Thursday, August 26, 2010

With an email, you can help in the fight to save Ivanpah.

But we only have about a week to get this done.

It seems that the California Energy Commission may be concerned about the
public’s opinion of this project. If enough comments come in, they may delay
their decision. Any significant delay, of course, would delay the tortoise roundup
planned, possibly beyond the deadline, resulting in a possible still-birth of this
boondoggle due to the federal ARRA funds being cutoff, since groundbreaking must occur by yearend to qualify to receive the loan guarantees.

Over at Coyote Crossing, there is an interesting post about this.

Here is the information that I received in an email from Chris at Coyote Crossing which
goes into the details about who can comment(anyone but California residents may have
more pull), the address and format of the comments, as well as suggested topics from
the folks at Basin and Range Watch.

I can not emphasize enough that time is of the essence here. We have about 1 week to
get our voices heard as the deadline to send the comments is September 2nd. It appears also from my reading of the email that a paper copy must also be sent via the postoffice in
addition to your email.

Here is the copy of the email with all the information:

What you're commenting on is formally known as, drumroll please, the California Energy Commission's Presiding Member's Proposed Decision on the BrightSource Energy application for the Ivanpah Solar Electric Generating System (ISEGS).


That's from now on referred to as the PMPD. It is readable here: and it's going to be very helpful to you to at least scan it. There will not be a quiz. However, a sentence or to lifted from the document and referred to in your comments will definitely make your comments sound more authoritative.


Public comments on the PMPD are accepted until September 2. I'm sending this on Wednesday August 25, so that's a week from tomorrow. Getting them emailed AND postmarked earlier than that is not a bad idea.

The California Energy Commission "encourages" the public to comment on the PMPD The Notice (with an address) reads:

The Members of the public and governmental agency representatives are encouraged to submit their written comments by the close of the 30-day review period. The Energy Commission encourages comments by e-mail. Please include your name or organization's name in the name of the file. Those submitting attached comments by electronic mail should provide them in either Microsoft Word format or as a Portable Document (.pdf) to []. One paper copy must also be sent to the Energy Commission's Docket Unit, 1516 Ninth Street, MS-4, Sacramento, CA 95814. Identify all comments with "Docket No. 07-AFC-5."

[NOTE the requirement for mailing a paper copy.]


California residents probably have somewhat more pull here. However, the lands at issue are owned by all US citizens, and so US citizens have every right to comment. Some people reading this aren't US citizens, and that's fine: everything that reminds the CEC that *people around the world are paying attention here* is good, and besides, the Mojave Desert is a world-class tourist destination — anything that interferes with the visual resource and wildlife resource elements of that desert erodes the standing of the Southwest states in the global economy, long-term. Who travels ten thousand miles to visit a mirror factory?


There are significant identified issues with the PMPD. Pasted below are notes taken by Basin and Range Watch's Laura Cunningham describing a whole lot of those issues that have been brought to the CEC's attention, and additional public comment on those issues will likely generate more willingness to reconsider those topics. But let me remind you that what's important here is not that you send in exhaustive effort-filled comments: simply mentioning that you're concerned about the topics and feel they have not been adequately addressed is fine. Or you can keep it general and talk about public lands — YOUR public lands — being handed over to industry. No one expects you to pretend to expertise you do not have — in fact, that'd probably hurt. What does count is that you are who you are and you're concerned about this destruction of the desert, and that you're saying so in your own words — which is why we aren't doing one of those boilerplate cut-paste email petition things.

Thank you again.

begin notes from Laura C:

CEC must fulfill its duties under CEQA and California Endangered Species Act if it will issue a permit (under the authority of California Department of Fish and Game) for "take" of tortoise. It is not fulfilling its duties.

The whole translocation plan for tortoises is in draft form, and is not even available for public review in part. New guidance from US Fish and Wildlife Service says "relocation" is under 500 meters, and "translocation" is over 500 m, but this is only to inform decisions about testing for disease (blood samples drawn to test for Upper Respiratory Tract Syndrome). But the differences is meaningless to the tortoise. Whenever you move a tortoise into an area with a resident population of tortoises already present, there is the potential for agonistic behavior (aggression) on the part of the residents when a newcomer invades it home range. This often causes the newcomer to move away long distances.

Currently some of the tortoises would be relocated short-distance to the west and north of the project "out of harm's way" yet these very areas are also slated for solar developments and two high-speed train routes. This will not guarantee tortoises are safe in the future.

Mojave National Preserve has not yet agreed to be the recipient site for long-distance translocated tortoises, but if this option is chosen, full separate NEPA review should be undertaken for this action.

No translocation or relocation of any kind should be done, as it is problematic and tortoises are in decline rangewide. Documents obtained by Freedom of Information Act from agencies involved in the Fort Irwin Expansion tortoise translocation show that the effort there failed. Tortoises were moved staring in March 2008, to December 2009: 44.3% died and 17.4 % are missing. This happened mostly from coyote predation. Coyotes are present also in the Ivanpah project site. Translocation may do more harm than good, as it can spread diseases into the host population. Disease testing does not always work, and not all diseases are tested for. The August 2010 Draft Independent Science Advisors Report for the Desert Renewable Energy Conservation Plan recommends against translocation/relocation of tortoises.

During the hearing no plans to fence Interstate 15 were made, to keep these wandering tortoises from going on the highway, and BrightSource should at least be made to pay for this.

The Ivanpah Valley is within the Northeastern Recovery Unit, which has tortoises with very unique genetic make-up. It is imperative that any mitigation land acquired by the applicant for the loss of tortoise habitat be kept within this northeastern Mojave Desert area, not across the desert as CEC has allowed. Because this genetic population is unique, and the Ivanpah Valley is the only place in California which contains it, no projects should be allowed to destroy tortoise habitat and take (kill) tortoises.

There are so many changes to the FEIS and SA that have not been fully vetted in evidentiary hearings or public review that the project needs to be delayed so that the public can review everything.

The Tortoise Translocation Plan has changed significantly, is still a draft, and part of the plan has not been circulated to the public.

Moving tortoises any distance (whether relocation or translocation) is stressful to the tortoises and should not be done. Translocation is not mitigation, it only reduces "take" (mortality), therefore it should not be considered as reducing impacts to tortoises to less than significant levels.

How will wildfires be fought by the limited San Bernardino County fire and emergency services? Many other large projects are proposed for Ivanpah valley, is this being taken into account?

How will the loss of 4,000 acres of recreational land next to the Mojave National Preserve be made up for? People use this valley for camping, hiking, birdwatching, rockhounding, and wildlife viewing.

I do not want a "Solar and Ecological Interpretive Center" to replace the experience of hiking and being out in a quiet wild desert. (This is a mitigation proposal the county is pushing for the site).

The vistas of the desert will be destroyed by industrialization and glare.

How will we be assured that rare birds on Clark Mountain (an Internationally Important Bird Area according to Audubon) will not be killed by the three giant power towers? Whippoorwills, Hepatic tanagers, and Gray vireos breed here, and the first two species nowhere else in California.

How will rare plants be conserved and truly mitigated for? Placing fences around individual plants in the middle of the solar field will not save these plants. How will the applicant know where to buy mitigation land that has the same rare plants on them?

How will the public be guaranteed a return on its large investment if the project is subject to ongoing heliostat failure by flash floods? This project site is on an active floodwash alluvial fan below Clark Mountain.

The project is speculative, being a scaled-up version of a 6 MW test power tower. It is 370 MW, and how is the public assured that it will work?”

I know I have posted in the past that I felt the comment periods were just a feel good mechanism, kind of like a relief valve, and that the decision may have already been made.
I was wrong. Folks, I trust Chris at Coyote Crossing and Laura and Kevin over at Basin
and Range Watch, if they say there’s a chance of stopping or delaying this project by
submitting our comments, I believe them. I am aboard. I will definitely be commenting,
just one voice opposing the project among many voices, no better or worse than any other.

The whole key is to get a bunch of people to write about this. The main thing is we need
people to write.

If I can do it, so can you. I sincerely hope that you do.

In closing, let me tell you what happened to me yesterday.

I went back up to the Big Morongo Canyon Preserve, in that major heat wave, to get
away from this giant megalopolis, to get back to nature, and to think about what next to
do about this Ivanpah situation. I realized very quickly that a return visit there to do a farewell hike at this time is out of the question for me, it’s even hotter there than at Big
Morongo was yesterday, and I barely made the ridgetop to ridgetop hike. I don’t know if
I was just exhausted or what, but when I was coming down from the ridgetop on the Yucca Ridge trail, on my way back to civilization, it hit me that it might be all over at Ivanpah, and
such a wave of sadness hit me, my eyes welled up, I had to stop for a moment to wipe
my eyes so I could see- but I continued on and drove back home.

Once there, online, I discovered that maybe all isn’t over with Ivanpah.



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