Campo Kumeyaay Nation

FEBRUARY 26, 2008

Chairman Cuero’s official letter to California Public Utilities Commission

February 25, 2008

c/o Aspen Environmental Group
235 Montgomery Street, Suite 935
San Francisco, CA 94104

RE:  Draft EIR/EIS, Sunrise Powerlink Project

Dear Sirs:

Thank you for the opportunity to comment on the Sunrise Powerlink

As you’re aware, the Campo tribal government has weighed in twice on the proposed Sunrise Powerlink.  In our first correspondence with the PUC we expressed a willingness to listen and review the details of the project in the EIR process.  We also asked that potential direct benefits to the Campo Reservation population be included with your evaluation of the potential impacts.  Subsequently, we sent a letter of opposition to the newly released Alternative Route D due to the disproportionate impact to area residential use.  We also asked that land access arrangements be made prior to determining that a route through the Reservation is a viable alternative.

After reviewing the document, we have made some decisions regarding the proposed route through the Campo Indian Reservation, as well as some general comments regarding the document.


The document is unclear regarding the weighting of dissimilar impacts.  For example, underground lines in some areas may reduce the visual impact while dramatically increasing the potential for impacts to archeological resources.  Since the integrity of the archeological site is difficult if not impossible to mitigate through relocation, it seems that a heavier weight should go to this factor than to aesthetic impacts.  It appears that aesthetics gets heavier weight, particularly, in proposing alternatives through wealthier communities.

It is also clear that the impacts to the La Posta, Manzanita and northern Campo Reservations from an alternative routing north of all three Reservations has not been adequately evaluated.  This should be done prior to finalizing the route preferences.

The Environmental Justice evaluation is weak.  Environmental Justice refers to siting or locating facilities in minority or economically disadvantaged communities.  EJ policy was enacted to help empower those who do not have political clout to get fair treatment.  There is no substantive socioeconomic evaluation of the proposed routes.  There should be a detailed comparative analysis of the routes based on income, education, employment, as well as, racial minority populations.

It is clear that there is no direct benefit to the Campo Indian Reservation.  In fact, the project would likely have an adverse direct financial impact on our present and proposed tourism based businesses near the freeway.  This adverse impact is not adequately addressed in the document but further evaluation is not required if this alternative is dropped, as we now request.  We have also sent a letter to SDG&E denying access for the purpose of surveying this alternative route. 

We look forward to maintaining open lines of communication regarding this project and ask to be included in any future evaluations.  We also ask to be consulted regarding the direct impacts to any archeological sites along the adopted route.

Additional comments may be submitted before the close of comment deadline.


H. Paul Cuero, Jr.

Campo Kumeyaay Nation


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