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Johanna Wald’s Blog

Clearing Up the Record on Solar Energy on Public Lands

Johanna Wald

Posted February 10, 2012

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This week, Los Angeles Times published the first article of a long-awaited series about the impacts of large scale-solar projects on the Mojave Desert. Unfortunately, the first story failed to provide a fully accurate picture of the reality and efforts underway to ensure we have a robust and successful national solar program.

As I have discussed in my blogs, I’ve spent my entire career – almost 40 years – protecting America’s public lands. My mission at NRDC was straightforward: to preserve our forests and rangelands, wilderness areas, wetlands, free-flowing rivers and beaches from destructive activities such as coal mining, oil and gas drilling, road construction and other commercial development. But our changing climate is changing everything, including our conservation goals. We are faced with hard choices. Those choices entail trade-offs, but I have confidence we’re going to be able to strike the right balance.

About three years ago, I learned two things: The first one was that climate change was already having real impacts on the lands and resources that I have been working for so long to protect, and the second was that that there were more than 100 pending applications for renewable energy projects, both wind and solar, in areas of California that I had devoted a lot of time and effort to protecting.

And I had an epiphany – I realized that everything that I had worked for in my career was threatened directly by climate change or by unmanaged renewable energy development. So I switched not only the focus of my work but how I did it in order to facilitate environmentally responsible renewable energy development.

I did it not through litigating but through consensus building efforts, involving conservation groups, utilities and solar energy companies, federal and state regulators and many other stakeholders. And when I saw through those efforts what good could result, I embarked on an exciting and yet challenging undertaking to help develop a robust national solar energy program that would provide a balanced approach to protecting important landscapes and wildlife while helping the solar industry to succeed.

In 2009, the Bureau of Land Management saw a 78 percent increase in applications for solar energy projects on public lands, from 107 to 223 that were pending review, and only 2 projects had progressed to the stage of environmental reviews. Funding made available during this time through the American Recovery and Reinvestment Act helped “fast-track” the permitting of nine large-scale solar projects for development on public lands, including BrightSource’s Ivanpah project.

But despite the Los Angeles Times’ suggestion, NRDC was never involved in moving that project forward.  Rather, our only engagement was to submit detailed comments to the BLM and to the Interior Department in the public review process before the agencies made their final decision on permitting it. (See full comments here).

It is true that many of the first projects that came out of the gate, Ivanpah included, raised serious concerns about the immediate and long-term environmental impacts on public lands, wildlife and other natural resources.  Here are some reasons why this happened:

  • In the absence of any policy or guidance from the BLM as to what were appropriate sites for solar development, companies got a free hand in selecting the sites they wanted to develop on public lands
  • The selection process for these sites unfortunately didn’t incorporate environmental and cultural heritage considerations – something that Interior, BLM, environmental and conservation groups and many other stakeholders have been working to ensure are an underlying aspect of the siting process going forward
  • BLM had no history of dealing with this new type of energy resource, which is very different than oil and gas. On the contrary, the agency had little expertise in permitting these types of projects
  • Insufficient and inconsistent environmental reviews at the front end of the planning process and major investments by solar developers made it difficult to ”fix”  these projects and in many cases resulted in costly modifications to lessen some of their impacts

The Los Angeles Times comparison of solar to oil and gas development on public lands is also misreported as is the important progress by Interior and BLM in prioritizing environmentally responsible development on public lands. In fact, my colleague Jessica Goad from the Center of American Progress has detailed in a blog some of the key facts that the article overlooked. Here’s a summary from her excellent post:

  • The 21 million acres is the amount of public land that could be made available to solar energy development in six western states – AZ, CA, CO, NV UT, NM – rather than the amount that will be eventually leased. These preselected lands have the fewest environmental conflicts and high solar potential
  • Of the 21 million acres of land that BLM proposed to make available for solar projects, Interior announced in October 2011, in response to more than 100,000 public comments, that it would give incentives and preference to projects sited within 285,000 acres of ‘solar energy zones’ 
  • All in all, 7 solar projects were given the green light on public lands in California as of the end of 2011, totaling approximately 28,000 acres. And an Interior Department analysis suggests that the most solar that would likely be developed on BLM land in six western states over the next 20 years is 214,000 acres
  • In a report released in May 2011, the Interior stated that, “currently, 38.2 million acres of public lands are under lease for oil and gas devel­opment, of which 16.6 million acres are ac­tive and 21.6 million acres are inactive
  • According to a Wilderness Society analysis, over 50 million acres of public lands are already available to oil and gas in five states – CO, NM, MT, UT, WY

While some have called for a complete ban on large scale solar projects on public lands in favor of  deployment of much smaller power generation options such as rooftop solar,  the reality is that small-scale generation, by itself, even with an aggressive target, is not sufficient.

NRDC’s detailed analyses of this issue have revealed that along with greatly increased energy efficiency, energy conservation and roof-tops and other important measures, we need large scale projects to meet our climate goals. Even though we need large scale projects, however, we still must make every effort to ensure that these projects are built on appropriate places. Simply put, we need a broad portfolio of solar power projects – big and small, urban and rural, and on appropriate private and public lands – to meet our current climate goals.

Designing a solar program that balances the nation’s need for increasing solar production from public lands and the need to protect the publicly owned resources of those lands is a tall order. We believe that a ‘solar energy zones’ approach – which the Interior Department recently endorsed – is the right way to go.

Interior’s solar zones based approach would guide solar projects to the appropriate places – areas with high solar potential – helping minimize impacts to wildlife and sensitive lands while reducing risk and uncertainty for investors. A solar program like the one Interior has proposed is a major step toward achieving the right balance, and we look forward to continue working with Interior and the BLM, conservation groups, the solar industry and utilities to develop a strong and comprehensive final program.

The planet is changing and we must change with it. The traditional conventions –including some traditional conventions of the environmental community – must yield to the new realities. Our greatest challenge today is to make the hard choices that will provide the greatest environmental benefit for all and result in the fewest impacts to wildlife and wild lands.

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Ron DickersonFeb 15 2012 04:09 PM

Ms. Wald,

First of all, I concur with your view that the LA Times article did not provide a fully accurate picture regarding the development of utility scale solar in the desert southwest. However, considering the breadth of the issues involved, doing so would require nothing less than a tome equal in volume to the US tax code. That said, I submit the first article in the series provided a succinct and well reasoned analysis regarding mainstream environmental organizations involvement and/or lack thereof in the energy planning and permitting processes. As the second article in the series reveals the net effects of such inadequacies--potentially needless destruction and waste of citizen's resources is underway...

In your bullet points, you appear to be making excuses for the poor permitting of the iconic Ivanpah project and shifting the blame to Agency policy and site selection shortcomings. As a citizen who has followed integrated renewable resource planning for more than five years, I disagree with those arguments. First of all, as the Times article shows, some agency whistle blowers are the most vocal critiques, while a sickening silence is emanating from trusted environmental orgs. Additionally, as you well know, the NRDC and other NGOs have been intimately involved in various upfront State and Federal Agency sponsored renewable planning initiatives, as "environmental stakeholders". One of the initiatives was key to utility scale renewable development: RETI was specifically for the purpose of creating an inventory of renewable energy zones and rank those areas in a manner that upfront and properly informed downstream selection processes. While highly touted and indeed informative, RETI is proving to be inadequate in addressing key environmental concerns. I believe it fair to say the you and your NRDC colleague, Carl Zichella (representing the Sierra Club at the time) as the appointed/selected environmental representatives share a good portion of that blame. After many hours spent in witness of the RETI study process (equal participation by individual citizens was not allowed) my retrospect view is the environmental representatives should have focused far less on promoting transmission expansion and spent far more energy in securing the protection of sensitive sites, and the most efficient use of existing infrastructure.

To be fair, I'm not one that lays the blame for shortcomings solely at the feet of environmental NGOs. The issues involved are highly complex, and are beyond the scope and typical expertise of traditional environmentalists. Generally speaking, a very small percentage citizens, if any, are prepared or have the resources to adequately participate in the planning and permitting of energy infrastructure and the majority of folks who are concerned participate in a de-facto manner by contributing to environmental NGOs such as the one you work with.

Agendas and objectives of org.s such as NRDC have created a situation where a host of unneeded compromise and downplaying of beneficial alternatives has been decided upfront, often to the dismay of grassroots contributors. What the results in the Mojave are revealing is that it is not in the best interests of the public to rely solely upon traditional environmental NGOs to provide needed advocacy for protecting treasured lands, habitat and the cultural heritage shrines that rest there.

Ron Dickerson

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