Saturday, November 22, 2014

Silurian Valley Spared by BLM

If you have ever been to the Silurian Valley, you know it is one of those grand places that inspires and beckons you to pull over, get out of your car, and hike.  After driving on Interstate 15 from Barstow, the Silurian Valley is a strong dose of tranquility, providing relief from the traffic, billboards and franchise restaurants of our Anthropocentric world and what Aldo Leopold called the "epidemic of geometry."  As you drive up the two-lane Death Valley Road,  you leave behind the sight of the small highway outpost of Baker and you are swallowed by the immensity of the Silurian Valley. It is just you and the narrow road dividing thousands of acres of wilderness on either side.  This week, Jim Kenna, the State Director for the Bureau of Land Management (BLM) in California, spared this place for future generations to experience when he rejected plans by Spain-based Iberdrola to build the Aurora Solar project.

The Silurian Valley, with the Avawatz Mountains far in the distance.  Even further in the background is the southern portion of Death Valley National Park.
Kenna's decision represents a significant milestone under the Department of Interior's Solar Energy Development policy, which seeks to encourage industrial-scale solar energy development in identified "Solar Energy Zones" (SEZ) while applying a more rigorous criteria against projects proposed outside of those zones in areas called "variance" lands.  Iberdrola's Aurora Solar project is the first project to be considered under this variance process in California. 

Rigorous Criteria

The BLM evaluated Iberdrola's proposal against 24 different factors, ranging from the availability of space in existing solar energy zones, impacts on sensitive wildlife and cultural resources.  The project was proposed for a location well over 100 miles away from the nearest SEZ.  The BLM's decision noted that the Riverside East and Chocolate Mountain SEZs both have thousands of acres of land available for new projects, so the destruction of the Silurian Valley was unnecessary.

Native Americans, explorers and traders traversed the Silurian Valley on the Old Spanish Trail that connected Sante Fe, New Mexico with Los Angeles.  The trail crossed the southwestern desert with short distances between natural sources of water - springs still used by wildlife today. Visitors to the Silurian Valley can experience a landscape that still looks much like the way it did to travelers nearly 200 years ago.  There are not that many places in the lower 48 United States where our natural heritage remains so intact; an industrial-scale facility of any kind in the Silurian Valley would dominate the viewshed and undermine the cultural and scenic value of the area.  The BLM's decision notes that the cultural resources of the Silurian Valley weighed heavily in the BLM's rejection of Iberdrola's variance application. 

The BLM also looks at a project's ability to use existing infrastructure when proposing to build a facility outside of a SEZ.  The BLM found that Iberdrola's proposed solar project would require over 40 miles  of new access roads.  And although Iberdrola said it planned to connect its solar project to a nearby LADWP transmission line, it had not yet secured an agreement from LADWP to do so.  If LADWP rejected its interconnection request, Iberdrola's project would require many miles of new transmission lines through the desert to reach other transmission facilities near Primm, Nevada.

The BLM's review of the project application found conflicting views regarding the value of wildlife habitat in the Silurian Valley.  While a Western Governors Council habitat evaluation tool noted only moderate values for wildlife in the Silurian Valley, this tool probably lacks the local detail necessary to make site-specific decisions.  In a letter to the BLM regarding the Silurian Valley, the U.S. Fish and Wildlife Service (FWS) noted the importance of the area's intact desert habitat as a key east/west linkage for the desert tortoise.  The FWS also noted that a solar project could become a trap for migratory birds.  Nearby dry lake beds fill up with water after rains, and attract a variety of bird species; these birds could easily mistake a shimmering solar plant for a body of water.

What's Next?

The next major policy decision for the Silurian Valley will be whether or not to keep the Special Analysis Area (SAA) that the draft Desert Renewable Energy Conservation Plan (DRECP) included in the area.  The fate of the Special Analysis Areas will be decided before the DRECP is finalized - they will either become development focus areas or set aside for conservation.  The BLM's decision to reject Iberdrola's solar application in the Silurian Valley suggests that the Special Analysis Area there stands a better chance of becoming part of the DRECP's conservation lands, but we will only know when the BLM announces its decisions on the Special Analysis Areas.

In the meantime, Iberdrola has 30 days to appeal the BLM's decision to reject the Aurora Solar project, but this is likely to be a steep battle.  Even if the Department of Interior asked the BLM to take another look at its decision,  grassroots and national-level environmental organizations have spoken out against the project.  If BLM ultimately allows the project to go through the full environmental review process, it is likely to be contentious and costly for Iberdrola.

Saturday, November 8, 2014

Investigation Sheds Light on Industry Influence over Desert Policy

The Inspector General (IG) of the Department of Interior released a report this month confirming that a senior Obama administration official with cozy ties to the renewable energy industry pressured subordinates to ignore environmental concerns in favor of providing rubber-stamp approval to power plants.  The IG report focuses on the actions of Steve Black - who retired from Interior in 2013 and served as senior counselor to former Secretary of Interior Ken Salazar  - because he dated a lobbyist for renewable energy company NextEra and also put his name forward to serve as CEO of the American Wind Energy Association (AWEA), all while continuing to manage the approval of renewable energy projects on public lands.  At the very least, Mr. Black's actions constitute the appearance of impropriety that undermines our ability to trust Interior leadership to manage public lands based on sound science rather than special interests.

As senior counselor to the Secretary of Interior, Black had considerable influence and managed to reach into the Department's many offices - including the Fish and Wildlife Service (FWS) and the Bureau of Land Management (BLM) - in an attempt to manipulate the recommendations of environmental impact analysis and wildlife investigations.  The IG report suggests that Black exerted improper influence that resulted in potentially less scrutiny of a wind project that ended up killing a golden eagle in the western Mojave Desert, attempts to manipulate environmental reviews of at least two solar projects in the Ivanpah Valley,  and revisions of the draft Desert Renewable Energy Conservation Plan (DRECP) to expand the industry's access to biologically sensitive lands.

The IG was prevented from fully investigating Black's actions on behalf of industry.  Although Black and NextEra officials were interviewed early on in the investigation, the IG report suggests that Black and some company officials stopped cooperating with the investigation after the IG uncovered e-mails indicating NextEra believed Black was critical in clearing the path for its projects.

North Sky River Wind Project

The IG report examines whether or not Black's influence facilitated the approval of NextEra's North Sky River wind project in the western Mojave Desert.  The IG report quotes e-mails of NextEra executives who were confident that Black worked at NextEra's behest to prevent a thorough environmental review of the company's wind project, which biologists were concerned could result in the deaths of golden eagles or even California condors.  Although the project was built on private land, it required access to public lands for transmission and fiber optic lines, as well as modification of BLM roads.  NextEra learned in May 2011 that BLM and FWS were discussing whether to conduct a more thorough analysis of the entire wind project as a "connected action."  NextEra complained to Black about the potential environmental analysis, singling out a particular BLM biologist that the company thought was trying to "kill" the project.    Interior only completed a "finding of no significant impact" for the project, and not the more thorough assessment that NextEra dreaded.

Although BLM officials told the IG that their decision to conduct a less thorough environmental review was their own and not a resutl of any pressure by Black, e-mails included in the IG report clearly show that NextEra executives credited Black with the "green light we were expecting," and avoiding "wacky application of law or discretion."

The IG report also shows that Black continued to alert NextEra officials to concerns by wildlife officials that could stop the project, giving the company the ability to quickly intervene with other political contacts.  In June 2011, Black forwarded a California Department of Fish and Wildlife report that expressed concern that the North Sky River wind project would have a significant impact on birds and bats.  NextEra officials then sent it to Manal Yamout, who at the time worked in the office of Governor Jerry Brown, and asked her for "background intel and guidance."  By August 2011, Yamout got a job as a lobbyist for NextEra and began dating Black.

The North Sky River wind project was eventually permitted and built, and killed its first golden eagle in early 2013, just weeks after beginning operations.  According to the IG report, FWS officials reported that they frequently told NextEra that the company should apply for a golden eagle "take" permit.  However, NextEra officials told the IG that Black provided contradictory advice that the company should only complete an "avian and bat protection plan," and that FWS was not yet ready to issue "take" permits.

Pressure to Favor Industry in the DRECP

A deputy division chief for FWS' Region 8 - covering the California desert - told the IG that "Black did not want to “let go” of potential development areas that had environmental concerns, and the DRECP process had been delayed many times by his repeated requests to the team to reassess areas in which renewable energy acreage and megawatts could be added."  An FWS biologist interviewed echoed the concern, indicating that Black put pressure on FWS to keep certain development areas in the DRECP despite concerns that such areas would conflict with wildlife values.

Although the IG report does not state which development focus areas Black sought to include in the DRECP, interviews with some employees indicate Black pressured them to include more development areas for the wind industry.  This pressure on behalf of the wind industry came after Black asked a NextEra executive to submit Black's name as a candidate to be CEO of the American Wind Energy Association (AWEA), according to the IG report.  The fact the Black was pushing for increased wind industry access to desert wildlands when he was being considered to lead AWEA is extremely troubling.  Documents released in response to a previous Freedom of Information Act (FOIA) request show that Black and other Interior officials communicated closely with AWEA to ensure that the draft Interior regulations did not jeopardize the wind industry's access to public lands and ability to kill bald and golden eagles.

Black's direct outreach to lower-level employees working on the DRECP eventually resulted in a rebuke by the BLM's State Director for California Jim Kenna, who reportedly told Black to stop calling employees working on the DRECP.

The Mojave yucca above are going to be bulldozed to make way for First Solar's Silver State South solar project.  Steve Black pressured a biologist to change the biological opinion regarding the impacts of an unspecified First Solar project on the desert tortoise.  Although the IG report does not specify which project was involved, the Silver State South project is a likely candidate.

Director of FWS Dan Ashe told investigators that he had to complain to Interior leadership about Black's meddling in FWS' review of the BrightSource Energy Ivanpah Solar project impacts on the desert tortoise.  According to the report, Black applied pressure directly to the field office responsible for evaluating the Ivanpah project's impacts.

Black's direct pressure on Interior employees involved in evaluating renewable energy projects apparently did not stop after Director Ashe expressed concerns, since that incident pre-dated Black's outreach to employees working on the DRECP and his apparent engagement with a biologist working on another solar project in the Ivanpah Valley.  A biologist interviewed for the IG report indicated that Black pressured her to change a biological opinion for a project proposed by First Solar.  It is possible that the project in question is First Solar's Silver State South project, which was the focus of contentious evaluation regarding the project's impact on a desert tortoise habitat linkage in the Ivanpah Valley.  However, the biologist told the IG that the biological opinion remained unchanged despite Black's pressure, whereas the record shows that the biological opinion for Silver State South eventually was changed to make way for that project.  It's not clear from the IG report when they interviewed the biologist.  Of note, First Solar sold the Silver State South project to NextEra Energy in October 2013, the same company that previously employed Black's girlfriend as a lobbyist. 

Sunday, November 2, 2014

Celebrating the Desert Protection Act

Senator Dianne Feinstein's California Desert Protection Act (CDPA) was signed into law 20 years ago on October 31, 1994, establishing new protections for vast stretches of the desert.  The CDPA established 69 new Wilderness areas,  created the Mojave National Preserve, converted Death Valley and Joshua Tree National Monuments into National Parks, and added acreage to both parks.

Watching the sun set in a remote corner of the Mojave forges a connection between me and generations past, and it would be nice to know that future generations will share the same natural heritage.  Witnessing mountain shadows gently stretch across miles of open desert, hearing coyotes howl at twilight as bats flutter by, and being immersed in an infinite blanket of stars overhead are some of the treasured experiences you can have in the desert. 

Clouds stroll across the sky during the midday in the Mojave National Preserve, casting shadows on the mountains and valley.
These experiences are increasingly threatened, however, as cities sprawl outward, new major highways threaten to slice across the landscape, and transmission lines and power plants interrupt the wild.  As we watch industry and other human sprawl carve up the unprotected portions of the desert, pollute its air and spoil the night sky, it is good to hear that the Senator plans to continue her efforts for another desert protection bill that would grant Wilderness and monument designation to more of the desert.  This will not be an easy win, and the Senator has been working on this second desert protection bill since 2009.  The first draft bill of the CDPA that established the Mojave National Preserve was originally introduced in 1986, long before it finally passed Congress in 1994.

If Feinstein's new desert protection act passes, it will be worth the wait.  It would offer more permanent protection status to beautiful landscapes, ensuring that desert's solitude will not be hard to find.  Unlike some of the National Parks on the east coast - where towns and cities may be seen from a large portion of the parks - the American southwest still has much larger intact landscapes where nature dominates, not human society.  And California is especially blessed with grand desert vistas - not what they once were, but certainly unique among the lower 48 United States for their accessibility and intactness.   You can drive  from the southern entrance of Joshua Tree National Park north to Scotty's Castle in Death Valley National Park for 335 miles almost entirely on two-lane road surrounded by beautiful desert, with only minor human interruptions.   And for miles on either side there is a seemingly boundless stretch of wildlands begging for exploration and offering a peaceful moment to appreciate life.

Tuesday, October 28, 2014

DRECP Spotlight: Cuddeback

When I was a kid growing up in Victorville watching jets taking off from now-closed George Air Force Base, I didn't know that some of them were probably bombing a 12 square mile patch of desert in California known as the Cuddeback Air Force Bomb and Gunnery Range.  The U.S. Air Force gave up the Cuddeback range in August 2012, but the Bureau of Land Management (BLM) is still figuring out whether it is "suitable for public use."  The Desert Renewable Energy Conservation Plan (DRECP) does not designate the Cuddeback range as either a development focus area or a conservation area, even thought it is immediately adjacent to two wilderness areas, and probably serves as important habitat for the desert tortoise and Mojave ground squirrel.

The Google map above shows the approximate boundaries of the former Cuddeback Air Force Range.  The DRECP does not recognize the range as BLM land, even though Department of Interior testimony acknowledged that the U.S. Air Force relinquished the land to the BLM in 2012.

It may not be possible to allow the public to roam the area until unexploded ordinance is removed, but the DRECP should designate the former Cuddeback Air Force Range as conservation land to remove ambiguity about its ecological importance.  According to a data set available on the DRECP Gateway,  portions of the Cuddeback range serve as a key population center and habitat linkage for the Mojave ground squirrel.  The range is also adjacent to the Superior-Cronese Desert Wildlife Management Area for the desert tortoise.

A screenshot from the DRECP Gateway data set on Mojave ground squirrel habitat shows that the former Cuddeback Air Force Bomb and Gunnery Range provides important habitat for this species.

In the scope of the DRECP, a 12 square mile patch of desert seems almost irrelevant.  But it is a gaping hole in a stretch of land administered by the Department of Interior, and if it were properly recognized for its ecological importance it would probably qualify for designation as an area of critical environmental concern (ACEC) and inclusion within the National Landscape Conservation System (NLCS).

Congressman Kevin McCarthy introduced legislation that would transfer the range to the U.S. Navy as part of the China Lake Naval Air Weapons Station (H.R. 4458), but designation of the area for conservation purposes under the DRECP would not preclude future use by the Navy.  In fact, other lands sought by the Navy are designated as NLCS in the draft DRECP,  so it is not clear why the Cuddeback area is left un-designated.

Monday, October 27, 2014

DRECP Spotlight: Bats

According to the Desert Renewable Energy Conservation Plan (DRECP), a full build-out of the anticipated wind energy target in the California desert region would kill from 4,000 to 283,000 bats each year (page IV.7-273).   This estimate assumes 2,023 turbines would be installed in development focus areas in the western Mojave, Lucerne Valley, Chocolate Mountains and Imperial Valley.

The wide range in the bat death estimate - a spread of over 270,000 - shows just how little we know about how renewable energy in the desert will impact bats.  The wind industry does not always cooperate with independent studies on wildlife impacts, and the industry funds the American Wind Wildlife Institute to shape the public discussion on this topic in a way that is favorable to industry.
The moon sets in the western Mojave desert during the early dawn hours.  I don't have my own picture of a bat because I'm not that good of a photographer.
I have not seen any information in the DRECP that states whether bat populations in the California desert could even survive mortality in the middle range of this estimate.  If the industry kills 100,000 bats each year for the next 25 years, will bats be able to maintain healthy populations?  What would be the breaking point for various bat species in the desert?  Could we see local extirpation of bats in the western Mojave and Chocolate Mountains?  The DRECP proposes to monitor bat populations after implementation of the DRECP, but it is not clear whether steps will be taken to curtail industry operations if bat populations spiral downward. 

Sunday, October 26, 2014

Renewable Energy World Slips on DRECP Coverage

Online industry magazine Renewable Energy World declared in a recent article that the Desert Renewable Energy Conservation Plan (DRECP) "kneecaps" the renewable energy industry, inaccurately arguing that 3,162 square miles of development focus areas is not enough for the industry.  This is my attempt to deconstruct the article's overall lack of understanding of the DRECP and the state of renewable energy in the California desert:

Claim 1:  The energy industry will be handicapped by the DRECP because 80 percent of the development focus areas are on private lands, and it is too difficult for the industry to acquire and develop private lands:  

Response:  This is not consistent with facts on the ground.  There are nearly 4,000 megawatts of wind and solar projects approved, under construction or operational on non-federal lands in the DRECP area, indicating that industry has easily acquired and developed private lands.  These include projects with a capacity of hundreds of megawatts built on already-disturbed lands.  I have previously covered some of these projects on this blog.   Renewable Energy World should examine Volume IV, page IV.25-8 of the DRECP cumulative analysis, which lists dozens of these projects.

And the DRECP still leaves over 570 square miles of development focus areas on federal lands - that is enough space on BLM land alone to accommodate tens of thousands of megawatts of renewable energy projects if every acre were to be developed. (The DRECP assumes that you can build about one megawatt of solar for every 7.1 acres of land - see Appendix F of the DRECP).  As I mentioned in a previous blog post, the DRECP designates way more development focus areas than would be needed to meet the 20,000 megawatt target.

Claim 2:  Concentrated Solar Power (CSP) - such as parabolic trough or solar power tower technology - is particularly hard hit by the DRECP.

Response:  Access to land has not been a significant limiting factor for CSP projects.  CSP has been hit by the fact that that CSP projects are more expensive than photovoltaic solar projects.  Some CSP projects approved by regulators were later scrapped because of the costs, and converted to photovoltaic projects.

Access to land has not, and will not be a big problem for CSP, which has been built on private and federal lands.  The Abengoa Solana and Mojave Solar projects in Arizona and California, respectively, have a combined generating capacity of over 500 megawatts using parabolic trough solar technology.  Both were built on private lands.  The 250 megawatt Genesis Solar power project was built on BLM lands in the Riverside East Solar Energy Zone, and uses parabolic trough technology. 

And once again showing how little research went into Renewable Energy World's article, claims that the DRECP handicaps solar power tower technology are contradicted by facts on the ground.  The DRECP will establish a development focus area where BrightSource continues to explore plans to build the large Hidden Hills solar power tower project (on private lands, by the way).   BrightSource Energy also has dibs on two other rights-of-way on federal lands in the Riverside East Solar Energy Zone - Palen and Sonoran West.  BrightSource had to withdraw its plans to build the Palen project because it could not secure sufficient financing with the looming expiration of federal tax credit, even though CEC and BLM were set to approve the project. 

Claim 3:  The California Wind Energy Association (CalWEA) is concerned that not enough lands identified as development focus areas are actually available for wind energy.

Response:  I have addressed this before.  CalWEA believes that it has the right to nearly every square inch of the desert, and acts like it is a neglected child that has not been given its fair share.  The wind industry has industrialized over 70 square miles of the desert region, and in the western Mojave Desert the industry has built one of the largest wind energy centers in the entire world.  One of the biggest limiting factors for wind energy in the desert region will be conflicts between the Department of Defense and wind operators because turbines interfere with the testing of radars and weapons.  If Renewable Energy World had been paying attention to the DRECP process in 2012 and 2013, they would have noticed that these concerns made wind development difficult, if not impossible, over a significant portion of the DRECP area. 

Before the wind industry gobbled up 70 square miles of land, the military laid claim to much more of the desert at Edwards Air Force Base, the China Lake Naval Air Weapons Station, Fort Irwin, Twentynine Palms Marine Corps Air-Ground Combat Center, and the Chocolate Mountain Aerial Gunnery Range.  These bases also interact with bases in Arizona and Nevada for testing and training.  In other words, CalWEA wants to cut in line in front of the military industrial complex, which itself has already clashed with conservation goals and popular outdoor recreation in the desert. In other words, get back in line CalWEA.

The wind industry's impacts on birds and bats is another limiting factors, and some of the places that the industry would like to develop in the desert host healthy populations of protected golden eagles.  No industry should be given a blank check to destroy natural treasures (see below).

Claim 4: Drought caused by climate change is killing wildlife, so we should build renewable energy projects even if they kill wildlife. It's worth the sacrifice.

Response:   The reason climate change is a problem is that human society consumes energy and natural resources with little regard for the consequences or for sustainability.  Arguing that we should just ignore the impacts of the renewable energy industry on biodiversity would be a continuation of this same broken paradigm.  It is the same twisted logic that the far right would use after a terrorist attack - we are under threat, so therefore we should give up our civil liberties to make our society safer.  It sets up a false dichotomy that suggests we can only have clean energy if we jeopardize biodiversity.  This is not true, and one of the initial drivers of the DRECP was to fix the idea that the industry must have access to every corner of the desert in order to be successful.  As I have mentioned above, renewable energy projects are popping up all over the desert, and the smarter and more flexible companies know how to find places to build projects on already-disturbed lands with less impact on wildlife.

Claim 5:  Estimates of bird deaths at solar power tower projects are "faulty."

Response:  Usually an industry-sponsored publication is not the best place for reliable coverage of scientific studies that are critical of that same industry, so there should be no surprise here.  Renewable Energy World's cursory look at the complex issue of bird deaths at solar power tower projects only exhibits the publication's scientific illiteracy, and the publication relies principally on quotes from industry officials to criticize research into avian mortality.  The author attempts to challenge a renowned wildlife expert who has been published in dozens of peer-reviewed studies and reports by stating that he misleadingly inflates the estimated number of annual bird deaths at the Ivanpah Solar project, which the researcher pegged at 28,000 for the upper range of his estimate.

Renewable Energy World notes that only a few hundred dead birds have been found at Ivanpah, and concludes that therefore the study suggesting thousands of birds may have died must be inaccurate.  Without belaboring the details, the Renewable Energy World author seems to not understand that researchers looking for dead birds do not always find all of the birds that have died. (If you want a thorough examination of the numbers and the science, check out this excellent KCET ReWire piece).  How do we know how many birds died as a result of the Horizon Deepwater oil spill?  Did we go out and find every single bird carcass?  No, we studied smaller areas or populations, considered other factors and biases, and produced a potential range of global impacts, called an estimate.  (And no, just because the oil industry kills birds does not justify our society killing even more birds in a different region - a greater harm does not excuse a lesser harm).

Hopefully Renewable Energy World can introduce a little more nuance and sophistication into its writing on these topics.

According to Renewable Energy World, the DRECP's 3,162 square miles of development focus areas (in pink) is not enough for industry to build solar and wind projects.

Saturday, October 25, 2014

Juniper Flats Safe For Now

Activists in the Lucerne and Victor Valleys received good news from the BLM this past week that plans for the North Peak Wind project had been withdrawn.  The project would have industrialized  nearly 16 square miles of a popular outdoor recreation area known as Juniper Flats popular for hiking and horseback riding, where desert habitat transitions from creosote and yucca scrub to chapparal, grassland and desert conifer.  Groups such as the Alliance for Desert Preservation and Mojave Communities Conservation Collaborative quickly organized to protect Juniper Flats, as well as to challenge the proposed Coolwater-Lugo Transmission project, which is still pending.

The hills in the background would have been carved up by wide access roads to reach newly installed wind turbines, which would have towered over the subtle peaks and erased the sense of peace and solitude that visitors find when visiting Juniper Flats.
Although it is not yet clear why the company withdrew the wind project application, local expression of concern regarding the fate of the beautiful Juniper Flats likely sent a strong signal to the developer - E.ON Climate and Renewables - that they faced an uphill battle.  Local concern also prompted opposition to the project by San Bernardino County supervisors. 

Another significant factor might have been the draft Desert Renewable Energy Conservation Plan (DRECP).  Under the BLM's preferred alternative, the Juniper Flats area would be designated as an area of critical environmental concern (ACEC), and a smaller portion of the area would be brought into the National Landscape Conservation System.  This put the wind project on a collision course with the DRECP because energy projects that do not have a published draft environmental review within 60 days of the draft DRECP's release would be subject to the DRECP's land designations (DRECP Volume II, page II.3-312).  North Peak Wind almost certainly could not complete a draft environmental review before the end of 2014, and would have been doomed by the DRECP's decision to designate Juniper Flats as an ACEC.

Fans of the Juniper Flats area are now asking to expand the NLCS designation to cover more of the area.  You can sign a petition in support of the NLCS designation at the Alliance for Desert Preservation website.  Although the ACEC status alone would prevent new energy applications among the hills, the addition of NLCS status would probably make the conservation status more enduring.

Saturday, October 18, 2014

Nevada: Draft Plan Would Endanger Natural Treasures

The Bureau of Land Management (BLM) put forward a draft resource management plan (RMP) for southern Nevada that ignores opportunities to protect lands with wilderness characteristics and proposes industrial-scale energy development near natural landmarks.  The draft RMP adds to the extraordinary burden that desert activists face as they comb through the Desert Renewable Energy Conservation Plan for neighboring California; comparing the two plans highlights how bureaucratic boundaries can result in arbitrary differences in how we manage desert wildlands.

Wildlands Sidelined

The RMP acknowledges that an inventory of desert habitat identified over 378 square miles of land with wilderness characteristics - sufficient size, naturalness, and outstanding opportunities for either solitude or primitive and unconfined recreation - that could be managed to preserve these attributes. However, the preferred alternative would only protect about 15% of these lands.

This area in the foreground, east of the Wee Thump Joshua tree woodland qualify as lands with wilderness characteristics, but will not be managed as such in the BLM's preferred alternative.  Spirit Mountain can be seen in the distance.

Most of the lands with wilderness characteristics that the BLM chose to respect are in the Gold Butte area of Nevada - which has been eyed as a possible monument - although even some eligible lands within the Gold Butte region will not be counted under the BLM's preferred alternative.  Areas outside of Gold Butte fare worse. Tens of thousands of acres of wildlands near the McCullough Mountains, Searchlight, around the Muddy Mountains, and the Resting Springs Range will be ignored.  The draft RMP does not give a rationale for why these lands will be ignored, even though they meet the criteria to be designated as lands with wilderness characteristics.

Energy Zones Threaten Landmarks

The preferred alternative would establish six new solar energy zones and several areas where wind energy would be encouraged across the region, including two solar energy zones less than 10 miles from Ash Meadows National Wildlife Refuge and a wind energy area immediately adjacent to the most remote corner of the Mojave National Preserve.   The draft RMP appears to ignore planning guidance from the Department of Interior because it overestimates the need for solar energy zones in the region, and does not properly analyze the zones that it proposes.

The BLM map below shows existing solar energy zones (Dry Lake and Amargosa) in dark blue, and proposed solar energy zones in light blue.  You can zoom in on the map with the tools embedded at the bottom.

When the Department of Interior first established solar energy zones in 2012, it stated that additional zones could be created after considering whether market conditions and space available in existing solar energy zones merited additional zones (page 168 of the Record of Decision for the Solar Programmatic EIS).  Nevada still has a total of five solar energy zones, with two in the area affected by the RMP.  Most of the solar energy zone acres in Nevada remain available, which calls into question why the RMP would create six additional zones.  Although Nevada plans to increase renewable energy consumption, it has already-disturbed lands, rooftops, and existing solar energy zones that could accommodate more energy generation than the Las Vegas region could use.

A single resort along the Las Vegas strip is installing 6.4 megawatts of solar panels on the rooftop of its convention space.  Imagine if all of the resorts, big box stores, parking lots, and homes of Las Vegas installed solar panels.  Photo by NRG.

Interior's 2012 solar energy development policy also requires that proposals to establish new zones analyze the potential environmental impacts in-depth.  To give you a comparison, the draft EIS published for Nevada's first solar energy zones analyzed impacts in over 2,400 pages.  But the draft RMP released this month seems to barely scratch the surface in its assessment of how the new solar energy zones might impact the environment.  The RMP does not even mention how solar facilities could pose a danger to migrating or resident birds at Ash Meadows, and it analyzes the potential impact of these zones on endangered pupfish in one sentence:

"Alternative 3 would make an even greater area around Ash Meadows available for solar projects which could lead to moderate to major impacts to the Ash Meadows special status species, including Devil's Hole pupfish, if the projects cause a lowering of the water table through groundwater withdrawals." - the extent of the draft RMP's analysis of impacts on Devil's Hole pupfish
Although solar uses less water than other types of energy generation, a single utility-scale solar project can still use millions of gallons of water a year for construction and washing dust off of solar panels.  Groundwater in the Amargosa area is already scarce, and some agricultural irrigation had to end in the mid-1970s because lowering groundwater supplies threatened to exterminate pupfish that depend on natural springs in and around the Ash Meadows National Wildlife Refuge.

The beautiful Amargosa Valley and Ash Meadows.  Although not visible, streams and springs dot the landscape and provide important habitat for wildlife. Photo by Basin & Range Watch.

The draft RMP proposes the Lathrop Wells and Ash Meadows solar energy zones, both within ten miles of the wildlife refuge, and a third solar energy zone - South Beatty - that would likely draw on the same groundwater supplies.  These three proposed zones would join the existing Amargosa Valley solar energy zone, which remains completely available to developers.  A total of four solar energy zones in the Amargosa Valley could decimate groundwater supplies and wildlife.

In addition to the solar energy zones, the draft RMP would designate areas deemed appropriate for wind energy, and areas where wind energy should be avoided.  Some of the proposed "open" wind areas would be on designated critical habitat for the desert tortoise north of Searchlight, and along the Nevada/California border immediately adjacent to the Mojave National Preserve.  The "open" wind area next to the Preserve appears to cater to the proposed Crescent Peak wind energy project.

Planning Disparity

As I continue to review the Desert Renewable Energy Conservation Plan (DRECP), I am struck by the disparities between the DRECP and draft Nevada RMP.  Unlike the DRECP, the draft RMP for southern Nevada does not consider how much renewable energy could be sited on already-disturbed lands, nor does it have any clear explanation of why the proposed solar energy zones are deemed necessary at this time.

The draft RMP also does very little to protect habitat connectivity for wildlife.  For example,  wind and solar zones would stretch across the Pahrump Valley, potentially fragmenting and severing currently intact habitat linking the Mesquite and Pahrump Valley Wilderness areas on the California side of the border with the Toiyabe National Forest and Red Rock National Conservation Area.  A better alternative would designate more of these desert valleys as exclusion areas for energy development.  

The draft RMP also seems to ignore how energy development along the border with California and immediately adjacent to the Mojave National Preserve could impact recreational values of those connected lands.  Wind turbines placed along the Crescent Peaks would introduce an industrial, man-made element to one of the most remote and peaceful corners of the Preserve, and pose a threat to raptors and other birds in the area.  Blinking red lights atop turbines would compete with the stars in the desert night sky.

And how does increased energy development and water consumption along the Amargosa River  in Nevada impact riparian habitat downstream in California, where the Amargosa is designated a wild and scenic river providing key habitat to even more resident and migratory wildlife?  These are questions and impacts not fully evaluated in the draft RMP.

The draft RMP should be revised to exclude energy development near some of these natural treasures, and consider the role of distributed generation and already-disturbed lands in meeting our renewable energy needs.