First Solar's Silver State South: Wrong from the Start

The Bureau of Land Management (BLM) this month issued a supplemental draft environmental impact statement supporting First Solar's proposed Silver State South solar facility, which would be built on a narrow strip of desert that has also been recognized as a critical desert tortoise connectivity corridor.  BLM intends to approve a modified layout of the solar project that would destroy up to 4.8 square miles of mostly intact desert wildlands between the small gambling outpost of Primm, Nevada and the Lucy Gray Mountains.  The project layout preferred by the BLM appears to ignore a recommendations by the US Fish and Wildlife (USFWS), and Washington is rushing to approve the project before further wildlife connectivity studies are completed.

Project Benefits from Washington's Duplicitous Ivanpah Policy
The Ivanpah Valley has been subject to contradictory Federal actions and decisions that suggest Washington's land stewardship goals in this corner of the northeastern Mojave Desert are incompatible with the energy industry's callous siting decisions and the Obama administrations propensity to cater to corporate wishes on public lands.

• Interior approved BrightSource Energy's Ivanpah Solar and First Solar's smaller Silver State North projects by 2010, despite characterization of the area by the Nature Conservancy as ecologically important to the health of the Mojave Desert ecosystem, and concerns by the US Fish and Wildlife Service that desert tortoise habitat connectivity should not be disrupted by the massive projects.

• In early 2011 construction of BrightSource's Ivanpah project was temporarily halted after officials realized the project's impact on desert tortoises would far exceed the initial estimate of 34 animals.  As of August 2012, the project has displaced over 340 desert tortoises from the 5.6 square mile construction area (more tortoises have been handled outside of the construction area), according to a review of compliance documents submitted to the California Energy Commission.  This number is a testament to the high quality habitat in Ivanpah.

• The US Fish and Wildlife Service recommended in June 2011 that the BLM prohibit large-scale industrial development in remaining portions of the Ivanpah Valley to maintain habitat connectivity, according to a revised biological opinion. 

• The final Solar Energy Development Program implemented by Interior this month designates the Ivanpah Valley as an exclusion zone where future solar energy projects would be prohibited because of the ecological importance of the habitat, but the policy includes a loophole that allows earlier project proposals to move forward in the exclusion zone.

Interior Guts ACEC Proposal
Continuing with it's two-faced approach, the Department of Interior is rushing to approve the Silver State South project, even though it will directly conflict with the intent of the Solar Development Program exclusion zones, the desert tortoise recovery plan, and USFWS tortoise connectivity guidelines.  The draft environmental review acknowledges the importance of this area, even though much of it will be destroyed by the project:

"The area that lies between the Silver State North Project and the Lucy Gray Mountains is the most viable linkage between the northern and southern portions of the Ivanpah Valley. It is thought that severing this corridor would effectively isolate the northern portion of the valley from the southern by forcing tortoises to move through passes to the east side of the Lucy Gray Mountains (USFWS 2011)." -- draft environmental impact statement for Silver State South

BLM's compromise is to partially approve a nomination by Basin and Range Watch to designate the Ivanpah Valley as an Area of Critical Environmental Concern (ACEC), explaining that its support fo the ACEC is based on 1.) the need to protect the desert tortoise connectivity corridor and 2.) the presence of rare desert plants.  However, BLM cut out some of the most important lands necessary to maintain tortoise connectivity on desert wildlands between Primm and the Lucy Gray Mountains in order to accommodate the solar project, arguably gutting the ACEC nomination of one of the key reasons for its implementation.  If the solar project is approved, the desert tortoise corridor could be reduced from approximately two miles down to less than two-thirds of a mile.  The USFWS estimates that tortoises need a corridor about 1.4 miles wide to maintain connectivity.

Mojave yucca and creosote bushes on desert wildlands between the gambling outpost of Primm, and the Lucy Gray Mountains (in the distance). Much of the desert pictured here would be destroyed for the Silver State South Solar project.

The map below shows the proposed layout of the Silver State South project, with the solar array depicted in white and gray blocks on what is currently intact desert habitat.  The faint orange outlined area to the east, south and north of the solar array is a modified outline for the ACEC nomination, which was changed substantially to accommodate the solar project on habitat that is most essential to tortoise connectivity.
Silver State South Solar

A study is underway to determine whether higher elevation terrain to the east of the Lucy Gray Mountains also offers a viable linkage, according to the draft environmental impact statement, but the study will not be completed until after the project is likely to be approved.

Conservation Groups Silent or Supportive
Despite the very poor choice of locations by First Solar, and Washington's decision to favor corporate development over proper land stewardship, the reaction from conservation groups thus far has been disappointing, since they have either looked the other way or signaled tacit support.  The Center for Biological Diversity, despite its historical leadership in protecting the desert tortoise, participated in a ceremony last year that celebrated the smaller first phase of the Silver State project, known as Silver State North, (bright green area in the map above), and has not opposed Interior's decision to fast track the larger Silver State South ahead of meaningful connectivity studies.  The local Sierra Club chapter in southern Nevada opposed any conservation measures that might stop the Silver State South project. 

The silence from these conservation groups is tantamount to complicity in what is a significant ecological disaster in the Mojave Desert, with over 12 square miles of wildlands on the chopping block, over 340 tortoises already killed or displaced, and a significant tortoise connectivity corridor in jeopardy.  While some conservation groups are arguing at the national level that solar and wind projects should be located on already-disturbed lands and rooftops, so far only smaller groups, such as Basin and Range Watch and Western Watersheds, have voiced opposition to ill-sited projects in the Ivanpah Valley.

Give Ivanpah a Break
The Bureau of Land Management should favor the No Action Alternative in this case.  Each of the project layouts presented in the draft environmental review would incur substantial and, more importantly, unnecessary harm. The project would impede the desert tortoise recovery, destroy habitat for rare desert plants, and deprive golden eagles and other raptors of foraging territory.  First Solar has  sited projects on already-disturbed lands in the past -- the company's Silver State South project is not worth the harm to our desert ecosystem, or the financial risk that it entails for the company.