California Native Plant Society
2707 K Street, Ste. 1 l Sacramento, CA 95816-5113 l (916)447-2677 l FAX (916)447-2727
December 23, 2009
BLM California Desert District
22835 Calle San Juan de los Lagos
Moreno Valley, CA 95814
Re: Solar Millenium Ridgecrest solar project (CACA-049016) PSA/DEIS scoping comments from the California Native Plant Society
To whom it may concern:
Please accept and fully consider these comments submitted on behalf of The California Native Plant Society regarding the development of a draft Environmental Impact Statement (DEIS) for the proposed Solar Millenium Ridgecrest solar project (CACA-049016).
The mission of The California Native Plant Society (CNPS) is to conserve California native plants and their natural habitats. CNPS supports renewable energy generation via large-array utility scale projects only when sited on already-disturbed lands, e.g., brownfield and fallow agricultural lands. We oppose the siting of large-array renewable energy projects sited in functionally intact desert areas on public trust lands, especially as the first option. We hope the DIES process for this project will produce an environmental analysis that allows for the development of renewable energy resources in a manner that protects the existing vast, intact, functional character of the southwestern desert ecosystem.
The California Desert is a unique and special environment, as recognized by Federal Land Policy Management Act in establishing the California Desert Conservation Area. The vast landscape is home to diverse biological communities, cultural sites, scenic and wild places, and other valuable areas which survive despite pressures from various human activities over the past century. The desert lands also sequester carbon, both by desert plants and by microbes living throughout the fragile desert crust, which represents a benefit in the state’s effort to reduce carbon emissions. These lands also are attractive for renewable energy projects, and have fueled a rush by companies to file applications on public lands for potential projects. The need to find alternatives to carbon based energy is great.
In California, we are moving forward to meet a Renewable Portfolio Standard of 33% by 2020, a goal which is widely supported as necessary to address climate change. CNPS strongly endorses increased conservation, energy efficiency and demand-side management actions of the sort that California has pioneered, but we recognize that, despite those efforts, it is likely that some utility scale projects will be sited in the desert, potentially as early as December 2010. It is of critical importance that they be sited appropriately.
More specifically, we would like to offer the following recommendations regarding the development of the DEIS for this project:
Purpose and Need/Cumulative Impacts:
The DEIS should address risks associated with global climate change including both the need for climate change mitigation strategies (e.g., reducing greenhouse gas emissions) and the need for climate change adaptation strategies (e.g., conserving intact wild lands and the corridors that connect them). Renewable energy projects are elements of a national climate change mitigation strategy to reduce greenhouse gas emissions. Several California state, national, and international climate change reports describing climate change adaptation strategies underline the importance of protecting intact wild lands and associated wildlife corridors as a priority adaptation strategy measure.
The habitat fragmentation, loss of connectivity for terrestrial wildlife, and introduction of predator and invasive weed species associated with other proposed solar thermal projects in the Mojave desert are anathema to an effective climate change adaptation strategy. Siting projects within vast, functionally intact ecosystems rather than on disturbed lands confounds climate change adaptation strategy with a poorly executed climate change mitigation strategy. CNPS maintains that the solution to this problem is to build and operate the large-scale utility scale projects in sites away from intact wild lands. The way to maintain healthy, vibrant ecosystems is not to fragment them and reduce their biodiversity. The DEIS needs to assess whether the proposed project does more to protect or reduce native biodiversity if built at this location.
Biological Resources:
Special Status Plants and Special Status Plant Communities
The DEIS must identify and analyze the loss of carbon sequestration that will occur under the proposed project. Desert vegetation types are able to sequester atmospheric carbon dioxide (greenhouse gas) 24 hours/day, unlike other vegetation communities that are able to sequester CO2 only during daylight hours. The proposed project, and all desert utility-scale projects to follow, will decrease the carbon sequestration benefits from desert vegetation. These impacts should be identified and analyzed in the DEIS.
CNPS recommends the DEIS address project impacts to rare, threatened, and endangered plants within study areas by following policies and guidelines outlined in BLM Special Status Plan Management Manual 6840-1, and BLM Management Manual Supplement H-6840.06, both available on-line via the BLM website at (respectively):
http://www.blm.gov/ca/pdfs/pa_pdfs/biology_pdfs/SpecialStatusPlantManagement.pdf
and
http://www.blm.gov/ca/pdfs/pa_pdfs/biology_pdfs/6840.06-supplement.pdf.
In particular, CNPS recommends that the DEIS maintain the following BLM policies and guidelines:
1. Federally listed threatened and endangered plant taxa, and those proposed for federal listing will be addressed as per the requirements of the federal Endangered Species Act
2. For Candidate Plant Species, the BLM will carry out management, consistent with the principles of multiple use, for the conservation of candidate plant species and their habitats and will ensure that actions authorized, funded, or carried out do not contribute to the need to list any of these species as Threatened or Endangered. Specifically, the BLM will adopt the guidelines outlined in BLM Special Status Plant Manual Supplement 6840-06 section C.
3. California State listed plants and CNPS List 1B plants are recognized as BLM Sensitive Plant Species and will be given the same level of protection as Candidate Plant Species and all of the policy statements given for candidate species apply equally to sensitive plant species (cf. BLM Special Status Plant Manual Supplement 6840-06 section C).
4. The probability of occurrence of rare plants must be considered as High, project's Habitat Disturbance Level within each SESA much be considered as High, and therefore all botanical inventories conducted as part of an environmental review within each SESA must meet a minimum intensity level of Complete as defined in BLM Special Status Plan Management Manual 6840-1 sections III.E.1 and III.E.2.
5. Many special status plant inventories of public lands conducted to assess the impacts of a project are performed by consultants hired by project proponents. Personnel conducting botanical inventories within projects must have strong backgrounds in plant taxonomy, plant ecology, field sampling design and methods, and knowledge of the floras of the area to be inventoried. Such qualifications help to ensure that all special status plants occurring in the area to be inventoried will be located, including those that were not predicted to occur at the start of the inventory. Therefore, botanical survey personnel requirements must meet the qualifications outlined in BLM Special Status Plan Management Manual 6840-1 section III.D.1.
6. In order for the BLM to adequately determine the quality of such third party inventories, CNPS recommends full floristic botanical surveys be conducted as per the CNPS Botanical Survey Guidelines and the California Department of Fish & Game Guidelines for Assessing the Effects of Proposed Projects on Rare, Threatened, and Endangered Plants and Natural Communities. Both available online via the following websites:
For CA DFG Guidelines:
http://www.dfg.ca.gov/biogeodata/cnddb/pdfs/Protocols_for_Surveying_and_Evaluating_Impacts.pdf
For CNPS Guidelines:
http://www.cnps.org/cnps/rareplants/pdf/cnps_survey_guidelines.pdf
A lack of fall surveys may under-represent the full suite of rare plant taxa occurring on site. Full florisitic surveys performed during late summer/early fall must be done in order to obtain a more complete census of desert plant taxa occurring at the proposed project site. Botanical surveys should be deemed inadequate until additional surveys are conducted in late summer and fall in a year with adequate summer rainfall.
CNPS further recommends that the DEIS assess project impacts to plant taxa occurring within the project area that are considered rare within California but more common elsewhere. These taxa represent plants occurring at the periphery of their population ranges and whose genetic stock may represent biological factors critical to a taxon's ability to adapt to changing climatic conditions. These plant taxa are listed as CNPS List 2 plants.
We appreciate the opportunity to provide these DEIS scoping comments for the proposed Ridgecrest solar project. CNPS will continue to remain actively involved throughout all phases of the planning effort.
Sincerely,
Greg Suba
Conservation Program Director
California Native Plant Society
2707 K Street, Suite 1
Sacramento, CA 95816
916-447-2677 x-206