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.

Monday, October 13, 2014

DRECP Spotlight: Conservation Designations

My last couple of Spotlights focused on how the Desert Renewable Energy Conservation Plan designates areas where large-scale renewable energy projects will be considered and fast-tracked, including development focus areas (DFAs), special analysis areas, and future assessment areas.  In an attempt to balance this destruction with conservation, the DRECP also identifies lands to be protected from various forms of destruction.  The types of DRECP conservation designations for lands in the California desert vary depending on whether the land is administered by the Bureau of Land Management (BLM) or private (non-federal).

BLM Conservation Designations

While the DRECP bestows conservation designations on some key BLM lands in the California desert,  the designations may not be very durable because they can be lifted in a future revision of a BLM land use plan.   This is particularly troubling because the projects built on DFAs will leave their mark on the landscape and ecosystem for generations after the projects are eventually dismantled, but conservation designations may be vulnerable to shifting policy priorities and economic pressures even within the next few years.  BLM State Director Jim Kenna, however, assured the public that it would be very difficult to remove the conservation designations, according to the Desert Sun.

For lands administered by the BLM, conservation designations include 1.) National Landscape Conservation System lands (NLCS) , 2.) Areas of Critical Environmental Concern" (ACEC), and 3.) Wildlife Allocations.   Of these three, the BLM would presumably need to meet a higher bar for removing NLCS status from lands in the future because Congress asked the BLM to identify which lands in the California desert meet the criteria for addition to the NLCS (Section 2002 of the Omnibus Public Land Management Act of 2009).  Because NLCS designations are considered to be the "crown jewels" of the BLM, removing NLCS status probably would attract extra scrutiny in the future.    The draft DRECP makes clear, however, that these are administrative designations and can be undone through future administrative actions (page II.3-314 of Volume II of the DRECP).

ACECs, on the other hand, have been removed from the California desert over the history of the California Desert Conservation Area (CDCA) plan.  For example, eight years after the original CDCA Plan was published, a plan revision deleted two ACECs originally designated to protect culturally significant sites because those cultural artifacts could not be found during surveys in 1987.  That said, more acres of ACECs have been added than deleted from the CDCA since 1980.

Conservation for Non-Federal Lands

In the case of private lands, areas deemed ecologically important will be known as "Conservation Planning Areas."   Unlike the BLM's conservation designations where renewable energy development will not be allowed, designations on non-federal lands will serve more as guidelines for future conservation easements that will probably depend in large part on "mitigation" funding from projects that destroy desert habitat elsewhere in California.  Protecting these lands will be more difficult because no single entity owns or controls them. This has been, and will continue to be a key weakness of conservation planning in the California desert - non-federal lands have facilitated the urban sprawl that has resulted in the loss of vast stretches of desert habitat without much consideration for the intrinsic value of protecting open wildlands.

For example, wildlife linkages connecting the Angeles and San Bernardino National Forests to the Mojave Desert will not be possible to protect without the cooperation of landowners near Lucerne Valley and El Mirage Valley.   The same goes for open desert around the Yucca Valley and Joshua Tree, where the many parcels of private land - if developed - would interrupt wildlife linkages.  It will be up to local communities to press the respective municipalities and counties to designate and enforce zoning and planning that protects these open spaces.

Open desert west of Phelan and surrounding Palmdale - like this area pictured above - is partially fragmented with residential development and roads, but some remaining open lands are designated as conservation planning areas.  How quickly these lands are purchased and set aside for conservation will depend on the availability of mitigation funds from projects that destroy habitat elsewhere in the desert, or from often undependable funding from federal and state conservation grants.

Acquiring Ecologically Important Private Lands

The DRECP identifies "conservation priority areas" that will be considered first for purchasing private lands to protect key wildlife habitat and linkages.  As I mentioned earlier, this funding is most likely to come from mitigation fees charged to project developers.  However, the draft DRECP also notes that some government funding could also support the purchase of private lands for conservation (page II.3-293, Volume II).  Potential Federal funding sources include the Land and Water Conservation Fund, and the Fish and Wildlife Service's Cooperative Endangered Species Conservation Fund HCP Land Acquisition Grants.  State funding sources may include the California Greenhouse Gas Reduction Fund and state tax credits that provide an incentive for landowners to donate land or accept conservation easements.

However, these conservation funding sources probably are not going to be reliable year-to-year, so progress in protecting wildlife habitat on non-federal lands is likely to be slow.  Without community cooperation, it seems likely that conservation efforts on non-federal lands will be outpaced by destruction for a variety of human uses.

Thursday, October 9, 2014

DRECP Spotlight: Development Focus Areas

The draft Desert Renewable Energy Conservation Plan identifies 2,024,000 acres (3,162 square miles) of "development focus areas" (DFA) in the preferred alternative.  Of that total, 367,000 acres (573 square miles) are on lands administered by the Bureau of Land Management (BLM).  I wrote yesterday about the assumptions that were used to come up with this many acres of DFAs.

DFAs By County:
The following numbers include a both private and BLM-administered lands.  Imperial County shoulders the heaviest DFA burden at 734,000 acres (1,146 square miles), followed by San Bernardino County at 399,000 acres (623 square miles), Kern County at 360,000 acres (562 square miles), Riverside County at 268,000 acres (418 square miles), Los Angeles County at 218,000 acres (340 square miles), and Inyo County at 45,000 acres (70 square miles).

Construction crews bulldozing Joshua tree woodland habitat in Kern County to make way for a wind energy facility.  Most of the wind facilities in this corner of the western Mojave Desert are built on private lands, although the BLM has also approved wind development here.  Photo courtesy of Friends of Mojave.
Incentives for Industry:
On BLM lands, DFAs will allow renewable energy projects to receive fast-track environmental review.  The DRECP will aim to make it cheaper and quicker for projects to be reviewed and permitted on BLM lands designated as DFAs.  You can read more about the specific incentives for DFAs on BLM lands in Volume II of the draft DRECP (PDF- page II.3 - 304).  On private lands, DFA status may make it easier for projects to receive Federal permits for the "take" (to kill or harass) of endangered species, although further benefits of the DFA designation for private lands will depend on the specific county's zoning and permitting process.

DFAs By County:
Imperial County shoulders the heaviest DFA burden at 734,000 acres (1,146 square miles), followed by San Bernardino County at 399,000 acres (623 square miles), Kern County at 360,000 acres (562 square miles), Riverside County at 268,000 acres (418 square miles), Los Angeles County at 218,000 acres (340 square miles), and Inyo County at 45,000 acres (70 square miles).

How Much Will be Developed?:
As I mentioned in yesterday's post about the DRECP's assumption that the California desert must host 20,000 megawatts of renewable energy projects by the year 2040, the industry needs far less than 2 million acres to generate 20,000 megawatts.  According to the DRECP acreage calculator, generating just above 20,000 megawatts would actually require developing somewhere in the ballpark of 284,000 - 351,000 acres (443 - 548 square miles).  This is still an enormous amount of land, but less than the total number of DFA acres.

A map of the draft DRECP's Preferred Alternative, with the DFAs designated in dark pink:



Wednesday, October 8, 2014

DRECP Fact of the Day: 20,000 Megawatts

This is an important number in the Desert Renewable Energy Conservation Plan (DRECP).  The State and Federal agencies that drafted the DRECP start with the assumption that the California desert region may need to host at least 20,000 megawatts of large-scale wind, solar or geothermal energy projects by the year 2040.  Based on this assumption, the DRECP agencies calculated how many acres would need to be designated as development focus areas (DFAs) to accommodate these 20,000 megawatts.
This is what the DRECP does not mention: a study by the UCLA's Luskin Center for Innovation calculated that the rooftops in Los Angeles County alone could accommodate over 22,000 megawatts of solar panels.  As I pointed out in my earlier post on the DRECP, the plan unfortunately discarded an alternative that would consist only of distributed generation (solar panels on rooftops, over parking lots, and other spaces in our cities).   The DRECP's purpose and need statement (Volume I.1) makes it clear that the Department of Interior and California Energy Commission assume that it is necessary to industrialize desert wildlands for large-scale renewable energy projects, so we're fighting an uphill battle in convincing the powers that be that there is a more sustainable and wildlife-friendly way to generate clean energy.  
For the sake of dissecting the rest of the DRECP's assumptions, we'll look at what the document says, but we should not forget that the DRECP underestimates the potential of distributed generation. To accommodate 20,000 megawatts of large-scale renewable energy in the desert, the DRECP designates over 2 million acres of DFAs.  However, the DRECP purposefully inflates the number of DFA acres because it anticipates that ultimately not every single acre of the DFAs will be available to renewable energy developers.  The DRECP expects that renewable energy companies will be unable to develop some parts of the DFAs because of local permitting constraints, wildlife concerns, access to transmission, or other issues.  So they over shot in their designation of DFAs to ensure that the renewable energy industry will have ample opportunity to build large-scale projects. 

With the right incentives and policies, we could tap the vast potential of spaces in our cities to generate clean energy.  The DRECP, however, assumes that we will need to bulldoze hundreds of square miles of desert to tap solar and wind resources, even though the technology allows us to do so without such destruction.
But how did we get to 20,000 megawatts?  The "Planning Process" section of the DRECP (specifically, Volume I.3, page I.3-43) attempts to lay out how they arrived at the 20,000 megawatt number.  The document states that this is how many megawatts of clean energy the desert region will be expected to generate in the year 2040 when demand for energy is expected to be much higher than today because of a bigger population and increased use of plug-in electric vehicles.  What is less clear in the document is how much of the overall burden the desert is expected to carry compared to the rest of the State.  Does the plan account for the potential development of wave energy or wind projects off the coast of Los Angeles?

The plan also doesn't make clear how the calculation accounts for projections that renewable energy technology and energy conservation efforts will become more efficient over time.  Solar panels in the year 2025 will likely generate more energy per acre than solar panels in 2015, and some of our appliances will hopefully use less energy in 2030 than they do today.

Much of the technical calculations that go into the 20,000MW assumption were discussed and decided in DRECP stakeholder meetings back in 2012 or earlier.  But we're left to squabble over the impacts of these assumptions, and we are not given much room to question why our renewable energy future has to look so much like our current energy paradigm - involving the wholesale destruction of the land to blindly feed the mantra of economic growth and increasing conumsption.


Tuesday, October 7, 2014

DRECP Fact of the Day: Eagles

Golden eagles soar over the Mojave Desert. We know that wind turbines and golden eagles do not mix well.  Solar power towers - like those that BrightSource and NRG built in the Ivanpah Valley - can burn eagles alive.  And sprawling photovoltaic solar plants can destroy the wildlands where golden eagles like to forage for food.   The U.S. Fish and Wildlife Service (FWS) is responsible for monitoring the status of the golden eagle, and determining whether or not any industry - including the renewable energy industry - is permitted to "take" (harass or kill) golden eagles.  (Note: the golden eagle is not an endangered species, but it is protected under the Bald and Golden Eagle Protection Act)

A golden eagle recovering from an injury at the High Desert Museum in Bend, Oregon.  These birds face a number of threats from humans, including climate change, power lines, strikes with vehicles, and wind turbines.
According to Appendix H of the Desert Renewable Energy Conservation Plan (DRECP), the FWS has determined that the total number of golden eagles that can be "taken" each year in the California desert is 15.  (Appendix H, page H-28)  According to the draft DRECP:
"This number will go up or down depending on factors such as implementation of projects that take golden eagles inside or outside the DRECP area and the population status of golden eagles. The USFWS Migratory Bird program will send a letter annually in December to the DRECP executives to inform them of the amount of eagle take available for the following calendar year." 
This means that if FWS permits a wind project in the California desert to "take" up to 3 golden eagles a year for the next 20 years, there will be three fewer eagles available for other renewable energy projects to kill on an annual basis for the next 30 years.  But FWS could revise the total cap of golden eagle "take" to be lower if studies determine that the golden eagle population is actually doing worse than expected, or revise the total "take" number to be higher if they find the golden eagle population to be doing well.

The FWS estimates that as many as 230 golden eagles call the California desert area home.  The FWS believes that the population can remain stable - even with 15 eagles killed each year - because eagles from the California desert and surrounding territory will lay eggs and hatch baby eagles that can help replenish the population.

What is not clear is what will happen if the golden eagle population declines rapidly for other unexplained reasons, but FWS has already handed out so many permits to kill golden eagles that it has essentially given a green light to the local extinction of this majestic bird.  FWS permits to kill golden eagles can be good for as long as 30 years, which makes it tougher to shut off the human causes of eagle deaths.  Can FWS force energy projects to shut down to avoid the local extermination of golden eagles?  FWS is handing out checks that are good for as many as 30 years, but the eagle population is dynamic - it can go up or down each year, and we do not always have control over what factors cause that fluctuation. What happens when FWS not only goes broke, but is in default - allowing companies to kill more golden eagles than can be replenished naturally?

The golden eagle is one of many amazing species that calls the desert home, and you can see that the DRECP lays out a policy framework that can substantially impact - for better or worse - the future of wildlife in the desert. Whenever I have time I will try to pull out these examples of impacts (on wildlife, lvisual resources, recreation, etc) and convey my concerns as accurately as possible.  I do ask for your patience, though, because this is not my full time job and the DRECP is over 8,000 pages.


Sunday, October 5, 2014

DRECP: First Impressions

The draft Desert Renewable Energy Conservation Plan (DRECP) was released at the end of September, almost 34 years after the Department of Interior finalized its original plan for managing the vast and beautiful California Desert Conservation Area.  With nearly 8,000 pages and extensive reformulation of land use policies throughout 22 million acres of California, the DRECP will take a while to digest and formulate thorough comments.  This plan will shape the future of one of the largest intact ecosystems remaining in the lower 48 United States, so it will be worth the time to review and provide input.

By the Numbers - Energy Industrialization
3,146 square miles:  The number of square miles of "Development Focus Areas" (DFA) designated by Federal and State agencies in the preferred alternative where large-scale wind, solar, and geothermal energy development will be encouraged or fast-tracked.   Although it is important to note that the DRECP does not anticipate that every acre of the DFA will be developed, the total area of DFAs is approximately four times the amount of land already urbanized or paved over by our desert cities.  About 576 square miles of the DFAs fall on public lands managed by the BLM, and the rest on private or other non-federal lands.

285 square miles:  The number of square miles that would be designated as study areas and variance lands where renewable energy may be considered after additional environmental analysis and administrative review.  The study areas are broken up into two different types - special analysis areas and future assessment areas - and were designated because Interior recognizes the value of these lands to the renewable energy industry, but also the potential value of cultural and biological resources there;  Interior believes more information is needed before it determines whether they should be bulldozed or preserved.

182 square miles:  Renewable energy projects already approved throughout the DRECP, according to the cumulative impacts analysis.  Of these 182 square miles of approved projects, as much as 100 square miles have already been industrialized or bulldozed.  Many more square miles of projects are under environmental review.

10%:  The portion of the 22 million acre DRECP plan area where large-scale renewable energy will be encouraged or considered within DFAs and study areas. One out of every ten acres of the region will be considered a prime area for renewable energy generation.
One of Many Uses

As I mentioned in my last post before the DRECP was released, the California Desert Conservation Area was specifically identified by Congress as requiring careful management for its unique conservation values, and to balance multiple competing human uses of this beautiful landscape.  The DRECP attempts to make way for 20,000 megawatts of large-scale renewable energy in a region under pressure by urban sprawl, overdrawn groundwater supplies, multiple large military bases and training centers, mining, grazing, and various types of outdoor recreation.

So, identifying ten percent of the entire DRECP planning area as DFAs strongly signals that the renewable energy industry - despite being a latecomer to the long line of desert users and abusers - is being given a prized status.  Especially when you consider that large-scale renewable energy facilities typically exclude many other uses by closing open trails, killing wildlife, and disrupting scenic vistas.

What About Rooftop Solar?

The draft DRECP fails to fully evaluate an alternative focused on distributed generation, even though the large-scale renewable energy projects that it supports are quickly becoming outdated.   We would not need to bulldoze a single acre for large-scale renewable energy if we fully tapped the potential of energy conservation (shutting off appliances we are not using), energy efficiency (engineering appliances so they use less energy), and the scalability of solar, wind, and energy storage.  These options mean that our clean energy future could fit in our backyards, on our rooftops, in our garage,  and over parking lots.

The DRECP acknowledges calls by the public for more distributed generation and less desert destruction, but refuses to evaluate a distributed generation alternative primarily because the Federal and State entities that developed the plan have orders from their bosses (the President and California Governor Jerry Brown) to facilitate the expansion of utility-scale renewable energy on wildlands.  These State and Federal policies are a relatively blunt tool against climate change because they set a target for generation without giving much guidance on how to value things like migratory birds, desert tortoises, beautiful sunsets, or the wilderness experience. (The policies also cater to business interests more sincerely than they answer the demand for climate action, as evident in the White House's approval of coal, oil, and gas leases on public lands elsewhere in the United States that are inconsistent with its own statements on the urgency of addressing our fossil fuel footprint.) The DRECP is an attempt to more deftly direct the impacts of these utility-scale renewable energy policies, but the plan's underestimation of distributed generation is very unfortunate.

The DRECP agencies could partially fix this flaw if they re-examine the baseline assumptions of how much renewable energy we will need from utility-scale versus distributed generation, and then reduce the total acreage of DFAs.  The DRECP is built around the assumption that the desert region will need to shoulder the burden of 20,000 megawatts of utility-scale renewable energy generation, but acknowledging the potential of distributed generation could ease this burden on our wildlands.

And Larger Projects on Already-Disturbed Lands?

The DRECP preferred alternative does identify already-disturbed lands - such as current or former agricultural lands - as DFAs, with a particular concentration of such DFAs in the western Mojave and in the Imperial Valley.  While I think this is much better than bulldozing intact desert habitat, it is important to note that building large-scale renewable energy projects on already-disturbed lands is not without consequence.  Removing farm fields and putting in solar panels can increase air pollution with wind-blown dust, and alters local economies.  Also, there are some species of wildlife that make use of agricultural lands, such as the western burrowing owl.  The location of the already-disturbed lands is also important to consider.  For example, we would not want to build a bird-scorching solar power tower along the Colorado River migratory bird flyway, even if it was built on already-disturbed lands.

The 'C' in DRECP Stands for Conservation

The DRECP attempts to protect key landscapes for wildlife and recreation through conservation designations - federal and non-federal.  On lands mostly under private or local jurisdiction, a general conservation plan identifies areas where conservation easements and zoning may help protect key open spaces.  On lands administered by the Bureau of Land Management (BLM), the DRECP designates additional areas of critical environmental concern (ACEC), National Landscape Conservation System lands, and recreation management areas.  While these BLM designations will help steer destructive uses away from some of the larger blocks of intact desert, the overarching concern is that these designations are not as durable as Wilderness Areas or Monuments.  In other words, the BLM could undo the ACECs or NLCS designations a few years from now.

All-in-all, the DRECP preferred alternative would bestow welcomed conservation designations on some key public lands.  However, the draft plan leaves some ticking time bombs and is another swipe of the scalpel at one of the largest intact ecosystems remaining in the lower 48 United States.  For example, the Silurian Valley contains a large "special analysis area" that might accommodate Iberdrola's pending plans for a large wind and solar project.  Much of the Hidden Hills area - situated among wilderness areas in California, and the beautiful Pahrump Valley that spans both California and Nevada - would be designated as a DFA.  And a "future assessment area" in the Cadiz Valley means that some day a solar power tower could be built in this serene landscape, reaching hundreds of feet into the air to spoil the look and feel of a stretch of desert where the predominant human development is a lonely two lane highway - the Historic Route 66.

Desert habitat in the western Mojave Desert, around Lucerne Valley, and in the Imperial Valley would be under even more stress since much of the DFAs are concentrated in these regions.  Much of this land currently falls under county jurisdiction.  This will have substantial implications for already fragmented and beleaguered Joshua tree and pinyon woodland habitat along the foothills of the San Bernardino and San Gabriel Mountains, and the grasslands of the Antelope Valley.  The DRECP appears to offer a compromise by protecting some narrow wildlife corridors, but that may be all that remains if human development - housing, farms, and now renewable energy - fills in the open space of what is currently a rural checkerboard of desert where jackrabbits and coyotes cross peoples' front yards transiting from one patch of desert to the next.

Devil in the Details

In a plan covering over 22 million acres, it can be difficult to figure out how some of our favorite corners of the desert will be affected.  For the DFAs and conservation designations covering private or non-federal lands, it is best to consider these proposals in the context of your local or county zoning and project permitting process.  If you live next to an open patch of desert that is in private hands, local officials and zoning policies will have the ultimate say on what can be built on these non-federal lands, regardless of whether or not a particular parcel is considered a DFA or conservation area in the DRECP.   For desert lands that are managed by the BLM, look closely at how the BLM plans to manage these lands under the DRECP.  For example, an ACEC may exclude renewable energy development, but allow other uses that could still have an impact on wildlife.  Many of the details for BLM land use plan changes are buried in Appendix L of the DRECP.

Here are a few issues I have identified, so far.

Silurian Valley:  As mentioned above, the special analysis area in the Silurian Valley is troublesome.  If Interior decided to move forward with allowing any development in the Silurian Valley, we would lose the untrammeled qualities that make this place such a majestic gateway to the desert for travelers exiting Interstate 15.

Mojave National Preserve: The draft DRECP proposes a "future assessment area" immediately adjacent to the Mojave National Preserve at the intersection of the Ivanpah and Clark Mountains.  If Interior ultimately decides to approve renewable energy development here, it would destroy wildlife habitat and introduce industrial development to the viewshed of even more of the scenic Preserve.

Lucerne and Apply Valleys:  The DRECP preferred alternative would designate an ACEC around the Juniper Flats area and the Granite Mountains east of Apple Valley that would likely foil attempts by wind energy companies to build on land prized for outdoor recreation and recognized as important golden eagle habitat.  However, DFAs would stretch across much of the lower elevation areas of this region, decimating the checkerboard of remaining creosote and yucca scrub habitat that connect the Juniper Flats and Granite Mountains.  Much of the DFAs here fall on private lands.

Ancient Creosote Rings:  Situated near the Johnson Valley Off-Highway Vehicle Area, the King Clone Creosote Ring - one of the oldest living organisms on the planet - is currently protected by a small ACEC that is surrounded by mostly undeveloped desert habitat.  The draft DRECP adds National Landscape Conservation status to the existing ACEC, but would designate most of the open desert around it as a DFA.  Again, much of the DFAs around the rings fall on private or State lands, not BLM.

Cady Mountains:  The ghost of the Calico Solar project lives on.   This project was approved but never built because of troubles with the "suncatcher" technology and financing.  The old right-of-way for the Calico Solar project remains undesignated in the draft DRECP.  Presumably this would still count as a solar exclusion zone under the Solar Energy Development Policy finalized in 2012, but it seems odd that this area was not designated as an ACEC given that studies pointed out the significant importance of the entire right-of-way for wildlife - including white-margined beardtongue, Mojave fringe-toed lizard, and desert tortoise.

Desert Tortoise Natural Area:  This sanctuary for the desert tortoise near California City would lose about 250 acres at its northern edge that would then be designated as part of a larger DFA, according to documents in Appendix L of the DRECP.

I will need to continue studying the plan and look forward to hearing other people's concerns from across the desert on how the DRECP will impact our desert wildlands.

Public Input Needed:

You can provide your input on the draft DRECP to Federal and State agencies by e-mail or regular mail, or at any one of several public meetings scheduled in California towns and cities.   Comments are ultimately due by January 9, 2015. 

Stay tuned for more as we continue to look through the draft DRECP.

Sunday, September 21, 2014

The DRECP: To Protect or Undo the Desert?

The Department of Interior this week will unveil the draft Desert Renewable Energy Conservation Plan (DRECP), and it is a big deal.  The DRECP will establish "development focus areas" where the review and approval of large-scale renewable energy projects will be streamlined, and will identify other lands for additional conservation measures.  How much of each - destruction and conservation - and which lands will be affected will be revealed in the draft later this week. 

The DRECP is a big deal because it will propose the most significant changes to how we manage the California desert since Congress first ordered Interior to take better care of the of these lands decades ago.  In 1976, Congress passed the Federal Land Policy and Management Act that ordered Interior to establish the California Desert Conservation Area Plan (CDCA) "to provide for the immediate and future protection and administration of the public lands in the California desert within the framework of a program of multiple use and sustained yield, and the maintenance of environmental quality."   Interior finalized this plan in 1980 and it guides the management of over 10 million acres of public lands in the desert.  Depending on what balance the DRECP strikes between conservation and energy development, the DRECP could undermine the original intent of the CDCA Plan by giving one human use undue access to public lands and impair other qualities of the California desert that Congress sought to protect.

The DRECP will drastically alter how the California Desert Conservation Area (highlighted above) will be managed. Map from the DRECP website.
It's Going to Get Loud

The State and Federal agencies presenting the DRECP - the Bureau of Land Management (BLM), Fish and Wildlife Service (FWS), California Department of Fish and Wildlife (CDFW), and the California Energy Commission (CEC) - are likely to receive an earful no matter what the draft DRECP looks like.  There is historic precedent for what is about to happen.

Although the ecologically illiterate view the desert as a wasteland, it is apparently the most beloved wasteland in existence because there is no question that there are a lot of people passionate about the desert, and a lot of companies that have substantial economic interest in developing the desert.  These intense human demands on the desert are what brought Congress to order the CDCA Plan in the first place, and that plan elicited a vocal response from the public when it was first presented as a draft.

The Silurian Valley in the mid-day sun, north of the highway outpost of Baker, California..  It is difficult to comprehend the magnitude of these wildlands.  The Silurian Valley is a vast swath of creosote bush scrub habitat that will either become an industrial zone, or be preserved for future generations under the DRECP.  The high point of the Avawatz Mountains in the distance is over 15 miles from where this photo is taken.  That is more distance than the greatest width of Shenandoah National Park, more than the length of the Yosemite Valley, and nearly twice the width of the San Francisco Peninsula.
Bill Mayhew, a zoologist and founder of the University of California's Natural Reserve System, was a member of a citizens' committee that advised BLM on the creation of the CDCA.  In an April 1980 interview with the Associated Press, Mayhew lamented the onward march of golf courses and subdivisions in the Palm Springs area, and described the CDCA plan as "the only chance we've got...[y]ou can't just have everybody out here doing as they please, not anymore. There's so many people that they just love the desert to death."  Mayhew's research focused on the fringe-toed lizard at the time - a species that continues to face habitat loss and degradation.  Mayhew warned that there would be ongoing conflict over the CDCA Plan across various interest groups.  "There's going to be blood on the floor before this thing's settled."  Then-State Director for the BLM in California Jim Ruch told the Associated Press that the "conflicts that made it necessary for us to prepare this plan in the first place are not going to diminish as time goes on...[t]hey are going to get worse."

So What's New About the DRECP?

The original CDCA Plan was published in 1980 after years of study and public comment, and acknowledged the need to accommodate the growth of renewable energy as one human use among many others that necessitated better management, including recreation, other types of energy generation and transmission, cultural and scenic resources.  The original CDCA Plan published in 1980 did not pretend to solve all of the conflicts, but it did seek to strike a balance among the various uses without granting one industry undue privilege to destroy intact wildlands.  And the authors probably could not imagine hundreds of square miles of the desert being bulldozed for utility-scale energy projects.

Renewable energy appeared to be an insignificant threat to the desert back then.  Other industrial and recreational uses of the desert seemed to be at the forefront of the public debate, and still significant enough to merit Congressional action.  Off-highway vehicle recreation, mining, and fossil fuel power plants spurred widespread concern for the desert landscape.  If you think the concerns expressed in recent CEC hearings for solar power plants are new, take a trip into the archives.  The California Energy Commission in 1981 approved Southern California Edison's plans to build a 1,500 megawatt coal power plant proposed to be built in the Ivanpah Valley (never built), and conditionally approved alternative sites in the Cadiz and Rice Valleys - all locations prized for remote and beautiful desert scenery. A coal power plant belching pollution would have been an unwelcome addition.  In an article published in the Lodi News-Sentinel, a spokesman for Native American tribes echoed a sentiment often heard in response to industrial-scale solar development today - "[w]e don't want coal power plants anywhere on the Mojave" - noting that the desert is "sensitive to religious tribal values." Environmentalists echoed similar concerns about the impacts of off-highway vehicle usage, which etched thousands of miles of tracks and new roads into the desert.

When Interior sought input from the public and other agencies on the creation of the CDCA Plan in the late 1970s, the CEC did communicate the State's desire to develop utility-scale renewable energy projects in the desert.  The BLM noted the CEC's Biennial Report from 1979 as part of the input it used to determine the extent of interest in destroying the desert for energy production, including wind, geothermal and solar projects.  The 1979 Biennial Report projected that in the year 2000 there may be as much as 1,500 megawatts (MW) of wind energy,  2,900 MW of geothermal projects, and 300 MW of solar throughout the State in a "conventional" scenario.  

It will not surprise you to learn that the CEC in 1979 identified wind resource areas in the western Mojave Desert near Tehachapi and the Antelope Valley, Palm Springs, and eastern San Diego County, and geothermal resource areas in the Imperial Valley and north of San Francisco.  Neither the original CDCA Plan nor the 1979 CEC Biennial Report identified specific areas in the desert for solar, but with a target of 300 megawatts that probably would not have been viewed as a challenge to the overall goals of the CDCA Plan.  Today, the DRECP plans to amend the CDCA to accommodate as much as 20,000 megawatts of renewable energy projects - a substantial increase over original assumptions from 1979.  For the DRECP, the question will ultimately be how many of these megawatts will be sited on already-disturbed lands, on rooftops, or on currently pristine desert wildlands.

A map from the CEC's 1979 Biennial Report depicts the presumed extent of viable geothermal and wind resources in California.  This report was used by the BLM in its consideration of future energy development in the CDCA.  Much less extensive than the energy zones being examined under the DRECP amendment to the CDCA.

Although the CEC's 1979 Biennial Report does not specify how much solar should be built in the desert, it seems quite appropriate to me that the image that immediately follows the wind/geothermal map in the report is that of a rooftop solar installation.  The CEC was on to something.
National Conservation Area or National Industrial Area? 

When the draft DRECP is released, we will see to what degree the Obama administration wants to respect the CDCA as a nationally significant conservation area, or convert the region into an industrial zone.  I am concerned that the DRECP may very well put the thumb on the scale to favor one type of human use - specifically, the for-profit destruction of intact desert wildands by companies that want to build large wind, solar or geothermal energy projects.  If this is the case, it could constitute undue impairment of the qualities of the California desert that Congress sought to protect with the passage of the FLPMA in 1976. 

Congress and Interior in 1976 recognized that the environmental health of the California desert was "seriously threatened" by the growing population of southern California, and the popularity of multiple human uses in the desert, including recreation, mining, energy, and grazing.  The original CDCA Plan attempted to balance all of these competing demands, without giving any single user dominance over the other and while maintaining the overall quality of the environment.

There have been two substantial changes in the energy landscape since 1976 that will be relevant to the DRECP.  First, we recognize that our current energy paradigm is too dependent on fossil fuels and has created a climate crisis that threatens our environment and communities, requiring a rapid switch from fossil fuels to clean energy.  Secondly, technological and economic evolution has made distributed solar generation, energy efficiency, and local energy storage a viable alternative to our fossil fuel addiction.  A shift to renewable energy in 1979 would have essentially required a reliance on utility-scale renewable energy power plants.  Today, policies and incentives can be crafted to ensure that our new energy path is not only renewable, but also sustainable and friendly to wildlands and wildlife.  We will see this week if the DRECP recognizes this opportunity to protect a unique, fragile, and beautiful landscape.

Monday, September 8, 2014

Time for Desert Communities to Take PRIDE

The Daily Press and residents of the Victor Valley in the western Mojave Desert are issuing a PRIDE (People Ready to Improve the Desert Environment) challenge to address the many facets of blight that are evident in the region.   As a kid playing in the open desert across the street from my Victorville home in the 1980s and 90s, I would find trash dumped by residents too lazy or cheap to responsibly dispose of tires, furniture and other refuse. 

I have written before about the need for desert communities to respect themselves and surrounding wildlands, in part by minimizing our impact on desert habitat and keeping both the desert and our cities clean.  The lack of respect by some leaves an impression for all to see, but how long we tolerate the mess is ultimately up to all of us.  In a single hour, my sister and I were able to fill five large bags  of trash that we removed from a small patch of Joshua tree and pinyon juniper habitat in the western part of the Victor Valley.  Not long after that, I heard about a couple of other organizations closer to the Yucca Valley that were committed to volunteer clean-ups of our desert.  Most recently, I was inspired by Death Valley Jim's initiative to clean-up some public lands near Barstow and Yermo that have been trashed by disrespectful users.

So it is refreshing to see community leaders in the Victor Valley taking notice, and refusing to tolerate the mess left by a few.  Most recently, Daily Press editor Steve Hunt kicked off a series to showcase both examples of blight, as well as evidence of folks taking pride in the community. 

Here are some of my own photos to showcase some of the messes I have unfortunately come across during my travels in the desert:

I came across this heap of illegally dumped trash and a discarded boat in the middle of what was otherwise a beautiful stretch of the western Mojave Desert between Palmdale and El Mirage, and just south of Edwards Air Force Base.


I got up early one morning in December 2012 to photograph sunrise in some Joshua tree woodland area in western Victorville, and had to do a lot of creative framing to keep trash out of the photos.  Eventually I gave up and made trash the subject.

The typical beautiful desert sunrise cast striking colors on the horizon, but you have to look past the trash dump.

There were several different trash piles scattered about in close proximity.  I could not help but wonder whether they were all from the same person - perhaps returning with more trash every other year - or from different people.  Either way, I was frustrated that I could not enjoy a walk in the desert without stumbling upon their mess.

On a hike in the Juniper Flats area above Apple Valley I came across a common sight - a balloon caught in the shrubs.  I have pulled at least a dozen balloons and many more plastic bags from the desert, even from areas as remote as the Silurian Valley and near the Cady Mountains. If you buy a helium-filled balloon, please do not release it.


The desert is a beautiful place, and those that have the privilege to live in the desert should take pride in their community and the desert wildlands that surround us. 


The morning sun hits yucca in bloom near Apple Valley and Juniper Flats.
As others have done, you can always set out and clean up your neighborhood or your favorite patch of desert.  Every twenty minutes or hour that you spend walking and picking up trash will add up over time, and eventually we can defeat the apathy that has allowed blight to flourish.   For organized events, I am sure you can stay tuned to the Daily Press, or check out the Environmental Awareness Day event at the Mall of Victor Valley on October 17 for opportunities to get involved.   On September 27, there are several events scheduled for National Public Lands Day across southern California, and Death Valley Jim has helpfully listed the details on his website