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Smart Solar

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Colorado

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Utah

Focusing on Low-Conflict Zones to Promote the West’s Economy, Protect Wildlands, and Build a Clean Energy Future

Smart Solar

wilderness.org

Focusing on Low-Conflict Zones to Promote the West’s Economy, Protect Wildlands, and Build a Clean Energy Future

Smart Solar Solar energy is already playing an important and growing role in meeting our energy needs, kick-starting the economy and protecting our clean air and water with sustainable, Americanmade energy. With rooftop solar programs across the country, large-scale projects capable of powering hundreds of thousands of homes under construction in the west, and community-based systems of all sizes in between, the sunny days for the solar industry and our clean energy economy are just beginning.

To truly tap solar energy’s enormous potential, conservationists, sportsmen, elected officials, utility commissioners, energy companies and others are united in calling for forward thinking policies that will speed construction of environmentally responsible projects. Our western public lands in particular offer a valuable opportunity to build a sustainable solar energy program that will accelerate clean energy production while preserving the wildlife and wildlands we are proud to claim as our natural heritage.

For our public lands, that means building a program that guides projects to low-conflict zones – areas with great solar resources that do not contain critical wildlife habitat, wilderness quality lands or sensitive cultural resources. Many of the nation’s energy, environmental and economic experts are working hard to find a commonsense solution to the challenge of speeding development while minimizing impacts on the land. While early permitting efforts for solar energy development on public lands have been characterized by a scattershot, project-by-project approach, a consensus is emerging in support of a straight-

Nevada Solar One concentrating solar project using solar trough technology.

Photo Credit: Lynn D. Rosentrater; Creative Commons: Attribution required; Non-commercial use only; No derivative works allowed

forward concept to greatly improve the process of permitting projects: an effective solar energy program built around solar energy zones with high solar potential and few environmental conflicts can provide the solar industry the predictability it needs to get projects permitted and built in a timely manner, while safeguarding our wild lands, water and wildlife. On July 14, 2011, Interior Secretary Salazar announced the Department of the Interior’s commitment to create a “framework for developing large utility-scale solar energy projects on public lands, based on landscape-level planning and the best available science, designed to promote the development in “solar energy zones” in six western states.”

To learn more about the opportunities a guided-development approach might offer, The Wilderness Society produced a report in 2010 highlighting a number of the proposed solar energy zones: “In the Zone: Powering the Future and Protecting Wildlands with Guided Solar Development.” We are following up now with “Smart Solar – Focusing on Low-Conflict Zones to Promote the West’s Economy, Protect Wildlands, and Build a Clean Energy Future” to show why conservationists and solar industry representatives are working with the Department of the Interior to make this approach truly work – for both industry and the land.

As you’ll read in Smart Solar, an approach based on smart solar energy zones using the best available science is the surest path to a clean energy future that protects America’s public lands.

Focusing solar projects in low-conflict areas like the Brenda proposed Solar Energy Zone can lower construction costs and speed environmentally responsible development.

Photo Credit: Jon Belak, The Wilderness Society

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Smart Solar Kick-starting a Shift to Responsible Renewable Energy Development on Public Lands After a decade of government inattention and inactivity, the Obama administration and Secretary Ken Salazar’s Department of Interior (DOI) have prioritized responsible renewable energy development on public lands. Starting from scratch, DOI has taken important actions to build a solar energy program and complete the permitting for numerous new large-scale projects, the first ever on public lands. If we are to tap the true potential of solar energy development on our public lands, however, we must do more, and we must do better.

DOI’s Bureau of Land Management (BLM) is tasked with overseeing 250 million acres of public lands across the west, including lands with some of the best solar resources in the world. The BLM is currently building its program for solar energy development. There is growing support for building that program around specific geographic zones so that solar companies will know where to go (and where not to go) in order to move forward with development plans in the most expeditious manner. Such an approach will also allow utilities to plan for needed transmission lines and make real progress on harnessing clean energy from our public lands while minimizing impacts to the wildlife, water and wild places that depend on these same lands.

A successful program will also need clear, consistent guidelines that allow the agency to efficiently and responsibly review and process the many applications for the projects that will ultimately be built within these zones.

The BLM’s zone-based program for solar energy on public lands will provide decision makers, energy companies and the public the tools needed to achieve these goals. As Secretary Salazar said during his July 14, 2011 announcement on next steps for the solar energy program, the BLM will help shape a robust solar energy development program “that will outlast the Obama administration” and provide certainty for businesses that want to establish renewable energy projects on public lands.

A Framework for BLM’s Solar Energy Program – the Solar Programmatic Environmental Impact Statement A key component of the BLM’s solar energy program is the Solar Programmatic Environmental Impact Statement (PEIS), now being prepared by Argonne National Laboratory in coordination with DOI, the BLM and the U.S. Department of Energy. According to the BLM, the PEIS “assesses environmental, social, and economic impacts associated with the development and implementation of agency-specific programs that would facilitate environmentally responsible utility-scale solar energy development in six southwestern states [Arizona, California, Colorado, New Mexico, Nevada, and Utah.]” As part of this assessment the BLM has prioritized the identification of areas with high solar potential and minimal conflicts – proposed Solar Energy Zones (SEZs).

The BLM published the Draft PEIS in December 2010, and received over 80,000 public comments, highlighting the importance of this effort and the great interest in putting in place a sustainable solar energy program for our public lands. Conservation groups, solar companies, sportsmen, local communities, and many others reviewed the Draft PEIS and provided feedback to the BLM on everything from the boundaries of individual proposed SEZs to mitigation measures and best practices the agency should include as part of the solar energy program.

Many of the comments included a common, simple and compelling message: a successful solar energy program for our public lands must be built around a zone-based approach to development. As you will read in Smart Solar, the BLM has made a great start with the SEZs currently under consideration – while the agency has made it clear that it will potentially be making significant refinements to the proposed SEZs, the SEZs currently contain more than three times the amount of land than the BLM

“As a local resident, I can tell you that I want solar in my back yard, and I want it in the right places, like the Antonito Solar Energy Zone.” Olive Valdez of Southern Colorado’s San Luis Valley.

Factory worker at Amonix concentrating photovoltaic panel manufacturing plant in North Las Vegas.

Photo Credit: Amonix

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Focusing on Low-Conflict Zones to Promote the West’s Economy, Protect Wildlands, and Build a Clean Energy Future

predicts will be needed in the next 20 years. The agency is also pursuing numerous efforts to identify additional appropriate areas for development which will continue to build on this solid foundation.

Benefits of Focusing on Low-Conflict Solar Energy Zones What makes a zone-based approach to solar energy development on public lands so attractive to so many people? Years of experience evaluating potential development areas and proposed projects have shown that while large-scale solar projects offer huge potential for creating jobs, boosting our economy and cleaning up pollution, their size, diverse technology needs and the impacts of solar energy development on the land require a proactive approach to finding the most appropriate sites for development. This experience has also taught us that a project-by-project approach simply will not provide the predictability that developers, utilities, land managers, environmental groups and the public need to build a clean energy future at the pace and scale required. Without a comprehensive program that guides solar projects to low-conflict areas and addresses the technical and economic feasibility of applications, Americans risk wasting time and money permitting projects that may never get built. In addition, failing to focus on the most appropriate areas puts our natural heritage at risk, threatening key wildlife habitat, wildlands and cultural resources. In short, the future of solar energy development on public lands depends on putting a zone-based program in place.

Building a Foundation for a Lasting Solar Energy Program – Refining the Proposed Solar Energy Zones and Identifying Additional Zones DOI and the BLM appear to be listening to the chorus of support for such an approach, and are taking steps in the right direction. The Department announced in July 2011 that the BLM would be preparing a Supplement to the PEIS to address the recommendations and concerns it has received to date. Chief among the goals for the Supplement is setting in place a clear process for designating new SEZs going forward and performing additional analysis to further streamline permitting for future projects proposed in the SEZs. Based on our intensive research to date, we’re confident that with refinements, most of the proposed SEZs identified by BLM are good places to site solar projects. We and many other conservation groups and others have highlighted needed boundary adjustments and strategies to address potential impacts at the project level for the proposed SEZs, and pending those improvements have supported designation of all but a few of the

New Mexico Congressman Ben Ray Luján says, “I am encouraged that groups like The Wilderness Society and many others are working with the solar industry and the Obama administration to promote ‘smart zones’ where we can harness solar energy on our public lands with minimal impact to the surrounding environment.”

proposed SEZs. The BLM has made it clear that it will be refining the current proposed SEZs, potentially by removing entire SEZs as well as removing some portions of SEZs based on information the agency is gathering through public comment and its own research. These refinements are critical to ensure that the SEZs which are ultimately designated through the PEIS process are truly appropriate areas where solar projects can succeed.

Thankfully, there is flexibility to do so without constraining development, as the SEZs currently contain more than three times as much land as the BLM predicts will be needed in the next 20 years and the agency’s solar energy program will include a process for identifying new appropriate development areas.

The potential removal of some areas does underscore the importance of the ongoing and future efforts to identify appropriate new SEZs. For example, Arizona BLM’s “Restoration Design Energy Project” is identifying potential low-conflict wind and solar development areas across land ownership in the state. In southeastern California, the BLM is analyzing a “Renewable Energy Evaluation Area” in the West Chocolate Mountains which could lead to the establishment of new zones for development, and the BLM is working with other state and federal agencies on a “Desert Renewable Energy Conservation Plan” to identify both priority renewable energy development areas and potential habitat conservation areas critical for offsetting impacts and ensuring the long-term health of the California desert ecosystem. Along with the process for designating new SEZs which the Supplement to the PEIS will lay out, these efforts will ensure the solar energy program for our public lands has room to grow for decades to come. Finally, though the BLM has committed to focusing on the SEZs, we expect that the agency will also include some kind of variance process that would allow consideration of appropriate sites outside of zones if they meet a strict set of criteria that are designed to ensure that the exception does not become the rule.

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Smart Solar

Arizona

Smart Solar – A Guide to the BLM Proposed Solar Energy Zones Smart Solar provides a close-up of the 24 proposed SEZs across the six southwestern states included in the Draft PEIS. As previously noted, most of the proposed SEZs are good places for solar projects, but a few are inappropriate for designation and some require significant refinements. We have recommended needed improvements to the BLM, and the following pages detail those refinements, as well as the reasons why the SEZs should be the focus of the BLM’s solar energy program. Maps, pictures, and perspectives from a number of people engaged in solar development on public lands provide an armchair tour of the places most likely to support successful solar projects.

Desert tortoise in a burrow. Guiding solar projects to low-conflict areas can help avoid impacts to wildlife habitat and endangered species.

Photo Credit: Arizona Game and Fish Department

How does the Solar PEIS process work as part of BLM’s solar program?

The BLM is currently developing a Programmatic Environmental Impact Statement (PEIS) for solar development on public land. This PEIS will form the backbone of the agency’s solar energy program for the next 20+ years. Once complete, the PEIS will designate areas as open or closed for solar development, as well as designating priority Solar Energy Zones (SEZs), delineating a process for designating new SEZs going forward, and defining best practices for development, mitigation measures and other policies necessary for an effective and efficient solar energy program on public lands in the west. The PEIS process is a public one, ensuring numerous opportunities for public input. Here’s a timeline of the PEIS process: • Summer 2008: BLM initiates PEIS process • Summer 2009: BLM introduces 24 proposed SEZs • December 2010: BLM publishes the Draft PEIS, including analysis of the 24 proposed SEZs and 21 million acres of additional land that the agency is considering making available for development • July 2011: DOI commits to a zone-based program for solar energy on public lands and announces that BLM will be preparing a Supplement to the PEIS with more detailed analysis of the proposed SEZs and a proposed process for designating new SEZs • Fall 2011: scheduled publication of the Supplement with a 90-day public comment period • Summer/Fall 2012: scheduled completion of the process with publication of the Final PEIS and Record of Decision

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As described in more detail in the blue box to the left, the BLM will be finalizing the PEIS over the next year. The BLM’s work in the coming months to refine the proposed SEZs and put in place a comprehensive, zone-based solar energy program will determine whether our clean energy future succeeds or continues the conflicts and controversy that have characterized the free-for-all approach to energy development on public lands for decades.

It is critical that the agency move quickly and efficiently to complete the PEIS and get the solar energy program off the ground.

A continued reliance on a scattershot, case-by-case permitting approach will simply not provide us the structure needed to support solar development at the pace and scale America needs to transition to a clean and independent energy future.

Focusing on Low-Conflict Zones to Promote the West’s Economy, Protect Wildlands, and Build a Clean Energy Future

ARIZONA

The BLM has committed to a zone-based approach to solar development on public lands, and through extensive and ongoing research we and our conservation partners have conducted on the proposed SEZs over the past two years, we have grown ever more confident in our assessment that solar projects built there can generate enough electricity from the sun to power hundreds of thousands of homes and businesses across the West while minimizing environmental impacts. The Brenda and Gillespie zones and additional zones to be designated going forward will make an excellent foundation on which to build a solar energy program for public lands in Arizona.

Arizona Wildlife Federation President Tom Mackin says, “We recognize the importance of making American energy more secure. Future planning for solar must include a balance of meeting our energy goals coupled with the protection of critical wildlife habitat and access to public lands. We applaud the BLM for focusing solar development in suitable zones throughout the West because it will avoid conflict and delay, getting homegrown power online quickly.”

Smart Solar – Focusing on Low-Conflict Zones to Promote Arizona’s Economy, Protect Wildlands and Build a Clean Energy Future •

•

•

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Increase economic opportunities by generating tax revenue, creating green jobs during component manufacturing and project construction and operations, and developing a market for associated service industries; Help meet state renewable energy standard – Arizona has a requirement that 15% of the state’s electricity come from renewable energy sources by 2025; Protect sensitive lands and the wildlife they support by ensuring development only occurs in appropriate areas; and Provide clean power to reduce carbon emissions and help preserve and protect wildlands, wildlife, water supplies and communities across America and around the globe.

Avoiding Conflicts, Controversy and Costly Delays A key benefit of focusing on low-conflict SEZs for solar development is the opportunity to avoid sensitive wildlife habitat, wilderness quality lands and important cultural resources when selecting project sites. A project-by-project approach simply will not provide the predictability that developers, land managers, environmental groups and the public need to build a clean energy future at the pace and scale required. In addition, failing to focus on the most appropriate areas puts our natural heritage at risk, threatening key wildlife habitat and wildlands. For example, in Arizona, ecologically inappropriate and economically risky areas that could potentially be left open for development if the BLM does not truly focus permitting and construction of solar projects in the SEZs include: • Wilderness quality lands: over 500,000 acres, including such places as the Red Rock Canyon Proposed Wilderness Area southwest of Phoenix. Adjoining the existing Woolsey Peak Wilderness and near the Gila River, Red Rock Canyon’s rugged terrain provides ample opportunities for hiking, hunting and fishing and boasts Sonoran Desert wildlife such as Desert Bighorn Sheep, Sonoran desert tortoise, banded Gila monster, lowland leopard frog and a range of bat species.

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Arizona

The sun shines almost year round on Arizona, and with strong local support for renewable energy and proximity to urban energy markets, it is a great place for solar energy development.

With the needed refinements detailed here, two of the three proposed Solar Energy Zones (SEZs) in Arizona – Brenda and Gillespie – hold great potential for low-conflict solar development: they are located on flat land with few sensitive natural and cultural resources and are near existing roads and transmission lines, which will lower construction costs and help get clean electricity to consumers sooner. While Bullard Wash, the third proposed SEZ in the state, contains a unique plant community and associated sensitive wildlife habitat that makes it inappropriate as a priority development area, the BLM’s ongoing, Arizona-specific Restoration Design Energy Project provides great opportunities to identify additional SEZs going forward.

Smart Solar BLM Proposed Arizona Solar Energy Zones Arizona

2

Yavapai County

93

60

La Paz County 1

Maricopa County

10

Yuma County

3

BLM Proposed Solar Energy Zone*

Large Map Area

The Wilderness Society’s Recommendation: Candidate for Designation Should not be Designated 40

Representative Special Status Species Habitat** 17

BLM Desert Tortoise Essential Habitat BLM Desert Tortoise May be Essential Habitat 10

Solar Energy Zone Name

Data Sources:

Acreage

* Bureau of Land Management, 2010 ** Bureau of Land Management, 1992 *** National Renewable Energy Laboratory, 2011

3,878

Bullard Wash

7,239

Gillespie Total Acres in Arizona

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8

BLM Proposed

Brenda

Tucson NREL Solar Energy Potential*** Excellent

2,618 13,735

0

5

Phoenix

10

Miles 20

Very Good

Focusing on Low-Conflict Zones to Promote the West’s Economy, Protect Wildlands, and Build a Clean Energy Future

Arizona

1

Brenda Proposed Solar Energy Zone.

Photo Credit: Jon Belak, The Wilderness Society

2

Bullard Wash Proposed Solar Energy Zone.

Photo Credit: Jon Belak, The Wilderness Society

3

Gillespie Proposed Solar Energy Zone.

Photo Credit: Jon Belak, The Wilderness Society

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Smart Solar

Arizona

Details on the Proposed Arizona SEZs The proposed SEZs in Arizona will take advantage of up-front planning to guide solar projects into areas where they will get clean energy to consumers sooner and at a lower cost, create thousands of jobs and protect the environment. The BLM will continue to refine the proposed SEZs, potentially by removing entire SEZs as well as removing some portions of SEZs based on information the agency is gathering through public comment and its own research. The potential removal of some areas also underscores the importance of ongoing and future efforts to identify new SEZs. In Arizona, the BLM’s “Restoration Design Energy Project” (RDEP) is identifying potential low-conflict wind and solar development areas across land ownership in the state.

Along with the process for designating new SEZs which the Supplement to the BLM Solar Programmatic Environmental Impact Statement will lay out, RDEP will ensure the solar energy program for public lands in Arizona has room to grow for decades to come. Our key recommendations for needed improvements to the Arizona SEZs follow. With these improvements, based on what we know now, the proposed Brenda and Gillespie SEZs are good for solar and good for the environment.

Good for Solar • Great solar potential: the proposed Brenda and Gillespie SEZs receive so much sun that the National Renewable Energy Laboratory classifies the solar resource as excellent, its highest rating; • Flat landscape: allows for cost effective construction; and • Proximity to existing roads and transmission lines: being close to existing infrastructure speeds development and reduces impacts.

Good for the Environment • No conflicts with protected areas, proposed wilderness, or critical wildlife habitat; • Generally dominated by sparse, shrubby plants that are of low value to wildlife; • Prioritizing low water use solar technologies can limit potential impacts from groundwater pumping; and • Solar power produced in SEZs will reduce our reliance on polluting fossil fuels and help tackle the threats of climate change.

Even the SEZs best suited for development need to address the natural and cultural resources that exist on-site. These places may be “flat” but they are neither empty nor unimportant. To ensure that the SEZs are located in areas where solar projects are most likely to be built while minimizing impacts, conflicts and delays, we and our conservation partners have conducted

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extensive research on the proposed SEZs and made detailed recommendations to the BLM for needed improvements to the boundaries and strategies to address potential impacts at the project level. Key recommendations for each of the SEZs follow.

We have also made general recommendations to improve projects by addressing key potential conflicts and issues wherever they occur, including: • Prioritizing low-water use technologies to protect water resources and groundwater dependent ecosystems; • Protecting water quality; • Minimizing soil erosion, associated damage to vegetation, and the need to salvage Arizona state-protected native plants; • Minimizing spread of soil diseases and toxins; • Safeguarding habitat connectivity and wildlife movement corridors; • Avoiding impacts to sensitive species in playa wetlands; • Avoiding potential desert tortoise critical habitat and using best practices for tortoise relocation; • Protecting sensitive and important species, such as desert tortoise, pronghorn, desert horned lizard, greater sagegrouse, and rare desert, riparian and groundwater-dependent plants; and • Evaluating proximity to existing or need for new transmission, roads and other associated infrastructure.

Brenda SEZ The proposed Brenda SEZ is two miles east of the town of Brenda in La Paz County, west-central Arizona. The proposed SEZ is situated in a valley with the Granite Wash and Little Harquahala Mountains to the east and the Plomosa Mountains and Bear Hills to the west. US Highway 60 runs adjacent to the southeast border, providing excellent access to the site.

Key recommended refinements and strategies to minimize impacts: • Revise the boundaries to avoid the Tyson and Bouse washes on the northwestern and northeastern corners of the proposed SEZ. These areas include a greater diversity of plant and animal species and are also key for maintaining surface water flow and groundwater recharge.

Focusing on Low-Conflict Zones to Promote the West’s Economy, Protect Wildlands, and Build a Clean Energy Future

Key characteristics which are incompatible with solar development: • This area supports a diverse assemblage of plants characteristic of both the Sonoran and Mojave deserts, including large areas of palo verde cactus shrub, Joshua trees and saguaro cacti. In addition to unacceptable impacts which development in this area could cause, the strict Arizona native plant salvage laws could create extensive and costly salvage requirements for development of large solar projects in many areas of the proposed SEZ; and • Species listed under the Endangered Species Act with potential habitat in the Bullard Wash area include Gila topminnow (endangered), Arizona cliff rose (endangered), desert pupfish (endangered), the Sonoran population of the bald eagle (threatened), and southwestern willow flycatcher (endangered, and observed on the proposed SEZ during site surveys).

Gillespie SEZ The proposed Gillespie SEZ is located in western Maricopa County, 26 miles southwest of the town of Goodyear. The SEZ is southeast of the Harquahala Basin, between the Gila Bend Mountains to the southwest and Centennial Wash to the northeast. There are numerous existing transmission lines north and east of the SEZ, including five 500 kV lines and one 345 kV line less than a mile away. While the northern portion of the proposed SEZ is appropriate for development, the southern portion includes extensive riparian wash complexes that would create significant challenges for construction and could cause unacceptable impacts to wildlife habitat, and thus should be excluded from the SEZ. Key recommended refinements and strategies to minimize impacts: • Revise the boundary to exclude the area south of Agua Caliente Road. Extensive grading would be required to develop the southern portion of the proposed Gillespie SEZ, causing unacceptable impacts to wildlife habitat and increased project costs.

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Arizona

Bullard Wash SEZ The proposed Bullard Wash SEZ is located in Yavapai County in west-central Arizona, 70 miles northwest of Phoenix. The proposed SEZ is in a valley with the Black Mountains to the north, the Harcuvar Mountains to the Southwest and the Date Creek Mountains to the northeast. Overall, concerns about the diverse plant and wildlife community present in the proposed Bullard Wash SEZ as well as potential effects from solar development on special status species in the area make it unlikely that environmentally responsible development is possible in this area. For these reasons, we recommend that the BLM should not designate Bullard Wash as a SEZ.

Smart Solar

California

CALIFORNIA California has already established itself as a leader in solar development, with ambitious rooftop solar programs, numerous large- and community-scale projects under construction, and many more in the permitting pipeline. With its world-class solar resources and forward-thinking requirement that 33% of the state’s energy come from renewable resources by 2020, that trend is likely to continue. California has great potential in its Solar Energy Zones (SEZs) as well – although the proposed Iron Mountain and Pisgah SEZs contain sensitive wildlife habitat and other natural and cultural resources that make them inappropriate for designation as SEZs, with the refinements detailed here the Riverside East and Imperial East SEZs are good areas for solar development. In addition to these SEZs, the BLM is moving forward with processes such as the West Chocolate Mountains renewables planning effort and the Desert Renewable Energy Conservation Plan (DRECP) which are identifying additional new priority development areas.

The BLM has committed to a zone-based approach to solar development on public lands, and through ongoing research we and our conservation partners have conducted on the proposed SEZs over the past two years, we have grown ever more confident in our assessment that solar projects built there can generate enough electricity from the sun to power millions of homes and businesses across the West with reduced environmental impacts. The Riverside East and Imperial East zones and additional zones to be designated going forward will make an excellent foundation on which to build a solar energy program for public lands in California.

Avoiding Conflicts, Controversy and Costly Delays A key benefit of focusing on low-conflict SEZs for solar development is the opportunity to avoid sensitive wildlife habitat, wilderness quality lands and important cultural resources when selecting project sites. A project-by-project approach simply will not provide the predictability that developers, land managers, environmental groups and the public need to build a clean energy future at the pace and scale required. In addition, failing to focus on the most appropriate areas puts our natural heritage at risk, threatening key wildlife habitat and wildlands. For example, in California, ecologically inappropriate and economically risky areas that could potentially be left open for development if the BLM does not truly focus permitting and construction of solar projects in the SEZs include: • Wilderness quality lands: over 90,000 acres, including beautiful areas such as the Cady Mountains, additions to the Death Valley National Park Wilderness, the Iron Mountain Citizens’ Proposed Wilderness Area and others;

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•

The Ivanpah Valley in California’s San Bernadino County and Nevada’s Clark County is an important and sensitive ecosystem. Factors that make this area inappropriate for development include: • Rich in diverse plant and animal life, including a healthy population of desert tortoises, rare plant species, several rare bat species, the elusive and rare Gila monster, rare bird species including golden eagles, and Desert Bighorn Sheep that traverse the valley when migrating among the surrounding mountain peaks; • Vulnerability to loss of scarce groundwater, which could draw down water tables and harm wildlife; • Potential adverse impacts on the adjacent Mojave National Preserve. Among the likely consequences would be loss of scenic views, diversion of water from the preserve and obstruction of a wildlife corridor that allows wildlife to move between the preserve and other protected areas; and • Presence of areas sacred to Native Americans.

Smart Solar – Focusing on Low-Conflict Zones to Promote California’s Economy, Protect Wildlands and Build a Clean Energy Future •

•

•

•

Increase economic opportunities by generating tax revenue, creating green jobs during project construction and operations and developing a market for associated service industries; Help meet state renewable energy standard – California has a requirement that 33% of the state’s electricity come from renewable energy sources by 2020, the highest such standard in the nation; Protect sensitive lands and the wildlife they support by ensuring development only occurs in appropriate areas; and Provide clean power to reduce carbon emissions and help preserve and protect wildlands, wildlife, water supplies and communities across America and around the globe.

Focusing on Low-Conflict Zones to Promote the West’s Economy, Protect Wildlands, and Build a Clean Energy Future

Summit of Sheephole Mountain, north of Joshua Tree National Park.

Photo Credit: ©2011 Michael E. Gordon www.michael.gordon.com

Details on the Proposed California SEZs The proposed SEZs in California will take advantage of up-front planning to guide solar projects into areas where they will get clean energy to consumers sooner and at a lower cost, create thousands of jobs and protect the environment. The BLM will continue to refine the proposed SEZs, potentially by removing entire SEZs as well as removing some portions of SEZs based on information the agency is gathering through public comment and its own research. The potential removal of some areas also underscores the importance of ongoing and future efforts to identify new SEZs. In southeastern California, the BLM is analyzing a “Renewable Energy Evaluation Area” in the West Chocolate Mountains which could lead to new zones, and the agency is working with other state and federal agencies on a “Desert Renewable Energy Conservation Plan” to identify both priority renewable energy development areas and potential habitat conservation areas critical for offsetting impacts and ensuring the long-term health of the California desert ecosystem. Along with the process for designating new SEZs which the Supplement to the BLM Solar Programmatic Environmental Impact Statement will lay out, these efforts will ensure the solar energy program for our public lands has room to grow for decades to come. Our key recommendations for needed improvements to the California SEZs follow. With these improvements, based on what we know now, the proposed Riverside East and Imperial East SEZs are good for solar and good for the environment.

Good for the Environment • No conflicts with protected areas, proposed wilderness, or critical wildlife habitat; • Prioritizing low water use solar technologies can limit potential impacts from groundwater pumping; and • Solar power produced in SEZs will reduce our reliance on polluting fossil fuels and help tackle the threats of climate change.

Even the SEZs best suited for development need to address the natural and cultural resources that exist on site. These places may be “flat” but they are neither empty nor unimportant. To ensure that the SEZs are located in areas where solar projects are most likely to be built while minimizing impacts, conflicts and delays, we and our conservation partners have conducted extensive research on the proposed SEZs and made detailed recommendations to the BLM for needed improvements to the boundaries as well as strategies to address potential impacts at the project level. Key recommendations for each of the SEZs follow. We have also made general recommendations to improve projects by addressing key potential conflicts and issues wherever they occur, including: • Prioritizing low-water use technologies to protect water resources and groundwater dependent ecosystems; • Protecting water quality; • Minimizing soil erosion and associated damage to vegetation; • Minimizing impacts to sand transport areas needed to maintain wildlife habitat for species that live on sand dunes; • Ensuring consistency with California Desert Conservation Area management goals; • Minimizing impacts to cultural resources; • Safeguarding habitat connectivity and wildlife movement corridors; • Avoiding desert tortoise critical habitat and using best practices for tortoise relocation; • Protecting sensitive and important species, such as desert tortoise, Mojave fringe toed lizard and flat tailed horned lizard, Desert Bighorn Sheep, golden eagles, and rare desert, riparian, and groundwater-dependent plants; and • Evaluating proximity to existing or need for new transmission, roads and other associated infrastructure.

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California

Desert photographer Michael Gordon says, “As a professional photographer, my business requires me to visit and photograph protected iconic western landscapes.

I recognize our need to quickly transition to renewable energy sources, and I support a zone-based approach that sites land, water, and resource intensive solar projects on suitable public and private lands. This path allows me to grow my business while benefitting all those who care deeply for the western landscape and its legacy. This ensures that these special places will remain to inspire future generations.”

Good for Solar • Great solar potential: the proposed Riverside East and Imperial East SEZs receive so much sun that the National Renewable Energy Laboratory classifies the solar resource as excellent, its highest rating; • Flat landscape: allows for cost effective construction; and • Proximity to existing roads and transmission lines: being close to existing infrastructure speeds development and reduces project costs and impacts.

Smart Solar BLM Proposed California Solar Energy Zones Barstow 40

3

San Bernardino County

Victorville

95

California

2 Twentymile Palms

Riverside

Riverside County Palm Springs

215 74

4

10

Blythe Mecca

San Diego County

15

Salton Sea

86 111 New

Rive

r

8

San Diego

er

Alamo Riv

El Centro

1

Imperial County

BLM Proposed Solar Energy Zone* The Wilderness Society’s Recommendation: Candidate for Designation

5

Should not be Designated

80

Large Map Area

BLM Proposed West Chocolate Mountains Renewable Energy Evaluation Area* San Francisco

West Chocolate Mountains Study Area

Representative Special Status Species Habitat** Mojave Desert Tortoise Critical Habitat

Solar Energy Zone Name Imperial East Iron Mountain Pisgah

BLM Proposed

Data Sources:

Acreage

* Bureau of Land Management, 2010 ** U.S Fish and Wildlife Service, 2010 *** National Renewable Energy Laboratory, 2011

5,722 106,522

NREL Solar Energy Potential*** Excellent

202,896

Total Acres in California

339,090

Los Angeles San Diego

23,950

Riverside East

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15 40

0

10

20

Miles 40

Good

10

Focusing on Low-Conflict Zones to Promote the West’s Economy, Protect Wildlands, and Build a Clean Energy Future

Imperial East Proposed Solar Energy Zone.

Photo Credit: Argonne National Laboratory

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Iron Mountain Proposed Solar Energy Zone.

Photo Credit: © 2011 Michael E. Gordon | www.michael-gordon.com

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Pisgah Proposed Solar Energy Zone.

Photo Credit: © 2011 Michael E. Gordon | www.michael-gordon.com

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Riverside East Proposed Solar Energy Zone.

Photo Credit: Argonne National Laboratory

California

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Smart Solar

California

Imperial East SEZ The proposed Imperial East SEZ is in southeastern California and lies in the Imperial Valley in Imperial County. I-8 runs east–west along the northeast edge of the proposed SEZ, while State Route 98 passes through the southern edge. San Diego lies 120 miles to the west, and Yuma, Arizona, is 29 miles to the east via I-8. A 115-kV transmission line intersects the southwest corner of the proposed SEZ, and a 500-kV line is located about half a mile to the south, running east-west.

Key recommended refinements and strategies to minimize impacts: • This proposed SEZ is within a BLM flat-tailed horned lizard Wildlife Habitat Management Area; disturbance of soil and vegetation types used by the species should be limited per the inter-agency rangewide management strategy for this species; • Golden eagle are predicted in this and all other California SEZs; U.S. Fish and Wildlife Service Interim Golden Eagle Technical Guidance Protocols should be adhered to to determine presence of the species within a ten-mile radius of all proposed project areas; and • One cultural resource survey has been conducted in this proposed SEZ (the survey was conducted for the All-American Canal Lining Project in the early 1990s); no cultural sites were located within the SEZ area, but the Final Environmental Impact Statement for the canal lining project noted the area south of the SEZ as an area with a high density of prehistoric and historic cultural resources, and further surveys within the SEZ should be performed.

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Riverside East SEZ The proposed Riverside East SEZ is located six miles west of the town of Blythe in Riverside County in southeastern California, within the Chuckwalla Valley and the southern portion of Palen Valley. I-10 runs east–west along the southern boundary of the SEZ, State Route 177 runs north–south through the western section, and Midland Road crosses the northeastern portion of the SEZ. US Hwy 95 runs north–south about three miles from the eastern boundary of the SEZ. An existing 500-kV transmission line runs east-west along I-10 and parallel to the southern boundary of the proposed SEZ. In addition, a 230-kV line passes through the far western section of the proposed SEZ. Key recommended refinements and strategies to minimize impacts: • Revise boundary to protect Microphyll Woodlands by moving the eastern and northeastern boundary to avoid the McCoy Wash watershed, and the northwestern boundary to exclude the Microphyll Woodlands in upper Chuckwalla Valley and Palen Valley; • Avoid ground disturbance near Palen Lake, Ford Dry Lake and wetlands; • Exclude Microphyll Woodlands, Wildlife Habitat Management Plan Areas, sand dunes and sand transport corridors, and habitat connectivity areas from development; • The proposed SEZ has been identified as a probable bighorn sheep movement corridor, contains dune habitats that support Mojave fringe-toed lizard and other sand-dependent species, and contains important desert tortoise habitat as well as golden eagle habitat; proposed developments must account for potential impacts to these species; • The proximity of major interstates and existing and approved (Devers II) transmission infrastructure provide opportunities for solar development with limited needs for additional major infrastructure; and • Cultural resources in this SEZ include aboriginal trails, a potential Papago area of cultural significance, and portions of Camp Rice, a World War II era training center; potential impacts to these areas should be evaluated and avoided.

Focusing on Low-Conflict Zones to Promote the West’s Economy, Protect Wildlands, and Build a Clean Energy Future

While we believe strongly that the Pisgah SEZ is not appropriate for development of solar energy, we do recommend that the BLM consider a limited base of lands near the proposed Pisgah SEZ identified as the Daggett Triangle. These lands were identified by conservation stakeholders in 2009 as potentially appropriate for development and should be assessed in conjunction with adjacent private lands, potentially through the DRECP process.

Key characteristics which are incompatible with solar development: • Presence of numerous special status species: Emory‘s Crucifixion-thorn, Small-flowered Androstephium, Whitemargined Beardtongue, Arroyo Chub, Mohave Tui Chub, desert tortoise, Mojave Fringe-toed lizard, Southwestern Pond Turtle, Burrowing Owl, Golden Eagle, Bendire‘s Thrasher, and Desert Bighorn Sheep; • Presence of donated lands or lands acquired with Land and Wildlife Conservation Fund funds; • Habitat connectivity: the proposed Pisgah SEZ is within an area of essential habitat connectivity that links together the Desert Tortoise Recovery Units in the Western Mojave, Eastern Mojave and Northern Colorado deserts.

Furthermore, this habitat connectivity area links the natural landscape blocks and native species occurring in the Bristol, Cady, Rodman, Newberry and Ord Mountain areas; and • Existing information shows the area contains habitation sites, rock art, lithic scatters, and hearths, indicating that the area may have had important prehistoric activity, and should be systematically inventoried.

Iron Mountain SEZ The proposed Iron Mountain SEZ is in San Bernadino County in the Ward Valley, a broad valley in the Mojave Desert bounded by the Turtle Mountains to the east and the Iron Mountains to the west. The SEZ is 37 miles northwest of the town of Blythe and 31 miles north of I-10. The Old Woman Mountains and the Palen-McCoy Wilderness Areas also lie nearby. The area is very isolated and remote and importantly, there is no transmission access within or near this SEZ. The BLM should remove the proposed Iron Mountain SEZ from further consideration due to the high level of occurrence of sensitive resources and general inconsistency with screening criteria the conservation community and the BLM itself have developed for siting solar facilities in the desert.

Key characteristics which are incompatible with solar development: • Habitat connectivity: essential habitat linkages for Desert Bighorn Sheep, desert tortoise and other wideranging species that occur within the proposed Iron Mountain SEZ; • Presence of numerous special status species: desert tortoise, Desert Bighorn Sheep, Mojave fringe toed lizard, desert rosey boa, desert night lizard, and Golden Eagle; • Wilderness quality lands: over 10,000 acres proposed for wilderness designation in the Iron Mountain Citizens’ Proposed Wilderness Area, some of which provide connectivity between Joshua Tree National Park and the Mojave Preserve; and • Native American tribes have identified this SEZ as having great cultural significance, and development of this area could also conflict with an ACEC designated to protect Patton’s Iron Mountain Divisional Camp.

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California

Pisgah SEZ The proposed Pisgah SEZ is in the Central Mojave Desert region in San Bernardino County. I-40 and Historic Route 66 pass through the SEZ, which is 26 miles southeast of the town of Barstow. Recent surveys associated with solar projects permitted in 2010 confirmed that solar development in this area would entail loss of habitat and displacement of many wildlife species, including the state and federally threatened desert tortoise, special-status reptiles, special-status mammals, migratory birds and numerous rare plant species. Because of its location within an area of essential wildlife habitat and habitat connectivity, the BLM should remove the Pisgah SEZ from further consideration.

Smart Solar COLORADO

Colorado

Colorado has built a reputation as a national leader on renewable energy, steadily increasing its wind and solar portfolio over the years and in 2010 passing a law requiring that 30% the state’s energy come from renewable resources by 2020, one of the highest standards in the country. The state’s great potential for solar includes four Solar Energy Zones (SEZs) proposed by the BLM on public lands. With the needed refinements detailed here, Colorado’s proposed SEZs are very good areas for solar development.

The BLM has committed to a zone-based approach to solar development on public lands, and through extensive and ongoing research we and our conservation partners have conducted on the proposed SEZs over the past two years, we have grown ever more confident in our assessment that solar projects built there can generate enough electricity from the sun to power hundreds of thousands of homes and businesses across the West while minimizing environmental impacts. These zones and additional zones to be designated going forward will make an excellent foundation on which to build a solar energy program for public lands in Colorado.

Fifth-generation San Luis Valley residents Olive and Demetrio Valdez run cattle on their organic southern Colorado ranch less than a mile from the proposed Antonito Southeast Solar Energy Zone. Strong supporters of a zonebased program for solar on public lands, Olive says, “As a former Wildlife Commissioner, I can tell you the Antonito zone offers great economic benefits for our community from solar development without harming the wildlife that make this place special. As a local resident, I can tell you that I want solar in my back yard, and I want it in the right places, like the Antonito zone.”

Avoiding Conflicts, Controversy and Costly Delays

Smart Solar – Focusing on Low-Conflict Zones to Promote Colorado’s Economy, Protect Wildlands, and Build a Clean Energy Future •

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•

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Increase economic opportunities by generating tax revenue, creating green jobs during project construction and operations, and developing a market for associated service industries; Help meet state renewable energy standard – Colorado has a requirement that 30% of the state’s electricity come from renewable energy sources by 2020; Protect sensitive lands and the wildlife they support by ensuring development only occurs in appropriate areas; and Provide clean power to reduce carbon emissions and help preserve and protect wildlands, wildlife, water supplies, and communities across America and around the globe.

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A key benefit of focusing on low-conflict SEZs for solar development is the opportunity to avoid sensitive wildlife habitat, wilderness quality lands and important cultural resources when selecting project sites. A project-by-project approach simply will not provide the predictability that developers, land managers, environmental groups and the public need to build a clean energy future at the pace and scale required. In addition, failing to focus on the most appropriate areas puts our natural heritage at risk, threatening key wildlife habitat and wildlands. For example, in Colorado, ecologically inappropriate and economically risky areas that could potentially be left open for development if the BLM does not truly focus permitting and construction of solar projects in the SEZs include: • Wilderness quality lands: over 2,500 acres of the Rio Grande Citizens’ Proposed Wilderness Area, roughly 25% of the total 10,150 acre unit. The broader area includes the Rio Grande River corridor, well-known for its steep cliffs and lush riparian vegetation and contains important habitat for raptors including prairie falcons and bald and golden eagles; • 13,382 acres (in ten areas) designated by the Colorado Natural Heritage Program as areas of high biodiversity significance; and • 561 acres of the Colorado Division of Wildlife/BLM Hot Creek State Wildlife Area.

Focusing on Low-Conflict Zones to Promote the West’s Economy, Protect Wildlands, and Build a Clean Energy Future

Details on the Proposed Colorado SEZs The proposed SEZs in Colorado will take advantage of up-front planning to guide solar projects into areas where they will get clean energy to consumers sooner and at a lower cost, create thousands of jobs, and protect the environment. The BLM will continue to refine the proposed SEZs, potentially by removing entire SEZs as well as removing some portions of SEZs based on information the agency is gathering through public comment and its own research. The potential removal of some areas also underscores the importance of ongoing and future efforts to identify new SEZs through the process the BLM will lay out in the upcoming Supplement to the BLM Solar Programmatic Environmental Impact Statement. These efforts will ensure that the solar energy program for our public lands has room to grow for decades to come. Our key recommendations for needed improvements to the SEZs follow. With these improvements, based on what we know now, the proposed Colorado SEZs are good for solar and good for the environment.

Good for the Environment • No conflicts with protected areas, proposed wilderness, or critical wildlife habitat; • Generally dominated by sparse, shrubby plants that are of low value to wildlife; • Prioritizing low water use solar technologies can limit potential impacts from groundwater pumping; and • Solar power produced in SEZs will reduce our reliance on polluting fossil fuels and help tackle the threats of climate change.

Even the SEZs best suited for development need to address the natural and cultural resources that exist on site. These places may be “flat” but they are neither empty nor unimportant. To ensure that the SEZs are located in areas where solar projects are most likely to be built while minimizing impacts, conflicts and delays, we and our conservation partners have conducted extensive research on the proposed SEZs and made detailed recommendations to the BLM for needed improvements to the boundaries and strategies to address potential impacts at the

Antonito Southeast SEZ The proposed Antonito Southeast SEZ is located in southern Colorado’s San Luis Valley in southeastern Conejos County, on the border between Colorado and New Mexico, immediately adjacent to US Hwy 285, which provides excellent site access. The proposed SEZ is two miles southeast of the town of Antonito.

Key recommended refinements and strategies to minimize impacts: • Perform pre-development surveys and analysis of potential impacts to Gunnison’s prairie dog and avoid, minimize and/or mitigate impacts; and • Analyze and avoid, minimize and/or mitigate potential impacts to the Old Spanish National Historic Trail located immediately east of the proposed SEZ.

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Colorado

Good for Solar • Great solar potential: the proposed Colorado SEZs receive so much sun that the National Renewable Energy Laboratory classifies the solar resource as excellent, its highest rating; • Flat landscape: allows for cost effective construction; and • Proximity to existing roads and transmission lines: being close to existing infrastructure speeds development and reduces impacts.

project level. Key recommendations for each of the SEZs follow.

We have also made general recommendations to improve projects by addressing key potential conflicts and issues wherever they occur, including: • Prioritizing low-water use technologies to protect water resources and groundwater dependent ecosystems; • Protecting water quality; • Minimizing soil erosion and associated damage to vegetation; • Minimizing dust effects on air quality and snowmelt; • Safeguarding habitat connectivity and wildlife movement corridors – although the Colorado SEZs have some overlap with elk and pronghorn winter habitat, these use areas are relatively widespread along the edges of the San Luis Valley; with good project siting and design to preserve wildlife habitat connectivity, as well as construction planning to avoid winter disturbance, big game winter habitat issues can be appropriately addressed and population level effects to these species avoided; • Protecting sagebrush ecosystems and associated species, including Gunnison sage-grouse, Gunnison’s prairie dog, Ferruginous hawk and Colorado larkspur; and • Evaluating proximity to existing or need for new transmission, roads and other associated infrastructure.

Smart Solar BLM Proposed Colorado Solar Energy Zones 2 nt

Sai

Saguache County Head Lake

Rio Grande County

San Luis Lake

4 Riv e

Alamosa County Colorado

160 Alam

osa

Mountain Home Reservoir

285

Rive

r

r

ch a r as

285

les

r Cha

Cu

Smith Reservoir

Conejos County

Costilla County

Navajo R iv

er

Platoro Reservoir

3 Con

ejos

Rive

r

Sanchez Reservoir

Cove Lake Reservoir

1 BLM Proposed Solar Energy Zone* The Wilderness Society’s Recommendation:

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Fort Collins

Candidate for Designation

Representative Game Species Habitat** 70

Mule Deer Severe Winter Range

25

Data Sources:

Colorado Springs

* Bureau of Land Management, 2010 ** Colorado Division of Wildlife, 2008 *** National Renewable Energy Laboratory, 2011

Solar Energy Zone Name

Pueblo

BLM Proposed Acreage

Antonito Southeast

9,729

DeTilla Gulch

1,522

Fourmile East

3,882

Los Mogotes East

5,918

Total Acres in Colorado 0

10

Page 18

Denver

21,051 20

Miles 40

NREL Solar Energy Potential*** Excellent

Large Map Area Good

er

Riv

Focusing on Low-Conflict Zones to Promote the West’s Economy, Protect Wildlands, and Build a Clean Energy Future

Antonito Southeast Proposed Solar Energy Zone.

Photo Credit: Alex Daue, The Wilderness Society

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DeTilla Gulch Proposed Solar Energy Zone.

Photo Credit: Jon Belak, The Wilderness Society

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Fourmile East Proposed Solar Energy Zone.

Photo Credit: Alex Daue, The Wilderness Society

Colorado

1

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Los Mogotes East Proposed Solar Energy Zone.

Photo Credit: Jon Belak, The Wilderness Society

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Smart Solar

Colorado

DeTilla Gulch SEZ The proposed DeTilla Gulch SEZ is located in southern Colorado’s San Luis Valley in Saguache County. The proposed SEZ is three-and-a-half miles northeast of the town of Saguache and is immediately adjacent to US Hwy 285, which provides excellent site access. Two transmission lines (230 kV and 115 kV) intersect the SEZ. Though this SEZ has the highest level of natural resource conflicts of all the Colorado SEZs, with careful project design and meaningful mitigation to offset potential impacts to Gunnison’s prairie dog, the area is appropriate for designation as a SEZ. Key recommended refinements and strategies to minimize impacts: • Revise the boundary to remove overlap with the active Gunnison’s prairie dog colony on the northern edge of the SEZ, and perform pre-development surveys and carefully analyze and avoid, minimize and/or mitigate potential impacts to Gunnison’s prairie dog from development within the SEZ; and • Analyze and avoid, minimize and/or mitigate potential impacts to the Old Spanish National Historic Trail located a quarter mile from the proposed SEZ. Fourmile East SEZ The proposed Fourmile East SEZ is located in southern Colorado’s San Luis Valley in Alamosa County. The proposed SEZ is immediately adjacent to US Hwy 160 and CO Hwy 150, providing excellent access to the site. The SEZ is 11 miles northeast of the town of Alamosa.

Key recommended refinements and strategies to minimize impacts: • Revise the boundary to remove narrow area east of CO Hwy 150 to avoid impacts to the Old Spanish National Historic Trail; this portion of the proposed SEZ is not contiguous with the rest of the SEZ and would thus also be difficult to develop; and • Perform pre-development surveys and analysis of potential impacts to Gunnison’s prairie dog and avoid, minimize and/or mitigate impacts.

Los Mogotes East SEZ The proposed Los Mogotes East SEZ is located in southern Colorado in the southwestern part of the San Luis Valley in Conejos County. The proposed SEZ is two-and-a-half miles west of US Hwy 285 and three-and-a-half miles west of the town of Romeo.

Key recommended refinements and strategies to minimize impacts: • Perform pre-development surveys and analysis of potential impacts to Gunnison’s prairie dog and avoid, minimize and/or mitigate impacts; and • Analyze and avoid, minimize and/or mitigate potential impacts to the Old Spanish National Historic Trail located immediately east of the proposed SEZ.

Matt Abbey, General Manager for the San Luis and Rio Grande Railroad (SLRG) says, “Like using rail for transportation, building solar projects in low-conflict areas where they are most likely to succeed isn’t just good for the environment, it is good business. A solar zone located adjacent to the SLRG excites us as a company and as local citizens committed to making a big impact with a small footprint.”

“The review process by the BLM of potential zones for solar development is an example of the recognition that the more we reduce the uncertainties of siting and permitting the more attractive these projects can become to solar developers and investors.” Mike Gibson, Manager, San Luis Valley Water Conservancy District

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Focusing on Low-Conflict Zones to Promote the West’s Economy, Protect Wildlands, and Build a Clean Energy Future

NEVADA Southern Nevada boasts some of the best solar resources in the nation, with great potential for clean energy development in the flat expanses between the state’s many mountain ranges. That potential is evident from the seven Solar Energy Zones (SEZs) proposed for Nevada in the BLM Solar Programmatic Environmental Impact Statement (PEIS), more than any other state.

As detailed here, several of the proposed Nevada SEZs need significant refinements, but overall they are very good areas for solar development.

The BLM has committed to a zone-based approach to solar development on public lands, and through extensive and ongoing research we and our conservation partners have conducted on the proposed SEZs over the past two years, we have grown ever more confident in our assessment that solar projects built there can generate enough electricity from the sun to power millions of homes and businesses across the West while minimizing environmental impacts. These zones and additional zones to be designated going forward will make an excellent foundation on which to build a solar energy program for public lands in Nevada.

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Increase economic opportunities by generating tax revenue, creating green jobs during project construction and operations and developing a market for associated service industries; Help meet state renewable energy standard – Nevada has a requirement that 25% of the state’s electricity come from renewable energy sources by 2025; Protect sensitive lands and the wildlife they support by ensuring development only occurs in appropriate areas; and Provide clean power to reduce carbon emissions and help preserve and protect wildlands, wildlife, water supplies and communities across America and around the globe.

Avoiding Conflicts, Controversy and Costly Delays A key benefit of focusing on low-conflict SEZs for solar development is the opportunity to avoid sensitive wildlife habitat, wilderness quality lands and important cultural resources when selecting project sites. A project-by-project approach will simply not provide the predictability that developers, land managers, environmental groups and the public need to build a clean energy future at the pace and scale required. In addition, failing to focus on the most appropriate areas puts our natural heritage at risk, threatening key wildlife habitat and wildlands. For example, in Nevada, ecologically inappropriate and economically risky areas that could potentially be left open for development if the BLM does not truly focus permitting and construction of solar projects in the SEZs include: • Sage grouse habitat: more than 1 million acres of core breeding habitat; • Elk, pronghorn and mule deer migration corridors: more than 1 million acres; and • Wilderness quality lands: 140,000 acres.

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Nevada

Smart Solar – Focusing on Low-Conflict Zones to Promote Nevada’s Economy, Protect Wildlands, and Build a Clean Energy Future

Clint Bentley, Director of The Fraternity of the Desert Bighorn, says, “With careful planning and coordination I strongly support solar energy development on Nevada’s public lands. If properly located, solar projects can provide great benefits to our State.

However, strong input on development areas from local residents and wildlife experts is critical to minimize damage to wildlife habitat and impacts to animal travel corridors. With this involvement, and a focus on low-conflict areas for development, I look forward to participating in sound planning and implementation of a responsible solar energy program for our public lands.”

Smart Solar BLM Proposed Nevada Solar Energy Zones 1 6 ive

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hit eR

Esmeralda County Nye County

Lincoln County

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Solar Energy Zone Name

BLM Proposed Acreage

Gold Point

4,810

Millers

Nevada

Clark County

8,968

7 Lake Mead

16,787

Total Acres in Nevada

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76,874

East Mormon Mt.

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15,649

Dry Lake Valley North

95

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Dry Lake

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16,552

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31,625

Delamar Valley

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Amargosa Valley

Las Vegas

171,265

Large Map Area Reno

BLM Proposed Solar Energy Zone*

Lake Mohave

The Wilderness Society’s Recommendation: Candidate for Designation

Representative Special Status Species Habitat NDOW Greater Sage-Grouse Habitat** Desert Tortoise Critical Habitat*** Data Sources: NREL Solar Energy Potential**** Excellent

Very Good

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Virgin Riv

5

Las Vegas

* Bureau of Land Management, 2010 ** Nevada Department of Wildlife, 2001 *** U.S Fish and Wildlife Service, 2010 **** National Renewable Energy Laboratory, 2011

0

10

20

Miles 40

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Focusing on Low-Conflict Zones to Promote the West’s Economy, Protect Wildlands, and Build a Clean Energy Future

Millers Proposed Solar Energy Zone.

Photo Credit: Jon Belak, The Wilderness Society

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Gold Point Proposed Solar Energy Zone.

Photo Credit: Alex Daue, The Wilderness Society

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Amargosa Valley Proposed Solar Energy Zone.

Photo Credit: Jon Belak, The Wilderness Society

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Dry Lake Valley North Proposed Solar Energy Zone.

Photo Credit: Jon Belak, The Wilderness Society

Delamar Valley Proposed Solar Energy Zone.

Photo Credit: Jon Belak, The Wilderness Society

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East Mormon Mt. Proposed Solar Energy Zone.

Photo Credit: Rob Mrowka, Center for Biological Diversity

Dry Lake Proposed Solar Energy Zone.

Photo Credit: Rob Mrowka, Center for Biological Diversity

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Nevada

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Smart Solar Details on the Proposed Nevada SEZs The proposed SEZs in Nevada will take advantage of up-front planning to guide solar projects into areas where they will get clean energy to consumers sooner and at a lower cost, create thousands of jobs, and protect the environment. The BLM will continue to refine the SEZs, potentially by removing entire SEZs as well as removing some portions of SEZs based on information the agency is gathering through public comment and its own research. The potential removal of some areas also underscores the importance of ongoing and future efforts to identify new SEZs through the process the BLM will lay out in the upcoming Supplement to the Solar PEIS. These efforts will ensure that the solar energy program for our public lands has room to grow for decades to come. Our key recommendations for needed improvements to the SEZs follow. With these improvements, based on what we know now, the proposed Nevada SEZs are good for solar and good for the environment.

Nevada

Good for Solar • Great solar potential: all of the SEZs receive so much sun that the National Renewable Energy Laboratory classifies the solar resource as excellent, its highest rating; • Flat landscape: allows for cost effective construction; and • Proximity to existing roads and transmission lines: being close to existing infrastructure speeds development and reduces impacts.

Good for the Environment • No conflicts with protected areas, proposed wilderness, or critical wildlife habitat; • Generally dominated by sparse, shrubby plants that are of low value to wildlife; • Prioritizing low water use solar technologies can limit potential impacts from groundwater pumping; and • Solar power produced in SEZs will reduce our reliance on polluting fossil fuels and help tackle the threats of climate change.

Even the SEZs best suited for development need to address the natural and cultural resources that exist on-site. These places may be “flat” but they are neither empty nor unimportant. To ensure that the SEZs are located in areas where solar projects are most likely to be built while minimizing impacts, conflicts and delays, we and our conservation partners have conducted extensive research on the proposed SEZs and made detailed recommendations to the BLM for needed improvements to the boundaries as well as on strategies to address potential impacts at the project level. Key recommendations for each of the SEZs follow. We have also made general recommendations to im-

Page 24

prove projects by addressing key potential conflicts and issues wherever they occur, including: • Prioritizing low-water use technologies to protect water resources and groundwater dependent ecosystems; • Protecting water quality; • Minimizing soil erosion and associated damage to vegetation; • Minimizing spread of soil diseases and toxins; • Safeguarding habitat connectivity and wildlife movement corridors; • Avoiding impacts to sensitive species in playa wetlands; • Avoiding desert tortoise critical habitat and using best practices for tortoise relocation; • Protecting sensitive and important species, such as desert tortoise, pronghorn, desert horned lizard, Greater SageGrouse, and rare desert, riparian, and groundwater-dependent plants; and • Evaluating proximity to existing or need for new transmission, roads and other associated infrastructure.

Amargosa Valley SEZ The proposed Amargosa Valley SEZ is 13 miles northwest of the town of Amargosa Valley in southwestern Nevada. The SEZ lies towards the northern end of the Amargosa Valley in Nye County and is located along the ephemeral Amargosa River between the Bare and Funeral Mountain Ranges.

US Hwy 95 runs along the northeastern edge of the proposed SEZ. Key recommended refinements and strategies to minimize impacts: • Revise the boundary to remove the Amargosa River and 100-year flood channel as well as the associated wash to preserve wildlife, plant habitat and hydrological function, as well as provide flood control; • The recommended boundary adjustment would also maintain a desert tortoise/wildlife movement corridor that is key to linking nearby populations; • Application of low-water use solar technologies is particularly important for the area of the proposed Amargosa Valley SEZ because of potential impacts of groundwater pumping to the nearby Ash Meadows National Wildlife Refuge and Devil’s Hole and the endangered, groundwater-dependent species that live there;

Focusing on Low-Conflict Zones to Promote the West’s Economy, Protect Wildlands, and Build a Clean Energy Future

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Avoid indirect impacts to endemic dune beetle species; these species do not have suitable habitat within the SEZ, but could be affected by changes in sand transport to areas east of the SEZ; and Consider extending the SEZ north in low-conflict lands between the Amargosa River and US Hwy 95.

Delamar Valley SEZ The proposed Delamar Valley SEZ is 21 miles southwest of the town of Caliente in Lincoln County, southeastern Nevada.

The SEZ lies between the South Pahroc Range to the west and the Delamar Mountains to the east and southeast. The proposed SEZ is nine miles east of US Hwy 93.

Dry Lake SEZ The proposed Dry Lake SEZ is located in southern Nevada in the Dry Lake Valley in Clark County, and is bounded on the west by the Arrow Canyon Range and on the southeast by the Dry Lake Range. The proposed SEZ is 22 miles northeast of Las Vegas and I-15 and US Hwy 93 run along the southeast and southwest boundaries, respectively.

Key recommended refinements and strategies to minimize impacts: • Revise the boundary to exclude the Dry Lake playa, the series of rugged and jumbled washes flowing southwest to northeast into the playa near the SEZ’s northern

•

Dry Lake Valley North SEZ The proposed Dry Lake Valley North SEZ is located in Lincoln County in southeastern Nevada. The SEZ is located in the Dry Lake Valley and is bounded by numerous mountain ranges on the east and west. The proposed SEZ is 15 miles west of the town of Panaca and is nine miles west of US Hwy 93.

Key recommended refinements and strategies to minimize impacts: • Revise the boundary to avoid important wildlife habitat and other sensitive natural resources, including habitat for Desert Valley Kangaroo mouse, desert horned lizard and burrowing owl, as well as Eastwood milkweed; and • Proximity to existing transmission lines and roads will decrease disturbance and development costs by reducing associated infrastructure needs. The nearby segment of the 500 kV SWIP transmission line now under construction will provide significant additional transmission capacity when it is complete.

East Mormon Mountain SEZ The proposed East Mormon Mountain SEZ is in Lincoln County in southeastern Nevada and straddles Toquop Wash, just east of East Mormon Mountain. The proposed SEZ is 10 miles north of I-15 and 13 miles northwest of the town of Mesquite.

Key recommended refinements and strategies to minimize impacts: • Evaluate impacts of the 2005 fire on desert tortoise critical habitat to assess whether adjacent unburned areas may have increased value and whether burned areas may no longer provide habitat; and • Avoid impacts to major washes to maintain surface hydrologic function and protect wildlife habitat.

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Nevada

Key recommended refinements and strategies to minimize impacts: • Revise the boundary to remove the southern end of the SEZ, from where Jumbo Wash enters the playa and south of there to protect sensitive natural resources in the playa lake; • Consider extending the SEZ to the northeast in lowconflict lands; • Groundwater flows south through the Delamar Valley and continues into the Pahranagat National Wildlife Refuge, which provides habitat for special status, groundwater-dependent species; groundwater supply to these species must be maintained; and • Proximity to existing transmission lines and US Hwy 93 will decrease disturbance and development costs by reducing associated infrastructure needs. The nearby segment of the 500 kV Southwest Intertie Project (SWIP) transmission line now under construction will also provide significant additional transmission capacity when it is complete.

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boundary, the heavily developed area in the southeast corner, and the portion southeast of I-15; Consider extending the SEZ to the northeast in lowconflict lands there; and Proximity to a large metropolitan area, existing transmission lines and roads will decrease disturbance and development costs by reducing materials transportation costs and associated infrastructure needs. The nearby segment of the 500 kV SWIP transmission line now under construction will also provide significant additional transmission capacity when it is complete.

Smart Solar Gold Point SEZ The proposed Gold Point SEZ is located in Esmeralda County in southwestern Nevada. The SEZ is in the upper Lida Valley between MacGruder Mountain and Slate Ridge. The proposed SEZ is 21 miles southwest of the town of Goldfield, nine miles west of US Hwy 95 and two miles south of State Hwy 3.

Nevada

Key recommended refinements and strategies to minimize impacts: • Avoid impacts to pronghorn herds in the Lida Valley by using project design that protects pronghorn access to forage and water and scheduling construction outside of dry periods when access is most critical; and • New transmission to the SEZ could be run along highways 3, 266 and 95, limiting impacts by co-locating with existing infrastructure rather than routing through undisturbed areas.

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Millers SEZ The proposed Millers SEZ is located in Esmeralda County in western Nevada. The SEZ is north of US Hwy 95/US Hwy 6, which runs east–west along its southern border. The proposed SEZ is 13 miles northwest of the town of Tonopah.

The SEZ is in the southeast end of the Big Smoky Valley, in an area known as Tonopah Flat, and is surrounded by Lone Mountain to the south, the Monte Cristo Range to the west, and the San Antonio Mountains to the east.

Key recommended refinements and strategies to minimize impacts: • Avoid important wildlife habitat in sand dunes; • Avoid indirect impacts to endemic dune beetle species; these species do not have suitable habitat within the SEZ, but could be affected by changes in sand transport to areas northeast of the SEZ; and • Since this site is adjacent to US Hwy 95/US Hwy 6, access to the site would require minimal ground disturbance.

The proximity of existing transmission lines also raise the possibility of using existing capacity on those lines or upgrading them instead of building new lines.

Focusing on Low-Conflict Zones to Promote the West’s Economy, Protect Wildlands, and Build a Clean Energy Future

NEW MEXICO In the sizzling Chihuahuan desert of New Mexico, blue skies are the norm and the sun packs a punch, making for huge solar development potential in the region. The state’s great potential for solar includes three Solar Energy Zones (SEZs) proposed by the BLM on public lands. With the needed refinements detailed here, New Mexico’s proposed SEZs are very good areas for solar development.

The BLM has committed to a zone-based approach to solar development on public lands, and through extensive and ongoing research we and our conservation partners have conducted on the proposed SEZs over the past two years, we have grown ever more confident in our assessment that solar projects built there can generate enough electricity from the sun to power millions of homes and businesses across the West while minimizing environmental impacts. These zones and additional zones to be designated going forward will make an excellent foundation on which to build a solar energy program for public lands in New Mexico.

Smart Solar – Focusing on Low-Conflict Zones to Promote New Mexico’s Economy, Protect Wildlands, and Build a Clean Energy Future •

•

•

Avoiding Conflicts, Controversy and Costly Delays A key benefit of focusing on low-conflict SEZs for solar development is the opportunity to avoid sensitive wildlife habitat, wilderness quality lands and important cultural resources when selecting project sites. A project-by-project approach simply will not provide the predictability that developers, land managers, environmental groups and the public need to build a clean energy future at the pace and scale required. In addition, failing to focus on the most appropriate areas puts our natural heritage at risk, threatening key wildlife habitat and wildlands.

For example, in New Mexico, ecologically inappropriate and economically risky areas that could potentially be left open for development if the BLM does not truly focus permitting and construction of solar projects in the SEZs include: • Wilderness quality lands: nearly 500,000 acres of the New Mexico Wilderness Alliance Citizens’ Wilderness Inventory lands, including beautiful landscapes from Chihuahuan desert grasslands to sky islands and wild river gorges.

Areas threatened include the Animas Mountains North, Gila Lower and Middle Box, Nutt Grasslands North and South, Eagle Nest and many more; • Endangered species habitat: over 3,000 acres of high and medium suitability habitat for the Aplomado falcon, a raptor that is listed as endangered under the Endangered Species Act; and • Sensitive cultural and historical resources: significant late prehistoric village sites in Chupadera and Mesa Well Canyon, including several large pueblos numbering more than 100 rooms.

Page 27

New Mexico

•

Increase economic opportunities by generating tax revenue, creating green jobs during project construction and operations and developing a market for associated service industries; Help meet state renewable energy standard – New Mexico has a requirement that 20% of the state’s electricity come from renewable energy sources by 2020; Protect sensitive lands and the wildlife they support by ensuring development only occurs in appropriate areas; and Provide clean power to reduce carbon emissions and help preserve and protect wildlands, wildlife, water supplies, and communities across America and around the globe.

New Mexico Public Regulation Commissioner Jason Marks says, “Roof-top solar and low-cost, but intermittent wind energy are important parts of our clean energy future. But to truly displace fossil fuels across our region, we will need large solar projects that bring economies of scale and can incorporate cost-effective storage. This kind of development often poses its own environmental impacts. We can minimize those impacts and keep costs to energy consumers as low as possible through initiatives like Smart Solar and the BLM’s focus on proposed Solar Energy Zones on public lands.”

Smart Solar BLM Proposed New Mexico Solar Energy Zones Sierra County

Caballo Reservoir

Lake Lucero

Ri o de an Gr

25

DoĂąa Ana County

70

Otero County

3

54

2

Las Cruces 10

1

New Mexico

BLM Proposed Solar Energy Zone* 25

The Wilderness Society’s Recommendation: Santa Fe

Candidate for Designation 40

Representative Special Status Species Habitat**

Large Map Area

Aplomado Falcon High Suitability Habitat Aplomado Falcon Moderate Suitability Habitat

Albuquerque

25

Aplomado Falcon Low Suitability Habitat

Solar Energy Zone Name

BLM Proposed Acreage

Afton

77,623

Mason Draw

12,909

Red Sands

22,520

Total Acres in New Mexico

Page 28

113,052

Data Sources: * Bureau of Land Management, 2010 ** New Mexico Cooperative Fish & Wildlife Research Unit & New Mexico State University, 2005 *** National Renewable Energy Laboratory, 2011

0

5

10

Miles 20

10

Las Cruces NREL Solar Energy Potential*** Excellent

Very Good

Focusing on Low-Conflict Zones to Promote the West’s Economy, Protect Wildlands, and Build a Clean Energy Future

Afton Proposed Solar Energy Zone.

Photo Credit: Jon Belak, The Wilderness Society

2

Mason Draw Proposed Solar Energy Zone.

Photo Credit: Argonne National Laboratory

3

Red Sands Proposed Solar Energy Zone.

Photo Credit: Jon Belak, The Wilderness Society

New Mexico

1

Page 29

Smart Solar Details on the Proposed New Mexico SEZs The proposed SEZs in New Mexico will take advantage of up-front planning to guide solar projects into areas where they will get clean energy to consumers sooner and at a lower cost, create thousands of jobs and protect the environment. The BLM will continue to refine the proposed SEZs, potentially by removing entire SEZs as well as removing some portions of SEZs based on information the agency is gathering through public comment and its own research. The potential removal of some areas also underscores the importance of ongoing and future efforts to identify new SEZs through the process the BLM will lay out in the upcoming Supplement to the BLM Solar Programmatic Environmental Impact Statement. These efforts will ensure that the solar energy program for our public lands has room to grow for decades to come. Our key recommendations for needed improvements to the SEZs follow. With these improvements, based on what we know now, the proposed New Mexico SEZs are good for solar and good for the environment.

New Mexico

Good for Solar • Great solar potential: the proposed New Mexico SEZs receive so much sun that the National Renewable Energy Laboratory classifies the solar resource as excellent, its highest rating; • Flat landscape: allows for cost effective construction; and • Proximity to existing roads and transmission lines: being close to existing infrastructure speeds development and reduces impacts.

Good for the Environment • No conflicts with protected areas, proposed wilderness, or critical wildlife habitat; • Generally dominated by sparse, shrubby plants that are of low value to wildlife; • Prioritizing low water use solar technologies can limit potential impacts from groundwater pumping; and • Solar power produced in SEZs will reduce our reliance on polluting fossil fuels and help tackle the threats of climate change.

Even the SEZs best suited for development need to address the natural and cultural resources that exist on site. These places may be “flat” but they are neither empty nor unimportant. To ensure that the SEZs are located in areas where solar projects are most likely to be built while minimizing impacts, conflicts and delays, we and our conservation partners have conducted extensive research on the proposed SEZs and made detailed recommendations to the BLM for needed improvements to the boundaries and strategies to address potential impacts at the

Page 30

project level. Key recommendations for each of the SEZs follow.

We have also made general recommendations to improve projects by addressing key potential conflicts and issues wherever they occur, including: • Prioritizing low-water use technologies to protect water resources and groundwater dependent ecosystems; • Protecting water quality; • Minimizing soil erosion and associated damage to vegetation; • Minimizing spread of soil diseases and toxins; • Safeguarding habitat connectivity and wildlife movement corridors; • Avoiding impacts to sensitive species in playa wetlands; • Protecting sensitive ecosystems and associated species, including Aplomado falcon habitat; and • Evaluating proximity to existing or need for new transmission, roads and other associated infrastructure.

Focusing on Low-Conflict Zones to Promote the West’s Economy, Protect Wildlands, and Build a Clean Energy Future

Afton SEZ The proposed Afton SEZ is six miles southwest of Las Cruces in Doña Ana County, New Mexico, just north of the Mexican border. The proposed SEZ is less than a half a mile from I-10, has two existing 345-kV transmission lines through it, and a 115 kV transmission line two and-a-half miles north of the SEZ. Key recommended refinements and strategies to minimize impacts: • Avoid developing projects in areas close to bluffs or cliffs to minimize potential impacts to peregrine falcons; • Avoid sand dune areas to limit potential impacts to sensitive plant species and cultural resources that may occur in such areas. Species that could potentially exist in dune areas within the SEZ include sand prickly pear cactus, sandburg pincushion cactus and sandhill goosefoot; and • Carefully assess cumulative impacts from numerous proposed transmission lines and power plants in the area.

Key recommended refinements and strategies to minimize impacts: • Revise the northeast boundary to remove almost 2,000 acres of overlap with the Sleeping Lady Hills unit of the New Mexico Wilderness Alliance Citizens’ Proposed Wilderness Inventory. This portion of the proposed SEZ is also identified as high-suitability Aplomado falcon habitat; and • Carefully assess cumulative impacts from numerous proposed transmission lines and power plants in the area.

Red Sands SEZ The proposed Red Sands SEZ is six miles southwest of the town of Alamogordo in Otero County, New Mexico. The proposed SEZ is immediately adjacent to US Hwy 70, and three 115-kV transmission lines intersect with the zone. The Red Sands SEZ is in a very rural area in the Tularosa Basin, and is surrounded by military lands including Holloman Air Force Base, White Sands Missile Range, and Fort Bliss. It is also near White Sands National Monument and the Mescalero Apache Reservation. The BLM has already improved this proposed SEZ by excluding areas with ongoing grassland restoration efforts underway. Additional recommended refinements are below.

Key recommended refinements and strategies to minimize impacts: • Addressing potential impacts from groundwater use is particularly important for the proposed Red Sands SEZ. The shallow water table in this area is essential for sustaining habitat for many species of wildlife in the region and in the nearby White Sands National Monument. Of particular concern is the White Sands pupfish, a US Fish and Wildlife Service (USFWS) species of concern, which does not have habitat within the proposed SEZ but could be impacted by groundwater pumping; • Minimize impacts to the White Sands woodrat, a USFWS species of concern, by performing pre-construction surveys and avoiding habitat if it is found; and • Carefully assess cumulative impacts from numerous proposed transmission lines and power plants in the area.

Page 31

New Mexico

New Mexico Congressman Ben Ray Luján says, “From industry to local communities, we must work together to harness the amazing renewable energy potential of our nation. This means collaborating on ways to address the economic and environmental impacts of generating renewable energy on our public lands, especially when it comes to wildlife and habitat. I am encouraged that groups like The Wilderness Society and many others are working with the solar industry and the Obama administration to promote ‘smart zones’ where we can harness solar energy on our public lands with minimal impact to the surrounding environment.”

Mason Draw SEZ The proposed Mason Draw SEZ is in Doña Ana County, New Mexico, 17 miles west of Las Cruces. The proposed SEZ is directly adjacent to I-10 and has a 115-kV transmission line through it.

Smart Solar UTAH Utah’s expansive deserts are known for clear skies and abundant sunshine, providing rich resources for clean, renewable energy from solar projects. The state’s great potential for solar includes three Solar Energy Zones (SEZs) proposed by the BLM on public lands. With the needed refinements detailed here, the proposed Milford Flats South and Escalante Valley SEZs are very good areas for solar development. The proposed Wah Wah Valley SEZ may also be appropriate as a priority solar development area, but as detailed below, we have recommended that the BLM complete a Resource Management Plan for the surrounding area before designating it as a SEZ. The BLM has committed to a zone-based approach to solar development on public lands, and through extensive and ongoing research we and our conservation partners have conducted on the proposed SEZs over the past two years, we have grown ever more confident in our assessment that solar projects built there can generate enough electricity from the sun to power hundreds of thousands of homes and businesses across the West while minimizing environmental impacts. These zones and additional zones to be designated going forward will make an excellent foundation on which to build a solar energy program for public lands in Utah.

Jay Banta, Member of the National Board of Directors and Co-Chair of the Utah State Chapter of Backcountry Hunters and Anglers, says, “People from around the country and the world come to Utah to hunt, fish and spend time with their families in our alpine forests and red rock canyons. By ensuring solar projects are built in appropriate zones, we can protect our natural heritage while harnessing the state’s enormous clean energy potential.”

Avoiding Conflicts, Controversy and Costly Delays Smart Solar – Focusing on Low-Conflict Zones to Promote Utah’s Economy, Protect Wildlands, and Build a Clean Energy Future •

•

•

Utah

•

Increase economic opportunities by generating tax revenue, creating green jobs during project construction and operations and developing a market for associated service industries; Help meet state renewable energy goal – Utah has a goal that 20% of the state’s electricity come from renewable energy sources by 2025; Protect sensitive lands and the wildlife they support by ensuring development only occurs in appropriate areas; and Provide clean power to reduce carbon emissions and help preserve and protect wildlands, wildlife, water supplies, and communities across America and around the globe.

Page 32

A key benefit of focusing on low-conflict SEZs for solar development is the opportunity to avoid sensitive wildlife habitat, wilderness quality lands and important cultural resources when selecting project sites. A project-by-project approach simply will not provide the predictability that developers, land managers, environmental groups and the public need to build a clean energy future at the pace and scale required. In addition, failing to focus on the most appropriate areas puts our natural heritage at risk, threatening key wildlife habitat and wildlands. For example, in Utah, ecologically inappropriate and economically risky areas that could potentially be left open for development if the BLM does not truly focus permitting and construction of solar projects in the SEZs include: • Wilderness quality lands: nearly 400,000 acres of lands being considered for wilderness in Utah, including areas in the culturally rich Colorado Plateau, the remote Dirty Devil wilderness complex, and several impressive mountain ranges and basins in the west desert region.

Focusing on Low-Conflict Zones to Promote the West’s Economy, Protect Wildlands, and Build a Clean Energy Future

Details on the Proposed Utah SEZs The proposed SEZs in Utah will take advantage of up-front planning to guide solar projects into areas where they will get clean energy to consumers sooner and at a lower cost, create thousands of jobs and protect the environment. The BLM will continue to refine the proposed SEZs, potentially by removing entire SEZs as well as removing some portions of SEZs based on information the agency is gathering through public comment and its own research. The potential removal of some areas also underscores the importance of ongoing and future efforts to identify new SEZs through the process the BLM will lay out in the upcoming Supplement to the BLM Solar Programmatic Environmental Impact Statement. These efforts will ensure that the solar energy program for our public lands has room to grow for decades to come. Our key recommendations for needed improvements to the SEZs follow. With these improvements, based on what we know now, the proposed Utah SEZs are good for solar and good for the environment.

Good for Solar • Great solar potential: the proposed Utah SEZs all receive so much sun that the National Renewable Energy Laboratory classifies the solar resource as excellent, its highest rating; • Flat landscape: allows for cost effective construction; and • Proximity to existing roads and transmission lines: being close to existing infrastructure speeds development and reduces impacts.

Good for the Environment • No conflicts with protected areas, potential wilderness, or critical wildlife habitat; • Generally dominated by sparse, shrubby plants that are of low value to wildlife; • Prioritizing low water use solar technologies can limit potential impacts from groundwater pumping; and • Solar power produced in SEZs will reduce our reliance on polluting fossil fuels and help tackle the threats of climate change.

Sara Baldwin, Senior Policy and Regulatory Associate at Utah Clean Energy, says, “Utah Clean Energy has long highlighted the great potential that solar energy offers our state. Prioritizing development in areas with the best solar resources and the fewest conflicts with natural resources will give us the best chance of reaping the benefits of solar on public lands.”

Utah

Even the SEZs best suited for development need to address the natural and cultural resources that exist on site. These places may be “flat” but they are neither empty nor unimportant. To ensure that the SEZs are located in areas where solar projects are most likely to be built while minimizing impacts, conflicts and delays, we and our conservation partners have conducted extensive research on the proposed SEZs and made detailed recommendations to the BLM for needed improvements to the boundaries and strategies to address potential impacts at the project level. Key recommendations for each of the SEZs follow.

We have also made general recommendations to improve projects by addressing key potential conflicts and issues wherever they occur, including: • Prioritizing low-water use technologies to protect water resources and groundwater dependent ecosystems; • Protecting water quality; • Minimizing soil erosion and associated damage to vegetation; • Minimizing spread of soil diseases and toxins; • Performing air quality modeling and dust emissions inventories; • Safeguarding habitat connectivity and wildlife movement corridors – although the SEZs overlap with crucial pronghorn habitat, it is important to note that a significant portion of the entire state of Utah is crucial pronghorn habitat; with good project siting and design to preserve wildlife habitat connectivity, as well as construction planning to avoid disturbance during fawning season, potential impacts to pronghorn can be appropriately addressed and population level effects to this species avoided; • Avoiding impacts to sensitive species in playa wetlands; • Avoiding desert tortoise critical habitat and using best practices for tortoise relocation; • Protecting sensitive ecosystems and associated species, including Utah prairie dog and greater sage-grouse; • Designating ecological reference areas that could provide control areas for researching impacts of utility-scale solar development and could inform future efforts to minimize and mitigate impacts; and • Evaluating proximity to existing or need for new transmission, roads and other associated infrastructure.

Page 33

Smart Solar BLM Proposed Utah Solar Energy Zones Beaver County 1 Milford

Beaver River

3

Iron County

Minersville Reservoir

15

2

BLM Proposed Solar Energy Zone* The Wilderness Society’s Recommendation: Candidate for Designation

Ogden

Representative Special Status Species Habitat**

Large Map Area 80

UDWR Greater Sage-Grouse Habitat Solar Energy Zone Name

Provo

BLM Proposed Acreage

Escalante Valley

6,614

Milford Flats South

6,480

Wah Wah Valley

6,097

Total Acres in Utah

15

19,191

Utah

Data Sources: * Bureau of Land Management, 2010 ** Utah Division of Wildlife Resources, 2010 *** National Renewable Energy Laboratory, 2011 0

5

Page 34

10

Salt Lake City

Miles 20

NREL Solar Energy Potential*** Excellent

Good

70

Focusing on Low-Conflict Zones to Promote the West’s Economy, Protect Wildlands, and Build a Clean Energy Future

Wah Wah Valley Proposed Solar Energy Zone.

Photo Credit: Jon Belak, The Wilderness Society

2

Escalante Valley Proposed Solar Energy Zone.

Photo Credit: Jon Belak, The Wilderness Society

3

Utah

1

Milford Flats South Proposed Solar Energy Zone.

Photo Credit: Jon Belak, The Wilderness Society

Page 35

Smart Solar Escalante Valley SEZ The proposed Escalante Valley SEZ is located in Iron County in southwestern Utah, 30 miles northwest of Cedar City.

Situated in the south-central part of the Escalante Desert, Escalante Valley SEZ is bounded by the Black Mountains and the Antelope Range to the south, the Shauntie Hills and Wah Wah Mountains to the northwest, and the Mineral Mountains to the northeast. State Route 56 is 15 miles south of the proposed SEZ, a 138 kV transmission line is three miles southeast of the SEZ, and a high voltage DC transmission line is 4.5 miles south of the SEZ. Key recommended refinements and strategies to minimize impacts: • Perform pre-development surveys for Utah prairie dog, which has occupied habitat in the area; development should not impact occupied habitat or compromise connectivity between occupied colonies; • Perform pre-development surveys for greater sagegrouse, which could potentially have habitat in the area; development should not impact occupied habitat or compromise connectivity between seasonal habitat areas; and • Avoidance of the dry lakebed in the southwest of Escalante Valley and dry washes is recommended to prevent impacts to Great Basin spadefoot and Great Plains toad.

Utah

Milford Flats South SEZ The proposed Milford Flats South SEZ is located in Beaver County in southwestern Utah, 28 miles north of Cedar City.

Situated in the northeastern part of the Escalante Desert, Milford Flats South SEZ is bounded by the Black Mountains to the south and southeast, the Wah Wah Mountains to the west, and the Mineral Mountains to the northeast. The nearest major road is State Route 21, which lies five miles to the east. The nearest existing transmission is a high voltage DC line two miles to the northwest of the proposed SEZ. Key recommended refinements and strategies to minimize impacts: • Perform pre-development surveys for Utah prairie dog, which has occupied habitat in the area; development should not impact occupied habitat or compromise connectivity between occupied colonies; and • Perform pre-development surveys for greater sage-grouse, which could potentially have habitat in the area; development should not impact occupied habitat or compromise connectivity between seasonal habitat areas.

Page 36

Wah Wah Valley SEZ The proposed Wah Wah Valley SEZ is in the middle of the Wah Wah Valley and State Highway 21 runs down the middle of the SEZ. This is the most remote of the three Utah SEZs, with the town of Milford 20 miles to the east and the nearest major town, Cedar City, 50 miles to the south. A high voltage DC transmission line is 18 miles east of the proposed SEZ. While there don’t appear to be natural resource conflicts within the proposed Wah Wah Valley SEZ that would make it inappropriate for designation, the BLM has never applied its standard land management planning process (a Resource Management Plan, or RMP) to this area. Completing this process is important for understanding how solar development would affect the landscape in the context of the range of current uses and conditions. For this reason, we recommend that the BLM prioritize the designation of the Milford Flats South and Escalante Valley SEZs and de-prioritize the designation of the Wah Wah Valley SEZ until an RMP is completed for the area.

Key recommended refinements and strategies to minimize impacts: • The BLM should complete an RMP for this region to evaluate solar development in the context of current conditions and uses as well as potential impacts to special status species and other resource values and uses.

Jim Byrne, Utah Director of the Western Grid Group and member of the Utah Renewable Energy Zone Task Force, says, “Smart planning for solar development is critical for the West’s economy and environment. Guiding projects to lowconflict zones can also help prioritize transmission line access, helping resolve the “chicken and the egg” conundrum facing solar developers and transmission planners looking to access location constrained renewable energy resources.”

Focusing on Low-Conflict Zones to Promote the West’s Economy, Protect Wildlands, and Build a Clean Energy Future

The Wilderness Society thanks our conservation partners for the excellent and ongoing collaborative work to analyze the BLM proposed Solar Energy Zones, and the many people working to support environmentally responsible renewable energy development on public lands.

Portions of this document include intellectual property of ESRI and its licensors and are used herein under license.

Copyright © 1999-2008 ESRI and its licensors. All rights reserved.

Aerial imagery data used in state maps were acquired in 2009-2010, and were obtained through The U.S. Department of Agriculture Farm Service Agency’s National Agricultural Imagery Program online map service. http://www.fsa.usda.gov/FSA/apfoapp?area=home&subject=prog&topic=nai Analysis for determining distances to existing transmission lines for all Solar Energy Zones was completed using the following data source: POWERmap, powermap.platts.com ©2011 Platts, A Division of The McGraw Hill Companies.

All cartography completed by Jon Belak, The Wilderness Society Designer: Greg McBride (www.gregmcbride.com) For more information, please contact Alex Daue at The Wilderness Society’s BLM Action Center (303) 650-5818 x108, alex_daue@tws.org, or visit our website at www.wilderness.org/smartsolar Front Cover, Inside Front Cover, and Back Cover Photos: • Left Photo: Gillespie Proposed Solar Energy Zone, Arizona Photo Credit: Jon Belak, The Wilderness Society • Center Photo: Photovoltaic Solar Panels Photo Credit: U.S. Department of Energy • Right Photo: Home at Night.

Photo Credit: ©iStockphoto.com/EricVega

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