Unintended Consequences ? 

EPA’s

Good Neighbor Environmental Board, 

June 16, 2011 ~ San Diego 

Donna Tisdale

Any errors or omissions are unintentional
Community Activist 

Life-long Border Resident

• Born and raised in Brawley, an Imperial Valley farming community

• 34 year resident of Boulevard, CA, at Morning Star Ranch 2 miles from US/ Mexico 

border in Eastern San Diego County / abutting Campo tribal lands.

• Volunteer Community activist for over two decades 

• Chair, Boulevard Community Planning Group, (1990-present ~ elected advisory 

land use group for San Diego County)

• Co-Founder and President, Backcountry Against Dumps, (1989 –present~ nonprofit )

• Secretary, The Protect Our Communities Foundation, (2009 to present ~ nonprofit) 

Work with diverse interests, groups, agencies, decision makers, and residents ,including tribal members,

to protect and defend rural lands and resources from inappropriate and unsustainable development.
Environmental Justice Issues:

Rural Low-Income border communities 

in Eastern San Diego and Western Imperial Counties

disproportionately impacted 

by large-scale renewable energy projects

• Boulevard, CA: population 1,496 

Per capita income: $17, 213

18 % Hispanic ~ 10.7 % Native American ~ 29% Disabled ~ 23 % Veterans 

• Jacumba, CA: population 695 

Per capita income: $13, 704

35% Hispanic ~ 28.9% Disabled ~ 22.9 % Veterans 

• Ocotillo, CA: population 454 

Per capita Income: $17,092

23.6 % Hispanic ~ 41% disabled ~ 38% Veterans

Per 2000 Census
Rural border communities are on an unwanted Fast Track 

for transformation into industrial energy zones 

to serve distant cities

• No industrial zoning—No problem.

• Federal agencies are unlawfully down-zoning previously protected 

public lands that were zoned to protect critical resources

• No water—No problem.

• State and federal agencies just sign overriding considerations that 

impact sole source aquifers and other vanishing desert water.

• Sensitive biological / cultural resources / endangered species in 

the way—No Problem.

• Understaffed tribal offices, often volunteers, are bombarded with 

project applications and calls for cultural consultations. Sadly, 

consultation often comes after the project has been approved in 

violation of NHPA.
Border Area Industrial Renewable Energy Projects:

Partial list with Direct and Indirect costs

Wind and solar projects each require new gen-tie lines and substations 

most impact private rural land

 $2 billion: SDG&E's Sunrise Powerlink (unresolved state & federal litigation )

 $2 billion: Tessera’s Solar Two /Stirling Dish (Ocotillo /Plaster City) (injunction/unresolved litigation) (K-Road new owner)

 $500 million: Tenaska’s Imperial Solar Energy Center South (PV/CPV) (DOE loans on hold)

 $500 million: Tenaska’s Imperial Solar Energy Center West (CPV) (DOE loans on hold)

 $500 million: Soitec CPV manufacturing plant in San Diego 

 $285 million: SDG&E's proposed ECO Substation (Jacumba/ Boulevard ) (CPUC Permit to Construct –Protested)

 $400 million: Iberdrola’s Tule Wind (Boulevard) (FEIR/EIS /MUP pending) (Golden Eagle /cultural resources)

 $500 million: Invenergy’s Shu'luuk Wind on Campo tribal land (Boulevard)

 $300 million plus: Enel Green Power’s 158 MW Jewel Valley Wind and 10 MW solar project (Boulevard) 

 ?? ?$ million: Sempra’s Energia Sierra Juarez Cross-border Gen-tie at ECO Substation (Jacumba)

 $630 million: Pattern Energy’s Ocotillo Express Wind (Ocotillo) 

 $??? Million: Pattern Energy’s Kitchen Creek Wind (Forest –west of Boulevard)

 $3.5 billion: SDG&E's proposed smart grid to accommodate renewable energy and backup generation. 

 $???million: SDG&E’s Power Purchase Agreement for Phase I of Sempra’s 1,250 MW Energia Sierra Juarez

 $1.8 billion: SDG&E's Power Purchase Agreements for 450 MW of new gas-fired peaker-power to backup 

intermittent wind and solar energy (San Diego) 

Some unavailable project costs are estimated / Wind costs average $2 million per MW
Large-scale projects include expansion plans / 

importation of energy 

• SDGE’S $300 million ECO Substation at Jacumba is designed to accept up to five 

cross-border 500 kV lines to import energy from Sempra’s 1,250 MW Energia Sierra Juarez 

Wind project immediately south of the Jacumba Wilderness in Baja.

• The IBEW has opposed the importing of energy and exporting of jobs 

• The $2-3 billion 500 kV Sunrise Powerlink will further expand north, to 

L.A. and beyond, through sensitive areas of the Cleveland National Forest.

• SDGE’s Imperial Valley Substation is planned for an additional dozen or so 

new lines within the Yuha Desert ACEC and FTHL Management Area. 

• Many if not all of these expansions, and impacts, will run through the 

same impacted rural communities—spurring even more industrial growth
Renewable energy land rush ~ not so green from rural 

front line impact zones

• The scraping of tens of thousands of acres of sensitive public land and in tact 

habitat increases erosion, dust storms, and respiratory diseases

• Much of the impacted area has already been scientifically identified as globally 

significant and rare Mediterranean mosaic with abundant wildlife and critical 

wildlife corridors.

• Groundwater will be siphoned off from stressed desert aquifers that feed our 

wells. Our communities have no alternate affordable water source.

• Billions of dollars are being redistributed from tax and utility rates payers to for 

profit corporations, many are foreign owned.

• We have Spanish, Italian, German, Irish, US, French, German, and multi-national 

corporations hard at work lobbying decision makers and the media, behind closed 

doors, to marginalize and discredit our on-the-ground knowledge and efforts at 

self defense. 

• Critics have even been falsely accused of violence and threats of violence in 

attempts to discredit and marginalize them. Developers are undermining and 

gutting our land use and community plans and protections, and the value of our 

investments in our homes. 
Imperial Valley

No compliance – No problem

• Highest rates of unemployment and asthma.

• No Farmland Conversion Policy for renewable energy.

• Clearing tens of thousands of acres of desert land & removing farmland from 

production and irrigation increases levels of PM10 and exposure to Valley Fever.

• 948 acre-Imperial Solar Energy Center approved:30-40 year conversion of prime 

farmland, only 4 full time jobs, only $30-80k annual benefit, concerns from staff, 

and objections from Farm Bureau and Ag Commissioner.

• Export of desert groundwater approved from controversial well located within EPA 

designated Ocotillo/Coyote Wells Sole Source Aquifer (in documented overdraft) 

for the 6500 acre SES Solar Two Stirling Dish project and hydrogen production 

plant. 

• Export of water from same well for construction of Sunrise Powerlink through BLM 

lands / despite SDG&E promise not to use groundwater.

• CEC staff commented on County’s failure to comply with their own zoning, land 

use plans, and ordinances in Solar Two EIR/EIS process—before the Commission 

approved overriding considerations.

• Cultural consultation was started after project approval just like Sunrise Powerlink
Solar Two site in Imperial Valley

Lush desert wash/ forage for 

bighorn sheep...

Area proposed from transformation 

into industrial solar factory
Wildlife impacts

• Golden Eagles ~ considered sacred by some Kumeyaay clans as part 

of their creation stories

• Flat Tailed Horned Lizards

• Reintroduced Condors

• Wide variety of raptors, bats, song birds

• Bighorn Sheep

• Flat Tailed Horned Lizards

• Mountain Lions

• Bob cats and much more...

• Where are the big predators expected to go?
Nothing is sacred—not even sacred sites!

• Native Americans that I work with are shocked, alarmed, and outright angry at the scale 

and scope of impacts to cultural resources from many massive projects. 

• Critical resources, heritage, and legacies are being lost, damaged, destroyed, or 

removed, on a massive scale. These resources qualify and should be designated as 

Properties of Religious and Cultural Importance.

• Village sites, ceremonial sites, burial and cremation sites, traditional cultural properties 

and landscapes, are all at risk.

• Culturally significant landscapes and sense of place are being forever altered for 

renewable energy projects that should, instead, be built on new and existing structures 

and already disturbed lands close to the point of use. 

• BLM’s unjustified and unlawful down-zoning Plan Amendments and Fast-tracking of 

these destructive projects is especially galling and inexcusable.
Boulevard



Cumulative projects map: 25 existing Kumeyaay turbines

about 400 turbines planned for Boulevard, over 150 for Ocotillo, 

and over 60 miles of turbines in Baja—for export to California

Ocotillo

Jacumba

Ejido Jacume
Concentrated turbine projects 

cannot meet safe setbacks 

• Most experienced health, noise, sleep, and other medical and scientific 

experts, investigating wind turbine impacts, recommend a bare minimum 

1.25 mile setback with 2 miles or more in hilly open terrain like ours—to 

protect public health and safety.

• The cumulative projects map shows that our rural communities and 

homes will have turbines on multiple, if not all, sides at much less than the 

setbacks recommended for public health and safety.

• Impacted residents, deeply resent it when developers repeatedly say that 

turbines are as quiet as your refrigerator, and they don’t cause health 

problems, or impact wildlife, or property values.
Industrial Wind /Solar 

community issues/concerns

• Cumulative impacts from multiple projects in condensed targeted areas surrounding 

rural low-income communities.

• Industrial conversion of public lands adversely impacts recreation areas and tourism 

dollars for economically depressed rural communities

• Adverse impacts to fragile desert aquifers / designated sole source aquifers that rural 

communities rely on.

• 30-40 year conversion of prime farm land and farmland into industrial solar zones IN 

VIOLATION of the Farmland Protection Act– is called temporary and insignificant. It is 

neither.

• High levels of Noise and/or Electrical Pollution generated by wind turbines, solar 

inverters, transformers, substations, transmission lines, communications, smart grid. 

• Intermittent energy generates dirty electricity. IEEE has proposed two new standards 

for injecting harmonics into grid and how EMF is measured—environmental safety 

noted. 

• Exposure to EMF/RF has been linked to a variety of illnesses and cancer. Read Dirty 

Electricity by epidemiologist Samuel Milham, MD, MPH.

• Property value impacts are real, documented, and denied by industry, their hired guns, 

and those suffering from the “hear no evil, see no evil, speak no evil” syndrome. 
In 2005, no one opposed the

50 MW Kumeyaay Wind project built on tribal land 

until the turbines started turning and the reality of living with turbines hit home ... 

Kumeyaay Wind’s Unexplained catastrophic failure ~ December 2009: 

witnesses saw blue light ball arc out to all 25 turbines ~ off-line about 4 months ~

All 75 blades, rotors, electronics were replaced

Calls for an investigation have been ignored by Secretary Salazar .

NEPA scoping is being conducted, now, for another 125 turbines for Shu’luuk Wind

photo from San Diego Union Tribune
Industrial wind turbines 

are not good neighbors.

Industry reps say 700 - 1,000 feet setback is OK. 

It is not OK for those families subjected to what they describe as 

sheer torture.
Kumeyaay Wind turbines are spaced too close, generating more 

turbulence & impacts

complaints include:

Sleep disruption, heart trouble, ear & sinus pain, blood pressure, blood sugar, 

vertigo, anxiety, migraines, confusion, cognitive, feelings of unease, and at least 2 

suspicious cancer cases in tribal homes near the wind project substation.
Kumeyaay Wind turbines, 

installed on leased Campo tribal lands, loom over the

home of impacted Manzanita tribal members. 

The 25 turbines are owned by an Australian company and operated by a company 

from Texas
Turbine wake turbulence

increases noise and infrasound pollution.

More turbines result in more turbulence...
A growing body of evidence is being

gathered from wind energy victims around the globe—despite a 

blatant lack of support or help from their own government agencies 

that are busy supporting the project developers

• Like MTBE that was meant to improve air quality but poisoned groundwater instead, adverse 

impacts from not-so-green industrial wind turbines were either unintended, unrecognized, 

under estimated, or just plain swept under the rug by the industry and their cheerleaders.

• Communities have been left to fend for themselves, while local, state and federal 

governments lavish generous cash grants, tax breaks and credits, property and sales tax 

reductions or exemptions, renewable energy credits, and more... 

• These hulking and pulsing 40-50 story tall generators emit audible and low frequency noise, 

infrasound, dirty electricity, and flashing light pollution that negatively impacts people, pets, 

livestock, and wildlife in unnecessary and unacceptable ways. 

• Some families have had to abandon their homes to regain their health. Some were forced to 

sign gag-orders as a condition of having the offending company buy them out at reduced 

prices. The loss or sale of these homes rarely make it into industry property value studies.

• The stories from impacted turbine neighbors are the same, regardless of what part of the 

world they live in. It is a matter of physics.

• Massive solar projects can include tens of thousands of tracking buzzing modules that can 

stand 20-40 feet tall. Inverters, substations, remote control systems, and other equipment 

also generate high levels of EMF/RF
contrary to industry claims

CUMULATIVE ADVERSE IMPACTS are a reality

• Adverse health effects / Quality of life: low frequency noise, infrasound, shadow flicker, 

dysfunctional aviation lights, dirty electricity EMF/RF pollution from turbines, power lines, substations, 

project communication towers. Some homes have had electrical pollution compared to microwave ovens. 

Kumeyaay Wind turbines impact residents 3 miles away and more. Ocotillo and Boulevard will be 

surrounded by hundreds of turbines with no way to protect our residents.

• Increased Class I Fire risk in high-fire severity zone . Joint state / federal documents confirm 

this unmitigable risk. San Diego Gas & Electric wants to cut power to rural communities when the wind 

blows too hard to prevent fires, but continue to run power through on big lines.

• Volunteer Fire Departments: underfunded, under-equipped, under-trained, and understaffed. Limited mitigation dollars for big projects like Sunrise Powerlink go to fire districts that don’t serve 

us, or spend the money elsewhere. Turbines and substations represent new and cumulative risk.

• Property Value Losses: Denied by industry and front men. Losses confirmed by licensed 

appraisers, average up to 40% with some properties a total loss and abandoned due to adverse impacts 

and lack of buyers. Enforceable Property Value Guarantee Agreements are needed but resisted by 

developers.

• Increased utility rates & fire insurance Fire insurance is already hard to secure and 

expensive since 2003 & 2007 fire storms –some sparked by SDG&E’s power lines. Some homeowners 

cannot secure insurance at any price. At least one Boulevard homeowner has to buy insurance through 

Lloyd’s of London and have been told that the policy will be cancelled if wind turbine projects move 

forward in their Boulevard neighborhood as planned.
Boulevard’s Ruggedly Beautiful Mc Cain Valley 

Resource Conservation & Recreation Area

attracts tourists that help support local businesses.

Illegally down-zoned by BLM to accommodate Iberdrola’s 200 MW Tule Wind, 

and a new utility corridor for Sunrise Powerlink—where no power lines exist

Previously protected for visual, biological, and cultural resources / sacred site
The little house in the foreground belongs to Boulevard couple in their 80’s. Tule 

Wind turbines are planned on the ridgeline behind their home of 40 years. 

That ridge is part of the Lark Canyon OHV Park. Turbines will be installed inside the park and within 

about 1,000 feet of this home, and Lark Canyon & Cottonwood Campgrounds. Acousticians tell us that 

rugged terrain like this increases the adverse impacts of low frequency noise from turbines.
Turbines do represent hazards,

so why are they being proposed for public recreation areas, 

campgrounds, fire-prone sensitive wild lands, and adjacent to 

homes, tribal offices, public and private roads, and high voltage 

power lines ?
German turbine fire reportedly caused by electrical fault.

We don’t need this happening in our fire-prone backcountry.
Boulevard, Jacumba , and Ocotillo are not equipped, staffed, or funded to deal with these 

massive and high risk industrial energy structures / projects

Especially the high concentration clusters that we are facing
Iberdrola’s Rugby Wind Farm: 

A failed turbine rotor assembly 

crashed with all 3 giant blades still attached.

It failed on March 14th – just five months after installation 

Each blade weighs about 7 tons

Iberdrola wants to install turbines in McCain valley 

within 900 feet of homes, campgrounds, and inside an OHV Park.
Enel Turbine Collapse, Fenner, NY 

Still under investigation. 

Enel wants to install almost 80 turbines on absentee owned ranch land 

extremely close to many Boulevard homes. 

For perspective, See tiny people standing at base of turbine.
Requested GNEB recommendations:

• Focus efforts on energy conservation and point of use renewable energy projects that do not 

need extensive and invasive infrastructure upgrades and eminent domain. There are many 

examples, including universities like UCSD our own military bases that are creating micro 

grids for security and reliability.

• Stop the Fast Tracking and subsidized funding of these bloated large-scale projects, the use 

of priceless and irreplaceable desert groundwater, and the destruction of sensitive habitat, 

cultural resources, and virtually defenseless rural communities.

• Listen to and support impacted residents and communities —instead of blindly adopting 

industry bias as gospel and dismissing valid claims and evidence as NIMBYism.

• Urge the initiation and funding of unbiased third party peer-reviewed full-spectrum noise , 

electrical , and health studies—using the scientific method and the right measuring tools. 

• Support a moratorium on wind turbine projects within a minimum 2 mile radius of occupied 

buildings, sensitive receptors ,and non-participating property lines, until valid dose response 

peer reviewed studies have been completed.

• Help impacted tribal residents who are suffering now from the Kumeyaay turbines but 

cannot move away and may even be prevented from speaking out about adverse impacts 

from projects that do, or are expected to, generate revenue for their tribal government. 

Tribal benefits and jobs can be withheld to control the actions of individual members. The 

Bureau of Indian Affairs, Indian Health Services and Housing Authority do have independent 

trust responsibilities that should not be ignored.
"Instead of being politically correct, we 

need to be scientifically correct, and 

look for better solutions" 

John Droz, Jr. / Physicist

Thank you...