BrightSource Energy's submitted details and environmental analysis for its alternative site configuration--redesigned primarily to avoid areas on the site with high concentrations of special status plants--has been posted to the California Energy Commission (CEC) website. A previous post on this blog provided a synopsis of BrightSource Energy's press release on the matter. The details provide more illumination on the altered impact of the proposed redesign, although the massive site would still displace, and likely result in the loss of many rare plants and desert tortoise. Some of the greatest overall impacts of Ivanpah will remain, to include the displacement of many genetically significant desert tortoises, grazing land for Peninsula bighorn sheep, and ephemeral washes. Permitting so much construction in the Ivanpah Valley reduces biologically diverse Mojave Desert habitat and sets a precedent for accepting a private company's ill-informed siting decision with nominal mitigation measures that do not sufficiently addresses the overarching problems plaguing the Mojave's future. The result: squeezing "translocated" and "salvaged" survivors into increasingly smaller pockets of Mojave wilderness, and dismissing an opportunity to demonstrate that energy companies must locate sites on previously disturbed land of less biological significance.
You can see in the graphic below that the redesigned Ivanpah would reduce its footprint in the northern and middle sections where studies indicate many Rusby's desert mallow, desert pincushion, Mojave milkweed, Parish's club cholla, and nine-awned pappus grass occur. The four known occurrences of small-flowered androstephium remain within the site footprint, but BrightSource's submitted plan indicates that the plants would be "salvaged." Experts that testified at the Ivanpah evidentiary hearings in January indicated the relocation of the plant species may not be effective and could result in the loss of the plant.
The largest mitigation area measures 433 acres and the land would be open to the Mojave Desert north of the project site. Construction of a gas line to the Kern River Gas Line would run through this northern mitigation area, however. The two other mitigation areas measure 38 and 5 acres. The 5 acre parcel would be isolated within the Ivanpah site, and the 38 acre plot would also be positioned between Ivanpah 1 and Ivanpah 2. A screenshot of the northern mitigation area is copied below, although you can see the full report on the CEC website under "Applicant's Biolgical Mitigation Proposal". In short, the yellow squares represent Mojave milkweed occurences, green represents Parish's club cholla, red crosses represent desert pincushion, purple circles represent nine-awned pappus grass, etc.
BrightSource assesses that it would reduce it's required grading in the Ivanpah 3 area by 88% as a result of the mitigation area, since much of that area of the site would have required grading to remove rocks. BrightSource also assesses that many plants in the remaining project footprint that are not relocated can be "avoided" during construction and operation of the plant--perhaps an unrealistic definition of avoidance. Even though BrightSource prides itself on the reduced need for grading in its construction techniques, the site would still need to be mowed, and the construction of mirrors and towers ultimately would have a serious negative impact on any plants "avoided" in the site footprint as a result of shading, vehicle traffic, etc.
This proposal would be better than the original since the redesign would spare so many special status plants, but the inclusion of so many plants in the "avoided" category despite remaining on the site footprint is misleading. And if BrightSource is permitted to build even this redesigned site, the benefits ultimately spare some local species at the expense of a more strategic management of dwindling Mojave habitat.