Turbine siting (2016); Hallmark at Shenandoah Warehouse Project Initial Study, San Bernardino (2016; 6); Tri-City Industrial Complex Initial Study, San Bernardino (2016; 5); Hidden Canyon Industrial Park Plot Plan 16-PP-02, Beaumont (2016; 12); Kimball Business Park DEIR (2016; 10);
Jupiter Project IS and MND, Apple Valley, San Bernardino County (2016; 9); Revised Draft Giant Garter Snake Recovery Plan of 2015 (2016, 18); Palo Verde Mesa Solar Project EIR, Blythe (2016; 27); Reply on Fairview Wind Project Natural Heritage Assessment, Ontario, Canada (2016; 14); Fairview Wind Project Natural Heritage Assessment, Ontario, Canada (2016; 41); Reply on Amherst Island Wind Farm Natural Heritage Assessment, Ontario (2015, 38); Amherst Island Wind Farm Natural Heritage Assessment, Ontario (2015, 31); Second Reply on White Pines Wind Farm, Ontario (2015, 6); Reply on White Pines Wind Farm Natural Heritage Assessment, Ontario (2015, 10); White Pines Wind Farm Natural Heritage Assessment, Ontario (2015, 9); Proposed Section 24 Specific Plan Agua Caliente Band of Cahuilla Indians DEIS (2015, 9); Replies on 24 Specific Plan Agua Caliente Band of Cahuilla Indians FEIS (2015, 6); Sierra Lakes Commerce Center Project DEIR, Fontana (2015, 9); Columbia Business Center MND, Riverside (2015; 8);
West Valley Logistics Center Specific Plan DEIR, Fontana (2015, 10);
Smallwood CV 46
Willow Springs Solar Photovoltaic Project DEIR (2015, 28); Alameda Creek Bridge Replacement Project DEIR (2015, 10); World Logistic Center Specific Plan FEIR, Moreno Valley (2015, 12); Elkhorn Valley Wind Power Project Impacts, Oregon (2015; 143); Bay Delta Conservation Plan EIR/EIS, Sacramento (2014, 21); Addison Wind Energy Project DEIR, Mojave (2014, 32);
Replies on the Addison Wind Energy Project DEIR, Mojave (2014, 15); Addison and Rising Tree Wind Energy Project FEIR, Mojave (2014, 12); Palen Solar Electric Generating System FSA (CEC), Blythe (2014, 20); Rebuttal testimony on Palen Solar Energy Generating System (2014, 9); Seven Mile Hill and Glenrock/Rolling Hills impacts + Addendum, Wyoming (2014; 105); Rising Tree Wind Energy Project DEIR, Mojave (2014, 32); Replies on the Rising Tree Wind Energy Project DEIR, Mojave (2014, 15); Soitec Solar Development Project PEIR, Boulevard, San Diego County (2014, 18); Oakland Zoo expansion on Alameda whipsnake and California red-legged frog (2014; 3); Alta East Wind Energy Project FEIS, Tehachapi Pass (2013, 23); Blythe Solar Power Project Staff Assessment, California Energy Commission (2013, 16); Clearwater and Yakima Solar Projects DEIR, Kern County (2013, 9); West Antelope Solar Energy Project IS/MND, Antelope Valley (2013, 18); Cuyama Solar Project DEIR, Carrizo Plain (2014, 19);
Desert Renewable Energy Conservation Plan (DRECP) EIR/EIS (2015, 49); Kingbird Solar Photovoltaic Project EIR, Kern County (2013, 19); Lucerne Valley Solar Project IS/MND, San Bernardino County (2013, 12); Tule Wind project FEIR/FEIS (Declaration) (2013; 31); Sunlight Partners LANDPRO Solar Project MND (2013; 11); Declaration in opposition to BLM fracking (2013; 5);
Blythe Energy Project (solar) CEC Staff Assessment (2013;16); Rosamond Solar Project EIR Addendum, Kern County (2013; 13); Pioneer Green Solar Project EIR, Bakersfield (2013; 13); Replies on Soccer Center Solar Project MND (2013; 6); Soccer Center Solar Project MND, Lancaster (2013; 10); Plainview Solar Works MND, Lancaster (2013; 10);
Alamo Solar Project MND, Mojave Desert (2013; 15);
Replies on Imperial Valley Solar Company 2 Project (2013; 10); Imperial Valley Solar Company 2 Project (2013; 13);
FRV Orion Solar Project DEIR, Kern County (PP12232) (2013; 9); Casa Diablo IV Geothermal Development Project (2013; 6); Reply on Casa Diablo IV Geothermal Development Project (2013; 8); Alta East Wind Project FEIS, Tehachapi Pass (2013; 23); Metropolitan Air Park DEIR, City of San Diego (2013; ); Davidon Homes Tentative Subdivision Rezoning Project DEIR, Petaluma (2013; 9); Oakland Zoo Expansion Impacts on Alameda Whipsnake (2013; 10); Campo Verde Solar project FEIR, Imperial Valley (2013; 11pp); Neg Dec comments on Davis Sewer Trunk Rehabilitation (2013; 8);
Smallwood CV 47
North Steens Transmission Line FEIS, Oregon (Declaration) (2012; 62); Summer Solar and Springtime Solar Projects IS/MND Lancaster (2012; 8); J&J Ranch, 24 Adobe Lane Environmental Review, Orinda (2012; 14); Replies on Hudson Ranch Power II Geothermal Project and Simbol Calipatria Plant II (2012; 8);
Hudson Ranch Power II Geothermal Project and Simbol Calipatria Plant II (2012; 9); Desert Harvest Solar Project EIS, near Joshua Tree (2012; 15); Solar Gen 2 Array Project DEIR, El Centro (2012; 16); Ocotillo Sol Project EIS, Imperial Valley (2012; 4);
Beacon Photovoltaic Project DEIR, Kern County (2012; 5); Butte Water District 2012 Water Transfer Program IS/MND (2012; 11); Mount Signal and Calexico Solar Farm Projects DEIR (2011; 16); City of Elk Grove Sphere of Influence EIR (2011; 28); Sutter Landing Park Solar Photovoltaic Project MND, Sacramento (2011; 9); Rabik/Gudath Project, 22611 Coleman Valley Road, Bodega Bay (CPN 10-0002) (2011; 4); Ivanpah Solar Electric Generating System (ISEGS) (Declaration) (2011; 9); Draft Eagle Conservation Plan Guidance, USFWS (2011; 13); Niles Canyon Safety Improvement Project EIR/EA (2011; 16); Route 84 Safety Improvement Project (Declaration) (2011; 7); Rebuttal on Whistling Ridge Wind Energy Power DEIS, Skamania County, (2010; 6); Whistling Ridge Wind Energy Power DEIS, Skamania County, Washington (2010; 41); Klickitat County’s Decisions on Windy Flats West Wind Energy Project (2010; 17); St. John's Church Project DEIR, Orinda (2010; 14);
Results Radio Zone File #2009-001 IS/MND, Conaway site, Davis (2010; 20); Rio del Oro Specific Plan Project FEIR, Rancho Cordova (2010;12); Results Radio Zone File #2009-001, Mace Blvd site, Davis (2009; 10); Answers to Questions on 33% RPS Implementation Analysis Preliminary Results Report (2009; 9);
SEPA Determination of Non-significance regarding zoning adjustments for Skamania County, Washington (Second Declaration) (2008; 17);
Draft 1A Summary Report to CAISO (2008; 10);
Hilton Manor Project Categorical Exemption, County of Placer (2009; 9); Protest of CARE to Amendment to the Power Purchase and Sale Agreement for Procurement of Eligible Renewable Energy Resources Between Hatchet Ridge Wind LLC and PG&E (2009; 3);
Tehachapi Renewable Transmission Project EIR/EIS (2009; 142); Delta Shores Project EIR, south Sacramento (2009; 11 + addendum 2); Declaration in Support of Care’s Petition to Modify D.07-09-040 (2008; 3); The Public Utility Commission’s Implementation Analysis December 16 Workshop for the Governor’s Executive Order S-14-08 to implement a 33% Renewable Portfolio Standard by 2020 (2008; 9);
The Public Utility Commission’s Implementation Analysis Draft Work Plan for the Governor’s Executive Order S-14-08 to implement a 33% Renewable Portfolio Standard by 2020 (2008; 11);
Draft 1A Summary Report to California Independent System Operator for Planning Reserve
Smallwood CV 48
Margins (PRM) Study (2008; 7.);
SEPA Determination of Non-significance regarding zoning adjustments for Skamania County, Washington (Declaration) (2008; 16);
Colusa Generating Station, California Energy Commission PSA (2007; 24); Rio del Oro Specific Plan Project Recirculated DEIR, Mather (2008: 66); Replies on Regional University Specific Plan EIR, Roseville (2008; 20); Regional University Specific Plan EIR, Roseville (2008: 33); Clark Precast, LLC’s “Sugarland” project, ND, Woodland (2008: 15); Cape Wind Project DEIS, Nantucket (2008; 157);
Yuba Highlands Specific Plan EIR, Spenceville, Yuba County (2006; 37); Replies to responses to comments on responses on North Table Mountain MND, Butte County (2006; 5);
North Table Mountain MND, Butte County (2006; 15);
Windy Point Wind Farm EIS (2006; 14 and Powerpoint slide replies); Shiloh I Wind Power Project EIR, Rio Vista (2005; 18); Buena Vista Wind Energy Project NOP, Byron (2004; 15); Callahan Estates Subdivision ND, Winters (2004; 11);
Winters Highlands Subdivision IS/ND (2004; 9);
Winters Highlands Subdivision IS/ND (2004; 13);
Creekside Highlands Project, Tract 7270 ND (2004; 21); Petition to California Fish and Game Commission to list Burrowing Owl (2003; 10); Altamont Pass Wind Resource Area CUP renewals, Alameda County (2003; 41); UC Davis Long Range Development Plan: Neighborhood Master Plan (2003; 23); Anderson Marketplace Draft Environmental Impact Report (2003; 18); Negative Declaration of the proposed expansion of Temple B’nai Tikyah (2003; 6); Antonio Mountain Ranch Specific Plan Public Draft EIR (2002; 23); Replies on East Altamont Energy Center evidentiary hearing (2002; 9); Revised Draft Environmental Impact Report, The Promenade (2002; 7); Recirculated Initial Study for Calpine’s proposed Pajaro Valley Energy Center (2002; 3); UC Merced -- Declaration (2002; 5);
Replies on Atwood Ranch Unit III Subdivision FEIR (2003; 22); Atwood Ranch Unit III Subdivision EIR (2002; 19);
California Energy Commission Staff Report on GWF Tracy Peaker Project (2002; 20); Silver Bend Apartments IS/MND, Placer County (2002; 13); UC Merced Long-range Development Plan DEIR and UC Merced Community Plan DEIR (2001; 26);
Colusa County Power Plant IS, Maxwell (2001; 6);
Dog Park at Catlin Park, Folsom, California (2001; 5); Calpine and Bechtel Corporations’ Biological Resources Implementation and Monitoring Program (BRMIMP) for the Metcalf Energy Center (2000; 10); Metcalf Energy Center, California Energy Commission FSA (2000); US Fish and Wildlife Service Section 7 consultation with the California Energy Commission regarding Calpine and Bechtel Corporations’ Metcalf Energy Center (2000; 4); California Energy Commission’s Preliminary Staff Assessment of the proposed Metcalf Energy Center (2000: 11);
Smallwood CV 49
Site-specific management plans for the Natomas Basin Conservancy’s mitigation lands, prepared by Wildlands, Inc. (2000: 7);
Affidavit of K. Shawn Smallwood in Spirit of the Sage Council, et al. (Plaintiffs) vs. Bruce Babbitt, Secretary, U.S. Department of the Interior, et al. (Defendants), Injuries caused by the No Surprises policy and final rule which codifies that policy (1999: 9). California Board of Forestry’s proposed amended Forest Practices Rules (1999); Sunset Skyranch Airport Use Permit IS/MND (1999);
Ballona West Bluffs Project Environmental Impact Report (1999; oral presentation); Draft Recovery Plan for Giant Garter Snake (Fed. Reg. 64(176): 49497-49498) (1999; 8); Draft Recovery Plan for Arroyo Southwestern Toad (1998); Pacific Lumber Co. (Headwaters) HCP & EIR, Fortuna (1998; 28); Natomas Basin HCP Permit Amendment, Sacramento (1998); San Diego Multi-Species Conservation Program FEIS/FEIR (1997; 10); Volunteer comments on other Environmental Review Documents:
Proposed Regulation for California Fish and Game Code Section 3503.5 (2015: 12); Statement of Overriding Considerations related to extending Altamont Winds, Inc.’s Conditional Use Permit PLN2014-00028 (2015; 8);
Covell Village PEIR, Davis (2005; 19);
Bureau of Land Management Wind Energy Programmatic EIS Scoping (2003; 7.); NEPA Environmental Analysis for Biosafety Level 4 National Biocontainment Laboratory (NBL) at UC Davis (2003: 7);
Notice of Preparation of UC Merced Community and Area Plan EIR, on behalf of The Wildlife Society—Western Section (2001: 8.);
Preliminary Draft Yolo County Habitat Conservation Plan (2001; 2 letters totaling 35.); Merced County General Plan Revision, notice of Negative Declaration (2001: 2.); Notice of Preparation of Campus Parkway EIR/EIS (2001: 7.); Draft Recovery Plan for the bighorn sheep in the Peninsular Range (Ovis candensis) (2000); Draft Recovery Plan for the California Red-legged Frog (Rana aurora draytonii), on behalf of The Wildlife Society—Western Section (2000: 10.);
Sierra Nevada Forest Plan Amendment Draft Environmental Impact Statement, on behalf of The Wildlife Society—Western Section (2000: 7.);
State Water Project Supplemental Water Purchase Program, Draft Program EIR (1997); Davis General Plan Update EIR (2000);
Turn of the Century EIR (1999: 10);
Proposed termination of Critical Habitat Designation under the Endangered Species Act (Fed.
Reg. 64(113): 31871-31874) (1999);
NOA Draft Addendum to the Final Handbook for Habitat Conservation Planning and Incidental Take Permitting Process, termed the HCP 5-Point Policy Plan (Fed. Reg. 64(45):
11485 - 11490) (1999; 2 + attachments);
Covell Center Project EIR and EIR Supplement (1997).
Position Statements I prepared the following position statements for the Western Section of The Wildlife Society, and one for nearly 200 scientists:
Smallwood CV 50
Recommended that the California Department of Fish and Game prioritize the extermination of the introduced southern water snake in northern California. The Wildlife Society--Western Section (2001);
Recommended that The Wildlife Society—Western Section appoint or recommend members of the independent scientific review panel for the UC Merced environmental review process (2001);
Opposed the siting of the University of California’s 10th campus on a sensitive vernal pool/grassland complex east of Merced. The Wildlife Society--Western Section (2000); Opposed the legalization of ferret ownership in California. The Wildlife Society--Western Section (2000);
Opposed the Proposed “No Surprises,” “Safe Harbor,” and “Candidate Conservation Agreement” rules, including permit-shield protection provisions (Fed. Reg. Vol. 62, No. 103, pp. 29091-29098 and No. 113, pp. 32189-32194). This statement was signed by 188 scientists and went to the responsible federal agencies, as well as to the U.S. Senate and House of Representatives.
Posters at Professional Meetings
Leyvas, E. and K. S. Smallwood. 2015. Rehabilitating injured animals to offset and rectify wind project impacts. Conference on Wind Energy and Wildlife Impacts, Berlin, Germany, 9- 12 March 2015.
Smallwood, K. S., J. Mount, S. Standish, E. Leyvas, D. Bell, E. Walther, B. Karas. 2015.
Integrated detection trials to improve the accuracy of fatality rate estimates at wind projects.
Conference on Wind Energy and Wildlife Impacts, Berlin, Germany, 9-12 March 2015. Smallwood, K. S. and C. G. Thelander. 2005. Lessons learned from five years of avian mortality research in the Altamont Pass WRA. AWEA conference, Denver, May 2005. Neher, L., L. Wilder, J. Woo, L. Spiegel, D. Yen-Nakafugi, and K.S. Smallwood. 2005. Bird’s eye view on California wind. AWEA conference, Denver, May 2005. Smallwood, K. S., C. G. Thelander and L. Spiegel. 2003. Toward a predictive model of avian fatalities in the Altamont Pass Wind Resource Area. Windpower 2003 Conference and Convention, Austin, Texas.
Smallwood, K.S. and Eva Butler. 2002. Pocket Gopher Response to Yellow Star-thistle Eradication as part of Grassland Restoration at Decommissioned Mather Air Force Base, Sacramento County, California. White Mountain Research Station Open House, Barcroft Station.
Smallwood, K.S. and Michael L. Morrison. 2002. Fresno kangaroo rat (Dipodomys nitratoides) Conservation Research at Resources Management Area 5, Lemoore Naval Air Station. White Mountain Research Station Open House, Barcroft Station. Smallwood, K.S. and E.L. Fitzhugh. 1989. Differentiating mountain lion and dog tracks. Third Mountain Lion Workshop, Prescott, AZ.
Smith, T. R. and K. S. Smallwood. 2000. Effects of study area size, location, season, and allometry on reported Sorex shrew densities. Annual Meeting of the Western Section of The Wildlife Society.
Presentations at Professional Meetings and Seminars
Smallwood, N., and S. Smallwood. 2025. Improving methods in environmental review Part 1:
Smallwood CV 51
Habitat assessment of wildlife species with potential to occur on a project site. The Wildlife Society – Western Section, Visalia, California, 5 February 2025.
Smallwood, S., and N. Smallwood. 2025. Improving methods in environmental review part 2:
reconnaissance surveys for characterizing the wildlife community. The Wildlife Society – Western Section, Visalia, California, 5 February 2025.
Eagle mortality at wind turbines. Wings over the Columbia Gorge. Friends of the Columbia Gorge, 4 January 2024.
Ecology and recent population trend of burrowing owls in the Altamont Pass Wind Resource Area.
The Wildlife Society – Western Section Burrowing Owl Symposium, Riverside, California, 6 February 2023.
Renewable energy impacts to burrowing owls. The Wildlife Society – Western Section Burrowing Owl Symposium, Riverside, California, 7 February 2023.
Smallwood, K.S. and D.A. Bell. Long-Term Population Trend of Burrowing Owls in Vasco Caves.
Via Zoom to Audubon Society, 21 October 2021.
Long-Term Population Trend of Burrowing Owls in the Altamont. Golden Gate Audubon, 21 October 2020.
Long-Term Population Trend of Burrowing Owls in the Altamont. East Bay Regional Park District 2020 Stewardship Seminar, Oakland, California, 18 November 2020.
Smallwood, K.S., D.A. Bell, and S, Standish. Dogs detect larger wind energy effects on bats and birds. The Wildlife Society, 28 September 2020.
Smallwood, K.S. and D.A. Bell. Effects of wind turbine curtailment on bird and bat fatalities in the Altamont Pass Wind Resource Area. The Wildlife Society, 28 September 2020.
Smallwood, K.S., D.A. Bell, and S, Standish. Dogs detect larger wind energy effects on bats and birds. The Wildlife Survey, 7 February 2020.
Smallwood, K.S. and D.A. Bell. Effects of wind turbine curtailment on bird and bat fatalities in the Altamont Pass Wind Resource Area. The Wildlife Survey, 7 February 2020.
Dog detections of bat and bird fatalities at wind farms in the Altamont Pass Wind Resource Area.
East Bay Regional Park District 2019 Stewardship Seminar, Oakland, California, 13 November 2019.
Repowering the Altamont Pass. Altamont Symposium, The Wildlife Society – Western Section, 5 February 2017.
Developing methods to reduce bird mortality in the Altamont Pass Wind Resource Area, 1999- 2007. Altamont Symposium, The Wildlife Society – Western Section, 5 February 2017.
Smallwood CV 52
Conservation and recovery of burrowing owls in Santa Clara Valley. Santa Clara Valley Habitat Agency, Newark, California, 3 February 2017.
Mitigation of Raptor Fatalities in the Altamont Pass Wind Resource Area. Raptor Research Foundation Meeting, Sacramento, California, 6 November 2015.
From burrows to behavior: Research and management for burrowing owls in a diverse landscape.
California Burrowing Owl Consortium meeting, 24 October 2015, San Jose, California.
The Challenges of repowering. Keynote presentation at Conference on Wind Energy and Wildlife Impacts, Berlin, Germany, 10 March 2015.
Research Highlights Altamont Pass 2011-2015. Scientific Review Committee, Oakland, California, 8 July 2015.
Siting wind turbines to minimize raptor collisions: Altamont Pass Wind Resource Area. US Fish and Wildlife Service Golden Eagle Working Group, Sacramento, California, 8 January 2015.
Evaluation of nest boxes as a burrowing owl conservation strategy. Sacramento Chapter of the Western Section, The Wildlife Society. Sacramento, California, 26 August 2013.
Predicting collision hazard zones to guide repowering of the Altamont Pass. Conference on wind power and environmental impacts. Stockholm, Sweden, 5-7 February 2013.
Impacts of Wind Turbines on Wildlife. California Council for Wildlife Rehabilitators, Yosemite, California, 12 November 2012.
Impacts of Wind Turbines on Birds and Bats. Madrone Audubon Society, Santa Rosa, California, 20 February 2012.
Comparing Wind Turbine Impacts across North America. California Energy Commission Staff Workshop: Reducing the Impacts of Energy Infrastructure on Wildlife, 20 July 2011.
Siting Repowered Wind Turbines to Minimize Raptor Collisions. California Energy Commission Staff Workshop: Reducing the Impacts of Energy Infrastructure on Wildlife, 20 July 2011.
Siting Repowered Wind Turbines to Minimize Raptor Collisions. Alameda County Scientific Review Committee meeting, 17 February 2011
Comparing Wind Turbine Impacts across North America. Conference on Wind energy and Wildlife impacts, Trondheim, Norway, 3 May 2011.
Update on Wildlife Impacts in the Altamont Pass Wind Resource Area. Raptor Symposium, The Wildlife Society—Western Section, Riverside, California, February 2011.
Siting Repowered Wind Turbines to Minimize Raptor Collisions. Raptor Symposium, The Wildlife Society - Western Section, Riverside, California, February 2011.
Smallwood CV 53
Wildlife mortality caused by wind turbine collisions. Ecological Society of America, Pittsburgh, Pennsylvania, 6 August 2010.
Map-based repowering and reorganization of a wind farm to minimize burrowing owl fatalities.
California burrowing Owl Consortium Meeting, Livermore, California, 6 February 2010.
Environmental barriers to wind power. Getting Real About Renewables: Economic and Environmental Barriers to Biofuels and Wind Energy. A symposium sponsored by the Environmental & Energy Law & Policy Journal, University of Houston Law Center, Houston, 23 February 2007.
Lessons learned about bird collisions with wind turbines in the Altamont Pass and other US wind farms. Meeting with Japan Ministry of the Environment and Japan Ministry of the Economy, Wild Bird Society of Japan, and other NGOs Tokyo, Japan, 9 November 2006.
Lessons learned about bird collisions with wind turbines in the Altamont Pass and other US wind farms. Symposium on bird collisions with wind turbines. Wild Bird Society of Japan, Tokyo, Japan, 4 November 2006.
Responses of Fresno kangaroo rats to habitat improvements in an adaptive management framework.
California Society for Ecological Restoration (SERCAL) 13th Annual Conference, UC Santa Barbara, 27 October 2006.
Fatality associations as the basis for predictive models of fatalities in the Altamont Pass Wind Resource Area. EEI/APLIC/PIER Workshop, 2006 Biologist Task Force and Avian Interaction with Electric Facilities Meeting, Pleasanton, California, 28 April 2006.
Burrowing owl burrows and wind turbine collisions in the Altamont Pass Wind Resource Area. The Wildlife Society - Western Section Annual Meeting, Sacramento, California, February 8, 2006.
Mitigation at wind farms. Workshop: Understanding and resolving bird and bat impacts. American Wind Energy Association and Audubon Society. Los Angeles, CA. January 10 and 11, 2006.
Incorporating data from the California Wildlife Habitat Relationships (CWHR) system into an impact assessment tool for birds near wind farms. Shawn Smallwood, Kevin Hunting, Marcus Yee, Linda Spiegel, Monica Parisi. Workshop: Understanding and resolving bird and bat impacts.
American Wind Energy Association and Audubon Society. Los Angeles, CA. January 10 and 11, 2006.
Toward indicating threats to birds by California’s new wind farms. California Energy Commission, Sacramento, May 26, 2005.
Avian collisions in the Altamont Pass. California Energy Commission, Sacramento, May 26, 2005.
Ecological solutions for avian collisions with wind turbines in the Altamont Pass Wind Resource Area. EPRI Environmental Sector Council, Monterey, California, February 17, 2005.
Ecological solutions for avian collisions with wind turbines in the Altamont Pass Wind Resource
Smallwood CV 54
Area. The Wildlife Society—Western Section Annual Meeting, Sacramento, California, January 19, 2005.
Associations between avian fatalities and attributes of electric distribution poles in California. The Wildlife Society - Western Section Annual Meeting, Sacramento, California, January 19, 2005.
Minimizing avian mortality in the Altamont Pass Wind Resources Area. UC Davis Wind Energy Collaborative Forum, Palm Springs, California, December 14, 2004.
Selecting electric distribution poles for priority retrofitting to reduce raptor mortality. Raptor Research Foundation Meeting, Bakersfield, California, November 10, 2004.
Responses of Fresno kangaroo rats to habitat improvements in an adaptive management framework.
Annual Meeting of the Society for Ecological Restoration, South Lake Tahoe, California, October 16, 2004.
Lessons learned from five years of avian mortality research at the Altamont Pass Wind Resources Area in California. The Wildlife Society Annual Meeting, Calgary, Canada, September 2004.
The ecology and impacts of power generation at Altamont Pass. Sacramento Petroleum Association, Sacramento, California, August 18, 2004.
Burrowing owl mortality in the Altamont Pass Wind Resource Area. California Burrowing Owl Consortium meeting, Hayward, California, February 7, 2004.
Burrowing owl mortality in the Altamont Pass Wind Resource Area. California Burrowing Owl Symposium, Sacramento, November 2, 2003.
Raptor Mortality at the Altamont Pass Wind Resource Area. National Wind Coordinating Committee, Washington, D.C., November 17, 2003.
Raptor Behavior at the Altamont Pass Wind Resource Area. Annual Meeting of the Raptor Research Foundation, Anchorage, Alaska, September, 2003.
Raptor Mortality at the Altamont Pass Wind Resource Area. Annual Meeting of the Raptor Research Foundation, Anchorage, Alaska, September, 2003.
California mountain lions. Ecological & Environmental Issues Seminar, Department of Biology, California State University, Sacramento, November, 2000.
Intra- and inter-turbine string comparison of fatalities to animal burrow densities at Altamont Pass.
National Wind Coordinating Committee, Carmel, California, May, 2000.
Using a Geographic Positioning System (GPS) to map wildlife and habitat. Annual Meeting of the Western Section of The Wildlife Society, Riverside, CA, January, 2000.
Suggested standards for science applied to conservation issues. Annual Meeting of the Western Section of The Wildlife Society, Riverside, CA, January, 2000.
Smallwood CV 55
The indicators framework applied to ecological restoration in Yolo County, California. Society for Ecological Restoration, September 25, 1999.
Ecological restoration in the context of animal social units and their habitat areas. Society for Ecological Restoration, September 24, 1999.
Relating Indicators of Ecological Health and Integrity to Assess Risks to Sustainable Agriculture and Native Biota. International Conference on Ecosystem Health, August 16, 1999.
A crosswalk from the Endangered Species Act to the HCP Handbook and real HCPs. Southern California Edison, Co. and California Energy Commission, March 4-5, 1999.
Mountain lion track counts in California: Implications for Management. Ecological & Environmental Issues Seminar, Department of Biological Sciences, California State University, Sacramento, November 4, 1998.
“No Surprises” -- Lack of science in the HCP process. California Native Plant Society Annual Conservation Conference, The Presidio, San Francisco, September 7, 1997.
In Your Interest. A half hour weekly show aired on Channel 10 Television, Sacramento. In this episode, I served on a panel of experts discussing problems with the implementation of the Endangered Species Act. Aired August 31, 1997.
Spatial scaling of pocket gopher (Geomyidae) density. Southwestern Association of Naturalists 44th Meeting, Fayetteville, Arkansas, April 10, 1997.
Estimating prairie dog and pocket gopher burrow volume. Southwestern Association of Naturalists 44th Meeting, Fayetteville, Arkansas, April 10, 1997.
Ten years of mountain lion track survey. Fifth Mountain Lion Workshop, San Diego, February 27, 1996.
Study and interpretive design effects on mountain lion density estimates. Fifth Mountain Lion Workshop, San Diego, February 27, 1996.
Small animal control. Session moderator and speaker at the California Farm Conference, Sacramento, California, Feb. 28, 1995.
Small animal control. Ecological Farming Conference, Asylomar, California, Jan. 28, 1995.
Habitat associations of the Swainson’s Hawk in the Sacramento Valley’s agricultural landscape. 1994 Raptor Research Foundation Meeting, Flagstaff, Arizona.
Alfalfa as wildlife habitat. Seed Industry Conference, Woodland, California, May 4, 1994.
Habitats and vertebrate pests: impacts and management. Managing Farmland to Bring Back Game Birds and Wildlife to the Central Valley. Yolo County Resource Conservation District, U.C. Davis,
Smallwood CV 56
February 19, 1994.
Management of gophers and alfalfa as wildlife habitat. Orland Alfalfa Production Meeting and Sacramento Valley Alfalfa Production Meeting, February 1 and 2, 1994.
Patterns of wildlife movement in a farming landscape. Wildlife and Fisheries Biology Seminar Series: Recent Advances in Wildlife, Fish, and Conservation Biology, U.C. Davis, Dec. 6, 1993.
Alfalfa as wildlife habitat. California Alfalfa Symposium, Fresno, California, Dec. 9, 1993.
Management of pocket gophers in Sacramento Valley alfalfa. California Alfalfa Symposium, Fresno, California, Dec. 8, 1993.
Association analysis of raptors in a farming landscape. Plenary speaker at Raptor Research Foundation Meeting, Charlotte, North Carolina, Nov. 6, 1993.
Landscape strategies for biological control and IPM. Plenary speaker, International Conference on Integrated Resource Management and Sustainable Agriculture, Beijing, China, Sept. 11, 1993.
Landscape Ecology Study of Pocket Gophers in Alfalfa. Alfalfa Field Day, U.C. Davis, July 1993.
Patterns of wildlife movement in a farming landscape. Spatial Data Analysis Colloquium, U.C.
Davis, August 6, 1993.
Sound stewardship of wildlife. Veterinary Medicine Seminar: Ethics of Animal Use, U.C. Davis.
May 1993.
Landscape ecology study of pocket gophers in alfalfa. Five County Grower's Meeting, Tracy, California. February 1993.
Turbulence and the community organizers: The role of invading species in ordering a turbulent system, and the factors for invasion success. Ecology Graduate Student Association Colloquium, U.C. Davis. May 1990.
Evaluation of exotic vertebrate pests. Fourteenth Vertebrate Pest Conference, Sacramento, California. March 1990.
Analytical methods for predicting success of mammal introductions to North America. The Western Section of the Wildlife Society, Hilo, Hawaii. February 1988.
A state-wide mountain lion track survey. Sacramento County Dept Parks and Recreation. April 1986.
The mountain lion in California. Davis Chapter of the Audubon Society. October 1985.
Ecology Graduate Student Seminars, U.C. Davis, 1985-1990: Social behavior of the mountain lion; Mountain lion control; Political status of the mountain lion in California.
Smallwood CV 57
Other forms of Participation at Professional Meetings
Scientific Committee, Conference on Wind energy and Wildlife impacts, Berlin, Germany, March 2015.
Scientific Committee, Conference on Wind energy and Wildlife impacts, Stockholm, Sweden, February 2013.
Workshop co-presenter at Birds & Wind Energy Specialist Group (BAWESG) Information sharing week, Bird specialist studies for proposed wind energy facilities in South Africa, Endangered Wildlife Trust, Darling, South Africa, 3-7 October 2011. Scientific Committee, Conference on Wind energy and Wildlife impacts, Trondheim, Norway, 2-5 May 2011.
Chair of Animal Damage Management Session, The Wildlife Society, Annual Meeting, Reno, Nevada, September 26, 2001.
Chair of Technical Session: Human communities and ecosystem health: Comparing perspectives and making connection. Managing for Ecosystem Health, International Congress on Ecosystem Health, Sacramento, CA August 15-20, 1999. Student Awards Committee, Annual Meeting of the Western Section of The Wildlife Society, Riverside, CA, January, 2000.
Student Mentor, Annual Meeting of the Western Section of The Wildlife Society, Riverside, CA, January, 2000.
Printed Mass Media
Smallwood, K.S., D. Mooney, and M. McGuinness. 2003. We must stop the UCD biolab now. OpEd to the Davis Enterprise.
Smallwood, K.S. 2002. Spring Lake threatens Davis. Op-Ed to the Davis Enterprise.
Smallwood, K.S. Summer, 2001. Mitigation of habitation. The Flatlander, Davis, California.
Entrikan, R.K. and K.S. Smallwood. 2000. Measure O: Flawed law would lock in new taxes. Op-Ed to the Davis Enterprise.
Smallwood, K.S. 2000. Davis delegation lobbies Congress for Wildlife conservation. Op-Ed to the Davis Enterprise.
Smallwood, K.S. 1998. Davis Visions. The Flatlander, Davis, California.
Smallwood, K.S. 1997. Last grab for Yolo’s land and water. The Flatlander, Davis, California.
Smallwood, K.S. 1997. The Yolo County HCP. Op-Ed to the Davis Enterprise.
Radio/Television
PBS News Hour,
FOX News, Energy in America: Dead Birds Unintended Consequence of Wind Power Development, August 2011.
Smallwood CV 58
KXJZ Capital Public Radio -- Insight (Host Jeffrey Callison). Mountain lion attacks (with guest Professor Richard Coss). 23 April 2009;
KXJZ Capital Public Radio -- Insight (Host Jeffrey Callison). Wind farm Rio Vista Renewable Power. 4 September 2008;
KQED QUEST Episode #111. Bird collisions with wind turbines. 2007; KDVS Speaking in Tongues (host Ron Glick), Yolo County HCP: 1 hour. December 27, 2001; KDVS Speaking in Tongues (host Ron Glick), Yolo County HCP: 1 hour. May 3, 2001; KDVS Speaking in Tongues (host Ron Glick), Yolo County HCP: 1 hour. February 8, 2001; KDVS Speaking in Tongues (host Ron Glick & Shawn Smallwood), California Energy Crisis: 1 hour. Jan. 25, 2001;
KDVS Speaking in Tongues (host Ron Glick), Headwaters Forest HCP: 1 hour. 1998; Davis Cable Channel (host Gerald Heffernon), Burrowing owls in Davis: half hour. June, 2000; Davis Cable Channel (hosted by Davis League of Women Voters), Measure O debate: 1 hour.
October, 2000;
KXTV 10, In Your Interest, The Endangered Species Act: half hour. 1997.
Reviews of Journal Papers (Some scientific journals for whom I’ve provided peer review) Journal Journal
American Naturalist Journal of Animal Ecology
Journal of Wildlife Management Western North American Naturalist Auk Journal of Raptor Research
Biological Conservation National Renewable Energy Lab reports Canadian Journal of Zoology Oikos
Western Birds Journal of Caribbean Ornithology
Ecosystem Health The Prairie Naturalist
Environmental Conservation Restoration Ecology
Environmental Management Southwestern Naturalist
Functional Ecology The Wildlife Society--Western Section Trans.
Journal of Zoology (London) Proc. Int. Congress on Managing for Ecosystem Health Journal of Applied Ecology Transactions in GIS
Ecology Tropical Ecology
Wildlife Society Bulletin Peer J
Conservation Biology Biology Open
Western Wildlife PLOS One
Heliyon Global Ecology and Conservation
Wildlife Monographs Journal for Nature Conservation
Biological Control Ecological Solutions and Evidence
Smallwood CV 59
Journal Journal
Wind Energy Environmental and Ecological Statistics
The Condor Ecosphere
Diversity Renewable and Sustainable Energy Reviews
Northeastern Naturalist
Committees
• Scientific Review Committee, Alameda County, Altamont Pass Wind Resource Area • Ph.D. Thesis Committee, Steve Anderson, University of California, Davis • MS Thesis Committee, Marcus Yee, California State University, Sacramento Other Professional Activities or Products
Testified in Federal Court in Denver during 2005 over the fate of radio-nuclides in the soil at Rocky Flats Plant after exposure to burrowing animals. My clients won a judgment of $553,000,000. I have also testified in many other cases of litigation under CEQA, NEPA, the Warren-Alquist Act, and other environmental laws. My clients won most of the cases for which I testified.
Testified before Environmental Review Tribunals in Ontario, Canada regarding proposed White Pines, Amherst Island, and Fairview Wind Energy projects.
Testified in Skamania County Hearing in 2009 on the potential impacts of zoning the County for development of wind farms and hazardous waste facilities.
Testified in deposition in 2007 in the case of O’Dell et al. vs. FPL Energy in Houston, Texas.
Testified in Klickitat County Hearing in 2006 on the potential impacts of the Windy Point Wind Farm.
Memberships in Professional Societies
The Wildlife Society
Raptor Research Foundation
Honors and Awards
Fulbright Research Fellowship to Indonesia, 1987
J.G. Boswell Full Academic Scholarship, 1981 college of choice Certificate of Appreciation, The Wildlife Society—Western Section, 2000, 2001 Northern California Athletic Association Most Valuable Cross Country Runner, 1984 American Legion Award, Corcoran High School, 1981, and John Muir Junior High, 1977 CIF Section Champion, Cross Country in 1978
CIF Section Champion, Track & Field 2 mile run in 1981
National Junior Record, 20 kilometer run, 1982
National Age Group Record, 1500 meter run, 1978
Community Activities
District 64 Little League Umpire, 2003-2007
Dixon Little League Umpire, 2006-07
Smallwood CV 60
Davis Little League Chief Umpire and Board member, 2004-2005 Davis Little League Safety Officer, 2004-2005
Davis Little League Certified Umpire, 2002-2004
Davis Little League Scorekeeper, 2002
Davis Visioning Group member
Petitioner for Writ of Mandate under the California Environmental Quality Act against City of Woodland decision to approve the Spring Lake Specific Plan, 2002 Served on campaign committees for City Council candidates
Robert M. Smith
Partner
[email protected]
T +1 206 370 5743
F +1 203 370 6271
K&L GATES LLP
925 FOURTH AVENUE SUITE 2900 SEATTLE WA 98104-1158
T +1 206 623 7580 F +1 206 623 7022 klgates.com
March 17, 2026
City of Twentynine Palms
Planning Department
6136 Adobe Road
Twentynine Palms, CA 92277
Re: Proposed E-Group PS Solar Facility
Dear Mr. Gardner:
This letter is submitted on behalf of our client, E-Group PS, LLC (“E-Group”). Attached as Attachment A are supplemental responses to public comments submitted on the draft environmental impact report for the project, prepared by K&L Gates, E-Group, and its environmental consultant, Dudek Environmental. This can replace the previously submitted response in the agenda packet provided to City Council (as it incorporates and updates our previous responses). We look forward to discussing these issues further with you and City Council. Thank you for your continued assistance on this project and consideration of the responses contained herein.
Yours sincerely,
Robert M. Smith
Partner
RMS:
1605879335.11
Response to DEIR Public Comments
Geneva Solar Project
No Comment
er
Comment Response
1 General
Comment
The DEIR discloses mass grading of approximately
528,000 cubic yards of soil, the equivalent of
nearly 50,000 dump trucks.
Grading the project site involves 264,000 cubic yards of cut and fill.
Given that this material will be redistributed on the project site, there will be no import or export of cut and fill by dump trucks. 2 Yuhaaviata
m of San
Manuel
Nation
YMSN requests that the Cultural Resources
Mitigation Measures are revised as they do not
quite reflect what we had previously sent. YSMN
understands that they are not the only Tribe
consulting on this project but believe the
mitigation measures could be more detailed. I
have attached previous correspondence from
YSMN’s Tribal Archaeologist, Kristen Tuosto. She
had provided mitigation measures for both
Cultural Resources and Tribal Cultural Resources.
This comment has been addressed in the Cultural Resources Monitoring Plan submitted for Tribal review. E-Group is happy to address any questions or comments in consultation with YMSN and the City.
3 Mojave
Desert Air
Quality
Managem
ent District
We have reviewed the project as proposed and
based on the information available to us at this
time, the District recommends that the County
requires the owner/operator obtain a Dust
Control Plan (DCP) for the project. The most
current Dust Control Plan Requirements and Dust
Control Plan Submission Form are available at
https://www.mdaqmd.ca.gov/permitting/complia
nceforms. Please note the Solar Dust Control Plan
fee schedule located in Table 1 of MDAQMD Rule
302.
Additionally, the District will require:
• Signage compliant with Rule 403
Attachment B shall be erected at each project site
entrance not later than the commencement of
construction.
• Use a water truck to maintain moist
disturbed surfaces and actively spread water
during visible dusting episodes to minimize visible
As discussed in Section 2.4, Air Quality, of the DEIR, the Project would implement mandatory dust control measures imposed by the City of Twentynine Palms and MDAQMD through Rule 403 concerning fugitive dust control. Accordingly, E-Group will submit a Construction Dust Control Plan in compliance with MDAQMD requirements as required and will incorporate the requested provisions. Postconstruction, the Construction Dust Control Plan will be converted by MDAQMD into a Solar Dust Control Plan that the Project will be required to operate in compliance with.
E-Group has conferred with MDAQMD staff via email and has confirmed that no other MDAQMD permits or approvals are required.
There are no existing buildings on the site that would implicate asbestos concerns.
1605879335.11
Response to DEIR Public Comments
Geneva Solar Project
No Comment
er
Comment Response
fugitive dust emissions. For projects with exposed
sand or fines deposits (and for projects that
expose such soils through earthmoving), chemical
stabilization or covering with a stabilizing layer of
gravel will be required to eliminate visible
dust/sand from sand/fines deposits.
• All maintenance and access vehicular
roads and parking areas shall be stabilized with
chemical, gravel or asphaltic pavement sufficient
to eliminate visible fugitive dust from vehicular
travel and wind erosion. Take actions to prevent
project-related track out onto paved surfaces, and
clean any project-related trackout within 24
hours. All other earthen surfaces within the
project area shall be stabilized by natural or
irrigated vegetation, compaction, chemical or
other means sufficient to prohibit visible fugitive
dust from wind erosion.
• Obtain District permits for any
miscellaneous process equipment that may not be
exempt under District Rule 219 including, but not
limited to: Internal Combustion Engines with a
manufacture's maximum continuous rating
greater than or equal to 50 brake horsepower.
• Comply with all applicable provisions
listed in Rule 403 - Fugitive Dust Control.
• An asbestos checklist is required for any
demolition or renovation of existing buildings.
MDAQMD asbestos informational flowchart and
notification forms are available at
https://www.mdagmd.ca.gov/permitting/asbestos
-information.
1605879335.11
Response to DEIR Public Comments
Geneva Solar Project
No Comment
er
Comment Response
• The proponent should ensure all heavyduty trucks comply with CARB (California Air Resources Board) idling regulations.
4 Agua
Caliente
Band of
Cahuilla
Indians
I have attached the mitigation measures and or
recommendations that ACBCI-THPO would like to
include in the Environmental Impact Report.
E-Group is supportive of incorporating the requested mitigation measures and has provided updated language to the City. The revised language has been incorporated into the Cultural Resources Monitoring Plan. E-Group is happy to address any questions or comments in consultation with the Agua Caliente Tribe and the City. 5 Kerrie Aley The EIR fails to consider the environmental impact of increased density resulting from the rezoning.
Impacts to increased density on the area subject to residential rezoning have been evaluated throughout the DEIR.
6 Kerrie Aley If the solar facility is constructed, tortoises will likely move away from the construction site into
this unstudied area. Furthermore, the increased
zoning density may cause significant negative
impacts to the remaining tortoise population.
Excluding the impact of rezoning constitutes a
piecemeal analysis of a project, which is not
permitted under CEQA.
As noted in Section 2.5, Biological Resources, of the Draft EIR (“DEIR”), any desert tortoises occupying the project site will be relocated to an appropriate mitigation site approved by the California Department of Fish & Wildlife (“CDFW”) and U.S. Fish & Wildlife (“USFWS”) pursuant to Mitigation Measures BIO-5 and BIO-6. Any future residential development would be required to comply with similar mitigation through Mitigation Measure BIO-7.
7 Kerrie Aley While the land next to a large scale solar plant is theoretically "developable land" it is highly
unlikely that the unzoned property would be a
desirable residential place to live given the loss of
scenic views, dust, and the close proximity to
industrial facilities. The upzoning of the land
adjacent to an industrial facility for housing
violates Twentynine Palms General and Land Use
Plan and most land use professionals would find
this type of rezoning objectionable as there are no
transitional land use buffers between residential
and industrial. This seems to me to be spot zoning
to accommodate a specific project.
The project complies with State law requirements that the City does not reduce the potential supply of available housing. State law does not require, nor would it be appropriate, for the City to evaluate the desirability of all residentially zoned property. The project is consistent with the City’s General Plan through maintaining the existing available housing density.
1605879335.11
Response to DEIR Public Comments
Geneva Solar Project
No Comment
er
Comment Response
8 Kerrie Aley In my opinion the ONLY acceptable way to
approve this project would be to require that the
area proposed for housing be deeded
conservation land (an area for the displaced
tortoise) and that more suitable parcels be
purchased by the applicant which can be rezoned
to accommodate the loss of land for housing. I
would encourage that the land east of this project
be also considered for conservation land to buffer
these homeowners from the negative impact of
this project.
Based upon discussions with CDFW and USFWS, the agencies have rejected an initial proposal to subject land adjacent to the project site to a conservation easement for the benefit of desert tortoise, in lieu of areas that the agencies consider more favorable for the overall conservation of desert tortoise.
9 Kerrie Aley Please re-evaluate your Land Use Element as part of Twentynine Palms General Plan update to
accommodate suitable solar plants sites rather
than spot zoning parcels just because there is a
project applicant.
The proposed energy zone includes City-wide standards that govern sites that would be suitable for renewable energy development, including but not limited to the project site.
10 Kerrie Aley When considering solar facilities you must also consider how this now degraded land can be used
after the plant is decommissioned. While it is easy
to scrape desert land to remove desert native
plants it is biologically difficult and very expensive
to restore the land. I see no mention of this issue
in the EIR mitigation and would hope that a
requirement to remove the solar hardware and
rehabitat the land is included in the project's
conditions of approval. Liken to oil drilling
companies I have discovered that most solar
companies have similar corporate structures that
make it very difficult to enforce terms of
approval. This fact can be demonstrated by the
40,000 uncapped oil wells in California.
The proposed energy zoning requires approval of a decommissioning plan. The environmental impacts of decommissioning are considered in the DEIR. See, e.g. Mitigation Measures BIO-1, BIO-2, BIO-3, and BIO-10 and pgs. 1-6, 2.5-26-27, and 2.13-15.
1605879335.11
Response to DEIR Public Comments
Geneva Solar Project
No Comment
er
Comment Response
11 Shawna
Alvarez
The flora and fauna that inhabit this region are
finely tuned to its rhythms and extraordinarily
vulnerable to disruption. Of particular concern is
the desert tortoise, a federally protected and
endangered species whose long-established
habitat within this area has been extensively
documented. These animals have lived on this
land for generations. Relocation is not a humane
or viable solution; it is well established that
relocation causes extreme stress and often results
in death. Proceeding with a project that knowingly
destroys their habitat is to guarantee their
suffering and loss.
Impacts to desert tortoise are discussed in DEIR Section 2.5, Biological Resources. In accordance with the California Environmental Quality Act (“CEQA”), potentially significant impacts have been mitigated in full compliance with local, state and federal regulations pursuant to Mitigation Measures BIO-5 and BIO-6.
12 Shawna
Alvarez
Disruption of desert soil releases particulate
matter and soil-borne microbes into the air—
phenomena observed in other regions where
industrial solar fields have been constructed.
These airborne particles pose serious risks to
respiratory health, particularly in a region already
subject to strong Santa Ana winds. When the
fragile topsoil is destroyed, those winds no longer
carry only air, but dense clouds of dust capable of
exacerbating allergies, asthma, and chronic illness.
The resulting air quality would be intolerable for
those who live here.
Dust and associated health impacts are discussed in DEIR Section 2.4, Air Quality. See pgs. 2.4-27-28. As provided therein, “Although the site will be graded for both the Solar Project and the Residential GPA, the potential for the release of the spores which result in Valley Fever is considered low, given the County-wide low incidence rates. In addition, as discussed above, compliance with standard dust control measures would limit the amount of fugitive dust generated during construction, further minimizing the potential for any released spores to become airborne.” In addition to compliance with MDAQMD rules governing fugitive dust control through the implementation of a project-specific Dust Control Plan, potential dust-related impacts are addressed through Mitigation Measure AES-1 that requires implementation of a Habitat Restoration Plan (see DEIR Appendix D.3) upon completion of construction to expedite habitat restoration and reduce fugitive dust impacts during operations.
13 Shawna
Alvarez
The desert also functions as a natural system for
water absorption, filtration, and drainage.
Destroying this land compromises its ability to
manage rainfall, increasing the likelihood of
Impacts to drainage and hydrology are discussed in DEIR Section 2.11.
As noted therein, the project (including associated grading) avoids existing ephemeral streams, thereby preserving existing drainage on the site.
1605879335.11
Response to DEIR Public Comments
Geneva Solar Project
No Comment
er
Comment Response
flooding and erosion. What has functioned for
centuries as a natural watershed would be
rendered ineffective, creating cascading
consequences for the environment and nearby
communities.
14 Shawna
Alvarez
Twentynine Palms and the Morongo Basin are
known worldwide for their quiet, open vistas and
profound sense of solitude. People travel from
across the globe to experience the stillness and
beauty that only the desert can provide. Over the
past decade, tourism has become an essential
pillar of the local economy, built precisely on
these qualities. Industrial solar fields—producing
constant noise, visual blight, and ecological
damage—would replace serenity with a loud,
buzzing, barren landscape.
Construction and operational noise impacts associated with the project are addressed in Section 2.13 of the DEIR. As described therein, the project would not result in a significant source of operational noise. Aesthetic impacts are addressed in DEIR Section
2.3, which concludes that the project is not visible from most public viewpoints, including Two Mile Road, and would not significantly impact scenic vistas.
15 Peter Lang The DEIR repeatedly describes the project as a “50 megawatt (MW) commercial solar generation
facility” (Project Description; Notice of
Availability). This figure is used implicitly to frame
the project’s scale, asserted public benefits, and
regulatory context. However, elsewhere in the
DEIR and NOA, the project description specifies
approximately 170 inverters, each identified as
225-kilowatt (kW) units (Noise Analysis;
equipment descriptions). Using the DEIR’s own
specifications: 170 inverters × 225 kW = 38,250
kW, or approximately 38.25 MW AC.
The DEIR does not disclose:
• transformer counts,
• transformer MVA or kVA ratings,
• export limits at the point of interconnection,
The project has a generating capacity of over 50 MW. The Project Description identifies 160,000 PV modules. Based upon further project refinement, the project will install approximately 130,000 modules each rated at 395 WDC, resulting in a total approximate generating capacity of 51.35 MWDC. Because less modules are required, any environmental impacts associated with the installation and operation of modules will be less than described in the DEIR.
Photovoltaic modules are the project’s source of power generating, directing, and converting solar energy into electrical energy at the module level.
As noted in the project description, the project includes approximately 170 inverters. Inverters do not generate electricity, but rather convert DC electricity into AC electricity for grid interconnection. The inverters operate at a reduced output level in order to reduce noise and thermal impacts.
1605879335.11
Response to DEIR Public Comments
Geneva Solar Project
No Comment
er
Comment Response
• or any explanation reconciling the stated “50
MW” figure with the inverter fleet described.
CEQA requires a stable, accurate, and internally
consistent project description. A project cannot
be analyzed, mitigated, or approved based on a
capacity figure that is not supported by the
equipment description elsewhere in the same
document. If the project’s actual maximum AC
export is approximately 38 MW, describing it as a
50 MW facility materially mischaracterizes its
scale and implications.
The FEIR must clearly and unambiguously disclose:
• maximum AC export capacity (MWac),
• DC nameplate capacity (MWdc),
• DC/AC ratio,
• transformer numbers and ratings,
• and any interconnection or export constraints.
16 Peter Lang The DEIR discusses zoning changes largely as a procedural matter, without adequately addressing
the equity and fairness implications of imposing
an industrial use on existing residents who bear
the impacts but receive few, if any, corresponding
benefits.
The FEIR must explicitly analyze:
• incompatibility with surrounding land uses,
• reliance interests of existing residents,
• and the irreversible nature of this land use
conversion.
CEQA requires public agencies to consider and evaluate the environmental consequences of their discretionary actions through the preparation of appropriate studies and documentation, including environmental reports. The CEQA process does not take into consideration equity, fairness, or purely economic impacts associated with a given development project. Friends of Davis v. City of Davis (2000) 83 Cal. App. 4th 1004, 1019; Porterville Citizens for Responsible Hillside Development v. City of Porterville (2007) 157 Cal. App. 4th 885, 902-3. Compatibility with the surrounding area is considered throughout the DEIR, including Sections 2.3, 2.4, 2.12, and 2.13, consistent with the standards provided in the CEQA Guidelines. 17 Peter Lang The DEIR acknowledges that creation of an Energy zoning district could facilitate future solar projects
and that cumulative visual impacts could become
significant (Cumulative Impacts discussion).
The cumulative potential for future solar projects is evaluated as appropriate throughout the DEIR. See, e.g. DEIR pgs. 2.3-22-23, 2.5-
50. As noted in the DEIR, any future proposed solar developments would be subject to the design standards and controls incorporated
1605879335.11
Response to DEIR Public Comments
Geneva Solar Project
No Comment
er
Comment Response
This is a critical admission. Zoning changes are not
neutral; they function as policy inducements.
Once an Energy zone is established in this
location, future projects may cite it as precedent,
incrementally intensifying impacts that the DEIR
already acknowledges could be cumulatively
significant. The FEIR must analyze this zoning
change as an active mechanism for cumulative
impacts, not merely as a hypothetical possibility.
Failure to do so understates long-term
environmental risk.
into the City’s energy zone ordinance, which are designed to ensure that future solar projects are appropriately sited and reduce potential impacts. Further, any such projects would be subject to environmental review by the City and imposition of appropriate mitigation measures, similar to the analysis provided in the DEIR.
Because there are no such projects proposed and many impacts would depend upon a site-specific analysis, any further evaluation of impacts associated with future solar projects would be purely speculative.
18 Peter Lang The DEIR bundles a Residential General Plan Amendment that increases density from RL-5 to
RS-1 on approximately 60 acres near the project
site.
The DEIR does not clearly explain:
• why this amendment is tied to the solar project
approvals,
• whether it is intended to offset project impacts,
• or how induced growth effects are addressed.
Under CEQA, General Plan Amendments require
independent justification and analysis. Bundling
this amendment with the solar project without a
clear rationale obscures its purpose and impacts.
The FEIR must clarify this relationship and fully
analyze growth inducing effects.
The reasoning is fully explained on pg. ES-3 of the DEIR: “The Residential GPA portion of the Project consists of changes to the General Plan necessary to offset the Solar Project’s impacts associated with Senate Bill (SB) 330. Because the Solar Project will remove 241 acres of residential land from the City’s total residential supply, the applicant for the Solar Project is required to offset the loss and assure that the City does not reduce its potential housing supply.
A General Plan Amendment and Rezone are proposed to change the land use and zoning designations on the 119 acres of RL-5 designated land of parcels 0612-201-01 and 0612-201-05 south of the Solar Project. The GPA and Rezone will redesignate 60 acres (half of the RL5 designated land) as Single Family Residential, 1 unit per acre (RS-1), while the remaining 59 acres remain RL-5 (see Exhibit 5). Because the Solar Project will eliminate the potential for 48 residential units (the maximum density allowed in the RL-5 designation), the GPA and Rezone will increase the density of the southerly 236 acres from the currently allowable 71 units to a maximum of 119 units. This change will therefore accommodate the 48 units which would be lost if the Solar Project is approved. There is no residential development proposed on this acreage as part of the Project.”
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As noted in Section 2.14 and Section 6, because the project maintains the same permissible residential density on the project site and surrounding area would be the same as existing conditions and therefore would not increase the potential residential density or population of the area.
19 Peter Lang The DEIR’s operational noise analysis relies on simplified assumptions that materially
understate real-world conditions. Specifically, the
analysis:
• does not adequately model the cumulative noise
produced by approximately 170 inverters
operating simultaneously,
• appears to rely on point-source assumptions
that do not reflect distributed industrial
equipment,
• does not address tonal noise or low-frequency
humming characteristic of inverter operation,
• and does not analyze noise from ancillary
sources such as transformers, alarms,
maintenance vehicles, or nighttime activity.
The 170 inverters would be distributed throughout the 184-acre project site, spaced at least 120 feet apart. As noted in the DEIR, the nearest noise sensitive receptors are located over 1,400 feet from the solar project site. The vast majority of the inverters will be significantly farther from such sensitive receptors. Accordingly, the individual contribution of inverters to received operational noise at nearby residential land uses will depend upon the distance to the nearest sensitive receptor and only the closest inverters would have an impact on such sensitive receptors. As noted in response to comment 15, E-Group intends to operate inverters at a reduced output level to further reduce inverter noise as compared to the factory estimates evaluated in the DEIR. Noise from inverters is also significantly reduced at night.
The DEIR qualitative analysis of inverter and transformer noise at the closest residences to the project is appropriate given the large separation distance between the project and these closest residences. To validate that the conclusions of the DEIR qualitative analysis are accurate, Dudek performed an additional screening level quantitative analysis, contained in the attached spreadsheet (Screening Analysis for Equipment Noise Impacts at Closest Off-site Receivers). See Exhibit 1. As concluded in the attached spreadsheet, combined inverter and transformer noise at the closest residence would be no greater than 45 dBA, which is well below the general plan noise element exterior limit of 65 dBA for residences.
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Consequently, the DEIR operational noise conclusion of less than significant is accurate.
Noise from operations of the project transformer is analyzed in the DEIR. See DEIR, pg. 2.13-13. As noted therein, “At a distance of 1,000 feet, transformer noise would be expected to attenuate well below the City’s standards at 15 feet (about 5 meters) and would not be perceptible at the nearest sensitive receptors.” Routine maintenance is anticipated to occur infrequently and manually, without utilizing high noise generating equipment. No maintenance activities are anticipated to occur at night, other than as needed to address emergency conditions.
Regarding tonal or low frequency noise from inverters, both transformers and inverters produce noise in the low frequency range (less than 200 hertz [Hz]) as well as in the audible range (human hearing is most sensitive to the range between 1000 and 4000 Hz).
Environmental noise, including operational noise from facilities, is normally measured in the dBA scale, which corresponds well to human hearing response. For low frequency sound, levels are measured and reported using the G-weighted scale (dBG). On the dBG scale, sound levels are not normally audible to the human ear until they reach an intensity of 85 dBG. At distances very close to transformers or inverters, sound levels might reach 85 dBG and be audible to humans. For a solar facility similar to the E-Group PS Solar Project, Dudek performed measurements using specialized meters designed for low frequency sound levels (Dudek 2014). For an inverter, the measured sound level was approximately 60 dBG at 50 feet from the inverter. For a transformer, the measured sound level was approximately 62 dBG at 25 feet from the transformer. See Exhibit 2. Thus, even at distances relatively close to the equipment, sound levels were well below the audible range for humans. Given
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that the closest residences are over 1,400 feet from the solar facility, low frequency noise from operations would not be audible at these residences. In addition, the noise measurements show distribution of sound energy across the range of 1 – 80 Hz for both inverters and transformers, meaning the noise is not tonal (i.e., composed of a single or narrow band of frequencies).
E-Group will not be installing any alarms on the project site other than potentially installing security alarms.
20 Peter Lang Throughout the DEIR, construction noise is characterized as “temporary.” This
characterization is used to justify a conclusion of
less-than-significant impact.
However, the DEIR does not provide:
• enforceable limits on construction duration,
• caps on the number of concurrent noiseproducing activities, • mandatory monitoring requirements,
• or penalties for exceedances.
The DEIR does not rely upon the temporary nature of the construction noise to conclude that it is a less than significant impact.
As noted in the DEIR: “However, most construction activities will be confined within the property’s boundary and over 1,400 feet northwest of the nearest existing single-family home. Grading activities will consist of mobile equipment traveling across the site, which would generate noise levels of about 85 dBA at 50 feet, which attenuate by about 6 dB for every doubling of distance. At a distance of 1,400 feet, noise levels would be expected to be well below the City’s standard of 65 dBA at the nearest existing home, as graders pass the northeastern corner of the site. This noise level will not be sustained, and will be reduced rapidly as equipment moves southerly or easterly on the site. In addition, this noise level will occur during the less sensitive daytime hours, and for a period of about 3 months (grading phase). The residents at the closest residential unit will not experience substantial sustained noise levels during the grading phase, and impacts would be less than significant. As shown in Table
2.13-3, the highest level of noise during construction of the Solar Project will be from pile drivers installing the solar racks on the site.
These activities could generate noise levels of up to 95 dBA at 50 feet.
At a distance of over 1,400 feet, those noise levels would be reduced well below the City’s 65 dBA standard.”
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Construction noise will be less than significant because it will be below the noise thresholds established under the City’s noise ordinance. Violations of the City noise ordinance are enforced through the City’s existing code enforcement regulations. 21 Peter Lang The DEIR fails to address the public health and wellbeing effects of chronic noise exposure on
nearby residents, including sleep disruption,
stress, and reduced quality of
life. CEQA requires consideration of human health
impacts where environmental effects affect
people. The FEIR must address chronic noise as a
public health issue, particularly for residents
within close proximity to the site.
See above. The project will not result in significant noise impacts that would result in adverse impacts to nearby residents. The City’s noise ordinance is adequately protective of public health.
22 Peter Lang The DEIR states that approximately 142 acres would be disturbed and graded, with cut and fill
“balanced on site.” However, it does not disclose
total earthwork volumes. Using standard civil
engineering assumptions, grading approximately
131.6 acres to even modest average depths
implies hundreds of thousands of cubic yards of
soil movement, equivalent to tens of thousands
of dump-truck loads.
See response to comment 1, above.
23 Peter Lang This analysis ignores the episodic, wind-driven nature of dust in desert environments,
particularly given prevailing northeast winds that
blow toward town, nearby residences, Two Mile
Road, the cemetery, and the Highway 62
commercial corridor.
Assumed compliance is not enforceable
mitigation. The FEIR must include wind-based
Potential dust impacts are evaluated in the DEIR. See DEIR pgs. 2.4- 19-20, 2.4-27-28. As demonstrated in the DEIR, PM10 and PM2.5 emissions were estimated to be substantially below the significance thresholds. Furthermore, the project would submit a Dust Control Plan as required by MDAQMD Rule 403. Rule 403 requires operators to prevent fugitive dust from leaving a site by using reasonable control measures, keeping emissions below particulate limits, and avoiding visible dust beyond the property line. MDAQMD will be notified within 10 days prior to the commencement of activity operations on the project site and the Dust Control Plan will be
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shutdown thresholds, real-time monitoring, and
performance standards.
inspected by MDAQMD staff as required by Rule 403(D)(7) in order to ensure dust suppression/mitigation methods will be implemented and are functioning as intended.
Note that the City Development Code regulations proposed for the Renewable Energy zone also contain several conditions that must be included for the Project. These include:
The proposed commercial solar field will be designed, constructed, and operated so as to minimize dust generation, including provision of sufficient watering of excavated or graded soil during construction to prevent excessive dust.
Watering will occur at a minimum of three times daily on disturbed soil areas with active operations, unless dust is otherwise controlled by rainfall or use of a dust palliative, or other approved dust control measure.
All clearing, grading, earth moving, and excavation activities will cease during period of winds greater than 20 miles per hour (averaged over one hour), or when dust plumes of 20 percent or greater opacity impact public roads, occupied structures, or neighboring property.
For sites where the boundary of a new commercial solar field will be located within one-quarter mile of a primary
residential structure, an adequate wind barrier will be provided to reduce potentially blowing dust in the direction of the residence during construction and ongoing operation of the commercial solar field.
Any unpaved roads and access ways will be treated and maintained with a dust palliative or graveled or treated by another approved dust control method to prevent excessive dust, and paving requirements will be applied pursuant to City standards.
On-site vehicle speed will be limited to 15 miles per hour.
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Reliance upon compliance with adopted local, regional, and state regulations is sufficient under CEQA without incorporating additional mitigation measures. Oakland Heritage Alliance v. City of Oakland (2011) 195 Cal. App. 4th 884, 904-05.
24 Peter Lang The DEIR acknowledges residences approximately 1,400 feet from the project site but does not apply
enhanced protections appropriate for sensitive
receptors.
Impacts that may be less than significant at
greater distances can be significant at closer
proximity. The FEIR must explicitly analyze impacts
at the nearest residences and tailor mitigation
accordingly.
The DEIR identifies all sensitive receptors within the surrounding area and evaluates impacts to the closest residential properties. See, e.g.
DEIR pgs. 2.4-15, 2.4-26, 2.13-9-16.
25 Peter Lang Dust deposition on roadways, increased truck traffic, and construction access can degrade
visibility and roadway safety. The DEIR does not
adequately analyze these risks, particularly along
Two Mile Road and nearby corridors.
As noted in the DEIR, the project will require submittal and approval of a construction management plan that addresses these issues, as well as submission and approval of a Dust Control Plan to MDAQMD.
See DEIR pgs. 1.9, 2.17-14.
26 Peter Lang The DEIR confirms the presence of occupied desert tortoise habitat and acknowledges
approximately 142.1 acres of permanent habitat
impact.
Permanent habitat loss is a significant biological
impact that cannot be minimized through
procedural measures alone. The FEIR must fully
confront this reality.
The project proposes and incorporates mitigation for desert tortoise impacts in compliance with local, state, and federal law. See Mitigation Measures BIO-5 and BIO-6. Also see response to comment
27. 27 Peter Lang The DEIR proposes compensatory mitigation at a minimum 1:1 ratio, to be achieved through offPursuant to the CEQA Guidelines, the compensatory mitigation approach presented in Section 2.5, Biological Resources, of the DEIR is not considered deferred mitigation. “Formulation of mitigation
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site land acquisition or mitigation bank credits,
with details to be provided later
for agency approval.
The DEIR does not identify:
• mitigation lands or banks,
• performance standards,
• monitoring metrics,
• or success criteria.
Deferred mitigation of this magnitude does not
support a “less than significant” conclusion under
CEQA.
measures should not be deferred until some future time. However, measures may specify performance standards which would mitigate the significant effect of the project and which may be accomplished in more than one specified way.” 14 CCR §15126.4(a)(1)(B). “Compliance with regulatory permits or standards may serve as mitigation if compliance would result in mitigation of the significant effect.” 14 CCR §15126.4(a)(1)(D).
Consistent with CEQA Guidelines §15126.4(a)(1)(D), the DEIR appropriately relies on the regulatory process and provides a commitment to mitigation with feasible mechanisms for
implementation that are enforceable. Compensatory mitigation under the Endangered Species Act and California Endangered Species Act is developed through formal consultation and permitting processes with CDFW and USFWS, whereby mitigation requirements are refined and approved based on project-specific impacts and agency standards. The DEIR therefore appropriately identifies the need for compensatory mitigation and the applicable regulatory framework, while acknowledging that the specific mitigation details will be determined through subsequent agency review and approval.
Specifically, Mitigation Measure BIO-6 requires mitigation at a minimum of a 1:1 ratio, provides a procedure by which such impacts will be mitigated (either through the purchase of off-site habitat mitigation lands or the purchase of mitigation credits), that E-Group obtain an Incidental Take Permit from CDFW and USFWS, and that EGroup comply with approved conservation plan requirements.
Further detail is not appropriate at this time as it is subject to review and approval by both CDFW and USFWS. E-Group has already submitted an Incidental Take Permit application to CDFW (see Exhibit 3), which is currently under review. Furthermore, the desert tortoise mitigation proposed in the DEIR is consistent with the USFWS General
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Conservation Plan for Mojave Desert Tortoise, recently approved and adopted by USFWS in 2025. See Exhibit 4.
Similar conditions of approval have been upheld as sufficiently protective and not deferred mitigation. See Rialto Citizens for Responsible Growth v. City of Rialto (2012) 208 Cal. App. 4th 899, 945 (holding that requiring ESA consultation with USFWS concerning potential take of endangered species was proper under CEQA); Defend the Bay v. City of Irvine (2004) 119 Cal. App. 4th 1261, 1276 (finding requiring later consultation and approval of a take permit from CDFW and/or USFWS did not constitute deferred mitigation). 28 Peter Lang The DEIR’s reliance on exclusion fencing and clearance surveys prevents immediate take but
does not mitigate permanent habitat conversion
or fragmentation. Fencing excludes tortoises from
their habitat rather than conserving it.
Perimeter fencing, access roads, and graded
expanses fragment wildlife movement
corridors. The DEIR lists measures but does not
evaluate functional connectivity loss or
long-term population effects.
The DEIR acknowledges that the project will result in the loss of suitable habitat for desert tortoise on the project site and incorporates appropriate measures to mitigate for that loss pursuant to Mitigation Measures BIO-5 and BIO-6. Habitat fragmentation is discussed in DEIR pgs. 2.5-32-34, which concludes that the project will not result in a significant impact.
29 Peter Lang Large-scale grading and soil compaction alter natural sheet flow, infiltration, and erosion
patterns. The DEIR does not adequately evaluate
extreme storm events or downstream
sediment impacts.
See response to comment 13. Impacts to drainage and hydrology are extensively discussed in DEIR Section 2.11, which is further supported in a hydrology study prepared for the project which incorporates hydrologic modeling under 100-year storm events.
30 Peter Lang The DEIR’s own findings of permanent visual degradation conflict with the City’s identity as a
peaceful community and gateway to Joshua Tree
National Park. The FEIR does not
Economic impacts are outside the scope of CEQA analysis. Also see response to comment 10 above.
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analyze economic impacts related to tourism
perception, visitor experience, or safety concerns.
The City’s agreement for approximately $100,000
per year must be weighed against:
• administrative oversight costs,
• enforcement and monitoring,
• infrastructure wear,
• and potential losses to tourism and property
values.
The DEIR provides no net fiscal impact analysis.
While the DEIR references decommissioning, it
does not provide a fully costed, binding plan or
financial assurance sufficient to cover worst-case
abandonment scenarios,
including partial construction or project failure.
31 Peter Lang The project irreversibly converts intact desert land and soil structure. The FEIR must address longterm ecological consequences beyond construction materials and energy
benefits.
These impacts are discussed throughout the DEIR, including but not limited to DEIR Section 2.5.
32 Kat TalleyJonesI am also concerned about the CEQA impact determination: Potentially Significant impact prior
to mitigation. Despite attempts at mitigation, any
tortoise mortality given their endangered status is
a tragedy.
Construction vehicles, equipment, and personnel
increase the risk of:
• Crushing tortoises or burrows
• Entrapment in trenches or excavations
• Vehicle strikes
The DEIR does not state that unauthorized take would occur. The DEIR requires that any potential take of desert tortoise be mitigated through appropriate mitigation and approval of an incidental take permit by CDFW and USFWS. See Mitigation Measures BIO-5 and BIO6. E-Group is compliant with those requirements. The potential impacts discussed in the comment are discussed in DEIR Section 2.5 and are appropriately avoided through the imposition of Mitigation Measures BIO-1 and BIO-5.
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The DEIR acknowledges that unauthorized take
could occur without strict controls, which is a
significant impact under CEQA and the
Endangered Species Act.
33 Suzanne
Lyons
The DEIR assumes that the Project site can
accommodate a large fixed-tilt solar photovoltaic
facility without providing a site-specific solar
access or horizon shading analysis, despite the
Project’s location at the base of a rising landform.
Without such analysis, the DEIR cannot
substantiate its assumptions regarding grading
volumes, panel height, layout stability, or longterm operability. CEQA does not permit reliance on conceptual
assumptions where later engineering may
materially alter the Project and its impacts.
E-Group conducted extensive analysis and due diligence of the project site to confirm its suitability for solar development prior to entering into a lease of the property. The grading volumes, panel height, and site design have all been engineered and designed by the project engineering team and evaluated in the project’s grading plan application submitted to the City. Should the project require further modification at a later date, any such modifications that have the potential to result in greater environmental impacts would be subject to supplemental environmental review under CEQA.
34 Suzanne
Lyons
The DEIR discloses approximately 500,000 cubic
yards of cut and fill but does not demonstrate that
this figure represents a maximum or stable upper
bound. Fixed tilt solar development on rolling or
toe-of-slope terrain frequently requires additional
grading or increased panel height to avoid shading
losses. If grading volumes increase, impacts
related to dust, hydrology, erosion, aesthetics,
and
biological resources would be materially
understated.
See responses to comments 1 and 33.
35 Suzanne
Lyons
No independent, third-party technical feasibility
review has been conducted to evaluate solar
access, grading feasibility, drainage constraints,
constructability, or operational assumptions. Best
practice for a utility-scale solar facility of this
CEQA does not require third-party technical feasibility review. EGroup’s plans and studies have been prepared by consultants who have significant experience with their subject matters and the development of renewable energy projects. E-Group similarly has significant experience in the construction, development, and
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size—particularly one proposed within city limits
and adjacent to residential uses—is independent
technical vetting. The City is being asked to rely
almost entirely on
applicant-retained consultants and
subcontractors, without independent
verification . . . A thorough technical examination
of the DEIR by a neutral 3rd party is necessary for
decisionmakers the public to have confidence
that they have been given all of the relevant
technical details needed to assess the full impact
of the proposed project.
operation of renewable energy projects. E-Group understands that the project engineering and design, associated with grading, electrical, and building permits, will be evaluated by Charles Abbott Associates, Inc.
36 Suzanne
Lyons
Operational noise analysis does not adequately
address cumulative inverter fields, tonal noise,
alarm systems, maintenance vehicles, or nighttime maintenance activities. Construction noise is dismissed as “temporary” without enforceable
limits on duration or phasing. Chronic noise
impacts on nearby residents and associated
public-health considerations are not adequately
evaluated.
See responses to comments 19 and 20.
37 Suzanne
Lyons
The Project involves mass grading of intact, winderodible desert soils in a windy corridor near residences, roadways, and commercial areas. The
DEIR relies primarily on generalized regulatory
compliance rather than enforceable, site specific
monitoring, thresholds, and shutdown protocols.
See response to comment 23.
38 Suzanne
Lyons
The DEIR confirms permanent loss of occupied
desert tortoise habitat yet relies on minimum
acreage-based mitigation that does not replace
lost corridor and connectivity function.
Permanent exclusion fencing constitutes a longSee response to comment 28.
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term barrier effect that is not adequately analyzed
at the corridor scale.
39 Suzanne
Lyons
The DEIR concedes permanent, unmitigable
aesthetic impacts but fails to fully contextualize
these impacts within the City’s gateway setting,
tourism economy, and established residential
character. Potential increases in panel height or
grading to address feasibility constraints related to
solar absorption of panels in sloping terrain
subject to daily and seasonal shading could further
exacerbate visual impacts beyond those disclosed.
Aesthetic impacts are addressed in DEIR Section 2.3, which concludes that the project is not visible from most public viewpoints, including Two Mile Road, and would not significantly impact scenic vistas.
Because the project would not significantly impact scenic vistas or be visible from most publicly utilized roadways, it is not anticipated to affect tourism. See response to comment 33 concerning subsequent changes in the project design.
40 Suzanne
Lyons
The DEIR states that the Project would be
decommissioned after approximately 35 years but
provides no binding plan, cost estimate, or
secured financial assurance. Without enforceable
commitments, the City risks inheriting abandoned
infrastructure and long-term environmental
degradation.
See response to comment 10.
41 Suzanne
Lyons
The DEIR’s alternatives do not meaningfully avoid
the Projects primary impact drivers, including
industrial land use incompatibility, habitat loss,
corridor fragmentation, dust, and visual
degradation. A reasonable range of site or design
alternatives has not been fully evaluated.
The DEIR evaluates a reasonable range of project alternatives. As noted in the DEIR, this includes a reduced project density alternative, which would lessen, but not avoid, identified significant impacts associated with changing the visual character of the project site. The other impacts listed in the comment were not identified as significant impacts in the DEIR.
42 Suzanne
Lyons
The DEIR acknowledges that the Project cannot be
built under the City’s current zoning and General
Plan framework and that a new zoning designation
would be required to allow an industrial-scale
solar power facility at this location. The affected
area is currently characterized by rural residential
zoning and large-lot development patterns that
support quiet, low-intensity use. Rather than
The fact that a project requires an amendment to the city’s zoning code or general plan does not in and of itself create a significant impact under CEQA. Lighthouse Field Beach Rescue v. City of Santa Cruz (2005) 131 Cal. App. 4th 1170, 1207. Amendments to city zoning and general plan are properly considered when evaluating consistency. Id. Adoption of the identified general plan amendment and zone change have been held to constitute appropriate mitigation to resolve a potential land use conflict. Los Angeles Parks Alliance v.
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analyzing this conversion as a significant land-use
incompatibility
impact, the DEIR treats it as a planning exercise—
effectively reshaping the City’s land-use
framework to accommodate a specific project.
CEQA requires the opposite approach: the Project
must be evaluated against the City’s adopted land
use vision, not vice versa.
Los Angeles Metropolitan Transit Authority (2025) 2025 WL 1261816, *10-13.
“CEQA nowhere calls for evaluation of the impacts of a proposed project on an existing general plan; it concerns itself with the impacts of the project on the environment, defined as the existing physical conditions in the affected area. The legislation evinces no interest in the effects of proposed general plan amendments on an existing general plan, but instead has clearly expressed concern with the effects of projects on the actual environment upon which the proposal will operate.” Environmental Planning & Information Council v. County of El Dorado (1982) 131 Cal. App. 3d 350, 351. Impacts associated with the project, including the impacts associated with the proposed zone change and general plan amendment, are evaluated throughout the DEIR. This includes an evaluation of the project’s impacts on adjacent residential zoning, where appropriate. For example, the DEIR evaluates noise impacts to sensitive receptors, concluding that the project will result in a less than significant noise impact.
43 Suzanne
Lyons
The DEIR does not meaningfully evaluate:
• incompatibility between an industrial power
plant and nearby residences on 5-acre parcels,
• loss of quiet rural character,
• inequitable impacts on existing homeowners
whose expectations were based on long-standing
zoning protections,
• or precedent effects created by introducing an
industrial energy zone within city limits.
Economic impacts to property values are beyond the scope of CEQA.
Regarding impacts associated with land use compatibility and noise, see responses to comments 42 and 19, respectably. Regarding the precedential effects of the project, see response to comment 17. 44 Suzanne
Lyons
By creating a new zoning pathway to permit
industrial-scale solar facilities within city limits,
the City risks opening the door to additional
proposals in similarly situated areas. The DEIR
See response to comment 17.
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does not analyze whether this zoning action could
lead to cumulative land-use conversion pressure,
increased infrastructure demands, or progressive
erosion of residential and gateway character.
45 Suzanne
Lyons
The FEIR must:
1. Analyze the Project as a land-use
incompatibility impact, not merely a zoning
amendment.
2. Evaluate the precedent effect of creating a new
industrial energy zoning category within the City.
3. Compare this site against less sensitive, more
compatible locations, rather than assuming this
site is appropriate because it is available or near
existing electrical infrastructure.
See responses to comments 19 and 42. Regarding alternative site locations, several were evaluated but were determined to be unfeasible. See DEIR, pg. 3-4.
46 Suzanne
Lyons
From the earliest stages of consideration, the
Project has been presented to the City and public
through a narrative suggesting that approval was
effectively inevitable due to AB 205, and that
refusal to cooperate would result in loss of local
control and economic benefit. This framing is
reflected in early staff reports and
correspondence from E-Group’s legal counsel
(Exhibit 1.)
This narrative is not a substitute for CEQA analysis.
CEQA requires that the City independently
evaluate whether the Project is appropriate for
the proposed site and whether its environmental
impacts can be avoided or mitigated to a lessthan-significant level. Assertions of inevitability— whether explicit or implied—risk narrowing the
The DEIR does not rely upon AB 205. The environmental analysis is conducted consistent with CEQA requirements.
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range of alternatives, minimizing scrutiny, and
biasing the
environmental review process.
47 Suzanne
Lyons
First, the E-Group project would likely not have
been approved under AB 205 because AB 205
does not cover projects deemed to have serious
environmental
impacts.
The E-Group site carries a constellation of serious
environmental risks that occur simultaneously
including: (1) the project is sited within City limits
(unlike the majority of industrial-scale solar plants
in CA), (2) the project is sited
within a crucial wildlife corridor that (3) also
happens to be an occupied desert tortoise habitat,
(4) the site is located in a windy location where (5)
prevailing wind direction means that winds would
blow from the site toward neighborhoods, roads,
and town, thus creating possible dust impacts, and
(6) the site is not in a flat (as E-Group initially
stated (Exhibit 2) location but one that is
undulating and sloped so that (7) the site would
require mass grading to an extreme extent (over
5000,0000 cubic yards cut and fill) and (8) grading
would not be on previously used soil but rather on
pristine desert soil where biological crust would
be disturbed, and (9) earthmoving also would
include grading of consolidated alluvial sediments
which are highly erodible by wind worsening dust
effects, and (10) the site is close to is
The environmental impacts discussed in the comment are addressed in the DEIR, which concludes that such impacts are less than significant. Projects evaluated through the AB 205 process can be approved despite having significant environmental impacts under CEQA. In fact, AB 205 contemplates that such projects may have a significant environmental impact, given that AB 205 requires preparation of an environmental impact report rather than a negative declaration.
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close to neighbors and quiet community spaces
(e.g. the Twentynine Palms Cemetery and Desert
Community Church, and (11) the site exists within
an alluvial fan system frequently exposed to flood
risks, and finally (12) public health risks including
respiratory disease exist due to the proximity of
the site due to population centers.
48 Suzanne
Lyons
Third, the E-Group project appears to NOT meet
the 50-MW ac generating capacity requirement.
The DEIR refers to the project as a “50 MW” solar
plant but its own facts and figures indicate the
project would only generate about 38
MW of ac power. Generating capacity (ac) equals
the number of inverters multiplied by the capacity
of each one. The DEIR tells us about 170 inverters
are planned each with a generating capacity of
225 kW so we see the E-Group would produce 170
x 225 = 38.2 MW (ac). Thus the E-Group project
would not meet the minimum generating capacity
of 50 MW (ac) under AB 205. The City has strong
reason to conclude that the AB 205 “ultimatum”
issued in a 2023letter from E-Group was based on
a false premise.
The DEIR refers to the project as a 50-MW plant
even though its own technical parameters do not
support this. It is understood that in some
applications, generating capacity can be expressed
as DC “nameplate” capacity. Nameplate
values are higher than ac values. Still, if E-Group
were to claim that its 50 MW designation is based
on “nameplate” or dc values, this does not change
To meet the requirements for AB 205, a facility must have a generating capacity of 50 megawatts. Cal. Pub. Util. Code § 25545(b)(1). “Generating capacity” is defined elsewhere under California regulations as the maximum gross rating of the facility minus the minimum auxiliary load or the total nameplate generating capacity. See 22 CCR § 2003(a), 17 CCR § 95112. The project has a generating capacity of 50 MW. See response to comment 15.
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the fact that the AB 205 threshold is 50 MW ac
and their project does not meet it. Thus, for this
reason, the project would never have been
approved under AB 205 and the project was never
inevitable under AB 205.
49 Suzanne
Lyons
In light of all of this, the FEIR must clearly explain
its internal inconsistency re the generating power
of the plant. If indeed AB 205 was never the
credible constraint that E-Group presented it as,
corrective steps are now needed to the public
record
to show that:
• the Project can be evaluated on its merits, not
under duress or assumed outcomes,
• alternatives and mitigation have not been
improperly constrained by a false dichotomy
between approval and loss of control.
• “inevitability framing” is cleansed from pubic
discourse. The public has been led to believe the
project is inevitable under AB 205, Exhibit 1. At
this point, public statements correcting the record
are necessary so the public and
decision-makers understand they can freely
decide whether or not this project is truly in the
public interest.
See responses to comments 46, 47, and 48.
50 Suzanne
Lyons
The Project proposes a large fixed-tilt solar array.
Fixed-tilt photovoltaic systems are especially
sensitive to low-angle sun conditions, particularly
during winter months when the sun remains close
to the horizon for much of the day. Even
See response to comment 33. E-Group conducted a staged, industrystandard energy yield assessment for the project. An initial solar resource and production estimate using SolarGIS—based on longterm satellite irradiance data and standard loss assumptions that indicated approximately 98 GWh per year of net generation. The analysis was subsequently refined using PVsyst, applying modeling methodologies consistent with NREL standards, including NSRDBPage 377 of 1008 1605879335.11
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modest terrain rises, berms, or regraded
landforms can materially reduce energy
production during these periods.
The Project site is located near the base of a rising
landform, where surrounding terrain slopes
upward away from the site. This setting raises a
fundamental
feasibility question: whether the site provides
adequate solar access throughout the year
without inducing design changes that would
increase environmental impacts.
Despite this, the DEIR provides:
• no horizon-profile analysis,
• no site-specific shading-loss modeling,
• no demonstration that grading and layout
assumptions are sufficient to avoid shading losses.
On irregular or toe-of-slope sites, developers
typically face three options:
1. Increase grading to create a uniform plane and
reduce row-to-row shading;
2. Increase panel or rack height to lift arrays
above local obstructions;
3. Accept reduced output or density, undermining
project economics and triggering redesign.
If the Project is to meet its stated capacity and
economic assumptions, the most likely outcome is
increased grading or taller structures. Either
response would directly affect:
aligned solar resource inputs, detailed electrical and thermal losses, and site-specific shading analysis based on array technology, layout, and geographic location. The PVsyst model resulted in an updated annual net energy estimate of approximately 101 GWh per year, demonstrating close alignment between independent modeling approaches. Using U.S. EPA conversion methodologies, this level of generation is equivalent to powering roughly 9,400 average U.S. households annually and would avoid approximately 40,000 metric tons of CO₂ emissions per year compared to conventional grid electricity.
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• dust generation,
• erosion and drainage behavior,
• visual prominence,
• biological disturbance.
The DEIR does not analyze these reasonably
foreseeable outcomes.
51 Suzanne
Lyons
Adjustments to tilt angle or racking height—often
used to compensate for suboptimal solar access—
can increase the apparent height and visibility of
the Project from nearby roads and residences. The
DEIR does not disclose maximum
panel heights, leading/trailing edge elevations, or
cross-sections showing the array relative to
existing landforms.
The projected height of racks and panels is discussed in the DEIR project description, including depictions therein. The height is also analyzed in the view study incorporated into the DEIR. If the height were to be significantly adjusted in a manner that would create a possibility of potential environmental impacts not evaluated in the DEIR, any such change would need to be evaluated through supplemental environmental review.
52 Suzanne
Lyons
No independent third-party technical review has
been conducted to verify that the Project can be
built as described without materially increasing
grading, height, or
footprint. Best practice for a project of this scale is independent feasibility analysis, particularly where
site constraints are evident.
See response to comment 35.
53 Suzanne
Lyons
The DEIR acknowledges the presence of nearby
residential receptors yet concludes that
operational noise impacts would be less than
significant, with or without mitigation. This
conclusion is not supported by a rigorous analysis
of all
reasonably foreseeable operational noise sources
associated with an industrial scale
solar facility.
See response to comment 19.
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Operational noise sources for this Project include,
but are not limited to:
• inverter banks distributed across the site,
• transformers and switchgear,
• communications and monitoring equipment,
• security and alarm systems,
• routine and emergency maintenance vehicles,
• night-time maintenance activities (expressly
contemplated by the DEIR).
A critical deficiency in the DEIR is the treatment of
inverters as isolated point sources, rather than as
a distributed field of multiple simultaneous
sources whose noise contributions accumulate
over distance. With the planned 170 inverters
operating concurrently, the cumulative sound
level at residential receptors would be materially
higher than what is predicted based on a singlesource model.
The idea is simply this: 170 inverters make more
noise than one, yet the sound estimate in the DEIR
is based on just one.
In addition, inverter noise often contains tonal or
low-frequency components (commonly perceived
as a hum or whine). Tonal noise is more
noticeable, more difficult to mask, and more likely
to cause annoyance and sleep
disturbance than broadband noise at the same
nominal decibel level. The DEIR does not disclose
whether tonal penalties were evaluated or
applied.
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54 Suzanne
Lyons
The DEIR states that maintenance activities would
occur at night. Nighttime operations substantially
change the impact analysis because:
• ambient background noise levels are lower,
• residents are more sensitive to disturbance,
• sleep disruption and stress-related health effects
become relevant.
Despite this, the DEIR does not analyze nightspecific operational noise levels, does not impose enforceable restrictions on the frequency or
duration of night
maintenance, and does not require postinstallation compliance testing under nighttime conditions.
As noted in the DEIR, maintenance is anticipated to occur only on an as-needed basis and infrequently (estimated to be twice per year).
Such infrequent noise is unlikely to result in a potentially significant temporary noise impact such as through the generation of noise in excess of established local standards for nighttime hours. In response to this comment, E-Group is willing to commit to not conducting maintenance at the project site at night, except as needed to address an emergency.
55 Suzanne
Lyons
The DEIR characterizes construction noise as
temporary and therefore less than significant.
CEQA does not allow this conclusion unless the
DEIR includes clear, enforceable limits on:
• construction hours,
• total construction duration,
• sequencing and phasing,
• maximum noise levels at sensitive receptors.
Absent such limits, “temporary” becomes an
indefinite condition rather than a mitigation. Large
solar projects often experience extended
construction periods due to supply-chain delays,
redesigns, and weather. Without enforceable
duration caps, the DEIR cannot assume short-term
exposure.
See responses to comments 19 and 20.
56 Suzanne
Lyons
Chronic noise exposure is associated with sleep
disturbance, stress, cardiovascular effects, and
See response to comment 21.
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reduced quality of life. These effects are
particularly relevant where residents are exposed
during nighttime hours. The DEIR does not
meaningfully address these health-related
considerations, despite acknowledging nearby
residential receptors.
57 Suzanne
Lyons
The FEIR must:
1. Provide cumulative operational noise modeling
that accounts for all inverters and associated
equipment operating simultaneously.
2. Evaluate and disclose tonal noise
characteristics and apply appropriate penalties
where applicable.
3. Model nighttime operational noise separately
from daytime conditions.
4. Require post-construction noise testing at the
nearest residential receptors (including my home),
with enforceable corrective actions if standards
are exceeded.
5. Impose enforceable limits on construction
hours, total duration, and
phasing, rather than relying on the
characterization of construction as “temporary.”
6. Establish clear daytime and nighttime noise
limits at residential property lines and identify the
mechanism for enforcement.
See responses to comments 19 and 54. See also DEIR Section 2.13.3 for a description of enforceable daytime and nighttime noise limits.
Post-construction noise testing is not required per local standards and is not proposed as the noise analysis presented in the DEIR determined that project operations would not result in a potentially significant noise impact.
58 Suzanne
Lyons
The Project involves extensive grading and
disturbance of intact desert soils. Desert soils in
this region are inherently wind-erodible, and the
Project site is located in an area that regularly
experiences strong winds. Fugitive dust
generation
Impacts associated with dust generation are addressed through compliance with MDAQMD Rule 403 concerning fugitive dust control, including compliance with its specific requirements for solar projects.
Specifically, and as described above in responses to comments 3, 12,23, and 61, the project would prepare and submit to MDAQMD a
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under these conditions is not speculative; it is a
foreseeable and recurring impact.
Dust impacts are of particular concern because:
• the Project site is near residences,
• dust can be transported long distances toward
town and commercial corridors,
• dust can reduce visibility on nearby roadways,
creating safety hazards,
• fine particulate matter (PM₁₀ and PM₂.₅) has
documented respiratory and cardiovascular health
effects.
Dust Control Plan and Mitigation Measure AES-1 would require revegetation of the site after construction activity.
59 Suzanne
Lyons
The DEIR relies heavily on compliance with
existing air district rules and generic best
management practices. While regulatory
compliance is necessary, it is not sufficient under
CEQA where site-specific conditions elevate risk.
Given the scale of grading, the wind regime, and
the proximity of receptors, the DEIR must include
project-specific, enforceable dust controls, rather
than deferring to future plans or discretionary
implementation.
See responses to comments 3 and 23.
Note that the City Development Code regulations proposed for the Renewable Energy zone also contain several conditions that must be included for the Project. These include:
The proposed commercial solar field will be designed, constructed, and operated so as to minimize dust generation, including provision of sufficient watering of excavated or graded soil during construction to prevent excessive dust.
Watering will occur at a minimum of three times daily on disturbed soil areas with active operations, unless dust is otherwise controlled by rainfall or use of a dust palliative, or other approved dust control measure.
All clearing, grading, earth moving, and excavation activities will cease during period of winds greater than 20 miles per hour (averaged over one hour), or when dust plumes of 20 percent or greater opacity impact public roads, occupied structures, or neighboring property.
For sites where the boundary of a new commercial solar field will be located within one-quarter mile of a primary
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residential structure, an adequate wind barrier will be provided to reduce potentially blowing dust in the direction of the residence during construction and ongoing operation of the commercial solar field.
Any unpaved roads and access ways will be treated and maintained with a dust palliative or graveled or treated by another approved dust control method to prevent excessive dust, and paving requirements will be applied pursuant to City standards.
On-site vehicle speed will be limited to 15 miles per hour. 60 Suzanne
Lyons
Construction-related truck traffic can:
• generate additional dust from disturbed
surfaces,
• track sediment onto paved roads,
• increase accident risk due to reduced visibility
and degraded road conditions.
The DEIR does not adequately analyze these
secondary dust and safety impacts or commit to
enforceable controls.
See response to comment 25.
61 Suzanne
Lyons
The FEIR must:
1. Require continuous or periodic PM₁₀/PM₂.₅
monitoring during grading and construction, with
publicly reportable results.
2. Establish wind-speed thresholds that trigger
mandatory work stoppage and stabilization
measures.
3. Require stabilization of inactive disturbed
areas using proven desert appropriate methods.
4. Mandate track-out controls, paved access
points, and routine roadway cleaning where
needed.
As discussed in the DEIR, the grading and earth moving activities proposed by the project would be required to comply with MDAQMD Rule 403. MDAQMD Rule 403 includes requirements for a Dust Control Plan, signage and fencing requirements, as well as surface watering and stabilization to eliminate visible fugitive dust from vehicular travel and wind erosion.
Furthermore, Rule 403 also requires activities to not cause fugitive dust from transport, handling, construction, or storage activities to remain visible in the atmosphere outside the emission source property. Fugitive dust emissions cannot exceed 100 µg/m³ (difference between upwind and downwind samples at the property line over at least five hours).
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5. Include enforceable complaint-response and
corrective-action protocols with clear timelines.
6. Analyze and mitigate visibility and road safety
impacts associated with dust generation.
Note that the City Development Code regulations proposed for the Renewable Energy zone also contain several conditions that must be included for the Project, including several of those recommended by the commenter. These include:
The proposed commercial solar field will be designed, constructed, and operated so as to minimize dust generation, including provision of sufficient watering of excavated or graded soil during construction to prevent excessive dust.
Watering will occur at a minimum of three times daily on disturbed soil areas with active operations, unless dust is otherwise controlled by rainfall or use of a dust palliative, or other approved dust control measure.
All clearing, grading, earth moving, and excavation activities will cease during period of winds greater than 20 miles per hour (averaged over one hour), or when dust plumes of 20 percent or greater opacity impact public roads, occupied structures, or neighboring property.
For sites where the boundary of a new commercial solar field will be located within one-quarter mile of a primary
residential structure, an adequate wind barrier will be provided to reduce potentially blowing dust in the direction of the residence during construction and ongoing operation of the commercial solar field.
Any unpaved roads and access ways will be treated and maintained with a dust palliative or graveled or treated by another approved dust control method to prevent excessive dust, and paving requirements will be applied pursuant to City standards.
On-site vehicle speed will be limited to 15 miles per hour. 62 Suzanne
Lyons
The DEIR acknowledges that portions of the site
contain drainage features and that bridges or
Correct. The DEIR includes a hydrology analysis, identifies site drainage, and incorporates both buffers and bridge design to avoid
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crossings would be used to avoid grading certain
gullies. This acknowledgment alone indicates that
the site is hydrologically active and that
natural flow paths are present.
such ephemeral streams that govern hydrologic connectivity through the project site.
63 Suzanne
Lyons
Large-scale grading, compaction, and the
installation of access roads and infrastructure can
significantly alter:
• runoff patterns,
• flow velocities,
• erosion and sediment transport,
• downstream deposition and flooding behavior.
See response to comment 13.
64 Suzanne
Lyons
The DEIR relies on future drainage studies, plans,
and permits to support conclusions of less-thansignificant impact. CEQA requires that the EIR itself disclose and analyze how drainage will
function post-project, not merely assert that
future compliance will occur.
Without detailed disclosure of:
• pre- and post-project flow patterns,
• capacity of crossings and conveyances,
• erosion control performance under extreme
events,
decision-makers cannot evaluate whether the
Project would increase flooding or erosion risks
on- or off-site.
The DEIR includes the analysis recommended in the comment and does not defer the analysis. The hydrologic and hydrology analysis, evaluating pre- and post-flow patterns, ephemeral stream capacity, and erosion is included in DEIR Appendixes D.2, H.1, and H.2 and discussed in DEIR pgs. 2.5-28-32 and 2.11-22-25.
65 Suzanne
Lyons
Drainage infrastructure requires ongoing
maintenance. Blockage, sediment accumulation,
and structural failure are foreseeable over a multidecade project life. The DEIR does not analyze:
• consequences of culvert or bridge failure,
• maintenance responsibilities and enforcement,
• extreme storm scenarios.
The DEIR analyzes extreme storm (100-year flood) scenarios. See the analysis described in response to comment 65. The bridges are engineered to withstand such conditions and failure of such bridges is not reasonably foreseeable. Because the bridges are on private property and are required to access areas of the project site, the project applicable would be both responsible and incentivized for proper management and upkeep.
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66 Suzanne
Lyons
The DEIR confirms that the Project site is located
within occupied Mojave desert tortoise habitat,
documenting active and semi-active burrows and
direct observations of individual tortoises. See
Exhibits 5-8 which are photos of tortoises taken in
2024 to get a sense of the tortoises who call the
vicinity of the project home, The DEIR further
acknowledges that the Project would result in the
permanent loss of approximately 142 acres of
suitable habitat, with additional temporary
disturbance.
This is not a speculative or marginal impact.
Permanent loss of occupied habitat for a
federally and state-listed species is, by definition,
a severe and irreversible impact. Yet the DEIR
characterizes this impact as less than significant
with mitigation. The proposed mitigation is
inadequate, not only because translocation is
difficult under the most careful protocols but also
because the mitigation is not commensurate with
the loss of ecological function at this specific
location.
The DEIR appropriately identifies impacts to desert tortoise as potentially significant, incorporates appropriate mitigation subject to review and approval by USFWS and CDFW, and concludes that the impact is less than significant upon incorporation of mitigation. The mitigation proposed is consistent with the General Conservation Plan for Mojave Desert Tortoise recently approved and adopted by USFWS in 2025. See Exhibit 4.
In addition, E-Group has submitted an Incidental Take Permit application to CDFW (see Exhibit 3), which is currently under review.
The specific determination of take authorization, compensatory mitigation requirements, and permit conditions under Endangered Species Act and California Endangered Species Act is the responsibility of the USFWS and the CDFW, respectively. Consistent with CEQA Guidelines Sections 15126.4(a)(1)(B) and 15126.4(a)(1)(D), the DEIR appropriately commits the project to obtaining all required permits and to implementing compensatory mitigation as required by the applicable resource agencies. The mitigation measures, ratios, and implementation details will be developed and approved through the formal consultation and permitting processes with USFWS and CDFW in compliance with state and federal requirements.
Also see response to comment 27.
67 Suzanne
Lyons
The Project site lies within a fragmented but still
functioning wildlife corridor connecting larger
habitat areas, including lands associated with
Joshua Tree National Park and the Marine Corps
Air Ground Combat Center. This
corridor has already been compromised by roads,
development, and infrastructure, making
remaining connective areas increasingly
important.
See response to comment 28.
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The Project proposes permanent exclusion
fencing and security fencing that would remain in
place for the life of the facility, explicitly excluding wildlife from the site. While exclusion fencing may
reduce direct take within the fence line, it also:
• permanently removes habitat from use,
• creates a long-term barrier to movement,
• increases edge effects and predation risk,
• and contributes to cumulative corridor
fragmentation.
The DEIR does not provide a corridor-scale
analysis of how this Project interacts with existing
and reasonably foreseeable development in the
area, nor does it evaluate whether remaining
movement pathways would be functionally viable
after Project implementation.
68 Suzanne
Lyons
The DEIR relies on a minimum 1:1 compensatory
mitigation ratio, typically satisfied through off-site
land acquisition or mitigation bank credits. This
approach treats habitat as interchangeable
acreage rather than as a functioning component
of a specific landscape system.
In a corridor setting, the ecological value of
habitat is not defined solely by size, but by:
• location,
• connectivity,
• permeability,
• and relationship to adjacent land uses.
E-Group agrees with this comment. The factors identified in the comment are some of the factors considered by CDFW and USFWS in approving a suitable mitigation site as part of approval of an Incidental Take Permit.
E-Group has submitted an Incidental Take Permit application to CDFW (see Exhibit 3), which is currently under review. Additionally, EGroup been in consultation with USFWS regarding project impacts to desert tortoise habitat and related issuance of an Incidental Take Permit through the USFWS General Conservation Plan for the Desert Tortoise in California.
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Off-site mitigation cannot replace the movement,
dispersal, and connectivity functions lost at this
location unless it is functionally equivalent and
geographically relevant. The DEIR does not
demonstrate that such equivalency would be
achieved.
69 Suzanne
Lyons
The DEIR includes survey results that were
conducted during periods when desert tortoise
detectability is reduced. Also, allowing clearance
or linear-feature surveys “at any time of year”
further increases the risk of under-detection.
Underestimating baseline occupancy undermines:
• impact assessment,
• mitigation design,
• and confidence in avoidance and minimization
measures.
CEQA requires that baseline conditions be
established using the best available science,
particularly where listed species are concerned.
Mojave desert tortoise surveys were conducted from May 6-9, 2025 (DEIR, Table 2.5-1). As described in DEIR Appendix D.5, these surveys were completed in accordance with the USFWS 2018 Mojave Desert Tortoise Survey Protocol, which identifies April to May and September to October as periods when desert tortoises are typically most active and detectable. Accordingly, the May 2025 protocol-level surveys were conducted within a seasonally appropriate survey window consistent with the best available science and agencyapproved methodology and provided optimal detection and baseline conditions.
In addition to the May 2025 surveys, a prior protocol-level Mojave desert tortoise survey was conducted in December 2023, and incidental desert tortoise individuals and/or sign were documented and mapped during other biological field investigations conducted in 2023 and 2024 (DEIR Appendix D.5). While seasonal activity levels may vary, the combination of protocol-level surveys and incidental observations conducted over multiple years provides a reasonable and conservative characterization of baseline conditions for the project area.
As described in DEIR Appendix D.5, Section 6.3.1.2.1, even though neither tortoises nor tortoise sign were found within some portions of the Biological Study Area at the time of the survey, the area may reasonably be part of tortoise’s home range. The annual home range
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of a female desert tortoise averages around 35 to 40 acres, about one third the size of male home ranges, which are variable, and a home range of a male desert tortoise can be greater than 500 acres (USFWS 2009). Given the homogeneity of the vegetative and topographic resources, desert tortoises would be expected to have potential to occupy the entire site. Therefore, the DEIR conservatively evaluated the impacts to desert tortoise habitat accordingly.
Any authorized take and compensatory mitigation would be determined through formal consultation and permitting with the USFWS and the CDFW, which ensures that mitigation requirements are adequate with confirmed impacts.
Also see response to comment 66.
70 Suzanne
Lyons
Beyond direct habitat loss, the Project would
generate indirect impacts that degrade adjacent
habitat over time, including:
• chronic dust deposition,
• altered drainage patterns,
• invasive plant introduction,
• increased human activity and noise,
• artificial lighting and edge effects.
The DEIR addresses these impacts in a piecemeal
fashion and does not evaluate their combined,
long-term effect on habitat quality or corridor
function.
Both the direct and indirect biological impacts of the project are evaluated in DEIR Section 2.5. As noted in the DEIR, the project includes a revegetation plan, as required by Mitigation Measure AES1, which is expected to eliminate long-term dust deposition. AES-1 requires planting of appropriate native vegetation, which will eliminate concerns regarding establishment of invasive plants. See responses to comments 13 and 64 concerning impacts to drainage patterns. As noted on DEIR pg. 2.3-20, the project does not propose artificial lighting.
71 Suzanne
Lyons
The DEIR acknowledges that the Project would
result in significant and unavoidable aesthetic
impacts that cannot be fully mitigated. This
concession alone is sufficient to warrant serious
reconsideration of the Project’s suitability for this
As noted in the comment, the DEIR acknowledges that the changes to the visual character of the project site represent a significant and unavoidable impact. However, it also notes that the project will not significantly impact public views and vistas, including from most (but not all) residences. See DEIR Section 2-3.
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location and, ultimately, halt the project at this
stage.
Unfortunately, although the DEIR acknowledges
the significance and unavoidability aesthetic
impacts, it understates the contextual importance
of them. It treats aesthetic impacts as isolated
visual effects rather than as a
transformation of community character and
gateway experience.
The Project would introduce a large industrial
facility into an area characterized
by:
• low-density residential use,
• open desert views,
• and a transitional gateway landscape leading
toward Joshua Tree National Park.
This transformation is permanent. Once graded,
fenced, and industrialized, the landscape cannot
be restored to its prior character, even if the
facility is later removed.
72 Suzanne
Lyons
As discussed earlier, feasibility constraints related
to solar access may require:
• additional grading,
• increased panel height,
• or reconfigured layouts.
Any of these responses would increase visual
prominence and further degrade scenic quality.
The DEIR does not analyze these reasonably
foreseeable outcomes.
See response to comment 33.
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73 Suzanne
Lyons
The FEIR must:
1. Provide visual simulations from actual sensitive
receptor locations, including nearby homes (such
as mine), hotels along Highway 62, and roadways.
2. Analyze worst-case panel height and grading
scenarios rather than optimistic conceptual
layouts.
3. Evaluate nighttime visual conditions, including
vehicle lights, security lighting, and maintenance
activity.
4. Explicitly weigh the Project’s permanent visual
change against the City’s stated goals for
community character and gateway identity.
The DEIR includes visual simulations from Two Mile Road (which includes views of residences south of Two Mile Road), Desert Congregational Church, and homes east of the project site. As noted above, the project is estimated to require maintenance twice per year and does not propose artificial lighting. Land use compatibility is evaluated in Section 2.12.
74 Suzanne
Lyons
Twentynine Palms functions as a gateway
community to Joshua Tree National Park. Its
economic vitality is closely tied to:
• scenic quality,
• quiet desert character,
• and visitor perception of safety, cleanliness, and
authenticity.
The DEIR does not meaningfully evaluate how
permanent visual industrialization, increased dust,
or degraded travel corridors could affect visitor
behavior, length of stay, or regional reputation.
Note that industrial-scale solar power plants are
rare in California City limits precisely because they
are generally considered impactful visually as well
as other reasons. An large-scale industrial solar
power plant does
not evoke associations of an ecologically oriented
“green” economy. Placed in town and near
See response to comment 39.
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neighbors, towns, and roadways the plant looms
as an example of irresponsible, inappropriate solar
development. Dig a little deeper into the strange
sight, and visitors will learn that the site was
placed in a crucial wildlife corridor where it
destroyed occupied desert tortoise habitat. The EGroup plant would be largely perceived as a sad, cautionary tale rather
than a hopeful sign of clean energy.
75 Suzanne
Lyons
Industrial facilities located near residences
commonly affect:
• property values,
• marketability,
• and long-term residential stability.
The DEIR does not analyze whether nearby
homeowners would experience diminished
property values or whether the City could face
indirect fiscal consequences as a result.
Economic impacts, including but not limited to alleged reductions in property values, are outside the scope of CEQA.
76 Suzanne
Lyons
The DEIR references community benefits and
annual payments to the City, but it does not
provide a net fiscal analysis that accounts for:
• staff time and administrative oversight,
• enforcement and compliance monitoring,
• infrastructure wear,
• emergency response readiness,
• potential legal exposure.
The modest annual payment of $100,000 per year
may not offset even a single additional public
safety or enforcement obligation.
Pursuant to the City’s regulations, E-Group has reimbursed City staff and consultants for its costs in processing the project applications.
Because the project is a private project, E-Group is responsible for wear and tear and maintenance to its infrastructure. Pursuant to both the development agreement and City regulations, E-Group is required to indemnify the City for its legal costs associated with defending challenges to the project. Note that the economic benefits of the project are understated in the comment – for most of the project lifespan, E-Group will contribute $150,000 annually, adjusted for CPI.
The City Council previously unanimously supported the proposed public benefits package at a public workshop held in 2025. 77 Suzanne
Lyons
The DEIR references “community benefits”
associated with the Project but does not disclose a
community benefits package developed through
The public benefits are not intended to mitigate the impacts discussed in the comment, which were determined to be less than significant in the DEIR or less than significant based upon mitigation
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meaningful consultation with affected community
groups, as contemplated in AB 205-style
community engagement frameworks. Instead, the
only clearly articulated benefit appears to be an
annual payment of approximately $100,000 to
the City’s General Fund, with no defined
programmatic purpose, no dedicated recipients,
and no enforceable commitments tied to the
Project’s localized impacts.
From a fiscal and CEQA perspective, this raises
concerns because an unrestricted general-fund
payment does not establish a nexus to the
Project’s specific burdens on nearby residents and
City resources, including dust, noise, visual
degradation, habitat loss, road safety, and longterm monitoring and enforcement obligations.
The DEIR does not compare this payment against
foreseeable City costs or disclose whether the
payment would be indexed, secured, or binding
on successor
owners/operators over the Project’s life. Without
this information, decision-makers cannot evaluate
whether the Project represents a net fiscal benefit
or a net fiscal liability to the City.
identified separately in the DEIR. See response to comment 76 for additional response.
78 Suzanne
Lyons
The DEIR states that the Project would have an
operational life of approximately 35 years and that
the Applicant would be responsible for removing
facilities and restoring the site at the end of
operations. These statements are aspirational,
not enforceable mitigation.
Decommissioning is required and enforceable pursuant to the City’s proposed energy zone regulations. See Section 19.23.040(19). This includes the standards for the decommissioning plan.
Decommissioning is not relied upon as mitigation for any potentially significant impact identified in the DEIR and the impacts associated with decommissioning, as well as mitigation with such activities, is
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The DEIR does not include:
• a detailed decommissioning plan,
• a cost estimate based on realistic removal and
restoration requirements,
• or any secured financial assurance guaranteeing
that decommissioning would occur even if the
Project owner becomes insolvent, abandons the
Project, or transfers ownership.
CEQA requires that mitigation measures be fully
enforceable and financially feasible. Without
secured assurances, the City risks inheriting
degraded land, abandoned infrastructure, and
long-term dust and erosion hazards.
thoroughly described in the DEIR. See DEIR, pgs.1-6, 2.5-26-27, Mitigation Measures BIO-1, BIO-2, BIO-3, and BIO-10.
79 Suzanne
Lyons
The DEIR assumes a fully built and fully
operational facility for 35 years. It does not
analyze scenarios in which:
• grading occurs but construction stalls,
• the Project becomes economically unviable,
• ownership changes before completion,
• or portions of the site are abandoned.
These scenarios are not speculative. They are
foreseeable risks, particularly where large capital
investments are proposed by an entity structured
primarily as a developer/investor. CEQA requires
disclosure of reasonably foreseeable
consequences, including failure modes.
As noted above, the applicant would be required to enter into a decommissioning plan as part of project approvals. The circumstances discussed in the project would result in less environmental impacts than those discussed in the DEIR and therefore do not need to be discussed separately.
80 Suzanne
Lyons
Across multiple resource areas, the DEIR relies on
language such as:
• “as determined by the qualified biologist,”
• “as needed,”
• “to the satisfaction of the City,”
• “prior to issuance of permits.”
The language in the mitigation measures is sufficiently defined and enforceable. The language is based on similar conditions that have been upheld in court for similar projects. It is common for certain plans to be approved subsequent to CEQA review but prior to the commencement of project construction or operation. The timing for
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This type of discretionary language effectively
delegates environmental decisionmaking to
applicant-retained consultants and postpones
critical determinations until after CEQA review is
complete.
CEQA does not allow mitigation to consist of
undefined future decisions without objective
standards. Such deferral undermines
enforceability and public accountability.
such approvals is further defined in the Mitigation Monitoring and Reporting Program (“MMRP”).
81 Suzanne
Lyons
Publicly available information suggests the
Applicant functions primarily as a
developer/investor relying on subcontracted
technical teams, and that ownership or
operational control of the Project may change
over time. This increases the importance of:
• mitigation measures that run with the land,
• clear identification of responsible parties,
• secured funding mechanisms,
• and City enforcement authority that does not
depend on voluntary compliance.
Mitigation measures that are effective only if a
particular company remains involved are
inadequate under CEQA.
The DEIR is an environmental review of the effects of the project and is not specific to the project applicant. The MMRP provides additional detail as to which party is responsible for mitigation. The City enforces both the mitigation measures and conditions of approval under its permitting authority incorporated into the permits themselves and the City’s general zoning enforcement authority. 82 Suzanne
Lyons
The DEIR evaluates a limited set of alternatives,
including No Project and a reduced-intensity
variant. These alternatives do not meaningfully
avoid or reduce the Project’s most significant
impacts, including:
• industrial land-use incompatibility,
• permanent loss of occupied habitat,
• corridor fragmentation,
As noted elsewhere, most of the impacts identified in the comment were determined to be less than significant in the DEIR. As noted on DEIR pg. 3-4, an alternative site location was considered but the alternative site would not significantly lessen the aesthetic or visual impacts of the project.
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• dust generation,
• and irreversible aesthetic degradation.
An alternatives analysis that merely adjusts
project scale while preserving the same
fundamental conflicts does not satisfy CEQA’s
requirement to explore feasible means of
avoiding or substantially lessening significant
effects.
83 Suzanne
Lyons
The DEIR does not meaningfully evaluate:
• siting the Project on previously disturbed or
industrial land,
• locations farther from residences and sensitive
receptors,
• or configurations that maximize avoidance of
key biological and visual resources.
Economic or interconnection convenience alone is
not sufficient justification for rejecting less
damaging alternatives.
At the request of City Council, E-Group evaluated a potential alternative site located on the eastern side of Twentynine Palms immediately adjacent to existing industrial areas. Upon review, the analysis concluded that it would not avoid significant impacts to visual and aesthetic resources and would increase views of the project from Joshua Tree National Park and Tribal lands. It was also considered operationally infeasible given the amount of shading and limited irradiation on the site. Finally, such a location would require that the gen-tie line run through numerous residential properties to connect to a substation, which was concluded to be both infeasible and a significant additional impact to residential properties. See Exhibit 5. Further, the City of Twentynine Palms has limited industrial zones and E-Group is unaware of any vacant industrial parcels that would be of sufficient size for a utility scale solar project that would not suffer the same limitations and concerns as the site studied previously. Note that the project was relocated farther north as compared to the originally proposed location to reduce impacts to residential properties south of Two Mile Road.
84 Morongo
Basin
Conservati
on Ass’n
According to the Solar Industries Association
“Depending on the specific technology, a utilityscale solar power plant may require between 5 and 10 acres per megawatt (MW) of generating
capacity.”
See response to comment 15.
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• Using these numbers, the proposed 184-acre
solar array will produce, at the most, 36.8 MW of
solar power. At the E-Group public meeting we
were assured the Project would produce 50 MW
of solar energy. This proposed productivity must
be verified.
In the E-Group presentation to interested
community members, Mr. Smith (project
representative) stated that ‘…if the City was not
interested in permitting the solar project the
developer would utilize AB 205, although that was
not their first choice. ‘
• AB 205 requires the solar project to have a
generating capacity of 50 MW or more (see
above) and an energy storage system capable of
storing 200 megawatt hours or more of electricity.
Does the E-Group solar project meet the AB 205
requirements?
85 Morongo
Basin
Conservati
on Ass’n
When analyzing the impacts and possible
mitigation measures please do not consider the
use of “native desert plants” that are greener or
taller that the surrounding creosote, as was
suggested by the developer during his meeting
with community members.
Comment noted. Recommended plantings have been developed since that comment and are incorporated into the Habitat Restoration Plan incorporated in Appendix D.3 of the DEIR. 86 Morongo
Basin
Conservati
on Ass’n
When analyzing for glare please note this glare in
Biological Resources d) since the glare has the
potential to interfere with migrating birds
mistaking the area as a body of water. The panels
are at a fixed 21-degree angle, facing south but
could confuse the shorebirds, ducks, herons, and
egrets flying north.
The so-called “lake effect” and glare impacts to birds are addressed in the DEIR. See DEIR pgs. 2.5-24.
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Please review Cornell University eBird Hotspot for
Barker Dam in Joshua Tree National Park3 is due
south of the E-Group project. This is a new danger
for water birds and is cumulative with Cascade
solar (150 acres) in Joshua Tree, and SEPV2 and
SEPV8 on Lear Rd. (120 acres), and SEPV9 on
Indian Trail (80 acres). And see the pdf attached to
the email Why Do Birds Crash Into Solar Panels.
87 Morongo
Basin
Conservati
on Ass’n
Downwind receptors living in the Morongo Basin
east of Joshua Tree solar projects have
considerable experience with the dust from the
Cascade Solar Project on 150 acres in Joshua Tree;
and SEPV2 and SEPV8 built together on 120 acres
on Lear Avenue and SWPV9 on 80 acres on Indian
Trail in 29 Palms. All three project sites and the
proposed E-Group Project are on a Sand Transport
Path in the Mojave Desert described in Zimbelman
et.al Sand Transport Paths in the Mojave Desert.
Within the Green Circle Dust sources include
Cascade Solar,
SEPV 2, SEPV8, and SEPV9 Solar facilities on a total
of 350 acres and includes the proposed E-Group
PS project.
Active Sand Sources – red circles Emerson Dry
Lake and Dale Dry Lake in the Morongo Basin.
See responses to comments 12, 23 and 61. A key difference between the solar projects listed in the comment and the proposed project is that E-Group has committed to a Habitat Restoration Plan to restore native vegetation on the project site after construction, which would reduce long-term and operational dust impacts associated with the project. See Mitigation Measure AES-1 and DEIR Appendix D.3. 88 Morongo
Basin
Conservati
on Ass’n
The Mojave Desert Air Quality Management
District (MDAQMD) bases their analysis on
readings from ambient air monitors. The map on
the MDAQMD website, March 28, 2024, shows no
monitors east of Lucerne Valley. They also have
located Purple Air Monitors throughout their
The last date of measurements from the Twentynine Palms - Adobe Road Air Quality Monitoring Station was recorded in 2005. Therefore, the statement from the Initial Study that “The nearest monitoring station to the Project is located on Adobe Road, east of the Project site” is incorrect and is not incorporated into the DEIR. See DEIR, pgs.
2.4-12-13. As presented on CARB’s website and the DEIR, the closest
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district. The Purple Air monitors default is PM2.5.
There are 2 Purple Air monitors located east of the
proposed E-Group.
Project. One is in Desert Heights5 and the other in
Indian Cove. The Initial Study states “The nearest
monitoring station to the Project is located on
Adobe Road, east of
the Project site.” (page 20). Please clarify. If such a monitor exists, the measurements are not visible
to the public so are not useful.
air monitoring station to the project site is the Joshua Tree-National Monument station, located approximately 17 miles to the southwest, near Black Rock Canyon Campground. Notably, this location only records 8-Hour and Hourly ozone measurements. The Lucerne ValleyMiddle School station, also located west of the project site, only records PM10 concentrations. The closest air monitoring station which records PM2.5 concentrations is the Victorville-14306 Park Avenue station.
89 Morongo
Basin
Conservati
on Ass’n
In reality, if the Project is approved then all
downwind residents in Twentynine Palms and
Wonder Valley will suffer the results until
measures are taken to stop the soil erosion.
Downwind residents (all with lungs are literally the
“sensitive receptors” to be protected) of Cascade
Solar and Lear Ave. Solar have continually suffered
from substantial fugitive dust, PM10 and PM2.5,
both inside and outside their homes after the land
was cleared for the solar projects. See Figures 3
and 4. The 9 years between 2014 and 2025 show
no improvement This commenter is one of those
downwind residents. The undescribed long-term
impact from soil disturbance is fugitive dust
blowing for the project duration, operation, and
following the Project’s closure. There is always the
promise within Project Final EIRs to return the
area to its original condition but the desert is not
dealt with so easily. It will take hundreds to
thousands of years for the desert to return to its
original functioning condition if ever with our
changing climate. To those reading this letter –
See responses to comments 12 and 23. One key difference between the proposed project and the solar farms cited in the comment is that the project will incorporate a habitat restoration plan upon completion of construction to expedite habitat restoration and reduce fugitive dust impacts. See Mitigation Measure AES-1.
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take a drive and look at the condition of the
ground at the existing solar plants now, following
the 9 years since clearing.
When alerted to dust blowing, the MDAQMD will
require watering the soil several times a day.
Water, a scarce commodity (ask the TPWD)
doesn’t work but for a short while and who will
water after the project is in operation and
following its 30 year life span?
90 Morongo
Basin
Conservati
on Ass’n
The Great Basin Air Pollution Control District has
dust control mitigation plans based on research on
the dry Owens Lake--4 inches of crushed gravel
screened to a size greater than 3/8th inch in
diameter over a permanent permeable geotextile
fabric.7
Deposition of crushed gravel across the site would impede efforts to revegetate the site and would adversely impact utilization of the site by animals and other biological resources. Further, it would make it impossible to return the project site to its previous state upon decommissioning.
91 Morongo
Basin
Conservati
on Ass’n
Please add to the sources used when analyzing the
Biological Resources and Greenhouse Gas
Emissions
Elements the scholarly report California Desert’s
Role in 30X30 Carbon Sequestration and
Biodiversity.8
This report was presented to the California
Natural Resources Agency [CNRA], California Air
Resources
Board [CARB], and California Department of Food
and Agriculture [CDFA] on the importance of
desert carbon sequestration as part of the State’s
AB 1757’s commitment to reaching our state’s
broad climate change goals.
From the Executive Summary
As presented on page 2.9-20 of the DEIR, the GHG assessment did include a qualitative carbon sequestration discussion. GHG emissions associated with impacts of removing existing vegetation prior to replanting of converting the site’s natural desert vegetation to a solar field and future residences was not quantified due to the complex, variable, and site-specific factors that govern carbon sequestration and accumulation. Overall, annual CO2e emissions from the construction and operation of the Solar Project, the Solar Project’s CO2e emissions reduction, and buildout of the Residential GPA acreage would result in a net reduction of 12,916 MT CO2e. Given this decrease, not quantifying the impacts related to the loss of sequestered carbon (release of CO2) due to construction activities would not significantly alter the conclusions of the DEIR.
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“ …One of the most persistent
mischaracterizations is that the California desert is
a barren wasteland with low biodiversity and
limited capacity for carbon storage. Scientific data
refutes these inaccuracies, and this report will
demonstrate that the California desert has
extremely high biodiversity and is a significant
carbon sink with tremendous opportunity to
sequester carbon and help our state meet is
atmospheric carbon reduction goals.
There are 2 key takeaway messages from this
report:
1. The desert’s carbon storage process differs
significantly from more widely understood
sectors such as forests, grasslands, chaparral, and
wetlands.
2. Because of the distinct carbon storge process
found in the desert ecosystem, there is one
recommended strategy to maximize the desert
sector’s contribution to carbon emission
reduction: Intact desert lands need to be left
undisturbed.
92 CDFW The DEIR does not identify and analyze reasonable alternatives that would meet all stated Project
objectives while also minimizing potentially
significant Project impacts to hydrology and
biological resources associated with grading.
The DEIR states that one of the Project’s
objectives is to “d[D]evelop a project which limits
the impact on the land by allowing
E-Group investigated opportunities to reduce grading on the project site as recommended by the commenter. First, the proposed alternative would not result in a reduction or elimination of any identified significant and unavoidable impacts. The DEIR identifies changes to the visual character and views of the project site as the only significant and unavoidable impact associated with the project.
Reducing grading would not substantially reduce or eliminate such impacts. The DEIR includes a reduced density alternative, which
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renaturalization of the property once the project’s
operations have ended.” (DEIR, p. ES-4) As
proposed, the current project does not fully meet
the DEIR’s stated Project objectives and requires
extensive grading of approximately 140 acres of
land with approximately 264,000 cubic yards of
cut and fill. Presently, the DEIR identifies three
project alternatives: Alternative 1, No
Project/Construction; Alternative 2 No
Project/Existing General Plan; and Alternative 3,
Reduced Project Intensity.
An EIR need not examine all possible alternatives;
rather the necessary analysis is guided by the ‘rule
of reason’ and whether an alternative exists that
feasibly meets project objectives.2 The DEIR does
not identify an alternative that includes a terrainfollowing solar panel arrangement that would allow for greater ability for the solar facility to
utilize the existing terrain, thereby reducing both
the grading necessary to fulfill the remaining
Project objectives and associated impacts to
hydrology and biological resources.
Traditional construction methods for solar fields
require extensive grading to uniformly level the
construction site. Terrain-following solar
arrangements better conform with existing
terrain, often reduce project grading costs,
minimize habitat disturbance, facilitate habitat
recovery, minimize changes in hydrology, and
potentially reduce erosion issues.
would include reduced grading. The analysis of that alternative would be similar to a reduced grading alternative.
Second, compared to the proposed project, the terrain following solar panel arrangement alternative identified by the commenter may result in increased erosion potential. Compared to the project’s approach to grading (i.e., modifying existing terrain to develop relatively level building surfaces and maximizing onsite development of utility -scale renewable energy), partial retainment (or minimization) of onsite slopes/ topography) may result in higher velocity runoff from rain events. During such events, higher velocity flows could conceivably be directed to onsite channels that in turn could result in increased erosion and channel scour potential.
Third, the proposed grading is required to comply with San Bernardino County Fire Protection District access standards. The District requires that no fire access roads exceed a 12% grade. See Exhibit 6. As noted in the DEIR project description, the project includes multiple fire access roads throughout the project site to provide maintenance and fire access. The proposed grading of the project site is required to provide adequate fire access in compliance with County standards.
One of the reasons that E-Group selected a fixed panel design as compared to a more traditional tracker design was to reduce grading to the greatest extent feasible during project design.
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The DEIR should include and analyze a Project
alternative incorporating terrain-following
construction methods that meet Project
objectives while minimizing Project related
impacts. Grading of the Project site should be
optimized to meet Project objectives, reduce
potentially significant impacts to biological
resources and their habitats, reduce soil
disturbances, and changes in hydrology.
93 CDFW The DEIR discusses the “renaturalization” and
“revegetation” of the disturbed project areas
without defining specific and enforceable
mitigation measures with achievable success
criteria.
MM-BIO-1 of the DEIR suggests that the project
site would be allowed to "re-naturalize" as a
mitigation measure without defining what renaturalize means in the context of the DEIR. Per CEQA Guidelines 15126.4, mitigation measures
should be specific and enforceable so that the
DEIR can adequately analyze, disclose, and
mitigate significant project impacts.
Although the DEIR does not explicitly define the
objectives for facilitating the 're-naturalization' of
the site, it can be reasonably inferred by the
reader that the intent is to revegetate native
habitats as evidenced in BIO-1 which states
"…suitable habitat for special-status species (i.e.,
all undeveloped land or re-naturalized land within
As noted by the commenter, the DEIR incorporates Mitigation Measure AES-1, which requires implementation of the prepared Habitat Restoration Plan, incorporated in DEIR Appendix D.3, after completion of construction. The Habitat Restoration Plan includes specific details concerning the proposed “renaturalization” of the project site, including the objectives of the plan and appropriate native plant species and methodology for replanting efforts. See Restoration Plan Sections 3 through 5.
The primary objectives of the Habitat Restoration Plan are to replant native vegetation to address long-term and operational dust impacts as well as provide some mitigation for aesthetic impacts. While it is anticipated to provide some biological benefit, the Habitat Mitigation Plan is not relied upon in the DEIR for mitigation of potentially adverse biological impacts.
As identified in the Habitat Restoration Plan, the plant species proposed for restoration seeding were selected based on likelihood of success in modified/impacted terrain and soils and to provide as similar to vegetative diversity and structure as possible when
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the project site) with potential to occur in the
project…" and, "i[I]n order to reduce the severity
of these impacts, mitigation measures AES-1 and
AES-2 have been developed, which would allow
for the restoration of the native plant
environment surrounding the solar panels to the
extent possible." (DEIR p. 4-2) Additionally, DEIR
section 2.8 states that “o[O]nce operational, the
Solar Project will be revegetated (see Section 2.5,
Biological Resources), and storm flows will sheet
flow across the site and in existing drainage
channels. The revegetation will mimic the current
native condition and control erosion from storm
water across the site.” (DEIR, p. 2.8-17) However,
the DEIR does not analyze the post-Project site’s
ability to support revegetation efforts (e.g., renaturalize) given the extensive changes in topography associated with project grading
rendering the mitigation measure potentially
unenforceable and perhaps unachievable.
Furthermore, the DEIR does not define renaturalization or revegetation, nor does it identify success criteria associated with these concepts.
The grading of approximately 140 acres will
significantly alter the drainage patterns, soil
distribution, natural sediment and nutrient
transport processes, and may result in projectrelated soil compaction, reduced localized biodiversity, and the permanent loss or alteration
of complex micro terrain, microhabitats. These
compared to the native vegetation found in the existing vegetation communities on the project site.
Note that incorporation of Mitigation Measure BIO-10 further reduces and mitigates impacts associated with removal of native vegetation. In compliance with San Bernardino and City requirements concerning desert plant removal, it requires the removal, salvaging, and relocation of existing desert plants prior to grading activities.
When combined with Mitigation Measure AES-1, this would result in a net increase in desert plants within the project site and local area as compared to existing conditions.
Concerning alteration of drainage patterns, see Comment 13. The hydrology and hydraulic study incorporated into the DEIR thoroughly evaluated drainage and hydrologic impacts and concluded that the project would not impact drainage on the site.
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impacts may individually and collectively influence
the success or failure of revegetation attempts.
94 CDFW Alternative construction methods exist that allow greater conformity with existing terrain (see
comment above). These technologies may
significantly reduce the Project's grading needs.
The DEIR should minimize grading; where grading
cannot be avoided, the DEIR should include
specific and enforceable performance objectives
related to re-naturalization/revegetation (e.g.,
percent native cover, percent non-native cover,
minimum diversity criteria, cessation of
supplemental watering, etc.) and require a habitat
restoration plan for City and CDFW approval.
Note that the proposed habitat restoration plan is not proposed, and is not required, to mitigate biological impacts. Therefore, success criteria are not required to reduce any significant impacts identified in the DEIR.
In response to this comment, E-Group has updated the Habitat Restoration Plan to include success criteria and performance goals (including native plant species cover compared to Reference Site and Maximum percent total non-native cover) and qualitative and quantitative monitoring for a duration of five (5) years postconstruction. Regarding irrigation, the restoration program provided in the Habitat Restoration Plan consists of a seeding and weed control program only. No container planting, or whole plant salvage, will occur or is included in the Habitat Restoration Plan. As a result, an irrigation program is not required or included. The updated Habitat Restoration Plan will be submitted to the City prior to circulation of the Final EIR incorporating these changes.
95 CDFW Plans for re-naturalization and revegetation
(restoration) should be prepared by persons with
expertise in southern California ecosystems and
native plant restoration techniques. Plans should
identify the assumptions used to develop the
proposed restoration strategy. Each plan should
include, at a minimum: (a) the location of
restoration sites and assessment of appropriate
reference sites; (b) the plant species to be used,
sources of local propagules, container sizes, and
seeding rates; (c) a schematic depicting the
mitigation area; (d) a local seed and cuttings and
planting schedule; (e) a description of the
The Habitat Restoration Plan has been prepared by qualified experts/habitat restoration specialists with appropriate expertise in the development of restoration plans in desert environments. The Plan includes the restoration sites, the plant species to be used and source of vegetative material, the seeding and planting schedule, intent to utilize a reference site to determine progress of restoration activities, and an acknowledgement that the restoration approach does not include regular irrigation/supplemental watering.
Furthermore, the Habitat Restoration Plan identifies the native seed application process (see Section 6.3), weed and pest control measures (see Section 7.1.1), and general site maintenance (see Section 7.1.2). Seed collection is also discussed (see Section 5.3.1), as are vegetation communities and land covers present and mapped in
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irrigation methodology; (f) measures to control
exotic vegetation on site; (g) specific success
criteria; (h) a detailed monitoring program; (i)
contingency measures should the success criteria
not be met; and (j) identification of the party
responsible for meeting the success criteria and
providing for conservation of the mitigation site in
perpetuity. Monitoring of restoration areas should
extend across a sufficient time frame to ensure
that the new habitat is established, self-sustaining,
and capable of surviving drought.
CDFW recommends that local onsite propagules
from the Project area and nearby vicinity be
collected and used for restoration purposes.
Onsite seed collection should be initiated in
advance of Project impacts in order to accumulate
sufficient propagule material for subsequent use
in future years. Onsite vegetation mapping at the
alliance and/or association level should be used to
develop appropriate restoration goals and local
plant palettes. Reference areas should be
identified to help guide restoration efforts.
Specific restoration plans should be developed for
various Project components as appropriate.
the Biological Study Area (see Section 2.6). See responses to comments 93 and 94 for additional information.
96 CDFW CDFW is concerned that the DEIR’s mitigation
measure BIO-4 does not provide sufficient
specificity to ensure minimize and avoid impacts
to desert kit fox. The desert kit fox is a species of
special concern and is protected from take by
CDFW Code 14 CCR section 460. CDFW
recommends that surveys be conducted for all
E-Group is supportive of incorporating the requested mitigation measure updates. Please note that these recommended changes do not alter the significance of determination for this impact. E-Group supports revising Mitigation Measure BIO-4 as recommended by the commenter.
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areas proposed to be directly or indirectly affected
by the Project to determine the presence or
absence of this species and the number of desert
kit fox that may be present.
CDFW recommends mitigation measure be BIO-4
revised to reference survey methods that include
procedures used to classify identified dens as
inactive dens, active and potentially active dens,
and active natal dens, and methods to quantify
and locate single or paired animals. The measures
should also include detailed monitoring
requirements and methods of exclusion/passive
relocation to be conducted, and methods and
timing of den excavation.
CDFW recommends Mitigation Measure BIO-4 be
revised as follows:
BIO-4:
A pre-construction survey for Desert Kit Fox shall
be conducted for by a Qualified Biologist familiar
with desert kit fox within 10 days before initiation
of site preparation or grading activities to
determine the presence/absence of Desert Kit
Fox. The Qualified Biologist shall conduct a preproject survey to attain 100% visual coverage within the Project area and a minimum 500-foot
buffer to determine the presence or absence of
desert kit fox individuals, dens, and sign. The
project proponent shall provide the results of the
survey to CDFW prior to start of Project activities.
The survey report should identify the status of all
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identified dens, include an estimate of
occupancy, and detail the methodology utilized
to support these conclusions.
If potential dens are located, they shall be
monitored by the Qualified Biologist. Trail
cameras may be used to assist with observation
but shall not be the sole basis upon which the
status is determined. Permittee shall provide a
determination if active dens can be avoided and
buffered from Project activities to prevent take
and disturbance with the survey results.
Should active Desert Kit Fox dens be present
within the Project area that cannot be avoided
with an adequate buffer, a Desert Kit Fox
Relocation and Mitigation Plan shall be prepared
by a qualified biologist in consultation with
CDFW, and shall be implemented including
protective measures such as the establishment of
no disturbance buffer zones for active den and
active natal den. No disturbance or relocation of
active dens may take place when juveniles may
be present and dependent on parental care.
Permittee shall block off inactive dens within the
buffer zone with rocks and sticks to discourage
use during Project activities and remove when
construction is complete. The Qualified Biologist
shall periodically check the inactive burrows
remain blocked and are not reoccupied During
Project activities including construction and
decommissioning.
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Response to DEIR Public Comments
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A report to evaluate the success of the relocation
efforts and any subsequent re-occupation, if
applicable, shall be provided at the end of the
construction period. Data shall be readily
available to the CDFW upon request. If an
injured, sick, or dead desert kit fox is detected on
any area associated with the project, the
designated CDFW personnel at both the Ontario
office and the Wildlife Investigation Lab shall be
notified as described within the Desert Kit Fox
Relocation and Mitigation Plan.
97 CDFW The project will impact ephemeral stream
resources. The DEIR does not specify that the
Project proponent is required to obtain a
streambed alteration agreement for Projectrelated impacts to stream resources. CDFW remains concerned regarding the EIR’s and
Jurisdictional Delineation’s characterization of
streams, underestimating the number and extent
of Project-related impacts to streams and
hydrology. CDFW will continue to work with the
Project proponent to identify, analyze, avoid,
minimize, and mitigate project-related impacts to
ephemeral stream resources through the
streambed alteration agreement process.
E-Group has continued to be in discussion with these issues with CDFW and submitted a memorandum to CDFW that further
addressed the concerns (see Exhibit 7). The DEIR evaluates potential impacts to waters of the State using the best available information, including a detailed aquatic resource delineation and a projectspecific hydrologic and hydraulic analysis.
All water that can be characterized as streambeds and/or ephemeral streams has been appropriately delineated in the Aquatic Resources Delineation Report included in DEIR Appendix D.2 and that impacts to such streams have been appropriately avoided.
CDFW jurisdictional areas were mapped to include the bank of the stream/channel and outer dripline of adjacent riparian vegetation, as set forth under California Fish and Game Code Section 1602.
Watercourse indicators (e.g., bed and bank, break in slope, shelving, scour, changes in soil, sediment sorting, wracking, and changes in vegetation) were used to determine the outer bank of the stream channel.
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Furthermore, DEIR Appendix H.2 was reviewed in the context of potential jurisdictional aquatic resources. Results of the hydraulic modeling were reviewed in conjunction with the 2023 aquatic resource delineation. In locations where the modeled 100-year, 24- hour runoff extent extended beyond areas previously delineated as jurisdictional under CDFW criteria, those areas were reassessed in the field on June 17, 2024. This reassessment was conducted to determine whether the modeled features met the criteria for waters subject to regulation under Fish and Game Code Section 1602, which requires notification to CDFW prior to any activity that may substantially divert or obstruct the natural flow of, or substantially change the bed, channel, or bank of, a river, stream, or lake. Based on this reassessment, the DEIR identifies areas with the potential to function as waters of the State and evaluates impacts accordingly.
Any requirement as to whether the project requires a streambed alteration agreement is outside the scope of the DEIR, as the DEIR does not rely upon compliance with such regulations to mitigate any identified significant environmental impact, nor would failure to enter into such an agreement result in a significant environmental impact identified in the DEIR. E-Group will continue to discuss these issues with CDFW.
98 CDFW CDFW is concerned that the DEIR’s mitigation
measure BIO-8 does not specifically commit the
Project proponent to obtaining a streambed
alteration agreement for Project impacts to
stream resources.
Fish and Game Code section 1602 requires an
entity to notify CDFW prior to commencing any
activity that results in one or more of the
following: substantially divert or obstruct the
See response to comment 97. E-Group respectfully disagrees that there are any impacts to streambeds or ephemeral streams that have not been avoided. The comment provides no evidence of impacts beyond those discussed and addressed in the DEIR and the Aquatic Resources Delineation Report included in DEIR Appendix D.2.
Therefore, further mitigation is unnecessary. E-Group will comply with all existing regulatory requirements, as applicable.
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natural flow of any river, stream or lake;
substantially change or use any material from the
bed, channel or bank of any river, stream, or lake;
or deposit debris, waste or other materials that
could pass into any river, stream or lake. Please
note that "any river, stream or lake" includes
those that are episodic (i.e., those that are dry for
periods of time) as well as those that are perennial
(i.e., those that flow year-round). This includes
ephemeral streams, desert washes, and
watercourses with a subsurface flow. It may also
apply to work undertaken within the flood plain of
a body of water. Upon receipt of a complete
notification, CDFW determines if the proposed
Project activities may substantially adversely
affect existing fish and wildlife resources and
whether a Lake and Streambed Alteration (LSA)
Agreement is required. An LSA Agreement
includes measures necessary to protect existing
fish and wildlife resources. CDFW may suggest
ways to modify your Project that would eliminate
or reduce harmful impacts to fish and wildlife
resources.
CDFW’s issuance of an LSA Agreement is a
“project” subject to CEQA (see Pub. Resources
Code 21065). To facilitate issuance of an LSA
Agreement, if necessary, the DEIR should fully
identify the potential impacts to the lake, stream,
or riparian resources, and provide adequate
avoidance, mitigation, and monitoring and
reporting commitments. Early consultation with
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CDFW is recommended, since modification of the
proposed Project may be required to avoid or
reduce impacts to fish and wildlife resources.
Recommended potentially feasible mitigation
measure(s) to reduce impacts to less than
significant. CDFW recommends Mitigation
Measure BIO-4 be revised as follows:
BIO-8:
Avoidance and Minimization of Impacts to
Potential Jurisdictional
Aquatic Resources. Prior to ground disturbing
activities permittee shall obtain a streambed
alteration agreement for all Project impacts to
resources subject to Fish and Game Code section
1602. The following avoidance and minimization
measures would be implemented when grounddisturbing activities occur within 25 feet of waters of the state and/or jurisdictional streambeds (i.e.,
jurisdictional aquatic resources):
• All jurisdictional aquatic resources within
25 feet of project activities shall be fenced or
flagged as environmentally sensitive areas prior to
any ground disturbance.
• A biological monitor shall be present
during construction activities within 25 feet of
jurisdictional aquatic resources to ensure
avoidance.
• Best Management Practices shall be
implemented to avoid indirect impacts to
jurisdictional waters, including:
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Response to DEIR Public Comments
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- Water containing mud, silt, or other pollutants
from grading or other activities shall not be
allowed to enter jurisdictional aquatic resources
or be placed in locations that may be subjected to
high storm flows.
- Spoil sites shall not be located within
jurisdictional aquatic resources or in locations that
may be subject to high storm flows, where spoils
might be washed into drainages.
- Raw cement/concrete or washings thereof,
asphalt, paint or other coating material, oil or
other petroleum products, or any other
substances that could be hazardous, resulting
from project-related activities, shall be prevented
from entering jurisdictional aquatic resources.
- Equipment maintenance shall occur outside
jurisdictional aquatic resources and in such a
manner that no petroleum products or other
pollutants from the equipment enters on- or offsite state-jurisdictional aquatic resources either directly or indirectly.
99 Adams,
Broadwell,
Joseph &
Cardozo
(“ABJC”)
The Staff Report demonstrates that the City has
not completed its environmental review of the
Project, and has not yet prepared a Final EIR in
compliance with CEQA. The Staff Report
nevertheless asks the Planning Commission to
recommend that the City Council certify the Final
EIR and adopt the Project’s final Mitigation
Monitoring and Reporting Program (“MMRP”) –
despite the fact that neither document exists, and
neither document has been presented to the
Planning Commission. The draft resolutions
The applicant understands that the Final EIR will be available for review by the Planning Commission prior to its March 3 hearing. The MMRP was included in the materials provided to the Planning Commission prior to the first hearing on the project.
Regardless, the Planning Commission can recommend action on the EIR without the Final EIR being available. The Final EIR must be circulated for public review at least 10 days prior to certification. 14 Cal. Code Regs. § 15088. The Planning Commission is not certifying the Final EIR and CEQA Guidelines do not require the Final EIR be available to boards and agencies making recommendations to the
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attached to the Staff Report similarly acknowledge
that “the City is still in process of finalizing the
Responses to Comments, which will
be…incorporated into the Final EIR”, but
nevertheless ask the Planning Commission to
“recommend[] that the City Council certify the
Final Environmental Impact Report SCH No.
2024021042, adopt the MMRP, and adopt the
related Statement of Overriding Considerations”
and adopt the proposed General Plan
amendments, rezoning, and other entitlements.
The proposed recommendations are premature, in
violation of CEQA and the Municipal Code, and
unsupported by substantial evidence in the
record.
First, the Planning Commission cannot
recommend certification of the FEIR or MMRP
when public comments are still being evaluated,
and final mitigation measures and alternatives are
still under consideration. CEQA requires the lead
agency to consider all comments received on the
Draft EIR, and prohibits certification of an EIR
unless all feasible mitigation and alternatives have
been incorporated into the project to mitigate or
avoid significant effects on the
environment. Moreover, when a final EIR makes
important changes to the draft EIR, such as
revising an impact conclusion, adding an
alternative, or changing a mitigation measure, the
EIR must be recirculated for additional public
review and comment. The City has not finished
final decisionmaker. The sections cited by the commenter apply to the final approval of the proposed project, defined under CEQA as “the decision by a public agency which commits the agency to a definite course of action in regard to a project intended to be carried out by any person.” 14 Cal. Code Regs. § 15352. Because the Planning Commission’s recommendations do not constitute final approval, the cited CEQA provisions are inapplicable.
Recirculation of a Draft EIR is only required when significant new information is added to the EIR after public notice is given of the availability of the draft EIR for public review but before certification.
New information added to an EIR is not “significant” unless the EIR is changed in a way that deprives the public of a meaningful opportunity to comment upon a substantial adverse environmental effect of the project or a feasible way to mitigate or avoid such an effect (including a feasible project alternative) that the project's proponents have declined to implement. “Significant new information” requiring recirculation includes:
(1) A new significant environmental impact would result from the project or from a new mitigation measure proposed to be implemented.
(2) A substantial increase in the severity of an environmental impact would result unless mitigation measures are adopted that reduce the impact to a level of insignificance.
(3) A feasible project alternative or mitigation measure considerably different from others previously analyzed would clearly lessen the significant environmental impacts of the project, but the project's proponents decline to adopt it.
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considering public comments, and may need to
add or revise mitigation measures, consider new
alternatives, or recirculate the
DEIR in response to evidence presented by
commenters. The Planning Commission cannot
recommend certification of the EIR until the City
completes these steps.
14 Cal. Code Regs § 15088.5. Recirculation is not required where the new information added to the EIR merely clarifies or amplifies or makes insignificant modifications in an adequate EIR. Id.
As further discussed below, no comments provided provide “significant new information” not already addressed in the Draft EIR nor provide grounds warranting recirculation of the Draft EIR. 10 0
ABJC Second, under CEQA, the EIR must reflect the lead
agency’s independent judgment and analysis. In
recommending approval of the EIR, MMRP and
Project entitlements, the Planning Commission
has a duty to exercise independent
judgment in determining whether the EIR includes
all necessary mitigation and alternatives to reduce
the Project’s significant impacts to the greatest
extent feasible. The Commission cannot exercise
independent judgment over the adequacy of the
FEIR and final mitigation measures if they do not
yet exist.
The CEQA provisions cited by the commenter require that the lead agency circulate a draft EIR that reflects its independent judgment and that, as part of certification of the Final EIR, find that the FEIR “reflects the independent judgment of the lead agency.” Pub. Res.
Code § 21082.1(c). The City prepared the DEIR and there is no claim that it did not do so pursuant to its independent judgment. The City Council will similarly need to find that the Final EIR represents its independent judgment prior to certification of the Final EIR.
Regardless, there is nothing that would prevent the Planning Commission from finding that the Draft EIR analysis, additional analysis provided by City staff, and its own review reflects the independent judgment of the Planning Commission.
10 1
ABJC Finally, the City’s approval findings for the
Project’s entitlements must be supported by
substantial evidence. The Planning Commission
lacks substantial evidence to support the findings
to recommend approval at this time because the
substantial evidence in public comments from
agencies, members of the public, and experts
(including these comments) demonstrate that the
Project has significant, unmitigated environmental
and public health impacts that the DEIR fails to
disclose or mitigate. The draft resolutions ask the
Commission to find that the Project’s proposed
The comment mischaracterizes the evidentiary standard applicable to Planning Commission review. ““Substantial evidence” means “enough relevant information and reasonable inferences from this information that a fair argument can be made to support a conclusion, even though other conclusions might also be reached.” 14 Cal. Code Regs. § 15384. The proper evaluation is whether there is substantial evidence in the record and EIR analysis to support the City’s conclusions, even if there is contrary evidence in the record. Evidence is “substantial” if it is “reasonable in nature, credible, and of solid value.” Schafer v. City of Los Angeles (2015) 237 Cal. App. 4th 1250, 1260. When considering an EIR, “a court may not set aside an agency's approval of an EIR on the ground that an opposite
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GPAs, rezoning and other entitlements are
supported by the DEIR (not the FEIR), that there is
no evidence in the record of adverse, unmitigated
effects on public health or safety, and that the
proposed land use amendments “will not
adversely affect the existing community.” The
proposed findings are entirely
unsupported and contradicted by the record
which demonstrates that the Project has
significant, unmitigated public health impacts
from Valley Fever, unmitigated
biological resources impacts on special status
species, among other impacts. The Commission
cannot recommend approval of the Project’s
entitlements based on unsupported findings.
conclusion would have been equally or more reasonable.” Laurel Heights Improvement Ass’n v. Regents of Univ. of Cal. (1988) 47 Cal.3d 376, 393. Therefore, the proper evaluation is whether the City has provided substantial evidence to support the conclusions in the EIR, not whether the commenters have provided substantial evidence to support their arguments. The impacts mentioned in the comment have been adequately addressed in the Draft EIR and are supported by substantial evidence. Specific comments concerning such impacts are discussed further below.
10 2
ABJC For example, Citizens’ air quality expert James
Clark, Ph.D. finds that the DEIR fails to adequately
analyze and mitigate the Project’s potentially
significant impacts related to Valley Fever. Dr.
Clark’s comments provide substantial evidence
that construction workers, nearby residences, and
the surrounding community will be at a
heightened risk of being exposed to Valley Fever
spores during Project-related construction
activities, which may result in significant health
risks. This risk cannot be mitigated by the
mitigation currently proposed in the DEIR.
The comment introduces the commenter’s specific concern regarding the adequacy of the Draft EIR’s consideration of “valley fever” exposure. The comment states that the Draft EIR failed to adequately analyze and mitigate Project-related impacts associated with valley fever exposure.
The Draft EIR considered whether the Project would result in a significant impact attributable to valley fever (also known by the scientific name “coccidioidomycosis”). This topic is neither new to California nor new to CEQA, as it is a recognized fungal infection that occurs via the inhalation of spores that reside in soil. Indeed, the California Department of Public Health (CDPH) has a surveillance system to track valley fever cases and has been collecting case data since 1995.2
Valley fever is first introduced on page 2.4-27 of the Draft EIR, which is located in Section 2.4, Air Quality. The Draft EIR disclosed San
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Bernardino County experiences very low rates of valley fever (the reported incidence rate in 2022 was 3 per 100,000) and that the Center for Disease Control has reported no outbreak of valley fever in San Bernardino County (Draft EIR, p. 2.4-27). In addition, San Bernardino County – where the Project site is located – is not considered by the scientific and regulatory communities to be a highly endemic county for valley fever, based on the reporting data collected by CDPH. In concluding that the Project would not result in a significant human health impact attributable to valley fever exposure, the Draft EIR underscored the relevance of the Project location in a non-highly endemic county with low incidence rates and the Project’s required compliance with applicable regulatory standards for dust control measures, which would minimize the potential release and inhalation of fungal spores. (Draft EIR Draft EIR, p. 2.4-27).
The Draft EIR’s primarily qualitative approach to assessing the Project’s valley fever impact is consistent with CEQA Guidelines sections 15064, 15064.7 and 15142. It also was informed by the fact that neither the California Air Resources Board (CARB) nor the South Coast Air Quality Management District (SCAQMD) provide qualitative or quantitative thresholds of significance for addressing valley fever in the CEQA context. As also discussed in greater detail in the responses that follow, the less-than-significant impact conclusion is supported by substantial evidence in the form of the most recently updated reporting data and recommended standards of practice from multiple public agencies with expertise.
10 3
ABJC Citizens’ biological expert Shawn Smallwood, Ph.D. concludes that the Project fails to establish an
adequate environmental setting against which to
analyze the Project’s impacts to biological
resources. As a result, the DEIR fails to
See Responses to comments 105 through 108.
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adequately analyze and mitigate significant
impacts to burrowing owls, LeConte’s Thrasher,
and other special status species that likely use the
Project site. Dr. Smallwood also provides
substantial evidence that significant bird and bat
deaths will occur due to collision with projectrelated traffic, PV panels, and security fences. The DEIR also fails to adequately analyze potentially
significant impacts to
wildlife movement that the Project will cause. The
DEIR’s current mitigation measures do not reduce
these significant impacts to the greatest extent
feasible, as required by CEQA. The attached expert
reports are incorporated by reference into this
comment letter as if fully set forth herein and
must be considered part of the record for this
Project.
10 4
ABJC Further, the DEIR violates CEQA by piecemealing
review of the Project’s estimated ROG emissions
and by relying on deferred mitigation to address
the Project’s impacts to biological resources.
These violations lead the City to improperly
conclude that the Project will not result in
significant impacts to air quality or biological
resources. The City must revise and recirculate the
DEIR to fully disclose and mitigate the Project’s
significant impacts, in compliance with CEQA.
See Response to comment 117.
10 5
ABJC On January 4 and January 5, 2026, Dr.
Smallwood’s staff conducted a survey of the
Project site where they identified 23 species of
vertebrate wildlife—including 6 species with
special status. This brief survey identified 10
Although the commenter only conducted two days of surveys, Dudek conducted extensive and comprehensive field surveys over each season and over the course of two years from April 2023 through May 2025, which included vegetation mapping, habitat assessments, aquatic resources delineation, and focused special-status species