I have been meditating recently on the word “mitigation.” It is a word often used in environmental impact reports for large-scale solar projects, such as the 150-megawatt Desert Harvest project being planned for 1,000-1,200 acres of open desert five miles north of Desert Center.
Basically, what the environmental impact report is is 2,000-plus pages documenting the impacts of putting a massive solar farm in the desert, followed by plans to mitigate said impacts.
The dictionary definition of mitigate, from Merriam-Webster is (1) to cause to less harsh or hostile, mollify; (2) to make less severe or painful, alleviate or extenuate. Extenuate is, of course, an interesting word in and of itself. It means to lessen or to try to lessen the seriousness or extent of by making partial excuses.
So, when it comes to lessening the impacts of solar, it seems there are two basic classes of mitigations — direct, onsite actions andindirect, offsite actions.
In the direct, onsite mitigations, we have what companies do to lessen dust and other air pollution caused by construction. So the EIR for Desert Harvest shows that construction will cause a range of air pollution — carbon monoxide, particulate matter and nitrous oxide – above standards set by the South Coast Air Quality Management District. The project developer, enXco, will be required to implement a range of mitigations, frompaving roads leading to the project site; ensuring construction equipment is turned off when not in use, rather than sitting around idling; keeping soil loads 18 inches below the rim of trucks and limiting speeds on unpaved roads to 15 miles per hour.
Not perfect, but definitely lessened — an appropriate use of the word mitigation.
When we get to habitat, plants and animals, things start falling more into the extenuating side 0f the definition, because the main form of mitigation for habitat destruction is buying other land to offset the loss.
Thus, for the destruction of desert plants and soils on site, the BLM lists six mitigations, ranging from having an onsite biologist to monitor construction, educating workers about the site’s flora and fauna, the relevant regulations and their responsibilities for complying with them and a vegetation management plan.
But, the reports says, “Note that all disturbances to soils and vegetation are analyzed here as long-term and permanent impacts and off-site compensation is required.”
Which gets us to the sixth mitigation, which is how much land the company will have to buy to compensate for the loss of the 1,000-1,200 acres the project may destroy. For plants, the compensation ratio runs for 1 to 1, for creosote bush scrub lands to 3 to 1 for desert dry wash woodland, which is classified as a special-status plant community because of its role in the desert’s natural water system.
This is a bit of a shell game, moving plants and animals to other sites or just protecting other, similar sites. It’s a trade-off, and different people have different views on whether or not it’s one they find appropriate and worthwhile.
Translocation is tricky. For example, the report notes that while efforts could be made to take out and replant any Emory crucifixion thorns, a sensitive plant found on the Desert Harvest site, there are no documented instances of this being done successfully. Another possibility would be planting greenhouse-raised plants on the compensation lands.
In fact, it would probably be better to use the word compensate – to counterbalance, or to make an appropriate, counterbalancing payment –in such cases. There is no true mitigation for destroying habitat that can take hundreds or thousands of years to regenerate.
Which brings me — in a not quite clean segue — to the meeting in Desert Center April 14 on the Desert Harvest draft EIR and Holly Roberts, a project manager for the Bureau of Land Management’s Palm Springs office.
Roberts is one of the unsung heroines of the local renewable energy community. She is enormously respected but tends to keep behind the scenes.
At the meeting, she started off the BLM’s presentation with a brief talk on the kinds of feedback the agency is looking for, which is, she said, substantive.
“Question the BLM about the accuracy of its information or the adequacy of its process,” she said.
What doesn’t work are vague questions or complaining that a project is going to ruin the view from your patio, she said.
Roberts really believes that the process laid out for public comment periods in the National Environmental Protection Act is an example of grassroots democracy at its best. She wants people to get right up in the BLM’s face and challenge the agency on its facts and methodology.
She pointed out that the Desert Sunlight project now under construction north of the proposed Desert Harvest site was first planned for 20,000 acres.
“Because of public comments, 16,000 acres were taken off the project,” she said.
Of course, there are limitations to this approach, as seen in the case of the archeological artifacts found at NextEra’s Genesis project, which my colleague Keith Matheny wrote about in today’s paper.
Tribal concerns and ways of protecting prehistoric desert sites containing archeological artifacts do not fit well with the kind of linear, factual quantifications required by federal and state laws. To them, the sites are sacred and anything in the ground should be left there, completely undisturbed.
The Desert Harvest site has two prehistoric sites that are listed on the National Registry of Historic Places, according to the draft EIR. Alfredo Figueroa, the one tribal representative at the Desert Center meeting, said he has not been on the site so could not comment on whatever might be out there.
All that said, we will now see what kind of comments the Desert Harvest draft EIR generates. All 2,000-plus pages of it are online on the BLM Palm Springs Field Office website. Hopefully, people will dig in, look at the analysis of impacts, mitigations and compensations and give the agency some comments to think about.
Make Holly Roberts happy. You have till July 18.