An Array of Solar Panels (San Bernadino County, California), Photograph Attribution: Bureau of Land Managent

INTRODUCTION

 

 

March 11th, 2021

 

Miriam Liberatore, Project Manager

Bureau of Land Management,

Palm Springs South Coast Field Office

1201 Bird Center Drive

Palm Springs, CA 92262 www.blm.gov/office/palm-springs-south-coast-field-office.

Re: 2831-03 (P) CAD0000.06/CAD060 CACA-51967

Final Environmental Impact Statement and Proposed Land Use Plan Amendment to the California Desert Conservation Area Plan for the Crimson Solar Project.  Public Comments Due 3-15-21

 

Dear Ms. Liberatore: 

The Environmental Review Workshop has reviewed the Final Environmental Impact Statement (EIS) and Proposed Land Use Plan Amendment to the California Desert Conservation Area Plan (PA) for the Crimson Solar Project (Project). As taxpayer citizens who are concerned about developing alternative energy capacity while conserving natural areas and the environment, we have an interest which is or may be adversely affected by the planning decisions in the EIS. 

We request that the Bureau of Land Management (BLM) choose Alternative B as the preferred alternative and offer the following comments in support of our position:

1. We find that the biological minimization and mitigation measures proposed for the “preferred alternative” Alternative A (Appendix I; EIS) are not sufficient so as to result in negligible effects to sensitive and rare species including:

 

1. The federally listed Mojave Desert tortoise (Gopherus agassizii). Photo by USFWS. 

   

Permanent tortoise exclusion fences will be placed around the project. Why is an alternative that allows tortoises back into the solar field during operation not analyzed? 

The latest sampling data from surveys analyzed by US Fish and Wildlife Service indicates all Recovery Units have declined drastically from 2004 to 2014 except for the Northeastern Mojave Recovery Unit (USFWS. 2019. Status of the Desert Tortoise. Desert Tortoise Recovery Office. December 4, 2019). Current data indicate a continued decline across the range of the listed species despite its protected status and recovery actions.

2. The  BLM Sensitive Mojave Fringe-toed lizard (Uma scoparia). Photo by USFWS.

   

Mojave fringe-toed lizards are documented on dune and non-dune habitat on the proposed project site. Avoidance of rare sand habitats would reduce significant impacts to none.

Desert Dune habitat will have to be mitigated at an estimated 1,636.8 acres, but the BLM and CDFW have no idea whether enough compensatory land can be found locally, what condition the land is in, and how sand connectivity relates to dune habitat lost on the project. 

3. Special-Status Plant Species including Harwood’s eriastrum (Eriastrum harwoodii), Utah vine milkweed (Funastrum utahense), ribbed cryptantha (Johnstonella costata),and desert unicorn plant (Proboscidea althaeifolia).

Seedbanks may shift in different years, and some may not germinate in dry years so the actual locations of rare plant populations are likely unknown, and many could be graded. 

The mitigation measure BIO- 20 is unclear whether Special-Status Plant Species will be avoided in the solar field, or whether the solar panels will be constructed on top of the rare plants, and the vegetation simply trimmed. 

2. Public awareness

With the choice of Alternative B, the opportunity is present to create positive, public awareness of large scale solar plants that incorporate habitat protection and mitigation measures. The efforts already undertaken with newspaper articles and press releases to advertise scoping meetings for this development seem to be comprehensive.

It is indicated that the “entire suite of planned projects” is uncertain due to funding, schedules, etc. The adaptive management concept with this aspect will be important. 

Cumulative effects from development need to be kept on the radar. The actual vs. projected effects on wildlife and increased cases of valley fever due to fugitive dust will be important. Twenty public notices were sent to property owners during the planning for the development. Concise monitoring report fact sheets sent to the same owners could be helpful in showing further responsibility and building trust for further sustainable development within the suite of planned projects. 

3. Water resources and greenhouse gas emissions (GHG) calculations

In Appendix J, Section 2.1, the section should be updated to include the latest Proposed Rule: The Safer Affordable Fuel Efficient (SAFE) Vehicles Proposed Rule for Model Years 2021-2026.

a. An extensive execution phase water usage GHG impact due to electricity usage for water pumping should be included for activities like water pumping during the 17 month construction phase.

b. There are limited comments on the water quality impact in the EIS. A  plan for management of waste water generated during operations phase should be included in the document

 

We respectfully request that BLM choose Alternative B as the preferred alternative.

When responses to these comments are available, please email those or notify us where they can be viewed if they are posted for public viewing on your website.

Sincerely yours,

 

Andrew Lewis, M.S.

Environmental Reviewer (Associate in Utah)

Environmental Review Workshop

(Environmental Review, Inc., a 501(c)(3) Nonprofit Public Benefit Corporation)

1792 Rogers Avenue

San Jose, California  95112

 

Rachana Malviya Ph.D.

Environmental Reviewer (Associate in Tennessee)

Environmental Review Workshop

(Environmental Review, Inc., a 501(c)(3) Nonprofit Public Benefit Corporation)

1792 Rogers Avenue

San Jose, California  95112

 

Janet Fox B.S.

Senior Reviewer (Associate in Arizona)

Environmental Review Workshop

(Environmental Review, Inc., a 501(c)(3) Nonprofit Public Benefit Corporation)

1792 Rogers Avenue

San Jose, California  95112