HomeMy WebLinkAboutEmailed Comment from Jamie Guoz1
Brandon DeCriscio
From:Jaime Guoz <jaimeguoz@gmail.com>
Sent:Monday, December 8, 2025 9:39 AM
To:Shaun Temple
Cc:elizabeth@lcwlandtrust.org
Subject:CEQA Comment for the Hellman Solar PV Electrical System Project
Dear Planning Division / Shaun Temple:
I write to you in support of renewable energy but in opposition to the proposed Hellman Solar PV
Electrical System Project adjacent to the Los Cerritos Wetlands, given the wetlands’ ecological
sensitivity and the risk of hydrologic, soil, water quality, and biodiversity impacts. I respectfully request
that the City require a full alternatives analysis, a documented feasibility assessment of lower-impact
sites, and a full Environmental Impact Report (EIR), rather than a Mitigated Negative Declaration or
approval as currently proposed.
1. Scientific concern for wetland ecology and hydrology.
Peer-reviewed studies have documented that utility-scale photovoltaic (PV) installations adjacent to
wetland or hydrologically connected ecosystems can alter soil moisture, infiltration patterns, runoff, and
water-table dynamics; these alterations may degrade wetland functions and habitat. Given the limited
science specifically on salt-marsh / tidal / coastal wetlands, and the potential for long-term or
cumulative impacts, the precautionary principle should apply and avoidance of wetland-adjacent
ground arrays should be the priority.
2. Feasible low-impact alternatives are available and proven nearby.
The Hellman project requests roughly 1.5 MW of capacity — a scale that can be accommodated by:
rooftop or parking-structure / carport solar installations (e.g., municipal buildings, warehouse
roofs), requiring only about 2.2–2.5 acres of roof/canopy space; or
ground‐mounted arrays on capped landfills, brownfields, or heavily disturbed industrial sites (6–9
acres), which carry minimal ecological tradeoffs compared to wetlands;
carport rooftop solar at Port of Long Beach — Port’s existing installation of ~904.75 kW
demonstrates feasibility and local precedent.
Because these alternatives avoid any risk to wetlands, they should be selected over the current proposal
adjacent to Los Cerritos.
3. Required CEQA actions — Alternatives Analysis & Full EIR
Before any permit or approval:
The City must require a formal Alternatives Analysis, evaluating at minimum rooftop/carport,
brownfield/landfill, warehouse rooftop, and utility-land alternatives for the full 1.5 MW load. For
each alternative, the developer must provide structural feasibility, connection costs, estimated
yield, and justification for any rejection.
2
The City should not accept a Mitigated Negative Declaration, given the high ecological stakes;
instead, a full EIR is needed to assess direct, indirect, and cumulative impacts on soil, water,
hydrology, wildlife, wetlands, and community resilience.
If any portion of the project proceeds: require binding mitigation and long-term monitoring (soil
& water sampling, hydrology monitoring, biodiversity surveys), an enforceable buffer between
panels and wetland boundaries, and a decommissioning / restoration plan with performance
bond ensuring that, in the event of adverse impacts, the site can be restored to pre-project
hydrologic and ecological function.
4. Public-interest reuse of alternative sites.
I further urge the City to coordinate with municipal and regional agencies (Port of Long Beach, City of
Long Beach, Orange County water and waste agencies) to pursue solar siting on rooftops, parking
structures, or closed/underutilized lands. This would maximize public benefit, avoid ecological harm,
and support community-wide emissions reduction goals.
For your reference, key contact bodies for such alternative-site proposals include:
Port of Long Beach, 4801 Airport Plaza Dr., Long Beach, CA 90815 — for carport / port facility solar
siting.
City of Long Beach Public Works / Utilities Department, 411 W. Ocean Blvd., Long Beach, CA
90802 — for municipal rooftop/parking structure solar.
City of Seal Beach — Planning Division, 211 E. Ocean Blvd., Seal Beach, CA 90740 — as the CEQA
responsible agency for Hellman Project.
I appreciate the opportunity to comment, and I urge you to protect the integrity of Los Cerritos Wetlands
by requiring full evaluation of lower-impact alternatives before proceeding with any ground-mounted
solar adjacent to wetland habitat.
Sincerely,
Jaime Guoz
3154 Heather Road
Long Beach, CA 90808