FWS Comments on Silver State South Solar
FWS's asks the BLM to work with the applicant to modify the layout of the project if it is not possible to reject the project altogether, suggesting the alternatives already analyzed by BLM do not offer a sufficiently wide habitat linkage. Human development to the west, and the rough terrain of the Lucy Gray Mountains to the east leave tortoises with a relatively narrow strip of creosote bush scrub habitat as a genetic linkage connecting two different populations. Without genetic diversity, the species may become less resilient over time, thus hindering its recovery. The FWS letter also raises concerns about the project's impact on golden eagle foraging habitat -- the birds have been spotted soaring over the proposed project site -- as well as other migratory birds and bats.
In December, a joint letter from Audubon California, California Native Plant Society, Center for Biological Diversity, Defenders of Wildlife, National Parks Conservation Association, Natural Resources Defense Council, Sierra Club, and the Nature Conservancy asked BLM leadership in Washington to suspend development on public lands in Ivanpah until a regional ecological assessment and conservation plan are completed. Although the BLM evaluates a proposal for an area of critical environmental concern (ACEC) in its environmental review, the ACEC is significantly modified to accommodate the First Solar's project. According to the letter:
"The biological importance of this region should not be underestimated; natural communities in Ivanpah Valley support rare and diverse plants and animals including genetically distinct populations of the threatened desert tortoise which occur in relatively high densities. As stated above, under the current approach, the BLM is failing to adequately assess and account for the cumulative impacts from the current and proposed development. Only a properly defined landscape scale assessment and conservation plan will adequately protect the biological resources and values in the Ivanpah Valley."The joint letter also raises concerns regarding the effectiveness of mitigation measures instituted for other development projects in the desert, noting that "uncoordinated mitigation requirements for individual projects" limits their success. This is certainly evident with First Solar's proposed Stateline Solar project, which would be built on desert habitat now inhabited by tortoises that were already displaced--and thus put under stress--by BrightSource Energy's Ivanpah Solar project. The letter also seems to reference BrightSource Energy's plans to mitigate its project by purchasing desert habitat far from the Ivanpah Valley where it is unlikely to actually mitigate the local impacts of the project.
The letter does not specifically call out First Solar's projects in the Ivanpah Valley, but the suspension request would presumably apply to both Silver State South and Stateline, which are undergoing environmental review by the BLM. Although First Solar has won praise from national environmental groups for modifying other projects to reduce environmental impacts, the significance of remaining Ivanpah Valley habitat leaves little room for First Solar's Silver State South and Stateline projects, which would destroy nearly 8 square miles of intact habitat.
First Solar's proposals are not the only projects threatening this corner of the Mojave Desert. The company completed construction of its smaller Silver State North solar project, and Brightsource Energy has already mowed or bulldozed over 5 square miles for its own solar project. Wind energy and mining proposals also threaten to displace or kill wildlife, and destroy foraging habitat. The map below shows projects under construction or consideration for the Ivanpah Valley area.
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A copy of the letter submitted by the eight environmental groups is provided below.
Ivanpah Valley Letter