By J. David Garmon M.D.
President, Tubb Canyon Desert Conservancy 

Borrego In The Crosshairs, Again


Last updated 3/6/2023 at 10:01am

Figure 1. Page 27, San Diego Regional Decarbonization Framework Technical Report

Borrego's perennial celebration of springtime wildflowers is shadowed by a darker perennial – San Diego's incessant musings of turning Borrego Springs into an industrial wasteland. In 2010, Borregans fought off the Sunrise Powerlink. In 2015, it was the Desert Renewable Energy Conservation Plan. In 2021, it was the County Water Authority's Regional Conveyance System. This time it is the County's Regional Decarbonization Framework (RDF). (For the full Report, please visit

The Good News: San Diego County now has a Board of Supervisors that strives to make decisions based on facts and scientific evidence, that understands climate change is an existential threat caused by human activity, and that is taking actions within its power to address the causes of climate change.

The Bad News: Some of the same consultants who wrote SDG&E's decarbonization plan were hired by the County to write its decarbonization plan, referred to as the Regional Decarbonization Framework (RDF). Instead of assembling a breadth of independent expert opinion, the County is using the same small group of consultants that advised SDG&E. So, SDG&E, which represents itself, and the County, which represents the citizens of San Diego County, are getting advice from the same source despite the conflict of interest.

No wonder there is a striking similarity between SDG&E's and the County's visions for electricity generation in the future. Both plans – SDG&E's and the County's – see remote, industrial-scale power generation and the transmission lines to take electricity from the east county to the coast as essential to decarbonizing electricity production in San Diego County. Rooftop and parking lot Solar in coastal communities, which would not require new, long-distance transmission lines, are dismissed in the RDF, and by SDG&E, as insufficient to address the challenge.

The Worse News: The RDF's Scenario 1, the purported "low-cost option," envisions covering the unincorporated part of San Diego County known as Borrego Springs with industrial-scale Solar farms and transporting that electricity to the coast via new 500 kV transmission lines. Figure 1, from page 27 of the RDF, shows Borrego Springs covered in lime green squares indicating just how inexpensive electricity generated in Borrego Springs would be compared to other parts of the county. However, as explained below, the data used to create the conclusions illustrated by Figure 1 is incomplete, thus resulting in inaccurate conclusions, i.e., bad inputs create bad outputs.

Figure 2, from page 42 of the RDF, shows the build out of industrial-scale Solar farms in Borrego over the next 20 years. Although somewhat difficult to see, that expanding cluster of squares in the upper right-hand corner of the maps in Figure 2 is Borrego Springs, which would be carpeted by Solar farms instead of springtime wildflowers.

The Worst News: The San Diego County Board of Supervisors is scheduled to vote to approve, or not, the RDF on March 15, 2023.

The authors of the RDF claim they are not "picking winners or losers." And it is true the RDF considers scenarios for decarbonizing San Diego's electricity generation that are not as devastating for Borrego Springs and the Park as Scenario 1; but it doesn't take much creativity to imagine the discussions of government officials charged with choosing which decarbonization option to implement ... beginning with, "Why wouldn't we implement the least expensive option?"

At a meeting on February 6 with Supervisor Jim Desmond's Land Use staff person, Hunter McDonald, this author representing the Tubb Canyon Desert Conservancy pointed out the current draft of the RDF is making cost comparisons of various pathways to achieve decarbonization without including all the relevant costs. Specifically, the calculations behind Scenario 1 only take into account the costs of land acquisition and Solar farm construction. It does not include the multi-billion dollar cost of building new 500kV transmission lines. The RDF does not take into account the hundreds of millions of dollars of costs that would occur as a consequence of industrializing Borrego Springs and the Park – lost tourism revenue, decreased property values, decreased property taxes, lost hotel taxes, increased health costs due to degraded air quality, etc. – if Scenario 1, the purported low-cost option were selected and implemented. These costs that the RDF simply ignores can be calculated and must be included in any future draft of the RDF if this document is to be relied upon to make fact-based cost comparisons of the various possible pathways to decarbonization of San Diego's power generation.

At the same February 6 meeting, Bill Powers of the Protect Our Communities Foundation pointed out the current draft of the RDF that promotes remote, industrial-scale generation over distributed, in-basin (rooftop) generation in coastal communities does so by using patently incorrect numbers in its calculations. Left out of the RDF's calculations for electricity generation in the back county is the $3.9B that would be required to build the 500 kV transmission lines. Left out of the RDF's calculations of potential rooftop Solar in coastal communities is the true square footage of potential rooftop and parking lot Solar installations that could be built in coastal communities. A further example of the RDF's authors putting their collective thumbs on the "cost-comparison scale" is that the RDF uses outdated rooftop Solar construction costs that are almost twice actual current costs.

The County's current timeframe calls for the Board of Supervisors to approve the RDF at its meeting on March 15, 2023. The Tubb Canyon Conservancy and the Protect our Communities Foundation have requested Supervisor Desmond move to delay the approval of the RDF until such time as the calculation errors are corrected and all economic costs relevant to Borrego Springs are included in the RDF.

Supervisor Desmond needs to hear from every Borregan on this issue. If we want to protect our Park and community, we need to insist the Board of Supervisors delay approval of the RDF until such time as the true costs of decarbonization are reflected in its analysis of all the possible paths forward. When the accurate and full costs of each option are acknowledged and included in the calculations, they will show that building rooftop and parking lot Solar in coastal communities is the environmentally sound, low-cost option for decarbonizing San Diego's grid.

Please take the time NOW to call Supervisor Desmond's office at 619-458-2600 and speak to Hunter McDonald. Ask him to delay approval of the RDF until it reflects the true costs of each option for decarbonization discussed in the RDF. Or you may email Mr. McDonald at By email, by phone, or in person, NOW is the time to make your voice heard.