Here is the response from Solar Millenium, which suggests it did not even look for sites involving more than three landowners, and supports its decision citing "CEC guidance":
"The ease and certainty of establishing site control is a critical component of determining whether to proceed with a large-scale solar thermal project. Although different applicants may have different views regarding how many landowners is “too many” for site control purposes, the Applicant determined, based on CEC guidance, that the appropriate maximum number of landowners is three."
Two alternative sites highlighted by Solar Millenium deserve extra consideration by the company and the CEC--Boron and California City--since they could potentially reduce the impact on the Mojave Desert. According to data submitted by Solar Millenium, the alternative sites at Boron and California City would have required up to 20 miles of new transmission lines to tie into the power grid, but the sites are located near major roads and extra transmission lines could parallel what is already disturbed land. While the Boron site technically falls within Desert Tortoise critical habitat, it is on the edge of such designated territory and would be immediately adjacent to the US Borax mine. This would suggest that the Boron alternative site may not have as dense a desert tortoise population as exists on the current proposed site near Ridgecrest. The Ridgecrest location hosts at least 50 desert tortoise, in addition to several other sensitive species. The California City site is also located near disturbed land and just north of Highway 58.
The CEC should not be dissuading solar companies from aggregating more disturbed land--no matter how many owners--since doing so could result in pushing development to less valuable habitat. The California City and Boron sites would both involve three landowners, barely meeting CEC's apparent guidance to Solar Millenium, suggesting the company probably did not even look for additional land next to these sites to give them sufficient acreage for development since doing so would involve surpassing the three landowner limit. While fewer landowners probably simplifies the certification process, and certainly Solar Millenium's own development, this guidelines reduces the likelihood that solar companies will develop on disturbed land since this would complicate efforts to aggregate enough acres to make it economical for development. This leaves the large BLM-managed parcels as a juicy target for industrial scale solar development.
The Ridgecrest Solar Project helps to illuminate how the CEC's process and guidelines may contribute to poor solar siting decisions. This compounds ineffective policy from Washington, which imposed an arbitrary deadline demanding that solar companies break ground before the end of 2010 in order to qualify for federal aid. Perhaps CEC guidelines that encouraged the aggregation of disturbed land, and the extension of the federal funding deadlines could result in thousands of acres of prime Mojave Desert habitat from being mowed down. As the process currently stands, there does not appear to be any significant meaning or intent in the CEC's request for alternative site consideration, and it seems to convey a superficial sense of cost-benefit analysis to justify what is may end up being poor management of public lands.
Below is a screen shot of the Boron alternative location (outlined in red) adjacent to the US Borax mine.