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Clearing Up the Record on Solar Energy on Public Lands

Johanna Wald
February 14, 2012  |  16 Comments

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This week, Los Angeles Times published the first article of a long-awaited series about the impacts of large scale-solar projects on the Mojave Desert. Unfortunately, the first story failed to provide a fully accurate picture of the reality and efforts underway to ensure we have a robust and successful national solar program.

As I have discussed in my blogs, I’ve spent my entire career – almost 40 years – protecting America’s public lands. My mission at NRDC was straightforward: to preserve our forests and rangelands, wilderness areas, wetlands, free-flowing rivers and beaches from destructive activities such as coal mining, oil and gas drilling, road construction and other commercial development. But our changing climate is changing everything, including our conservation goals. We are faced with hard choices. Those choices entail trade-offs, but I have confidence we’re going to be able to strike the right balance.

About three years ago, I learned two things: The first one was that climate change was already having real impacts on the lands and resources that I have been working for so long to protect, and the second was that that there were more than 100 pending applications for renewable energy projects, both wind and solar, in areas of California that I had devoted a lot of time and effort to protecting.

And I had an epiphany – I realized that everything that I had worked for in my career was threatened directly by climate change or by unmanaged renewable energy development. So I switched not only the focus of my work but how I did it in order to facilitate environmentally responsible renewable energy development.

I did it not through litigating but through consensus building efforts, involving conservation groups, utilities and solar energy companies, federal and state regulators and many other stakeholders. And when I saw through those efforts what good could result, I embarked on an exciting and yet challenging undertaking to help develop a robust national solar energy program that would provide a balanced approach to protecting important landscapes and wildlife while helping the solar industry to succeed.

In 2009, the Bureau of Land Management saw a 78 percent increase in applications for solar energy projects on public lands, from 107 to 223 that were pending review, and only 2 projects had progressed to the stage of environmental reviews. Funding made available during this time through the American Recovery and Reinvestment Act helped “fast-track” the permitting of nine large-scale solar projects for development on public lands, including BrightSource’s Ivanpah project.

But despite the Los Angeles Times’ suggestion, NRDC was never involved in moving that project forward.  Rather, our only engagement was to submit detailed comments to the BLM and to the Interior Department in the public review process before the agencies made their final decision on permitting it. (See full comments here).

It is true that many of the first projects that came out of the gate, Ivanpah included, raised serious concerns about the immediate and long-term environmental impacts on public lands, wildlife and other natural resources.  Here are some reasons why this happened:

  • In the absence of any policy or guidance from the BLM as to what were appropriate sites for solar development, companies got a free hand in selecting the sites they wanted to develop on public lands
  • The selection process for these sites unfortunately didn’t incorporate environmental and cultural heritage considerations – something that Interior, BLM, environmental and conservation groups and many other stakeholders have been working to ensure are an underlying aspect of the siting process going forward
  • BLM had no history of dealing with this new type of energy resource, which is very different than oil and gas. On the contrary, the agency had little expertise in permitting these types of projects
  • Insufficient and inconsistent environmental reviews at the front end of the planning process and major investments by solar developers made it difficult to ”fix”  these projects and in many cases resulted in costly modifications to lessen some of their impacts

The Los Angeles Times comparison of solar to oil and gas development on public lands is also misreported as is the important progress by Interior and BLM in prioritizing environmentally responsible development on public lands. In fact, my colleague Jessica Goad from the Center of American Progress has detailed in a blog some of the key facts that the article overlooked. Here’s a summary from her excellent post:

  • The 21 million acres is the amount of public land that could be made available to solar energy development in six western states – AZ, CA, CO, NV UT, NM – rather than the amount that will be eventually leased. These preselected lands have the fewest environmental conflicts and high solar potential
  • Of the 21 million acres of land that BLM proposed to make available for solar projects, Interior announced in October 2011, in response to more than 100,000 public comments, that it would give incentives and preference to projects sited within 285,000 acres of ‘solar energy zones’ 
  • All in all, 7 solar projects were given the green light on public lands in California as of the end of 2011, totaling approximately 28,000 acres. And an Interior Department analysis suggests that the most solar that would likely be developed on BLM land in six western states over the next 20 years is 214,000 acres
  • In a report released in May 2011, the Interior stated that, “currently, 38.2 million acres of public lands are under lease for oil and gas devel­opment, of which 16.6 million acres are ac­tive and 21.6 million acres are inactive”
  • According to a Wilderness Society analysis, over 50 million acres of public lands are already available to oil and gas in five states – CO, NM, MT, UT, WY

While some have called for a complete ban on large scale solar projects on public lands in favor of  deployment of much smaller power generation options such as rooftop solar,  the reality is that small-scale generation, by itself, even with an aggressive target, is not sufficient.

NRDC’s detailed analyses of this issue have revealed that along with greatly increased energy efficiency, energy conservation and roof-tops and other important measures, we need large scale projects to meet our climate goals. Even though we need large scale projects, however, we still must make every effort to ensure that these projects are built on appropriate places. Simply put, we need a broad portfolio of solar power projects – big and small, urban and rural, and on appropriate private and public lands – to meet our current climate goals.

Designing a solar program that balances the nation’s need for increasing solar production from public lands and the need to protect the publicly owned resources of those lands is a tall order. We believe that a ‘solar energy zones’ approach – which the Interior Department recently endorsed – is the right way to go.

Interior’s solar zones based approach would guide solar projects to the appropriate places – areas with high solar potential – helping minimize impacts to wildlife and sensitive lands while reducing risk and uncertainty for investors. A solar program like the one Interior has proposed is a major step toward achieving the right balance, and we look forward to continue working with Interior and the BLM, conservation groups, the solar industry and utilities to develop a strong and comprehensive final program.

The planet is changing and we must change with it. The traditional conventions –including some traditional conventions of the environmental community – must yield to the new realities. Our greatest challenge today is to make the hard choices that will provide the greatest environmental benefit for all and result in the fewest impacts to wildlife and wild lands.

This post was originally published on the Natural Resources Defense Council's website and was reprinted with permission.

The information and views expressed in this blog post are solely those of the author and not necessarily those of RenewableEnergyWorld.com or the companies that advertise on this Web site and other publications. This blog was posted directly by the author and was not reviewed for accuracy, spelling or grammar.

16 Comments

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Jeff Kelly
Jeff Kelly
February 16, 2012
Thanks for some balance, Johanna. Millions of acres of the California desert are already permanently protected as wilderness areas. The rooftop solar boosters are well intentioned but lack a serious knowledge of national energy demand and production and what a gigawatt is, and what it will take for renewable energy to make a difference. The opposition to large-scale solar is driven as much by social belief (everything big is bad) than true environmental concerns. While the environmentalists fight over renewable energy, fracking and mountaintop removal just keep chugging forward, laughing at us.
Penny Melko
Penny Melko
February 16, 2012
Well, my dear Johanna, with the prevailing attitude by your group, Sierra Club and ABC birds, it is more humane to send hunters out to shoot the raptors and use their feathers and parts for crafts and use their meat to make dog food or cat food It's altogether legitimate to seriously consider this option. The birds die a terrible death, having their beaks, heads, wings and feet chopped off before they finally die. It's got to be better than letting chicks die of starvation or being eaten by small game in their nests. I'm thinking to do it seasonally, before breeding season. I wonder where and when California condors breed and set up camps. How about giving prizes for the most clean kills each day?

I live just below the LADWP wind area where the 2 Golden eagle carcasses were found. They are probably the same pair I see flying through Sand Canyon where I live and that are seen by the folks at Tomo-Khani state park. If it's OK for corporations to kill them, I think I'll help myself to the next ones I see! And the fine is what??? What's good for the goose is good for the gander.
Ceal Smith
Ceal Smith
February 16, 2012
Also see my response to Johanna Wald:

Ground-truth: Do We Need to Destroy Our Deserts To Fight Climate Change?

http://www.renewableenergyworld.com/rea/blog/post/2012/02/ground-truthing-do-we-need-industrial-solar-to-fight-climate-change
Penny Melko
Penny Melko
February 16, 2012
Hi GeraldR. In the grand picture, no one gave a thought about creating compulsory rerouting of all planes around the existing turbines. I don't know where you live, but if it's in SoCal, take the 14 fwy north. At about where the CA aqueduct crosses south of S Street, below Palmdale, the lights are absolutely visible from there after dark.

Yes, lots of things kill birds like WalMart's parking lot lights in southern Utah, buildings, disputably cats, but only turbines kill the endangered California condors, Bald eagles and Golden eagles. You are probably aware that lead bullets are banned for their part in poisoning them.

Those of us who live in eastern Kern that are fighting more carnage actually respect the planet and were hoping there would be a push for sustainability. It would create jobs for everyone in the U.S. for the next 100 years - cleaning up the negligence of the past. Instead, aweful things are happening like reopening drilling in the Arctic and and Gulf, fracking, attempting to open up uranium mining in the Grand Canyon, a coal mine near Bryce National Park. It won't end until the People make it end. This mean you and me and and army of people demanding without compromise that we move toward true sustainability. There are ample opportunities, from recycling and reusing post consumer and post commercial products and make new to developing smart homes and cooking and temperature control techniques for homes and everything else man uses that cut energy use to as little as possible.

Instead the giant corporations have everyone convinced that we must continue to drill, mine and kill everything that gets in our way. I say enough.
Gerry Wootton
Gerry Wootton
February 16, 2012
@sandcanyongal - the German stuff you're pointing at amounts to 0.31 $/Wp for the tracker (obviously not rooftop), 0.215 $/Wp for the inverter and ~1.36 $/Wp(AC) for the modules which works out to 1.88 $/Wp(AC) without a base, installation, cables, connectors, conduit, safety devices, meter, hardware, approvals, lawyers, etc. This isn't cheap when all is said and done -- with luck this could be a $4.50 / Wp installation. In any case, $/Wp is a dumb metric, what really matters is LCOE (kWh not W).

Typically, doing this type of installation requires (expensive) legal representation in order to obtain a zoning variance. If you go rooftop, then you need a professional engineering study.

The utility scale projects you speak of have to do a mountain of paperwork and environmental studies that take years and generally end up in the courts at some point. The cost of permitting a project like that is more than $1/Wp all by itself.

We can all cry for the turtles except that nobody crys when they are run over by the 40 or 50 heavy trucks a day carrying fracking fluid to a gas well. We can also cry for golden eagles impacted by a windfarm but nobody crys for the much larger number simply shot for fun or profit or poisoned by improperly treated dead stock. And has previously been talked to death, the familly cat is the single biggest slayer of small birds.

You make it seem like compulsory regulations for aviation warning lights is somehow the wind farm operators fault when they are just doing what they are legally required to do. If you want it different get the aviation rules changed - after all there is no reason in the modern era to fly by VFR.
Ceal Smith
Ceal Smith
February 16, 2012
This explains a lot, especially in light of the close (very close) ties between Gang Green and the Large-solar industry Association:

"The ties between Gang Green and big corporations seems to be growing, not diminishing. The U.S. Climate Action Partnership, for instance, teams Big Green groups like the Nature Conservancy, Environmental Defense Fund and Natural Resources Defense Council with the likes of Dow Chemical, Duke Energy, Shell, the notorious mining firm Rio Tinto and many other mega-corporations. Perhaps the exposé on the Sierra Club will lead to a cleanup, but for now, the gangrene in Gang Green is Big Green corporate donations"

Gang Green's gangrene
Why should big enviro groups take corporate cash?
by George Ochenski

http://missoulanews.bigskypress.com/missoula/gang-greens-gangrene/Content?oid=1536243
Penny Melko
Penny Melko
February 16, 2012
This is my last post so please bear with it. NRDC, you sold out too. I suggest each of you sit your loved ones in a comfortable place and read the following article out loud to them. To get to the article place a dot where I replaced the like with the word, dot. It is the story and dialog about Charles Keeling - the Keeling curve. http://wwwdotnytimesdotcom/2010/12/22/science/earth/22carbon.html

Take the advise. Go to the forests and wild places because, with the mentality described in this article, it will be gone in our lifetimes. I'm amazed that such an intelligent person has sold out our lives. Shame on you and how dare you do this, in your position.

If you looked a bit further you would see that Kern County opened 275 sq miles for housing and business development. Duh. Could the wind and solar be leveraged for this purpose, just maybe?...yes.
Penny Melko
Penny Melko
February 16, 2012
Anonymous, right on. I've been through a few environmental impact reports. The word mitigation mean pushing everything that is in the way of development aside. The local cement batch plants are approved that will drain riperian wetlands 9 feet! The impact of that single mitigation is monumental to the wildlife and fauna.

Everyone touts jobs as the single most important reason to develop industrial complexes. Yet, no one questions about what happened to all of jobs that have magically evaporated because they're outsourced and moved to other countries. Manufacturing is gone in the U.S. Along with the physical manufacturing also goes the design and manufacutring engineering positions, front officepositions, payroll, ar, ap, gl and the professional high paying positions in research and development, shop floor, distribution and let's not forget the patents and secrets. Focus should be on forcing these jobs to come back to the U.S., not create bad jobs because there is nothing else. The American People have been demoted to being merely the wallets for the rich, digging into our life savingss, 401Ks, home equity just to survive. Guys it's over. We know your game.
Penny Melko
Penny Melko
February 16, 2012
I'm completely disgusted that anyone would support one more day of industrial wind and solar development. I hear the thumping pressure and sound of the ill conceived turbines from up to 4 miles away coming from south of the 58 freeway. How does anyone justify putting red beacons by the hundreds on ridges so under cloud cover it looks like fires burning out of control? This society has been duped into believing that feeding technologies to the tune of 30% of the total cost of those projects will have a real effect on global warming. Never mind that the federally protected Mojave Desert tortoises are killed, just like the California condors. Those animals are not renewable When they're gone, they're gone forever. Folks, it's another out of control bubble, orchestrated by the media, getting millions in air time. They're nothing but cheap 'tricks.'
John Carr
John Carr
February 15, 2012
We may be focusing on the wrong public lands.

There are 128 million acres of right-of-way in this country.
It is already disturbed.
Normally, there are utility easements along the ROW including distribution and transmission lines.
PV installations lining a roadway are easier to access.
The land is already set aside.
Much of this ROW is Federal Interstate System land.
Use the energy for transportation.
It's being generated close to the point of consumption.
Why ruin our precious wild treasures?
We don't need to.

What we really need is a little more imagination.
ANONYMOUS
February 15, 2012
"The reality is that nothing we do does not leave a mark, it's rather a question of how much of a mark. A lot of the land in the southwest is quite fragile and I am amazed at how thoroughly it has been torn up by idiots on bikes and ATVs and in SUVs and trucks. One of my faves is a picture of a would be naturalist who, by the way is a strong opponent of utility scale solar, wearing heavy hiking boots at the end of their tracks clearly marked by the destruction of the microflora (and here's me in my SUV on a save-the-turtles mission)."

Amazing amount of stupidity out there. You are trying to say a hiking boot will have just as much of an impact as a 6 square mile solar farm.

As far as the OHV activity, it is very obvious that you have not visited one of the solar or wind sites. The average amount of disturbance from OHV's on the averavge solar site proosal is about one percent or less. About 5 percent in the worst case scenario. This is an uneducated comment, Gerald...
ANONYMOUS
February 15, 2012
Many thanks to Julie Cart for writing the LA Times article. There will be more articles like this.

NRDC is supporting the wholesale removal of 285,000 acres of wild public land for the Solar PEIS. They even wanted more than that, but the BLM cut acreage off because of environmental problems. So in effect, the BLM is a much more "environmental" organization/agency than NRDC. It really is a shame that big business infected the environmental community to the point where they are spinning the removal of 300,000 acres of wildlands as "environmental". The East Riverside Solar Study Zone would remove 150,000 acres of Colorado Desert Habitat, habitat for desert tortoises, bighorn sheep, Mojave fringe-toed lizards, burrowing owls and kit foxes not to mention dozens of rare plants and cultural sites.

You also forgot to mention that Robert F Kennedy is on the board of directors of NRDC and he is heavily invested in BrightSource Energy. Is that why you didn't oppose Ivanpah/BrightSource? Saying nothing is almost as bad as supporting it and you are aware of how many desert tortoises will be killed and displaced by Ivanpah. You also pulled the same thing for the Desert Sunlight Project. The applicant, First Solar is in violation of air quality standards and their water use has already made local well water levels go down. They are only one tenth completed with that project.

Go to the Ivanpah Project. About 200 fossil fuel burning cars commute to and from work. The plant will burn natural gas as backup. The heavy Earth moving vehicles do not run on vegetable oil. This is a C02 bomb. Why didn't NRDC think of that?

Carl Zichilla of NRDC always states that distributed generation will be too expensive. But Germany has installed 3,000 MW od DG just in December. In contrast, not one of the utility scale boondoggles on desert habitat is on line yet.
Gerry Wootton
Gerry Wootton
February 15, 2012
Ahh ... some balance. The reality is that nothing we do does not leave a mark, it's rather a question of how much of a mark. A lot of the land in the southwest is quite fragile and I am amazed at how thoroughly it has been torn up by idiots on bikes and ATVs and in SUVs and trucks. One of my faves is a picture of a would be naturalist who, by the way is a strong opponent of utility scale solar, wearing heavy hiking boots at the end of their tracks clearly marked by the destruction of the microflora (and here's me in my SUV on a save-the-turtles mission). When this lightweight traffic can leave a semi permanent mark, consider what damage the heavy equipment needed for oil and gas development does. And then consider the hit rate: only a fraction of all this activity actually produces any useful energy. Then, unconventional oil and gas production generally means a steady stream of heavy trucks for the next 25 years. Solar on the other hand is relatively light weight and requires no heavy logistics in operation, nor does it leave behind a residue of contamination. And there's worse things: 499 mountains - gone; 1400 streams - gone; 2200 square miles of forest - gone; double that by 2020. First there was a mountain then there was no mountain then there is 'a level plateau or a gently rolling contour with no highwalls remaining' (apologies to Donovan). Hey Fish and Wildlife Service - some one stole all the fish ... heck they stole the whole damn river.

From a personal perspective, my cottage is on a lake that has been acidified by smoke stacks nearly 100 miles away which greatly degraded the fishing. It's now at a level where if you have any cuts or scratches you can feel it when you swim. I guess someone decided my environment could be someone else's toilet.
ANONYMOUS
February 15, 2012
What the LATimes Article misses, and ignored by Johanna's response, is that the Obama administration is opening up oil, gas and coal leases, AND destroying desert ecosystems. How many ppm are we going to cut with this all of the above strategy?

The acreage of deserts jeopardized by solar is just an estimate for the southwestern deserts, and it does not include wind energy applications, which would destroy or fragment even more land. Each utility-scale project requires plenty of steel, concrete, and daily trips for the workers. Has this been factored into the overall net benefit of carbon reductions?

As for NRDC, if the NRDC found problems with BrightSource's ISEGS project, what is the NRDC doing about the other projects proposed for biologically important areas of the desert?
Bruce Michael
Bruce Michael
February 15, 2012
Thank you for the thoughtful and informative article. I am delighted that NRDC is recognizing the danger of climate change and realizing that in order to address the problem we will need large scale projects like those proposed. That attitude is needed for large scale wind projects throughout the country as well, both on-shore and off-shore.
bruce gladstone
bruce gladstone
February 15, 2012
I support the approach taken by the NRDC. By cooperating in a constructive intelligent way with the players in energy, the NRDC and others can effect an outcome that strikes a balance between global CO2 reduction and specific park preservation. The argument that we should "just use our roofs" ignores the economic, technological, and political realities. If you want to be an idealist or revolutionary, go ahead. But I prefer results. I don't believe a transmission line is the end of the park.

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Johanna Wald

Johanna Wald

I grew up in the East, and was never any further West than Ithaca, NY, until my second year in law school. That summer I made my first trip West and fell in love with its wilderness areas, stunning landscapes and wonderful wildlife. Two...
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