ReWire posted an update on the RE-Powering America's Land mapping tool updated by the Environmental Protection Agency the other day, and we described it as an important aid in proper siting of renewable energy facilities on land that's already been abused. We stand by that assessment. But we've heard some reaction to our piece that criticized the EPA's maps for including sites that the readers don't think should be developed. We agree with them. Here's why.
As we mentioned, the EPA expanded its mapping tool significantly before its re-release last week. The maps, downloadable as Google Earth kmz files, now include about 66,000 sites nationwide, up from around 24,000 in the previous version. The sites include contaminated "brownfields" abandoned and closed mine properties, and landfills that the EPA, in its first-pass examination of the sites, has determined may be suitable for renewables development.
Since the release of the first version of the mapping tool, many environmentalists who have been concerned about losing prime habitat or productive farmland to renewable development have seized on the RE-Powering America's Land initiative as an alternative. Given that the EPA has gone to all the trouble to identify places where the land's already pretty much trashed, they point out, shouldn't relevant state and federal governments be looking at those places first for development rather than old-growth desert or thriving farms?
It's a valuable argument. The fact that the Interior Department essentially ignored the EPA's work entirely in crafting its solar policy for Southwestern public lands is an egregious example of government working at cross-purposes.
Does that mean that every site on the EPA's map has been cleared as just fine for renewables development? Not even a little.
To its credit, the EPA doesn't claim that its map is anything other than a guide to places that have been significantly altered from their most ecologically productive state that might well be considered for renewable energy development. In its FAQ for the RE-Powering America's Land tool, the EPA says:
Is renewable energy the best reuse for contaminated land or a mine site?
Not necessarily. Local communities determine reuse options for contaminated land and mining sites. Individual site characteristics including the extent and level of contamination, site location, community preferences, and the local real estate market will combine to identify the "best" reuse for contaminated land or a mine site. Site-specific analysis is required to determine whether renewable energy development is an appropriate use for contaminated land or a mine site. While renewable energy development is one reuse option, other reuses such as residential, commercial, industrial, agricultural, open space, green space, and natural habitat should also be considered.
It's worth noting that not all contaminated land is created equal. Some brownfields, such as quite a number of sites burdened with unexploded or leaking military munitions can actually be pretty good habitat for wildlife, if only because developers tend to avoid properties where they might get blown up. That doesn't mean the contaminants on munitions sites are of no ecological concern, but it does mean that developing the site with solar just because it's contaminated might not be great for the environment.
Let's consider the example of Critical Habitat for endangered and threatened species. With the mapping help of biologist Dipika Kadaba -- she's been featured on these pages before -- ReWire took a look at some of the sites in the RE-Powering America's Land database in California, and compared those sites to critical habitat that's been designated for a number of protected species by the U.S. Fish and Wildlife Service.
As it turns out, of 9,708 California sites listed in the EPA's database, at least 710 are either wholly or partly included in designated Critical Habitat for endangered or threatened species protected under the federal Endangered Species Act.
Here''s an example of a few such sites in the California desert that infringe on Critical Habitat for three species: the Endangered California Condor, and the Threatened desert tortoise and Pearson's milk-vetch:
The blue dots on the map each represent at least one RE-Powering America's Land sites within Critical Habitat areas -- and in the case of a couple of the dots as many as two dozen adjacent sites or more. (For clarity's sake, we left out the thousands of blue dots that would have fallen entirely outside the habitat areas in question.) Though the EPA's information on acreage of the sites is woefully incomplete, some of them are very extensive indeed.
In fact, one "site" at Fort Irwin is listed as spanning 640,000 acres. That's 1,000 square miles at least partly within critical habitat for the Threatened desert tortoise. Even the most die-hard fan of the EPA's database would be hard-pressed to say that entire site should be considered shovel-ready for renewable energy development.
Fortunately, it's on federal land like BLM holdings and military bases where Critical Habitat designation has the sharpest teeth. Despite right-wing rumors to the contrary, designation of land as Critical Habitat offers almost no protection if the land is privately owned and the developer isn't getting federal funding. EPA's inclusion of sites in tortoise and Pearson's milk-vetch habitat in the desert probably doesn't pose nearly the long-term threat for those places as, say, sites in vernal pool habitat in the San Joaquin Valley might to protected species of fairy shrimp.
The big picture is important. We need to reduce our nation's greenhouse gas footprint as sharply as possible as soon as possible. We need to do so in as environmentally benign a manner as possible. The absolute, number one best first course is and will likely always be cutting down on the amount of energy we use. What we can't conserve, we should try to generate in the already built environment: on rooftops, parking lots, and other such places. Once we have done what we can there, we should turn to medium-sized to utility-scale development in our cities and towns, and preferably on land that's already been paved, and for which local communities don't have other overriding uses.
To that end, the EPA's tool is a valuable one for winnowing through millions of properties to see which demolished factories, landfills, and stripmines might be available and suitable for consideration as renewable energy sites. It's not a slam dunk endorsement. As in most other environmental issues, you need to dig deep and really learn about a site before you condemn it. Making snap judgements just gets you in trouble.
ReWire owes Dipika Kadaba thanks, and a round of drinks, for her assistance on this article.