Speak Up For An Energy Policy That Preserves Pristine Desert

The Federal government is currently reviewing a broad policy shift that could encourage solar energy development on thousands of square miles of pristine public land in America's deserts, according to its Draft Programmatic Environmental Impact Statement (Draft EIS).  Unfortunately, the new policy fails to consider a much better alternative, which is to encourage solar energy development on rooftops and on already-disturbed lands.  After a summary of the policy's potential impacts, you can read below to learn how to submit public comments on the policy as a concerned citizen, and urge a smarter approach.

Summary of the Policy:
The Departments of Interior and Energy are jointly reviewing three alternative policies for permitting solar energy on public land.   Each alternative makes a different amount of public land available to energy companies, but the government estimates that companies will use 214,000 acres (334 square miles) within 20 years.

• The "No Action Alternative" would basically maintain the status quo and allow energy companies to apply for use of any of our public lands.  This is not ideal since over the past two years the Federal government has granted approval to several solar projects on prime habitat for imperiled wildlife, even though there are less destructive places to build solar facilities.  

• The "Solar Development Program Alternative" would allow energy companies to apply for use of over 21,581,154 acres (33,720 square miles) of land in America's southwest.  This is the government's "preferred alternative."  Although this is less than the total amount of public land available under the status quo, it would still give energy companies access to sites that are important to the ecological health of the Mojave and Sonoran Deserts.  It prioritizes the wishes of energy companies over long-term land stewardship.

• The "Solar Energy Zone Alternative" would designate 677,384 acres (1,058 square miles) of public land as special zones for solar energy companies.  California would bear most of the cost, with over 339,000 acres of solar energy zones (SEZ) that would severely fragment the State's desert ecosystems.  The "Riverside East SEZ" would destroy a stretch of mixed creosote scrub, dune, and ironwood wash habitat stretching from Joshua Tree National Park all the way to California's border with Arizona, and another SEZ in the Mojave would wipe out one of the last remaining pockets of a rare wildflower.

What is Missing?
I know what you're thinking.  The Solar Energy Zone Alternative is what you'd vote for because 1,058 square miles is less than 33,000 square miles.  But this policy is missing an option that creates incentives for solar energy companies to put solar panels on rooftops, over parking lots, or on already-disturbed land.  As I mentioned earlier this month, the EPA's "RE-Powering America's Land" program has identified millions of acres of already-disturbed land that are ripe for solar energy development.  Why does the Draft EIS ignore the EPA's program and not present incentives for development on these already-disturbed lands?

A desert tortoise foraging on one of the proposed Solar Energy Zones in the Mojave Desert.  Photo from CEC EIS document.

The Draft EIS takes a narrow approach to solar energy policy at a time when we should be thinking outside the box.  The Department of Interior should accept that our pristine deserts are not an ideal place to build solar energy facilities, and should instead evaluate a fourth alternative that provides incentives for solar on already-disturbed land and on rooftops.  Even the projected development of 334 square miles could decimate our desert ecosystems, especially in California where the bulk of this industrialization is expected to occur.

A single solar project site can have impacts that reverberate throughout the desert.  For example, the approved Ivanpah Solar Energy Generating System will destroy over 5 square miles of habitat in the northeastern Mojave Desert.  Since the beginning of construction last fall, over 50 desert tortoises have been displaced or killed on the site.  This endangered species is in decline throughout its range and biologists are trying to defend it from the threats of urbanization, disease, invasive species and illegal off-highway vehicle use.   Solar energy development could push the desert tortoise closer to extinction as projects like Ivanpah destroy some of its best habitat and fragment its population, halting genetic linkages that are crucial to the overall health of the species.

Speak Up:
The government is currently accepting public comments on this plan.  Your comments can encourage the government to take a smarter approach to renewable energy development.   Submit comments at the Draft EIS website at this link by March 17th.  

Feel free to use some of the following talking points in your comments:

• We need to increase generation of renewable energy in order to limit harmful greenhouse gas emissions.  However, the Draft Programmatic EIS focuses on an unnecessarily destructive method of achieving this goal by sacrificing treasured public lands. 

• The Draft Programmatic EIS should include a fourth alternative that encourages distributed generation (commonly referred to as "rooftop solar") or development on already-disturbed lands.

• The Departments of Interior and Energy should work with the Environmental Protection Agency (EPA) to institute incentives for energy companies that build on lands identified in EPA's "RE-Powering America's Land Program," or on other lands that have been previously disturbed for agriculture or industry.

• The Draft EIS does not adequately assess the environmental impacts of industrial development in either of the three proposed alternatives, nor does it assess the impacts of transmission line upgrades that will be required by the projects.  In addition to the lack of a disturbed lands and distributed generation alternative, an inadequate understanding of the cumulative impacts of such widespread energy development in America's southwest will hinder the government's ability to identify which policy represents an ideal way forward for renewable energy.

• The "Solar Energy Development" program should not be the "preferred alternative," since it closely resembles the status quo, whereby energy companies are applying to use sites that are inappropriate for industrial development.  This program will still result in a lengthy and expensive environmental review process for energy companies, and it will severely fragment America's desert ecosystems.
  

• The "Solar Energy Zones" identified in the Draft Programmatic EIS would concentrate development on pristine desert habitat of importance to imperiled plant and wildlife. The Riverside East, Pisgah, and Iron Mountain Zones in California will have significant cumulative impacts on the threatened Mojave fringe-toed lizard and desert tortoise.  The Imperial Zone has already been determined to contain hundreds of sites of cultural significance to Native American tribes, and prime habitat for the threatened flat-tailed horned lizard.  

• Hundreds of square miles of industrial development in these zones will lead to cumulative ecological damage that the proposed mitigation measures will not be able to reverse.

Is this the future of our desert ecosystems?

Or can we preserve our deserts for future generations, and build solar energy on already-disturbed lands and rooftops?