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And is not peace, in the last analysis, basically a matter of human rights the right to live out our lives without fear of devastation - the right to breathe air as nature provides it - the right of future generations to a healthy existence?1 As the world becomes more crowded and corroded by consumption and capitalism, this landscape of minimalism will take on greater signicance, reminding us... just how essential wild country is to our psychology, how precious desert is to the soul of America.2 PHOTO: Rusting wind turbines on the Big Island of Hawaii from failed decommissioning and land restoration promises. A long-lasting change in the view scape due to insufcient bonding and escrow of funds necessary to decommission and restore the site after the projects economically useful life. BACKGROUND

The Ocotillo Wind Turbine Project (http://theabf.org/

what_we_do/advocacy) will bulldoze approximately 42 miles of 20-foot roads3 to install and service 112 - 400+ foot turbines 4 on 15.8 square miles (10,151 acres) of relatively undisturbed, publicly-owned desert lands5 located in Imperial County, California (http:// www.icpds.com/?pid=2843) that is administered by the Bureau of Land Management (BLM) 6 of the US Department of the Interior (DOI);7

Ocotillo Express LLC, a wholly owned subsidiary of

Pattern Energy Group, LP (Pattern Energy; previously Babcock & Brown, LP North American Energy Group; http://www.patternenergy.com/) is the corporate owner operator for this project.8 San Diego Gas & Electric (SDG&E) is the purchaser of the energy produced by this project (http://docs.cpuc.ca.gov/PUBLISHED/ FINAL_RESOLUTION/157540.htm). The project is said to have a 30-year economic life. Pattern Energy claims that after this 30-year life, the wind turbines will be decommissioned and the desert landscape restored9 to its original condition.10

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From a 30,000 foot view, this project is deemed necessary to help California achieve its renewable portfolio standard (RPS) and greenhouse gas (GHG) reduction objectives, diversify the nation's energy supply, job creation, and the implementation of the Energy Policy Act (EPAct) "sense of Congress" direction to authorize the production of 10,000 MW of non-hydropower renewable energy on public lands by 2015;11

However from a local, birds-eye view, this project, and the many similar projects that will follow it on public lands surrounding the southern portion of Anza-Borrego Desert State Park (ABDSP; the Park) primarily in San Diego County, has severe aesthetic, cultural, and nonmonitized environmental impacts. Taxpayers are also paying for the projects construction.12

Due to the location of this site immediately contiguous to ABDSP, this land has been previously designated as MUC L land since 1980 under the California Desert Conservation Area (CDCA) plan. Under the CDCA Plan, multiple-use class L (Limited Use) land is designated as such to: protect sensitive, natural, scenic, ecological, and cultural resources values. Public lands designated as Class L are managed to provide for generally lowerintensity, carefully controlled multiple use of resources, while ensuring that sensitive values are not signicantly diminished. The status of this land has been changed by BLM, specically to accommodate this project. The May 11th DOI Record of Decision (ROD) amends the CDCA Plan to identify approximately 10,151 acres of public land within the Project footprint as suitable for wind energy development. The status was changed in a fast track without a transparent administrative process, economic impact analysis, or public comment period on the projects impact on the ABDSP;

In the 5,000 page Final Environmental Impact Statement (FEIS) and California Environmental Quality Act (CEQA) Environmental Impact Report (EIR) [http://www.blm.gov/ ca/st/en/fo/elcentro/nepa/ocotillo_express_wind.html] developed by Helix Environmental Planning (http://www.helixepi.com/) commissioned by Pattern Energy there is little economic analysis of the potential adverse economic and environmental impacts of this project on the ABDSP, its 500,000 to over a million annual visitors to this desert wilderness area, and the approximately $50 million in annual revenue to the region from these visitors to the Park;13

Neither Pattern Energy nor SDG&E have provided information necessary to verify that they have reserved adequate funds to decommission and restore this site after its economically useful life. Also, evidence has not emerged whether BLM and/or Imperial County has

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received a bond or insurance of adequate size to complete the decommissioning and restoration of this site should Pattern Energy fail or spin off the project prior to its useful economic life;14

The project sponsors have yet to provide evidence regarding the probable costs of adverse health impacts to the public in the path of dust storms occasioned by this project and its large-scale disturbance of soils, desert pavement,15 and cryptobiologic crust16 that may have formed over thousands of years;17

A consultant hired by Imperial County, Development Management Group, Inc. (http:// www.dmgeconomics.com/home), asserts that this project will deliver an estimated $48.89 million in property tax revenues to Imperial County over the thirty year life of the project. However, no independent, professional economic impact analysis has emerged that this revenue stream is sufcient to cover the potential long-term costs to taxpayers of California or to Imperial and San Diego counties.18

ECOLOGICAL & POLITICAL CONTEXT Desert ecosystems are fragile.19 This is because desert ecosystems are characterized by having low resiliency to perturbations.20 Essentially, a criticality is reached where a minute disturbance in one part of the ecosystem can shift or even crash the entire system.21 Once a system tipping point occurs, a cascading failure can result in massive changes to the existing biomes that make up the surrounding desert ecosystem.22 The political context is that this project fullls national energy policy and is strategic.23 It is assumed to be necessary in order to create jobs, to achieve critical policy goals, and to reverse the economic impacts of abrupt climate change. The California desert, from Washington, DC, is viewed as empty land, lying idle. For some, it is expendable for the greater common good. That may be one reason why the FEIS/EIR did not take into account the projects potential adverse environmental and economic impacts on the ABDSP. ANZA-BORREGO FOUNDATION (ABF) CONCERNS REGARDING THIS PROJECT

The proposed site is directly adjacent to the ABDSP along 5-miles of its boundary. The Park and the surrounding region possesses unique natural and cultural resources that are irreplaceable and of Statewide and National importance. Designated as a National Natural Landmark in 1975 and a Biosphere Reserve by the United Nations in 1985, two-thirds of the

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total acreage of the State Park or 460,000 acres is more than 80 per cent of the total California Wilderness Preservation System (CWPS), and it includes approximately 61 sensitive plant species, 86 sensitive animal species, 9 California Historic Landmarks, and over 5,000 cultural resource sites. The Park receives 500,000 to over a million visitors a year, who come to enjoy these features. The Park is a major contributor to the economic well-being of the region;

Under the fast tracking of the Ocotillo Express Wind Turbine Project there has been little analysis of the environmental and economic impacts to the Park. ABFs concern is to make certain that this is not just another energy project where prots go to the energy company (Pattern Energy Group, LP and SDG&E in this case) and ultimate adverse economic costs are born by the taxpayers of California and of Imperial and San Diego counties;

ABF believes renewable energy projects are too important for the nations energy future and to address the threats from abrupt climate change to treat the siting of these energy projects in such a cavalier manner as allowed by fast tracking.

What is necessary before the project proceeds further are: (a) full disclosure of the economics of this project. Pattern Energy is using public money and public land to develop this project but not telling the public what the ultimate economic costs will be; (b) assurance of the availability of capital for decommissioning and restoration of the site after 30-years; (c) funding of ongoing research and mitigation of the environmental impacts that Pattern Energys 5,000 page FEIS/EIR indicates may or may not occur; and (d) assurance that SDG&E, in their Power Purchase Agreement with Pattern Energy, is not using ratepayer funds to subsidize this project;

Rationale for these assurances before the approval and start of this project: In some current cases of federal and state permits for fracking, mountaintop removal, nuclear power plant siting, thermal coal electricity plant siting, solar and wind farms, and offshore oil drilling, these projects have ultimately proceeded by privatizing prots and ofoading economic costs of the project to the public.

ABFs PROPOSAL FOR MOVING FORWARD WITH THIS PROJECT

A remedy to the present fast tracking of the industrialization of Californias desert lands is the following: (a) an immediate moratorium on the fast tracking process starting with the

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Ocotillo Express Wind Turbine Project;24 (b) require this project put $10 million in an escrow for scientic research and monitoring regarding the environmental impacts to the ABDSP and protected desert lands,25 managed by a neutral third party;26 (c) eliminate any SDG&E subsidies to the project and warrant against hidden future subsidies;27 and (d) escrow and bond sufcient funds to restore the site after its useful economic life to a given standard, conrmed by a neutral third party with set automatic penalties for non-timely compliance by Pattern Energy, SDG&E or any entity that has subsequently assumed ownership.28 Anza-Borrego Foundation (ABF) is the nonprot cooperatingassociation for Anza-Borrego Desert State Park. We acquire land for conservation in and around the Park (50,000 acres to date), educate the public onits resources, and support research relevant to our region. ABF has approximately 1,400 members. Anza-Borrego Desert State Park is the largest state park in California covering 600,000 acres of southeast California from the edge of the coastal mountains east to the Salton Sea and south almost to the US/Mexico border. The elevation ranges from 6,200 feet to just 150 feet.Twelve wilderness areas and many miles of hiking trails provide visitors with an unparalleled opportunity to experience the wonders of theunspoiled California Desert. The park features washes, wildowers, palm groves, cacti, and sweeping vistas. Visitors may also have the chance to see roadrunners, golden eagles, kit foxes, mule deer, and bighorn sheep as well as iguanas, chuckwallas, and the red diamond rattlesnake.

QUESTIONS AND ANSWERS Does ABFs opposition to this green energy wind-power project mean that it is opposed to renewable energy? No. ABF is entirely supportive of sustainable renewable energy projects. Although this project is a renewable energy project, we do not believe it is sustainable in that it neither takes into account the long-term economic nor the environmental costs of the project on the California desert landscape. It is entirely unclear whether, due to the long-term adverse economic and environmental impacts of this project that have not yet been presented either to the decision makers or to the public to date, that it will ever produce one net kilowatt hour (kWh) of sustainable green energy. Isn't ABF's opposition just another not-in-my-back-yard (NIMBY) ght? No. However, the project is in ABFs backyard. That is one reason why we are commenting on it. If this project made economic and environmental sense, ABF would be willing to support it. However, based on the
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data that has been developed so far by BLM, other government agencies, and Pattern Energy, ABF believes that this project makes neither economic nor environmental sense. That is why we oppose the project. If this project is so bad for the Park, why isn't the Park ghting the project itself? You will need to contact the ofce of the California State Parks to answer this question. Their contact information can be found at: http://www.parks.ca.gov/. Isnt creating local jobs more important than saving a few acres of desert? No. Both are important. The ABDSP is a major economic generator for the entire region. It makes absolutely no sense to threaten this revenue stream to create a few temporary jobs. If this project goes ahead, can the desert actually ever be restored to its original condition? Not really. The soils, desert pavement, and the cryptobiologic crust may have formed in the deserts over thousands of years. Sometimes, like in the Desert Cahuilla Area, the cyrotobiotic crust can be 10,000 years old. The plant and animal community have evolved together over long periods of time also. Much of the proposed development area is an alluvial fan. Scraping and road building over such a vast area will likely also cause disruption on lands and hydrology off-site, as well on the proposed development site. Does this mean that under any conditions should no development occur on the site? Not necessarily. As long as the actual costs of restoring the site to an acceptable standard are calculated in the projects business plan and those funds are escrowed and/or bonded so that restoration can actually occur without end-of-project litigation or the transfer of the economic costs of decommissioning and restoration to the taxpayers of California of Imperial and San Diego counties. However, these actual site restoration costs and assurances of an up-front fund to pay these restoration costs have not been developed and contractually obligated to date. ENDNOTES:
1

President John Fitzgerald Kennedy, Commencement Address at American University (June 10, 1963), quoted in James W. Douglass, JFK and the Unspeakable: Why He Died and Why It Matters (New York: Simon & Schuster, 2008), 45.
2 3

Terry Tempest Williams, RED: Passion and Patience in the Desert (New York: Pantheon Books, 2001), 6.

The project would include construction of 42 mi of roads for access to the O&M building and each turbine. Access roads would be cleared of vegetation and graded. Permanent road width would be 20 ft. During construction, these roads would be enlarged to 36-ft wide to facilitate access by the large tracked cranes used in turbine erection.
4

Actually, between 428 and 448 ft, depending on the type of rotor blades that are used. The project will generate up to 315 megawatts (MW) of electricity using a combination 1.6 to 3.0 MW wind turbine generators.

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5

The project site occurs in a designated BLM limited use area in which motorized vehicles are restricted to designated routes of travel. Most of the project site is relatively undisturbed. Surrounding land uses outside the action area include ABDSP to the north and west and BLM-administered land to the north, east, and west. The Coyote Mountains Wilderness Area is located to the north, the Jacumba Wilderness Area is to the south, and the Yuha Basin Area of Critical Environmental Concern occurs to the southeast.
6

The Bureau of Land Management (BLM) is responsible for management of public lands and resources for present and future generations. All surface management activities, including reclamation, must comply with all pertinent Federal laws and regulations, and all applicable State environmental laws and regulations. The fundamental requirement, implemented in 43 CFR 3809, is that all public land use under Plan of Operations or Notice on the public lands must prevent unnecessary or undue degradation. The Plan of Operations and any modications to the approved Plan of Operations must meet the requirement to prevent unnecessary or undue degradation. Authorization to allow the release of efuents into the environment must be in compliance with the Clean Water Act, Safe Drinking Water Act, Endangered Species Act, other applicable Federal and State environmental laws, consistent with BLMs multiple use responsibilities under the Federal Land Policy and Management Act and fully reviewed in the appropriate National Environmental Policy Act (NEPA) document. Among other provisions, the law established a general national policy that BLM-managed public lands be retained in federal ownership, established management of the public lands based on the principles of multiple use and sustained yield, and generally required that the federal government receive fair market value for the use of public lands and resources. For wind energy facilities on BLM lands, the BLM completed a nal PEIS (January 2006) supporting land management plan amendments providing for wind energy development in the western states. On December 19, 2008, BLM issued its updated wind energy development policy. As of May 2010, the BLM has authorized 206 rights-of-way to develop wind power on public land.
7

The project site is in the Yuha Desert, which is in the Colorado Desert portion of the larger Sonoran Desert. This region is characterized as a hot and dry climate with summer high temperatures up to 120F and less than 3 inches of annual rainfall (ASDM 2010). Elevations in the project site range from approximately 1,490 ft above mean sea level in the southwest portion of the project site to 300 ft elevation in the northeast portion of the site. Elevation generally decreases from the west to the east. The project site is dominated by desert scrub assemblages of brittlebush (Encelia farinosa), cheesebush (Ambrosia salsola), creosote bush (Larrea tridentata), teddy-bear cholla (Cylindropuntia bigelovii), white bursage (Ambrosia dumosa), and Wolfs cholla (Cylindropuntia woli). Other community components include desert agave (Agave deserti), desert lavender (Hyptis emoryi), four-wing saltbush (Atriplex canescens), mesquite, ocotillo (Fouquieria splendens subsp. splendens), smoke tree (Psorothamnus spinosus) woodland, and badlands.
8

Pattern Energy (http://www.patternenergy.com/) is owned by Riverstone Holdings LLC (www.riverstonellc.com). Pattern Energy was formed from the management team of Babcock & Browns North American Energy Group when Babcock & Brown, an Australian infrastructure investment group, declared bankruptcy in 2009 (http://www.smh.com.au/business/watchdog-didnt-even-sniffbabcock-20110831-1jm01.html#ixzz1qTudRe5Z). Pattern Energy retains the Babcock & Brown North American energy development team, which has successfully developed, nanced and placed into operation 2,000 MW of wind power capacity in 11 states. Pattern Energy also maintains the current Babcock & Brown development pipeline that exceeds 4,000 MW of wind power capacity in 11 states and 4 countries in addition to several power transmission projects.

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9

A restoration plan might include the following objectives: restore disturbed plant communities and range and wildlife habitat to species composition and vegetation cover similar to those found in adjacent areas undisturbed by project activities; restore hydrology to support functions similar to pre-construction conditions; restore native plant cover and control invasive non-native species in areas highly susceptible to invasion, but as yet not dominated by these species; incorporate construction and reclamation BMPs and revegetation measures to stabilize soils and prevent increased erosion and sedimentation and other potential soil-related problem areas disturbed by project activities; incorporate non-linear (e.g., sinuous) construction pathways, minimization of vegetation removal, or other visual impact minimization measures where feasible.

10

Testimony by Hunter Armistead, Executive Director, Pattern Energy Group at the Imperial County Supervisors public hearing regarding this project on April 24, 2012. Unfortunately, this statement has not been backed up by either contractual terms with BLM nor with an escrow or bond requirement to make certain that this statement can be implemented after 30-years. Thus, at present, this statement is mostly meaningless. Generally, restoration of desert lands means to replant and restore the diverse desert vegetation affected or destroyed by the land use activity. When Pattern Energy leaves the site, it will be in a safe condition that doesn't pose a hazard to humans or wildlife, interfere with water ows, or create dust. Over time, as vegetation is reestablished, the disturbed areas will closely resemble its original state.
11

See DOI Record of Decision available at: http://www.blm.gov/pgdata/etc/medialib/blm/ca/pdf/elcentro/ nepa/ocotilloexpress.Par.35134.File.dat/Ocotillo%20Signed%20ROD.pdf. Carbon dioxide and other greenhouse gases from burning fossil fuels are the primary anthropogenic causes of global warming. Global warming has resulted in the melting of glaciers, sea level rise, ocean acidication, crop failure and the increased variability of weather patterns that has resulted generally in more frequent, longer, and more severe droughts, along with more frequent and severe ooding.
12

"Up to two-thirds of the value of a wind project may derive from federal programs and tax subsidies, as the revenues from the sale of power may not be sufcient to pay for the project development and operating costs. These tax subsidies include combinations of accelerated depreciation, production tax credits (PTCs), investment tax credits (ITCs), federal cash grants and federal loan guarantees (North American Windpower (June 2009). "Federal tax benets pay as much as 65% of the capital cost of wind power projects in the United States" (Keith Martin, Chadbourne and Parke, LLP, Financing Wind Power conference, Dec. 3-5, 2003, New York, NY).
13

Of particular concern are reports that Governor Jerry Brown muzzled California State Parks for providing important and necessary testimony on the adverse impacts of this project on the ABDSP. Unfortunately, this muzzling, if it occurred, might be considered an impermissible gift of public funds if the result of not having this input from the Park is to transfer costs from Pattern Energy to the public.
14

Some experts believe that the desert land disturbed by this project cannot be restored at any cost. Others claim that restoration can occur at little or no cost. Unfortunately, no independent analysis of the costs of restoration has been developed, nor restoration to an agreed upon standard considered. All is left to future discretion with the hope that whatever the cost may be can be paid, with no assurances that this cost will not be ultimately born by the taxpayers of California and of Imperial and San Diego counties.

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15

Desert pavement is a nonbiological sorting of the surface of arid desert soils into small pebble-sized interlocked rock fragments due primarily to wind erosion. See http://www.agc.army.mil/research/products/ desert_guide/lsmsheet/lspave.htm. Sometimes desert pavement is coated with desert varnish, a darkcolored coating consisting primarily of clay minerals with oxides of iron (Fe) and manganese (Mn). See http://www.agc.army.mil/research/products/desert_guide/lsmsheet/lsvarn.htm.
16

Cryptobiotic soil crusts are specialized communities of cyanobacteria, mosses and lichens that form on the surface of arid desert soils over long periods of time. The value of these crusts are that they hold soils in place and protect the underlying sediments from erosion. They are also an important pioneer stage in succession on bare ground, often enabling grasses and herbs to become established. Scraping the desert of these cryptobiotic crusts promotes erosion and inhibits future plant growth. See http:// waynesword.palomar.edu/crypto1.htm#.
17

Dust storms can carry large amounts of soil bacteria, viruses, and fungi of aerosol size hundreds and sometimes thousands of miles that lodge in human lungs. About 10% may cause human diseases. For example, airborne bacteria can include human pathogens that cause severe respiratory and other illnesses that especially affect the young and adults whose immune systems are compromised due to previous illnesses. The dust of the southern California desert often contains the soil fungus, Coccidioides immitis that spreads valley fever, a severe respiratory disease. See Howard G. Wilshire, Jane E. Nielson, and Richard W. Hazlett, The American West at Risk: Science, Myths, and Politics of Land Abuse and Recovery (Oxford & New York: Oxford University Press, 2008), 47-8, 460 footnote #25.
18

If it is true, as some allege, that construction costs will be borne by federal taxpayers, decommissioning and land restoration costs will be born by Imperial County and California taxpayers, and cash ow from the sale of energy to SDG&E will go all to Pattern Energy, this is something that the public needs to understand. If this is the case, this is a money-for-nothing project where prots are privatized and costs go to the public. Full disclosure of the economics of this project and independent economic analysis is required to determine if this project makes any economic sense at all for the public taxpayer.
19

To date, all studies point to the conclusion that the soils disrupted by projects similar to the Ocotillo Express Wind project may take a century or more to regain normal soil densities and healthy plant coverage. See Wilshire, Nielson & Hazlett, 143, 148, 155-6, 163.
20

Systems are resilient if, under stress, they can reorganize themselves and continue to function. Resilience is the capacity of a system to absorb disturbance and reorganize while undergoing change so as to still retain essentially the same function, structure, identity, and feedbacks. See Brian Walker, C.S. Holling, Stephen Carpenter, and Ann Kinzig, Resilience, Adaptability and Transformability in SocialEcological Systems, Ecology and Society 9, no. 2 (2004): 5. Available at http:// www.ecologyandsociety.org/vol9/iss2/art5/print.pdf quoted in Thomas Homer-Dixon, The Upside of Down: Catastrophe, Creativity, and the Renewal of Civilization (Washington, DC, Island Press, 2006), 398, # 62.
21

See Per Bak, How Nature Works: The Science of Self-Organized Criticality (New York: Oxford University Press, 1997), 1-3.

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22

All tipping points involve a point of no return, a system state beyond which the consequence is inevitable, even if system forcings are reduced. Points of no return are inherently difcult to dene, because the dynamical problems are nonlinear. See James Hansen, et. al., Target Atmospheric CO2: Where Should Humanity Aim? For example, in places where annual rainfall may increase by 20 percent as a result of climate change, the groundwater might increase as much as 40 percent. Conversely, the analysis showed in some cases just a 20 percent decrease in rainfall could lead to a 70 percent decrease in the recharging of local aquifers -- a potentially devastating blow in semi-arid and arid regions. See Water supplies could be strongly affected by climate change, at http://web.mit.edu/newsofce/2008/agugroundwater-1218.html (accessed 12/18/08).
23

The big picture: seehttp://www.guardian.co.uk/environment/2012/apr/25/governments-catastrophicclimate-change-iea?intcmp=122.

24

For example, this delay of approval for the project can be put to good use by updating the FEIS/EIR to include potential mitigation of adverse environmental and economic impacts to the ABDSP and to address the shortcomings in the Biological Opinion (BO) of the US Fish & Wildlife Service (USF&WS) as discussed in Mark C. Jorgensens Comments on the BO of the USF&WS (May 2, 2012).
25

For example, the proposed project could degrade Peninsular bighorn sheep (protected under the Endangered Species Act) habitat through the introduction of nonnative plant species. Nonnative plants are generally lower quality forage for bighorn than natives. Nonnative species have the potential to outcompete native species, thereby potentially altering the quality of forage available for sheep. Invasive nonnative plants, particularly grass species and Sahara mustard (Brassica tournefortii), also can alter the natural re regime of the area, primarily through increased frequency and intensity of res. Additionally, the USF&WS appears to have arbitrarily de-designated critical habitat for this endangered species from 800,000 acres to the current 370,000 acres. For example, the Steele/Burnand Anza-Borrego Desert Research Center, University of California.
27

At present, the economics of the Power Purchase Agreement between Pattern Energy and SDG&E has not been revealed to enable a third party verication that such an impermissible subsidy is anticipated.
28

Presently, the decommissioning plan would be submitted to the BLM for review and approval only prior to a closure of the project site. At BLMs discretion, roads would be removed. All roads and tower pads would be restored in accordance with the BLM- approved decommissioning plan. However, it appears that all permits and legal agreements presently do not contain requirements of an up-front bond or escrow to cover the costs of decommissioning and restoration of the site. This has been a long-standing problem with energy projects as the tendency has been to spin the project off to an undercapitalized entity close to the end of the projects useful economic life to avoid the costs of decommissioning and land restoration.

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Renewable Energy Projects Proximate to Anza-Borrego Desert State Park and Cuyamaca Rancho State Park
Riverside County San Diego County

Salton Sea
Avalon Development NRG Borrego Solar One

Y
Imperial County

Eurus Energy

Y W
Julian

Borrego Springs

A
EnXco

A
CACA 050636 Chariot

Anza-Borrego Desert State Park

CACA 049613 solar project Project Denied CACA 049150 Superstition Solar1

CACA 050635 Sawtooth/ National Quarries

Cuyamaca Rancho State Park

A
Descanso

W $ _ " !

CACA 049698 Tule CACA 045248 Tule/Iberdrola Manzanita Wind Campo Wind

CACA 047518 Ocotillo Express Palm Cyn Wash

CACA 048004 Renewnergy LLC

$ _ " !
CACA 051552 Ocotillo Express CACA 050916 Ocotillo Express Sugarloaf

CACA 047740 Imperial Valley Solar

CACA 050485 Debenham-MIller Basin

Jordan/Padoma Wind

MEXICO

Commodity Solar Energy Facilities Wind Energy Facilities

Anza-Borrego Desert State Park Jacumba Eade acquisition project Cuyamaca Rancho State Park

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0 5 10 15 20 Miles

Project areas approximate and accurate to the best of our knowledge as of date of creation. sources: USBLM (http://www.blm.gov/ca/st/en/fo/cdd/alternative_energy.html)

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