Wednesday, November 11, 2015

Final Plans for Public Lands Portion of DRECP Introduce Ambiguity

The Department of Interior on Tuesday released the final environmental impact statement for the first phase of the Desert Renewable Energy Conservation Plan (DRECP), which significantly alters the land use planning for public lands administered by Interior in the California desert.  Although the final version expands conservation designations that were popular in the draft DRECP,  it also seems to introduce uncertainty for nearly 802,000 acres of "unallocated" lands that are neither part of conservation nor a development designation.  The public has 30 days to submit any concerns regarding the final draft before it is made official by a Record of Decision.

Subtle Change Has Significant Impacts

If you looked at the draft DRECP released for public comment late last year you probably paid attention to where large-scale energy development would be allowed, and where it would not.  After all, it is the added threat posed by utility-scale energy development to public lands that prompted the plan in the first place.  You probably looked at the maps showing where Development Focus Areas and variance lands would streamline renewable energy development.  Under the draft DRECP these were the only places where new utility-scale power plants could be built. Other areas - public lands with conservation designations and lands considered "non-designated" - would not allow new large-scale renewable energy generation (see below, page II.3-426 of the draft DRECP).

So it was a surprise to find that the final DRECP opened those "non-designated" lands to renewable energy development.  The final DRECP now calls these lands "unallocated" and they cover 802,000 acres of desert wildlands.  This subtle change nearly doubles the amount of acreage vulnerable to utility-scale energy development, adding to the 428,000 acres of development focus areas and variance lands designated for streamlined renewable energy development.

The final DRECP suggests that renewable energy projects on unallocated lands will not benefit from the streamlining features of the development focus areas, but experience over the past couple of years indicates that energy developers are willing to move forward with project proposals outside of designated development zones.  Some management prescriptions included in the final DRECP could be used to deny industrial development on unallocated lands, but they appear to be written vaguely enough to give wide discretion to permit substantial energy development outside of the development focus areas.  Interior has not signaled how it intends to screen projects proposed on these lands.  Please see the map below for the locations of unallocated lands in the final DRECP.

The resulting combination of development focus areas, variance lands, and unallocated lands provides more acreage to energy development than the California portion of the Solar Programmatic EIS.  In some cases, areas identified as solar energy exclusion areas under the Programmatic EIS could now be re-opened to energy companies.  For example, the former site of the proposed Calico Solar power project south of the Cady Mountains - identified as an exclusion area under the Programmatic EIS - appears to be among the unallocated lands potentially available to solar energy development.

Conservation Lands Given Some Durability

The final DRECP does try to clarify concerns the public expressed after release of the draft regarding the durability of the National Conservation Lands designation (NCL, also known as the National Landscape Conservation System or NLCS).  Interior clarified that they considered the NCL designations established in the final DRECP to be permanent.  However, the final DRECP indicates that Interior will always exercise the discretion to change how the National Conservation Lands are managed.

The final DRECP bestows conservation designations to many of the public lands in the California desert through NCL designations and Areas of Critical Environmental Concern (ACEC).  The vast majority of public comments on the draft DRECP released last year expressed a desire to extend these designations to more of the desert.  Although Interior expanded some NCL designations in the final DRECP, it still seems that Interior was conservative in designating NCL status.  Vast tracts of public lands in the western Mojave are left out of the National Landscape Conservation System.

The most notable changes in the final DRECP include the removal of the potential development area in the Silurian Valley and the extension of NCL status to more wildlands in the Cadiz Valley and around Iron Mountain.  Although ACEC designations are extended to other areas of the desert and limit industrial-scale development, ACEC's can be rolled back during future administrative revisions of the land use plan.
The Silurian Valley has been designated as National Conservation Lands after Interior discarded a proposed development area here. Avawatz Mountains in the distance.

Sunday, November 8, 2015

Solar Power Tower Developers Attempt to Dismiss Shortfalls

Solar power tower developers have chided critical press coverage of their massive facilities as letting perfect be the enemy of good.  But we have learned enough about this technology to know that power tower projects do not even qualify as "good" clean energy projects.  Far superior alternatives exist in terms of life-cycle carbon emissions and sustainable siting.

Solar power towers have earned a bad reputation, and their developers are desperate to restore the green halo that they enjoyed a few years ago.  NRG - the current owner of the Ivanpah Solar project in California - and Solar Reserve - owner of the Crescent Dunes project in Nevada - have long been on the defensive with inaccurate and misleading public relations efforts.  But they have stepped up their PR efforts after new reports on their natural gas use and impacts on wildlife. Although developers promise to eventually deliver energy storage benefits, other technologies allow us to do so without burning birds in mid-air or natural gas.

The Ivanpah Solar project destroyed 5.6 square miles of intact desert habitat, displaced or killed over 150 desert tortoises, burns birds in mid-air, and burns natural gas at night to keep its boilers warm.  But the project's owner, NRG, would like you to believe that it is a good "clean" energy project.
Dissecting the PR Campaign
You'll hear that the power tower projects' natural gas use is trivial, or that the projects have found a way to avoid all bird deaths.  Or that they have only been built on already-disturbed lands. These claims are misleading and dismiss significant deficiencies in sustainability that do not deserve to be part of our renewable energy portfolio.

Natural Gas
The latest fact to irk the solar power tower industry is that the Ivanpah Solar project uses natural gas to keep its giant boilers warm at night, and emitting nearly 50,000 metric tons of carbon dioxide each year.  A Las Vegas Sun editorial favorable to NRG - a corporate behemoth that also operates coal and oil burning power plants - suggested that concerns over Ivanpah's natural gas usage is tantamount to criticizing the fuel usage of a hybrid Toyota Prius.  This is an erroneous comparison.  It would be more accurate to say that Ivanpah Solar is a Tesla electric vehicle that secretly burns fossil fuels when it is sitting in the garage at night and not even being used.  Or, at best, Ivanpah is like a Volkswagen Jetta that we thought had a certain level of efficiency, but later found out to guzzle a lot more fossil fuels.

We were told that Ivanpah is a solar power project that generates energy from the sun, but apparently it cannot do so without burning natural gas.  And the Ivanpah project's developers increased the amount of natural gas usage after the public environmental review process.  Are we making perfect the enemy of good?  No, because "good" clean energy projects don't actively burn fossil fuels to generate said "clean" energy.   Other renewable energy technologies have matured beyond the need for fossil fuel training wheels.  We're not going to applaud NRG for taking us back to the fossil fuel era.

Crescent Dunes does not use natural gas like its cousin in Ivanpah, but from a life-cycle perspective its power tower is still a monument to fossil fuels.  The project's tower is composed of approximately 130,000 cubic yards of concrete, according to the Las Vegas Review-Journal.  Every cubic yard of concrete is responsible for nearly 400lbs of carbon emissions (low estimate). So the Crescent Dunes project alone is responsible for at least 23,000 metric tons of carbon emissions.  Other solar technologies (and especially rooftop solar) do not require as much carbon-intensive material as power tower construction.

Bird Deaths
The industry has deployed two opposite, but misleading responses to the problem of bird mortality at power tower projects - that they have solved the bird mortality problem (not true), and that other human activities kill more birds than power towers so therefore we should not be concerned with mortality at power towers (a classic red herring).

Wildlife biologists have attempted to study bird deaths at the Ivanpah and Crescent Dunes projects, but the sheer size of the projects pose many challenge.  Finding dead birds among fields of mirrors that can span several square miles is not easy, and scavengers can pick up the dead birds before biologists have a chance to find them.

In the case of the Crescent Dunes project, the solar flux generated by the field of mirrors in stand-by mode may be so intense that the birds are incinerated in mid-air, leaving little for biologists to find on the ground.  Solar Reserve erroneously claims that simply putting the mirrors in a different stand-by position will reduce bird deaths at the project to zero. This is a nonsensical claim because bird deaths at power tower projects are not only caused when mirrors are in a stand-by position.  Focusing the mirrors in many different positions may reduce the intensity of the solar flux during stand-by, but birds can still sustain life-threatening heat stress in the elevated heat above the mirror field.  And when the mirrors are focused on the power tower, the intense heat closest to the power tower still burns birds' feathers. 

Solar Reserve counters that the brightly-lit tower will "deter" birds.  This is another absurd claim because we know that the brightly-lit tower at Ivanpah still kills birds.  If anything, the intense light may attract swarms of insects that attract the birds.  A video (see below) recently obtained by Basin & Range Watch also shows what are likely horned larks flying into the solar flux zones immediately adjacent to the brightly-lit tower at Crescent Dunes.  All evidence indicates that solar power towers kill birds, whether they are in operation or in stand-by mode.  Industry cannot simply wish away a problem and expect us to accept their unscientific claims.

Studies based on early mortality reports estimate that the Ivanpah Solar project may kill as many as 28,000 birds each year.  NRG executives have told the press that those numbers are "inflated," and then deploy the "cat" excuse - cats kill millions of birds each year, so it's not worth worrying about power tower impacts on birds.   ReWire excellently tackles this faulty comparison in-depth.  Simply put, two wrongs do not make a right.  We need to reduce all sources of avian mortality, and especially avoid introducing new sources of mortality in the heart of our desert wildlands.

Definition of "Disturbed" Lands
Utility-scale energy developers that bulldoze wildlands will find any reason to label wildlands as worthy of destruction.  An NRG executive wrote an op-ed chiding coverage of the Ivanpah plant's use of natural gas, but also claims that:
"[I]t is important to note that the plant was not built on undisturbed land, as stated in the article. The land had been previously used for cattle grazing and off-road vehicle use, and was littered with abandoned vehicles and crisscrossed with transmission lines and is within walking distance of a 36-hole golf course, an Interstate, a casino and a shopping mall." -David Knox, NRG.
This is a ridiculous statement and shows NRG's ignorance of geographic scale and conservation biology.  For starters, NRG doesn't know where it's own project is located.  NRG's website depicts the location of Ivanpah as being located north of Tecopa, over 50 miles away from the actual location.  In the Ivanpah Valley, where the project is actually located, the company mowed down nearly 5.6 square miles of intact desert wildlands.  For comparison, you could fit 12  Disneyland & California Adventure theme parks within the perimeter of the Ivanpah Solar project.

A screenshot taken from NRG's website on November 8, 2015.  NRG depicts the Ivanpah Solar project location as north of Tecopa, California.  It is actually located southwest of Primm Nevada, over 50 miles away.
It is true that a highway splits the Ivanpah Valley, and the relatively small outpost of Primm has some hotels, gas stations, and a golf course.  But Ivanpah Solar is still more than three times larger than all of that development combined.  And the habitat that Ivanpah destroyed was not in an abused state as NRG claims - it was vibrant enough to host rare plant species and over 150 threatened desert tortoises.  Once again, NRG would like us to believe that previous human impacts are an excuse for the company to do more damage.
A construction marker on intact desert habitat before crews mowed down 5.6 square miles of creosote and yucca scrub habitat.  The video below shows crews mowing vegetation to make way for the Ivanpah Solar project.

Tuesday, November 3, 2015

Southern Nevada Wildlands Get Temporary Reprieve

A Federal judge recently ruled against the Bureau of Land Management's approval of the Searchlight Wind project because the BLM did not adequately analyze potential impacts on golden eagles, bats and desert tortoises, according to Basin & Range Watch.  The BLM initially approved of the Searchlight Wind project in 2013 based on poor quality wildlife surveys paid for by the developer.  The original impact analysis considered only three golden eagle nests within a ten-mile radius of the wind project, even though a separate study funded by the BLM found as many as ten nests.

Apex Clean Energy - the project developer - and the BLM may decide to redo some of the environmental analysis that the court found to be lacking.  However, it would be wiser if Nevada and its neighbors focused investments on energy efficiency, and implemented policies that encourage distributed, locally-controlled renewable energy generation and battery storage.

Spirit Mountain at dusk. This photo was taken from within the footprint of the proposed Searchlight Wind project site
This stretch of southern Nevada is relatively uninterrupted by large-scale human development, providing opportunities for primitive and unconfined recreation.  Once off U.S. Route 95, it is easy to find solitude in the vastness of the Piute Valley and Searchlight Hills, and witness a vibrant and diverse desert ecosystem.  The area is home critical habitat for the desert tortoise, the scenic Wee Thump Wilderness area, and Spirit Mountain, a location of significance to Native American tribes. 

If Apex Clean Energy insists on moving forward with the original project proposal, the area will be transformed by 87 wind turbines - each taller than the Statue of Liberty - and connected by over 35 miles of new roads and 16 miles of new transmission lines.  Apex Clean Energy's proposal further demonstrates that an industry-driven response to climate change lacks a conservation ethic or a concern for sustainability, and underscores the need for a community-focused clean energy path.

Sunday, October 11, 2015

Supervisor Lovingood Lays Out Hollow Case Against Monuments

San Bernardino County Supervisor Robert Lovingood traveled to Washington last week to testify against the potential establishment of national monuments in the California desert, but his concerns rang hollow.  His most concrete complaints centered on the prospects of a long-shuttered gold mine located over 70 miles from the nearest San Bernardino County city and owned by a Canadian company.  Lovingood's testimony reveals that his opposition to the monuments is politically motivated, rather than practically rooted and that he is out of touch with his constituents.

Lovingood Picks a Battle Over Castle Mountains

Most San Bernardino County residents would fall in love with the Castle Mountains if they saw them.  But Supervisor Lovingood's testimony suggests he has a different vision for this remote stretch of the county.  Lovingood expressed concern to officials in Washington that the nearby Castle Mountain gold mine may have difficulty operating if a desert monument is established around this portion of Joshua tree-studded wildlands.  The monument proposal would not impede mine operations, according to the Senate, but Lovingood worries that the monument would scare away the mine's international investors and a chance at 300 jobs and $250 million in tax revenue.  Lovingood failed to mention that the tax revenue would be unreliable and that the jobs would probably go to Nevada, not San Bernardino County residents.

Joshua trees frame the Castle Mountains in the eastern Mojave Desert, San Bernardino County, California.  A Canadian mining firm has won County Supervisor Robert Lovingood's support to revive a gold mine here, over 70 miles from the nearest County town, and next to a national park. Photo by David Lamfrom.
Mining has been a centerpiece of both Lovingood's and Congressman Paul Cook's opposition to the desert monuments, yet San Bernardino County acknowledges that mining jobs accounted for approximately a tenth of one percent of the county's employment in 2014.  And even if the Castle Mountain mine's Canadian owners can wrangle the millions of dollars it needs from investors to resume operations, its remote location probably will draw workers from Nevada, not California.   The mine is located between the Nevada town of Primm and the California town of Needles.  Needles has a population of less than 5,000 people and is located over 70 miles from the mine.  The next nearest California city is Barstow, over 130 miles away.  You'll spend the money you earn at the mine on the gas it takes to get there.

The gold mine's proponents seem to be chasing a quick buck.  Gold prices are just now rising but could drop yet again, leaving the mine closed and workers out of a job.  Lovingood is pinning up the mine as some economic hope when it is barely more than a mirage. Nonetheless, the Senate has worked with the mining company to ensure that the monument proposal would not affect its operations.  The mine could begin operations today, if it so desired.  And even if it does, I bet most of the workers will be from Nevada, and most of the money will flow to Toronto.

Passing the Buck on Road Repairs

Passing the buck for his own leadership failures, Lovingood stated that the monument proposals would make it difficult to repair county roads and that the Department of Interior has a long list of deferred maintenance that impacts county transportation.

The stretch of Route 66 in San Bernardino County represents one of the most pristine segments of this historic road, coursing through desert wildlands that are preserved as earlier generations experienced them early last century.  The route courses through an area rich with history, from Native American cultural sites, the experiences of economic refugees in the Great Depression, and where Patton trained his troops for World War II.
Lovingood indicated that a monument designation would make it more difficult to repair Route 66 because the county would not be able to mine raw materials immediately adjacent to the road.  This seems like a ridiculous argument.  How often do road repair crews ask to mine your front yard for raw materials needed to fix the road?  Even if this were a valid argument, Lovingood has no excuse for the fact that the county has closed a significant portion of Route 66 for over a year because of damage caused by a rain storm in 2014.

The County is responsible for repairs to Route 66, but has failed to do so for over a year on a 30+ mile portion of the Mother Road.  County Supervisor Lovingood has no excuse for this failure. Image from San Bernardino County.
The county's closure of Route 66 is significant because tourists from all over America and the world travel to see this pristine stretch of Route 66, only to be turned around by bright orange traffic signs.  The last time I went camping in the desert I had to turn around and find an alternate site, turned back by the road closures.  Lovingood is busy spending county money on travel to Washington to oppose a monument, but he can't find the money to repair this road and advance the county's tourism economy?  Mojave Trails National Monument would protect a stretch of American heritage along this historic route.  It's time that the County also act as a good steward of this national treasure and repair Route 66.

Lovingood also complains that the Federal government has not been able to pay for maintainance on roads and infrastructure within existing national parks.  This is indeed a problem, but Lovingood seems to forget that Congress controls Federal spending.  He could have spent his time in Washington asking Congress to properly fund the Department of Interior.  Cutting a fraction of tax loopholes that allow corporations to do their banking in the Cayman Islands would quickly fill any funding shortfalls for our national parks, and much more.

Time for Leadership

It is time for San Bernardino County's leaders to shepherd the economy into a sustainable future and not drag it into an outdated past.  Mining is a big part of San Bernardino County's history, but it is not a big part of our modern economy.  San Bernardino County's website contains images of mining activities and the most recent image on the website (below) is from 1919.  Even if the county posted more recent photos, its own reports acknowledge that mining now constitutes a mere fraction of one percent of the county's employment.

A photo of miners from 1919. Image from San Bernardino County website.
San Bernardino County is home to some of the most beautiful, pristine landscapes in the nation. Tourists travel across the world to see our national parks and county residents enjoy spending weekends under starry night skies, or riding down a 4x4 route in the desert for rejuvenation or solitude.  But the county has done little to recognize these treasures.  I mentioned earlier that a portion of Historic Route 66 has been closed for over a year.  County Supervisor Lovingood has also not shown any leadership in pressing Washington to fund our national parks or to encourage tourism.  Instead, he is flying to Washington to protest his own constituents' efforts to protect our public lands from destruction.

It is not too late for Lovingood to step up to the plate and represent his District.  It should not be difficult. Nature has blessed San Bernardino County with an increasingly rare treasure - peaceful, pristine open space.  Let's manage this space responsibly for future generations.

Thursday, October 8, 2015

What are you doing on Tuesday?

Now is our moment to protect public access to desert wildlands for future generations to enjoy.   Tuesday is an important opportunity to tell government officials that we cherish the vast open landscapes that the California desert has to offer.  Our presence will send a message that we are tired of losing public lands to private, for-profit destruction.  At stake will be the White House's consideration of the Mojave Trails, Castle Mountains and Sand-to-Snow National Monuments.  Without these monuments, our desert will transition from a humbling, natural landscape to an industrial checkerboard. 

The desert that early inhabitants experienced was a lot more expansive than the desert we know today, and if we don't take action now, our grandchildren will inherit a landscape unrecognizable to us and preserved only in our photographs.  Since 2009, dozens of square miles of our desert wildlands have been bulldozed and converted into energy projects and subdivisions. The alternative to these monuments is to continue bleeding away our wildlands through a thousand cuts.  Allowing mining here, transmission lines there, and more energy projects over there.  Soon enough, the sense of solitude and the vistas that we cherished will be gone.

Please show your support for our desert public lands on Tuesday, October 13, 1:00PM at the Whitewater Preserve.  Government officials will be on hand to hear comments about our desert wildlands and discuss the monument proposals.  For more details and to RSVP, please visit the following link: October 13 Public Meeting

The map below shows the solar and wind energy projects proposed as of 2008, at the height of the renewable energy rush on wildlands.  It is illustrative of the extent of destruction that is possible if we do not take steps to protect our public lands.  At least 24 of the proposed projects fall within the proposed boundaries of the monuments, and the map does not depict other destructive proposals, including pipelines and mines.  Without monument status, these lands may be unrecognizable in another 30 years.

Sunday, October 4, 2015

Cook's Desert Bill is a Political Ransom Note

A new bill introduced by Congressman Paul Cook would encourage the destruction of over 246 square miles of desert wildlands in exchange for widely supported conservation designations.  The bill - the California Minerals, Off-Road Recreation, and Conservation Act - panders to harmful, for-profit uses of public lands, including in the heart of the Mojave Desert along Historic Route 66.

The bill appears to be an effort to counter the desert conservation and recreation legislation introduced by Senator Feinstein, who decided earlier this year to seek establishment of desert monuments through the Antiquities Act because of roadblocks in Congress.  Contrary to misinformation I have seen spread online, the monuments would not "restrict access" for people that enjoy and explore desert wildlands.  I say this as a person that uses designated routes to access remote areas of the desert for camping, hiking and photography.  Unlike the monument proposals, Cook's bill would promote the mismanagement of our public lands and do irreparable damage to the landscapes that we treasure.

No Mojave Trails Monument; Mining Instead 

The community widely supports a monument designation for Mojave Trails to protect a swath of intact desert wildlands from Ludlow to Needles from industrial-scale development.  But Cook's  bill would explicitly prevent a monument designation, and instead establish a "Mojave Trails Special Management Area" where mining would be encouraged on nearly 150 square miles of this remote and pristine stretch of desert along Historic Route 66.  Mining, like large-scale solar projects, can involve significant and long-lasting disturbance of the land that is often visible for miles around.

Allowing so much mining in such a remote area would undermine the very qualities people from all over the world appreciate about this stretch of Route 66 and surrounding wildlands.  Cook's own bill recognizes these qualities, stating its intent "to secure the opportunity for present and future generations to experience and enjoy the magnificent vistas, wildlife, land forms, and natural and cultural resources of the Management Area."  But this intent is immediately undermined by the inclusion of language pandering to the mining industry.

The bill also includes provisions to facilitate the expansion of the Castle Mountain Mine next to the Mojave National Preserve.  This gold mine ceased operations in 2001 because of falling gold prices, but a Canadian company is pushing to re-open strip-mining operations and tap new water wells.  The mine is in the remote Lanfair Valley, over 80 miles from the nearest city.  Conservationists had hoped to include the reclaimed land in the Preserve and protect the Joshua tree studded landscape.  Cook's bill will allow the Canadian company to strip more of the mountains before eventually including them in the Mojave National Preserve.

Expanding Motorized Free-for-All Zones

Mining companies would not be the only interest robbing us of desert wildlands.  Cook's bill would also expand Off-Highway Vehicle (OHV) Recreation Areas by 95 square miles, adding to over 220 square miles of existing OHV Recreation Areas.  Let's be clear - there is a stark difference between maintaining access to public lands through designated routes,  which I support, and the destructive free-for-all that is encouraged within Off-Highway Vehicle Recreation Areas. 

An example of a high-disturbance area in the Johnson Valley Off-Highway Vehicle Recreation Area. There are no limits to where vehicles can travel within OHV Recreation Areas.

An example of a designated route in the Mojave Desert. There are thousands of miles of such routes across the California desert.  Designated routes provide access to outdoor recreation and solitude, but noticed that desert vegetation and soils are healthy.  Designated routes can be enjoyed responsibly.  OHV Recreation Areas will turn the desert into a Mad Max-like free-for-all with no regard for nature.
The additional square miles would be added to the Johnson Valley and Spangler Hills OHV Recreation Areas.  These are unnecessary expansions that will lead to the degradation of wildlands over time.  Most of the desert - other than official wilderness areas - are accessible through thousands of miles of designated dirt roads.  But in OHV Recreation Areas, motorized vehicles do not adhere to designated routes.  Hundreds upon hundreds of off-trail trips by motorized vehicles convert a healthy desert ecosystem into a severely disturbed area that will take a long time for nature to repair.

There is no shortage of options for off-highway vehicle use in the California desert, and it can be accommodated responsibly and sustainably.  Many visitors to the desert respect the wild qualities of the landscape that make it worth the trip, staying on designated routes to visit places for camping, hiking, rock hounding, etc.   In the western Mojave alone there are more miles of designated routes than there are miles of roads in Los Angeles. There are even off-highway vehicle races that are held in the desert on some of these designated routes.

Given how destructive and self-indulgent OHV Recreation Areas are, it's a bit of a stretch to think that we even have 220 square miles of such zones in the California desert.  The existing OHV Recreation Areas encompass a combined land area more than three times the size of Washington, D.C.  Adding 95 more square miles is overkill.

Political Ransom, Not a Balanced Compromise

Cook's bill is representative of a political process that holds conservation hostage on behalf of private interests.  Every acre of land that we simply let be in its natural state for future generations to enjoy requires the immediate sacrifice of some other area.  Even Feinstein's California Desert Conservation and Recreation Act includes compromises that would allow utility companies to build transmission lines across the untarnished vistas of the Mojave Trails area.  Cook's bill also includes this gift to the utility companies.

This is not a new dynamic but it is one that seems to be getting worse.  You want to protect some canyons for future generations? Tell me what public lands we should sacrifice to oil and gas companies.  You want to protect this desert valley?  Then pick which mountains we should carve up for a wind energy facility.

The political narrative driving this hostage taking suggests that being good stewards of public lands is some diabolical plan by the Federal government to take our rights and prohibit access to the land.  Our elected representatives hide behind false notions that they are making a balanced compromise, or defending public access or property rights. But what they are really doing is handing over our natural treasures to private interests.

Public land managed for future generations is an American treasure.  It means that two or three generations from now a distant relative can visit your favorite camping spot in the Mojave and experience the same quiet sunset that you did.  Future generations will not fault us for protecting wildlands, but they will blame us for the scars that our reckless decisions leave on the landscape.

Wildflowers in bloom along the lava rock near Amboy Crater in the proposed Mojave Trails National Monument.
Taken from atop Amboy Crater, looking north toward the Bristol Mountains.  Route 66, barely visible, lies between Amboy Crater and the mountains in the distance.

Sunday, September 20, 2015

First Solar Project Displaces Over 160 Desert Tortoises

First Solar has displaced at least 161 adult and juvenile desert tortoises to make way for its Silver State South Solar project in Nevada, as of August 2015, according to documents provided by the Department of Interior.  Initial information indicates several tortoises relocated from the project site have already died, possibly as a result of being forced into unfamiliar ranges.  First Solar is clearing over 3.7 square miles of intact desert habitat for the project after the company ignored requests to consider less destructive locations.  Underscoring its interest in profit over the environment, the company has even funded attacks on rooftop solar - a more sustainable alternative to meeting our renewable energy needs that First Solar sees as a threat to its bulldozer-led approach.

Translocation Results Uneven
Although the 161 desert tortoises found on the Silver State South project site were moved to the surrounding desert before bulldozers leveled the area for solar panels, at least seven of the displaced animals have fallen victim to natural predators and hyperthermia months after construction began. By contrast, only three of the animals already resident in the translocation recipient site have succumbed to predation, according to a review of documents provided by the Department of Interior in response to a Freedom of Information Act request.  Biologists will need to determine if the translocated tortoises have lower survival rates than tortoises already residing in the recipient site.

We do not know much about how the process of translocation impacts tortoises, but we do know that tortoises are very accustomed to their home range.  Tortoises in their home range know where they can find fleeting pools of water during a rain shower, or where to find shelter from the sun when foraging during the hot daytime hours.  Messing with their routines probably does not have a positive effect.

This deceased tortoises was relocated from the solar project site in late 2014, and was found dead in July 2015.  The tortoise was relocated relatively far from its home territory, which was bulldozed by First Solar.  The tortoise almost certainly was killed by a predator.  This photo was provided by the Bureau of Land Management in response to a Freedom of Information Act request.  Full documents provided by the Department of Interior can be found here.
A previous study of desert tortoise translocation from nearby Fort Irwin found that nearly half of the translocated animals have died.  Biologists are still not sure if that outcome is "good, bad, or typical," underscoring just how little we know about the impact of human activities on the species.  As previously noted on this blog, the translocation of tortoises is not the only experiment taking place because of the Silver State South project.  Biologists are also monitoring tortoise populations to see if the narrow strip of habitat remaining through the Ivanpah Valley just west of the Lucy Gray Mountains is sufficient to maintain genetic connectivity between two populations of the tortoise.  If the populations become genetically isolated, they may become less resilient and see a decline over time.

It is probably best to error on the side of caution and not push the desert tortoise and other desert wildlife past a tipping point.  Instead companies like First Solar advocate for the destruction of vast swaths of desert wildlands to make way for more utility-scale solar projects.

First Solar Not Interested in Sustainability
First Solar has sided with monopolistic utility companies in attacks on rooftop solar, funding a skewed study to portray rooftop solar as uneconomical (a study that was countered by the Institute for Local Self Reliance that points out the many benefits of distributed generation).  First Solar is apparently convinced that the price of electricity displayed on our utility bills is an accurate portrayal of the true costs of the energy we consume.  This is ironic for a company that owes its existence to a movement that has accelerated demand for renewable energy precisely because of the need to acknowledge the total costs shouldered by our planet for destructive energy sources.

Despite ample time and opportunity to find better locations for its Silver State South project, First Solar stubbornly moved forward with its destructive project in the Mojave desert.  First Solar ignored opportunities to double down on rooftop solar investments, or larger projects on already-disturbed lands.  

Construction crews for First solar bulldoze intact desert habitat for the Silver State South Solar project in the Ivanpah Valley.

Thursday, September 3, 2015

Calculating the Many Benefits of Distributed Generation

"Renewable distributed generation (“DG”) has benefits to society that cannot be measured on utility balance sheets." That is the bottom line of an extensive white paper submitted by the Sierra Club to the California Public Utilities Commission (CPUC), the regulatory body that is currently deciding whether rooftop solar will continue to expand in California or be buried by monopolistic utility companies seeking to continue a destructive status quo.

The CPUC will decide by the end of the year how much the energy generated by a rooftop solar installation is worth under net-metering, and it has solicited proposals from stakeholders regarding how to determine this value.  If you live or work in a home with solar panels on the roof, or if you have purchased shares in a community solar project because you don't own the roof over your head, the utility companies currently credit you at the retail rate of electricity for every kilowatt-hour (kWh) that your solar panels generate.  Environmental groups and the solar industry want to keep a fair credit under whatever net-metering tariff CPUC lays out at the end of the year.

But utility companies are lobbying the CPUC to reduce this credit drastically and to add outrageous fees onto the bill of any customer that installs their own solar panels.  If utility companies convince CPUC to add enough fees and reduce the credit rooftop solar installations receive for energy they generate, they could succeed in making rooftop solar less economical and thus ensure that customers remain dependent on a centralized grid that involves entangling our open spaces in transmission lines and bulldozing the desert.

Solar panels are added to a parking lot where they provide shade to vehicles and generate clean energy, rather than displacing intact desert wildlands.
Adding up the Benefits
To many of us who value clean air and intact wildlands, there would be no need to ponder whether rooftop solar should continue to expand; many desert conservation activists would argue for more aggressive policies and incentives to unleash the untapped potential in our cities to install solar panels.  But the CPUC's deliberation regarding the value of rooftop solar has been carried out on an uneven negotiating table, where powerful utility companies have dismissed the benefits of DG as "illusory."  Most of the debate regarding rooftop solar's value focuses on benefits to the grid, and being able to reduce the need for costly new transmission lines and central station power plants.  But the Sierra Club white paper also brings other benefits into focus.

The Sierra Club's submission fights back against the utility industry, arguing that CPUC should consider the many benefits of rooftop solar that utility companies and CPUC have previously dismissed or underestimated when calculating the future net-metering credit, including avoided land use, avoided carbon emissions, avoided particulate matter pollution, benefits to the local economy, and avoided water use.  The Sierra Club recommended specific values for each of these benefits to be incorporated into CPUC's overall calculation; if they are accepted it is likely that the new net-metering credit will encourage continued expansion of rooftop solar to the chagrin of rich utility companies.

Societal Cost of Carbon Emissions and Particulate Pollution
The Sierra Club white paper argues that the current CPUC proceedings likely underestimate the benefit of avoided carbon emissions and particulate matter pollution.  The white paper cites the immense impacts of climate change induced by continued carbon emissions on California society and economy, including the receding Sierra snowpack, drought, wildfires and sea level rise.  As climate change worsens, so too will these impacts.  The paper also takes a harder look at the actual costs to society of continued particulate matter and nitrous oxide emissions from fossil fuel plants in the state, and recommends a higher benefit be ascribed to rooftop solar based on the potential to displace these harmful emissions.

Avoided Land Use
The white paper also challenges an earlier CPUC decision to ignore avoided land use when calculating the benefit of rooftop solar.  The Sierra Club white paper notes that every kWh of electricity generated by rooftop solar saves at least $.002 in costs to society.  I know what you're thinking - that seems like a low-ball amount.  This value does not reflect avoided destruction of wildlands, but rather the avoided conversion of agricultural land.  Probably to challenge utility company claims that avoided land use benefits are "illusory," the Sierra Club derived this $.002/kWh benefit from studies on the value of farm or ranch land that would otherwise be used for utility-scale solar if the rooftop solar sector does not continue to expand.

As you might imagine, the desert wildlands in the Ivanpah Valley or near the Soda Mountains are priceless, and in my mind avoiding the destruction of intact habitat would justify quite a bit more than a $.002 per kilowatt hour bump in the value of rooftop solar generation.  But as we have seen before in Sacramento and decision-making halls, protecting wildlands and wildlife generally does not gain much traction in policy deliberations unless you can make some sort of economic argument.  Ultimately, the conservation of open space and wildlife is why our entire grid should be overhauled to prioritize energy efficiency and distributed generation. 

That said, the amount put on the table by the Sierra Club will at least keep the avoided land use benefit on the table as CPUC calculates a final net-metering benefit.  And in the scheme of the net-metering debate, a  $.002 per kWh benefit is not insignificant since it will further erode the utility company attempts to kill rooftop solar.  For future rooftop solar installations, every dollar counts as individuals and businesses consider whether it is worth it to go solar.  Let's take a typical 5 kilowatt residential solar system in Southern California as an example.  A system that size could generate up to 9,260 kWh per year, depending on location and weather.  The Sierra Club white paper is suggesting this system is providing society with the annual benefit of about $18.52 per year for avoided agricultural land loss (not including the many other benefits of DG), and that this value should be reflected in the final CPUC rooftop solar value determination. 

Local Economy
Advocates for rooftop solar have long pointed out that distributed generation invests directly in our communities, rather than allowing utility and energy companies to amass capital and wealth among select shareholders far away.  Rooftop solar jobs also stay in our communities, rather than the limited jobs created by remote central station power plants.

To capture this benefit, the white paper proposes a $.030 per kWh benefit be included in the calculation. That means that the 5 kW rooftop solar system I mentioned as an example would bring $277 of value each year to local society (assuming the value of that local investment is spread out over the lifetime of the system) that should be accounted for when considering whether we expand rooftop solar or submit to the utility companies' preferred centralized, destructive model of generating energy at distant power plants.