Tribes implore President Obama to stop Ocotillo Express wind project, save cultural resources

[Liberty Belle]

Source: East County Magazine

“We believe that DOI [Department of the Interior] is posed to violate the law and our rights to religious freedom and our cultural identities guaranteed by DOI’s own policies, the United States Constitution, and international declarations. We need your help.” --Chairman Anthony Pico, Viejas Band of Kumeyaay Indians, in a letter to President Barack Obama

Part I in a series on potential impacts of the Ocotilllo Wind Express project

March 23, 2012 (Ocotillo) – For months, Ocotillo residents and conservationists have been waging a David and Goliath battle seeking to stop Pattern Energy’s proposed Ocotillo Wind Express project. Now Kumeyaay, Cocopah,Quechan and other Native American tribes have banded together to oppose the massive project-- joining residents, desert conservation groups and outdoor enthusiasts who seek to protect resources from destruction—including hundreds of cultural and archaeological sites.

On March 28, the Imperial Valley Planning Commission will rule on whether to approve the controversial project. At the federal level, the Secretary of the U.S. Department of the Interior is expected to issue a final decision by May 1. A petition seeking to stop the project has been launched by Ocotillo residents: http://www.change.org/petitions/say-no- ... y-project#. The project would place up 112 to 155 turbines each 450 feet tall on 12,500 acres of publicly owned Bureau of Land Management land. Turbines would be sited within half a mile of homes. Residents have voiced alarm over impacts on health, views, wildlife, and property values. The project would destroy not only desert terrain, but also archaeological and sacred Native American sites.

Viejas Chairman Anthony Pico, speaking at a renewable energy conference March 16 at the U.S. Grant Hotel in San Diego, Viejas Chairman Anthony Pico voiced frustration and outrage at a fast-track process that he believes has violated numerous laws. “A fast-track process favoring renewable energy projects without regard to all classes of environmental impacts will result in irreparable harm to federal public lands that are sacred to tribes,” Chairman Pico warned. He added that pressures from the highest levels of the federal government “has caused those engaged in the management of public lands to abandon all common sense, their responsibilities to tribes pursuant to the United State trust obligation, and the duties and responsibilities delegated to them under relevant law.”

“Non-native people put their history in books. Our ancestors put their history on the ground and in the rocks, in the geoglyphs and in the petroglyphs, in the places where we live,” Pico said. “Destruction of this record is irreparable and it takes part of our lives.” View a video of his full speech: http://vimeo.com/38796301




Read more: http://www.eastcountymagazine.org/node/9104

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There are hundreds of documented archaeological sites on this project site that will be destroyed, including this giant geoglyph, as well as many cremation/burial sites and ceremonial sites that several tribes use to this day as teaching areas for their youths and for religious purposes. Destroying this is wrong on so many levels. Our government has broken so many promises to the Indians through the years, and now this? If you think this is wrong, sign the petition at the link above.

I should add that Chairman Pico is among the most highly respected tribal leaders around, a man who led his people out of poverty some years ago and was recently restored to leadership at a time when his people needed his wise counsel at the hel. He recently invited the Kennedy School of Government to work with his tribal council in developing "nation building" strategies to create a better future for the Viejas people, who have been generous in our community, providing fire protection and wildfire training for every fire agency in San Diego County, donating to local schools and worthy community causes. This is not how our federal government should be treating our Native Americans.

[FrodosPet]

1. NIMBY is alternative energy's biggest hurdle

People complain about the deserts covered by solar cells and the hills and seascapes covered with windmills, when they should be thinking about the even bigger problems of hydrocarbons.

[Liberty Belle]

2. That is a totally disrespectful thing to say.

I guess if you live in Appalachia we could just say you should shut up about mountains being sliced apart and rivers clogged from coal mining because we need the power. Or that Gulf Coast residents should just learn to live with oil spills. It is wrong to impose devastation on local people to satisfy energy needs. There is a mentality now that these projects can be built absolutely anywhere and nothing is off limits.

The Ocotillo project is also hurting non-Native Americans. There are people who live less than a half mile away and some will be surrounded on 3 sides by 450-foot-tall turbines. That's close enough for major health effects. The government is trying to force some of them to move away from homes they've lived in all their lives.

When we disrespect human beings and nature, we are in the wrong.

The Indians are very supportive of going green, just not in this way. Some of our local tribes are recycling all their water. One has a LEED certified Green casino. Another has a wind farm on their own reservation, but in an area with minimal impacts. Others have solar power on many of their own homes.

Is anything off limit in your book? Would you pave Yellowstone and fill in the grand canyon with wind turbines? How many do you have in YOUR backyard--or do you only want them in someone else's?

[obxhead]

4. I yearn to see windmills off the coast of the OBX.

I hear this argument all the time and it's BS.

Oil spills and rivers clogged with mining runoff do not compare to a broken view.

I completely understand and respect not disturbing sacred burial grounds etc, but an argument on health? Seriously? Windmills will be a detriment to someones health? Yeah, your pillow is more likely to harm you while you sleep.

I LOVE the OBX (NC) and I seriously yearn for the days when I can sit there and snap pictures of the vast wind farms. It's time to move forward in a positive way.

[DallasNE]

6. I'm With You

How many people live in this 12,500 acre area? It is out in the middle of nowhere. They tend to build these things along ridge lines to catch the most wind. At the base they make a footprint that is about 20' x 20'. My guess is that the local people simply want to be paid more money for things being built on public land. They should be more concerned about the strip mining and coal fired plants being built in their back yard rather than this clean, renewable energy.

[tabasco]

9. 20'x20' footprint? LOL!

You need acres for a single wind turbine and roads throughout the industrial facility.

http://www.aweo.org/faq.html

[DallasNE]

21. Do You Believe Everything You Read?

I see these things dotting cornfields all over the place and farmers plant right up next to them. The blades low point is plenty high to allow for large combines to harvest the corn. They bury the power lines so there is no sign of the wires that transport the electricity away. I see no issue with clean, renewable energy like this -- no acid rain and no carbon released into the atmosphere to contribute to global warming.

[tabasco]

22. No I don't. Are you stupid?

How fortunate for you there are no trees where you live, just corn plants. At the industrial wind facilities I have visited in West Virginia, ACRES of trees must be cut for a SINGLE wind turbine.

Have a great day.

P.S. - asking someone if they "believe everything they read" is the equivalent of asking them "are you stupid?"

[quakerboy]

5. Health effects?

The potential health detriments of living near an oil spill, a mountain top removal or a fracking area seem fairly self explanatory. But I have never heard of any ill health effects of living near a windmill. I noted that in the article as well, but there was no further explanation there. Can you elaborate on this?

[tabasco]

8. You said it so much nicer than I would have.

Thank you.

Conservation is our only hope, not blighting the landscape to meet our voracious wastefulness.

[obxhead]

11. That answer is impossible to achieve.

I fully agree with conservation and reduction of needs efforts.

The simple fact is our population is expanding though. Conservation will NEVER answer our problems.

So we can choose to build a variety of clean energy solutions or we can build nothing but dirty energy solutions. I vote for more windmills and solar farms than coal and nuke plants.

I'll take a slowly turning windmill over coal dust and smoke.

[tabasco]

13. Keep dreaming. And unplug your refrigerator.

Our population expansion and energy consumption are unsustainable.

Wind and solar will never provide enough power to replace other conventional sources, until there is drastic population decrease or drastic lifestyle change.

I vote for nuclear. It can be done safely.

[obxhead]

14. No matter how safe you make nuclear

what do you do with the waste? Maybe you're open to storing it in your yard?

I never said replace either. Why is there NO room for green energy to fill some of our needs?

[kristopher]

16. Your assertion about renewables is false.

It may be your opinion, but there are no experts in the field of noncarbon energy resources that agree with you.




This is a single paragraph abstract (see original form below) that I’ve broken apart for ease of reading:

Energy Environ. Sci., 2009, 2, 148 - 173, DOI: 10.1039/b809990c

Review of solutions to global warming, air pollution, and energy security

Mark Z. Jacobson

Abstract
This paper reviews and ranks major proposed energy-related solutions to global warming, air pollution mortality, and energy security while considering other impacts of the proposed solutions, such as on water supply, land use, wildlife, resource availability, thermal pollution, water chemical pollution, nuclear proliferation, and undernutrition.

Nine electric power sources and two liquid fuel options are considered. The electricity sources include solar-photovoltaics (PV), concentrated solar power (CSP), wind, geothermal, hydroelectric, wave, tidal, nuclear, and coal with carbon capture and storage (CCS) technology. The liquid fuel options include corn-ethanol (E85) and cellulosic-E85. To place the electric and liquid fuel sources on an equal footing, we examine their comparative abilities to address the problems mentioned by powering new-technology vehicles, including battery-electric vehicles (BEVs), hydrogen fuel cell vehicles (HFCVs), and flex-fuel vehicles run on E85.

Twelve combinations of energy source-vehicle type are considered. Upon ranking and weighting each combination with respect to each of 11 impact categories, four clear divisions of ranking, or tiers, emerge.

Tier 1 (highest-ranked) includes wind-BEVs and wind-HFCVs.
Tier 2 includes CSP-BEVs, geothermal-BEVs, PV-BEVs, tidal-BEVs, and wave-BEVs.
Tier 3 includes hydro-BEVs, nuclear-BEVs, and CCS-BEVs.
Tier 4 includes corn- and cellulosic-E85.

Wind-BEVs ranked first in seven out of 11 categories, including the two most important, mortality and climate damage reduction. Although HFCVs are much less efficient than BEVs, wind-HFCVs are still very clean and were ranked second among all combinations.

Tier 2 options provide significant benefits and are recommended.

Tier 3 options are less desirable. However, hydroelectricity, which was ranked ahead of coal-CCS and nuclear with respect to climate and health, is an excellent load balancer, thus recommended.

The Tier 4 combinations (cellulosic- and corn-E85) were ranked lowest overall and with respect to climate, air pollution, land use, wildlife damage, and chemical waste. Cellulosic-E85 ranked lower than corn-E85 overall, primarily due to its potentially larger land footprint based on new data and its higher upstream air pollution emissions than corn-E85.

Whereas cellulosic-E85 may cause the greatest average human mortality, nuclear-BEVs cause the greatest upper-limit mortality risk due to the expansion of plutonium separation and uranium enrichment in nuclear energy facilities worldwide. Wind-BEVs and CSP-BEVs cause the least mortality.

The footprint area of wind-BEVs is 2–6 orders of magnitude less than that of any other option. Because of their low footprint and pollution, wind-BEVs cause the least wildlife loss.

The largest consumer of water is corn-E85. The smallest are wind-, tidal-, and wave-BEVs.

The US could theoretically replace all 2007 onroad vehicles with BEVs powered by 73000–144000 5 MW wind turbines, less than the 300000 airplanes the US produced during World War II, reducing US CO2 by 32.5–32.7% and nearly eliminating 15000/yr vehicle-related air pollution deaths in 2020.

In sum, use of wind, CSP, geothermal, tidal, PV, wave, and hydro to provide electricity for BEVs and HFCVs and, by extension, electricity for the residential, industrial, and commercial sectors, will result in the most benefit among the options considered. The combination of these technologies should be advanced as a solution to global warming, air pollution, and energy security. Coal-CCS and nuclear offer less benefit thus represent an opportunity cost loss, and the biofuel options provide no certain benefit and the greatest negative impacts.

As originally published:

Abstract

This paper reviews and ranks major proposed energy-related solutions to global warming, air pollution mortality, and energy security while considering other impacts of the proposed solutions, such as on water supply, land use, wildlife, resource availability, thermal pollution, water chemical pollution, nuclear proliferation, and undernutrition. Nine electric power sources and two liquid fuel options are considered. The electricity sources include solar-photovoltaics (PV), concentrated solar power (CSP), wind, geothermal, hydroelectric, wave, tidal, nuclear, and coal with carbon capture and storage (CCS) technology. The liquid fuel options include corn-ethanol (E85) and cellulosic-E85. To place the electric and liquid fuel sources on an equal footing, we examine their comparative abilities to address the problems mentioned by powering new-technology vehicles, including battery-electric vehicles (BEVs), hydrogen fuel cell vehicles (HFCVs), and flex-fuel vehicles run on E85. Twelve combinations of energy source-vehicle type are considered. Upon ranking and weighting each combination with respect to each of 11 impact categories, four clear divisions of ranking, or tiers, emerge. Tier 1 (highest-ranked) includes wind-BEVs and wind-HFCVs. Tier 2 includes CSP-BEVs, geothermal-BEVs, PV-BEVs, tidal-BEVs, and wave-BEVs. Tier 3 includes hydro-BEVs, nuclear-BEVs, and CCS-BEVs. Tier 4 includes corn- and cellulosic-E85. Wind-BEVs ranked first in seven out of 11 categories, including the two most important, mortality and climate damage reduction. Although HFCVs are much less efficient than BEVs, wind-HFCVs are still very clean and were ranked second among all combinations. Tier 2 options provide significant benefits and are recommended. Tier 3 options are less desirable. However, hydroelectricity, which was ranked ahead of coal-CCS and nuclear with respect to climate and health, is an excellent load balancer, thus recommended. The Tier 4 combinations (cellulosic- and corn-E85) were ranked lowest overall and with respect to climate, air pollution, land use, wildlife damage, and chemical waste. Cellulosic-E85 ranked lower than corn-E85 overall, primarily due to its potentially larger land footprint based on new data and its higher upstream air pollution emissions than corn-E85. Whereas cellulosic-E85 may cause the greatest average human mortality, nuclear-BEVs cause the greatest upper-limit mortality risk due to the expansion of plutonium separation and uranium enrichment in nuclear energy facilities worldwide. Wind-BEVs and CSP-BEVs cause the least mortality. The footprint area of wind-BEVs is 2–6 orders of magnitude less than that of any other option. Because of their low footprint and pollution, wind-BEVs cause the least wildlife loss. The largest consumer of water is corn-E85. The smallest are wind-, tidal-, and wave-BEVs. The US could theoretically replace all 2007 onroad vehicles with BEVs powered by 73 000–144 000 5 MW wind turbines, less than the 300 000 airplanes the US produced during World War II, reducing US CO2 by 32.5–32.7% and nearly eliminating 15 000/yr vehicle-related air pollution deaths in 2020. In sum, use of wind, CSP, geothermal, tidal, PV, wave, and hydro to provide electricity for BEVs and HFCVs and, by extension, electricity for the residential, industrial, and commercial sectors, will result in the most benefit among the options considered. The combination of these technologies should be advanced as a solution to global warming, air pollution, and energy security. Coal-CCS and nuclear offer less benefit thus represent an opportunity cost loss, and the biofuel options provide no certain benefit and the greatest negative impacts.

You can download the full article at the author's webpage here: http://www.stanford.edu/group/efmh/jacobson/Articles/I/revsolglobwarmairpol.htm

direct download link: http://www.stanford.edu/group/efmh/jacobson/Articles/I/ReviewSolGW09.pdf

html abstract here: http://www.rsc.org/publishing/journals/EE/article.asp?doi=b809990c

Download slide presentation here: http://www.stanford.edu/group/efmh/jacobson/Articles/I/0902UIllinois.pdf

[Kolesar]

17. He claimed "major health effects" from a wind turbine a half mile away.

You claimed "major health effects" from a wind turbine a half mile away.

It would take me ten minutes to walk to it. Are you claiming it could kill somebody?

[Honeycombe8]

19. The post you respond to isn't disrespectful, IMO.

It's merely a factual statement of the possibly LARGER problems caused by fossil fuels and other energy sources.

There is a study being done on this project. It's not true that windmills are placed just anywhere without any thought or consideration to the environment or culture of an area.

The fact is that ALL sources of energy cause destruction of some sort. It's a matter of weighing which causes the most for the most people and for safeguarding the environment and culture for the future.

No one seems to want the windmills. Yet, they seem to be far less destructive than any other type of energy source.

If we want a society that uses fuel - and we do - we will have to use some sort of destructive energy source. Take your pick. Would they prefer oil wells on that site? Or windmills? Or coal mines with blasting?

The problem with windmills is that they can't be placed just anywhere. There are only certain locations that have the wind and space necessary for them to be useful.

Let's see what the study says.

Also, aren't Native Americans predominantly Republican and prefer fossil fuels to alternative sources? Maybe not, but I have gotten that impression over the last few years. But maybe it was just a couple of outspoken Native Americans who were tea party sympathizers. If they are, they are likely to be anti-Obama-administration policies of any sort, just like the other Republicans these days.

[denem]

3. Sorry, but on what I've managed to read so far, this really does look like NIMBY.

The opposition yo the wind farm has been lead by the residents of Ocotillo, a town of 296 people because the edge of the wind farm would be 5 miles from the town limits. Ocotillo is 92% white. 2 Native Americans live there. The has not been a determination or approval on anything so far but,

After years of opposition, they have (as per the statement) co-opted the Viejas Band of Kumeyaay Indians. On the BLM site, the department says it has began consultations with Viejas Band of Kumeyaay Indians, now they have made their concerns known.

I have reservations about the statement, There are hundreds of documented archaeological sites on this project site that will be destroyed, including this giant geoglyph . I would have thought it should be possible to place 155 windmills over an area of 12,500 acres sensitively appropriately and sensitively, and with any doubt, not build one on top of that geoglyph.

[freedom fighter jh]

7. Sounds like a BLM snow job.

I was able to listen to the first 2.5 minutes of the video.

There is a process for considering cultural resources and environmental impacts. It sounds like BLM violated that process by not completing the cultural resources part of the environmental impact statement until after the EIS comment period closed. Therefore no one could respond to the cultural resources report. At least that's what I got from the short section of the video that I was able to listen to.

There should be a process for appeal. Maybe in court, since it sounds like the National Historic Preservation Act was violated, as well as possibly the National Environmental Policy Act.

[hunter]

10. I'm NIMBY here. These wind farms will be abandoned when subsidies end.

Last edited Sat Mar 24, 2012, 02:45 PM - Edit history (1)

These wind Farms are the Easter Island Stone Heads of our civilization.

The sort of industry that builds giant wind farms cannot be supported by wind farms alone.

Without expensive environmentally destructive power storage projects, power distribution upgrades, and fossil fuel backup, wind power is next to useless.

Currently wind power is a fairy tale supported by the natural gas industry. The natural gas industry knows that for every megawatt of wind power installed, a few more megawatts of nimble natural gas power plants must be installed to keep the power system stable.

I don't think a fracking natural gas / wind powered future is anything nice to look forward too.

I hope this project dies a horrible expensive death and scares investors away from wind.

I support the tribes.

http://www.change.org/petitions/say-no-to-the-ocotillo-wind-energy-facility-project

[kristopher]

12. Actually you support nuclear power

You've made that abundantly clear for years. And since renewable energy sources are what stand in the way of nuclear power's expansion you have no trouble making posts filled with fictional claims about the capabilities of renewables.

[kristopher]

15. Tribal concerns as expressed in the Environmental Review

Environmental Impact Statement is here http://www.blm.gov/pgdata/etc/medialib/blm/ca/pdf/elcentro/nepa/ocotilloexpress/feis.Par.17804.File.dat/OWEF%205_Consultation.pdf

All emphasis added.

My impression is that there are two classes of objections: 1) claims related to ground disturbance within the project area and 2) claims related to views being disturbed from "spiritual" sites.

The law that we all live by gives a fair amount of weight to 1) but little weight to 2).

There has been an aggressive outreach process for identification of specific areas of ground disturbance but the Tribes don't seem inclined to identify specific areas within the project development site that they want protected:
Further, and more detailed, information about its components and boundaries is necessary in order to define and understand it properly in order to apply the applicable guidelines, even though the BLM generally recognizes the religious and cultural value that the Tribes attribute to the cultural landscape they have identified. The BLM continues to seek such information from the Tribes.

It could be inferred that the viewshed argument is the most significant to them and but since it has little chance of actually halting the wind project, they are using nonspecific claims of ground disturbance in an attempt to obstruct the process.

Finally, to be clear about one point, the glyph in the OP photo is not within the development area and is in no way physically threatened by the wind farm. The complaint is that the wind farm will destroy the view from that, and other, spiritual spots.

Relevant information starts at page 5-3 and includes a full accounting of the discussions to date with the Indian Tribes. There is a summary table of the meetings and extensive text describing the positions of all parties. I'm reproducing a small amount of it here that I consider the most information rich.

Final EIS/EIR 5-13 February 2012
5. Consultation, Coordination, and Public Participation Ocotillo Wind Energy Facility
Commencing page 5-13

Consultation with Indian tribes, and discussions with tribal organizations and individuals has revealed very strong concern about the project and the impacts it would cause under all of the build alternatives. They have stated during meetings and in written correspondence their perception of the importance and sensitivity of cultural resources within and near the OWEF project area. Many Tribes have told the BLM that they attach religious and cultural significance to the project area and the broader landscape and some have proposed that the project area is part of a larger TCP that encompasses the project site and surrounding area. They view the high density of resources as interrelated and consider the area as a whole to be sacred. During consultation, multiple Tribes expressed their direct opposition to the project including the Campo Band of Mission Indians, Kwaaymii Laguna Band of Indians, Manzanita Band of Kumeyaay Indians, Quechan Indian Tribe, San Pasqual Band of Diegueno Indians and the Viejas Band of Kumeyaay Indians. The Southern California Tribal Chairmen’s Association has also sent the BLM a resolution in opposition to the OWEF project (No. 2012-02), dated January 24, 2012.

The SCTCA’s resolution states that they are opposed to the project due to the fact that it “lies within a rich landscape that is culturally and religiously significant to the SCTCA member tribes and if constructed, the proposed project will cause irreparable harm to those tribes and resources of great cultural value to them.” Their earlier resolution, No. 2011-13 dated November 22, 2011, further explains that:

“[T]he SCTCA member Tribes have continuing cultural and religious associations with the lands subject to effect by the OWEP including their natural and cultural features, their plants and animals, the ancestral human remains interred therein, and the vistas across the valley and into the surrounding foothills and mountains...”

In November 2011, the Viejas Band of Kumeyaay Indians provided the BLM with Tribal Council Resolution No. 112311B which stated that the project area is encompassed by a TCP (Traditional Cultural Property) that should be recognized as an Indian Sacred Site under Executive Order 13007 and should also be considered eligible for listing on the NRHP under Section 106. They provided a map with an outline of its proposed boundaries.

Specific to the TCP discussion, some Tribes have indicated that certain geological features including Coyote Mountain and Signal Mountain (Little Wii Shpaa or Little Eagle Mountain in the Cocopah language), which are outside the ROW application, and Sugarloaf Mountain, which is within the ROW application area, hold significant value. Specifically, concern about impacts to the view shed towards important cultural locations, as well as impacts to the viewshed from the Spoke Wheel Geoglyph and other geoglyphs and sites of traditional and religious importance. The Cocopah Indian Tribe has expressed in government-to-government meetings that Signal Mountain is a sacred corner marker in their belief system that the area from the project to Signal Mountain was part of a corridor used by the Cocopah people, and that Signal Mountain forms part of their strong connection to the land and power is received from it.

A letter from Viejas Tribal Chairman Anthony Pico dated December 27, 2011, to State Director Jim Kenna explained:

“The proposed project area is a culturally and religiously significant landscape valued by the Kumeyaay, Cocopah and Quechan peoples. It is rich with evidence of our use and occupation, and we maintain a spiritual connection to the landscape, its plants, animals, views and natural features which include not one but three spiritually significant mountains: Coyote Mountain, Signal Mountain and Sugarloaf Mountain.

Our knowledge of who we are and where we come from is passed along in songs, stories and ceremonies that originate from and reference the Ocotillo area. We tell those stories, sing those songs and practice those ceremonies today. The project area is a teaching place, where we teach the youth our traditions and spiritual practices. Our concerns are about much more than simply avoiding archaeological sites, which were identified by a paid archaeological consultant. Proper consultation and analysis of this area, had it been conducted, would have and should have included tribal views and values. To date those views have been ignored and no effort has been made to correct that. This landscape, given that it is the origin of certain songs and ceremonies, and that it contains places integral to our language and stories, is invaluable to us. The proposed project in each of its forms, including a reduction in turbine number, will have serious and irreparable impacts to this landscape and to the tribes' cultural and religious practices. There is no mitigation that can make up for that. We are not opposed to renewable energy; we are opposed to this project in this place...”

Vice-President Ronda Aguerro of the Quechan Indian Tribe in a letter to the BLM dated December 9, 2011, states that the cultural resources found in the OWEF project area:

“...reflect the repeated, annual migration of the Quechan, and other Yuman Tribes, as they exercised cultural, spiritual/religious, and utilitarian practices in that area. The OD (Ocotillo Desert) is part of the traditional Western Corridor for the Quechan Tribe and it is also an area of transition between the Quechan, Cocopah, Kumeyaay and Kamia/Desert Kumeyaay.”

Her letter goes on to also explain:

“The area of the OD holds tremendous spiritual essence for the Quechan Tribe. The APE lies at the bottom of Coyote Mountain (Carrizo Mountain), which is an important cultural component to the Quechan cosmology. The importance of that mountain is recounted and held sacred in our Creation Story, songs, and other oral traditions. To allow a project of such magnitude to be erected next to one of our sacred sites-which helps form our identity as Quechan-would be a desecration to our culture and way of life.”

The Manzanita Band of Kumeyaay expressed their concerns about the OWEF project to Secretary of the Interior Ken Salazar in the following way by letter dated September 29, 2011, from Chairman Leroy Elliott:

“We respectfully request you to consider that the Kumeyaay people do not record or maintain our history in books and libraries as the white man culture does. We Native Americans record our history on the land where we lived, at the sacred sites where we prayed, and in the communities where we coexisted in harmony with the cultural and environmental landscape. Our people have maintained this way for ten thousand years and it is only in the past two hundred years that we were forced to abandon our way of life as a means of survival....

The vast majority of our heritage history evidencing that our people lived here in the region for over 10 millenniums is now gone due to the development of these prime real estate locations.. All that remains of our history lies in the few remote areas of McCain Valley, Jacumba, and Ocotillo.....

It is on this land in McCain Valley, Jacumba, and Ocotillo where our ancestral people lived, worked, worshiped, sang, danced, and died. It is on this land that our people were cremated ceremoniously and our family bones are placed undisturbed on the land, hopefully for all time. Now, approval of your three priority projects will destroy in one generation what took hundreds, even thousands of generations to establish... All for technology that could well be antiquated within just one twenty-year generation. Let us not rush ahead be so foolish. McCain Valley, Ocotillo, and Jacumba, are all three Traditional Cultural Properties and the last of our Kumeyaay major heritage sites. We request that Cultural Conservation Easements be establish so that the general public has restricted access and these sacred communities can be again preserved for our Native citizens to ceremonially enjoy without energy project structures...

Placing wind turbines and transmission lines between your described and limited archaeological sites desecrates the ancestral communities that were established and in practice long before your written history. Using your science to define and describe our historic cultural communities and spiritual concepts is another example of how your government dishonors ours. These Native American homelands are Traditional Cultural Properties that are cherished and should be protected...”

In a letter to BLM Archaeologist Carrie Simmons, dated May 16, 2010, Ms. Carmen Lucas of the Kwaaymii Laguna Band of Indians provided a list of her concerns regarding the preservation and protection of cultural resources within the desert in the face of increasing renewable energy development. She asked that among other things, “the small fragmented remains (to include Human Remains) that tell the prehistory of the people who knew how to live and move with the rhythm of this environment for thousands of years without destroying it not be impacted”, and that “the intangible view sheds that help tell the sacred legends not be obstructed or impacted.”

The section that discusses the policy framework for Tradition Cultural Properties starts on page 5-96:

Traditional Cultural Properties
Commenters representing some of the Tribes have proposed that a TCP exists within the project area and the surrounding region; that this area comprises a landscape which is historically, culturally, religiously and spiritually important to the commenting Tribes and to its members; and that the TCP is eligible for listing in the National Register of Historic Places (National Register).

In response to those comments, and as a result of the ongoing Section 106 consultation process with the Tribes, the ACHP, SHPO, and other consulting parties, the BLM acknowledges that the Tribes have identified an area that includes the project area, as a TCP. The BLM recognizes and understands that this identified TCP is of significant cultural and religious importance to a number of Tribes that have submitted comments on the Draft EIR/EIS for the proposed project.

A TCP may be eligible for listing in the National Register based on its “association with cultural practices or beliefs of a living community that (a) are rooted in that community’s history, and (b) are important in maintaining the continuing cultural identity of the community” (US Department of the Interior, National Park Service Cultural Resources, National Register Bulletin 38, Guidelines for Evaluating and Documenting Traditional Properties, page 1).

The first step in determining whether a TCP is eligible for inclusion in the National Register is to ensure that it is a tangible property. The second step in determining eligibility for the National Register is to assess “the integrity of the relationship between a property and the beliefs or practices that may give it significance” (Bulletin 38, page 9). In addition, the condition of the property must be such that the relevant relationships between a property and the beliefs or practices that give it significance survive (Bulletin 38, page 10).

After determining whether it is a tangible property, a TCP must, like all other potential historic properties, be evaluated against the four National Register criteria for eligibility:
(a) Association with events that have made a significant contribution to the broad patterns of our history;
(b) Association with the lives of persons significant in our past; (c) Embodiment of the distinctive characteristics of a type, period, or method of construction, or that represent the work of a master, or that possess high artistic values, or that represent a significant and distinguishable entity whose components may lack individual distinction; or
(d) History of yielding, or potential to yield, information important in prehistory or history.

Based on this guidance, for the purposes of the NEPA/NHPA process for this project, the BLM is assuming that the part of the TCP that is within the project’s area of potential effects (APE) is eligible for the National Register; that it has cultural and religious value to the Tribes; and that the part of the TCP that is within the proposed project’s APE will be adversely affected by the project should any of the project alternatives be approved. The BLM has selected this approach because it has not been provided enough information to date about the full extent of the TCP boundaries as currently mapped by the Viejas and other Tribes to apply any of the preceding criteria and to ultimately make a determination of the eligibility of the larger area for the National Register. The BLM is consulting with the Tribes, the ACHP, SHPO and other consulting parties to reduce and resolve project-related adverse effects to the TCP, to be documented in a Memorandum of Agreement developed to resolve the adverse effects identified for the project or alternatives.


Cultural Landscape
Several commenters assert that there exists a cultural landscape within the project area. Specifically, the Viejas Tribal Council and other Tribes contend that the project area is a part of a larger cultural landscape and TCP, which exists in the eastern part of San Diego County and western part of Imperial County (Comment EC6-c).

A Cultural Landscape has been defined as “a geographic area (including both cultural and natural resources and the wildlife or domestic animals therein), associated with a historic event, activity, or person or exhibiting other cultural or aesthetic values” (U.S. Department of the Interior, National Park Service, 1996, The Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for the Treatment of Cultural Landscapes, page 4). The same document states “there are four general types of cultural landscapes, not mutually exclusive: historic sites, historic designed landscapes, historic vernacular landscapes, and ethnographic landscapes” (page 4). An ethnographic landscape is then identified as “a landscape containing a variety of natural and cultural resources that associated people define as heritage resources. Examples are contemporary settlements, sacred religious sites, and massive geological structures. Small plant communities, animals, subsistence and ceremonial grounds are often components” (page 4).

The BLM acknowledges that resources identified through cultural resource investigations within the area of potential effects and through consultation with Tribes may indicate the potential for there to exist an ethnographic cultural landscape in and around the project site. As noted above, the BLM has only received general information about the significance of the identified landscape. Further, and more detailed, information about its components and boundaries is necessary in order to define and understand it properly in order to apply the applicable guidelines, even though the BLM generally recognizes the religious and cultural value that the Tribes attribute to the cultural landscape they have identified. The BLM continues to seek such information from the Tribes.

Districts

Several commenters assert that the archaeological resources recorded within the project area should be considered together as a district. Districts are significant concentrations, linkages, or continuities of sites, buildings, structures, or objects united historically or aesthetically by plan or physical development. Districts derive their importance from being unified entities based on the interrelationships of various individual resources. Examples of districts include business districts, canal or irrigation systems, estates and farms, industrial complexes, rural villages, transportation networks, residential areas, rural historic districts, and groups of habitation sites. According to the US Department of the Interior, National Park Service Cultural Resources, National Register Bulletin 15, How to Apply the National Register Criteria for Evaluation, a district “must be a definable geographic area that can be distinguished from surrounding properties by changes such as density, scale, type, age, style of sites, buildings, structures, and objects or by documented differences in patterns of historic development or associations.”

Although the Archaeological Survey Report (ASR) prepared for the project did not positively identify the archaeological resources recorded in the project area as constituting or contributing to one or more districts based on available information, the BLM acknowledges that further research may reveal the potential for a district or multiple districts to exist within the project area. Further research may also reveal that some of the archaeological resources within the project area may be part of a larger previously identified district, such as the In-Ko-Pah Gorge Discontiguous District; the Yuha Basin Discontiguous District, or a larger yet-to-be identified district, whose boundaries may extend outside of the project area. There is also a potential for the additions to the multiple property listing of the Earth Figures of the California-Arizona Colorado River Basin Thematic Group.

The County has determined that the BLM’s assumptions about the existence of a TCP and its eligibility for the NRHP do not require that the County treat it as a historical resource for purposes of the CEQA analysis in this joint document. (As used here, “historical resource” encompasses “archaeological resource” pursuant to CEQA Guidelines Section 15064.5.) CEQA confirms the County’s discretion to make a separate CEQA determination under the criteria set forth in the CEQA statute and Guidelines. The County has determined that the project site is not a historic resource under CEQA, and the following is a summary of the basis for the County’s determination. The assumed TCP is not listed on the CRHR , and has not been determined by the State Historical Resources Commission to be eligible for such listing, so the site is not a mandatory historical resource under CEQA Guideline 15064.5(a)(1). The assumed TCP also has not formally been determined to be eligible for the National Register, although BLM is assuming such eligibility for the purposes of its NEPA analysis. The site is not included in a local register of historical resources, so the site is not a presumed historic resource under CEQA Guidelines 15064.5(a)(2). The project site also is not a site that is significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California, so the site is not a discretionary historic resource under CEQA Guideline 15064.5(a)(3).

In making the determination whether the assumed TCP is a historic resource, the County has reviewed the information relating to whether the site has traditional, religious, and cultural significance as well as other information. For purposes of the CEQA analysis, the County as lead agency has determined that substantial record evidence supports a determination that the site is not a historical resource under the definition set forth in CEQA Guideline 15064.5(a)(3). The Tribes have not provided sufficient of tribal or ethnographic information about the use of this project site (historic or otherwise); in light of the paucity of information, the BLM has made a conservative assumption of eligibility as a TCP. In the County’s view, the paucity of information supports a finding that the site is not a historic resource. The claim that there is a significant cultural association with the project site has only arisen in the last several years. Some such use may be in response to the proposed project. In addition, the use and status of the site may be compared to that of the Spoke Wheel Geoglyph, a significant historic resource in the project vicinity. Therefore, based on the County’s review of the record, the County is making its discretionary determination as CEQA lead agency that the assumed TCP is not a historical resource for CEQA purposes.

[Vincardog]

18. There must be somewhere else to put them, we have a lot going up here in IA. No health

effects that I have seen. The objection to destroying heritage sites is valid,
they cannot protect everything but they have to minimize the cost.

[JoeyT]

20. The first sentence from the quote doesn't come as much of a shock.

"We believe that DOI is posed to violate the law and our rights to religious freedom and our cultural identities guaranteed by DOI’s own policies, the United States Constitution, and international declarations."

It isn't like their track record on that is particularly good. I mean, sure the government isn't actively eradicating tribes anymore, and they do at least pay lip service to pretending to care. Well, right up until someone with enough money turns up, then the lip service ends and it's time to shove the people aside and do whatever the money wants.

I am kind of shocked at how many liberals have decided that the wind farm has to go *right there* and American Indians and whatever holy sites left to them be damned. NIMBY indeed.