Tag Archives: BLM

Mitigation meditation — the solar trade-offs

Posted: May 15th, 2012 | Author: | Filed under: The Green Blog | Tags: , , , , , , , , , , , , , , , , , , , , ,
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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.

Reading the Desert Harvest draft EIS — and green schools

Posted: April 17th, 2012 | Author: | Filed under: The Green Blog | Tags: , , , , , , , , ,
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The problem with the Bureau of Land Management’s environmental impact statements for large-scale solar projects is their length. The recently released draft EIS for enXco’s 150-megawatt Desert Harvest solar project near Desert Center is a case in point. I don’t have an exact page count yet, but a quick eyeballing puts it well over 1,000. Chapter 4, the key Environmental Consequences section is 615 pages in and of itself.

So, I have started chipping away at the report’s most important sections so you won’t have to. The goal is to have a reasonable understanding of what the main issues surrounding the photovoltaic project are by May 14, when the BLM will hold two public meetings, one in Desert Center and one in Joshua Tree, to gather public comment on the draft.

Let’s begin at the beginning with the relatively compact Executive Summary — an easy 9 pages.

The main thing you need to know here is that the BLM has come up with seven alternative scenarios for the project – ranging from no project at all to three different ways to cut its size down from 1,208 acres to either 1,161 acres or 1,044 acres.

The alternative the agency likes best so far is Alternative 7, which reduces the footprint down to 1,044 acres, specifically taking out a 9-acre area that contains crucifixion thorn, a “sensitive” plant. However it does leave in 47 acres which are part of an official wildlife habitat management area.

Alt 7 also provides for much higher racking for the panels — 15 feet versus the 6-foot-tall racking systems used in all the other alternatives.  It is not well explained here, but other alternatives that reduce the project footprint also reduce the amount of power it will produce by between 5 megawatts and 15 megawatts.

Alt 7 would keep it at 150 megawatts.

The Executive Summary also identifies seven unavoidable adverse impacts of the project, which range from air quality – air pollution during construction – to permanent loss of plant and animal habitat to a dramatic change in the visual landscape.

“The project would create impacts from the conversion of natural desert landscape to landscape dominated by industrial character. Long-term scarring would follow project decommissioning. The project would have strong visual contrast with the surrounding landscape and would be visible from proximate wilderness areas and scenic vistas.”

The report also looks at the cumulative impact of land use conversion along Interstate 10, slipping in a key figure. Desert Harvest is part of a total land use conversion that will eventually encompass 52,000 acres, or 2.5 percent of the land, along the I-10 corridor.

That figure is more than a third of the 147,910 acres of the federally designated Riverside East solar zone, and the report notes, there are no mitigation measures to reduce the visual impact.

On the environmental side, the project would add to the cumulative loss of habitat and migration corridors for sensitive and endangered species, even with mitigation measure.

Between now and final approval, all these issues will have to be resolved, and Riverside County, which is the lead jurisdiction on state permitting for the project – that is making sure it meets California’s rigorous Environmental Quality Act, or CEQA — will have to adopt a “Statement of Overriding Considerations” that will allow the project to go forward despite significant unavoidable impacts.

So, that’s the overview. Stay tuned as I continue to read and fill in the details.

And, before I end here, the Princeton Review, in partnership with the U.S. Green Building Council, has released its Guide to Green Colleges, which this year contains 322 listings on U.S. and Canadian campuses that “demonstrate a strong commitment to sustainability in their academic offerings, campus infrastructure, activities, and career preparation.”

The link to the online guide is http://www.princetonreview.com/green-guide.aspx

California is well represented, as might be expected, and yes, UC Riverside is on the list.

My various alma maters are also on the list — thank goodness – Brandeis University in Waltham, Mass., where I got my B.A., and the University of Maryland’s College Park campus, where I got my master’s of journalism degree.

Cultural showdown at the Genesis solar project

Posted: February 24th, 2012 | Author: | Filed under: The Green Blog | Tags: , , , , , , , , , , , , , , , , ,
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The discovery of what could be prehistoric tribal artifacts at NextEra’s  250-megawatt Genesis solar project in the Riverside East solar zone east of the Coachella Valley has sparked a potential standoff between Native American tribal groups on one side and the Bureau of Land Management and the solar developer on the other.

At issue is whether or not work on the solar thermal plant can continue in the area where the artifacts were found, even if it means NextEra might have to abandon the project all together.

The story starts in mid-November when crews grading land at the solar site found stone artifacts called metates and manos, which are prehistoric grinding tools, laying on a bed of charcoal, according to tribal officials.  BLM officials have called the find “unprecedented.”

Since then, the BLM has ordered all work stopped on a 200-acre area of the Genesis site and has been working on a plan that is supposed to ensure any significant archeological finds are preserved but will allow the project to continue.  Telephone conferences with stakeholders have also been held as the bureau has tried to hammer out a workable plan.

The details of exactly what was found and what has happened since the discovery have not been made public so far. NextEra files monthly status reports on the project with the California Energy Commission, but the sections on cultural resources were removed from both the November and December reports.

Steve Stengel, NextEra’s spokesman, laid out the company’s position in a statement recently emailed to The Desert Sun.

“During the permitting process for the Genesis Project, the involved agencies anticipated that Native American artifacts could be found during construction and an agreement was signed by two Native American Tribes that defines a process for respectfully treating the artifacts. While some artifacts have been found, no determination has been made that the artifacts are of a village or prehistoric site. At the request of the BLM, construction activities have been temporarily suspended on a small portion of the project site. The remainder of the site is under construction.”

Desert Sun photographer Richard Lui and I visited the Genesis site the end of January, when I asked NextEra officials point blank if any significant cultural artifacts had been found. They fudged the answer, first saying no, then adding that it would depend on who defined what a significant artifact is. They also did not tell us that the BLM had ordered grading stopped on a portion of the site.

At this point, the draft of the plan for handling the site and any artifacts is also confidential, but based on tribal letters raising concerns about it, the basic idea is that NextEra would be allowed to continue work on the site, using a method called controlled grading. That means trucks would continue to grade the land, but only about an inch down at a time, with the dirt sifted for any artifacts.

John Kalish, field manager at the BLM’s Palm Springs office, said Friday afternoon, the plan was close to approval, despite strong opposition from Native American tribes in the area.

Under agreements with the tribes that were required as part of the federal approval for the project, NextEra was supposed to notify them of any archeological finds on the Genesis site within 48 hours. The tribes are also supposed to be consulted on any further plans for handling of such sites.

According to two letters from the Colorado River Indian Tribes to the BLM, this has not happened. In a letter dated Jan. 19, Eldred Enas, chairman of the Colorado River tribes, said they had not been notified until almost two weeks after the find and they have repeatedly stated that they don’t want the site graded; they consider it a spiritual site and they want it left alone.

In both letters they cite a number of agreements and protocols which state that site avoidance is the preferred mitigation process for cultural findings such as the ones at the Genesis site, unless it is unfeasible, which NextEra maintains it is. The plant itself is planned for about 2,000 acres, so cutting it down by 200 acres or more could mean no project. 

And because assessment of the site is being carried out primarily by NextEra consultants along with archeologists from the BLM and Energy Commission, Enas said the process may be inherently biased.

“While we do not doubt the integrity of these entities, we believe their interests naturally, and necessarily align with the Project’s continued development and completion. Tribal interests may lie elsewhere,” he wrote.

From the tribes’ point of view, he said, the discovery of the artifacts in and of itself makes the site sacred, and no further evaluation is needed to declare it off limits.

He asks for a much slower process to evaluate the site with a Colorado River tribes expert involved and with face-to-face meetings with BLM officials.

Obviously, this is a story that requires further research and reporting.  I will be talking more with NextEra, BLM  and tribal officials on Monday.

I will also be catching up on the status of the kit fox survey now underway, which is trying to find the reason for the recent outbreak of canine distemper among foxes on or near the Genesis site.  From October to December, seven kit foxes died from the disease — another unprecedented occurrence.

NextEra’s next solar plant will be PV

Posted: September 2nd, 2011 | Author: | Filed under: The Green Blog | Tags: , , , , , , , , , , , , ,
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As it begins construction on its 250-megawatt Genesis solar thermal project east of the Coachella Valley, NextEra Energy has its second desert solar plant in the works.

The company has filed an application with the Bureau of Land Management for a 750-megawatt photovoltaic plant, called the McCoy Solar Energy Project, to be located 13 miles northwest of Blythe. The BLM filed a notice of the application in the Federal Register earlier this week, which means the official scoping period has begun, during which the agency collects public input on what issues it needs to look at for its official environmental impact report.  The deadline to submit comments to the agency for this round will be Sept. 28.

The available information on McCoy thus far is sketchy.  The project site includes 7,700 acres of public land and 470 acres of private land, which means the BLM will have to partner with Riverside County for the environmental impact report.  To connect to the grid, the project will need a 16-mile tie-line to connect with Southern California Edison’s Colorado River substation, and the right of way for that line will include both public and private land.

According to the company’s initial application, the McCoy project would generate enough electricity to power 225,000 homes. On the jobs front, NextEra estimates it about 600 jobs during peak construction and 13-20  for ongoing operation.

The fact that NextEra has chosen photovoltaic panels over solar thermal for this second project reflects the ongoing shift to PV for utility-scale solar plants — a trend driven by the plunging costs of panels and, hopefully, an easier permitting process.

NextEra had a difficult time permitting Genesis as solar thermal, primarily over water issues. Solar thermal requires a lot of water, and NextEra originally planned Genesis using the most water-intensive “wet cooling” technology, which led to long wrangles over whether the project would tap into the Colorado River aquifer. The BLM pushed back and the company had to change to more water-efficient “dry cooling” technology to get the project approved.

The tradeoff here is that while PV uses almost no water, it isn’t as reliable a power source as solar thermal, which uses heat from solar troughs to run steam turbines. The turbines create a smoother power flow compared to the spikier electricity coming from PV panels that convert sunlight directly to electricity.

While it is impossible to know at this point,  in the past, the BLM has held at least two public scoping meetings per project on the solar plants it has already approved in the Riverside East solar zone — one in the Coachella Valley, usually at UCR Palm Desert, and one in Blythe.  Given the Sept. 28 deadline, whatever’s going to happen will likely be happening soon.

I will be following up on this next week along with First Solar’s Desert Sunlight project to see how many valley residents have gotten call backs from the job fairs the company held almost three weeks ago.

Here’s hoping the Labor Day weekend will be followed by green jobs for some of the 1,200 valley job seekers who turned out at the Spotlight 29 Casino to apply for work on Desert Sunlight last month.

Wind turbines in the high desert

Posted: August 8th, 2011 | Author: | Filed under: The Green Blog | Tags: , , , , , , , , , , , , , , , ,
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I took a drive up to Pappy & Harriet’s in Pioneertown on Saturday to attend a meeting of a recently formed group called Save Our Desert, which is organizing fast and furious to oppose a company that is looking to put wind turbines on ridgeline locations in Pipes Canyon.

The company, Element Power, is a global renewable energy firm with U.S. offices in Portland. It has already gotten permission from the Bureau of Land Management to put up test towers topping out at 197 feet on Black Lava Butte, a moutain that rises more than 4,700 feet above see level.

The towers are part of a feasibility study the company is performing prior to deciding on whether to submit an application for the full project. I have not talked with the company yet, so have not heard their side. The environmental impact study they filed to put the test towers up is on the Save Our Desert website.

Black Lava Butte in Pipes Canyon

Cherry Good, a local resident who is one of the main movers behind the group, spoke at the meeting on Saturday, detailing a long list of ojbections to putting large turbines in Pipes Canyon.   She started with the turbines’ impact on the desert plants and animals and kept rolling through the noise and fire hazards associated with wind turbines and the impact on property values.

Other concerns revolve around the canyon’s isolation. The key criteria for renewable energy development on public lands are a site’s proximity to existing infrastructure — that is roads and power generation needed for construction — and transmission lines, needed to take the power to urban markets.

 Just putting the test towers on the buttes required flying them in by helicopter because no roads exist. Construction would require paving a road through the canyon, which Good said, is not very wide.

Test wind tower in Pipes Canyon (Photo from The Press-Enterprise)

“The center of Pipes Canyon would cease to exist,” she said.

Getting construction material up to Pioneertown would also be a challenge, as anyone will tell you who’s driven up the two lanes of  Pioneertown Road behind a slow-moving trailer — as I did Saturday.

If this project goes forward, it might not be the only one looking to put mammoth turbines on pristine ridgelines.  Closer to home there’s the Cabazon Ridge project, which would put a string of wind turbines  on private land along the ridge lines of Santa Rosa and San Jacinto National Monument, on the south side of Highway 111 going into Palm Springs.

There are already lots of turbines on the north side of 111, but the southside is where the mountains rise up, pristine and jagged. Cabazon Wind Energy LLC, which has filed an application with the BLM, wants to put somewhere between 42 and 52 wind turbines, all more than 400 feet tall, on the ridgelines.

This project has not gotten a lot of public attention and therefore has not sparked the kind of opposition Save Our Desert is currently mounting.  I’m going to be gathering more information on both projects for a future article.

The people at the meeting in Pioneertown are dead set against the turbines and angry that the test towers were erected with no advance notice from the BLM or Element Power. These are the same folks who organized to defeat the Green Path North transmission project, an effort by the Los Angeles Department of  Water and Power to build a transmission line across the desert to bring renewable energy to the city.

Most of them moved to the high desert because of their love of desert landscapes and isolation from the rush of modern of life.  Many of them already live off the grid, powering their homes with solar and wind energy.

Which is all to say when these people get organized they are a force to be reckoned with, and they know it.

“I don’t like the idea of speculators coming in here for profit and to make a cash cow out of Pioneertown,” said Randy Bristow, who’s lived in Pipes Canyon for more than 10 years.  “This is a California scenic route. It’s beyond me that anyone would think about tampering with our desert.”

“We live two miles from the buttes,” said Max Thomas, a yoga teacher who’s lived in the high desert for 12 years and is off the grid. “To think that we would have to look at 400 foot towers on those beautiful mesas makes me sick. I’ll fight to the death to stop it.”