California Does Not Need More Fossil Fuels

The California Public Utilities Commission is considerng whether to offset the loss of the failed San Onofre nuclear power plant with new natural gas power plants.  San Onofre's twin reactors generated over 2,250 megawatts of electricity.  We will need to take affirmative steps to offset the loss of that generating capacity, but we should find the most sustainable way to fill this gap without creating more environmental problems. 

As the Sierra Club notes, replacing San Onofre with natural gas plants is unnecessary because energy forecasts for California indicate that roughly half of San Onofre's generating capacity will be offset with energy efficiency gains; we can fill the rest of the gap with improvements in transmission or added rooftop solar capacity in the Los Angeles basin.  Consider that solar panels on California rooftops already generate over 1,880 megawatts of  clean energy.  Instead of wasting ratepayer money on new fossil fuel plants that will pollute our communities, encourage drilling on public lands, and contribute to climate change, we should invest in local clean energy. 

Follow this link to a Sierra Club site that helps you send a message to the California Public Utilities Commission, and personalize your message demand more investment in energy efficiency and rooftop solar.

Waking up to the Solar Power Tower Threat

As BrightSource Energy began to bulldoze approximately 5.6 square miles of pristine desert to build its Ivanpah Solar power project, we quickly learned the impact on terrestrial species - rare wildflowers, long-lived yucca plants, and desert tortoises were displaced or killed.   Now that the Ivanpah Solar project is powering on, thousands of mirrors focusing the sun's rays at three towers have burned or battered dozens of birds in the first couple of months of becoming operational.  Chris Clarke with KCET's ReWire has been reporting on the troubling new trend - dead birds being found after colliding with mirrors or burning to death in super-heated air over the project.  We need to replace fossil fuels with renewable energy, but we need to do so in a way that minimizes (not expands) the human threat to ecosystems and wildlife.  The vast majority of BrightSource Energy's negative impacts on wildlife could have been avoided if we invested more in solar panels on rooftops, or properly sited photovoltaic projects on already-disturbed lands.

This photo of BrightSource Energy's Ivanpah Solar project was taken from miles away in the Mojave National Preserve.  The bright glow on the ground is from thousands of mirrors aimed at the three towers - the mirrors may appear as a lake or other body of water to birds from far away, attracting them to their deaths.

You can read about the analysis at ReWire.  I am copying below the avian mortality lists from the California Energy Commission monthly compliance reports from October and September.  I am also embedding recordings of the songs and calls of some of the species affected by BrightSource Energy's Ivanpah Solar project.   The birds burned or battered by the project range from MacGillivray's Warbler to a Peregrine Falcon.  The vast majority of these losses could have been avoided if we invested more in solar panels on rooftops, or properly sited photovoltaic projects on already-disturbed lands.



Songs and calls from some of the birds killed at BrightSource Energy's Ivanpah Solar project:

MacGillivray's Warbler, found dead with melted/scorched feathers:


Blue-Gray Gnatcatcher, found dead with melted/scorched feathers:

Peregrine Falcon, found injured with scorched feathers:


Wilson's Warbler, found dead with melted/scorched feathers:


Mourning dove, found dead after collision with large solar mirror:


Yellow-rumped Warbler, found dead with melted/scorched feathers:


Verdin, found dead with melted/scorched feathers:


House finch, found dead with melted/scorched feathers:

Conservation Groups Warn Against Approval of Ivanpah Projects

Defenders of Wildlife this month warned the Department of Interior that its pending approval of two large-scale solar projects in the Ivanpah Valley would destroy irreplaceable desert habitat and degrade an important wildlife linkage, despite smarter alternatives.  In a separate letter, the Nature Conservancy noted that Interior's approval of the projects would ignore science-based guidance on how to manage public lands and minimize impacts of energy projects.

The two solar projects - First Solar's Silver State South and Sateline projects - would be built on the California-Nevada border on a narrow corridor of habitat that connects different populations of the beleaguered desert tortoise.  A loss or degradation of this habitat linkage would make it more difficult for the desert tortoise to recover from the downward spiral it has experienced over the last half century, and erode its resilience as it faces a host of human threats, including climate change.  Conservationists argue that the projects' solar panels could be placed on already-disturbed lands or rooftops; there is no reason these two projects must be built in a place so important the health of the Mojave Desert ecosystem, and the survival of the tortoise.  In fact, the persistent threat we will face from climate change - even if we shut off all carbon emissions overnight - requires that we take a more thoughtful and sustainable approach to the deployment of clean energy.

A map included in the Final Environmental Impact Statement for the Silver State South project shows how the width of the desert tortoise linkage (in green) will be impacted if the Silver State South project (blue outline) is built.  The primary connectivity corridor would be reduced significantly, leaving a 1.39 mile corridor at the narrowest point. The corridor has already been impacted by the Silver State North project, and a natural gas plant (in orange).

Defenders Postures for Legal Action

Interior in September signalled its intent to approve both the Silver State South and Stateline Solar projects when it published a biological opinion for both projects that suggested that the projects' impacts on the habitat linkage could be "mitigated."    Defenders responded to the biological opinion with a notice of intent to challenge Interior's review of the projects under the Endangered Species Act (ESA).  Interior's pending approval of the projects ignores biologists' research - and Interior's own policy - that designates the Ivanpah Valley as an important wildlife corridor that should be off-limits to future industrial development.  The Solar Energy Development Program established the Ivanpah Valley as an "exclusion zone" that would prohibit large-scale habitat destruction for solar projects;  the two First Solar projects were excepted from this policy, however, because they were in the permitting phase before the policy was finalized.

The Fish and Wildlife Service (FWS) late last year recommended that the Bureau of Land Management deny approval of the project because of the potential loss of an important linkage.  Probably in part because of political pressure, FWS changed its tune in the biological opinion released in September 2013, although only half-heartedly.  As I noted in my last blog post on the biological opinion, FWS is ultimately unsure as to whether or not the Silver State South solar project will diminish the viability of the desert tortoise habitat linkage.  FWS acknowledges in the biological opinion that the consequences of a lost habitat linkage could be severe:  two isolated populations of desert tortoise across over 500 square miles that will be too small to maintain population growth over time.

In its notice of intent to take legal action, Defenders states:

"Indeed, the FWS’s determination to roll the dice with the Tortoise’s fate and hope for the best also contravenes the most fundamental premises underlying section 7(a)(2) of the ESA. In adopting that provision, “Congress has spoken in the plainest of words, making it abundantly clear that the balance has been struck in favor of affording endangered species the highest of priorities, thereby adopting a policy which it described as ‘institutionalized caution.’”... Plainly, the high-risk approach adopted by the Service here is the very antithesis of the “institutionalized caution mandate” embodied in section 7."

Defenders' response to Interior also takes issue with the biological opinion's changing tune on the effectiveness of translocating desert tortoises from sites being destroyed for projects to intact habitat.  In the biological opinion, Interior states that "post-translocation survival rates will not significantly differ from that of animals that have not been translocated." Research indicates - and Interior has previously acknowledged - that tortoises relocated from their homes are much more likely to die within a few years.  Ten tortoises translocated this year from the Moapa Solar project site under construction in Nevada died within months of being moved.  Defenders points out that FWS itself stated in 2012 that it “does not support translocation as a proven minimization measure for development projects."

Nature Conservancy Expresses Concern

The Nature Conservancy's (TNC) letter to Interior in response to the final environmental review of the Silver State South project and biological opinion for both the Silver State South and Stateline projects raises serious concerns regarding Interior's adherence to its own policies.  TNC points out that the project does not conform to Interior's own approach to landscape-level conservation and planning, or its policies on mitigating the impacts of approved projects.

Regarding landscape-level planning, TNC notes that: 

"BLM’s preferred alternative to site another large solar facility in the Ivanpah Valley in Nevada does not conform to the interests of the recovery of desert tortoise; converts irreplaceable, high quality habitat; and restricts an important tortoise corridor. Further, relative to the magnitude of the habitat values that will be lost, the mitigation measures are not sufficient in scope or magnitude, nor are they sufficiently durable."

The TNC letter cites Secretary of Interior Sally Jewell's order number 3330 as identifying proper land management and durable mitigation measures as necessary to achieve a balance in managing public lands, especially to enhance the resilience of our wildlife in the face of climate change.  It is ironic that a solar project intended to ease the burden of climate change could have the opposite effect.  I am sure some will argue that these two projects should be approved so that the tortoise can face a better chance of survival from climate change, but we have to remember that the deleterious impacts of the greenhouse gas emissions already in the atmosphere will persist for decades, regardless of whether or not these particular projects are built.  According to Nature, "even if carbon-dioxide emissions were to cease overnight, the half a trillion tonnes of carbon that have been pumped into the atmosphere since major industrialization began in around 1850 will affect Earth’s biosphere, glaciers and oceans for centuries to come," in its coverage of the International Panel on Climate Change's report.

With this persistent threat in mind, it is imperative that our deployment of clean energy happen quickly, but with great care for the ecosystems and natural resources we would like to protect.  Tactical patience - taking the time to identify the best places for clean energy projects, and protecting the places that are important to the survival of wildlife - will pay dividends in the long run, whereas sloppy planning and deployment will leave us with more messes to clean up in the decades to come. Interior's plan to approve two First Solar projects in the Ivanpah Valley does not exhibit this level of care or concern for the sustainability of the Mojave Desert, and jeopardizes the recovery of the desert tortoise.

Below is a copy of Defenders of Wildlife's Notice of Intent to take legal action against Interior for violating the Endangered Species Act:

Mount Charleston Blue Butterfly

Mount Charleston blue butterfly finally received Federal protection. Photo by Corey Kallstrom, USFWS

The U.S. Fish and Wildlife Service listed the Mount Charleston blue butterfly as endangered in September, which should result in more resources to protect this species from vanishing.  The Mt. Charleston blue butterfly is only known to occur in the higher reaches of the Spring Mountains in Nevada, west and northwest of Las Vegas. 

The butterfly's population is likely declining, although information gaps preclude us from quantifying its population trends.  The species is believed to be extirpated from six of 16 locations that it has been known to inhabit, and it is only "presumed" to occupy eight of the 10 other locations.  In other words, it may exist in 10 relatively confined locations throughout the mountains, but for eight of those locations it probably has only a tentative existence, at best.

The butterfly faces a threat from climate change - more extreme precipitation and drought patterns are expected in the southwest - and collecting by poachers.  Because of threat from poaching, critical habitat will not be identified since that would involve publishing more precise locations that could make the species more vulnerable to illegal collection.  Because of the threat posed by collectors, the U.S. Fish and Wildlife Service determined that four other butterflies found in the same area and similar in appearance to the Mt. Charleston blue also warrant protection.

The Spring Mountains seen in the distance from the Pahrump Valley.

Interior Rolling the Dice on Future of the Desert Tortoise

The U.S. Fish and Wildlife Service's (FWS) biological opinion provides a seemingly conflicted and reluctant expression of support for the Silver State South solar project on the basis of mitigation measures that it admits may not offset the damage done by the project to the viability of a key habitat linkage for the desert tortoise.  The biological opinion is FWS' contribution to the Bureau of Land Management's (BLM) environmental review of the Silver State South project, and evaluates how the project will impact the desert tortoise.   Perhaps to speed approval of the project, the opinion glosses over a significant potential consequence of the project - local extirpation of the desert tortoise population in the Ivanpah Valley.

The Silver State South solar project would be built at the pinch point of the hour-glass shaped Ivanpah Valley, and potentially isolate two populations of the desert tortoise; both the BLM and FWS acknowledge that "current research does not indicate whether reductions in the width or configuration of the corridor compared to existing conditions would reduce or eliminate its ability to maintain the genetic linkage between populations north and south of the Project area." In other words, the Department of Interior plans to approve the Silver State South Solar project even though it does not know if the Silver State South project will essentially sever the habitat linkage.

Extirpation

If the Silver State South project does reduce the viability of the habitat linkage, extirpation of the desert tortoise from the Ivanpah Valley seems to be a possible outcome, although the FWS' biological opinion is written in such a way to avoid direct mention of this outcome.  According to the biological opinion, "[l]oss of population connectivity between the northern and southern portions of Ivanpah Valley would create a nearly closed population of desert tortoises within a 258-square-mile area in its southern portion...and a nearly closed population within the 255-square-mile area of the northern portion of the valley."

The consequences of cutting the habitat linkage are summed up in the biological opinion as "demographic stochasticity and genetic deterioration likely [to] diminish the potential for population growth."  In other words, the project could divide one larger population into two smaller isolated populations that would be too small to maintain population growth in the face of natural and man-made changes (including climate change, wildfire, and natural fluctuations in birth rate, sex ratios, and age distribution), and could cease to exist over time.  As the FWS notes in the revised recovery plan for the desert tortoise that it issued in 2011, such habitat fragmentation places isolated populations "at higher risk of localized extirpation from stochastic events or from inbreeding depression (Boarman et al. 1997; Boarman and Sazaki 2006)."  The Ivanpah population covers a significant portion of the eastern Mojave Desert, and its decline could have ripple effects on the ecosystem.

The biological opinion notes that the northern and southern Ivanpah populations already fall slightly below the recommended density of tortoises necessary to maintain a stable or growing population, suggesting the project's impediment on the habitat linkage could push the populations over the edge.

Ineffective Mitigation

The FWS biological opinion evaluates several mitigation measures that will be funded by First Solar, but the document casts doubt on whether any of them can actually offset the damage that will be done by the solar project to the habitat linkage.  The mitigation measures mostly attempt to reduce tortoise mortality elsewhere in the Ivanpah Valley.  For example, First Solar will pay for tortoise fencing along the Morningstar Mine Road several miles away from the project, and closure of illegal off-highway vehicle (OHV) routes elsewhere in the eastern Mojave recovery unit.  The routes to be closed are unlikely to be the routes in the habitat linkage since the BLM states in the Final EIS that it does not plan to close any routes on the Nevada side of the Ivanpah Valley.

The Final EIS and biological opinion also notes that First Solar's mitigation funds will enable increased law enforcement patrols in the area to "reduce damage to habitat and injury and death of desert tortoises." However, the BLM will continue to manage the Special Recreation Management Area (SRMA) that overlaps the habitat linkage for "intensive recreation," including competitive OHV events that draw thousands of participants.  Given that so many OHV routes will remain open in the SRMA, it's not clear what illegal habitat destruction law enforcement will be able to detect or stop.  OHV events in the habitat linkage will continue to result in desert tortoise mortality, but the impacts will be compounded by the loss of habitat to the Silver State South solar project.

The only serious effort to offset the damage to the habitat linkage may not even be feasible.  FWS states that it may be possible to remove fencing around the Large-Scale Translocation Site - a portion of the desert on the opposite side of Interstate 15 that hosts tortoises translocated from other parts of Clark County, Nevada - to open up a marginal connectivity corridor on the other side of the valley.  Because of the potential that the tortoises there suffer from diseases at a higher rate than the natural population in the Ivanpah Valley, it may not be prudent to remove the fencing.  Even if the fencing is removed, however, FWS notes:

"If the Bureau is able to remove or realign the fence around the Large-Scale Translocation Site, the improved connectivity on the west side of Interstate 15 would not completely compensate for decreased connectivity to the east of the Silver State South Project, primarily because Primm and the Stateline Hills comprise impermeable and semi-permeable barriers, respectively, to movement of desert tortoises through this area."

Kicking the Can Down the Road

So this is where we stand:

• FWS and BLM are not sure if the Silver State South solar project will diminish the viability of the desert tortoise habitat linkage.

• If the Silver State South project severs the habitat linkage or renders it ineffective, the result will be two isolated populations of desert tortoise across over 500 square miles that will be too small to maintain population growth over time.  They could disappear altogether in the face of other threats, and without a linkage that enhances the species' resilience.

• The mitigation measures required by the Final EIS may help reduce overall direct mortality in the region, but it is not clear if this will make a difference after First Solar destroys tortoise habitat in the narrow corridor between Primm and the Lucy Gray mountains.

What is even worse is that we may not know exactly how the project impacts the viability of the habitat linkage for quite some time, given the slow reproductive rate of the desert tortoise.  According to the biological opinion:

"Although the loss of habitat would occur in a relatively short time and be clearly visible, loss or degradation of connectivity would likely not occur for several years and be more difficult to detect."

So what is the Department of Interior's response?  The U.S. Geological Survey will conduct a long-term monitoring effort in an attempt to detect degradation of the habitat linkage's effectiveness.  If the monitoring detects a change, the BLM would have to re-initiate formal consultations under the Endangered Species Act and implement efforts to remediate the damage to the habitat linkage.  However, neither the biological opinion nor the Final EIS identify specific remediation efforts or what positive effect they could have on the viability of the habitat linkage.  Would they decommission the Silver State South solar project early and attempt to restore the habitat?  Would they sponsor speed-dating events for tortoises in the area? Would they blast through the Lucy Gray Mountains to widen the habitat corridor? If these ideas sound ridiculous it's because there is not much you can do to improve connectivity once you have bulldozed 3.7 square miles of tortoise habitat at the narrowest point of a habitat linkage.

The Silver State South Solar project could effectively isolate and decimate two large populations of the desert tortoise, but the BLM plans to approve it anyways with the hope that they can implement unspecified remediation efforts years after the habitat is already destroyed.  Without identifying what those measures are, there is no reason to believe that the damage can be undone.

Rose-Colored Glasses

Even after all of that uncertainty and doubt, the biological opinion concludes "that the proposed actions are not likely to appreciably diminish reproduction, numbers, or distribution of the desert tortoise in the action area, or to appreciably impede long-term recovery of the desert tortoise." FWS is betting on an unknown ability to correct this mistake even after the project is built. 

All of this begs the question: why must First Solar construct this large project at the narrowest part of the Ivanpah Valley habitat linkage?  This destruction is simply not necessary.  First Solar could install these solar panels on already-disturbed lands elsewhere in the southwest without jeopardizing the future of an entire population of the desert tortoise.  In our necessary efforts to cut fossil fuel emissions, there is no need to accept far-reaching and unnecessary compromises of our conservation ethic.

Below is a full copy of the biological opinion for the Silver State South and Stateline solar projects:

Solar Decathlon Where It Belongs

The Solar Decathlon is being held in California at long last.  The competition was first held in 2002, and features homes powered by rooftop solar panels, and built by teams from across the country and overseas competing to be the most sustainable in various categories.  The overall winning team must design and build a home that meets the following general criteria:

• Is affordable, attractive, and easy to live in

• Maintains comfortable and healthy indoor environmental conditions

• Supplies energy to household appliances for cooking, cleaning, and entertainment

• Provides adequate hot water

• Produces as much or more energy than it consumes.

Consider the "DesertSol" entry designed and built by the University of Nevada, Las Vegas (UNLV).  The DeserSol house uses a solar thermal system to heat water and the home itself, photovoltaic panels to supply energy, and advanced engineering that reduces framing materials by nearly 20%.  The entry will be on display at the Las Vegas Springs Preserve after the competition.

UNLV's DesertSol home design at the 2013 Solar Decathlon.  Solar power and water heating, low water consumption, and efficient use of materials have made this one of the event's most competitive designs. Photo from DOE Flickr page, creative common license.

Held every other year by the Department of Energy, the decathlon has always been hosted in Washington, D.C., but this year it is hosted in Irvine, California.  It seems more appropriate for the event to be held out west, or at least outside of Washington D.C.   Other than the Department of Energy folks that support this event, Washington does not seem to properly value the mostly untapped potential of energy efficiency and distributed generation that these designs embody - policy on these important fronts are mostly stalled.  Consider that a bill supporting energy efficiency (S. 1392) with bi-partisan support has yet to be passed by Congress.  Or that in 2011 the Department of Interior did not want the competition to take place on the National Mall because of the impacts of so many visitors on the grass there.  The irony was lost on Interior that it felt the need to protect a typical lawn from an event that raises awareness about sustainability, even thought Interior provides fast-track approval for the destruction of public lands for big energy projects.

So I am glad for the folks out west that can attend this event, and learn about innovations in sustainable design, energy efficiency, and distributed solar generation.  We should do more to tap these elements to change the energy paradigm, and challenge the assumption that more homes equal more big power plants and transmission lines.

Silver State South Solar Nears Approval; Problems Loom

Tbe Bureau of Land Management (BLM) in September released the final environmental impact statement (EIS) for the Silver State South solar project, which would destroy approximately 3.7 square miles of intact desert habitat. Although the direct impact on wildlife may not compare to BrightSource Energy’s Ivanpah Solar project, the Silver State South project almost certainly will have significant long-term effects on the ability of the desert tortoise to maintain habitat connectivity.



The BLM’s preferred alternative supports the solar project, and secondarily designates an Area of Critical Environmental Concern (ACEC) to protect the desert tortoise habitat that First Solar does not want to destroy.  The ACEC is a welcomed sweetener, but still does not override the bitterness that arises from the fact that destruction of habitat for the solar project is completely unnecessary since the solar panels would be just as happy on already-disturbed lands somewhere else in the state.  Tortoises, on the other hand, are unlikely to survive after they are evicted from their burrows.   There is no need for First Solar to push this species to the brink when alternative locations are available.

A stand of yucca on the site of First Solar's proposed Silver State South project site, just east of Primm, Nevada.

To add insult to injury, Southern California Edison - the utility company that is purchasing energy from the Silver State South project – is asking California regulators for permission to make corrections to its contract for the energy that will add over $60 million in costs to ratepayers. The additional costs result in part from a brand new substation; SCE previously told the California Public Utilities Commission (CPUC) a new substation was not necessary.   It took SCE nearly two years to notify CPUC about the corrections; the delay probably benefited SCE and First Solar because the incorrect information initially submitted to regulators made the cost of the project seem more competitive and reasonable.  CPUC will consider SCE’s request at the end of October.

Narrowing the Corridor

The project is poorly sited because it will impede a habitat connectivity corridor for the imperiled desert tortoise, potentially restricting gene flow for the species and challenging its resilience in the face of climate change, and ability to recover from a stark population decline over the past half century.  The U.S. Fish and Wildlife Service in December requested that the BLM not approve the project, or at a minimum reduce the project’s footprint. The BLM and First Solar reduced the footprint from the project analyzed in last year’s draft EIS, but only because First Solar initially proposed a 350 megawatt (MW) project.   First Solar only had commitments to sell 250 MW, so the footprint reduction is not a compromise by First Solar, but a right sizing of its inflated plans.

A map included in the Final EIS shows how the width of the desert tortoise corridor (in green) will be impacted if the Silver State South project (blue outline) is built.  The primary connectivity corridor would be reduced significantly, leaving a 1.39 mile corridor at the narrowest point.

First Solar’s project will narrow the habitat corridor down to 1.39 miles across at the narrowest point, reducing the width of the habitat corridor by a mile. The EIS estimates that as many as 115 tortoises will be displaced or killed by the project.  Over the long term, the species will have more difficulty maintaining genetic connectivity through the Ivanpah Valley, which leads to a narrow and also unprotected connectivity corridor across the McCullough Range to the El Dorado Valley.  Other connectivity has already been eliminated by Las Vegas’ urban sprawl.

The map above depicts the home ranges of tortoises known to inhabit the area.  Orange and yellow polygons are the ranges of tortoises that will be displaced or severely impacted by construction of the project.  Other tortoises may be impacted that were not detected during surveys.

Competing Uses

The tortoise connectivity corridor is already under threat from other competing uses of the public lands – Las Vegas plans to build another airport on the dry lake bed near Primm known as the Southern Nevada Supplemental Airport.  Although the dry lake bed itself does not provide suitable habitat for the tortoise, the airport may need to build roads and other associated facilities on desert lands that do serve as suitable habitat.  The airport's development and construction has been delayed by the economic downturn and construction of a new terminal at McCarran airport, but the city almost certainly will return to these plans when McCarran begins to reach capacity limits.

Furthermore, the area hosts many off-highway vehicle (OHV) events on designated routes through the desert and around the Lucy Gray Mountains east of Primm.  The Final EIS notes that as many as 22,000 people attend some of the events.  The EIS, however, fails to clearly articulate how the integrity of the tortoise corridor will be preserved while also allowing for the solar project, airport, and OHV events.

The map above depicts off-highway vehicle routes in the vicinity of the Silver State South solar project.  The blue and purple line represents a route used by high speed and competitive events that draw thousands of spectators.  Although the solar project is not depicted in this map, it will interrupt that route, and no alternative route has been proposed. Establishment of the ACEC will complicate identification of alternative routes.

Some of the OHV routes will be blocked by the Silver State South project, according to the EIS, although it is not clear if alternative routes will be permitted after designation of an ACEC.   New routes could result in further destruction of desert tortoise habitat; if BLM plans to permit alternative routes they should have been analyzed in the Final EIS as a connected action.

Area of Critical Environmental Concern (ACEC)

BLM responded to requests from the public and agencies to extend the ACEC to cover areas of the desert not used by the solar project, although the FEIS does not analyze a conservation alternative – where the project is denied but BLM evaluates conservation actions such as a more robust ACEC designation.

Nonetheless, if the BLM selects its preferred alternative, over 31,000 acres of desert habitat will be protected under the ACEC.   Basin and Range Watch originally proposed the ACEC in 2012 as an alternative to the solar project because of the overarching importance of this desert habitat.

Considering just how important this swath of desert is to the long term viability of an entire species, you would think the ACEC outline would cover as much of the suitable habitat as possible.  The ACEC outlined in the first map at the top of this blog post shows a lot of habitat remains unprotected by the designation.  The BLM may consider adding lands to the ACEC designation during its review of the Las Vegas Resource Management Plan.

Increasing Transmission Costs

SCE in Ma filed an amendment with CPUC correcting the original power purchase agreement (PPA) that was filed in 2011, and informing CPUC that the amendment will result in incremental costs of over $60 million.  The transmission upgrades required to accommodate the project on the grid include a new substation (two other substations exist nearby, but apparently Silver State South needs its own), and upgrades at other major substations in the El Dorado Valley, Hesperia, and Kramer Junction.

When SCE first filed the PPA in 2011 they stated the project would connect to the grid at the Ivanpah Substation, which was already approved and paid for to accommodate the Ivanpah Solar project.  It is not clear how SCE mixed up its substations, but they apparently knew the correct substation when they filed a separate regulatory application with the Federal Energy Regulatory Commission (FERC) in October 2011.  However, SCE never bothered to correct its PPA filing with CPUC until after they approved the contract.  Although the retail rate of the electricity from the project is not affected, ratepayers will pay for the upgrades through the “transmission access charge,” and the error suggests the PPA may not have been properly compared to other projects when SCE was initially selecting projects for contracts.

You can find the Final EIS on the BLM website for the Silver State South Solar project, although these documents are not readily available during the government shutdown imposed by Congress.

The following document was included in the draft EIS published in 2012, and lists all species that are likely to be impacted by the Silver State South solar project.

First Solar Supports Utility Company War on Rooftop Solar

First Solar, the company destroying several square miles of desert habitat to build solar facilities on pristine desert wildlands,  sided with utilities companies seeking to limit the expansion of rooftop solar in a regulatory filing this month.  First Solar's move is not surprising because the panels it manufactures and uses at its large solar facilities are not very efficient, and typically are not used in rooftop solar installations.  The company depends on monopolistic utility companies to buy energy from its projects, funds anti-environment politicians, and has insisted on building a large project that biologists have warned will degrade habitat connectivity for the threatened desert tortoise.

First Solar's Silver State North solar project in the foreground, and BrightSource Energy's Ivanpah Solar project in the background.  These large projects have destroyed several square miles of intact desert habitat, and required millions of dollars in transmission line upgrades. Both projects received tax incentives from

 But First Solar's move is bold - the company complains that rooftop solar installations place an unfair burden on other ratepayers, ignoring the fact that First Solar executives' pay checks are subsidized by taxpayers; the company's large projects are supported by Federal loan guarantees backed by the taxpayer.   First Solar CEO James Hughes received nearly 11.8 million dollars in salary and stock awards in one year, reaping a substantial profit from the utility companies that he defended in an editorial against rooftop solar.   Nearly every First Solar project requires expensive upgrades to the transmission system that also add to ratepayers' costs.   The company has built its projects on wildlands treasured by the public - including a project near Joshua Tree National Park - a cost that is difficult to quantify.

First Solar's argument against rooftop solar is misleading.  The Arizona Public Service utility company currently credits rooftop customers for energy they feed into the grid at a rate comparable to some utility-scale solar projects. The net metering credit for rooftop solar generators in Arizona is 15.5 cents per kilowatt hour, according to an Arizona newspaper, which is comparable or cheaper than the 15 to 18 cents per kilowatt hour that a California utility is paying for electricity from NRG's large California Valley Solar Ranch, according to the New York Times.  Unfortunately we do not know how much money First Solar receives for each  kilowatt hour of energy its projects produce because the rates are considered confidential business secrets.  What First Solar ignores in its attack on rooftop solar is the fact that rooftop solar add electricity to the grid without destroying open wildlands and alleviate the need for expensive new transmission lines.  When these benefits are factored in, rooftop solar is more economical than large-scale projects, according to a study supported by Vote Solar.

The First Solar filing with the Arizona Corporation Commission also unfairly compares rooftop solar and large-scale solar on a cost per watt basis.  The net metering credit to rooftop solar generators is calculated on a kilowatt-hour basis, not a cost per watt basis; the rooftop solar panel owners only receive a credit for the energy they send to the grid and share with other ratepayers.  Cost per watt, on the other hand, is the amount it costs to install the system - this is not as relevant to the net metering debate.  But even so, the costs to install rooftop solar systems will fall as local permitting costs also fall.  In Germany, which generates thousands of megawatts of clean energy with rooftop solar panels, the cost of a rooftop solar installation is $2.24 per watt - nearly as low as the cost per watt of utility-scale projects cited in First Solar's regulatory filing.

Distributed solar generation systems, like this one at Victor Valley College in California, benefit the customer because they send clean electricity into the grid without requiring ratepayers to pay for large and destructive power plants and transmission lines.

The First Solar filing also argues that utility-scale projects are more efficient because they provide energy that is easier to forecast for utility companies.  The company ignores the fact that rooftop solar makes the grid more resilient by distributing the energy generation across a broad geographic area, decreasing the impact of weather and other environmental factors on overall generation.  First Solar's projects, on the other hand, concentrate panels on a specific swath of land and can experience a significant drop in power production when a cloud hangs overhead.

If First Solar were genuinely concerned about the environment and costs to the community, its actions would match its words.  Instead, First Solar attacks a program that fairly credits rooftop solar generators, builds projects that destroy wildlife habitat, and makes the 1% even richer.