Silver State South Solar Nears Approval; Problems Loom

Tbe Bureau of Land Management (BLM) in September released the final environmental impact statement (EIS) for the Silver State South solar project, which would destroy approximately 3.7 square miles of intact desert habitat. Although the direct impact on wildlife may not compare to BrightSource Energy’s Ivanpah Solar project, the Silver State South project almost certainly will have significant long-term effects on the ability of the desert tortoise to maintain habitat connectivity.



The BLM’s preferred alternative supports the solar project, and secondarily designates an Area of Critical Environmental Concern (ACEC) to protect the desert tortoise habitat that First Solar does not want to destroy.  The ACEC is a welcomed sweetener, but still does not override the bitterness that arises from the fact that destruction of habitat for the solar project is completely unnecessary since the solar panels would be just as happy on already-disturbed lands somewhere else in the state.  Tortoises, on the other hand, are unlikely to survive after they are evicted from their burrows.   There is no need for First Solar to push this species to the brink when alternative locations are available.

A stand of yucca on the site of First Solar's proposed Silver State South project site, just east of Primm, Nevada.

To add insult to injury, Southern California Edison - the utility company that is purchasing energy from the Silver State South project – is asking California regulators for permission to make corrections to its contract for the energy that will add over $60 million in costs to ratepayers. The additional costs result in part from a brand new substation; SCE previously told the California Public Utilities Commission (CPUC) a new substation was not necessary.   It took SCE nearly two years to notify CPUC about the corrections; the delay probably benefited SCE and First Solar because the incorrect information initially submitted to regulators made the cost of the project seem more competitive and reasonable.  CPUC will consider SCE’s request at the end of October.

Narrowing the Corridor

The project is poorly sited because it will impede a habitat connectivity corridor for the imperiled desert tortoise, potentially restricting gene flow for the species and challenging its resilience in the face of climate change, and ability to recover from a stark population decline over the past half century.  The U.S. Fish and Wildlife Service in December requested that the BLM not approve the project, or at a minimum reduce the project’s footprint. The BLM and First Solar reduced the footprint from the project analyzed in last year’s draft EIS, but only because First Solar initially proposed a 350 megawatt (MW) project.   First Solar only had commitments to sell 250 MW, so the footprint reduction is not a compromise by First Solar, but a right sizing of its inflated plans.

A map included in the Final EIS shows how the width of the desert tortoise corridor (in green) will be impacted if the Silver State South project (blue outline) is built.  The primary connectivity corridor would be reduced significantly, leaving a 1.39 mile corridor at the narrowest point.

First Solar’s project will narrow the habitat corridor down to 1.39 miles across at the narrowest point, reducing the width of the habitat corridor by a mile. The EIS estimates that as many as 115 tortoises will be displaced or killed by the project.  Over the long term, the species will have more difficulty maintaining genetic connectivity through the Ivanpah Valley, which leads to a narrow and also unprotected connectivity corridor across the McCullough Range to the El Dorado Valley.  Other connectivity has already been eliminated by Las Vegas’ urban sprawl.

The map above depicts the home ranges of tortoises known to inhabit the area.  Orange and yellow polygons are the ranges of tortoises that will be displaced or severely impacted by construction of the project.  Other tortoises may be impacted that were not detected during surveys.

Competing Uses

The tortoise connectivity corridor is already under threat from other competing uses of the public lands – Las Vegas plans to build another airport on the dry lake bed near Primm known as the Southern Nevada Supplemental Airport.  Although the dry lake bed itself does not provide suitable habitat for the tortoise, the airport may need to build roads and other associated facilities on desert lands that do serve as suitable habitat.  The airport's development and construction has been delayed by the economic downturn and construction of a new terminal at McCarran airport, but the city almost certainly will return to these plans when McCarran begins to reach capacity limits.

Furthermore, the area hosts many off-highway vehicle (OHV) events on designated routes through the desert and around the Lucy Gray Mountains east of Primm.  The Final EIS notes that as many as 22,000 people attend some of the events.  The EIS, however, fails to clearly articulate how the integrity of the tortoise corridor will be preserved while also allowing for the solar project, airport, and OHV events.

The map above depicts off-highway vehicle routes in the vicinity of the Silver State South solar project.  The blue and purple line represents a route used by high speed and competitive events that draw thousands of spectators.  Although the solar project is not depicted in this map, it will interrupt that route, and no alternative route has been proposed. Establishment of the ACEC will complicate identification of alternative routes.

Some of the OHV routes will be blocked by the Silver State South project, according to the EIS, although it is not clear if alternative routes will be permitted after designation of an ACEC.   New routes could result in further destruction of desert tortoise habitat; if BLM plans to permit alternative routes they should have been analyzed in the Final EIS as a connected action.

Area of Critical Environmental Concern (ACEC)

BLM responded to requests from the public and agencies to extend the ACEC to cover areas of the desert not used by the solar project, although the FEIS does not analyze a conservation alternative – where the project is denied but BLM evaluates conservation actions such as a more robust ACEC designation.

Nonetheless, if the BLM selects its preferred alternative, over 31,000 acres of desert habitat will be protected under the ACEC.   Basin and Range Watch originally proposed the ACEC in 2012 as an alternative to the solar project because of the overarching importance of this desert habitat.

Considering just how important this swath of desert is to the long term viability of an entire species, you would think the ACEC outline would cover as much of the suitable habitat as possible.  The ACEC outlined in the first map at the top of this blog post shows a lot of habitat remains unprotected by the designation.  The BLM may consider adding lands to the ACEC designation during its review of the Las Vegas Resource Management Plan.

Increasing Transmission Costs

SCE in Ma filed an amendment with CPUC correcting the original power purchase agreement (PPA) that was filed in 2011, and informing CPUC that the amendment will result in incremental costs of over $60 million.  The transmission upgrades required to accommodate the project on the grid include a new substation (two other substations exist nearby, but apparently Silver State South needs its own), and upgrades at other major substations in the El Dorado Valley, Hesperia, and Kramer Junction.

When SCE first filed the PPA in 2011 they stated the project would connect to the grid at the Ivanpah Substation, which was already approved and paid for to accommodate the Ivanpah Solar project.  It is not clear how SCE mixed up its substations, but they apparently knew the correct substation when they filed a separate regulatory application with the Federal Energy Regulatory Commission (FERC) in October 2011.  However, SCE never bothered to correct its PPA filing with CPUC until after they approved the contract.  Although the retail rate of the electricity from the project is not affected, ratepayers will pay for the upgrades through the “transmission access charge,” and the error suggests the PPA may not have been properly compared to other projects when SCE was initially selecting projects for contracts.

You can find the Final EIS on the BLM website for the Silver State South Solar project, although these documents are not readily available during the government shutdown imposed by Congress.

The following document was included in the draft EIS published in 2012, and lists all species that are likely to be impacted by the Silver State South solar project.