Pahrump and Big Pine Paiute TribesBoth the Pahrump and Big Pine Paiute Tribes voiced concern over the impacts on biological resources anticipated if the project is approved by the CEC, and noted that the water impact assessment was inadequate. Also of significance, the Tribes concurred with the preliminary staff assessment that the project would have significant and unmitigable impacts on a landscape of cultural significance to the Tribes, but the Pahrump Paiute Tribe views the CEC's attempt at mitigation as inadequate, explaining the meaning of the landscape and the area to the Tribe's traditions and beliefs:
"This land falls within the path of the Salt Song, a religious trail the deceased of the Southern Paiute (including the Pahrump Paiute) follow to the afterlife. If this path is broken, the spirits of our deceased may not make it to the appropriate place in the afterlife. In exchange for negatively impacting all of the above, the PSA proposes that appropriate compensatory mitigation would be a few panels at an Interpretive Center addressing Native American history and land use, research of an area of historical tribal land use, and restoration of the project site in the event of closure. While our tribe feels these mitigations are proposed in good faith, we do not feel their level of compensation is commensurate with the level of impact this project will have." - Pahrump Paiute TribeNational Park Service and Old Spanish Trail Association
The Hidden Hills Solar project would be within view, and on top of remnants of the Old Spanish Trail National Historic Trail and Mormon Road. Both the National Park Service and the Old Spanish Trail Association are stewards of the Trail, have provided information on the Trail's route through the project area, and expressed concerns that BrightSource Energy is downplaying the Trail's significance and remnants of the Trail that likely exist on the project site. The CEC assessment recognizes the significance of this trail, and noted:
"While not all of the traces on the project site have been ground-truthed, it is clear that the project site lies squarely among all of these tracks/traces and, therefore, within the OST-MR Northern Corridor, a regionally and nationally significant travel/trade corridor that aided the exploration and shaped the development of the southwestern United States...The visual quality of this section of the OST-MR would be permanently damaged, resulting in a substantial adverse change in the significance of a historical resource and a significant and unmitigatable impact..." - CEC preliminary staff assessment
Although the CEC staff assessment assesses the Hidden Hills project would have significant impacts on biological resources, many intervenors felt that the report fell short of fully analyzing these impacts and establishing appropriate requirements for BrightSource Energy to reduce or "mitigate" those impacts. The Center of Biological Diversity lodged some of the strongest concerns that the CEC assessment was incomplete:
"For biological resources and other topics, the PSA is incomplete, making it impossible to assess much less comment on the all of the proposed project impacts. However, based on the information provided in the incomplete PSA, significant impacts have been identified for a suite of species (PSA pg 4.2-63-67) including groundwater dependent vegetation, special status plant species, migratory/special status resident avian species and potentially golden eagle and negative impacts to numerous other rare plants and animals, including the beleaguered desert kit fox and the declining state threatened desert tortoise." - Center for Biological Diversity submission to CECThe Center for Biological Diversity (CBD) also noted that the CEC assessment fails to comply with California environmental law by failing to fully evaluate sufficient alternatives to the proposed project, rightly noting that only one alternative analyzed in the assessment was at a different location. Other alternatives only explored different solar technologies, which would still have substantial impacts on biological resources. CBD advocates for the consideration of an alternative location on already-disturbed lands closer to the population centers where the electricity is needed.
Regarding wildlife impacts, CBD keyed in on the lack of complete assessment on the proposed projects impacts on golden eagles and bighorn sheep--which are known to forage in the area--as well as rare desert plants and vegetation dependent on groundwater resources. Significantly, CBD points out that the CEC assessment is missing a translocation plan for the desert tortoises known to inhabit the proposed project site, including an estimated 6 to 33 adult and sub-adult tortoises, and 3 to 34 juveniles. CBD proposes two years of studies of the translocation site and the host population before tortoises are moved from the proposed project site to the translocation area, although expresses concern that tortoise translocation may not be an effective "mitigation" measure based on studies and findings by the Scientific Advisory Committee fo the US Fish and Wildlife Service.
|A view of the lower Pahrump Valley, where the Hidden Hills Solar project would be built, with the Spring Mountains in the distance. BrightSource would install thousands of heliostats -- mirrors as large as garage doors -- and 750 foot tall "power towers", significantly taller than the design in the Ivanpah Valley.|
Nature Conservancy and Amargosa ConservancyAll of the commenters echoed and expanded upon concerns expressed earlier by BLM about the project's immense water demand, which is expected to put severe strain on an already overdrawn groundwater basin. But the Nature Conservancy and Amargosa Conservancy are both stewards of the nearbyAmargosa River -- an important ecosystems that the river supports. The Nature Conservancy noted in its comments that an independent analysis calls into question the validity of a study paid for by BrightSource energy.
Recognizing that there is insufficient data to accurately understand the Hidden Hills Solar project impacts on the Amargosa River's ecological stability, the Nature Conservancy and Amargosa Conservancy are working on long-term studies to understand the "plumbing" system of this area of the desert, but the studies are under-funded and results are approximately five years away. Both parties recommend more studies to understand and anticipate the solar project's impacts on the Amargosa River, which is designated as a Wild and Scenic River. Both organizations point out that the Hidden Hills Solar project's demand for water is unlike most agricultural demands because it is continuous and fixed over a long period of time (at least 30 years, if not more), straining the groundwater supply.
Inyo CountyThe California county where the project would be built has repeatedly urged the CEC to require BrightSource Energy to compensate it for the costs of extending services to such a remote area, and raised concern that BrightSource Energy dismisses the potential impacts of the project on visual resources and County infrastructure. Although BrightSource Energy is touting possible tax revenues for Inyo County as more than enough to make up for the County's costs, Inyo calls this math into question. The County notes that BrightSource Energy is just now starting to negotiate its tax agreement with San Bernardino County for the Ivanpah Solar project. Inyo County is asking that the conditions of certification require the company to obtain a letter of credit for 84.5 million dollars--an amount roughly equal to promised tax revenues--to ensure adequate funds are available to compensate the County for its expenditures.