Wednesday, October 12, 2016

Does The Military Really Need More Desert Bombing Ranges?

The Department of Defense's recent request to close off additional public lands in Nevada is simply unreasonable in light of the vast amount of land already available to the military for testing and training purposes.  The military is preparing to ask Congress to expand two of its test and training ranges in Nevada by as much as 1,416 square miles, including portions of popular public lands outside of Las Vegas. 

The military has not explained why the 21,000 square miles of existing test and training ranges throughout the southwestern states of California, Nevada, Arizona, Utah, and New Mexico are not sufficient (this total does not count other training ranges in other states and the Pacific Ocean, or smaller military facilities in the southwestern states). At this early stage in the environmental review process, the military has only explained that expanding the Nellis Test and Training Range (NTTR) would “improve the range’s capacity to support testing and training.” For the proposed expansion of the Fallon Range Training Complex, the military contends that it needs new lands to accommodate newer technology weapons.  Neither of the proposals consider the use of existing military ranges in the region.

Current Nellis Range A "Straitjacket"?
The Nellis Test and Training Range expansion would include wildlife habitat currently protected by the Desert National Wildlife Refuge and open to the public for 4x4 touring, camping and hiking.  The Air Force told the Las Vegas Review-Journal that it needs to close public access to additional portions of the Desert National Wildlife Refuge to install new radars and threat-emitters for training simulations.  The Air Force has already prohibited public access to half of the Refuge, which itself is only a portion of the total Nellis Test and Training Range.  The Air Force claimed that the current training range, totalling 4,608 square miles, is a "straitjacket," an incredulous statement considering that the range is already as large as Los Angeles County!

The military is conducting an environmental analysis and will solicit public comment, before asking Congress to legislatively expand the ranges.  If approved by Congress, the Nevada land withdrawals would be the latest in a series of expansions over the past two decades, surpassing the size of training ranges needed for conflicts and wars over the past century. The total area of training ranges in the southwestern states alone surpasses the 18,000 square miles of land that General Patton used to train troops during World War II.  War has become more automated and precise since World War II, but apparently this still requires a lot more land?

Military Already Prohibits Access to Vast Expanses of the West
Below is a list of the significant test and training ranges in California, Nevada, Arizona, Utah and New Mexico.  Public access is prohibited or extremely limited across these ranges:

  • China Lake Naval Air Weapons Station (Navy) - 1,718 square miles
  • Fort Irwin National Training Center (Army) - 1,000 square miles
  • Edwards Air Force Base (Air Force) - 481 square miles
  • Twentynine Palms Marine Corps Air and Ground Combat Center (Marines) - 1,136 square miles
  • Chocolate Mountains Aerial Gunnery Range (Navy and Marines)  - 712 square miles
  • Nellis Test and Training Range (Air Force) - 4,608 square miles (not including new request for an additional 471 square miles)
  • Fallon Range Training Complex (Navy) - 316 (not including pending request for an addition 945 square miles)
  • Yuma Proving Ground (Army)  - 1,300 square miles
  • Barry Goldwater Range (Air Force) - 2,968 square miles
  • Utah Test and Training Range (Air Force and Army) - 2,624 square miles 
New Mexico
  • White Sands Missile Range (Army) - 3,200 square miles 
  • McGregor Range (Army) - 947 square miles
Although the Department of Defense makes an effort to protect critical wildlife habitat within its test and training ranges, some impacts are inevitable and strain already besieged wildlife species. Consider the plans by the Twentynine Palms Marine Corps Air and Ground Combat Center to displace over 1,100 desert tortoises to make way for its recently approved expanded training area in the Johnson Valley of California.

Desert bighorn sheep. Photo by US Fish and Wildlife Service
If the Air Force is allowed to expand operations in the Desert Wildlife Refuge, they will inevitably harm desert wildlife such as bighorn sheep.  Increased low-level flight activity and possibly even the use of live munitions would scare or endanger wildlife in the area.   The Department of Defense should undertake a serious review of its testing and training ranges to see where it can leverage existing facilities operated by the various military services, instead of each service staking claim to its own corner of America to bomb and strafe our mountains, valleys, and wildlife.

You can find additional documents and the schedule for public comments for the proposed Nellis and Fallon range expansions at the following sites:

Nevada Test and Training Range (NTTR) Military Land Withdrawal Legislative Environmental Impact Statement Project Website

Fallon Range Training Complex Modernization Website

Tuesday, September 13, 2016

What to Watch For in the DRECP Announcement

The Secretary of Interior on Wednesday will finalize the Federal portion of the Desert Renewable Energy Conservation Plan (DRECP) after years of effort by Federal, State, and local agencies to identify which lands will be conserved for future generations, and which lands will be zoned for utility-scale renewable energy projects.

Interior released the final environmental analysis for the plan in November 2015.  Wednesday's roll out of a Record of Decision normally would constitute a rubber stamp approval of that analysis and officially put the plan into effect, but there are indications that Interior has tinkered further with the plan.  Here are some things to look for in the announcement, broken down by different stakeholders calls for changes to the plan:

Not Enough Destruction Zones: The renewable energy industry has loudly complained that the 600+ square miles of new industrial zones – known as Development Focus Areas (DFA) – that the DRECP is expected to designate in the California desert is not enough. They want more “flexibility” to build a project wherever they please, which is ironic because that is the same problem that necessitated the DRECP in the first place.  As California Energy Commissioner Karen Douglas stated, "large-scale renewable energy, especially on public land, is not the only game in town.”
 It just doesn't seem like industry got the message. 

According to a statement given to the Press-Enterprise, Interior may have made changes to the plan to address industry concerns.  Although we do not yet know what those changes are,  Interior could have loosened some of the siting guidelines that were designed to minimize impacts on wildlife and sensitive habitats.  It is also possible that Interior added more DFA lands, a move that would certainly rankle local residents and desert conservationists.  I think it is less than likely for Interior to add DFAs in the Record of Decision, but if they do they may also add additional conservation designations in other areas.  In order to justify the added DFAs, Interior would have to select lands analyzed in one of its previous alternatives for DFA potential.  I would especially keep an eye on any lands identified in the final environmental analysis as variance lands for potential to switch to DFAs.

Ideally Interior would do nothing to placate industry's over wrought concerns because 1.) 600+ square miles of DFAs is more than enough, 2.) is in addition to the vast swaths of desert already industrialized for large solar and wind projects, 3.) and is in addition to the hundreds of square miles of potential private land locations for renewable energy projects.

Construction crews remove old growth desert habitat for BrightSource Energy's Ivanpah Solar project in California.

No Destruction Necessary: This is the position of many residents of the region and groups like Basin & Range Watch and the Desert Protective Council.  They point to the fact that the right policies can encourage distributed clean energy generation in our backyards, on our rooftops, and over parking lots, without the need to destroy desert wild lands.  A UCLA study has identified enough rooftop solar potential in Los Angeles County alone to meet the region's clean energy needs.  And this does not count the potential for solar car ports covering existing parking lots or larger solar projects on already-disturbed lands.

Doubling down on policies that incentivize rooftop solar, projects on already-disturbed lands, and distributed storage solutions seem like a no-brainer because they make the grid more resilient, cut the need for expensive transmission lines, and spare our wildlands from destruction.  But Interior has made it clear that they plan to facilitate the construction of utility-scale energy projects on otherwise intact desert wildlands to satisfy political demands and cater to an industry that mirrors the fossil fuel empire's appetite for public lands.

A simple and beautiful solution to climate change.  Generating clean energy closest to the point of use.  On our homes and businesses.
The Plan is (Almost) Perfect:  Other environmental organizations have urged Interior to bolster some conservation measures in the plan, but otherwise are eager for Interior to finalize the plan before the next administration (which may not be as willing to bestow the conservation designations included in the plan depending on the election outcome).   After Interior revealed the final environmental analysis,  environmentalists called on Interior to specify that unallocated lands were off limits to renewable energy development. Without this clarification, 1,253 square miles of unallocated lands - areas not designated as DFAs or conservation areas - could be a back door to utility-scale energy development.

Environmentalists also called on Interior to extend conservation designations to areas identified as important habitat but left unallocated in the final analysis. These lands include the Soda Mountain area near Baker, desert tortoise habitat west of Ludlow, and remote desert pockets near Death Valley. Again, it is less than likely Interior will significantly adjust land designations in the Record of Decision. If they do add conservation designations, you can expect to see a commensurate addition of DFAs.

Next Steps?
We don't know if Jewell will mention plans for Phase II of the DRECP that will focus on identifying private lands for conservation or renewable energy development.

In many ways, the first phase of the DRECP was a simpler task because it focuses on public lands, for which Interior has the administrative capacity to confer land use designations. Phase II will require much more work with multiple counties to ensure that plans reflect each county's vision for development and conservation. That's no easy task as county decision makers face backlash not only for industrializing open space, but also criticism from business if they support conservation measures.

Conservation of private lands will also require money to either buy the lands outright or purchase conservation easements. But some of these lands are critically important and vulnerable to development. The initial DRECP analysis identified thousands of acres of private lands that would need to be protected in San Bernardino County to preserve a key wildlife corridor near Lucerne Valley. And Los Angeles County is home to thousands of acres of unprotected desert grassland and dwindling Joshua tree and juniper habitat near Palmdale.

Joshua tree woodland habitat in the western Mojave has been bulldozed to make way for urban sprawl and renewable energy development, much of it on private land.

And with Interior considering listing the Joshua Tree as an endangered species, just look at the Joshua tree habitat under assault in the western Mojave by urban sprawl and renewable energy development across Kern, Los Angeles, and San Bernardino counties. Much of it on private land. And herein lies the challenge for Phase II: how do we protect important habitat that currently remains intact on private land, but is often more important to counties as a tax base than a place to preserve biodiversity?

Tuesday, September 6, 2016

Air Force May Reduce Public Access in Nevada Wildlife Refuge

The Department of the Air Force is proposing to withdrawal an additional 301,507 acres (approximately 471 square miles) of public land to expand the already-massive Nevada Test and Training Range.  The proposed withdraw will likely involve restricting public access and degrading important wildlife habitat, including lands in the Desert National Wildlife Refuge near Las Vegas, and also parcels in the upper Amargosa Valley north of Beatty, Nevada (see map below).   This effort is separate from proposed legislation currently sitting in Congress that would withdrawal even more land from the Refuge.

Morning rain showers obscure the Sheep Range in the Desert National Wildlife Refuge.  The Air Force is proposing to withdrawal hundreds of square miles of additional desert wildlands on the Refuge and elsewhere in southern Nevada to reserve for training activities.
The Air Force is in the initial stages of its environmental review process, and will be sharing more details about its plans at public scoping meetings in October.  However, a study conducted for the Air Force and published online earlier this year suggests the Air Force wants greater flexibility to place ground targets in lands in the Desert National Wildlife Refuge.  It is not clear why the existing training range is insufficient; it already provides the Air Force with 2.9 million acres of land in Nevada. The use of live munitions in the Air Force's training scenarios would not only impact bighorn sheep habitat, but probably will require that the withdrawn lands exclude public access.

What Will Happen to Alamo Road?

One of the Air Force's proposed expansions would cover significant portions of Alamo Road, a 70-mile dirt road that traverses the refuge starting near the Corn Creek Visitor Center and ending near the town of Alamo and Pahranagat National Wildlife Refuge up north.  The road offers a rugged, natural escape across beautiful desert wildlands.  If the land is withdrawn, it is possible that public access will be restricted on this road, or prohibited entirely.

Mark Your Calendar and Attend A Public Scoping Meeting

According to the Notice of Intent published in the Federal Register, the Air Force plans to hold five public scoping meetings from 5 p.m. to 9 p.m., on the dates and at the locations listed below.
  • Wednesday, October 12, 2016: Beatty Community Center, 100 A Avenue South, Beatty, NV 89003
  • Thursday, October 13, 2016: Tonopah Convention Center, 301 Brougher Avenue, Tonopah, NV 89049 
  • Tuesday, October 18, 2016: Caliente Elementary School, 289 Lincoln Street, Caliente, NV 89008 
  • Wednesday, October 19, 2016: Pahranagat Valley High School, 151 S. Main Street, Alamo, NV 89001 
  • Thursday, October 20, 2016: Aliante Hotel, 7300 Aliante Parkway, North Las Vegas, NV 89084
The agenda for each scoping meeting is as follows:
5:00 p.m. to 6:30 p.m.—Open House and comment submission
6:30 p.m. to 7:00 p.m.—Air Force Presentation
7:00 p.m. to 9:00 p.m.—Open House and comment submission resumes

See the below map provided by the Department of Defense depicting the proposed withdrawal lands, and stay tuned for more information.

Tuesday, August 23, 2016

County Rejects Environmental Certification of Soda Mountain Solar

The San Bernardino County Board of Supervisors voted 3-2 to reject the environmental analysis of the Soda Mountain Solar project, placing a significant hurdle in the path of a project that would have threatened important wildlife habitat next to the Mojave National Preserve.  Supervisors Lovingood, Gonzales, and Rutherford expressed concern during a lengthy meeting today that the environmental analysis was inadequate and did not address the California Department of Fish and Wildlife's input regarding impacts on desert bighorn sheep.  During closing comments, Supervisor Lovingood pointed out that projects of this scale would be better located on already-disturbed lands in the County, and mentioned specific sites as examples.

Desert bighorn sheep perched on the slopes of Soda Mountain in the Mojave National Preserve.  The Soda Mountain Solar project would have been built nearby, threatening opportunities to restore bighorn sheep habitat connectivity across Interstate-15 and jeopardizing groundwater that may feed critical natural springs.
Regenerate Power,  the company that now owns the Soda Mountain Solar proposal after corporate behemoth Bechtel pulled out of the project, proposed to build the project along Interstate-15 and next to the Mojave National Preserve.  However, the location chosen for the project overlaps with an area being studied by biologists as an opportunity to restore connectivity for desert bighorn sheep.  The Interstate has acted as a genetic barrier to the bighorn sheep since it was constructed, and has begun to isolate sheep populations to the north and south.  Biologists are looking at ways that a wildlife overpass, artificial water sources, and modified culverts under the highway could re-connect sheep populations across the highway.  But the solar project could threaten these opportunities.

During the Supervisor meeting today, the public also expressed concern that the project's groundwater use would impact wildlife.  The Soda Mountain Solar project would require as much as 156.4 million gallons of groundwater during the 30 month construction period.  Once built, the project would require as much as 10.7 million gallons of water each year for panel washing and dust suppression during regular operation and maintenance, according to the final environmental impact statement.  This water use may jeopardize groundwater that also supplies natural springs used by a multitude of desert wildlife, including a rare desert fish and bighorn sheep.

The vote was an impressive reflection of persistent public demand for a smarter, more sustainable deployment of renewable energy.  The vote was also a rejection of the fast-track environmental review process that often accepts unnecessary risks to wildlife and wildlands, catering to industry while ignoring more efficient alternatives, such as solar on already-disturbed lands, on rooftops, and over parking lots.

Nearly 3 square miles of this intact desert habitat may now be spared after the San Bernardino County Board of Supervisors rejected the environmental certification of the Soda Mountain Solar project.  Photo by Michael E. Gordon.

Tuesday, August 2, 2016

Road to Recovery for Declining Tortoise Population Increasingly Narrow

The desert tortoise population continues to experience a significant decline, despite 26 years of recovery efforts under the Endangered Species Act.  Since 2004 - years into the recovery effort - the overall population has declined by nearly 32%, and the decline is even steeper in certain portions of the tortoise's range.

This startling trend is not evident in the Department of Interior's public posture, which is optimistic on the ability of landscape-level planning to protect habitat linkages and project-level mitigation to offset local population losses.  A closer examination of land management and mitigation practices calls into question Interior's resolve to arrest the decline of the desert tortoise as its habitat becomes increasingly fragmented.

Tortoise Population Spirals Downward
When the desert tortoise was listed as threatened under the Endangered Species Act in 1990, initial research and anecdotal evidence suggested human impacts were chiefly responsible for driving down the tortoise population by as much as 90% in the preceding hundred years (Berry, Kristin; Status of the Desert Tortoise in the United States).  The accuracy of the estimate from that 1984 study has been questioned by some, but none doubted that the tortoise had indeed experienced a significant population decline by the early 1980s.

Advanced research looking at the status of the desert tortoise since just 2004, however, has revealed a continued decline despite the efforts of many conservation groups and agencies to stabilize its population. Evaluation of the tortoise's status across its range - which spans parts of California, Nevada, Arizona and Utah - is broken down into five "recovery units."  Only one of five recovery units experienced a population increase. The overall population decline between 2004 and 2014 is estimated at 32%, with localized declines of as much as 67%.
A chart that will be further explained below shows downward population trends. We have been attempting to stabilize and recover the desert tortoise population for 26 years.  In the past ten years alone the species has continued a significant population decline throughout much of its range, with the exception of the northeastern Mojave.  Although, now, the northeastern Mojave faces significant development pressures.
The steepest declined occured in the Eastern Mojave Recovery Unit, where Interior has permitted four utility-scale solar projects in the narrow portion of a key habitat linkage.  Between 2004 and 2014, the tortoise population here dropped by 67%, according to the Fish and Wildlife Service report.  That is the estimated decline during just a portion of the 26 years that the desert tortoise has been listed as Federally protected, and millions of dollars spent on its recovery. Other habitat linkages in the Amargosa and Pahrump Valleys iare now threatened by other proposed energy projects.

In the Western Mojave Recovery Unit, the tortoise population as declined by as much as 51% since 2004.  The is where a checkerboard of Federal and private land poses a challenge to unified conservation efforts, and urban sprawl and transportation projects chip away at habitat connectivity. Urban sprawl around the Victor and Lucerne Valleys, the expansion of training areas for the Twentynine Palms Marine Corps base, and the Johnson Valley Off-Highway Vehicle Area all threaten to significantly fragment habitat and isolate tortoise populations over time.

In the Colorado Desert Recovery Unit, the tortoise has experienced a 36% decline since 2004.  The protection of some of its habitat in the newly designated Mojave Trails National Monument may help maintain some linkages that had previously been targeted by energy development.   The Upper Virgin River Recovery Unit has seen a 27% decline; tortoise habitat around Saint George is in the crosshairs of sprawl and road development.  Only the Northeastern Recovery Unit between Las Vegas and Utah has seen a significant population gain - a 270% increase - but these gains may be in peril as a key linkage may be affected by the Dry Lake Solar Energy Zone and energy projects being permitted in the area.

Keeping Habitat Linkages: Incredibly Important, Increasingly Difficult
Other studies of the tortoise's status also caution that it is difficult to extrapolate rangewide health from the current numbers because we should think of the tortoise not as a species that fills the desert uniformly, but slowly occupies and disappears from patches of the desert over time (although the apparent decline throughout the majority of its range is what is most troubling). But the tortoise's ability to maintain this population dance - natural population variation across its entire range - requires habitat connectivity.  Once connectivity to a certain portion of its range is lost, that local population may die off and not be re-populated later because tortoises can no longer naturally reach that patch of habitat.  The more we fragment the tortoise's range, the more difficult it will be for the species to maintain healthy populations without significant human intervention.

A key study published in 2013 by Roy Averill-Murray and other experts identifying remaining habitat linkages also calls out proposed energy development that could jeopardize them.  Some of these linkages are the best remaining alternative because other natural linkages have been foreclosed by previous development, such as off-highway vehicle recreation areas, military training and urban sprawl.

A map included in a study published by Herpetological Conservation and Biology shows the "least cost" tortoise habitat corridors in black, with pending renewable energy development in red and yellow. Some corridors are not

The likelihood of protecting these linkages seem slim, especially because the Department of Interior seems pressured to push the limits of desert tortoise survival, allowing development to overtake or threaten tortoise habitat linkages.  Most recently we saw Interior attempting to identify the minimum width necessary for habitat linkages to remain viable - hardly a conservative approach toward protecting the long-term viability of this species in decline.  The Averill-Murray study aptly sums up why this approach is problematic:
"Limited guidance is available for determining precise linkage widths, but minimum widths for corridor dwellers such as the Mojave Desert Tortoise should be substantially larger than a home range diameter (Beier et al. 2008). Inevitably, however, questions will be asked about what is the minimum width for a particular desert tortoise linkage, what is the relevant home range size from which to estimate that minimum width, and what are the minimum sampling considerations in estimating home ranges (cf. Harless et al. 2010). We agree with Beier et al. (2008) that this is analogous to asking an engineer, “what are the fewest number of rivets that might keep this wing on the airplane?” A more appropriate question for conservation is “what is the narrowest width that is not likely to be regretted after the adjacent area is converted to human use?”" -Conserving Population Linkages for the Mojave Desert Tortoise (Gopherus Agassizii), 2013
The Department of Interior did not get the memo.  It proudly announced in 2014 that it approved permits for First Solar to construct the the Silver State South and Stateline Solar projects in the eastern Mojave Desert, despite concerns that the projects would significantly narrow a key tortoise linkage by destroying nearly six and a half square miles of intact habitat.  Interior ignored initial advice from the Fish and Wildlife Service and pressured biologists to justify the narrowest corridor possible.  At the end of the day, First Solar was required to pitch in some money to protect desert tortoise habitat elsewhere, and monitor the status of tortoises that it displaced for the sake of the project.  Long-term, however, the viability of this linkage made narrower by the solar projects is now in question.

The Silver State South and North Solar project pictured above significantly narrowed a key habitat linkage in the Ivanpah Valley.  Two other solar projects nearby further impacted the Ivanpah Valley's tortoise population.

Elsewhere, the BLM's draft Las Vegas Resource Management Plan proposed three new solar energy zones within or on the edges of key tortoise linkages in southern Nevada.  Other wildlands in the Pahrump Valley considered "priority 2" tortoise habitat under the Solar Programmatic EIS are being targeted by utility-scale solar developers and new transmission lines.

Considering the importance of threatened habitat linkages - those we have identified and those that we have not - it seems possible that the tortoise could slowly become extinct from portions of its range that are already highly fragmented, unless humans artificially intervene to stabilize populations and ensure genetic exchange. This seems to be far from the point of the Endangered Species Act - instead of recovering a species we are essentially managing its decline.  To sculpt down and chop up tortoise habitat, and then keep the remaining populations on life support.

Local Mitigation a Short-Term Bandage on a Gaping Wound
Tortoise translocation has seen a lot of press over the past few years.  Reporters tagged along with BrightSource Energy staff as they relocated tortoises displaced by the Ivanpah Solar project, and newspapers highlighted the delayed plans by the US Marine Corps to relocate tortoises from a newly-designated training area in the eastern Johnson Valley.   But despite years and multiple translocation efforts, Interior's management of tortoise translocation seems haphazard, guided by a patchwork of research with uneven implementation and results.

New research helps provide some parameters to guide translocation efforts to reduce tortoise deaths in the months and years following relocation.  A recent study suggest that tortoises relocated to habitat nearby fare better than those relocated long distances, specifically looking at the fate of some tortoises relocated from the Ivanpah Solar project.   When tortoises are removed from their home range, they become more active and spend more time looking for burrows or forage, according to the study.  The study says that eventually they'll settle into a new routine and probably wont be as vulnerable.
Not all tortoises are as lucky as this juvenile (center of photo, just above GPS device placed for reference), spotted coincidentally after bulldozers already began destroying its habitat to make way for the Stateline Solar project in the Ivanpah Valley.  Most juvenile tortoises probably are not spotted during clearance surveys, and are crushed during construction.
Previous research suggests drought at the time of relocation worsen's a tortoise's survival chances, making them more vulnerable to natural predators.   Despite research suggesting some relocation efforts can be implemented successfully, an examination of recent translocations suggests results are uneven, and translocation efforts across Interior seem disjointed.  That said, just getting a hold of translocation results can be difficult; some offices are happy to dig up data while others require FOIA requests.

For example, the Department of Interior in June of 2012 announced that it approved the Moapa Solar project on the tribal trust land of the Moapa Band of Paiute Indians.  Since then, bulldozers have cleared over three square miles of intact desert habitat to make way for photovoltaic solar panels - the same technology that companies can also install on rooftops or as shade structures over existing parking lots.  Little public scrutiny was accorded to the environmental review of the Moapa Solar project, shepherded by Interior's Bureau of Indian Affiars.   The project's environemntal impact statement and biological opinion required that tortoises found on the project site be relocated to nearby habitat and for the data to be reported to the Department of Interior.

Initial efforts to obtain the information on the status of tortoises displaced by the Moapa Solar project were rejected, and Interior indicated that the information belonged to the solar developer.  This same type of data is routinely made available for other projects approved by the Department of Interior.  Eventually the information was released by the company and it was not good news.  According to information submitted by First Solar to the Fish and Wildlife Service, at least 22 desert tortoises of a total of 66 translocated tortoises had died as of 2015 after being displaced by the massive project.  Another nine could not be found.  That's a significant failure rate, even though the translocation should have benefitted from knowledge gained during other translocations.

Another problem with these numbers is that they do not provide the full picture of impacts on the tortoises.  Approximately 90 additional tortoises were passively excluded because biologists determined that at least a portion of their territory existed outside the project boundary.  But those tortoises are still losing some of their habitat and are likely exposed to additional stresses as a result of the project.  The data made available by First Solar does not discuss the fate of these excluded tortoises.

Who Is Tracking All of the Tortoises?
Not all projects result in a mortality rate as bad as the Moapa Solar project.  But it's not clear that the Fish and Wildlife Service is enforcing standards in how translocations are monitored and evaluated.  In response to correspondence with multiple offices across Interior, I have found that data on translocation efforts can come from private contractors, the Bureau of Land Management Field Offices, Bureau of Indian Affairs, or the Fish and Wildlife Service.   The data for each project almost always is provided in a different format.   There is a central website for the Fish and Wildlife Service's Desert Tortoise Recovery Office, but I was never pointed to a central office that might track translocation efforts across Interior's many jurisdictions.

For the Ivanpah Solar project translocation, the Fish and Wildlife Service is supposed to compare results to a control population of tortoises to determine if the translocated tortoises are susceptible to a higher degree of mortality than those elsewehere in the same area.  When I asked Fish and Wildlife Service if the current results revealed a statistically significant different, they had not yet done the analysis.  But at least they had the data.  The Moapa Solar project translocation monitoring data made available by First Solar did not include information on a control group with which it could be compared.  So there is no way for the public to know which translocation efforts are succeeding or failing, or by how much.

Another difference I found was that Fish and Wildlife Service established a "take threshold" for translocated tortoises -  a maximum allowable number of tortoises that might perish after relocation - for the purpose of some energy projects in the Ivanpah Valley.  If mortality of translocated animals exceeded the threshold, they would have to re-initiate consultation with the Fish and Wildlife Service to determine if anything different needed to be done to ensure that translocation was more successful.  Based on correspondence with Interior, it does not sound like a take threshhold was established for the animals translocated to make way for the Moapa Solar project.  It's not clear why Interior would establish a threshhold for some projects but not others.
A tortoise prepares to cross a two-lane road in the Mojave Desert.  A form a habitat fragmentation, but not as serious as some of the wider highways, urban sprawl, and massive energy projects.
Most of the public's attention may be focused on occassional news stories about specific projects or translocation efforts, a public relations battle that Interior fights with sometimes upbeat reviews of its own mitigation and translocation efforts. But the public's - and most likely Interior's - grasp of translocation effectiveness seems elusive.

Regardless of the effectiveness of translocation on a project-specific level, the overall tortoise population remains in trouble.  It seems that land managers are actively and passively making decisions that sculpt down the tortoise's range, ignoring a drumbeat of research on the importance of key habitat linkages and accepting the risk that the tortoise may struggle to inhabit or go extinct from portions of its range over the long-term.

Sunday, July 10, 2016

Yellow Pine Project Threatens Wildlands in Nevada

NextEra Energy is proposing to build a 250 megawatt solar project in Nevada's Pahrump Valley that would destroy 4.6 square miles of intact desert habitat on public land.  The project would further push the distance that residents of the Las Vegas area will travel to experience desert wildlands not scarred by industrial-scale energy projects.  The Ivanpah, El Dorado, and Moapa areas to the south and north of Las Vegas have lost approximately 21 square miles of desert habitat to industrial-scale solar development in the past few years.

Approximate area under consideration by NextEra for the Yellow Pine Solar project in the Pahrump Valley.  The total application area covers over 9,000 acres, and the final project would destroy approximately 3,000 acres of the parcel.

Some of the lands being considered for the project host desert tortoises already relocated once from a Clark County sanctuary, meaning the animals that survived the initial translocation will again be jeopardized, according to Basin &Range Watch.  Even before the tortoise translocation, the lands had been identified during Fish and Wildlife Service as a priority desert tortoise connectivity area.

The Yellow Pine Solar project will also require substantial water for construction and maintenance in a groundwater basin that is already severely over drafted.  Although the project does not currently have a power purchase agreement, Nevada's utility company has favored destructive centralized power plant and has funded attacks on rooftop solar.  This is despite the fact that analysis has soundly concluded that rooftop solar provides a net benefit to the grid.

Monday, May 9, 2016

Eagle Mountain: Confronting the Industrial Juggernauts

Please Take Action:  Send an e-mail by May 27, 2016 to " " asking the National Park Service to restore the maximum allowable acreage of the Eagle Mountain area to Joshua Tree National Park.

The National Park Service is considering restoring lands removed from what was then Joshua Tree National Monument in the 1950s (it did not become a National Park until 1994), but that restoration may not stop one more giant industrial project from moving forward in the Eagle Mountain area.   The land in question was originally removed from the Monument by Congress to allow for the expansion of the Eagle Mountain Mine, but that mine is no longer in operation.  Although the massive open pit remains, surrounding desert wildlands still provide important habitat for wildlife, including an important desert bighorn sheep corridor.  The Park Service is accepting public comments until May 27, 2016.

Mining, Sanitation, and now Energy Industries Stake Claims on Joshua Tree's Eagle Mountain

Eagle Mountain was within the original Joshua Tree National Monument in 1936, but it was removed in 1950 to cater to the mining and steel industries.  The National Park Service's consideration of restoring most of the lands to Joshua Tree National Park would bring more certainty that this wildlife habitat will be managed for conservation rather than profit.
  • Joshua Tree National Monument was established in 1936 after a grassroots campaign led by Minerva Hoyt urged President Roosevelt to protect the beautiful desert wildlands that were threatened by human activity, including the mass removal of cacti for gardens and the ridiculous practice of torching Joshua Trees to guide motorists at night.
Joshua Tree National Monument boundary as established in 1936.  The Eagle Mountain Area of current concern is highlighted in red. Map by the National Park Service.
  • America's demand for steel forced the National Park Service in 1948 to grant conditional use permits to industrialist Henry Kaiser for the Iron Chief mine in what was then Joshua Tree National Monument.  The Iron Chief mine was the smaller predecessor to the Eagle Mountain Mine.
  • In 1950, Congress withdrew thousands of acres from the Monument to make them available for large-scale mining operations, including the Eagle Mountain Mine.  The iron ore was sent to Kaiser's steel mill in Fontana, where processing resulted in significant air pollution.

Congress eviscerated Joshua Tree National Monument with Public Law 81-837, making thousands of acres of the Monument available to mining. Map by the National Park Service.
  • Competition from cheaper overseas steel and efforts to reduce air pollution resulted in the closure of Kaiser Steel mills in Fontana and the associated Eagle Mountain Mine next to Joshua Tree in the 1980s.
  • In 1989, Kaiser proposed to turn the open pit mine into a giant landfill for Los Angeles, seeking to import thousands of tons of garbage by truck.   The landfill would depend upon a land swap with the Bureau of Land Management.

The California Desert Protection Act of 1994 established Joshua Tree as a National Park, and restored some of the lands originally taken from the Monument in 1950.  But The Eagle Mountain landfill proposal prevented the return of the Eagle Mountain area to the Park. Map by the National Park Service.
  • After nearly two decades of legal wrangling, Los Angeles dropped plans to send its trash to Joshua Tree in 2013.
  • Kaiser Sells its mining claims to Eagle Crest, a company with another idea for the massive open pits of the old mine.
The Landfill Proposal Fades, but Energy Projects Loom
The landfill proposal was not the end to the Eagle Mountain saga.  After the landfill failure Kaiser sold its patented claims to Eagle Crest.  The Eagle Crest company wants to build a hydroelectric pumped storage project on the mine.   Another developer is proposing to build a utility-scale wind project on the Eagle Mountain lands that Congress removed from Joshua Tree in 1950, although that is not as far along as Eagle Crest.

Eagle Crest's plan is to fill one of the mine's lower open pits with groundwater.  When utility-scale solar and wind projects in the area generate excess clean energy that the grid cannot absorb, that energy would be used to pump the Eagle Crest water to another open pit at a higher elevation.  When the grid needs that energy again, the water would flow back to the lower pit through turbines, generating hydropower energy.  The project could use as much as 32 billion gallons of groundwater over its lifetime.  This is a seemingly frivolous use of water in a parched area, especially considering that excess renewable energy production could also be smoothed out with battery storage and demand response.

Although the National Park Service's proposed boundary change may not put an end to the Eagle Crest project, it would at least protect the surrounding wildlands that still serve as foraging habitat and corridors for wildlife.  Below is a map of the National Park Service's preferred alternative for the adjustment of the Joshua Tree National Park boundary in the Eagle Mountain area.

Monday, April 25, 2016

Wind Project To Be Crammed In Amidst Wilderness and Wildlife

Sweden-based company Eolus is reviving plans to build the Crescent Peak Wind project in southern Nevada on wildlands prized for wildlife and primitive recreation.  Basin & Range Watch learned that the company filed initial paperwork with the Bureau of Land Management (BLM) to begin environmental review of the project.
This photo was taken along the northeastern boundary of the Wee Thump Joshua Tree Wilderness Area. The Crescent Peak area is in the distance on the right, and would be covered in giant wind turbines if Eolus gets its way.
Solitude or Industrial Zone?
Eolus is targeting a patchwork of unprotected lands in the Piute Valley that the BLM acknowledges are ideal for primitive recreation, and surrounded by conservation and wilderness designations. The Piute Valley offers a “range of outdoor recreation activities associated with a wide-open landscape with limited developments,” according to the BLM's own draft resource management plan.

The Piute Valley is roughly an hour drive south from the Las Vegas metropolitan area, offering an outdoor getaway to a population increasingly hemmed in by sprawl and industry. Wildlands to the northeast of Las Vegas are being bulldozed for utility-scale solar and industrial parks (Dry Lake Solar Energy Zone, Moapa Solar project, Apex Industrial Park), suffering the same fate as the Ivanpah Valley to the southwest of the city.

If the project is built, however, dozens of giant wind turbines towering hundreds of feet in the air would span across the ridgelines, with red hazard lights flashing at night. The industrial project would tarnish the wilderness qualities of the neighboring Wee Thump Joshua Tree Wilderness, South McCullough Wilderness, Mojave National Preserve and Castle Mountains National Monument.

Looking north along the Walking Box Ranch Road, a gateway to the Castle Mountains National Monument. Crescent Peak is in the distance on the left, forming the gentle northern edge of the New York Mountain range that spans the California and Nevada border.
Golden Eagle Hot Spot
The western Piute Valley and McCullough Mountain area also appears to host a high density of golden eagle nests. A Nevada Department of Wildlife survey found nearly 40 golden eagle nests within and near the proposed footprint of the wind project. The Desert Renewable Energy Conservation Plan identified several golden eagle nests on the California side of the border in the New York Mountains and Castle Mountains (Appendix R2.7 of the Draft DRECP).

The Eolus project would have to conduct extensive golden eagle surveys to determine an estimated impact on the species, but some project developers decide to move forward with projects despite high risks to golden eagles and other avian species.

Stay tuned for updates on this project proposal and its estimated impacts on wildlands and wildlife.

Above: An approximate outline of the proposed Crescent Peak wind project in red, imposed on a Google Earth image of southern Nevada and eastern California. Below: A map submitted in 2012 by the project's first proponent - Oak Creek Energy Systems.