Monday, September 1, 2014

Overriding Considerations

What is human society doing differently today that suggests we learned from our extermination of one of the most abundant bird species on the planet?  On the 100th anniversary of the passing of the last passenger pigeon - a bird once so plentiful that migrating flocks of billions of birds darkened the skies - I would argue that we have developed ever more complex language, thought and institutions to justify similar destruction of the environment.  So many people participated in the extermination of the passenger pigeon, and we were left with no good reasons for the bird's disappearance.  Instead of learning from this chapter and recognizing the intrinsic value of wildlife and our moral imperative to protect biological diversity, we have simply found other ways to explain and excuse our actions.

Yes, we can point to the Endangered Species Act, Migratory Bird Treaty Act, and other environmental protection efforts that seek to mitigate our impact on ecosystems and wildlife, but even these are failing to hold back the destructive tide.  In a bold attack on conservation, the Obama administration's chief wildlife official Dan Ashe told conservationists that we “must accept a world with fewer wolves, salmon, and spotted owls,” and "a world with less biodiversity.”   We are building a concept of the future that requires the removal of others species to make way for a human society that barely respects its own kind.

A Wild Baseline in Decline

Orion magazine published an essay this summer on the extinction of the once ubiquitous passenger pigeon.  The writer of the piece, Christopher Cokinos, takes a look at why we even bother to remember the passenger pigeon.  Cokinos draws on a book by Joel Greenberg, A Feathered River Across the Sky, that describes the awe inspiring presence of the passenger pigeon, and Cokinos notes that:
"...every generation uses its own experience to create a baseline for what the state of the natural world is. I have seen 10 million Mexican free-tailed bats coming out of a cave in the Texas hill country...And the largest group of birds I have ever seen were maybe 400,000 snow geese in Rainwater Basin in Nebraska, south of the Platte River...Both of these aggregations would have been dwarfed by flocks of [passenger] pigeons...The biological wealth of this continent has been eroded significantly to maintain our wealth."
You could argue that the extinction of the passenger pigeon was remarkable for the scale of extermination that took place.  But what is more concerning to me is society's rate of participation - you could not just blame big industry, an oil spill, or climactic changes.  Society could not have killed billions of birds if there were not hundreds of thousands of volunteers for the cause - people who carried their own reasons or excuses for taking the birds, and who joined an aggregate of ignorance and selfishness in shooting these birds from the sky and clubbing them on the ground.

When flocks of passenger pigeons appeared overhead in the late 1800s, people would fire into the sky to partake in a joyful slaughter.  Greenberg's book is full of historical accounts of people firing from rooftops and balconies, and out of their windows to take their toll on flocks passing overhead.  Commercial interests would follow the pigeons, identify their roosting locations, and kill them wholesale to be shipped back to cities for food, or ship thousands of live birds by rail for pigeon shooting contests.  While it can be said that many of the birds were killed for food, the scale of slaughter that took place surpassed what we could justify for sustenance and veered into the realm of gluttony and greed, and the death of so many birds for "sport" is most illustrative of the fact that human society truly has no good excuse for why we killed off such a magnificent species.

And when Martha - the last surviving passenger pigeon - sat alone in her cage at a Cincinnati Zoo in the early 1900s, visitors would throw sand and rocks at her to get her to move, apparently unhappy with a visit to the zoo to see such a subdued specimen.   We took far more than we needed from this species until its last breath, and human society showed the worst of its ignorance and dispassion upon realizing this bird would never grace the skies again.  Some people believed that the flocks of pigeons must have died in the Pacific Ocean as they "dashed to freedom in Asia," or veered off course in dense fog or windstorms, according to Greenberg's historical research.  For all of the people that ran to grab their rifle at the first sight of passenger pigeons and made it their goal to kill as many of the birds as possible, they still could not believe that they were the cause.

An Indirect Slaughter

As individuals, most of us are not rushing outside with our rifles anymore.  We are rarely participating in the direct slaughter of our wild baseline.  Instead, we have installed layers of insulation between ourselves and our impacts, and we use the economy and our marketplace to justify tragedy.  We are no less culpable for these impacts, but we now have the language and institutions to blame forces and organizations beyond our individual control, even though these institutions are perpetuated by the aggregate of our individual participation.

Our society takes more than it needs; more than is sustainable.  And much of what we think we "need" is as absurd as what the people shooting passenger pigeons thought they needed.  As the Los Angeles Times noted, "the electrical output of more than four nuclear power plants is needed around the clock" to keep set-top cable TV boxes running in millions of homes.  For what? So we can record our favorite TV show when we're not home.   We take water from the Colorado River to irrigate alfalfa fields in one of the driest corners of the southwestern United States so that the crop can be shipped to China to feed dairy livestock.  Subsidies for corn crops have mowed down prairie and woodlands so we can put that ingredient in everything from fuel to snack chips, to soda beverages, at the expense of growing crops that are of actual nutritional benefit.  We have replaced thousands of square miles of rain forest with palm oil plantations so we can consume things like Oreos, microwave popcorn, and crackers.  Elephants are assassinated for ivory tusks that are made into trinkets.  Much of our economy could be characterized as ludicrous in the way it functions, and the desires that it satiates.

Overriding Considerations

One hundred years after we finished off the passenger pigeon (and plenty of other species),  we have now learned how to rationalize the extinction through the excuse of "economic growth."  Federal and State agencies entrusted with protecting natural treasures are granting industry more and more permits to destroy wildlife and landscapes in the name of economic development without applying any filter that preserves our moral imperative to protect biological diversity; if it makes money, it is usually worth the sacrifice.

The U.S. Fish and Wildlife Service tells us we must accept a world with less biodiversity.  Changes to the Endangered Species Act will make way for more landscape-scale destruction of wildlands and keep rare wildlife on the brink.  The misguided Breakthrough Institute claims such sacrifices are necessary to bring the world up to the United States' middle class standard of consumption, making the assumption that such an exceptional standard is sustainable and that wildlands and wildlife are only on this planet to serve humans.  (The Breakthrough Institute also assumes the global economy will allow a Utopian level of economic equality across borders when upper and middle classes are currently being built on the exploitation of others - through sweatshops, industrial agriculture and resource extraction).

Policymakers may view conservation through a prism of consumption and economic growth, but they cannot undo the fact that we are putting more and more natural treasures at risk.   This is where the language of trade-off has shamed environmental thought into accepting sacrifice.  "Overriding considerations" is a term applied in environmental law, but I think it is also a term that best describes the way we as individuals and as a society rationalize environmental tragedy. The near-term want for material consumption justifies costs we would not otherwise accept, and the costs are easier to accept because they are more distant.

It is not my intention to be cynical or pessimistic.  There is good work going on in communities to protect wild places, community health,  and previous generations of activists have left us with plenty for which we should be grateful.  But, in my view, trends remain negative and we are becoming further entrenched in an unsustainable path.  Although corporations and governments - which are often quicker to respond to each other than their consumers or customers - have the most control and influence over how we treat our environment, we should not lose sight of our individual participation in this paradigm.  Every opportunity we take to reduce our consumption is another vote that encourages a more sustainable direction.  If a couple thousand people rallied to reduce our impact on the passenger pigeon in the year 1880, maybe we'd still have a flock of passenger pigeons criss-crossing the skies over our eastern forests.  It may be too late for the passenger pigeon, but it's not too late for so many other species that are just as deserving as us to live on this planet.

Thursday, August 21, 2014

Sacrifice Upon Tragedy

When I hear people compare avian mortality levels at wind and solar projects to the number of birds killed by domestic cats, I hear an insensitive and illogical comparison.  One death toll used to excuse the tolerance of even more deaths.   If that argumentation is how we plan to reason through future human actions, we are in for a very depressing and morally-deprived future. 

To illustrate just how illogical this argumentation is, imagine telling Amnesty International that its efforts to advance peace are meaningless because the United States saves more lives through war.  There is only one correct path, and if you're not supportive of that path, you're wrong and your input is not welcome.  Or imagine someone arguing that examining and criticizing the loss of life in Ferguson is not worth discussing because there are bigger issues at hand.  That's what the Center for Strategic and International Studies (CSIS) broadcast on Thursday in a subsequently retracted Tweet (below).

A broader arena of injustice and crisis certainly exists, but our limited attention span and slogan-filled political system sometimes encourages un-principled comparisons and trade-offs.  However, that should not excuse us from working on the local level to advance sustainability and care for the living beings around us.

Wednesday, August 20, 2014

Article Exposes Shallow Depth of Energy Discussion

An article grossly mischaracterizing the current state of research into avian mortality at BrightSource Energy's Ivanpah Solar project quickly exposed the difference between rally-around-the-flag cheerleaders and those seeking to ensure renewable energy follows a sustainable path.  The piece by David Baker published on the San Francisco Chronicle website notes that only 321 dead birds were found at BrightSource Energy's Ivanpah Solar project from January to June, and casts doubt on the work of scientist Shawn Smallwood who estimated that Ivanpah may kill as many as 28,000 birds per year; Smallwood's estimate was cited in an Associated Press story bringing attention to the incineration of birds at Ivanpah.  David Baker's piece regurgitates a BrightSource Energy press release, and the Associated Press article cites testimony by Smallwood, a scientist who has been published in dozens of peer-reviewed publications and reports.

The Chair of the California Democratic Party's Environmental Caucus RL Miller endorsed Baker's shallow article, and she describes the Associated Press article citing Smallwood's estimates as the work of "solar bashing Repub[lican]s."  In a Tweet from his personal account, Paul Rauber - Senior Editor of the Sierra Club's Sierra magazine - characterized environmentalists' concern about avian mortality at solar plants as "hysterical."

Neither Baker, RL Miller, nor Paul Rauber appear to be familiar with the avian mortality research conducted by Smallwood and other wildlife experts, and apparently prefer discussions about sustainability to be polarized and devoid of critical thought.  What Baker and his short-sighted fans ignore is the fact that in any search for wildlife - whether the specimens are dead or alive - you have to consider how much area was searched, and searcher error.  When looking for dead animals, you also have to consider how many carcasses may have been removed or substantially dismantled by scavengers before they could be found by searchers.  Even though BrightSource Energy's press release notes that only 321 birds have been found dead at the Ivanpah Solar project site, the company's own testimony before the California Energy Commission accepts that the death toll is likely much higher.  That is because the 321 dead birds found so far only reflect incidental discoveries or nascent search efforts that may only examine a fraction of Ivanpah's 5.6 square mile footprint, and ignore most of the desert surrounding the project where injured birds may land and die beyond the boundaries of search efforts.

Smallwood notes that the 28,000 number is at the upper range of his estimate, but his research illustrates that the impacts are likely to be significant regardless of the specific number.  As he testified earlier this month:
“If I’m overestimating by even five percent, so what? These are huge numbers, absolutely huge numbers. And what we’re doing when we argue over these numbers, which are based on hugely uncertain adjustment factors, we’re also glossing over all the chicks that were left in the nests, and these birds died in spring. Glossing over all the social interactions, all the ecological interactions. We’re just arguing over numbers which really don’t reflect on all the impacts.”
While BrightSource has attempted to downplay these numbers by comparing them to other sources of human-caused bird mortality, the fact is that BrightSource's projects can have enormous impacts on regional and rare bird populations in addition to these other human impacts.

If Earth's true enemy is human society's unwillingness to pursue a sustainable path, Rauber and Miller prefer to narrowly focus the war on fossil fuels.  In the conduct of that war, they are ready to enact the renewable energy version of the Patriot Act.  Their discussion of environmental issues is not about protecting ecosystems or biodiversity, it is about winning the war.  And even though we share an enemy in the fossil fuel industry, we differ in the manner in which we are willing to conduct the war and the sacrifices we are willing to make.  Rauber has previously characterized bird deaths at wind facilities as "trivial," and used the Sierra Club's official Twitter handle to endorse an article excusing wind industry impacts because they have not surpassed the impact of domestic cats.  Rauber's own article on the wind industry's impacts on birds then downplayed the significance of these impacts and overestimated the industry's willingness to self-enforce corrective measures.

RL Miller previously derided Los Angeles Times reporter Julie Cart as the "most anti-solar reporter in the mainstream media" because Cart's articles were "indulging Republicans" by examining the impacts of utility-scale solar on remote desert lands.  In other words, the enemy is reading the newspaper, so don't you dare take a critical look at our leader's policies.  That may make sense in a political campaign where 30 second soundbites and slogans win votes, but we'll need a higher level of discussion if we're going to figure out how to safeguard the environment.

Climate change is an urgent threat to the environment, but it is a product of our careless and unsustainable consumption.  If our solution to climate change continues to promote unsustainable consumption, and ignore ecosystem destruction and the erosion of biodiversity, then what have we learned from this challenge? 

Sunday, July 27, 2014

Bridges for Bighorn

Despite efforts to protect desert habitat in the southwest, major highways criss-crossing the desert are isolating wildlife into smaller pockets and hindering genetic exchange necessary to keep species healthy and resilient.  Desert bighorn sheep are not exempt from this impact; they may be agile and swift, but they are no match for several lanes of speeding cars and semi-trucks, and they tend to shy away from culverts that cross under highways.

Biologists have already noticed that desert bighorn sheep populations in the Mojave and Colorado Deserts are becoming genetically isolated because the region's major highways - such as Interstate 15 and Interstate 40 - and other human developments pose a barrier to sheep movement from one range to another.  According to a 2005 article in Ecology Letters,  biologists found "a rapid reduction in genetic diversity (up to 15%)" among desert bighorn sheep resulting from "as few as 40 years of anthropogenic isolation. Interstate highways, canals and developed areas, where present, have apparently eliminated gene flow. These results suggest that anthropogenic barriers constitute a severe threat to the persistence of naturally fragmented populations."

Habitat Connectivity Not a Priority

This should be a familiar story, but if it doesn't ring a bell, a more widely known example can be seen in the Los Angeles basin, where the Los Angeles Times, National Geographic, and local news stations have covered the impact of highways and human development on the mountain lion population in the Santa Monica Mountains.  The mountain lions there are at increased risk of inbreeding and becoming less healthy because each population is too small and largely cut off from other populations by highways that are too dangerous to cross.

If you have been following human developments in the desert then you probably know that the process for permitting new transportation, mining and energy projects often puts habitat connectivity in the back seat.  Case in point, the Department of Interior approved construction of three giant solar projects and a new rail line in the Ivanpah Valley;  biologists have identified Ivanpah as important to tortoise genetic connectivity.  Other species at risk include the Mohave ground squirrel; this species' home range has declined as a result of urban and agricultural sprawl, and now solar and wind energy projects threaten to further fragment its habitat in the western Mojave. 

For the tortoise, industrial developers that destroy intact habitat often promise mitigation money that can go toward enhancing what is left of the desert tortoise's range.  However, these mitigation funds usually go toward closing illegal off-highway vehicle routes or putting up fencing along highways.  This does not really address the problem of connectivity.  Industrial projects that pump precious groundwater and threaten natural springs promise funds for "guzzlers" - man-made water sources for bighorn sheep.  These water sources may support a pocket of bighorn sheep, but do not address the ability of sheep to move across the range and connect with other populations increasingly isolated by industrial and transportation projects.

Although the Desert Renewable Energy Conservation Plan (DRECP) process will supposedly consider how to protect key wildlife corridors, the DRECP has been delayed significantly from its original timeline and it is not yet clear if the final plan will favor conservation or industry.  It is also unlikely that the DRECP will properly fund wildlife overpasses for bighorn sheep without sacrificing desert habitat.  The practice so far is that money for habitat improvement is provided by corporations paying to mitigate or offset the damage they are doing when they build new energy projects or housing developments.  This is a vicious cycle; we need to destroy habitat in order to improve habitat somewhere else.  Funding for conservation and wildlife should not depend solely on the destruction of these very treasures.

Bighorn Bridges

One measure that can be taken regardless of the DRECP may particularly benefit the desert bighorn sheep.  Looking back at the mountain lion example, wildlife officials are considering building a wildlife overpass across Interstate 101 in Agoura Hills to connect two mountain lion ranges currently severed by the highway.  Bighorn sheep have benefited from this approach outside of California.  In Arizona, the Game and Fish Department and Department of Transportation sponsored three wildlife bridges for bighorn over U.S. Highway 93.  As you can see in the video below, bighorn have been using the bridge to get across the highway safely, leading to a healthier and more resilient ecosystem.

The reason sheep need overpasses is evident in research submitted for the 2013 International Conference on Ecology and Transportation which monitored 199 bighorn sheep approaches to culverts passing under U.S. Highway 93.  Only four of the sheep crossed a culvert, and the rest turned back.  Sheep passed under large span bridges (probably less frightening than the narrow and low culverts), "but at significantly reduced frequencies relative to overpass utilization." Large underpasses might be more valuable for others species like desert tortoises, and could be wide enough to accommodate a natural desert substrate, such as plants to provide shade and cover for a range of different wildlife.

Research could identify the most critical choke points to determine where wildlife overpasses could best benefit the desert bighorn sheep population.  One potential linkage previously mentioned on this blog could be built near the Soda Mountains and Zzyzx Road, although Bechtel wants to bulldoze desert there, instead.   Perhaps another wildlife overpass could be built over Interstate 40 between Ludlow and Essex to help connect bighorn in the Mojave National Preserve to populations further south.  Locations for an overpass would need to be identified based on an understanding of sheep movement habits, where populations currently exist, or where they could be restored.

These camera-trap photos included in the Arizona Game and Fish Department evaluation shows bighorn sheep using wildlife overpasses along U.S. Highway 93.

We have identified a big problem - wildlife cannot move in meaningful numbers across our highways.  Some wildlife cannot cross above the highway, and some culverts that cross under our highways are not suitable for all species, like bighorn sheep.  We know that the problem is not going to change because our highways will not be going anywhere.  If anything, our transportation corridors will only be widened as we add lanes or rail lines to accommodate more traffic.  For all of the billions we invest in our roads, highways, and parking lots - with full attention paid to making sure we can fly along at 70 miles per hour, or find that perfect parking space at the grocery store - we are overdue on our obligation to repair some of the shortsighted and selfish damage we have done to the desert ecosystem.  Bridges for bighorns, or more underpasses for other wildlife would be a good step.

Sunday, July 20, 2014

How Much is Too Much Heat for Birds?

In testimony submitted in advance of California Energy Commission (CEC) evidentiary hearings scheduled for the end of this month, the CEC staff estimates that the impact of heated air above BrightSource's proposed Palen hybrid solar and natural gas project may result in as much as 2.5 times more bird deaths than at the BrightSource's Ivanpah hybrid project (I use the term "hybrid" because Ivanpah will burn nearly 525 million standard cubic feet  of natural gas, annually.  Palen will burn at least 728 million standard cubic feet of gas, annually.  Unlike photovoltaic solar projects, BrightSource's power tower design needs fossil fuels to warm up the boilers that also convert the sun's energy into electricity).
This peregrine falcon was found emaciated at BrightSource Energy's Ivanpah solar project and later died. Note the clear singing of the feathers likely caused by the intense heat generated by BrightSource's mirrors. Photo from the National Fish and Wildlife Forensics Laboratory report submitted to the California Energy Commission.
BrightSource has argued that birds are only at risk of death from solar flux (air heated by the concentration of the solar mirror field) in the air space close to the power tower where the heat is most intense.  CEC staff, however, assesses that birds are at risk from injury or death as soon as they enter the flux field, and that they do not need to reach the area close to the tower to be at risk of death.  At issue is the examination of dead birds found at BrightSource's Ivanpah project; some dead birds' feathers were singed by the heat, while others were found with no singing at all.  Early analysis suggested that the birds with singed feathers died of solar flux exposure, and dead birds with non-singed feathers may have died from collision with mirrors.  However,  CEC staff argues that dead birds with non-singed feathers found further from the power towers are also dying from exposure to heat from the solar flux based on the distribution of dead birds throughout the solar field.   This would mean that thermal stress alone, not just the singing and impairment of feathers, is leading to bird deaths.  The reason this is significant is because this would further underscore the increased threat BrightSource's technology poses to wildlife compared to other types of solar facilities, where collision is the primary threat.

The graphic above submitted by CEC staff compares the size of the Palen and Ivanpah solar towers and solar flux fields (Palen is the larger tower and field).  The color coding represents the relative thermal intensity at the Palen project; the intensity of the heat increases closer to the power tower.  CEC staff assesses that birds are at risk upon entering anywhere in the solar field and that the risk increases closer to the power tower, whereas BrightSource maintains that birds are only at risk of death or injury in the cone close to the tower (the darker red shading).

Shawn Smallwood, an expert on bird mortality at renewable energy projects, submitted testimony that the Palen hybrid project could incur as many as 10,787 birds per year (at an 80% confidence interval) based on preliminary data from Ivanpah and a study of bird mortality at the smaller Solar One in Dagget during the 1980s.  Mr. Smallwood also critiques BrightSource's proposal to use various technologies in an attempt to deter birds from coming close to the Palen project, such as the use of lasers, balloons and an untested means of disorienting the magnetic field of birds.  As Mr. Smallwood notes, "[a]nother approach with just as much sense would be to cut off one or both wings of birds so that they cannot fly at all."  Discussion at the evidentiary hearings this month may also examine whether or not BrightSource can curtail operations of the Palen project during peak bird migration months or when migratory birds are nearby, but BrightSource itself has pointed out that this would be infeasible because financially and because the project takes too long to power down.

Sunday, July 6, 2014

Coolwater-Lugo Transmission Line: A Horse Following the Cart

Southern California Edison (SCE) is suggesting that interconnection of Abengoa's Mojave Solar project is the primary reason it needs to build the nearly 75 mile Coolwater-Lugo transmission line through the Lucerne Valley, according to the Daily Press, even though Abengoa told the California Energy Commission (CEC) and Bureau of Land Management (BLM) in 2010 that these transmission lines would not be necessary.   Misrepresenting the need for new transmission lines during the CEC and BLM review of the project would have allowed Abengoa to downplay the costs and environmental impacts associated with approving the project.  The Coolwater-Lugo transmission line is likely to cost ratepayers at least 509 million dollars, and bring bulldozers and transmission towers to mostly undisturbed desert.

Without the Abengoa Mojave Solar project as an excuse,  SCE probably could address other distribution needs - such as relieving the transmission bottleneck at Kramer Junction - by upgrading existing lines, or building new lines along existing transmission corridors.  Alternatively, Abengoa could sell its electricity to LADWP, which also has transmission lines near the project site.

Abengoa Gambling on Transmission Approval

Abengoa may have misrepresented the need for new transmission when it sought approval from the CEC and BLM for its Mojave Solar project.  According to a document submitted by SCE to the Federal Energy Regulatory Commission (FERC) in 2011, Abengoa told SCE that it may not be able to complete the Mojave Solar project without SCE's new transmission line.   However, in documents submitted to the CEC in 2009 and 2010, Abengoa identified upgrades to existing transmission lines as sufficient to deliver power to Pacific Gas and Electric (PGE) - the northern California utility that agreed to purchase power from the Mojave Solar project - and specifically denied that the Coolwater-Lugo line would be necessary (see page 92 of the CEC's final decision - PDF).  Although power from the Abengoa Mojave Solar project is destined for northern California, SCE owns the transmission lines that will connect the project to the grid.
Abengoa and SCE on Record

The screenshot below is from page 92 of the CEC's September 2010 final decision on the Abengoa Mojave Solar project (AMS).  It states that Abengoa (the applicant) told the CEC that it could meet its obligations to PGE without the Coolwater-Lugo transmission line. 

The next two screenshots are from  a Federal Energy Regulatory Commission (FERC) document recording statements from SCE and Abengoa that the Mojave Solar project is not viable without the Coolwater-Lugo transmission project.  This document was issued by FERC in March 2011, but based on submissions from SCE and Abengoa from late 2010 and early 2011.  FERC ruled in favor of allowing SCE to pass along the costs of the Coolwater-Lugo transmission line to ratepayers.  The Coolwater-Lugo line is the delivery "network upgrade" portion of the "South of Kramer" project.  (FERC Docket EL11-10)


Abengoa filed the following document with the CEC in early 2010, indicating that despite transmission congestion, it could proceed with the Mojave Solar project by upgrading existing transmission infrastructure.

According to the CEC's final decision from September 2010,  the CEC acknowledged that the Abengoa Mojave Solar project would create a burden on existing transmission lines.  The document indicates - based on testimony from Abengoa - that the company chose "alternative 2," which would mostly involve upgrades to existing transmission infrastructure and participating in a congestion management program that would curtail the project's electricity delivery when existing lines were overloaded.

Probably because Abengoa signaled that the Coolwater-Lugo transmission line was not necessary for it to meet its obligations to PGE, the BLM also issued a Finding of No Significant Impacts (FONSI) approving the solar project's interconnection to existing infrastructure.   The BLM did not analyze the impacts of building the Coolwater-Lugo line when it reviewed the Abengoa solar project, but now SCE is suggesting the line is necessary to deliver the power to PGE.  If Abengoa had identified the Coolwater-Lugo line as necessary when the project was initially being reviewed, the new transmission line would have been analyzed as a connected action.

It is likely Abengoa will have to curtail generation during peak periods if the Coolwater-Lugo line is not built, but Abengoa knew this when it testified to the CEC that no new transmission lines were necessary to build the project.  If the company was gambling that the Coolwater-Lugo transmission line would be approved, it seems to have done so at great risk to its investors and was disingenuous toward California and Federal stakeholders.

At this point, SCE's use of the Abengoa Mojave Solar project as a key reason for building the Coolwater-Lugo transmission line is inconsistent with facts presented to the CEC and BLM.  SCE should either eliminate the Abengoa Mojave Solar project from its rationale (correcting the record with FERC and the California Public Utilities Commission), or Abengoa should petition the CEC to amend its initial approval.  Most likely, neither will happen and SCE will pass along millions of dollars of cost to ratepayers that was never supposed to be necessary, and destroy pristine desert.

Other Alternatives Available

SCE has examined eight other action alternatives to building the Coolwater-Lugo line, but it has ruled all of them out because they do not meet its objectives or would cost the utility company too much money.  SCE cited the need to connect the Abengoa Mojave Solar project as a reason to rule out six of the eight alternatives.

Alternatives include re-wiring existing transmission lines between Kramer Junction and Hesperia (Lugo), installing new transmission lines and towers between Kramer Junction and Hesperia, or building new transmission lines between Kramer Junction and the Antelope Valley (Llano).  All of these options could utilize existing transmission corridors.

SCE also claims the need to connect other unidentified large renewable energy projects as a reason to build the Coolwater-Lugo line.  At this time, there are no solar energy zones in the vicinity of Lugo and Coolwater substations.  Any wind projects between northern Lucerne Valley and Barstow would likely conflict with the Departments of Defense's flight and radar testing programs.  Moreover, the Granite Wind project near Apple Valley was cancelled, probably in part because of golden eagles in the area.  So, other than the Abengoa Mojave Solar project, there is no identifiable and timely need to connect other large projects to the grid.

SCE also cites the need to serve electricity to a growing Victor Valley as a reason to build the project.  Although SCE does not offer specifics, it also does not suggest alternatives for meeting this demand.  Smaller solar projects are being built in the Victor Valley that can serve local demand, and energy conservation and rooftop solar can help offset the need for an expensive new transmission line.

Abengoa and SCE are betting on a regulatory system that prioritizes industry profit above the need for a sustainable and smart renewable energy future.  Abengoa seems to be confused regarding its need for new transmission lines, and SCE seems eager to profit from new transmission lines.  Hopefully California and Federal regulators will wise up and demand a more efficient and sustainable alternative to the Coolwater-Lugo transmission line.

If Abengoa cannot deliver the project's energy to PGE, then perhaps it can re-negotiate its power purchase agreement and sell the energy to the Los Angeles Department of Water and Power (LADWP).  According to documents submitted by Abengoa to CEC in 2009, a 500kv LADWP transmission line runs next to the Abengoa Mojave Solar project and interconnection could occur without the extensive (and expensive) upgrades required by SCE and PGE.

Wednesday, July 2, 2014

First Solar Begins Ecosystem Destruction in Ivanpah

First Solar has begun construction on the 2.6 square mile Stateline Solar project - one of the company's two additional solar projects in the Ivanpah Valley - after a judge turned down a request for an injunction by the Defenders of Wildlife.   First Solar is also expected to begin bulldozing desert habitat for the Silver State South project, which will destroy over 3.7 square miles of tortoise habitat on the Nevada side of the Ivanpah Valley.  Both projects will destroy some of the best quality desert tortoise habitat in the Mojave Desert and, more insidiously, likely sever a habitat corridor linking separate populations of the tortoise.
A tractor begins clearing intact desert habitat for First Solar's Stateline project in the Ivanpah Valley.  In the initial phase of construction, the project has already displaced at least 16 desert tortoises, including one that was pushed out of its burrow by a bulldozer and happened to survive.  Photo from construction monitoring reports.
Tortoises Lose Key Habitat

According to construction monitoring reports,  First Solar has already translocated at least 16 tortoises - 8 adults and 8 juveniles - from the first phase of construction, which may be an area of approximately 500-700 acres (the final environmental impact statement indicated "zone 1" of construction would be 509 acres, although the current Notice to Proceed covers 693 acres).   Among the 16 tortoises,  one happened to survive being "unearthed" by a bulldozer, and only noticed by a monitor after the tractor had passed.  The incident is a testament to the likelihood that some tortoises - especially juveniles - are missed by pre-construction surveys and will be killed during the course of construction.

The first phase appears to be an area of desert habitat closer to the Ivanpah Dry Lake bed, which would typically support fewer tortoises compared to the other portions of the Stateline Solar site, so we may see a higher density of tortoises displaced by the next phases of construction.  According to the Final Environmental Impact Statement for the Stateline project, the Fish and Wildlife Service estimates as many as 37 adult tortoises may be impacted by the project, although many more juveniles are expected to be displaced or killed.

The Fish and Wildlife Service estimate may not count tortoises that are "passively relocated" during construction.  In other words, if a tortoise is found walking into the construction area, it will simply be placed outside of the new tortoise fence that excludes the animals from the habitat that is now being destroyed.  This can lead some tortoises to pace along the fence and die of heat stress, or place them at higher risk of predation if they no longer have access to a burrow on the other side of the fence.   At least one tortoise has been found pacing the new tortoise fence at Stateline.
This map from the Fish and Wildlife Service shows how the Primm area of the Ivanpah Valley is a natural bottleneck in tortoise habitat connecting two populations (from north to south).  The construction of the Stateline and Silver State South solar projects (brown footprints in the map) will essentially cut off this connectivity and potentially rob the species of genetic exchange necessary to maintain resilience.
As construction of the Stateline Solar project displaces or kills tortoises on site, arguably the worst impact will evolve over time as tortoises lose a key wildlife corridor that currently allows genetic exchange across populations of the species.  The Stateline and Silver State South projects are being built in a natural bottleneck in the Ivanpah Valley at the California and Nevada border.  Suitable tortoise habitat was already limited at the narrowest point near Primm, Nevada.  After First Solar's projects are built, the corridor will not support a full desert tortoise home range through the length of the bottleneck, contrary to best management practices and guidelines set forth in the Desert Tortoise Recovery Plan and discussed in the Bureau of Land Management's Solar Energy Development Policy.   The map above shows how the two First Solar projects limit habitat connectivity to a narrow sliver just east of the Silver State project (shown in light green). 

A view of the desert that will be destroyed by First Solar for the Stateline Solar project, as photographed from Metamorphic Hill.
Intricate Web of Wildlife Being Undone

Beyond tortoises, the construction activity has begun to destroy and displace other wildlife dependent upon, and critical to the vitality of this corner of the desert.  Construction activity likely forced at least one kit fox den to be abandoned, and another active kit fox den with pups is likely to be disturbed in a future phase of construction.   A burrow is now being monitored after crews discovered recent sign of use by western burrowing owls; no matter where the owls are now, there will not have a burrow to return to next year.   The first phase of construction is also impacting an area with the highest density of pink funnel lily, a rare desert wildflower.

Construction crews also found a dead Wilson's warbler and black-throated sparrow.  What is not clear is how they were killed - of natural causes, by construction activities, or by the nearby BrightSource Ivanpah Solar project.  If the latter, this may argue for extending the avian and bat mortality surveys beyond the perimeter of the Ivanpah Solar project. 

The rich diversity of wildlife being displaced or killed in the Ivanpah Valley is a stark counterpoint to the arguments put forward by industry that the desert is a wasteland, and a testament to the qualities that make the desert worth protecting.

Sunday, June 29, 2014

BrightSource Underperforming; Adds Fossil Fuels

The California Energy Commission (CEC) last week signaled support for BrightSource Energy's request to increase natural gas use at the Ivanpah Solar project to nearly 525 million standard cubic feet each year to help heat steam when the sun is not shining.   BrightSource's request to burn more natural gas underscores the difficulty the company has had with its experimental power tower project, even as the company proposes building the even larger Palen Solar project east of Joshua Tree National Park.  The difficulties at Ivanpah - increased fossil fuel use, impacts on birds and bats, and poor operational performance - undermine the company's argument that the CEC should approve Palen because of the project's proposed renewable energy and storage benefits.
The photo and text above were submitted by CEC staff as part of a supplemental staff assessment in the Palen Solar project proceeding regarding glare.  The Caltrans Aeronautics Division Chief was also part of the flight, and the flight crew noted that the glare was "excessive," "painful" and compromised vision.  Note that Unit 2 does not to appear be operational during this flight in early May.
According to supplemental analysis submitted by CEC staff for the Palen Solar project, the Ivanpah multifuel project was only online for a fraction of the anticipated capacity (see chart below) from January to March 2014.  Although these statistics were meant to provide context for the project's impacts on wildlife, they could also suggest that the overall ratio of natural gas and solar energy inputs could be skewed toward the fossil fuels if natural gas was used to keep steam warm while the company struggled to synchronize its mirrors.  According to the CEC's Renewable Portfolio Standard Eligibility Guidebook,  Ivanpah's energy generation must include no more than 2% of heat inputs from fossil fuels in order to count toward California's RPS goals.  With so many of the Ivanpah project's thousands of "heliostat" mirrors in stand-by mode for so many hours and days out of the year, it's possible that the project could surpass that 2% limit.

The chart speaks for itself.  The Ivanpah multifuel project has had a tough start and may need to burn more natural gas, despite BrightSource Energy's confidence that its technology is necessary to meet California's Renewable Portfolio Standard.
Even with only partial operational success in early 2014, incidental and preliminary biological surveys found hundreds of dead birds and bats at the Ivanpah multifuel project, killed either in the solar flux (superheated air above the field of mirrors) or collision with facility structures.  As a biologist noted in testimony submitted on behalf of the Center for Biological Diversity, it is likely that many more birds were killed but their carcasses were not found during the partial searches, or scavengers removed the dead birds and bats before they could be discovered in searches.  Biologists are still working to determine the full extent of the power towers' impacts on wildlife.

Once again we have to ask ourselves what we get in return for this sacrifice of intact desert wildlands.  In the case of Ivanpah, we have a multi-billion dollar hybrid solar/natural gas plant that has destroyed 5.6 square miles of prime tortoise habitat, and now burns and batters hundreds - and perhaps thousands - of birds and bats each year.   It would be much wiser to double down on renewable energy and storage technologies that do not use our treasured landscapes as testing grounds and instead promote a more sustainable grid, such as Solar City's batteries paired with rooftop solar, or UC Riverside's solar parking lots and battery storage.