Tuesday, October 28, 2014

DRECP Spotlight: Cuddeback

When I was a kid growing up in Victorville watching jets taking off from now-closed George Air Force Base, I didn't know that some of them were probably bombing a 12 square mile patch of desert in California known as the Cuddeback Air Force Bomb and Gunnery Range.  The U.S. Air Force gave up the Cuddeback range in August 2012, but the Bureau of Land Management (BLM) is still figuring out whether it is "suitable for public use."  The Desert Renewable Energy Conservation Plan (DRECP) does not designate the Cuddeback range as either a development focus area or a conservation area, even thought it is immediately adjacent to two wilderness areas, and probably serves as important habitat for the desert tortoise and Mojave ground squirrel.

The Google map above shows the approximate boundaries of the former Cuddeback Air Force Range.  The DRECP does not recognize the range as BLM land, even though Department of Interior testimony acknowledged that the U.S. Air Force relinquished the land to the BLM in 2012.

It may not be possible to allow the public to roam the area until unexploded ordinance is removed, but the DRECP should designate the former Cuddeback Air Force Range as conservation land to remove ambiguity about its ecological importance.  According to a data set available on the DRECP Gateway,  portions of the Cuddeback range serve as a key population center and habitat linkage for the Mojave ground squirrel.  The range is also adjacent to the Superior-Cronese Desert Wildlife Management Area for the desert tortoise.

A screenshot from the DRECP Gateway data set on Mojave ground squirrel habitat shows that the former Cuddeback Air Force Bomb and Gunnery Range provides important habitat for this species.

In the scope of the DRECP, a 12 square mile patch of desert seems almost irrelevant.  But it is a gaping hole in a stretch of land administered by the Department of Interior, and if it were properly recognized for its ecological importance it would probably qualify for designation as an area of critical environmental concern (ACEC) and inclusion within the National Landscape Conservation System (NLCS).

Congressman Kevin McCarthy introduced legislation that would transfer the range to the U.S. Navy as part of the China Lake Naval Air Weapons Station (H.R. 4458), but designation of the area for conservation purposes under the DRECP would not preclude future use by the Navy.  In fact, other lands sought by the Navy are designated as NLCS in the draft DRECP,  so it is not clear why the Cuddeback area is left un-designated.

Monday, October 27, 2014

DRECP Spotlight: Bats

According to the Desert Renewable Energy Conservation Plan (DRECP), a full build-out of the anticipated wind energy target in the California desert region would kill from 4,000 to 283,000 bats each year (page IV.7-273).   This estimate assumes 2,023 turbines would be installed in development focus areas in the western Mojave, Lucerne Valley, Chocolate Mountains and Imperial Valley.

The wide range in the bat death estimate - a spread of over 270,000 - shows just how little we know about how renewable energy in the desert will impact bats.  The wind industry does not always cooperate with independent studies on wildlife impacts, and the industry funds the American Wind Wildlife Institute to shape the public discussion on this topic in a way that is favorable to industry.
The moon sets in the western Mojave desert during the early dawn hours.  I don't have my own picture of a bat because I'm not that good of a photographer.
I have not seen any information in the DRECP that states whether bat populations in the California desert could even survive mortality in the middle range of this estimate.  If the industry kills 100,000 bats each year for the next 25 years, will bats be able to maintain healthy populations?  What would be the breaking point for various bat species in the desert?  Could we see local extirpation of bats in the western Mojave and Chocolate Mountains?  The DRECP proposes to monitor bat populations after implementation of the DRECP, but it is not clear whether steps will be taken to curtail industry operations if bat populations spiral downward. 

Sunday, October 26, 2014

Renewable Energy World Slips on DRECP Coverage

Online industry magazine Renewable Energy World declared in a recent article that the Desert Renewable Energy Conservation Plan (DRECP) "kneecaps" the renewable energy industry, inaccurately arguing that 3,162 square miles of development focus areas is not enough for the industry.  This is my attempt to deconstruct the article's overall lack of understanding of the DRECP and the state of renewable energy in the California desert:

Claim 1:  The energy industry will be handicapped by the DRECP because 80 percent of the development focus areas are on private lands, and it is too difficult for the industry to acquire and develop private lands:  

Response:  This is not consistent with facts on the ground.  There are nearly 4,000 megawatts of wind and solar projects approved, under construction or operational on non-federal lands in the DRECP area, indicating that industry has easily acquired and developed private lands.  These include projects with a capacity of hundreds of megawatts built on already-disturbed lands.  I have previously covered some of these projects on this blog.   Renewable Energy World should examine Volume IV, page IV.25-8 of the DRECP cumulative analysis, which lists dozens of these projects.

And the DRECP still leaves over 570 square miles of development focus areas on federal lands - that is enough space on BLM land alone to accommodate tens of thousands of megawatts of renewable energy projects if every acre were to be developed. (The DRECP assumes that you can build about one megawatt of solar for every 7.1 acres of land - see Appendix F of the DRECP).  As I mentioned in a previous blog post, the DRECP designates way more development focus areas than would be needed to meet the 20,000 megawatt target.

Claim 2:  Concentrated Solar Power (CSP) - such as parabolic trough or solar power tower technology - is particularly hard hit by the DRECP.

Response:  Access to land has not been a significant limiting factor for CSP projects.  CSP has been hit by the fact that that CSP projects are more expensive than photovoltaic solar projects.  Some CSP projects approved by regulators were later scrapped because of the costs, and converted to photovoltaic projects.

Access to land has not, and will not be a big problem for CSP, which has been built on private and federal lands.  The Abengoa Solana and Mojave Solar projects in Arizona and California, respectively, have a combined generating capacity of over 500 megawatts using parabolic trough solar technology.  Both were built on private lands.  The 250 megawatt Genesis Solar power project was built on BLM lands in the Riverside East Solar Energy Zone, and uses parabolic trough technology. 

And once again showing how little research went into Renewable Energy World's article, claims that the DRECP handicaps solar power tower technology are contradicted by facts on the ground.  The DRECP will establish a development focus area where BrightSource continues to explore plans to build the large Hidden Hills solar power tower project (on private lands, by the way).   BrightSource Energy also has dibs on two other rights-of-way on federal lands in the Riverside East Solar Energy Zone - Palen and Sonoran West.  BrightSource had to withdraw its plans to build the Palen project because it could not secure sufficient financing with the looming expiration of federal tax credit, even though CEC and BLM were set to approve the project. 

Claim 3:  The California Wind Energy Association (CalWEA) is concerned that not enough lands identified as development focus areas are actually available for wind energy.

Response:  I have addressed this before.  CalWEA believes that it has the right to nearly every square inch of the desert, and acts like it is a neglected child that has not been given its fair share.  The wind industry has industrialized over 70 square miles of the desert region, and in the western Mojave Desert the industry has built one of the largest wind energy centers in the entire world.  One of the biggest limiting factors for wind energy in the desert region will be conflicts between the Department of Defense and wind operators because turbines interfere with the testing of radars and weapons.  If Renewable Energy World had been paying attention to the DRECP process in 2012 and 2013, they would have noticed that these concerns made wind development difficult, if not impossible, over a significant portion of the DRECP area. 

Before the wind industry gobbled up 70 square miles of land, the military laid claim to much more of the desert at Edwards Air Force Base, the China Lake Naval Air Weapons Station, Fort Irwin, Twentynine Palms Marine Corps Air-Ground Combat Center, and the Chocolate Mountain Aerial Gunnery Range.  These bases also interact with bases in Arizona and Nevada for testing and training.  In other words, CalWEA wants to cut in line in front of the military industrial complex, which itself has already clashed with conservation goals and popular outdoor recreation in the desert. In other words, get back in line CalWEA.

The wind industry's impacts on birds and bats is another limiting factors, and some of the places that the industry would like to develop in the desert host healthy populations of protected golden eagles.  No industry should be given a blank check to destroy natural treasures (see below).

Claim 4: Drought caused by climate change is killing wildlife, so we should build renewable energy projects even if they kill wildlife. It's worth the sacrifice.

Response:   The reason climate change is a problem is that human society consumes energy and natural resources with little regard for the consequences or for sustainability.  Arguing that we should just ignore the impacts of the renewable energy industry on biodiversity would be a continuation of this same broken paradigm.  It is the same twisted logic that the far right would use after a terrorist attack - we are under threat, so therefore we should give up our civil liberties to make our society safer.  It sets up a false dichotomy that suggests we can only have clean energy if we jeopardize biodiversity.  This is not true, and one of the initial drivers of the DRECP was to fix the idea that the industry must have access to every corner of the desert in order to be successful.  As I have mentioned above, renewable energy projects are popping up all over the desert, and the smarter and more flexible companies know how to find places to build projects on already-disturbed lands with less impact on wildlife.

Claim 5:  Estimates of bird deaths at solar power tower projects are "faulty."

Response:  Usually an industry-sponsored publication is not the best place for reliable coverage of scientific studies that are critical of that same industry, so there should be no surprise here.  Renewable Energy World's cursory look at the complex issue of bird deaths at solar power tower projects only exhibits the publication's scientific illiteracy, and the publication relies principally on quotes from industry officials to criticize research into avian mortality.  The author attempts to challenge a renowned wildlife expert who has been published in dozens of peer-reviewed studies and reports by stating that he misleadingly inflates the estimated number of annual bird deaths at the Ivanpah Solar project, which the researcher pegged at 28,000 for the upper range of his estimate.

Renewable Energy World notes that only a few hundred dead birds have been found at Ivanpah, and concludes that therefore the study suggesting thousands of birds may have died must be inaccurate.  Without belaboring the details, the Renewable Energy World author seems to not understand that researchers looking for dead birds do not always find all of the birds that have died. (If you want a thorough examination of the numbers and the science, check out this excellent KCET ReWire piece).  How do we know how many birds died as a result of the Horizon Deepwater oil spill?  Did we go out and find every single bird carcass?  No, we studied smaller areas or populations, considered other factors and biases, and produced a potential range of global impacts, called an estimate.  (And no, just because the oil industry kills birds does not justify our society killing even more birds in a different region - a greater harm does not excuse a lesser harm).

Hopefully Renewable Energy World can introduce a little more nuance and sophistication into its writing on these topics.

According to Renewable Energy World, the DRECP's 3,162 square miles of development focus areas (in pink) is not enough for industry to build solar and wind projects.

Saturday, October 25, 2014

Juniper Flats Safe For Now

Activists in the Lucerne and Victor Valleys received good news from the BLM this past week that plans for the North Peak Wind project had been withdrawn.  The project would have industrialized  nearly 16 square miles of a popular outdoor recreation area known as Juniper Flats popular for hiking and horseback riding, where desert habitat transitions from creosote and yucca scrub to chapparal, grassland and desert conifer.  Groups such as the Alliance for Desert Preservation and Mojave Communities Conservation Collaborative quickly organized to protect Juniper Flats, as well as to challenge the proposed Coolwater-Lugo Transmission project, which is still pending.

The hills in the background would have been carved up by wide access roads to reach newly installed wind turbines, which would have towered over the subtle peaks and erased the sense of peace and solitude that visitors find when visiting Juniper Flats.
Although it is not yet clear why the company withdrew the wind project application, local expression of concern regarding the fate of the beautiful Juniper Flats likely sent a strong signal to the developer - E.ON Climate and Renewables - that they faced an uphill battle.  Local concern also prompted opposition to the project by San Bernardino County supervisors. 

Another significant factor might have been the draft Desert Renewable Energy Conservation Plan (DRECP).  Under the BLM's preferred alternative, the Juniper Flats area would be designated as an area of critical environmental concern (ACEC), and a smaller portion of the area would be brought into the National Landscape Conservation System.  This put the wind project on a collision course with the DRECP because energy projects that do not have a published draft environmental review within 60 days of the draft DRECP's release would be subject to the DRECP's land designations (DRECP Volume II, page II.3-312).  North Peak Wind almost certainly could not complete a draft environmental review before the end of 2014, and would have been doomed by the DRECP's decision to designate Juniper Flats as an ACEC.

Fans of the Juniper Flats area are now asking to expand the NLCS designation to cover more of the area.  You can sign a petition in support of the NLCS designation at the Alliance for Desert Preservation website.  Although the ACEC status alone would prevent new energy applications among the hills, the addition of NLCS status would probably make the conservation status more enduring.

Saturday, October 18, 2014

Nevada: Draft Plan Would Endanger Natural Treasures

The Bureau of Land Management (BLM) put forward a draft resource management plan (RMP) for southern Nevada that ignores opportunities to protect lands with wilderness characteristics and proposes industrial-scale energy development near natural landmarks.  The draft RMP adds to the extraordinary burden that desert activists face as they comb through the Desert Renewable Energy Conservation Plan for neighboring California; comparing the two plans highlights how bureaucratic boundaries can result in arbitrary differences in how we manage desert wildlands.

Wildlands Sidelined

The RMP acknowledges that an inventory of desert habitat identified over 378 square miles of land with wilderness characteristics - sufficient size, naturalness, and outstanding opportunities for either solitude or primitive and unconfined recreation - that could be managed to preserve these attributes. However, the preferred alternative would only protect about 15% of these lands.

This area in the foreground, east of the Wee Thump Joshua tree woodland qualify as lands with wilderness characteristics, but will not be managed as such in the BLM's preferred alternative.  Spirit Mountain can be seen in the distance.

Most of the lands with wilderness characteristics that the BLM chose to respect are in the Gold Butte area of Nevada - which has been eyed as a possible monument - although even some eligible lands within the Gold Butte region will not be counted under the BLM's preferred alternative.  Areas outside of Gold Butte fare worse. Tens of thousands of acres of wildlands near the McCullough Mountains, Searchlight, around the Muddy Mountains, and the Resting Springs Range will be ignored.  The draft RMP does not give a rationale for why these lands will be ignored, even though they meet the criteria to be designated as lands with wilderness characteristics.

Energy Zones Threaten Landmarks

The preferred alternative would establish six new solar energy zones and several areas where wind energy would be encouraged across the region, including two solar energy zones less than 10 miles from Ash Meadows National Wildlife Refuge and a wind energy area immediately adjacent to the most remote corner of the Mojave National Preserve.   The draft RMP appears to ignore planning guidance from the Department of Interior because it overestimates the need for solar energy zones in the region, and does not properly analyze the zones that it proposes.

The BLM map below shows existing solar energy zones (Dry Lake and Amargosa) in dark blue, and proposed solar energy zones in light blue.  You can zoom in on the map with the tools embedded at the bottom.

When the Department of Interior first established solar energy zones in 2012, it stated that additional zones could be created after considering whether market conditions and space available in existing solar energy zones merited additional zones (page 168 of the Record of Decision for the Solar Programmatic EIS).  Nevada still has a total of five solar energy zones, with two in the area affected by the RMP.  Most of the solar energy zone acres in Nevada remain available, which calls into question why the RMP would create six additional zones.  Although Nevada plans to increase renewable energy consumption, it has already-disturbed lands, rooftops, and existing solar energy zones that could accommodate more energy generation than the Las Vegas region could use.

A single resort along the Las Vegas strip is installing 6.4 megawatts of solar panels on the rooftop of its convention space.  Imagine if all of the resorts, big box stores, parking lots, and homes of Las Vegas installed solar panels.  Photo by NRG.

Interior's 2012 solar energy development policy also requires that proposals to establish new zones analyze the potential environmental impacts in-depth.  To give you a comparison, the draft EIS published for Nevada's first solar energy zones analyzed impacts in over 2,400 pages.  But the draft RMP released this month seems to barely scratch the surface in its assessment of how the new solar energy zones might impact the environment.  The RMP does not even mention how solar facilities could pose a danger to migrating or resident birds at Ash Meadows, and it analyzes the potential impact of these zones on endangered pupfish in one sentence:

"Alternative 3 would make an even greater area around Ash Meadows available for solar projects which could lead to moderate to major impacts to the Ash Meadows special status species, including Devil's Hole pupfish, if the projects cause a lowering of the water table through groundwater withdrawals." - the extent of the draft RMP's analysis of impacts on Devil's Hole pupfish
Although solar uses less water than other types of energy generation, a single utility-scale solar project can still use millions of gallons of water a year for construction and washing dust off of solar panels.  Groundwater in the Amargosa area is already scarce, and some agricultural irrigation had to end in the mid-1970s because lowering groundwater supplies threatened to exterminate pupfish that depend on natural springs in and around the Ash Meadows National Wildlife Refuge.

The beautiful Amargosa Valley and Ash Meadows.  Although not visible, streams and springs dot the landscape and provide important habitat for wildlife. Photo by Basin & Range Watch.

The draft RMP proposes the Lathrop Wells and Ash Meadows solar energy zones, both within ten miles of the wildlife refuge, and a third solar energy zone - South Beatty - that would likely draw on the same groundwater supplies.  These three proposed zones would join the existing Amargosa Valley solar energy zone, which remains completely available to developers.  A total of four solar energy zones in the Amargosa Valley could decimate groundwater supplies and wildlife.

In addition to the solar energy zones, the draft RMP would designate areas deemed appropriate for wind energy, and areas where wind energy should be avoided.  Some of the proposed "open" wind areas would be on designated critical habitat for the desert tortoise north of Searchlight, and along the Nevada/California border immediately adjacent to the Mojave National Preserve.  The "open" wind area next to the Preserve appears to cater to the proposed Crescent Peak wind energy project.

Planning Disparity

As I continue to review the Desert Renewable Energy Conservation Plan (DRECP), I am struck by the disparities between the DRECP and draft Nevada RMP.  Unlike the DRECP, the draft RMP for southern Nevada does not consider how much renewable energy could be sited on already-disturbed lands, nor does it have any clear explanation of why the proposed solar energy zones are deemed necessary at this time.

The draft RMP also does very little to protect habitat connectivity for wildlife.  For example,  wind and solar zones would stretch across the Pahrump Valley, potentially fragmenting and severing currently intact habitat linking the Mesquite and Pahrump Valley Wilderness areas on the California side of the border with the Toiyabe National Forest and Red Rock National Conservation Area.  A better alternative would designate more of these desert valleys as exclusion areas for energy development.  

The draft RMP also seems to ignore how energy development along the border with California and immediately adjacent to the Mojave National Preserve could impact recreational values of those connected lands.  Wind turbines placed along the Crescent Peaks would introduce an industrial, man-made element to one of the most remote and peaceful corners of the Preserve, and pose a threat to raptors and other birds in the area.  Blinking red lights atop turbines would compete with the stars in the desert night sky.

And how does increased energy development and water consumption along the Amargosa River  in Nevada impact riparian habitat downstream in California, where the Amargosa is designated a wild and scenic river providing key habitat to even more resident and migratory wildlife?  These are questions and impacts not fully evaluated in the draft RMP.

The draft RMP should be revised to exclude energy development near some of these natural treasures, and consider the role of distributed generation and already-disturbed lands in meeting our renewable energy needs.

Monday, October 13, 2014

DRECP Spotlight: Conservation Designations

My last couple of Spotlights focused on how the Desert Renewable Energy Conservation Plan designates areas where large-scale renewable energy projects will be considered and fast-tracked, including development focus areas (DFAs), special analysis areas, and future assessment areas.  In an attempt to balance this destruction with conservation, the DRECP also identifies lands to be protected from various forms of destruction.  The types of DRECP conservation designations for lands in the California desert vary depending on whether the land is administered by the Bureau of Land Management (BLM) or private (non-federal).

BLM Conservation Designations

While the DRECP bestows conservation designations on some key BLM lands in the California desert,  the designations may not be very durable because they can be lifted in a future revision of a BLM land use plan.   This is particularly troubling because the projects built on DFAs will leave their mark on the landscape and ecosystem for generations after the projects are eventually dismantled, but conservation designations may be vulnerable to shifting policy priorities and economic pressures even within the next few years.  BLM State Director Jim Kenna, however, assured the public that it would be very difficult to remove the conservation designations, according to the Desert Sun.

For lands administered by the BLM, conservation designations include 1.) National Landscape Conservation System lands (NLCS) , 2.) Areas of Critical Environmental Concern" (ACEC), and 3.) Wildlife Allocations.   Of these three, the BLM would presumably need to meet a higher bar for removing NLCS status from lands in the future because Congress asked the BLM to identify which lands in the California desert meet the criteria for addition to the NLCS (Section 2002 of the Omnibus Public Land Management Act of 2009).  Because NLCS designations are considered to be the "crown jewels" of the BLM, removing NLCS status probably would attract extra scrutiny in the future.    The draft DRECP makes clear, however, that these are administrative designations and can be undone through future administrative actions (page II.3-314 of Volume II of the DRECP).

ACECs, on the other hand, have been removed from the California desert over the history of the California Desert Conservation Area (CDCA) plan.  For example, eight years after the original CDCA Plan was published, a plan revision deleted two ACECs originally designated to protect culturally significant sites because those cultural artifacts could not be found during surveys in 1987.  That said, more acres of ACECs have been added than deleted from the CDCA since 1980.

Conservation for Non-Federal Lands

In the case of private lands, areas deemed ecologically important will be known as "Conservation Planning Areas."   Unlike the BLM's conservation designations where renewable energy development will not be allowed, designations on non-federal lands will serve more as guidelines for future conservation easements that will probably depend in large part on "mitigation" funding from projects that destroy desert habitat elsewhere in California.  Protecting these lands will be more difficult because no single entity owns or controls them. This has been, and will continue to be a key weakness of conservation planning in the California desert - non-federal lands have facilitated the urban sprawl that has resulted in the loss of vast stretches of desert habitat without much consideration for the intrinsic value of protecting open wildlands.

For example, wildlife linkages connecting the Angeles and San Bernardino National Forests to the Mojave Desert will not be possible to protect without the cooperation of landowners near Lucerne Valley and El Mirage Valley.   The same goes for open desert around the Yucca Valley and Joshua Tree, where the many parcels of private land - if developed - would interrupt wildlife linkages.  It will be up to local communities to press the respective municipalities and counties to designate and enforce zoning and planning that protects these open spaces.

Open desert west of Phelan and surrounding Palmdale - like this area pictured above - is partially fragmented with residential development and roads, but some remaining open lands are designated as conservation planning areas.  How quickly these lands are purchased and set aside for conservation will depend on the availability of mitigation funds from projects that destroy habitat elsewhere in the desert, or from often undependable funding from federal and state conservation grants.

Acquiring Ecologically Important Private Lands

The DRECP identifies "conservation priority areas" that will be considered first for purchasing private lands to protect key wildlife habitat and linkages.  As I mentioned earlier, this funding is most likely to come from mitigation fees charged to project developers.  However, the draft DRECP also notes that some government funding could also support the purchase of private lands for conservation (page II.3-293, Volume II).  Potential Federal funding sources include the Land and Water Conservation Fund, and the Fish and Wildlife Service's Cooperative Endangered Species Conservation Fund HCP Land Acquisition Grants.  State funding sources may include the California Greenhouse Gas Reduction Fund and state tax credits that provide an incentive for landowners to donate land or accept conservation easements.

However, these conservation funding sources probably are not going to be reliable year-to-year, so progress in protecting wildlife habitat on non-federal lands is likely to be slow.  Without community cooperation, it seems likely that conservation efforts on non-federal lands will be outpaced by destruction for a variety of human uses.

Thursday, October 9, 2014

DRECP Spotlight: Development Focus Areas

The draft Desert Renewable Energy Conservation Plan identifies 2,024,000 acres (3,162 square miles) of "development focus areas" (DFA) in the preferred alternative.  Of that total, 367,000 acres (573 square miles) are on lands administered by the Bureau of Land Management (BLM).  I wrote yesterday about the assumptions that were used to come up with this many acres of DFAs.

DFAs By County:
The following numbers include a both private and BLM-administered lands.  Imperial County shoulders the heaviest DFA burden at 734,000 acres (1,146 square miles), followed by San Bernardino County at 399,000 acres (623 square miles), Kern County at 360,000 acres (562 square miles), Riverside County at 268,000 acres (418 square miles), Los Angeles County at 218,000 acres (340 square miles), and Inyo County at 45,000 acres (70 square miles).

Construction crews bulldozing Joshua tree woodland habitat in Kern County to make way for a wind energy facility.  Most of the wind facilities in this corner of the western Mojave Desert are built on private lands, although the BLM has also approved wind development here.  Photo courtesy of Friends of Mojave.
Incentives for Industry:
On BLM lands, DFAs will allow renewable energy projects to receive fast-track environmental review.  The DRECP will aim to make it cheaper and quicker for projects to be reviewed and permitted on BLM lands designated as DFAs.  You can read more about the specific incentives for DFAs on BLM lands in Volume II of the draft DRECP (PDF- page II.3 - 304).  On private lands, DFA status may make it easier for projects to receive Federal permits for the "take" (to kill or harass) of endangered species, although further benefits of the DFA designation for private lands will depend on the specific county's zoning and permitting process.

DFAs By County:
Imperial County shoulders the heaviest DFA burden at 734,000 acres (1,146 square miles), followed by San Bernardino County at 399,000 acres (623 square miles), Kern County at 360,000 acres (562 square miles), Riverside County at 268,000 acres (418 square miles), Los Angeles County at 218,000 acres (340 square miles), and Inyo County at 45,000 acres (70 square miles).

How Much Will be Developed?:
As I mentioned in yesterday's post about the DRECP's assumption that the California desert must host 20,000 megawatts of renewable energy projects by the year 2040, the industry needs far less than 2 million acres to generate 20,000 megawatts.  According to the DRECP acreage calculator, generating just above 20,000 megawatts would actually require developing somewhere in the ballpark of 284,000 - 351,000 acres (443 - 548 square miles).  This is still an enormous amount of land, but less than the total number of DFA acres.

A map of the draft DRECP's Preferred Alternative, with the DFAs designated in dark pink:

Wednesday, October 8, 2014

DRECP Fact of the Day: 20,000 Megawatts

This is an important number in the Desert Renewable Energy Conservation Plan (DRECP).  The State and Federal agencies that drafted the DRECP start with the assumption that the California desert region may need to host at least 20,000 megawatts of large-scale wind, solar or geothermal energy projects by the year 2040.  Based on this assumption, the DRECP agencies calculated how many acres would need to be designated as development focus areas (DFAs) to accommodate these 20,000 megawatts.
This is what the DRECP does not mention: a study by the UCLA's Luskin Center for Innovation calculated that the rooftops in Los Angeles County alone could accommodate over 22,000 megawatts of solar panels.  As I pointed out in my earlier post on the DRECP, the plan unfortunately discarded an alternative that would consist only of distributed generation (solar panels on rooftops, over parking lots, and other spaces in our cities).   The DRECP's purpose and need statement (Volume I.1) makes it clear that the Department of Interior and California Energy Commission assume that it is necessary to industrialize desert wildlands for large-scale renewable energy projects, so we're fighting an uphill battle in convincing the powers that be that there is a more sustainable and wildlife-friendly way to generate clean energy.  
For the sake of dissecting the rest of the DRECP's assumptions, we'll look at what the document says, but we should not forget that the DRECP underestimates the potential of distributed generation. To accommodate 20,000 megawatts of large-scale renewable energy in the desert, the DRECP designates over 2 million acres of DFAs.  However, the DRECP purposefully inflates the number of DFA acres because it anticipates that ultimately not every single acre of the DFAs will be available to renewable energy developers.  The DRECP expects that renewable energy companies will be unable to develop some parts of the DFAs because of local permitting constraints, wildlife concerns, access to transmission, or other issues.  So they over shot in their designation of DFAs to ensure that the renewable energy industry will have ample opportunity to build large-scale projects. 

With the right incentives and policies, we could tap the vast potential of spaces in our cities to generate clean energy.  The DRECP, however, assumes that we will need to bulldoze hundreds of square miles of desert to tap solar and wind resources, even though the technology allows us to do so without such destruction.
But how did we get to 20,000 megawatts?  The "Planning Process" section of the DRECP (specifically, Volume I.3, page I.3-43) attempts to lay out how they arrived at the 20,000 megawatt number.  The document states that this is how many megawatts of clean energy the desert region will be expected to generate in the year 2040 when demand for energy is expected to be much higher than today because of a bigger population and increased use of plug-in electric vehicles.  What is less clear in the document is how much of the overall burden the desert is expected to carry compared to the rest of the State.  Does the plan account for the potential development of wave energy or wind projects off the coast of Los Angeles?

The plan also doesn't make clear how the calculation accounts for projections that renewable energy technology and energy conservation efforts will become more efficient over time.  Solar panels in the year 2025 will likely generate more energy per acre than solar panels in 2015, and some of our appliances will hopefully use less energy in 2030 than they do today.

Much of the technical calculations that go into the 20,000MW assumption were discussed and decided in DRECP stakeholder meetings back in 2012 or earlier.  But we're left to squabble over the impacts of these assumptions, and we are not given much room to question why our renewable energy future has to look so much like our current energy paradigm - involving the wholesale destruction of the land to blindly feed the mantra of economic growth and increasing conumsption.

Tuesday, October 7, 2014

DRECP Fact of the Day: Eagles

Golden eagles soar over the Mojave Desert. We know that wind turbines and golden eagles do not mix well.  Solar power towers - like those that BrightSource and NRG built in the Ivanpah Valley - can burn eagles alive.  And sprawling photovoltaic solar plants can destroy the wildlands where golden eagles like to forage for food.   The U.S. Fish and Wildlife Service (FWS) is responsible for monitoring the status of the golden eagle, and determining whether or not any industry - including the renewable energy industry - is permitted to "take" (harass or kill) golden eagles.  (Note: the golden eagle is not an endangered species, but it is protected under the Bald and Golden Eagle Protection Act)

A golden eagle recovering from an injury at the High Desert Museum in Bend, Oregon.  These birds face a number of threats from humans, including climate change, power lines, strikes with vehicles, and wind turbines.
According to Appendix H of the Desert Renewable Energy Conservation Plan (DRECP), the FWS has determined that the total number of golden eagles that can be "taken" each year in the California desert is 15.  (Appendix H, page H-28)  According to the draft DRECP:
"This number will go up or down depending on factors such as implementation of projects that take golden eagles inside or outside the DRECP area and the population status of golden eagles. The USFWS Migratory Bird program will send a letter annually in December to the DRECP executives to inform them of the amount of eagle take available for the following calendar year." 
This means that if FWS permits a wind project in the California desert to "take" up to 3 golden eagles a year for the next 20 years, there will be three fewer eagles available for other renewable energy projects to kill on an annual basis for the next 30 years.  But FWS could revise the total cap of golden eagle "take" to be lower if studies determine that the golden eagle population is actually doing worse than expected, or revise the total "take" number to be higher if they find the golden eagle population to be doing well.

The FWS estimates that as many as 230 golden eagles call the California desert area home.  The FWS believes that the population can remain stable - even with 15 eagles killed each year - because eagles from the California desert and surrounding territory will lay eggs and hatch baby eagles that can help replenish the population.

What is not clear is what will happen if the golden eagle population declines rapidly for other unexplained reasons, but FWS has already handed out so many permits to kill golden eagles that it has essentially given a green light to the local extinction of this majestic bird.  FWS permits to kill golden eagles can be good for as long as 30 years, which makes it tougher to shut off the human causes of eagle deaths.  Can FWS force energy projects to shut down to avoid the local extermination of golden eagles?  FWS is handing out checks that are good for as many as 30 years, but the eagle population is dynamic - it can go up or down each year, and we do not always have control over what factors cause that fluctuation. What happens when FWS not only goes broke, but is in default - allowing companies to kill more golden eagles than can be replenished naturally?

The golden eagle is one of many amazing species that calls the desert home, and you can see that the DRECP lays out a policy framework that can substantially impact - for better or worse - the future of wildlife in the desert. Whenever I have time I will try to pull out these examples of impacts (on wildlife, lvisual resources, recreation, etc) and convey my concerns as accurately as possible.  I do ask for your patience, though, because this is not my full time job and the DRECP is over 8,000 pages.

Sunday, October 5, 2014

DRECP: First Impressions

The draft Desert Renewable Energy Conservation Plan (DRECP) was released at the end of September, almost 34 years after the Department of Interior finalized its original plan for managing the vast and beautiful California Desert Conservation Area.  With nearly 8,000 pages and extensive reformulation of land use policies throughout 22 million acres of California, the DRECP will take a while to digest and formulate thorough comments.  This plan will shape the future of one of the largest intact ecosystems remaining in the lower 48 United States, so it will be worth the time to review and provide input.

By the Numbers - Energy Industrialization
3,146 square miles:  The number of square miles of "Development Focus Areas" (DFA) designated by Federal and State agencies in the preferred alternative where large-scale wind, solar, and geothermal energy development will be encouraged or fast-tracked.   Although it is important to note that the DRECP does not anticipate that every acre of the DFA will be developed, the total area of DFAs is approximately four times the amount of land already urbanized or paved over by our desert cities.  About 576 square miles of the DFAs fall on public lands managed by the BLM, and the rest on private or other non-federal lands.

285 square miles:  The number of square miles that would be designated as study areas and variance lands where renewable energy may be considered after additional environmental analysis and administrative review.  The study areas are broken up into two different types - special analysis areas and future assessment areas - and were designated because Interior recognizes the value of these lands to the renewable energy industry, but also the potential value of cultural and biological resources there;  Interior believes more information is needed before it determines whether they should be bulldozed or preserved.

182 square miles:  Renewable energy projects already approved throughout the DRECP, according to the cumulative impacts analysis.  Of these 182 square miles of approved projects, as much as 100 square miles have already been industrialized or bulldozed.  Many more square miles of projects are under environmental review.

10%:  The portion of the 22 million acre DRECP plan area where large-scale renewable energy will be encouraged or considered within DFAs and study areas. One out of every ten acres of the region will be considered a prime area for renewable energy generation.
One of Many Uses

As I mentioned in my last post before the DRECP was released, the California Desert Conservation Area was specifically identified by Congress as requiring careful management for its unique conservation values, and to balance multiple competing human uses of this beautiful landscape.  The DRECP attempts to make way for 20,000 megawatts of large-scale renewable energy in a region under pressure by urban sprawl, overdrawn groundwater supplies, multiple large military bases and training centers, mining, grazing, and various types of outdoor recreation.

So, identifying ten percent of the entire DRECP planning area as DFAs strongly signals that the renewable energy industry - despite being a latecomer to the long line of desert users and abusers - is being given a prized status.  Especially when you consider that large-scale renewable energy facilities typically exclude many other uses by closing open trails, killing wildlife, and disrupting scenic vistas.

What About Rooftop Solar?

The draft DRECP fails to fully evaluate an alternative focused on distributed generation, even though the large-scale renewable energy projects that it supports are quickly becoming outdated.   We would not need to bulldoze a single acre for large-scale renewable energy if we fully tapped the potential of energy conservation (shutting off appliances we are not using), energy efficiency (engineering appliances so they use less energy), and the scalability of solar, wind, and energy storage.  These options mean that our clean energy future could fit in our backyards, on our rooftops, in our garage,  and over parking lots.

The DRECP acknowledges calls by the public for more distributed generation and less desert destruction, but refuses to evaluate a distributed generation alternative primarily because the Federal and State entities that developed the plan have orders from their bosses (the President and California Governor Jerry Brown) to facilitate the expansion of utility-scale renewable energy on wildlands.  These State and Federal policies are a relatively blunt tool against climate change because they set a target for generation without giving much guidance on how to value things like migratory birds, desert tortoises, beautiful sunsets, or the wilderness experience. (The policies also cater to business interests more sincerely than they answer the demand for climate action, as evident in the White House's approval of coal, oil, and gas leases on public lands elsewhere in the United States that are inconsistent with its own statements on the urgency of addressing our fossil fuel footprint.) The DRECP is an attempt to more deftly direct the impacts of these utility-scale renewable energy policies, but the plan's underestimation of distributed generation is very unfortunate.

The DRECP agencies could partially fix this flaw if they re-examine the baseline assumptions of how much renewable energy we will need from utility-scale versus distributed generation, and then reduce the total acreage of DFAs.  The DRECP is built around the assumption that the desert region will need to shoulder the burden of 20,000 megawatts of utility-scale renewable energy generation, but acknowledging the potential of distributed generation could ease this burden on our wildlands.

And Larger Projects on Already-Disturbed Lands?

The DRECP preferred alternative does identify already-disturbed lands - such as current or former agricultural lands - as DFAs, with a particular concentration of such DFAs in the western Mojave and in the Imperial Valley.  While I think this is much better than bulldozing intact desert habitat, it is important to note that building large-scale renewable energy projects on already-disturbed lands is not without consequence.  Removing farm fields and putting in solar panels can increase air pollution with wind-blown dust, and alters local economies.  Also, there are some species of wildlife that make use of agricultural lands, such as the western burrowing owl.  The location of the already-disturbed lands is also important to consider.  For example, we would not want to build a bird-scorching solar power tower along the Colorado River migratory bird flyway, even if it was built on already-disturbed lands.

The 'C' in DRECP Stands for Conservation

The DRECP attempts to protect key landscapes for wildlife and recreation through conservation designations - federal and non-federal.  On lands mostly under private or local jurisdiction, a general conservation plan identifies areas where conservation easements and zoning may help protect key open spaces.  On lands administered by the Bureau of Land Management (BLM), the DRECP designates additional areas of critical environmental concern (ACEC), National Landscape Conservation System lands, and recreation management areas.  While these BLM designations will help steer destructive uses away from some of the larger blocks of intact desert, the overarching concern is that these designations are not as durable as Wilderness Areas or Monuments.  In other words, the BLM could undo the ACECs or NLCS designations a few years from now.

All-in-all, the DRECP preferred alternative would bestow welcomed conservation designations on some key public lands.  However, the draft plan leaves some ticking time bombs and is another swipe of the scalpel at one of the largest intact ecosystems remaining in the lower 48 United States.  For example, the Silurian Valley contains a large "special analysis area" that might accommodate Iberdrola's pending plans for a large wind and solar project.  Much of the Hidden Hills area - situated among wilderness areas in California, and the beautiful Pahrump Valley that spans both California and Nevada - would be designated as a DFA.  And a "future assessment area" in the Cadiz Valley means that some day a solar power tower could be built in this serene landscape, reaching hundreds of feet into the air to spoil the look and feel of a stretch of desert where the predominant human development is a lonely two lane highway - the Historic Route 66.

Desert habitat in the western Mojave Desert, around Lucerne Valley, and in the Imperial Valley would be under even more stress since much of the DFAs are concentrated in these regions.  Much of this land currently falls under county jurisdiction.  This will have substantial implications for already fragmented and beleaguered Joshua tree and pinyon woodland habitat along the foothills of the San Bernardino and San Gabriel Mountains, and the grasslands of the Antelope Valley.  The DRECP appears to offer a compromise by protecting some narrow wildlife corridors, but that may be all that remains if human development - housing, farms, and now renewable energy - fills in the open space of what is currently a rural checkerboard of desert where jackrabbits and coyotes cross peoples' front yards transiting from one patch of desert to the next.

Devil in the Details

In a plan covering over 22 million acres, it can be difficult to figure out how some of our favorite corners of the desert will be affected.  For the DFAs and conservation designations covering private or non-federal lands, it is best to consider these proposals in the context of your local or county zoning and project permitting process.  If you live next to an open patch of desert that is in private hands, local officials and zoning policies will have the ultimate say on what can be built on these non-federal lands, regardless of whether or not a particular parcel is considered a DFA or conservation area in the DRECP.   For desert lands that are managed by the BLM, look closely at how the BLM plans to manage these lands under the DRECP.  For example, an ACEC may exclude renewable energy development, but allow other uses that could still have an impact on wildlife.  Many of the details for BLM land use plan changes are buried in Appendix L of the DRECP.

Here are a few issues I have identified, so far.

Silurian Valley:  As mentioned above, the special analysis area in the Silurian Valley is troublesome.  If Interior decided to move forward with allowing any development in the Silurian Valley, we would lose the untrammeled qualities that make this place such a majestic gateway to the desert for travelers exiting Interstate 15.

Mojave National Preserve: The draft DRECP proposes a "future assessment area" immediately adjacent to the Mojave National Preserve at the intersection of the Ivanpah and Clark Mountains.  If Interior ultimately decides to approve renewable energy development here, it would destroy wildlife habitat and introduce industrial development to the viewshed of even more of the scenic Preserve.

Lucerne and Apply Valleys:  The DRECP preferred alternative would designate an ACEC around the Juniper Flats area and the Granite Mountains east of Apple Valley that would likely foil attempts by wind energy companies to build on land prized for outdoor recreation and recognized as important golden eagle habitat.  However, DFAs would stretch across much of the lower elevation areas of this region, decimating the checkerboard of remaining creosote and yucca scrub habitat that connect the Juniper Flats and Granite Mountains.  Much of the DFAs here fall on private lands.

Ancient Creosote Rings:  Situated near the Johnson Valley Off-Highway Vehicle Area, the King Clone Creosote Ring - one of the oldest living organisms on the planet - is currently protected by a small ACEC that is surrounded by mostly undeveloped desert habitat.  The draft DRECP adds National Landscape Conservation status to the existing ACEC, but would designate most of the open desert around it as a DFA.  Again, much of the DFAs around the rings fall on private or State lands, not BLM.

Cady Mountains:  The ghost of the Calico Solar project lives on.   This project was approved but never built because of troubles with the "suncatcher" technology and financing.  The old right-of-way for the Calico Solar project remains undesignated in the draft DRECP.  Presumably this would still count as a solar exclusion zone under the Solar Energy Development Policy finalized in 2012, but it seems odd that this area was not designated as an ACEC given that studies pointed out the significant importance of the entire right-of-way for wildlife - including white-margined beardtongue, Mojave fringe-toed lizard, and desert tortoise.

Desert Tortoise Natural Area:  This sanctuary for the desert tortoise near California City would lose about 250 acres at its northern edge that would then be designated as part of a larger DFA, according to documents in Appendix L of the DRECP.

I will need to continue studying the plan and look forward to hearing other people's concerns from across the desert on how the DRECP will impact our desert wildlands.

Public Input Needed:

You can provide your input on the draft DRECP to Federal and State agencies by e-mail or regular mail, or at any one of several public meetings scheduled in California towns and cities.   Comments are ultimately due by January 9, 2015. 

Stay tuned for more as we continue to look through the draft DRECP.